Stakeholder Engagement Plan

Transcription

1 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector, July 2014

2

3 Abbreviations Abbreviation EEZ EIA ESIA ESMP ESMS IFC IFC PSs MoEW NGO PAC NTS SCD SEP ToR Description Exclusive Economic Zone Environmental Impact Assessment Environmental and Social Impact Assessment Environmental and Social Management Plan Environmental and Social Management System International Finance Corporation IFC Performance Standards Ministry of Environment and Water Non-Governmental Organisation Project Affected Communities Non-Technical Summary Stakeholder and Consultation Database Stakeholder Engagement Plan Terms of Reference URS-EIA-MAN i

4 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Glossary Terms Comment Form Consultation Description A paper form through which stakeholders can submit written comments, views and opinions. Comment forms are distributed at public consultation meetings and made available in locations where EIA/ESIA documentation is disclosed and made available for comments. The process of sharing information, ideas and concerns in a two-way dialogue between project proponents and stakeholders, allowing stakeholders to express their views and for these to be considered in the decisions about project planning and implementation. Disclosure Engagement Environmental and Social Management System Grievance Grievance Procedure Stakeholder The process of publishing and making available information in various ways (such as on the internet, in paper form or in press announcements). General term for activity including both disclosure and consultation. A system to manage the environmental and social risks and impacts of a project s activities. Formal notified complaint by people who feel they have been adversely affected by project-related activities. Process of recording and addressing grievances so that they can be tracked through to a resolution. Any individual or group potentially affected by a project, or which has an interest in, or influence over, a project. ii URS-EIA-MAN

5 Table of Contents Abbreviations... i Glossary... ii Tables... v Figures... v Appendices... vi 1 Introduction Overview Background The South Stream Offshore Pipeline South Stream Transport B.V Environmental and Social Impact Assessment (ESIA) Environmental and Social Management and Monitoring Objectives of Stakeholder Engagement Coordination with South Stream Bulgaria Regulatory Framework Bulgarian Regulatory Requirements Financing Standards and Guidelines Espoo Convention Alignment of Stakeholder Engagement Processes Stakeholder Analysis Local Context Overview Local Communities Other Communities Stakeholder Identification and Mapping Disclosure and Engagement Methods and Materials Project Disclosure Methods Stakeholder Engagement Materials Communication Channels Completed Stakeholder Engagement Project Notification EIA/ESIA Scoping Consultations URS-EIA-MAN iii

6 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector 4.3 Espoo Notification EIA Consultations EIA Decision Interim ESIA Consultation Other Engagement Activities Varna Information Centre Overview of Stakeholders Comments and Suggestions Government Authorities Local Communities Landowners Land Users Marine Area Users Business and Business Associations Community Service and Infrastructure Organisations Non-Governmental Organisations (NGOs) Academic and Research Organisations Inter-governmental organisations Overview of Planned Activities ESIA Consultations ESIA Consultations for the South Stream Offshore Pipeline Post-ESIA Engagement Activities Environmental and Social Management Plan Community Investment Plan Grievance Procedure Disclosure Project Updates Construction & Pre-Commissioning, Operational and Decommissioning Phases Roles and Responsibilities Contact with South Stream Transport Feedback Process Grievance Procedure Overview Grievance Procedure Process Monitoring and Reporting Monitoring Tracking Stakeholder Engagement Activities Project Reporting Stakeholder and Consultation Database iv URS-EIA-MAN

7 Appendices Tables Table 2.1 Engagement Requirements for Bulgarian EIA Process... 6 Table 3.1 Local Communities within the Project s Area of Influence Table 3.2 Stakeholder Categories and Identification Table 3.3 Engagement Materials Produced Table 3.4 Engagement Mechanisms Table 4.1 Summary of Completed Engagement Activities (EIA and ESIA) Table 4.2 Scoping Consultation Meetings Table 4.3 Overview of Interim ESIA Consultations Table 5.1 Anticipated Timing of Planned Stakeholder Engagement Activities Table 5.2 Consultation Programme for Draft ESIA Report Table 5.3 Planned Engagement for ESMP Table 5.4 Anticipated Information Disclosure during the Construction and Pre-Commissioning Phase Table 7.1 Grievance Procedure Process Figures Figure 1.1 Route of the South Stream Offshore Pipeline... 2 Figure 1.2 Project Phases... 3 Figure 2.1 Summary of International Financing Standards and Guidelines on Stakeholder Engagement... 7 Figure 3.1 Map of Local Communities Figure 7.1 Grievance Procedure Flowchart URS-EIA-MAN v

8 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Appendices Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Regulatory Framework of the Republic of Bulgaria for EIA Public Consultation List of Stakeholders Identified Summary of Completed Stakeholder Engagement Activities Summary of Comments and Responses Copies of Public Announcements Comment Form vi URS-EIA-MAN

9 1 Introduction 1.1 Overview This document is the Stakeholder Engagement Plan (SEP) for the South Stream Offshore Pipeline Bulgarian Sector ( the Project ). The SEP is designed to ensure that the Project s plans for engagement with stakeholders during all phases of development of the Project are communicated and understood by all those concerned. The SEP sets out the approach which the Project will follow to implement an engagement programme with stakeholders over the life of the Project. For the purposes of this programme, a stakeholder is defined as any individual or group who is affected by a project or may have an interest in, or influence over, it. The SEP focuses on engagement with external stakeholders. In addition to the stakeholders discussed in this document, there are also a number of internal stakeholders, including Project staff, shareholders and contractors. Although there is on-going engagement with these stakeholders, these processes are not covered in this SEP. The SEP is a living document and is being developed progressively, and updates issued, as the Project moves through the various phases of planning and implementation. This update is intended to coincide with the release of the Environmental and Social Impact Assessment (ESIA) for the Bulgarian Sector of the South Stream Offshore Pipeline. The ESIA Report can be found online at: Further updates will be issued to address later stages of Project development, including the Construction & Pre-commissioning Phase. The SEP is organised as follows: Section 1 provides background information about the South Stream Offshore Pipeline, the ESIA process, the Project proponent (South Stream Transport B.V.), and outlines the objectives of stakeholder engagement; Section 2 outlines the national and international requirements for stakeholder engagement; Section 3 provides an overview of the local context, and describes how stakeholders are identified and the methods and tools used to support engagement; Section 4 summarises stakeholder engagement undertaken to date; Section 5 provides the programme for ongoing and future engagement; Section 6 describes roles, responsibilities and resources for stakeholder engagement; Section 7 explains the ways in which stakeholders can contact South Stream Transport, including the grievance mechanism for the Project; Section 8 describes the monitoring and reporting of stakeholder engagement activities. URS-EIA-MAN

10 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector 1.2 Background The South Stream Offshore Pipeline The South Stream Offshore Pipeline is the offshore component of the South Stream Pipeline System that will transport natural gas from Russia to the countries of Central and South-Eastern Europe. When complete, the entire Pipeline System will extend over more than 2,300 km. It is made up of four 32-inch (813 mm) diameter pipelines extending approximately 930 km across the Black Sea from the Russian coast near Anapa to the Bulgarian coast near Varna (Figure 1.1). When complete, the Pipeline will transport up to 63 billion cubic metres (bcm) of natural gas per year from Russia to Bulgaria. Figure 1.1 Route of the South Stream Offshore Pipeline The Bulgarian Sector (the Project) of the South Stream Offshore Pipeline extends approximately 232 km from the border between the Bulgarian and Turkish EEZs to a coastal location approximately 11 km south of the city of Varna. The majority of the Project lies in the Black Sea (229 km, including 205 km within the Bulgarian EEZ, plus approximately 24 km in Bulgarian territorial waters) and approximately 3 km are onshore. The landfall section of the Project is located within the Varna Municipality, approximately 11 km south of the central areas of Varna. The nearest residential area is the small community of Rakitnika, approximately 2 km north of the landfall. The shore crossing (where the Project will 2 URS-EIA-MAN

11 transition from sea to land) is at Pasha Dere Beach, where an existing pipeline (the Galata Pipeline) also comes ashore. From the shore crossing, the Project extends approximately 3 km inland, where it will be connected to the receiving terminal of the onshore project being developed by South Stream Bulgaria AD (SSB) as part of the South Stream Pipeline System on the Territory of the Republic of Bulgaria. The SSB receiving terminal (and associated compressor station), and the onshore pipelines downstream of the receiving terminal, are not part of the Project and are subject to a separate development and permitting procedure. The Project is being developed in phases, illustrated in Figure 1.2 below. Figure 1.2 Project Phases Feasibility Phase ( ) Assessment of Project options Preliminary engineering design Development Phase ( ) Engineering design EIA and ESIA Construction & Pre-Commissioning Phase ( ) Construction Pre-Commissioning Tests Operational Phase ( ) Ramp-up of gas deliveries Gas deliveries Decommissioning Phase (2065) Closure of pipeline South Stream Transport B.V. South Stream Transport B.V. (South Stream Transport) is an international joint venture established in 2012 to develop and operate the South Stream Offshore Pipeline. The Russian company Gazprom holds a 50% stake in the joint venture. The Italian company Eni S.p.A. has a 20% stake. The French energy company EDF and German company Wintershall Holding GmbH (BASF Group) each hold 15% Environmental and Social Impact Assessment (ESIA) The Project has undertaken an ESIA in accordance with the financing requirements for the South Stream Offshore Pipeline. The ESIA process illustrates South Stream Transport s commitment to develop and operate the South Stream Offshore Pipeline in an environmentally and socially responsible manner. The ESIA Report describes the main characteristics of the Project and the measures that will be implemented to avoid and minimise potential environmental and social impacts. URS-EIA-MAN

12 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector South Stream Transport has also undertaken an Environmental Impact Assessment (EIA) to meet Bulgarian national legislative requirements. EIAs to meet national requirements and ESIAs in accordance with the standards and guidelines of financing organisations have also been undertaken in the other countries through which the Offshore Pipeline passes (i.e. Russia and Turkey) Environmental and Social Management and Monitoring The mitigation measures developed during the EIA and ESIA process feed into the Project s Environmental and Social Management System (ESMS) which includes a number of Environmental and Social Management Plans (ESMP). The ESMP captures the mitigation and management measures and other environmental and social commitments made within the ESIA Report and associated documentation. The ESMP and associated plans will address and manage the environmental and social impacts that are likely to occur as a result of the relevant activities and will be in place throughout the construction and operation of the South Stream Offshore Pipeline. The ESMP will include an overarching Environmental and Social Monitoring Programme for the South Stream Offshore Pipeline which will outline monitoring requirements. Monitoring is required to demonstrate compliance with Bulgarian legal limits and applicable international standards and will provide verification of the overall design and effectiveness of the implemented mitigation and management measures. 1.3 Objectives of Stakeholder Engagement Stakeholder engagement (including consultation and the disclosure of information) is a key element of project planning, development and implementation. Effective stakeholder engagement assists good design, builds strong relationships with local communities and reduces the potential for delays through the early identification of issues to be addressed as a project progresses. South Stream Transport is committed to a transparent and respectful dialogue with stakeholders throughout the life of the Project. The activities of engagement are guided by Good International Industry Practice for ESIA, as well as all applicable laws and regulations in the countries where the Project operates. The aims of stakeholder engagement, outlined in this SEP, are to: promote the development of respectful and open relationships between stakeholders and South Stream Transport; identify Project stakeholders and understand their interests, concerns and influence in relation to Project activities; provide stakeholders with timely information about the Project and the ESIA process, in ways that are appropriate to their interests and needs (taking into account factors such as location, language, culture, access to information) and also appropriate to the level of expected risk and adverse impact; give stakeholders the opportunity, through consultation and other feedback mechanisms, to express their opinions and concerns in relation to the ESIA and Project development, and for 4 URS-EIA-MAN

13 these to be reflected in the ESIA, the Project s Environmental and Social Management System (ESMS), and decisions about Project activities, where possible; support compliance with Bulgarian legislation for public consultation and disclosure for EIA and alignment with financing standards and guidelines for stakeholder engagement for ESIA; and record and resolve any grievances arising from Project-related activities. 1.4 Coordination with South Stream Bulgaria The landfall facilities of the Project will tie-in with the onshore pipeline under development by South Stream Bulgaria AD, approximately 3 km from shore crossing at Pasha Dere Beach. As such, the Project shares a number of stakeholders with the onshore pipeline project, particularly in the Varna and Avren municipalities. South Stream Transport works with South Stream Bulgaria on a variety of issues related to the Project. Stakeholder concerns common to both projects have been identified (including noise and traffic) and the two companies continue to work together to address and respond to these concerns. South Stream Bulgaria submitted the EIA Report for the onshore project in 2013, and public hearings were held in July At the invitation of South Stream Bulgaria, South Stream Transport attended the public hearings in Varna (Varna Municipality) and Priseltsi (Avren Municipality) to answer questions related to the offshore Project and to continue to develop relationships with local stakeholders. Similarly, public hearings for the South Stream Transport Offshore Pipeline Bulgaria Sector were held in December At the invitation of South Stream Transport, South Stream Bulgaria attended the public hearings in Varna (Varna Municipality) and Priseltsi (Avren Municipality) to answer questions related to the onshore Project and continue to develop relationships with local stakeholders. URS-EIA-MAN

14 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector 2 Regulatory Framework This section describes the regulatory framework that applies to the Project. The Project s approach to stakeholder engagement considers both regulatory requirements and principles of Good International Industry Practice (GIIP). 2.1 Bulgarian Regulatory Requirements Stakeholder engagement undertaken as part of the EIA process has adhered to national requirements, as defined by the Environmental Protection Act and related regulations and ordinances. Public consultation is a mandatory part of the EIA process. The competent authority for the EIA process is the Ministry of Environment and Water (MoEW). An overview of the EIA information disclosure and consultation process for the Project is shown in Table 2.1 whereas its regulatory framework is further detailed in Appendix A. Table 2.1 Engagement Requirements for Bulgarian EIA Process Activity What happens Purpose of engagement Notification of Investment Proposal Terms of Reference EIA Report (initial quality check) EIA Report (disclosure and consultation) The Project Notification Document is submitted to the MoEW, and to local authorities. The Terms of Reference for the EIA Report is submitted to the MoEW and disclosed for public review and comment. EIA Report is submitted to the MoEW. EIA Report is publicly disclosed for review and comment. Public hearings are held in affected municipalities. Inform the government stakeholders of the proposed Project, including its location and scope, identify potentially affected municipalities. The EIA process officially begins. Provide stakeholders with a description of the Project and the opportunity to comment. Feedback is used to determine structure and scope of the EIA. MoEW accepts or asks for modification to the EIA Report. Once the report is accepted, it is disclosed to other stakeholders. Provide stakeholders with a description of the Project and an assessment of its impacts. Stakeholders have an opportunity to review and comment. Feedback of the consultation is used by the Authorities to give their final decision on the ESIA. 6 URS-EIA-MAN

15 2.2 Financing Standards and Guidelines The financing standards and guidelines with which South Stream Transport will align are: The Common Approaches to Environmental and Social Due Diligence developed by the Organisation for Economic Cooperation and Development (OECD); The Equator Principles (EP), a credit risk management framework for determining, assessing and managing environmental and social risk in project finance transactions. Principle 5 sets out guidance for stakeholder engagement; and The Performance Standards (PS) of the International Finance Corporation (IFC) (part of the World Bank Group). PS 1, regarding the assessment and management of environmental and social risks and impacts, includes guidance for stakeholder engagement. These standards and guidelines all adopt a similar approach to stakeholder engagement. They underscore the importance of stakeholder engagement in building constructive relationships that are essential for environmental and social issues to be managed successfully. The main points common to all are summarised in Figure 2.1. Figure 2.1 Summary of International Financing Standards and Guidelines on Stakeholder Engagement Consultation Consult stakeholders about issues that may affect them, take their views taken into account in the ESIA process, and respond to questions and concerns in general Tailor so that it meets stakeholders' needs and interests, including vulnerable groups Disclosure Disclose and disseminate, in a timely way and in understandable language, relevant, understandable information about environmental and social issues. Extent and type of disclosure should be commensurate with project risks and impacts Grievance Resolution Put in place a transparent and fair mechanism, at no cost to stakeholder, to record and resolve community grievances Project Management Establish an Environmental and Social Management System to manage environmental and social issues Develop a Stakeholder Engagement Plan 2.3 Espoo Convention South Stream Transport also seeks to align with international conventions relevant to stakeholder engagement including the United Nations Convention on Environmental Impact Assessment in a URS-EIA-MAN

16 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Transboundary Context (Espoo, 1991). This sets out the obligations of signatory countries to assess the environmental impact of certain activities at an early stage of planning and lays down their general obligation to notify and consult each other on all major projects under consideration that are likely to have a significant adverse environmental impact across boundaries. Consultations related to Espoo is summarized in Section 4 of this SEP and further described in the EIA and ESIA Reports for the Bulgarian Sector of the South Stream Offshore Pipeline. 2.4 Alignment of Stakeholder Engagement Processes The objectives of stakeholder engagement under the EIA and ESIA processes are similar namely, to ensure that stakeholders are informed of, and have input into, project development and planning. To reduce stakeholder fatigue and potential confusion associated with two separate processes (EIA and ESIA), the processes have been aligned as much as possible. One of the most evident alignment activities was the development of the Scoping Report, which served as both the Terms of Reference for the EIA Report (under national requirements), and the scoping document for the ESIA. As the requirements for these documents were similar, one document was produced to fulfil the requirements for both processes. This document is referred to as the Scoping Report throughout this SEP. It was disclosed to the public, and served as the basis for both statutory consultations with national authorities, and public disclosure. This document, and the associated feedback from stakeholders, provided the foundation for the EIA Report and the ESIA Report. Following scoping, the EIA process in Bulgaria progressed ahead of the ESIA. Nonetheless, comments received through the EIA and ESIA processes have been considered in the overall development of the Project. Feedback received through the EIA process has been included in the ESIA documentation. 8 URS-EIA-MAN

17 3 Stakeholder Analysis For stakeholder engagement to be effective, it should be inclusive it is necessary to determine who the stakeholders are, to understand their needs and expectations for engagement, and their priorities and objectives in relation to the Project. This information is then used to tailor engagement to each type of stakeholder. Section 3.1 provides an overview of the area and communities in the vicinity of the Project. Section 3.2 explains how stakeholders, including vulnerable groups, are identified and lists the stakeholder groups identified to date. Section 3.3 describes how this analysis is used to develop tools and materials to engage stakeholders in ways appropriate to their needs and wishes. 3.1 Local Context Overview In Bulgaria, the Project is located in the Varna Municipality, a short distance north of the border with the Avren Municipality (Figure 3.1). Both municipalities are located within the Varna Region. Municipalities are the principal administrative unit of local government, and may be further subdivided into mayoralty units on the discretion of the municipal council. Within Varna Municipality, the Project is located within the Asparuhovo Mayoralty. The Mayor of Asparuhovo is an elected position under the Mayor of Varna with jurisdiction over specific local services. Many of the communities in the vicinity of the Project are located within the Asparuhovo Mayoralty, including Asparuhovo, Galata, Zelenika, Prijboj, Fichoza, Rakitnika, Borovets, and Kantara (an agricultural area adjacent to Borovets). These communities are all largely considered to be suburban areas of the city of Varna, and include a mix of permanent residences (where residents may commute to the city for work), and weekend or holiday homes (particularly in the settlements along the coast). The largest of these communities are Asparuhovo (population c. 20,000), and Borovets (c. 13,000); the others range from around 500 to 2,500 people. All of these communities are within approximately 10 km south of the city of Varna (i.e. south of Varna Bay). Rakitnika is the closest settlement to the Project, approximately 2 km north of the landfall. In Avren Municipality, the Project is located within the jurisdiction of the Priseltsi Mayoralty, which includes the communities of Priseltsi and Priseltsi VZ 1 (also known locally as Krushkite). Priseltsi is located on the main highway linking Varna and Burgas, south of the turnoff to the Project landfall, and has a population of approximately 1,165. Krushkite is the closest community to landfall facilities and access road; road traffic to the landfall facilities will use a section of the road leading to Krushkite. 1 VZ stands for villa zone. These communities are typically more rural and have lower levels of municipal services/infrastructure. URS-EIA-MAN

18 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Figure 3.1 Map of Local Communities Local Communities Local Communities, which are defined as populations which have the greatest potential to be impacted (positively or negatively) by the Project are a priority for both stakeholder engagement and the assessment of potential socio-economic, health, and other impacts. For the purposes of the SEP, these communities are referred to as Local Communities, which are defined as communities that are the closest communities to the Project Area. In the case of the city of Varna (i.e. the central urban area of the municipality) it is also considered to be a Local Community due to its role as the main supply and service centre in the region, and due to the potential for possible impacts associated with workforce accommodation and the marshalling yards. However, the community of Avren is not considered to be a Local Community due to its distance from the Project. The city of Burgas was not considered to be a Local Community during the ESIA process as due to the assumption that activities in Burgas would be limited to the use of existing port facilities. However, engagement was carried out with stakeholders in Burgas in Q due to the decision to locate a Quad Jointing Facility on a moored vessel operating in Burgas Port which was taken by the Construction Contractor (see Section 4.7). Table 3.1 summarises the Local Communities in Bulgaria. 10 URS-EIA-MAN

19 Table 3.1 Local Communities within the Project s Area of Influence Local Community Municipality of Varna Estimated Population Approximate distance From landfall facilities From pipeline alignment City of Varna 344, Km 11 Km Asparuhovo 20,000 7 Km 7 Km Galata and Zelenika 2,500 6 km 5 km Priboj and Fichoza 1,000 4 km 2.5 km Rakitnika km 2.4 km Borovets (incl. Kantara) 13,000 3 km 1 km (from Kantara) 3 km (from Borovets) Municipality of Avren Priseltsi 1,165 5 km 5 km Krushkite <100* 3 km 3 km * Included in Priseltsi but permanent population estimated to be less than 100 people. Krushkite is also known as Priseltsi VZ. Within and surrounding the Local Communities, a number of specific areas of interest are also identified, including: Pasha Dere Beach, where the Project comes ashore; the Chernomorets Tourist Resort, on Chernomorets Beach (one beach north of Pasha Dere Beach); the Ada Bacha fishing community, at the north end of Chernomorets Beach; and various scattered residences around Chernomorets Beach, the Kantara agricultural area, and south of Krushkite. These areas have been treated similarly to the Local Communities in terms of stakeholder engagement and impact assessment Other Communities The Project also interacts with other communities in Bulgaria which have not been designated as Local Communities for the purposes of the EIA and stakeholder engagement processes. Most notably, the municipal centres of Avren is not considered to be Local Community, although the relevant authorities are consulted as needed. The community of Avren is the administrative head URS-EIA-MAN

20 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector of the Avren Municipality. As described above, distinct communities within these municipalities are considered as Local Communities depending on their proximity to the Project and access roads. The ports at Varna West (in Beloslav Muncipality) and Burgas may be used for marshalling yards, in addition to the port facilities at Varna East (i.e. centrally located in the city of Varna). However, these areas are currently developed and operating as industrial ports. No new land development is anticipated and Project activities will be consistent with existing port activities. As such, the communities of Burgas and Beloslav are not considered to be Local Communities. 3.2 Stakeholder Identification and Mapping As part of the stakeholder identification process, it is important to include individuals and groups who may find it more difficult to participate in engagement and those who may be differentially or disproportionately affected by the Project because of their marginalised or vulnerable status. It is also important to understand how each stakeholder may be affected, or perceives they may be affected, so that engagement can be tailored to inform them and understand their views and concerns in an appropriate manner. The appropriate type of engagement is determined by a number of factors, including the likely impact of the project on the stakeholder (often related to location) their influence over the project, as well as stakeholders preferences and abilities to access information and participate in consultation. Stakeholders for the Project have been identified in several ways. These include: Drawing on the local knowledge of in-country environmental and social consultants; Feedback from consultations with stakeholders held to date; Desktop research including reviews of previous ESIAs for relevant (by type or location) previous projects; and Observations made during field visits to local communities in the Project area. The process of engaging stakeholders helps to identify further stakeholders as the Project develops. A list of stakeholders can be found in Appendix B It is helpful to group stakeholders based on common interests and characteristics. As such, South Stream Transport uses a number of stakeholder categories to help structure activities for stakeholders of the Project. These stakeholder categories are described in Table 3.2 Stakeholder Categories including a summary of the anticipated interest of these groups with respect to the Project (e.g. potential impacts, benefits, concerns) and how these groups have been engaged to date. 12 URS-EIA-MAN

21 Table 3.2 Stakeholder Categories and Identification Interest in the Project Stakeholders Identified Summary of Engagement to Date Land Owners The Project may require some temporary and/or permanent acquisition of land, which will require agreements with applicable landowners. Additionally, some landowners in the vicinity of the Project may be affected by Project activities, including changes to viewscapes or environmental conditions. Ministry Of Agriculture, Varna Municipality, Executive Forest Agency and local private owners. South Stream Transport has engaged with the Ministry of Agriculture and other state agencies who own the majority of the land affected by the Project. Affected private landowners have also been engaged. South Stream Transport is negotiating land purchase and/or use agreements with the applicable landowners in accordance with the Land Acquisition Plan. Land Users The Project may require some temporary and/or permanent acquisition of land, and as such may affect access to these areas. People who work on or use areas affected by Project land take may also be affected by access restrictions. Additionally, project activities may result in changes to the amenity of certain areas, such as changes to viewscapes or environmental conditions. Hunters and recreational visitors to Pasha Dere Beach and the landfall section. Engagement with land users has involved public disclosure of project documentation (including the ESIA Scoping Report, and draft EIA Report), via the South Stream Transport website, announcements in newspapers and poster campaigns. These reports have been accompanied by public comment periods and public meetings. Specific engagement has also been undertaken with the Varna Hunting and Fishing Association and the Galata Hunting Club to understand how they use the landfall section of the Project. Although no organised group of beach users has been identified, a number of people who use the beach have provided comments and engaged with the South Stream Transport since the Scoping Stage. General Public (including residents of, and visitors to, the Local Communities) Local Communities may be affected by impacts related to traffic, noise, and environmental changes, as well as changes to land use and access (including the beach and surrounding forest). They may also be able to benefit through employment and business opportunities, or local improvements such as gas supply. Residents of Local Communities (Varna, Asparuhovo, Galata-Zelenika, Priboj-Fichoza, Borovets (including Kantara), Rakitnika, Priseltsi and Priseltsi VZ) and tourists / visitors to these Local Communities. The general public has been engaged through a variety of public disclosure and consultation measures. This has included the publication of project documentation (including the Scoping Report, and draft EIA Report), via the South Stream Transport website, announcements in newspapers and poster campaigns. These reports have been accompanied by public comment periods and public meetings.

22 Interest in the Project Stakeholders Identified Summary of Engagement to Date Businesses and Business Associations Local businesses may benefit from procurement opportunities related to the provision of goods and services to the Project. Conversely, other businesses may be concerned about potential impacts on business revenues, particularly in relation to the tourism sector. Construction-related businesses and related support services (e.g. catering, security, accommodation, environmental management). Varna s Chamber of Commerce and Industry, Chamber of Tourism, Varna Employment Office and Varna Regional Labour Office. Port and related industry in Varna and Burgas and ship repair company Association Odessos. Businesses and business associations were engaged during the Scoping Stage in a roundtable meeting in February 2013 to establish any potential for perceived impacts or interest in the Project among this stakeholder group. Subsequent meetings have been held with the Chamber of Commerce and Industry, and the Chamber of Tourism, as well as local service offices in Varna. Marine Area Users Fishermen and fisheries organisations (including fishing businesses) may be interested in potential project impacts on fishing activities and livelihoods, including access to fishing areas and changes in fish health, migration and catch volumes. They could also be concerned about unplanned events (e.g. fuel spills) and how these events could affect fishing activities. Businesses, clubs or other groups that use the sea for recreation may be interested in their continued access to these activities, as well as any environmental changes that may arise from the Project. Local artisanal fishermen in the Ada Bacha Fishing Community, Association BG Fish and other commercial fishing companies. Diving and sailing clubs / businesses in Varna. Fishing organisations were notified of the publication of the Scoping Report (and were provided with a copy of the report) and invited to a roundtable meeting for marine area users and local businesses. Specific meetings were also held with the Ada Bacha fishing community to gather baseline information for the Fishing Study (see Appendix 15.1: South Stream Offshore Pipeline Fisheries Study) and to understand the concerns of fishers in relation to the Project. The main issues of concern have related to restrictions to access due to the Project s safety exclusion zones, and impacts on the marine environment. Diving and recreational boat clubs were notified of publication of the Scoping Report and invited (by letter and phone) to a roundtable meeting for marine area users and local businesses. They were also notified about the disclosure of the draft EIA Report and related consultation. Offshore oil-and-gas exploration companies also have an interest in accessing and using the marine area. Petroceltic International Plc and OMV. Meetings and exchanges of information and data took place regarding the proposed Pipeline route and coordination of activities between the Project and oil and gas exploration and shipping / port companies.

23 Interest in the Project Stakeholders Identified Summary of Engagement to Date Government Authorities National authorities have an interest in the national EIA and permitting procedures, particularly in terms of ensuring compliance with Bulgarian regulations. In addition to their regulatory role, government departments have specific interests in topic areas such as cultural heritage, transport and fisheries. Bulgarian national authorities including the MoEW, Ministry of Culture and Ministry of Health. National authorities are informed and consulted as part of the ESIA process, although formal engagement with the authorities is covered by the national EIA process. Engagement with various government departments responsible for specific topics of interest has been ongoing through the EIA, ESIA and permitting processes. Local and regional authorities have a general interest in the potential impacts and benefits for their respective communities. Varna Region, Varna Municipality, Avren Municipality, Asparuhovo Mayoralty, and Priseltsi Mayoralty. Regional environmental agencies such as the Regional Inspectorates of Environment and Water, Black Sea Basin Directorate: Varna, Executive Forest Agency and others. Local and regional authorities have been engaged throughout the course of the Project, as part of both the EIA and ESIA processes. Local authorities have also been interviewed as part of the socio-economic baseline data collection and to further discuss potential mitigation measures. Community Service and Infrastructure Organisations Community service and infrastructure providers are interested in how the Project might impact on community services and infrastructure development plans. This may include direct impacts (e.g. on road infrastructure or water mains) or indirect impacts (e.g. increased strain on local services due to use by Project workforce) Vik-Varna (Varna water and sewerage company), Varna Police, Department of Social Welfare (Varna Municipality), local high schools, cultural centres and pensioner clubs. Bulgarian Ministry of Health and National Commission for Combating Trafficking in Human Beings (Varna Branch). Engagement with community service and infrastructure organisations has involved public disclosure of project documentation (including the ESIA Scoping Report, and draft EIA Report), via the South Stream Transport website, announcements in newspapers and poster campaigns. These reports have been accompanied by public comment periods and public meetings. Individual meetings were also held with these stakeholders to gather socio-economic and health baseline information and seek feedback.

24 Interest in the Project Stakeholders Identified Summary of Engagement to Date Non-Governmental Organisations NGOs (including local, national and international NGOs, as well as other community based organisations) may be interested in a diverse set of issues, ranging from protection of the Black Sea ecology, to archaeological assets, to potential impacts on tourism and other industries. NGOs are often interested in reviewing and commenting on EIA and ESIA documents, particularly in regard to the identification of environmental and social impacts and the ways that these impacts will be mitigated and managed. Local and regional NGOs interested in environmental protection and ecosystems such as Black Sea NGO Network, Green Policy Institute, Maritime Club, Friends of the Sea and Bulgarian Society for the Protection of Birds. NGOs were engaged during the Scoping Stage with invitations to review and comment on the Scoping Report, and to participate in meetings. They were also notified and invited to comment on the draft EIA Report. NGOs identified to date have included those with a particular interest in the marine ecology and environmental protection of the Black Sea, as well as the protection of cultural heritage assets. NGOs were also interested in the political situation and risks, and the cost of construction of the Pipeline. Academic and Research Organisations Academic and research organisations may be interested in data from the Project s numerous marine surveys, as well as the potential effects on the marine environment or ecology, marine cultural heritage and environmental protection. Institute for Marine Research (Oceanology Institute), Institute of Fisheries Resources. Research institutes and university departments with a particular interest in issues pertaining to archaeology, the environment and the Black Sea were engaged during the Scoping Stage. Following Scoping, these stakeholders have been engaged for socio-economic and cultural heritage baseline data, particularly on Cultural Heritage Objects, Media Journalists and other representatives of the media are often interested in ensuring that clear and transparent information about the Project is communicated to the national population. Interested in general Project information including updates on the EIA and ESIA process. Bulgarian media at national, regional and local levels. Engagement with the media has occurred through press releases, announcements, interviews and press conferences during key disclosure events, such as the publication of EIA and ESIA documentation. Local media have also been engaged in response to local issues and current events, and on specific topics of interest to the Local Communities.

25 Vulnerable Groups Stakeholder identification and engagement also seeks to identify any potentially vulnerable or disadvantaged individuals and groups in local communities. Vulnerable groups are those who may be differently or disproportionately affected by the Project, or whose situation may mean that special care is needed to engage them in consultation and disclosure activities (e.g. in terms of language, literacy, technology, etc.). South Stream Transport has identified a number of potentially vulnerable groups for the Project, including children, elderly people, disabled and chronically ill people, individuals/households with incomes below the official subsistence level, commercial sex workers, and the Roma minority group. Where relevant, differential impacts on these groups have been considered in the impact assessment (e.g. impacts related to community health and safety). Other potentially vulnerable groups have also been considered, including women and other ethnic minorities. However, considering the socio-economic characteristics of the communities including the prevalence of these groups in the local communities, and the lack of evident vulnerability factors in terms of access to resources or representation these groups are not considered to be vulnerable in the context of the Project. South Stream Transport has also considered the needs of all potentially interested stakeholders, including those for whom special care in consultation may be needed, through the stakeholder engagement process. Efforts have been made to disclose information in a variety of ways so as to be accessible to all groups, regardless of socio-economic or other status. For example, printed copies of reports have been provided in central community locations, in addition to on the internet; announcements have been made in local, regional and national newspapers, and through posters in local shops, offices, bus stops, and other community locations; information has been hand-delivered to schools and pensioner groups; and open meetings have been held in Local Communities. All documents have been provided in Bulgarian. 3.3 Disclosure and Engagement Methods and Materials South Stream Transport employs a range of methods and channels for disclosing information in order to tailor disclosure to the interests and needs of the various stakeholder groups, and also produces materials appropriate for specific stakeholders and types of engagement. The engagement process encourages meaningful participation by stakeholders. The stakeholder engagement process includes two-way targeted engagement related to specific potential Project impacts, for example traffic, road use, and human trafficking. Impact assessment studies to date have shown that after the implementation of design controls, management and mitigation measures the majority of the residual environmental and social impacts of the Project are assessed to be of low or no significance; however, engagement activities will continue to be organised around specific topics of interest and known concerns of stakeholders Project Disclosure Methods Information about the Project may be disclosed in several ways: via the internet (publication of reports, ), in printed form (reports, letters, leaflets); in person in face-to-face meetings and telephone conversations. Project documentation is published in Bulgarian (and English as URS-EIA-MAN

26 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector appropriate). Translation and interpretation services are provided by South Stream Transport as needed. Disclosure of relevant project information, including project description; purpose, nature, and scale of the project; duration of proposed project activities; any risks to and potential impacts on Local Communities and relevant mitigation measures; and stakeholder engagement and grievance mechanism processes helps Local Communities and other stakeholders understand the risks, impacts and opportunities of the Project Stakeholder Engagement Materials Materials supporting stakeholder engagement include printed information in the form of leaflets and posters as well as documents that form the focus of disclosure and consultation activities, including the Terms of Reference for the EIA Report, the EIA Report, the Scoping Report and the ESIA Report. South Stream Transport also publishes Project documents and other information online at Other materials are developed to support consultation meetings, including presentations, posters and banners illustrating aspects of the Project and the ESIA process. The engagement materials produced are listed in Table 3.3. Table 3.3 Engagement Materials Produced Type Documents disclosed as part of the EIA process Documents disclosed as part of the ESIA process Supporting materials Details Scoping Report Non-Technical Summary of the Scoping Report Draft EIA Report Non-Technical Summary of the EIA Report Scoping Report Stakeholder Engagement Plan Non-Technical Summary of Scoping Report Draft ESIA report* Non-Technical Summary of Draft ESIA report* Environmental and Social Overview Report* Final ESIA Report* Project description leaflets (distributed at meetings and in communities) Project ESIA leaflets (distributed at meetings and in communities) Project updates published on South Stream Transport website and in print Posters and banners displayed at meetings Presentations used in meetings *Upcoming activity. The Scoping Report was used to support the national EIA process (as the Terms of Reference for the EIA Report), as well as the international ESIA process (as a scoping document for stakeholder engagement). The same Non-Technical Summary of the Scoping Report was also used for both processes Communication Channels Feedback mechanisms are adapted to suit the needs and preferences of the many different stakeholders, as well as their location. They range from comment boxes, which are used in local communities to gather feedback in written form, to web-based mechanisms that can gather feedback from all over the world. 18 URS-EIA-MAN

27 The different disclosure methods, materials and communication channels used to engage stakeholders are shown in Table 3.4. The information disclosed by these mechanisms includes all published information (including EIA and ESIA documents, non-technical summaries, and Project leaflets) as well as updated information between publications. Table 3.4 Engagement Mechanisms Stakeholder Category Disclosure Methods Communication Channels All stakeholders Residents of local communities Landowners Land users Fisheries and Marine area users South Stream Transport website Paper copies of documents made available in central community locations (e.g. town halls, cultural centres) Relevant information sent directly to affected landowners Paper copies of documents made available in central community locations (e.g. town halls, cultural centres. Notifications, key documents and invitations to meet with South Stream Transport have also been addressed to specific stakeholders. , telephone, and post , telephone, post and in person Secure comment boxes Community meetings and public hearings , telephone, post and in person Meetings and correspondence with South Stream Transport , telephone, post and in person Secure comment boxes Community meetings and public hearings Private and roundtable meetings with South Stream Transport Government authorities Inter-governmental organisations Non-governmental organisations (NGOs) Notifications, key documents and invitations to meet with South Stream Transport have been addressed to specific stakeholders. Notifications, key documents and invitations to meet with South Stream Transport have been addressed to specific stakeholders. Notifications, key documents and invitations to meet with South Stream Transport have been addressed to specific stakeholders. , telephone, post and in person Meetings and correspondence with South Stream Transport , telephone, post and in person Meetings and correspondence with South Stream Transport , telephone, post and in person Meetings and correspondence with South Stream Transport URS-EIA-MAN

28 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Stakeholder Category Disclosure Methods Communication Channels Community Service and Infrastructure Organisations Business and business associations Academic and scientific organisations Media Notifications, key documents and invitations to meet with South Stream Transport have also been addressed to specific stakeholders. Notifications, key documents and invitations to meet with South Stream Transport have also been addressed to specific stakeholders. Notifications, key documents and invitations to meet with South Stream Transport have also been addressed to specific stakeholders. Press releases and media interviews regarding Project updates and disclosure periods. , telephone, post and in person Meetings and correspondence with South Stream Transport , telephone, post and in person Meetings and correspondence with South Stream Transport , telephone, post and in person Meetings and correspondence with South Stream Transport Media contacts In addition, South Stream Transport has established an Information Centre in Varna. The Information Centre is an important communication channel for the Project. South Stream Transport personnel are available two days per week to respond to questions about the Project and direct people to information contained in Project reports and documents such as EIA and ESIA reports, NTS, and other Project brochures. More information on the Information Centre see section URS-EIA-MAN

29 4 Completed Stakeholder Engagement Stakeholder engagement in Bulgaria began in June 2012 with the official Notification of the Investment Proposal. Since then, South Stream Transport has carried out a series of formal and informal engagements to gather feedback and information for both the EIA and the ESIA processes. The primary consultation activities are summarised below in Table 4.1, whilst a fuller list of consultations held to date is contained in Appendix C. Please note that as a forward-looking plan, this SEP does not provide extensive detail on past engagement activities; instead, this information can be found in the Appendices and relevant chapters of the EIA and ESIA reports. Table 4.1 Summary of Completed Engagement Activities (EIA and ESIA) Event Date Engagement Notification of Investment Publication of the EIA and ESIA Scoping Report June 2012 January- February 2013 Notification Document was sent to MoEW, regional authorities, and municipalities. The EIA procedure was subsequently initiated. Scoping Report supported the EIA process (as the Terms of Reference for the EIA Report) and the ESIA process. Scoping Report, including a Non-Technical Summary (NTS), was publicly disclosed on 25 January 2013 and was available for public comment for 30 days. Disclosure included an announcement in two local newspapers, a press release, and publication of the report on the South Stream Transport website. Printed and bound copies of the Scoping Report and NTS were available in the Galata Cultural Centre and the Priseltsi Mayoralty office, along with comment boxes and comment forms. Copies were also distributed to stakeholders, including NGOs, pensioner groups, and local schools. Meetings with statutory stakeholders (identified by the MoEW) were held in January Meetings with other stakeholders, including community meetings in Galata and Priseltsi, were held in February Posters announcing the community meetings were displayed in shops and public spaces, as well as at Pasha Dere Beach and Ada Bacha. Espoo notification Publication of draft EIA Report January- February 2013 November- December 2013 Submission of transboundary information to Bulgarian authorities for the purposes of initiating international procedures under the Espoo Convention. Announcement of the EIA disclosure and consultation period published in two local newspapers on 18 Nov A reminder of the Public Hearings was published in the same newspapers on 18 Dec and broadcasted on local radio on 17 and 18 Dec Printed and bound copies of the EIA Report provided to local authorities for public access in the offices of the Municipality of Varna, Mayoralty of Asparuhovo, Mayoralty of Priseltsi and Municipality of Avren, along with comment boxes and comment forms. The EIA Report URS-EIA-MAN

30 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Event Date Engagement was also available for public access at the RIEW in Varna and the MoEW in Sofia. Invitation to the EIA Public Hearings with link to the online digital copies was also sent by to many stakeholders. Public hearings on the EIA Report were held in Varna and Priseltsi on 19 and 20 December respectively. Official stakeholder comment period until 27 Dec However comments were accepted by SSTTBV until 10 January 2014 and forwarded to the MOEW. EIA and ESIA Baseline studies Final EIA Decision Publication of the Stakeholder Engagement Plan 2012 to 2014 February 2014 February 2014 Engagement with various stakeholders for the purposes of collecting and ground-truthing baseline information and discussing potential impacts and mitigation. MoEW approved the EIA Report and published the announcement on their website. A statement on South Stream Transport s website announced the approval of the EIA Report. The SEP was published on the South Stream Transport website. Interim ESIA engagement EIA and Permitting February June ongoing Project updates meetings with local administrations to discuss Project developments, local employment and ESIA disclosure and consultation planning. Engagement with various government stakeholders to discuss permitting requirements and processes and provide updates regarding Project development. The following sections provide further details on the stakeholder engagement activities which have taken place to date. 4.1 Project Notification In June 2012, South Stream Transport formally initiated the national EIA procedure for the Project by notifying the Bulgarian authorities, via the MoEW, of its investment proposal. The Project Notification Document was also submitted to the Governor of the Varna Region and the Mayor of the Municipality of Varna. Project Notification was also communicated to other stakeholders, including the public, with an announcement in two local newspapers in the Varna Region ( Cherno More and Narodno Delo ). The Municipality of Avren was later notified (in October 2012) when the design of the Project had progressed and indicated that potential access routes would pass through this municipality. 22 URS-EIA-MAN

31 4.2 EIA/ESIA Scoping Consultations As the requirements for the content of the EIA Terms of Reference document in Bulgaria are similar to the nature and content of the Scoping Report for the ESIA, a single document was developed to meet the needs of both the national and international processes. This document is referred to as the Scoping Report. The MoEW undertook an initial review of the Scoping Report and advised that South Stream Transport should consult on the content of the report with the following statutory stakeholders: the Ministry of Health; the Regional Inspectorate of Environment and Water (RIEW, Varna Region); the Black Sea Basin Directorate; and the water supply and sanitation utility in Varna (ViK-Varna). South Stream Transport met with these stakeholders in January 2013 to gather comments and feedback on the Scoping Report and the proposed offshore Project. On 25 January 2013, the Scoping Report (including a Non-Technical Summary (NTS)) was publicly disclosed in a number of ways, summarised in Table 4.1. Stakeholders also had the opportunity to attend scoping consultation meetings for the EIA and ESIA Scoping in February Meetings included two open-house community meetings (in Galata and Priseltsi) and four roundtable meetings with specific stakeholder groups in Varna (clustered to their potential interest in the Project). These meetings are summarised in Table 4.2. The community meetings were held in the early evening to maximise the opportunities for both working and non-working people to participate. The meetings were advertised in local newspapers and through posters in local communities. Invitation letters were also delivered to key stakeholders such as local officials, schools, pensioner groups and cultural centres, and those invited to the roundtable meetings. Table 4.2 Scoping Consultation Meetings Meeting Stakeholders invited Date Location Roundtable Meetings Local Authorities Local Businesses and Marine Area Users Marine Authorities Representatives of local and regional government and governmental agencies Representatives of local and regional businesses, including scuba diving operators and other businesses using the marine area Representative of marine authorities including the Maritime Administration and Navy 5 Feb 2013 Varna 5 Feb 2013 Varna 6 Feb 2013 Varna NGOs Representatives of local and regional NGOs 7 Feb 2013 Varna URS-EIA-MAN

32 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Meeting Stakeholders invited Date Location Community Meetings* Local Communities Public meeting for residents of Varna Municipality 6 Feb 2013 Galata Local Communities Public meeting for residents of Avren Municipality 7 Feb 2013 Priseltsi * For all community meetings community representatives, including local government and other leaders, were invited to participate. These events were announced in local newspapers and with posters in the communities. Visual and printed materials were made available to support the presentations and discussion, as well as leaflets describing the Project and the EIA and ESIA processes. Copies of the Scoping Report and its Non-Technical Summary were distributed to stakeholders. At the meetings, there were also visual displays illustrating various aspects of the Project and the EIA/ESIA processes. Translation was provided (Bulgarian/English) where necessary. Stakeholders were invited to provide comments and suggestions, both in the meeting itself and via comment forms that were issued to all participants. Participants also had the opportunity to speak individually with representatives of South Stream Transport and EIA/ESIA consultants after the question and answer sessions were finished. Summaries of all meetings were documented by South Stream Transport and are stored in the Stakeholder Consultation Database (described further in Section 8). Appendix C provides a summary of stakeholder engagement activities to date, including meetings, letters, public announcements, and other communications. Appendix E provides copies of the public announcements regarding the publication of the Scoping Report and the EIA. 4.3 Espoo Notification The Espoo Notification Form for the Project was submitted to the Republic of Bulgaria (via the MoEW) on 1 February This document contained information about the potential transboundary impacts of the Project, and was provided to support the Government of Bulgaria in the government-led Espoo consultation process. The Republic of Bulgaria officially notified the Republic of Romania on the Project by sending an Espoo Notification to the Romanian Ministry of Environment and Forest, supported by additional information, in February After reviewing the documentation Romania decided not to participate in the EIA procedure in a transboundary context and informed Bulgaria about its decision. The MoEW provided South Stream Transport with an official response to Espoo Notification on 28 May Further information on the procedure and the materials is available on the MoEW s website: EIA Consultations Following the initial quality check by the MoEW, the EIA Report was disclosed on 18 November 2013 for public review and comment, for a period of 30 days minimum. An announcement marking the start of the EIA disclosure and consultation period was published in two newspapers on 18 November Another reminder announcement was published in the same newspapers 24 URS-EIA-MAN

33 on 18 December A radio announcement of the Public Hearings was also broadcast on 17 and 18 December Printed and bound copies of the EIA Report were provided to the relevant local authorities and were available for public access; comment boxes and comment forms were also provided at these locations. The EIA Report and supporting materials were available in: The office of the Municipality of Varna; The office of the Mayoralty of Asparuhovo; The office of the Mayoralty of Priseltsi; and The office of the Municipality of Avren. Digital copies were also provided directly to a number of the stakeholders identified to date. In addition to submitting comments in person at meetings or via the comment boxes, or to the authorities listed above, stakeholders could also submit comments to South Stream Transport by post, or by telephone. Public hearings were organised in consultation with the MoEW and took place in Varna and Priseltsi on 19 and 20 December, respectively. Following the public hearings, under Bulgarian legislation, stakeholders had seven days to submit any final comments (i.e. until 27 December 2013). However, as this seven day period coincided with the Bulgarian annual holiday period, South Stream Transport announced that they would accept comments until 10 January 2014, and that all written comments (with accompanying responses) received in this period would be provided to the MoEW. The official minutes of the public hearings and any written statements or comments provided at the hearings were also provided to the MoEW in accordance with Bulgarian legislation. The same set of minutes, comments and responses were also provided to the municipalities of Varna and Avren. All responses to individual s written comments were also directly addressed to the stakeholders themselves. Chapter 6 of the ESIA provides a summary of the comments and issues raised by stakeholders and how the Project responded to these. 4.5 EIA Decision The MoEW provides a decision on the EIA based on a decision of the Supreme Environmental Council within 45 days after the last Public Hearing. This meeting took place on 24 January The MoEW submitted an EIA approval decision to South Stream Transport and published the announcement on their website on 7 February This information was also published on South Stream Transport s website. Stakeholders had 14 days to appeal the decision of the EIA under the Administrative Code (Art. 99 (6) EPA). The legal provisions for public consultation and disclosure for the national EIA process end with the final submission of written comments from stakeholders on the EIA Report seven days after the public hearings. However, stakeholder engagement goes beyond EIA (and ESIA) disclosure and consultation and continues throughout the Construction and Pre-Commissioning, Operational and Decommissioning phases of the Project as described below and in Section 5.5. URS-EIA-MAN

34 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector 4.6 Interim ESIA Consultation Interim stakeholder engagement was undertaken in first half of 2014 in order to update key stakeholders on Project developments. Meetings were organised with key local authorities, employment agencies and NGOs representing vulnerable groups to give updates on the Project, discuss how stakeholder feedback has been addressed, and optimise the development of mitigation and management measures. Some meeting also focussed on ways to promote local employment and procurement by the Project Construction Contractor. Some of these meetings also served as a means to elicit preferences for the upcoming ESIA disclosure consultations and the ways to make the ESIA Report accessible to local communities. In several meetings, proposals for community investment were also raised. At the time of writing, stakeholder engagement for the EIA Report has been completed (May 2013), and engagement related to the disclosure of the ESIA Report is planned for early Q3 of Table 4.3 Overview of Interim ESIA Consultations Activity Anticipated Date Meeting(s) regarding onshore and offshore cultural heritage survey activities and regarding forest and replanting issues Meeting(s) with authorities to plan and discuss Project environmental and social monitoring activities Feb-April 2014 Feb-March 2014 Meeting(s) with stakeholders on specific mitigation and management measures including residents, NGOs and local authorities Feb-March 2014 Meeting with local authorities, port authorities, and local NGOs and stakeholders in Burgas to scope potential environmental and social issues of siting of Quad Jointing Facility May Other Engagement Activities Throughout 2013 and into 2014 South Stream Transport also held meetings and other communications with a broad spectrum of stakeholders, including national, regional, municipal and mayoralty administrations, local businesses, NGOs, fishery associations, and other organisations. These meetings were not required as part of any official procedures but served to introduce stakeholders to the Project and upcoming activities related to the EIA, ESIA and permitting, discuss their involvement in these processes, and gather data and information for the EIA and ESIA assessments, where necessary. Additionally, a number of stakeholders have been engaged to accommodate changes of political and institutional representatives, in order to maintain relationships with the institutions. Meetings were also held to specifically gather baseline data and information for the EIA and ESIA reports. These meetings, which generated comments and feedback of relevance to this ESIA Report, were held with: Ada Bacha Fishing Community; Executive Agency for Fisheries and Aquaculture; 26 URS-EIA-MAN

35 Executive Forest Agency; National Commission for Combating Trafficking in Human Beings; Regional Directorate of the Ministry of Interior (Varna Police); Varna Chamber of Commerce and Industry; and Varna Chamber of Tourism. In September 2013, South Stream Transport made a decision to change the construction design for the shore crossing in Bulgaria, shifting from an open-cut construction design to a trenchless design (i.e. microtunnelling under the beach of Pasha Dere). As a result of this change, a number of government stakeholders were consulted on issues related to the change in construction technique during the final stages of the EIA preparation. South Stream Transport has also opened an Information Centre in central Varna, where people can visit to find out more information about the Project, ask questions and provide comments or lodge grievances. The Information Centre is currently staffed by an SSTTBV Information Officer and Communications Manager. These staff members will be joined by a Community Liaison Officer (CLO) in the near future. In early 2014, further archaeological field surveys were undertaken. Prior to this, surveys of protected fauna and flora species were carried out in order to facilitate relocation and monitoring prior to and during the clearing of vegetation necessary in order to undertake the surveys. During Q1 2014, South Stream Transport extensively engaged with regional and local environmental authorities, state forest agencies, forest users and other relevant stakeholders in order to take into account all legal requirements and stakeholders preferences and concerns regarding these clearance activities. In early 2014 it was decided with the Contractor to locate the Quad Jointing Facility on a moored vessel in Burgas Port.. In order to collect baseline information and assess the environmental and social impacts of this activity, engagement occurred with Port of Burgas, Burgas authorities, local NGOs and other relevant stakeholders Varna Information Centre South Stream Transport has also opened an Information Centre in central Varna, where people can visit to find out more information about the Project, ask questions and provide comments or lodge grievances. The Information Centre is currently open every Tuesday and Wednesday, staffed by an Information Officer and Communications Manager. These staff members have recently been joined by a Community Liaison Officer (CLO). The Information Centre is a joint initiative of South Stream Transport and Sofia-based South Stream Bulgaria AD, whose representative also attends the open information days in the Centre twice per month. A series of events have been organized in the Information Centre since its opening at the beginning of 2014, with the aim of making the Centre well known among the residents Varna and Local communities as well as other stakeholders. Events have included a series called Building South Stream Together which has presenting Project contractors and their line of work to interested residents and stakeholders in the local area, and Building Communities which has URS-EIA-MAN

36 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector aimed to attract local residents to the Centre through more fun, activity-based initiatives such as a public book reading and a dedicated event on International Women s Day. As part of a recent initiative to promote local Project job opportunities, details of job vacancies within Project subcontractors in the region ares advertised in the Information Centre and updated on a weekly basis. Dedicated Project information relevant to Bulgaria and a list of upcoming events in the Information Centre can be accessed via the South Stream Transport website: Overview of Stakeholders Comments and Suggestions This section summarises the comments and suggestions received from stakeholders during the EIA and ESIA consultation processes to date, according to stakeholder category. A more detailed summary of the comments received and South Stream Transport s responses is provided in Appendix D Government Authorities Throughout the course of the Project, South Stream Transport has maintained a continual and open dialogue with national, regional and local Bulgarian authorities. National authorities are informed and consulted as part of the ESIA process, although most of the formal engagement with the authorities is covered by the national EIA process. The main authorities involved were the Ministry of Environment and Water, Ministry of Culture, Ministry of Health, Ministry of Transport and Ministry of Regional Development. The Ministry of Environment and Water is the main authority managing the review and approval process of the EIA although it collects recommendations from various government departments and agencies responsible for specific topics of interest, such as cultural heritage, transport and fisheries. Recommendations received from these authorities have been included in the environmental permit granted by the Ministry of Environment and Water and subsequently incorporated, as appropriate, by South Stream Transport in the ESIA report, Project design, ESMP and CMPs. In addition, during the Development Phase and since July 2012, South Stream Transport has continuously engaged with regional and local authorities across the Local Communities, namely with Region of Varna, Municipalities of Varna and Avren, Mayoralties of Asparuhovo and Priseltsi, and Regional agencies such as the Regional Inspectorates of Environment and Water, Black Sea Basin Directorate: Varna, Executive Forest Agency and others. Consultations enabled to discuss the Project and gather feedback and information from the Local Communities he rest of the concerned parties, for data collection and to discuss key issues and potential impacts of the Project. Comments received from local authorities has tended to reflect their area of jurisdiction and geography related interests, e.g. environment, traffic management, wellbeing of local communities, etc. Nonetheless, a number of discernable comments or questions have been expressed regarding the Project: That all appropriate measures should be taken to maximise the benefit of the Project to the local communities through local employment, local sourcing of goods and services and community investment; 28 URS-EIA-MAN

37 Questions regarding water supply for the Project and the potential impact on the availability of drinking water for Local Communities; Questions about access to Pasha Dere Beach and water quality impacts for bathing; Questions about Project-generated impacts such as noise, vibration, and sea water turbidity and potential release of pollutants from sediments during dredging and how these will be managed; Questions on vegetation clearance and tree cutting, especially on the permitting process and potential impacts on protected habitats and species and whether appropriate environmental management plans are being developed; and Questions related to safety, particularly in the event of a gas explosion Local Communities South Stream Transport has been engaged with residents of local communities at various stages of the Project Development throughout the EIA and ESIA processes. The public were invited to provide comments during: The Scoping Report disclosure and consultation period, including community meetings and roundtable meetings; The EIA Report disclosure and consultation period, including public hearings; and Through meetings and other communications with stakeholders outside of official consultation periods, including data collection meetings. The questions asked and the concerns raised have been similar in all public meetings and comment periods. A key concern was the use of and access to Pasha Dere Beach during construction and the restoration of the beach post-construction. This concern was addressed by the decision to cross the shore via microtunnels passing below Pasha Dere Beach and thereby avoiding Project use of the beach, enabling access for the public and minimizing beach water quality impacts from dredging. In addition, the most common topics raised included the following: Potential impact of the Project on the terrestrial environment, in particular disruption of seasonal ecological activities (e.g. breeding, migration) and potential impact on water quality and water resources within the Project Area; Potential impacts on the marine environment, including impacts related to underwater noise, water turbidity and quality from dredging and unplanned events (e.g. oil spills, pipeline leaks), as well as theenvironmental protection measures to manage impacts; Questions regarding the routing of the pipeline and the proximity of the Project to Local Communities and the city of Varna and potential impacts related to this; and Potential cumulative noise impacts, particularly in relation to the neighbouring facilities of SSB. URS-EIA-MAN

38 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Landowners South Stream Transport has engaged with the Ministry of Agriculture and other state agencies who own the majority of the land affected by the Project. Affected private landowners have also been engaged. All questions and comments from private landowners have been addressed during the land lease agreement process and impacts from the Project due to temporary or permanent land take are compensated by the settlements reached Land Users The methods of engagement with land users has been similar to that conducted with residents of local communities, Although no organised group of beach users has been identified, a number of people who use the beach have provided comments and engaged with the South Stream Transport since the Scoping Stage. Their main concern was the use of and access to Pasha Dere Beach during construction and the restoration of the beach post-construction. As discussed in Section above, these concerns were addressed by the Project design change to microtunneling for the shore crossing. Specific engagement has also been undertaken with the Varna Hunting and Fishing Association and the Galata Hunting Club to understand how they use the landfall section of the Project. These users are concerned by the potential impact on hunting from construction activities due to the potential temporary displacement of game Marine Area Users South Stream Transport has engaged with Marine Area Users in Varna Region at various stage of the Project. Fishing organisations and diving and recreational boat clubs were notified of the publication of the Scoping Report and invited to a roundtable meeting for marine area users and local businesses. They were also notified about the disclosure of the EIA Report and related consultation. Specific meetings were also held with the Ada Bacha fishing community to gather baseline information for the Fishing Study of the ESIA report and to understand the concerns of fishers in relation to the Project. The questions asked and the concerns raised were similar in all consultations, in particular: Potential adverse impacts of the Project on the marine environment from dredging and underwater noise; Questions about construction and operational safety exclusion zones for fishing and other marine activities; Questions about potential impacts on fish migration routes and spawning areas, including impact from underwater noise; and Concerns about whether dredging activities could increase water turbidity during the summer season and thus affect recreational diving. The Project responded to each of these comments at the time of asking and considered them in the development of the ESIA Report (refer to Appendix D). 30 URS-EIA-MAN

39 South Stream Transport also engaged with oil and gas exploration companies, including Petroceltic International Plc and OMV and shipping terminals/ports, including Varna Port East and West and Burgas Port. Meetings and exchanges of information and data took place regarding the proposed Pipeline route and coordination of activities between the Project and oil and gas exploration and shipping/port companies Business and Business Associations Local businesses may benefit from procurement opportunities related to the provision of goods and services to the Project. Conversely, other businesses may be concerned about potential impacts on business revenues, particularly in relation to the tourism sector. Businesses and business associations were engaged during the Scoping Stage in a roundtable meeting in February 2013 to establish any potential for perceived impacts or interest in the Project among this stakeholder group. Subsequent meetings have been held with the Chamber of Commerce and Industry, and the Chamber of Tourism, as well as local service offices in Varna. These stakeholders were also notified about the disclosure of the draft EIA Report and related consultation. Businesses and Business Associations are mainly interested by business opportunities and the positive impact the Project could have on local economy. Although local sourcing and hiring is under the remit of the Construction Contractor and not South Stream Transport s responsibility, it was requested that the Contractor advertise opportunities locally. Project expenditures will result in demand for local goods and services (particularly during construction) and some direct employment related to unskilled and semi-skilled positions may take place. Subsequently South Stream Transport met with local and regional employment and labour agencies to understand and facilitate the Contractor s local advertising and hiring process Community Service and Infrastructure Organisations South Stream Transport has continuously engaged with community service and infrastructure organisations, among which Vik-Varna (Varna water and sewerage company), Varna Police, Department of Social Welfare (Varna Municipality), local high schools, cultural centres and pensioner clubs as well as the Ministry of Health and National Commission for Combating Trafficking in Human Beings (Varna Branch). Community service and infrastructure providers are interested in how the Project might impact on community services such as road infrastructure and water mains and availability of social and health services for Local Communities due to an increase in demand by the Project workforce. Questions on potential impacts on residents and CSWs safety due to the Project workforce have also raised Non-Governmental Organisations (NGOs) South Stream Transport has been engaging with local, regional and national NGOs based on their interest in environmental and social issues related to the area of the Project, such as Black Sea NGO Network, Green Policy Institute, Maritime Club, Friends of the Sea and Bulgarian Society for the Protection of Birds. URS-EIA-MAN

40 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector NGOs were engaged during the Scoping Stage with invitations to review and comment on the Scoping Report, and to participate in roundtable meetings. They were also notified and invited to comment on the draft EIA Report. Meetings on specific topics or to give update on the Project developments have also been organized at various stage of the ESIA process. Comments received from NGOs has tended to reflect their area of interests, e.g. the environment, well-being of local communities, etc. Nonetheless, local and regional NGOs have mostly been concerned by potential environmental impacts particularly with regard to Natura 2000 protected areas. Comments were also raised on the Pasha Dere open-cut beach crossing via and its potential impact on the beach itself and its water quality. These concerns were addressed by the microtunnelling shore crossing alternative. Further concerns have related to marine environment impacts from nearshore works and terrestrial environmental impacts from vegetation clearance Academic and Research Organisations Research institutes and university departments with a particular interest in issues pertaining to archaeology, the environment and the Black Sea, such as the Institute for Marine Research (Oceanology Institute), Institute of Fisheries Resources, Regional Historic Museum of Varna, National Institute of Immovable Cultural Heritage and Centre for Underwater Archaeology were engaged during the Scoping Stage. Following Scoping, these stakeholders have been engaged for socio-economic and cultural heritage baseline data collection and involved in Project planning and design, and mitigation measures Inter-governmental organisations The Permanent Secretariat of the Black Sea Commission in Istanbul has been engaged through an introductory meeting in November 2012 and regular Project updates. During the introductory meeting, the Permanent Secretariat emphasised that the general public is very sensitive to safety and the possibility of unplanned events should be assessed, particularly risks such as earthquakes and corrosion of the Pipeline. No further feedback has been received. A summary of the main comments from all stakeholders received to date, and how these have been considered and addressed by the Project, is contained in Appendix D. 32 URS-EIA-MAN

41 5 Overview of Planned Activities The combined outcomes of both EIA and ESIA engagement programmes, as well as anticipated Project impacts and associated mitigation and management measures, will be considered in the planning and implementation of future Project engagement activities. Planned engagement activities will be commensurate with the scale of impacts predicted in the EIA and ESIA reports. The main upcoming stakeholder engagement activity in Bulgaria is centred around the consultation and disclosure progamme for the Bulgarian Sector ESIA Report (see Section 5.1). Targeted engagement with relevant stakeholders will also occur on discrete aspects of environmental and social management and monitoring as identified in the ESIA Report (see section 5.2.1). Ongoing engagement and liaison with Bulgarian authorities is planned throughout 2014 with regard to permitting procedures, management plans, and all necessary aspects of coordination in view of anticipated construction start in Beyond the planned engagement activities outlined above, South Stream Transport will continue to make it accessible for stakeholders to contact the company with regard to any questions, comments or issues they may have. Project reports and updates will also continue to be published on South Stream Transport s website and relevant stakeholders will be directly notified as appropriate. South Stream Transport has also developed a grievance procedure for the South Stream Offshore Pipeline, which will guide the management of grievances throughout the Project lifecycle (see Section 7). In addition, during the entire construction period, a Community Liaison Officer (CLO), with an office based in the Varna Information Centre, will be responsible for liaising with local residents and other Project s stakeholders in order to maintain a consistent dialogue and to address issues that may arise. Beyond 2014, stakeholder engagement will continue throughout the construction, operation and ultimately decommissioning of the Project. The timing of stakeholder engagement activities for the existing and future Project Phases are summarised in Table 5.1 and described below. Table 5.1 Anticipated Timing of Planned Stakeholder Engagement Activities Project Phase Planned Engagement Activity Anticipated Date Development Grievance Procedure disclosure Q Development ESIA Report disclosure and consultation Q Construction Final ESIA Report disclosed Q Construction ESIA Overview Report disclosure and consultation Q Construction Engagement with local authorities and other relevant organisations to plan Project information disclosure during construction Q URS-EIA-MAN

42 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Project Phase Planned Engagement Activity Anticipated Date Construction Notification of construction start Q Construction Construction Construction Construction Construction Construction Project information, coordination and regular update meetings with marine authorities, fisheries and marine users on nearshore and offshore construction schedule, exclusion zones and movements of vessels Engagement with Pasha Dere Beach Users to inform them of potential impacts on Pasha Dere beach, including the timing of proposed access restrictions, planned construction activities and the nature of any restorative work to be undertaken following construction. Ongoing Cultural Heritage consultations with the relevant Authorities and the relevant authorities will be informed of all chance finds. Engagement for the development of the Biodiversity Action Plan (BAP) Meetings to plan and develop Project environmental and social monitoring activities Meeting(s) regarding potential community investment opportunities and partners Q / 2017 Q / 2017 Q / 2017 Q Q Q3 / Q Construction Project update to targeted stakeholders Q Construction Development, Construction and Pre-Commissioning Annual Environmental and Social management report(s)* Ongoing engagement and coordination with Bulgarian authorities for permitting, monitoring and other procedures prior and during construction Q / Q Q to 2017 Construction and Pre-Commissioning Stakeholder Engagement Plan: Update Q / Q Operation On-going stakeholder engagement From 2017 Decommissioning On-going stakeholder engagement From 2065 * Precise details to be confirmed 34 URS-EIA-MAN

43 5.1 ESIA Consultations The focus of the ESIA consultations is to ensure that potentially affected stakeholders and other interested stakeholders are provided with the opportunity to: access clear and appropriate information (i.e. non-technical, local language) information on the Project and its potential impacts; provide feedback on the content of the ESIA Report including the assessment of impacts, and the proposed mitigation, management and monitoring measures, which will be taken into account in developing the ESMS for the Project; and provide input regarding plans for future engagement activities, including preferences for methods, materials and schedule. The draft ESIA Report was disclosed on 29 July 2014, along with a Non-Technical Summary (NTS) document and is available for review for a minimum period of 30 days from the date of disclosure. The draft ESIA Report (including NTS and appendices) will be accessible in a number of ways: o o o o o o Online at Printed copies are available in central locations: Varna Information Centre: 29, Tsar Simeon I str, Varna Priseltsi Mayor s Office: Mayoralty of Priseltsi, Priseltsi Village, Avren Municipality, Varna Galata Cultural Centre: 24, Kapitan, Galata, Varna Krushkite: Grocery store "bulbs" 275, Varna Rakitnika: El Toro Grocery Store, "Priboy 1" 890, Varna South Stream Transport Sofia Office: 53V, N.J. Vaptzarov blvd, Sofia Upon direct request to South Stream Transport (using the contact details found at the back of this document); Stakeholders will have the opportunity to comment in writing, and to attend meetings to discuss the draft ESIA Report. The meetings will allow stakeholders to put forward their views on the ESIA and the mitigation measures proposed, and also to express their preferences for communication methods during future phases of the Project. Announcements regarding the draft ESIA Report s disclosure and the date and timings of public meetings have been made in national, regional and local newspapers, as well as online ( Copies of the ESIA Report and/or Non-Technical Summary have also been delivered to identified stakeholders as appropriate, with invitations to comment and/or attend ESIA consultation meetings. The programme of ESIA consultation meetings is provided in Table 5.2 below. URS-EIA-MAN

44 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Table 5.2 Consultation Programme for Draft ESIA Report Meeting Type Stakeholders Date and Location* Drop-In Session Residents from Local Communities in Avren Municipality and general public Tuesday 12 August Priseltsi Cultural Centre Roundtable Meeting NGOs, Land and Marine Area Users Wednesday 13 August Golden Tulip Hotel, Varna Drop-In Session Varna residents, Local Communities and general public Wednesday 13 August Varna Information Centre Focused Meetings Specific stakeholders such as fishing organisations and beach resort. Various locations during week of 11 August *Programme may be subject to change; check local announcements and online ( for updates. In addition, South Stream Transport plans to arrange a separate meeting with the Bulgarian media to respond to questions about the Project and the ESIA Report. South Stream Transport also plans to host a business breakfast at the Varna Information Centre in which local businesses will be invited to learn about local procurement opportunities as presented by the Construction Contractor. These activities are planned to coincide with ESIA Consultation meetings. Additional meetings with specific stakeholders on the ESIA Report, may also be organised as appropriate. The above programme of meetings takes into account the outcomes and experiences of previous engagement activities in Bulgaria, including for the EIA: Stakeholders expressed their preference for public meetings to take place outside of working hours. Therefore, public meetings will be organised after 5 pm during the week; and In some public meetings, comments from NGOs and other stakeholders have been hindered as Question and Answer sessions were dominated by comments from a few members of the audience. South Stream Transport will hold arrange roundtable and focused meetings as appropriate to ensure an optimal dialogue with key stakeholders. Comments received during the disclosure period for the draft ESIA Report, and the related consultation activities, will be taken into consideration in the preparation of the final ESIA Report. The final ESIA Report will be disclosed on the South Stream Transport website and will inform the Construction and Pre-Commissioning Phase and Operational Phase of the Project, including the development and implementation of the Project Environmental and Social Management System (ESMS). 36 URS-EIA-MAN

45 5.1.1 ESIA Consultations for the South Stream Offshore Pipeline In addition to the ESIA Report for the Bulgarian Sector, ESIA Reports and accompanying NTS have been prepared for the Turkish and Russian sectors of the South Stream Offshore Pipeline. The ESIA Report for the Turkish Sector was disclosed on 11 June 2014 and consultations on the report were undertaken on the Week of 23 June The ESIA Report for the Russian Sector will be published in the summer of 2014 in English and Russian, and consultations on this report will also be scheduled during this period. SEPs for the Turkish and Bulgarian sectors have also been updated and published at the time of the disclosure of the ESIA reports, and contain more detailed information about the ESIA consultation program for Turkey and Bulgaria as well as planned engagement activities beyond the ESIA process. An ESIA Overview Report is being prepared by South Stream Transport which summarises the ESIAs conducted in each of the three affected countries and assesses the impact of the South Stream Offshore Pipeline through the Black Sea as a whole. The ESIA Overview Report will be published in English, Russian, Turkish and Bulgarian and sent to stakeholders who may have an interest in the impacts of the Pipeline on the Black Sea region, e.g. inter-governmental organisations, international or Black Sea regional environmental NGOs, etc. Access to the country ESIA documentation and SEPs, along with updates on the planned consultation program, will be published online at In addition to the ESIA consultation and disclosure program planned by South Stream Transport across the three affected countries, the export credit agencies (ECAs) responsible for the financing of the Pipeline will also disclose each the ESIA reports in accordance with their financing guidelines. The ESIA reports will be made available on the websites of the following ECAs: Swiss Export Risk Insurance (SERV): Japan Bank for International Cooperation (JBIC): SACE: Euler Hermes: Post-ESIA Engagement Activities Environmental and Social Management Plan Beyond the ESIA process, South Stream Transport will engage with stakeholders to provide input into the development of the Project s Environmental and Social Management Plan, as appropriate. Engagement planned for the development of the ESMP is described in Table 5.3. Although the table covers known engagement activities on aspects of the ESMP, engagement may be undertaken on other discrete aspects of the ESMP if deemed appropriate. URS-EIA-MAN

46 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Table 5.3 Planned Engagement for ESMP Plan Biodiversity Action Plan (BAP) Type of Engagement As some species and habitats within the Project Area are considered to be critical habitat 2, the Project has committed to developing a BAP which will seek to achieve net biodiversity gains by identifying additional opportunities to protect and conserve biodiversity and improve conservation measures for those species of conservation concern. During the first phase, relevant stakeholders will be identified and preliminary meetings will inform South Stream Transport on the existing or projected biodiversity programs monitored by national, regional and local government, universities, NGOs and local ecologists. These meetings will serve the broader objective of identifying potential institutions and biodiversity programs to partner with in order to develop these in a way that would serve the BAP goal to achieve net gains of those biodiversity values for which the critical habitats were designated. The information collected during this first phase will assist in developing the BAP, defining specific biodiversity actions and building potential partnerships with stakeholders. During a second phase, South Stream Transport will engage more closely with its partners for roll out of the BAP programs. During the life of the BAP, engagement with stakeholders identified in Phase 1 will continue to ensure they are informed of the BAP and its results. Rapid Health Appraisal (RHA) South Stream Transport s Construction Contractor will conduct a Rapid Health Appraisal in order to assess impacts on the availability of local health services, housing and other social services due to an increase in resource demands from the Project workforce. Therefore, in addition to the consultations held to date by South Stream Transport, the Project Contractor will conduct the following engagement and appraisal in Q3 2014: Further consultation with local health services to confirm how the healthcare needs of the construction workforce will be met; Agreement with local health services and other authorities on resource management if an unplanned event affected both local communities and the workforce; Further appraisal to ensure that access to hospitals, clinics, doctors surgeries and pharmacies is not restricted; and Further appraisal to confirm appropriate housing and health provision is in place for the onshore workforce. 2 Critical habitats are areas with high biodiversity value, including habitat of significant importance to Critically Endangered and/or Endangered species (as listed on the IUCN Red List); habitat of significant important to endemic and/or restrictedrange species; habitat supporting globally significant concentrations of migratory species and/or congregatory species; highly threatened and/or unique ecosystems; and/or areas associated with key evolutionary processes 38 URS-EIA-MAN

47 Plan Cultural Heritage Construction Management Plan Environmental and Social Monitoring Programme Type of Engagement South Stream Transport will engage with the relevant cultural heritage authorities to finalize the Chance Find Procedure, which covers the reporting and handling of CHOs in the event that as yet unknown CHOs are discovered during preconstruction surveys or during pipe-laying activities. Meetings with be arranged as necessary with stakeholders, such as government authorities, NGOs, and research institutes to discuss, plan and develop the Environmental and Social Monitoring Programme Community Investment Plan In addition to the measures to avoid and mitigate adverse Project impacts as outlined in the EIA and ESIA documentation, in line with good international industry practice, South Stream Transport commits to the implementation of a Community Investment Programme (CIP). A CIP is a foundation for promoting local development and building relationships with community stakeholders, and ensuring that community concerns are appropriately addressed, in a manner that supports business objectives. Information from completed stakeholder engagement and knowledge of the Project baseline and impacts have contributed to the development of a CIP. The CIP will be further developed during Q through disclosure of CIP objectives, principles and development criteria and needs assessment meetings with Local Communities, NGOs and other relevant stakeholders. Based on this first stage of consultations, South Stream Transport will formulate CIP initiatives and programs which will be implemented starting Q in partnership with identified organisations. During the life of the CIP, engagement with relevant stakeholders will continue to ensure they are informed of the CIP and its results Grievance Procedure Disclosure South Stream Transport has developed a Grievance Procedure to ensure that complaints are addressed in a timely and consistent manner. Stakeholders will be informed about the Grievance Procedure during consultations on the ESIA Report. The Grievance Procedure will be published on South Stream Transport s website and communicated to relevant stakeholders as appropriate. A non-technical leaflet explaining the Grievance Procedure has been prepared. It will be distributed at the ESIA disclosure meetings, made available at the Varna Information Centre or sent directly to stakeholders as appropriate. The leaflet will provide stakeholders with information on how they can contact South Stream Transport should they have any questions, suggestions or comments about the Project, or wish to raise a concern or make a complaint about Project activities. More information on the Grievance Procedure is contained in Section 7. URS-EIA-MAN

48 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Project Updates Brochures covering environmental and social issues of relevance to the Project will be developed in Project information and updates will also be regularly communicated via South Stream Transport s website, including reporting on the South Stream Offshore Pipeline s environmental and social management and performance. However, the precise nature of these reports will be defined during the course of A specific end-of-year Project update will also be sent to relevant stakeholders who have been engaged during the EIA / ESIA processes, as well as other stakeholders who have expressed an interest in the Project. This may take the form of a brochure or information leaflet. The SEP will also be updated around this time to detail the planned engagement activities which will occur prior to and during construction. 5.3 Construction & Pre-Commissioning, Operational and Decommissioning Phases Stakeholder engagement will continue over the life of the Project throughout the Construction and Pre-Commissioning, Operational and Decommissioning phases of the Project. With an operational life of 50 years, South Stream Transport is committed to maintaining relationships and communications with stakeholders over this time. Throughout this period, the SEP will be periodically updated, as appropriate, as needs and engagement activities evolve. During the Construction and Pre-Commissioning Phase phase, and the subsequent Operational Phase, the emphasis of engagement shifts from seeking and incorporating stakeholder input in future plans, to consultation and disclosure about activities that are current or about to take place, and receiving feedback from stakeholders regarding ongoing activities. Public notifications will be made prior to the start of construction activities and meetings will be arranged as appropriate with specific stakeholder groups to prior to and during construction activities. The following specific engagement activities will be undertaken: South Stream Transport will consult with the Ada Bacha community and other marine users regarding construction activities in the marine area in order primarily to inform them about Project-related activities well in advance in order to avoid and where possible, minimize disturbance to the fishermen, and also to minimize detours and, when detours are unavoidable reduce detour times. In addition, information on restricted areas will be provided to the relevant authorities for routine dissemination to marine stakeholders identifying marine exclusion zones through the Construction and Pre-Commissioning Phase. With regard to Pasha Dere Beach, notice of any onshore access restrictions will be advertised as far in advance as practicable including being posted at the beach and campsite and at entrances to the paths at a sufficient distance to avoid users progressing down the tracks only to find them closed. Early and ongoing engagement with stakeholders will be undertaken (including specifically to beach users and camping ground users) to discuss potential impacts on Pasha Dere beach, including the timing of proposed access restrictions, planned construction activities and the nature of any restorative work to be undertaken following construction. 40 URS-EIA-MAN

49 The results of any monitoring undertaken of relevance to the Pasha Dere beach (e.g. air quality, noise, landscape and visual amenity and seabed sediment and marine water quality) will be communicated through ongoing stakeholder engagement and disclosed on South Stream Transport's website. South Stream Transport will undertake consultation with local communities and other stakeholders on the potential uses of the timber that is felled for the Project. Other engagement activities will include: On-going discussions with regulatory authorities on environmental and social matters; Community Liaison Officer to ensure communities are informed about Project activities, seek their participation in decisions affecting their communities and provide a focal point for feedback and grievances; Regular reports and updates to stakeholders on Project progress, implementation of mitigation measures, compliance with ESMS and overall Project performance; Continued stakeholder access to the Information Centre during the Construction and Pre- Commissioning Phase where Project Information will be available and Project representatives on hand to receive feedback and respond to questions. Dedicated information events hosted in the Information Centre will also be ongoing; and Communication and, as appropriate, co-ordination with SSB on items of common interest in relation so stakeholders and Local Communities. An overview of the anticipated engagement materials and methods that will be disclosed up to the end of the Construction and Pre-Commissioning Phase of the Project is outlined in Table 5.4 below. Note that due to changing Project activities, the type of engagement which may occur during the Operational and De-Commissioning Phase may differ from that of the Construction and Pre-Commissioning and, as such, the engagement materials and methods to be used during those Project phases will be determined closer to the start of those phases. Table 5.4 Anticipated Information Disclosure during the Construction and Pre- Commissioning Phase Type Announcement of Project Milestones (e.g. start of construction, first gas, full operations) Grievance Procedure Stakeholder Engagement Plan ESMS Performance Report Company Sustainability Report Project Updates Notice of Upcoming Activities (e.g. construction) Method Website, Newspapers, Information Centre Website, Newspapers, Information Centre, Mail-outs Website, Information Centre Website, Information Centre Website, Information Centre Website, Newspapers, Information Centre Website, Newspapers, Mail-outs URS-EIA-MAN

50 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector 6 Roles and Responsibilities South Stream Transport s Stakeholder Engagement Team is the focal point for communications with stakeholders and for engagement activities. The overall Stakeholder Engagement Co-ordinator for the South Stream Offshore Pipeline is responsible for stakeholder engagement activities across Russia, Turkey and Bulgaria, and will have management oversight of the stakeholder engagement programme. Working with the overall co-ordinator are country-specific Stakeholder Engagement Experts one each for Russia, Turkey and Bulgaria. The Stakeholder Engagement Experts are responsible for the planning and implementation of engagement activities specific to each country. The Stakeholder Engagement Officer is responsible for the processing and recording of engagement activities and stakeholder communications. Part of this role is to manage the Stakeholder Consultation Database and to oversee the implementation of the Grievance Mechanism. A Community Liaison Officer (CLO), one each for Russia and Bulgaria, is working with the respective country Stakeholder Engagement Expert to ensure direct liaison with Local Communities and other Project stakeholders. In Bulgaria, the CLO office is located at South Stream Transport Information Centre in Varna. The CLO will be available to local communities and other interested or potentially affected stakeholders. The CLO will also usually be the first point of contact in relation to community questions, complaints or grievances and will also assist in the identification and resolution of issues or grievances that could arise from the Project. Supporting the South Stream Transport s Stakeholder Engagement Team are the overall ESIA consultant, URS, and the country-specific EIA/ESIA contractors. In Bulgaria, these contractors are Povvik AD and Geomarine Ltd. Geomarine Ltd are also the monitoring contractor. The stakeholder engagement programme is led by South Stream Transport s Technical Department (specifically, the overall Stakeholder Engagement Coordinator). The programme, along with supporting tools and processes, are communicated within South Stream Transport through formal procedures and management practices (e.g. meeting plans and pre-meeting briefings, standard Question-and-Answer resources), trainings (e.g. media training, stakeholder engagement training for field staff), and documentation (e.g. minutes of meetings, Stakeholder and Consultation Database). Prior to the start of construction, South Stream Transport will further discuss stakeholder engagement and management goals with the selected Construction Contractor. Plans and practices will be developed to ensure that the existing stakeholder engagement programme is maintained or improved throughout construction, with clear definition of procedures and responsibilities. There will be one Grievance Procedure for the Local Communities with coordination between the South Stream Transport CLO and the Contractor Site Liaison Office in managing and resolving community concerns. 42 URS-EIA-MAN

51 7 Contact with South Stream Transport 7.1 Feedback Process Stakeholders are invited to provide feedback about the Project. This lets us know how we are doing, and helps us identify areas that might be improved. Feedback may include questions, comments, requests for information, suggestions, concerns, and complaints. These can be provided in person, over the phone, or in writing by , fax or post. South Stream Transport will treat all types of feedback with professional consideration and respect, and base our responses on open and honest communication. In order to effectively manage, respond to, and benefit from stakeholder feedback, all feedback received is subject to a consistent Feedback Process. As part of the Feedback Process, South Stream Transport will: document all feedback; forward to the relevant people within the company; consider within the ongoing planning and implementation of the Project, including management and monitoring programmes; and provide responses where needed. Stakeholder feedback may also manifest through external channels, such as the media and social media. Where this type of feedback is identified, it may also be tracked through the Feedback Process to ensure that South Stream Transport is aware of (and proactively addressing) current issues and perceptions. While some feedback may be positive, some people may have complaints about Project activities. South Stream Transport is committed to treating complaints with the same consideration and respect as other types of feedback. South Stream Transport will work with all parties to address complaints and concerns. This process is managed through the company s Grievance Procedure. Stakeholders can contact South Stream Transport at any time by letter, phone, fax or . Contact information is available on South Stream Transport s website, and is included in all external publications and communications (including reports, leaflets, letters, s, etc.). These publications and communications have encouraged stakeholders to contact the company directly if they have comments or questions. Communications with South Stream Transport can be conducted in Bulgarian, English, Russian or Turkish. Meetings with South Stream Transport representatives can be arranged as needed. URS-EIA-MAN

52 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Communications can be sent to: Or Or South Stream Transport B.V. - Bulgaria Branch 53V N. J. Vaptzarov Blvd Sofia, Bulgaria Phone: +359 (2) South Stream Transport B.V. Varna Information Centre Tsar Simeon Street Varna, Bulgaria Phone: +359 (5) South Stream Transport B.V., ESIA and Permitting Department Parnassusweg 809, 1082 LZ Amsterdam, The Netherlands Phone: +31 (0) Fax: +31 (0) Or comments may be submitted by: to: esia@south-stream-transport.com via website: Grievance Procedure Overview A grievance is a complaint that someone has about the activities of the Project or South Stream Transport. A grievance might stem from: a specific incident such as a road accident, spill, property damage or night-time noise; the behaviour of workers such as disrespectful or discriminatory actions; an environmental impact such as water contamination, or damage to bird nests; a social impact such as strain on community services, or loss of recreation areas; other types of impacts such as traffic, health, and cultural heritage impacts. In line with good international industry practice, South Stream Transport has established a Grievance Procedure which aims to ensure that any grievances associated with Project activities are addressed in good faith through a transparent and impartial process. Specific objectives of the Grievance Procedure are: to help South Stream Transport identify issues and concerns early, so that we can address them quickly and proactively; to continuously improve Project performance in all areas; and 44 URS-EIA-MAN

53 to demonstrate South Stream Transport s commitment to meaningful stakeholder engagement, and respect for local opinions and concerns. During the development, construction, operation and, ultimately, decommissioning of the Project, South Stream Transport will use the Grievance Procedure, working in partnership with its contractors as a critical component of the broader Feedback Process and other stakeholder engagement activities Grievance Procedure Process A summary of the process for identifying, investigating and resolving grievances is provided in Table 7.1 below. The Grievance Procedure itself will be published on South Stream Transport s website in a non-technical format and stakeholders will be notified as appropriate. Table 7.1 Grievance Procedure Process Stage Description Stage 1: Feedback received Stage 2: Grievance logged Stage 3: Investigation and resolution Stage 4: Resolution accepted (or not accepted) Comments and questions are received and analysed as part of the standard Feedback Process. All communications are subject to the Feedback Process, which ensures that feedback is documented, incorporated, and responded to as needed. In some cases, this process may identify a grievance. If so, Stage 2 of the Grievance Procedure is initiated. When a grievance is identified, it is officially registered and given a unique identification number. It is categorised based on the type of complaint and its severity. An initial response is sent to the person(s) who raised the grievance within seven (7) working days, acknowledging their feedback and describing the next steps in the grievance process, time estimates for these steps and a contact person. South Stream Transport will investigate grievances and their surrounding circumstances. These investigations will be undertaken in a timely manner. Investigations may include photographs and other evidence, witness statements, interviews with affected stakeholders and other parties, review of site registers, and other information gathering activities. The results of these investigations will be reviewed and a resolution will be proposed. The development of the resolution may involve consultation with the person(s) involved. The proposed resolution will then be formally communicated to all parties. If the resolution is accepted by all parties, it is implemented and the grievance is closed. If the resolution is not accepted, it will be reconsidered and a revised resolution may be proposed. The affected person(s) may choose to pursue external remedies (e.g. through legal proceedings) at any time, including if an agreed resolution cannot be found. However, South Stream Transport is committed to fairly and URS-EIA-MAN

54 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Stage Description collaboratively resolving grievances through the Grievance Procedure wherever possible. Stage 5: Monitoring & Evaluation After the accepted resolution has been implemented, it will be monitored and its effectiveness will be evaluated. All parties will be notified that the resolution has been implemented and will have the opportunity to provide feedback on the grievance process and its implementation. Figure 7.1 Grievance Procedure Flowchart 46 URS-EIA-MAN

55 8 Monitoring and Reporting 8.1 Monitoring It is important to monitor stakeholder engagement to ensure that consultation and disclosure efforts are effective, and in particular that stakeholders have been meaningfully consulted throughout the process. Stakeholder engagement monitoring is managed through the South Stream Offshore Pipeline s ESMP. Monitoring will include: auditing implementation of the Stakeholder Engagement Plan; monitoring consultation activities conducted with government authorities and nongovernmental stakeholders; monitoring the effectiveness of the engagement processes in managing impacts and expectations by tracking feedback received from engagement activities; and monitoring any grievances received. 8.2 Tracking Stakeholder Engagement Activities Performance will be reviewed regularly against the Stakeholder Engagement Plan. Tracking of stakeholder engagement will be used to assess the effectiveness of South Stream Transport s stakeholder engagement activities. Indicators for tracking will include: materials disseminated: types, frequency, and location; place and time of formal engagement events and level of participation including by specific stakeholder categories and groups (e.g. women); numbers of visitors to the South Stream Transport Information Centre and Country Offices, and comments received by other routes (website, , post, phone, personal visits); number of comments by topic and type of stakeholder, and details of feedback provided; numbers and types of grievances and the nature and timing of their resolution; recording and tracking commitments made to stakeholders; and community attitudes and perceptions in Bulgaria and Russia based on media reports and stakeholder feedback. 8.3 Project Reporting Internal Reporting Quarterly reports will summarise all activity for the period, and provide a summary of issues raised and how they have been addressed, including timeliness of responses and corrective and mitigation measures to address grievances, and analysis of trends in key performance indicators (KPIs). These will include: total numbers of stakeholders engaged according to stakeholder category; URS-EIA-MAN

56 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector numbers of comments and queries received according by topic and responses given; issues raised and levels of support for and opposition to the Project; numbers of grievances lodged; and time to resolution of grievances External Reporting The SEP will be reviewed on a regular basis (at a minimum every 6 months) and revised as needed to reflect completed engagement activities and revise and confirm future engagement plans. During the Construction & Pre-Commissioning Phase, South Stream Transport will report regularly via its website and in local communities in Bulgaria and Russia on Project progress, implementation of mitigation measures, compliance with ESMS and overall performance. An Annual Environmental and Social Report will be prepared by South Stream Transport which will include a summary of issues raised by stakeholders, numbers and subjects of grievances, a summary of key actions taken to address concerns, and an analysis of trends in KPIs. During the Operational Phase, South Stream Transport will continue to provide updates as necessary, although it is difficult to predict what events will occur over an operational lifecycle of 50 years. South Stream Transport anticipates providing information to stakeholders which will focus on non-routine activities, after an unplanned event or incident (if one occurs), or if there is any change to company structure or practice. 8.4 Stakeholder and Consultation Database South Stream Transport has developed a Stakeholder Consultation Database (SCD) which formalizes the stakeholder engagement process in order to ensure that all Project stakeholder communications are documented and that any comments, suggestions, concerns or grievances received from stakeholders are recorded, tracked and addressed. The SCD can be used to analyse feedback received from stakeholders, and this analysis can be used in turn to inform the development of the ESIA and updates to the Stakeholder Engagement Plan. The SCD is a valuable tool to coordinate information about stakeholder engagement among South Stream Transport and its contractors and sub-contractors. The SCD will also help in the implementation of the ESMP which have been developed to capture design controls, safeguards, mitigation measures and monitoring commitments made within the ESIA. Adherence to these plans will be a condition of any Project construction and operation contracts awarded. The SCD also feeds into South Stream Transport s overarching Environmental and Social Monitoring Programme which will detail all monitoring requirements applicable to the South Stream Offshore Pipeline regardless of associated phase, topic or location. The SCD is used to store, retrieve and analyse information for all stakeholder communications and consultations. It allows data to be entered from meetings (e.g. minutes of meetings) and communications (e.g. letters, press releases, s, and face-to-face or telephone discussions) and can generate tailored reports about stakeholder activity. Input from stakeholders is also categorised by date and location, and by several thematic areas, enabling a diverse range of 48 URS-EIA-MAN

57 queries to support the ESIA, Project design and Project planning. In addition to the ability to analyse and export data, the SCD provides a regularly updated record of stakeholder engagement. URS-EIA-MAN

58 Stakeholder Engagement Plan South Stream Offshore Pipeline Bulgarian Sector Appendices Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Regulatory Framework of the Republic of Bulgaria for EIA Stakeholder Engagement List of Stakeholders Identified Summary of Completed Stakeholder Engagement Activities Summary of Comments and Responses Copies of Public Announcements Comment Form 50 URS-EIA-MAN

59 Appendix A: Regulatory Framework of the Republic of Bulgaria for EIA Stakeholder Engagement

60 Overview of Stakeholder Engagement in Bulgarian EIA Process Legislation The applicable Bulgarian legislation 1 requires that the public and other stakeholders be consulted about the Project and should have an opportunity to make comments relating to the information disclosed to the public in the course of the development of the Project. In Bulgaria, information disclosure and public consultation is regulated by the following legislation: Environmental Protection Act (EPA) (promulgated in the State Gazette issue 91/2002, amended and supplemented), in particular Section III Environmental Impact Assessment of Development Proposals ; Regulation on the conditions and order for performing environmental impact assessment (SG. 3/2006, last amend. and suppl. SG 94/2012); Regulation on the conditions and the order for performing Appropriate Assessment of the plans and programmes, projects and investment proposals with the subject and aim of the protected sites (SG No.73/2007, last amen. and suppl. SG 94/2012); and Regulation on the conditions and the order for performing Environmental Assessment of plans and programmes, (SG. 3/2006, last amend. and suppl. SG 94/2012). Under the Environmental Protection Act on Environmental Impact Assessment, proposed developments are subject to a screening process through which they are classified as either Annex 1 or Annex 2 developments. Annex 1 projects are all major investment developments with significant environmental impacts anticipated and may be of national significance. According to the EPA, Annex 1 projects require a mandatory EIA Annex 2 typically captures smaller scale projects which may or may not be deemed to require an EIA; these projects are usually addressed at the regional level under the Regional Inspectorate of Environment and Water or the Ministry of Environment and Water. Figure 1 summarizes the institutional hierarchy within Bulgaria. 1 Art.9 (1) and (2) of the EIA Regulation and Art. 95 (3) of the Environmental Protection Act.

61 Figure 1 Bulgarian Institutional Hierarchy and Responsible EIA Authorities In particular the Environmental Protection Act (EPA) clearly outlines the requirements for carrying out public consultation and information disclosure in relation to the Project. South Stream Transport is legally required to undertake consultations with relevant authorities, the public and other stakeholders in order to inform them of the proposed development, and to express comments, questions and concerns related to the Project, for consideration during the EIA process. The EIA Regulation provides supplementary instructions on the EIA process and consultation requirements as set out in the EPA. This also includes provisions for trans-boundary consultation. According to the legislation, undertaking of public consultation activities is largely mandated to the Project Proponent under the procedural supervision of the Competent Authority. Process According to the EIA Regulation, the EIA process, for the Project, in Bulgaria officially commences when South Stream Transport submits a Notification Document to the Ministry of Environment and Water about the Project. Department of Preventive Activities of MOEW is responsible for the EIA procedure for the Project. The content of the Notification is regulated by the EIA Regulation and includes project description, key facts and figures, information about project alternatives, an initial identification of the affected municipalities and some key potential issues. South Stream Transport submitted the Notification to the regional governor and municipal administration and presented MOEW with evidences stating that the Document has been submitted to the local municipalities as required by the national legislation.

62 Based on the Notification, the MОEW carried out a screening process for the necessity of EIA for the Project and send a Notification Response, including instructions to consult with affected public and regional and municipal administrations. The MОEW notifies in writing the municipality administrations where the Project will take place about the decision within a period of 3 days of making the decision on the EIA. To meet Bulgarian requirements for scoping consultation, South Stream Transport held consultations with the respective governmental agencies and organisations, the public in the affected municipalities and interested NGOs (so-called Scoping Meetings ) to determine the scope, contents and format of the EIA Report. Key stakeholders consulted during the Project Scoping phase include additional ministries and departments. They generated feedback on the proposed scope, approach and key issues to be addressed in the EIA and on recommendations on mitigation and monitoring. Following the Scoping meetings, South Stream Transport submitted a ToR document to the MОEW which outlined the proposed scope, contents and format of the EIA Report. South Stream Transport also informed the public about the scope, content and form of the EIA Report, as well as about the next steps via its website and via notifications in the media. Once the EIA Report was completed it was submitted to MOEW for review. Following submission, the MOEW checked the EIA Report for completeness and acceptability against the coordinated and revised scope of the ToR within 30 days of receipt. Тhe EIA Report was ready for public access after having received positive quality evaluation by MOEW and comments were addressed. MOEW informed South Stream Transport of the results from the EIA quality evaluation in written. In the assessment letter, MOEW specified the affected local government entities where South Stream Transport should organise public hearings on the EIA Report. South Stream Transport was required, together with the affected municipalities, to ensure public access to the EIA documentation. Each of the local-level and regional administrations, specified by the MOEW received a copy of the EIA Report for public disclosure. South Stream Transport, in coordination with the administrations, determined the date and time for holding the Public Hearings, as well as the venue, time for public access to the EIA report and the place and time for submission of written statements of opinions. The first hearing should be within 60 days of the request for meetings (Art. 97 (2) of the EPA). South Stream Transport notified the MОEW about the planned programme and activities in relation to the Public Hearings and agreed on the programme with the MОEW. South Stream Transport must announce the consultation program in the media and through local public notices at least 30 days prior to the Public Hearings. Details, such as date, time and venue of Public Hearings, as required, were published with the invitation in local newspapers 30 days in advance of the Public Hearings. In addition, South Stream Transport informed and invited in writing the identified key stakeholders. Representatives of the public were able to submit their opinions in writing at the Public Hearings or send opinions to South Stream Transport and to the MОEW no later than 7 calendar days after the Public Hearings. This legal provision was explicitly communicated in the invitations and information materials by South Stream Transport.

63 South Stream Transport received from the municipalities a copy of the materials with results of the public discussion no later than 3 days following the date of the public discussion. Within 7 days following the last public EIA discussion, South Stream Transport submitted to the MОEW an evaluation of the comments and written statements received from the public discussions. As legally required South Stream Transport provided a statement of the Public Hearings to each affected municipality and the MОEW within 10 days after the last Public Hearing. The MoEW provided a decision on the EIA based on a decision of the Supreme Environmental Council within 45 days after the last Public Hearing. The MОEW submitted the EIA decision to South Stream Transport and published the announcement on their website within 7 days of the decision. Stakeholders had 14 days to appeal the decision of the EIA under the Administrative Code (Art. 99 (6) EPA).

64

65 Appendix B: List of Stakeholders Identified to Date

66 Stakeholder Category National Government Regional Government Stakeholder Ministry of Environment and Water (MoEW) Ministry of Agriculture and Food (MAF) Ministry of Defence (MoD) Ministry of Interior (MoI) State Agency for Metrological and Technical Surveillance Ministry of Culture (MoC) Ministry of Economy and Energy (MEE) Ministry of Health (MoH) Ministry of Regional Development(MRD)* Ministry of Transport, Information Technologies and Communications (MTITC) Regional Inspectorate of Environmental and Water (under MoEW) Departments / Sub-Organisations Environmental Impact Assessment Directorate National Environment Protection Service Directorate National Protected Areas Department - Natura 2000 Department Environment Executive Agency Executive Agency of Fisheries and Aquaculture (EAFA) Agriculture Directorate Institute of Fishery Resources Executive Forest Agency (EFA) Naval Forces Directorate Directorate for Fire Safety and Civil Protection Centre for Underwater Archaeology National Institute of Immovable Cultural Heritage Projects Department Energy Markets and Infrastructure Department Bulgarian Agency for Investments State Health Control Department Technical Standards and Norms Directorate Spatial Planning Directorate Legal Directorate Bulgarian Institute for Standardisation Maritime Administration Directorate Bulgarian Ports Infrastructure Company Bulgarian Hydrographic Service Regional Administration of Varna (under MoI) Regional Forest Directorate (under MAF) Black Sea Basin Directorate (under MoEW) Regional Agriculture Directorate (under MAF) Regional Directorate of the Ministry of Interior (Varna Police, under MoI) Regional Labour Office (under MEE) State Forest Office Varna North Eastern Enterprise Shumen Permits Department Plans Department

67 Stakeholder Category Local Government Community services and Infrastructure Fisheries and Marine Area Users Stakeholder Regional Health Inspectorate (under MoH) Regional Maritime Administration (under MTITC) Bulgarian Navy, Varna Naval Headquarter (under MoD) Port Infrastructure Company, Regional Substructure, Port Varna (under MTITC) Agency for Geodesy, Cartography and Cadastre (under MRDPW) Road Infrastructure Agency (under MTITC) State Energy and Water Regulatory Commission (SEWRC) Regional Historic Museum (under MoC) National Construction Control Directorate Municipality of Varna Municipality of Avren Municipality of Burgas Vik Varna OOD Fire Safety and Civil Protection Regional Office Energo-Pro Varna EOOD Vivacom Varnagaz High schools in Asparuhovo and Galata Galata cultural centre Asparuhovo cultural centre Sport Clubs and Marinas Fisheries and associations Departments / Sub-Organisations Mayoralty of Asparuhovo Chamber of Tourism Department of Geodesy, Cartography and Cadastre Sector Fishery and Control District Road Administration Police of Varna Varna Local Employment Office Social Activities Directorate Mayoralty of Priseltsi Mayoralty of Blisnatsi Police of Burgas Varna Yacht Club Sailing clubs x4 Association Odessos Elekta JSC Fishery Association Ada Bacha Association BG Fish

68 Stakeholder Category Business and Business Associations Landusers Landowners Academic and/or Research Organisations Stakeholder Diving centers Sever Export Aquanaut Ltd Bulyard Devnya Cement OMV Bulgaria OMD Dvras Chalet Resort Chernomorets Geozashtita Varna EOOD Agropolychim JSC Bon Marine Logistic Business Trend Ltd Buy and Sell Ltd Company Elegance Ltd Eurolilni GPP Ltd. Varna Hydroremont OOD Varna Chamber of Commerce and Industry Caucasus Cable System Bulgaria Sport Club Cherno More Briz Ports Hunting and Fishing Association, Varna Galata Hunting Club Melrose Resources Bulgaria Shangrela EOOD First Investment Bank Private landowners Institute of Oceanology, Bulgarian Academy of Sciences (IOBAS) Technical University Varna Departments / Sub-Organisations Black Sea Diving Center Ltd Black Sea Scuba Scuba diving - Varna Dive Pro Ltd Diving Center Baracuda Ltd Varna Diving Centre Port of Varna JSC Navibulgar BMF Port Burgas

69 Stakeholder Category NGOs Other associations Intergovernmental associations Stakeholder Bulgarian Voluntary Search and Rescue Service (BULSAR) Public Environmental Centre for Sustainable Development Doze of Love Tourist Society Rodni Balkani Mayday Foundation Maritime Club Friends of the Sea Bulgarian Nudist Federation Bulgarian Association for Rural and Ecological Tourism Centre for Environmental Information and Education Bulgarian Society for the Protection of Birds Green Balkan Black Sea NGO Network World Wildlife Fund (WWF) Bulgaria (Sofia) Coalition for Sustainable Development Independent Public Control Nature for People National Commission for Combatting Trafficking in Human Beings Regional Roma Union Black Sea Centre for Environmental Education Green Policy Institute Sauchastie SOS Families at Risk Youth Information and Volunteer Centre Yugenpotokihorata.com Pensioner clubs in Asparuhovo and Galata The Commission on the Protection of the Black Sea Against Pollution Departments / Sub-Organisations

70

71 Appendix C: Completed Stakeholder Engagement Activities

72 Register of Stakeholder Engagement Activities (Up to 20 June 2014)* Date Consultation Stakeholder Name(s) Brief Description 5-Mar-2012 Outgoing Letter Ministry of Environment and Water Introductory letter 22-May-2012 Outgoing Letter Ministry of Environment and Water Introductory letter and meeting request 7-Jun-2012 Meeting Ministry of Environment and Water Introductory meeting 27-Jun-2012 Outgoing Letter Ministry of Environment and Water Submission of Project Investment Proposal 27-Jun-2012 Outgoing Letter Regional Administration of Varna Informing on Submission of Project Investment Proposal 27-Jun-2012 Outgoing Letter Municipality of Varna Informing on Submission of Project Investment Proposal 28-Jun-2012 Meeting Regional Administration of Varna Introductory meeting 28-Jun-2012 Meeting Governor of Varna Project introduced and initial contact made 29-Jun-2012 Public Announcement General Public Local media announcement: Project and EIA/ESIA process 29-Jun-2012 Meeting Regional Inspectorate of Environment and Water (Varna) Introductory meeting 13-Jul-2012 Outgoing Letter Regional Administration of Varna EIA/ESIA pre-scoping meeting request 13-Jul-2012 Outgoing Letter Municipality of Varna EIA/ESIA pre-scoping meeting request 13-Jul-2012 Outgoing Letter Black Sea Basin Directorate EIA/ESIA pre-scoping meeting request

73 Date Consultation Stakeholder Name(s) Brief Description 23-Jul-2012 Meeting Varna Regional Administration Black Sea Basin Directorate Regional Inspectorate of Environment and Water (Varna) Introductory meeting 23-Jul-2012 Meeting Municipality of Varna Introductory meeting 26-Jul-2012 Meeting Military Navy Regional Directorate of the Maritime Administration Agency Introductory meeting 26-Jul-2012 Meeting State Port Infrastructure Company Varna Institute of Fisheries Resources Introductory meeting 8-Aug-2012 Incoming Letter Municipality of Varna Comments from Project Notification period 23-Aug-2012 Meeting Ministry of Culture Introductory meeting 4-Sep-2012 Outgoing Letter Ministry of Transport, Communications and Information Technology Introductory letter: engagement with Maritime Administration 12-Sep-2012 Outgoing Letter Municipality of Varna Introductory information about the Project 19-Sep-2012 Outgoing Letter Ministry of Economy, Energy and Tourism Introductory letter and meeting request 19-Sep-2012 Outgoing Letter Ministry of Regional Development and Public Works Introductory letter and meeting request 19-Sep-2012 Outgoing Letter Ministry of Agriculture and Food Introductory letter and meeting request 20-Sep-2012 Outgoing Letter Executive Agency for Forestry Meeting request 20-Sep-2012 Outgoing Letter Executive Agency for Fisheries and Aquaculture Meeting request 21-Sep-2012 Meeting Regional Historic Museum of Varna Introductory meeting: archaeological surveys and data 21-Sep-2012 Outgoing Letter Bulgarian Agency for Investments Meeting request

74 Date Consultation Stakeholder Name(s) Brief Description 24-Sep-2012 Phone call Municipality of Varna Socio-economic data and Alternatives Assessment 24-Sep-2012 Meeting Mayoralty of Asparuhovo Socio-economic data and Alternatives Assessment 25-Sep-2012 Meeting Ministry of Agriculture and Food Introductory meeting: land use 25-Sep-2012 Meeting Executive Agency for Fisheries and Aquaculture Introductory meeting: fisheries 26-Sep-2012 Meeting Executive Agency for Forestry Introductory meeting: land use 28-Sep-2012 Incoming Letter Ministry of Environment and Water Information on EIA procedure, biodiversity act, Espoo. 4-Oct-2012 Outgoing Letter Ministry of Environment and Water Communication and interfaces procedures 5-Oct-2012 Outgoing Letter Municipality of Avren Introductory letter and meeting request 9-Oct-2012 Meeting Ministry of Regional Development and Public Works Introductory letter and meeting request 10-Oct-2012 Meeting Municipality of Avren Introductory letter and meeting request 29-Oct-2012 Outgoing Letter Municipality of Avren Socio-economic data request 2-Nov-2012 Incoming Letter Municipality of Varna Re socio-economic data request 12-Nov-2012 Incoming Letter Municipality of Avren Re socio-economic data request 13-Nov-2012 Phone call Mayoralty of Asparuhovo Socio-economic data; traffic studies 16-Nov-2012 Meeting Centre for Underwater Archaeology Cultural heritage sites and studies 21-Nov-2012 Outgoing Letter Mayoralty of Asparuhovo Socio-economic data request: villages in the municipality 27-Nov-2012 Outgoing Letter Mayoralty of Priseltsi Introductory letter

75 Date Consultation Stakeholder Name(s) Brief Description 27-Nov-2012 Outgoing Letter Mayoralty of Blisnatsi Introductory letter 10-Dec-2012 Outgoing Letter Regional Administration of Varna Introductory letter: new governor 11-Dec-2012 Meeting National Institute of Immovable Cultural Heritage Cultural heritage findings, spatial planning 12-Dec-2012 Meeting Executive Agency for Forestry Land use rights 13-Dec-2012 Meeting Ministry of Environment and Water Transboundary ESIA 14-Jan-2013 Meeting Ministry of Health Consultation on EIA Terms of Reference 15-Jan-2013 Meeting Black Sea Basin Directorate Consultation on EIA Terms of Reference 15-Jan-2013 Meeting Regional Water Company - Varna Consultation on EIA Terms of Reference 15-Jan-2013 Meeting Mayoralty of Asparuhovo Socio-economic data collection; Organization of scoping public consultations 16-Jan-2013 Meeting Regional Inspectorate of Environment and Water (RIEW) (Varna) Consultation on EIA Terms of Reference 17-Jan-2013 Meeting Ministry of Environment and Water Appropriate Assessment procedures: Natura 2000, Protected Areas 21-Jan-2013 Letter and Deliverable Ministry of Environment and Water Submission of EIA Terms of Reference 21-Jan-2013 Phone call Mayoralty of Asparuhovo Dissemination of EIA Terms of Reference 23-Jan-2013 Phone call Mayoralty of Asparuhovo Meeting organization 23-Jan-2013 Phone call Mayoralty of Priseltsi Dissemination of EIA Terms of Reference 23-Jan-2013 Hand Delivery Multiple, including: Pensioner clubs in Asparuhovo and Galata High schools in Asparuhovo and Galata Announcement: EIA Terms of Reference disclosure, invitation to comment

76 Date Consultation Stakeholder Name(s) Brief Description Galata cultural center Asparuhovo cultural center 23-Jan-2013 Outgoing Letters Local Authorities: Regional Administration of Varna Municipality of Varna Municipality of Avren Mayoralty of Asparuhovo Mayoralty of Priseltsi Black Sea Basin Directorate Regional Inspectorate of Environment and Water ( Varna) Regional Forest Directorate Civil Protection Varna Regional Water Company Varna Announcement: EIA Terms of Reference disclosure, invitation to comment and meeting request 23-Jan-2013 Outgoing Letter NGOs: Public Environmental Centre for Sustainable Development Tourist Society Rodni Balkani Mayday Foundation Marine Club / Friends of the Sea Black Sea NGO Network Bulgarian Nudist Federation Bulgarian Association for Rural and Ecological Tourism Centre for Environmental Information and Education Bulgarian Society for the Protection of Birds Green Balkan Announcement: EIA Terms of Reference disclosure, invitation to comment and meeting request 23-Jan-2013 Outgoing Letter Marine Authorities: Maritime Administration Varna Executive Agency of Fisheries and Aquaculture Military Navy State Port Infrastructure Company Varna Announcement: EIA Terms of Reference disclosure, invitation to comment and meeting request 23-Jan-2013 Outgoing Letter Marine Users and Business: Fisheries Association 'BG Fish' Fisheries Association 'Ada Bacha' Varna Chamber of Commerce Announcement: EIA Terms of Reference disclosure, invitation to comment and meeting request

77 Date Consultation Stakeholder Name(s) Brief Description Varna Chamber of Tourism Chalet resort Chernomorets Varna Yacht Club Sailing clubs x4 Diving clubs x6 23-Jan-2013 Outgoing Letter Ministry of Environment and Water EIA Terms of Reference provided: invitation to review 23-Jan-2013 Outgoing Letter Executive Environment Agency EIA Terms of Reference provided: invitation to review 23-Jan-2013 Outgoing Letter Ministry of Culture EIA Terms of Reference provided: invitation to review 23-Jan-2013 Outgoing Letter Ministry of Economy, Energy and Tourism EIA Terms of Reference provided: invitation to review 23-Jan-2013 Outgoing Letter Ministry of Health EIA Terms of Reference provided: invitation to review 23-Jan-2013 Public announcement General Public Press Release: EIA Terms of Reference disclosure, invitation to comment 24-Jan-2013 Meeting Mayoralty of Asparuhovo Establishment of comment stations 24-Jan-2013 Meeting Mayoralty of Priseltsi Establishment of comment stations 24-Jan-2013 Phone call Galata Cultural Centre Establishment of comment stations 24-Jan-2013 Meeting Galata Cultural Centre Establishment of comment stations 25-Jan-2013 Public announcement General Public Announcement in local newspapers: EIA Terms of Reference disclosure, invitation to comment 29-Jan-2013 Meeting Regional Administration of Varna Introductory meeting 31-Jan-2013 Outgoing Letter Black Sea NGO Network EIA Terms of Reference disclosure, Invitation to comment 31-Jan-2013 Incoming Letter Ministry of Environment and Water Comments on EIA Terms of Reference

78 Date Consultation Stakeholder Name(s) Brief Description 1-Feb-2013 Letter and Deliverable Ministry of Environment and Water Submission of Espoo Notification Document 1-Feb-2013 Incoming Letter Ministry of Health Comments on EIA Terms of Reference 4-Feb Received Executive Environment Agency EIA Terms of Reference receipt 5-Feb-2013 Outgoing Letter Executive Environment Agency EIA Terms of Reference submission letter 5-Feb-2013 Meeting Various local stakeholders: Water Supply and Sewerage - Varna Regional Forest Directorate - Varna Regional Inspectorate of Environment and Water - Varna Youth Information and Volunteer Center Business Trend Ltd Black Sea Basin Directorate Asparuhovo Region Avren Municipality Priseltzi Municipality Fire Safety and Civil Protection Regional Office Regional Administration Varna Roundtable meeting 5-Feb-2013 Meeting Various Businesses and Marine Users: Oceanology Institute Bulyard Dive Pro Ltd Aquanaut Ltd Black Sea Diving Center Ltd ELECTA JSC Diving Center Barracuda Ltd Fisheries association 'Odessos' Fisheries association 'BG Fish' Sport Club Cherno More Briz Devnya Cement Varna Diving Center Port of Varna JSC Roundtable meeting

79 Date Consultation Stakeholder Name(s) Brief Description Bulgarian Marine Chamber Varna Chamber of Commerce and Industry 6-Feb-2013 Meeting Galata Community Community meeting 6-Feb-2013 Meeting Various Marine Authorities Roundtable meeting Marine Administration; Naval Forces (under MOD); Port Infrastructure; Agropolychim JSC; 6-Feb-2013 Phone call Worldwide Fund for Nature (WWF) Comments on EIA Terms of Reference 6-Feb-2013 Comment Form Received Bulgarian Citizen (Female) Scoping Comment Form 6-Feb-2013 Comment Form Received Bulgarian Citizen (Male) Scoping Comment Form 6-Feb-2013 Meeting NGOs: Maritime Club Friends of the Sea Mayday Foundation Public Center on Environment and Sustainable Development Black Sea NGO Network Bulgarian Society for the Protection of Birds Rodni Balkani Society Black Sea Center for Environmental Education and Information Green Policy Institute Roundtable meeting 7-Feb-2013 Meeting Priseltsi Community Community meeting 13-Feb received Employee of Municipality of Varna Gas Department Comments on EIA Terms of Reference 14-Feb-2013 Espoo Submission Ministry of Environment and Water Submission of Espoo Notification document

80 Date Consultation Stakeholder Name(s) Brief Description 15-Feb-2013 Meeting Ministry of Environment and Water EIA; Espoo notification 15-Feb Received Resident of Rakitnika 1 Comments on EIA Terms of Reference 18-Feb-2013 Meeting Centre for Underwater Archaeology Cultural Heritage 20-Feb-2013 Incoming Letter Maritime Administration Varna Comments on EIA Terms of Reference 21-Feb Received Resident of Rakitnika 1 Comments on EIA Terms of Reference 21-Feb Received Resident of Rakitnika 2 Comments on EIA Terms of Reference 21-Feb Received Black Sea NGO Network Comments on EIA Terms of Reference 22-Feb-2013 Meeting Ministry of Environment and Water Natura 2000: Appropriate Assessment 22-Feb Received Resident of Rakitnika 1 Comments on EIA Terms of Reference 22-Feb Sent Resident of Rakitnika 1 Response to comments on EIA Terms of Reference 22-Feb-2013 Incoming Letter Ministry of Environment and Water Espoo notification in Romania 28-Feb-2013 Meeting Bulgarian Search and Rescue Service (BULSAR) Cultural Heritage; Permitting 1-Mar Sent Resident of Rakitnika 1 Detailed answers to comments on EIA Terms of Reference 7-Mar Sent Resident of Rakitnika 1 Response to comments on EIA Terms of Reference (Bulgarian translation) 7-Mar-2013 Incoming Letter Executive Environment Agency Comments on EIA Terms of Reference 27-Mar-2013 Meeting Ministry of Environment and Water EIA Table of Contents 29-Apr-2013 Meeting Ministry of Health Public health and risk assessment

81 Date Consultation Stakeholder Name(s) Brief Description 30-Apr-2013 Meeting Centre for Underwater Archaeology (under MoC) Underwater cultural heritage plan 10-May-2013 Public announcement Ministry of Environment and Water Espoo Notification on website 17-May-2013 Public announcement Ministry of Environment and Water Espoo: Romanian Government response on website 28-May-2013 Incoming Letter Ministry of Environment and Water Espoo: Romanian Government response; Project of National Importance requirements 7-Jun-2013 Incoming Letter Executive Agency for Forestry Land use 11-Jun-2013 Meeting Fisheries Association Ada Bacha Socio-economic data collection: fishing and livelihoods 12-Jun-2013 Meeting Municipality of Varna Socio-economic data collection meeting: tourism 12-Jun-2013 Meeting Regional Directorate of the Ministry of Interior (Varna Police) Socio-economic data collection: road safety, crimes rates 12-Jun-2013 Meeting Varna Chamber of Commerce and Industry Socio-economic data collection: economy and industry 14-Jun-2013 Phone call Ministry of Environment and Water EIA Project notification to Municipalities 17-Jun-2013 Mail Sent Ministry of Environment and Water Appropriate Assessment and EIA: Table of Contents and Methodology 26-Jun Sent Ministry of Environment and Water Appropriate Assessment and EIA: Table of Content and Methodology 12-Aug-2013 Phone call Sever Export Fleet and fishing data 14-Aug-2013 Meeting Fisheries Association Ada Bacha Meeting and Information request: Fishing 15-Aug-2013 Outgoing Letter Municipality of Varna Introductory letter and meeting request 15-Aug-2013 Outgoing Letter Regional Administration of Varna Introductory letter and meeting request

82 Date Consultation Stakeholder Name(s) Brief Description 16-Aug-2013 Outgoing Letter Sever Export Introductory letter 16-Aug-2013 Outgoing Letter Black Sea NGO Network Meeting request 18-Aug Received Black Sea NGO Network Meeting coordination 28-Aug-2013 Outgoing Letter Ministry of Defence Meeting to establish contact 28-Aug-2013 Outgoing Letter Ministry of Culture Meeting to establish contact 28-Aug-2013 Outgoing Letter Ministry of Economy and Energy Meeting to establish contact 28-Aug-2013 Outgoing Letter Ministry of Agriculture and Food Meeting to establish contact 28-Aug-2013 Outgoing Letter Ministry of Interior Meeting to establish contact 28-Aug-2013 Outgoing Letter Ministry of Environment and Water Meeting to establish contact 28-Aug-2013 Outgoing Letter Ministry of Health Meeting to establish contact 28-Aug-2013 Outgoing Letter Ministry of Regional Development Meeting to establish contact 28-Aug-2013 Outgoing Letter Ministry of Transport and IC&T Meeting to establish contact 3-Sep Meeting Municipality of Varna Meeting to establish contact 3-Sep Meeting Regional Administration of Varna Meeting to establish contact 5-Sep Meeting Centre for Underwater Archaeology Nearshore Cultural Heritage surveys 8-Oct Meeting Executive Forest Agency Reforestation on construction areas 8-Oct Meeting Ministry of Environment and Water New trenchless shore crossing option and planned re-submission of EIA

83 Date Consultation Stakeholder Name(s) Brief Description 10-Oct Meeting Black Sea Basin Directorate New trenchless shore crossing option and water supply 10-Oct Meeting North Eastern Forestry Company in Shumen Reforestation 14-Oct Meeting Natura 2000 Department (under MOEW) New trenchless shore crossing option and planned re-submission of EIA. 5-Nov Meeting Municipality of Avren Start of EIA Public Consultation process 5-Nov Meeting Mayoralty of Priseltsi Start of EIA Public Consultation process 5-Nov Meeting Municipality of Varna Start of EIA Public Consultation process 5-Nov Meeting Regional Administration of Varna Start of EIA Public Consultation process 21-Nov Meeting National Commission for Combating Trafficking in Human Beings Socio-economic data collection: commercial sex workers on Route 9 27-Nov-2013 Meeting Media Meeting Update on Project 2-Dec-2013 Outgoing Letter Regional Historic Museum Varna CHO finds 6-Dec-2013 Outgoing Letter Regional Administration of Varna Answer to questions from Varna citizens and request for a meeting 13-Dec received Local resident B with comments and questions on EIA report 13-Dec-2013 Incoming Letter Regional Historic Museum Varna Cultural Heritage finds on Pasha Dere beach and monitoring requirements 16-Dec-2013 Outgoing Letter Local resident A Answer to comments and concerns to the ToR of the EIA 17-Dec-2013 Meeting Centre for Underwater Archaeology (under MoC) Underwater Cultural Heritage 17-Dec-2013 Outgoing Letter Various stakeholders General invitation letter to the EIA public hearings 17-Dec received Black Sea NGO Network Answer to meeting request

84 Date Consultation Stakeholder Name(s) Brief Description 18-Dec sent Local resident B Answer to comments and concerns on the EIA report 19-Dec-2013 Meeting Regional Historic Museum Varna Cultural Heritage finds on Pasha Dere beach and monitoring requirements 19-Dec-2013 Meeting Black Sea NGO Network Update meeting 19-Dec-2013 Incoming Letter Ministry of Environment and Water Positive evaluation of EIA report 19-Dec-2013 Public Hearing Municipality of Varna EIA Public Hearings 20-Dec-2013 Public Hearing Mayoralty of Priseltsi EIA Public Hearings 25-Dec received Local resident C with statements and comments on the EIA report 27-Dec-2013 Outgoing Letter Municipality of Varna Letter with notes and statements from Public Hearings 27-Dec-2013 Outgoing Letter Municipality of Avren Letter with notes and statements from Public Hearings 27-Dec-2013 Outgoing Letter Mayoralty of Asparuhovo Letter with notes and statements from Public Hearings 27-Dec-2013 Outgoing Letter Mayoralty of Priseltsi Letter with notes and statements from Public Hearings 27-Dec-2013 Outgoing Letter Ministry of Environment and Water Letter with notes and statements from Public Hearings 27-Dec received Local resident D with statements and comments on the EIA report 27-Dec-2013 Incoming Letter Local resident A Letter with statements and comments on the EIA report 27-Dec-2013 Incoming Letter Local resident B Letter with statements and comments on the EIA report 30-Dec-2013 Outgoing Letter Ministry of Environment and Water Letter with SSTTBV answers to comments from Public consultations 06-Jan received Local resident E with statements and comments on the EIA report

85 Date Consultation Stakeholder Name(s) Brief Description 08-Jan-2014 Incoming Letter Ministry of Environment and Water Date and agenda for the meeting with Supreme Expert Environmental Council 09-Jan received Local resident F with statements and comments on the EIA report 09-Jan received Local resident G with statements and comments on the EIA report 10-Jan received Local resident H with statements and comments on the EIA report 10-Jan received Local resident I with statements and comments on the EIA report 10-Jan received Local resident J with statements and comments on the EIA report 10-Jan-2014 Incoming Letter Ministry of Environment and Water On provision of comments and responses to the EIA 14-Jan-2014 Outgoing Letter Centre for Underwater Archaeology (under MoC) UXO surveys and monitoring of works 16-Jan-2014 Outgoing Letter Executive Forest Agency Land use and easements 20-Jan-2014 Outgoing Letter Ministry of Environment and Water Reply letter to the invitation to the SEEC 20-Jan-2014 Outgoing Letter Ministry of Environment and Water Letter with SSTTBV answers to comments from Public consultations received between 27 Dec and 10 January (best practice) 22-Jan-2014 Outgoing Letter Municipality of Varna Letter with SSTTBV answers to comments from Public consultations received between 27 Dec and 10 January (best practice) 22-Jan-2014 Outgoing Letter Municipality of Avren Letter with SSTTBV answers to comments from Public consultations received between 27 Dec and 10 January (best practice) 22-Jan-2014 Outgoing Letter Municipality of Asparuhovo Letter with SSTTBV answers to comments from Public consultations received between 27 Dec and 10 January (best practice) 22-Jan-2014 Outgoing Letter Municipality of Priseltsi Letter with SSTTBV answers to comments from Public consultations received between 27 Dec and 10 January (best practice)

86 Date Consultation Stakeholder Name(s) Brief Description 24-Jan-2014 Meeting MOEW Supreme Environmental Expert Council (SEEC) meeting on evaluation of EIA 6-Feb-2014 Outgoing Letter Local resident A Answers to comments and questions on EIA report 6-Feb-2014 Outgoing Letter Local resident B Answers to comments and questions on EIA report 7-Feb-2014 Milestone Ministry of Environment and Water EIA Permit approved and signed. Communication is made on MOEW website and Newspaper. 10-Feb-2014 Outgoing Local resident A Answers to comments and questions on EIA report 10-Feb-2014 Outgoing Local resident B Answers to comments and questions on EIA report 10-Feb-2014 Outgoing Local resident C Answers to comments and questions on EIA report 10-Feb-2014 Outgoing Local resident D Answers to comments and questions on EIA report 10-Feb-2014 Outgoing Local resident E Answers to comments and questions on EIA report 10-Feb-2014 Outgoing Local resident F Answers to comments and questions on EIA report 10-Feb-2014 Outgoing Local resident G Answers to comments and questions on EIA report 10-Feb-2014 Outgoing Local resident H Answers to comments and questions on EIA report 10-Feb-2014 Outgoing Local resident E Answers to comments and questions on EIA report 12 Feb 2014 Meeting Regional Historic Museum of Varna Archaeological surveys 12-Feb-2014 Meeting State Forest Office - Varna Forest management and archaeological surveys 14 Feb 2014 Meeting Ministry of Environment and Water EIA and DDP comparison for DDP Approval 18-Feb-2014 Outgoing Local resident B Answers to comments and questions on EIA report

87 Date Consultation Stakeholder Name(s) Brief Description 19 Feb 2014 Incoming Letter Regional Inspectorate of Environment and Water - Varna Meeting confirmation Environmental monitoring 21 Feb 2014 Meeting Ministry of Environment and Water On EIA Decision take into effect date 25 Feb 2014 Meeting Regional Inspectorate of Environment and Water - Varna Environmental monitoring 25 Feb 2014 Meeting Romani people Expert Socio-economic baseline data collection - Livelihoods 25 Feb 2014 Meeting State Forest Office - Varna Socio-economic baseline data collection Foret use 26 Feb 2014 Meeting SOS Families at Risk Socio-economic baseline data collection Vulnerable people 26 Feb 2014 Meeting Mayoralty of Priseltsi Project update and impacts management 26 Feb 2014 Meeting Chamber of Commerce and Industry - Varna Local employment and sourcing 26 Feb 2014 Outgoing Letter Varna Local Employment Office Meeting request 26 Feb 2014 Outgoing Letter Varna Regional Employment Agency Meeting request 26 Feb 2014 Outgoing Letter Social Activities Directorate - Varna Municipality Meeting request 05 Mar 2014 Meeting Sauchastie Socio-economic baseline data collection 05 Mar 2014 Meeting Varna Regional Employment Agency Local employment 05 Mar 2014 Meeting Social Activities Directorate - Varna Municipality Local employment and Vulnerables 06 Mar 2014 Meeting Hunting and Fishing Association, Varna and Galata Hunting Club Forest use for hunting around Landfall area 07 Mar 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Environmental surveys week 1 & 2 12 Mar 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Environmental surveys week 3

88 Date Consultation Stakeholder Name(s) Brief Description 12 Mar 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Forest management program 12 Mar 2014 Meeting Ministry of Environment and Water Relocation plan for protected species 14 Mar 2014 Outgoing Hunting and Fishing Association, Varna Update on Project and hand delivery of information material 18 Mar 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Environmental surveys week 4 21 Mar 2014 Meeting Regional Inspectorate of Environment and Water - Varna Relocation plan for protected species 31 Mar 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Environmental monitoring week 5 4 Apr 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Environmental monitoring week 6 11 Apr 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Environmental monitoring week 7 29 Apr 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Environmental monitoring week 8 30 Apr 2014 Outgoing Letter Ministry of Environment and Water Meeting request for Export Credit Agencies environmental due diligence 30 Apr 2014 Outgoing Letter Port of Varna Meeting request for Export Credit Agencies environmental due diligence 30 Apr 2014 Outgoing Letter Port of Burgas Meeting request for Export Credit Agencies environmental due diligence 07 May 2014 Meeting Police of Burgas Socio-economic data collection meeting for Burgas mini environmental assessment 08 May 2014 Meeting Municipality of Burgas Socio-economic data collection meeting for Burgas mini environmental assessment 08 May 2014 Meeting Doze of Love Socio-economic data collection meeting for Burgas mini environmental assessment

89 Date Consultation Stakeholder Name(s) Brief Description 08 May 2014 Meeting Regional Roma Union Socio-economic data collection meeting for Burgas mini environmental assessment 09 May 2014 Meeting National Commission for Combating Trafficking in Human Beings Socio-economic data collection meeting for Burgas mini environmental assessment CSWs in Burgas 12 May 2014 Outgoing Letter Regional Inspectorate of Environment and Water - Varna Environmental monitoring final report 18 June 2014 Meeting National Commission for Combating Trafficking in Human Beings Discussion of provision of sexual health awareness training to Project workforce and communication of traffic awareness to CSWs 19 th June 2014 Meeting Social Activities Directorate - Varna Municipality Discussion of procedure for donation of wood to local communities and social service organisations 19 th June 2014 Meeting Sauchastie Discussion of procedure for donation of wood to local Roma community 19 th June 2014 Meeting Childrens Tours Oranisation Introduction and update on construction schedule and specific discussion of road access and potential impacts on childrens tour activities 20 th June 2014 Meeting Sauchastie Emergency Meeting to discuss assistance and donation to Roma community following Varna flooding and mudslide 20 th June 2014 Phone Call Bulgarian Red Cross Arrangements for financial and in kind donations to relief effort following Varna flooding and mudslide *As of 30 May, 2013 the following ministries changed their names: the Ministry of Economy and Energy (from the Ministry of Economy, Energy and Tourism), and the Ministry of Regional Development (from the Ministry of Regional Development and Public Works). ** The table does not include correspondence or meetings specifically related to baseline data collection, clarification, information requests or permitting procedures.

90

91 Appendix D: Summary of Comments and Responses

92 Appendix D.1 Comments Received from National, Regional and Local Authorities 2 Comments Consideration and Response Design Questions regarding water supply (drinking / sanitary) for the construction areas and landfall facilities, and about potential impacts on the water utility zone. South Stream Transport is working with ViK-Varna to ensure that the Project does not interfere with existing or planned infrastructure and activities, and that the applicable permitting procedures are followed. South Stream Transport have ensured that Project engineers provide the relevant authorities with the exact location of the pipeline route. Where infrastructure (e.g. water mains) is located, South Stream Transport will engage with the relevant agency and ensure that the appropriate permits and procedures are implemented B-ESIA This information has been communicated to the relevant authority (Vik-Varna) through meetings and other correspondence, and is described in Chapter 5 Project Description. Could the pipelines be spaced closer together to reduce the width of the Right-of-Way (RoW)? The design has taken into consideration the requirements of Bulgarian Ordinance No. 16 and related engineering standards. The RoW is in accordance with these parameters and cannot be reduced any further. Environment Question about water quality impacts at Pasha Dere Beach (specifically in terms of bathing water quality standards) during construction. All vessels used by the Project and its contractors will adhere to the requirements of MARPOL and Bulgarian national regulations. Vessels will comply with the requirements for discharge of ballast, bilge and waste water. In addition, any discharge of treated or untreated sewage will be prohibited within 2 NM from the shore B-ESIA Impacts to water quality are assessed in the EIA and ESIA. No significant impacts on bathing water quality at Pasha Dere Beach are anticipated. Further information is provided in Chapter 12 Marine Environment. Questions about the amount of dredged material, the content of the sediments, and the potential that contaminants (if present in the sediments) could be released into the environment. As part of the EIA and ESIA processes, sediment dispersion modelling was undertaken to determine the potential extent and impact of sediments and water quality. No significant impact is expected. This information is described further in Chapter 12 Marine Environment and has been discussed with the relevant authorities. A Dredging Management Plan will be developed once the dredging contractor has been appointed and the dredging plant identified. This will be developed in collaboration with the regulatory authority B-ESIA Where Chapters are referred to, consult the ESIA Report for further information.

93 Comments Vegetation clearance and tree cutting must be undertaken with the proper notifications and approvals, and with appropriate protection to terrestrial habitats. Consideration and Response The impacts of vegetation clearance and tree cutting on local habitats and species are assessed in Chapter 11 Terrestrial Ecology. All activities will be coordinated with, and reported to, the relevant authorities. Appropriate measures to mitigate any impact will be included in a comprehensive plan to restore the area, which will be agreed in advance with the responsible authorities. It will include a monitoring plan for recovery (where possible) of vegetation and compensatory afforestation after construction B-ESIA Safety Questions about emergency response measures in regard to pipeline leaks and ruptures, as well as potential for corrosion of the pipelines, and security issues relating to pipeline welding. South Stream Transport has committed to designing, building and operating the Pipeline according to strict quality and safety standards. The Pipeline will be built in accordance with pipeline industry standards, notably those of Det Norske Veritas (DNV), and European Standards (EN) for additional guidance where necessary. B-ESIA Monitoring, inspection, corrosion control and other design details are provided in Chapter 5 Project Description. This information has also been discussed with interested stakeholders. The ESIA also includes an assessment of potential impacts associated with unplanned events such as a gas leak. Emergency Response Plans will also be implemented and are described in Chapter 20 Unplanned Events. B-ESIA Pasha Dere Beach Concerns that since Pasha Dere Beach is a popular summer recreational area, construction would disrupt use of the beach. Due to a significant change in the design of the shore crossing (from open-cut to microtunnelling), the beach will no longer be closed during construction. Microtunnelling will allow the pipelines to cross Pasha Dere Beach without any disturbance to the beach or the cliff. Noise Question about potential noise disturbance from the Project, including noise from construction activities. To minimise noise disturbance, temporary noise barriers and soil screening bunds will be erected. Noise emissions will also be considered as part of the selection of the construction plant (equipment and machinery) and the orientation of the plant B-ESIA Noise impacts will be short-term and temporary and are assessed in Chapter 10 Noise and Vibration.

94 Appendix D.2 Summary of Public and Other Stakeholder Comments Comments Consideration and Response Environment and Ecology Concern that construction activities could disrupt seasonal ecological activities, such as breeding and migrations. A number of ecological surveys have been undertaken to inform the assessments of impacts on terrestrial and marine ecology. Mitigation measures have been designed to avoid and minimise impacts; these measures include the relocation of protected plants and animals, among others. These activities are being coordinated with the relevant authorities and are described in Chapter 12 Terrestrial Ecology and Chapter 13 Marine Ecology. Potential impact on national air emissions and climate change. Air emissions studies and impact assessments have been carried out as part of the EIA and ESIA processes. These studies have concluded that construction of the Project is predicted to increase national reported emissions of NOX and CO2 by less than 0.5% of national emissions. Monitoring activities will quantify direct emissions from the Project. Emissions and related impacts are described further in Chapter 9 Air Quality. Questions about environmental protection (terrestrial and marine), including the Project s approach to ecosystem protection and environmental management. The EIA and ESIA processes have assessed potential impacts on the environmental and ecosystems. These assessments are described in Chapter 12 Marine Environment, Chapter 13 Marine Ecology, Chapter 11 Terrestrial Ecology, and Chapter 18 Ecosystem Services. Each assessment identifies the mitigation and management measures that will be used to minimise potential impacts, as well as monitoring measures that will be applied throughout construction and operation of the Project. Potential impact on air quality in case of unplanned release of gas through the vent stack. Under normal operating conditions, there will be no routine emissions of gas. Venting will only take place during planned maintenance or shutdown activities that may require gas within certain areas of the landfall facilities to be released to atmosphere. There is no expected impact on air quality. Potential impacts on air quality are discussed in Chapter 9 Air Quality. In the very unlikely event of a leak or rupture, the Pipeline will be shut down immediately. It is not expected that any unplanned emissions would affect the air quality in the region. Potential impacts related to unplanned events are discussed in Chapter 20 Unplanned Events.

95 Comments Consideration and Response Potential impact of Project on regional water resources, including groundwater. Groundwater installations in the region draw water from a depth of more than 60 m and have sufficient resources; this is much deeper than any Project activity or infrastructure. The Project does not fall within the sanitary protection area of any water sources. The EIA and ESIA processes have evaluated the potential impacts of the Project on groundwater and other water resources. Chapter 7 Physical and Geophysical Environment describes the related studies and impacts, and concludes that the Project will not have an effect on water supply in the region. Potential impacts of the Project on protected areas, particularly in relation to the Natura 2000 area and the national protected areas of Rakitnik and Liman. Natura 2000 regulations do not prohibit development within Natura 2000 sites. However, an Appropriate Assessment is required to demonstrate that the integrity of the site will not be compromised by development was undertaken in line with applicable EU legislation. The findings of the Appropriate Assessment confirm that the impacts are acceptable and consistent with the objectives of the Natura 2000 designated sites. These assessments are included in the EIA and ESIA processes. South Stream Transport is working with the relevant authorities in Bulgaria to ensure that protected areas, habitats and species are properly managed and protected. Potential impacts on these protected areas are described in Chapter 11 Terrestrial Ecology. Marine protected areas are described in Chapter 13 Marine Ecology. Mitigation and management measures will be included in a Biodiversity Action Plan and Restoration and Remediation Plan B-ESIA Potential impact of the Project on water quality of the nearshore section. The EIA and ESIA processes have evaluated the potential for impacts on water quality, including sedimentation and other changes that may affect people swimming near the beach. This assessment is described in Chapter 12 Marine Environment; potential health effects are considered in Chapter 16 Community Health, Safety and Security. No significant impacts are expected. The quality of the water in the nearshore section will be monitored during the construction of the Pipeline and the results will be reported to the respective competent authorities. B-ESIA-6-048

96 Comments Consideration and Response Questions regarding potential noise and ecological impacts in relation to the landfall facilities and the neighbouring Varna Compressor Station. The landfall section of the Project comprises approximately 3 km of buried Pipeline on land, which ends at the South Stream Transport landfall facility and which includes infrastructure such as metering stations. Adjacent to the landfall facility is the Pasha Dere Receiving Terminal (RT) and the Varna CS, both of which are part of the onshore pipeline being developed by SSB. SSB conducted an EIA for the onshore pipeline, including the Varna CS, which was publicly disclosed in accordance with the Bulgarian EIA procedure. SSB are also subject to Bulgarian requirements for noise emission limits. Noise and ecological impacts associated with the Project s landfall facilities are described in Chapter 10 Noise and Vibration and Chapter 11 Terrestrial Ecology. The majority of noise generation is related to the Construction and Pre-Commissioning Phase and will be short term and temporary. While the Varna CS is outside the scope of the Project (as developed by SSB), the combined impacts of the offshore Project and the SSB infrastructure have been assessed in a Cumulative Impact Assessment. This is described in Chapter 21 Cumulative Impact Assessment. Additionally, the neighbouring facilities of SSB (including the Pasha Dere RT and Varna CS) are further discussed in Appendix 21.1: Environmental Assessment of the Pasha Dere Receiving Terminal and Varna Compressor Station. South Stream Transport is working with SSB to jointly manage impacts in the vicinity of the landfall facilities. Noise impacts from construction and operation of the Project, as well as the neighbouring compressor station. Potential noise impacts were assessed in both the EIA and ESIA processes. Noise impacts from the Project during the Construction and Pre-Commissioning Phase will be short-term and temporary, and are not expected to exceed the applicable national and international noise standards. To minimise noise disturbance, temporary noise barriers and soil screening bunds will be erected. Careful consideration has been given to the selection and orientation of construction activities and equipment, so as to minimise noise emissions B-ESIA The Project will also monitor noise emissions throughout the Construction and Pre-Commissioning Phase to ensure that the mitigation measures implemented are effective B-ESIA Noise impacts and mitigation measures are described in Chapter 10 Noise and Vibration. The Varna CS is not within the scope of the Project; it is part of the onshore pipeline being developed by SSB. Noise emissions related to the Varna CS were included in the EIA for this pipeline. South Stream Transport has also considered the potential for cumulative impacts as part of the EIA and ESIA reports for the Project, as described in Chapter 21 Cumulative Impact Assessment. In addition to EIA and ESIA reports, this information has frequently been discussed in meetings with stakeholders, including community meetings.

97 Comments Consideration and Response Impacts related to underwater noise emissions during construction and how this will be mitigated. Underwater noise emissions during construction have been modelled, and impacts on marine species are assessed in the EIA and ESIA processes. This is described in Chapter 13 Marine Ecology. The assessment has determined that noise from Project activities is unlikely to cause injury or mortality to fish or other species. However, the Project will still develop and adopt a Code of Good Practice for vessels operating near marine mammals B-ESIA Project Design and Location Questions regarding the routing of the pipeline and the location of the landfall facilities in the Varna area, and the consideration of alternative routes and locations. Concern about the proximity of the Project to the city of Varna. When defining the route, the technically and financially feasible alternatives were considered along with the related environmental and social characteristics and issues (including proximity to residential areas). This process is described in Chapter 4 Analysis of Alternatives of both the EIA and ESIA reports. These studies concluded that the selected landfall location south of Varna provided the optimal solution along the Bulgarian Black Sea coast. The Project is compliant with the Bulgarian and European safety standards in relation to the distances from nearest settlements. Information about Project alternatives, the selection of the landfall location, safety standards, and impacts on communities have been discussed in previous meetings, including community meetings related to the Scoping Report and draft EIA Report. Potential impacts on residents of nearby communities, and how these will be mitigated, are described in Chapter 15 Socio-Economics. EIA and ESIA Processes and Reports Questions regarding the split of the Project between South Stream Transport (offshore, with short onshore section) and South Stream Bulgaria AD (onshore pipeline through Bulgaria). Why are there two Project and two EIAs? The entire South Stream Pipeline System spans over 2,300 km, crossing a number of countries and different geographies to transport natural gas from Russia to the countries of Central and South-Eastern Europe. It is not unusual for a project of this size to be divided into separate elements due to the fact every country has its own regulations in which the Project must comply. In addition, the offshore engineering and environmental work is technically very different from the onshore work and passes through three different state jurisdictions. In terms of the EIA procedure, splitting the Project is in accordance with European legislation and the Aarhus Convention. The EIA Report considers the facilities of the infrastructure being developed by SSB and assesses the cumulative impacts of both projects onshore and offshore. South Stream Transport is working closely with SSB to jointly manage impacts in the vicinity of the landfall facility. This will include ensuring that all contractors work under an overarching set of management plans.

98 Comments Consideration and Response It is important to consider the cumulative impacts, and provide mitigation measures to manage these impacts. Cumulative impacts are assessed in both the EIA and ESIA processes. These impacts are described in Chapter 21 Cumulative Impact Assessment. What is the status of the national EIA Report? Following the EIA public comment period and public hearings, the EIA Report and comments / responses were provided to the MoEW. The Supreme Expert Environmental Council at the MoEW approved the EIA Report on 24 January 2014 and the MoEW issued the EIA Permit for the Project on 7 February This information has been provided in meetings based on the current status of the report. Health and Safety Concerns about safety and the risks associated with a high pressure gas pipeline (e.g. gas leaks or explosions). Safety has been a major factor in the design of the Project, which has been verified by independent experts. The Pipeline is designed to be one of the safest means of transporting gas and there are many controls in place (including throughout manufacturing and construction) to ensure the quality of all components. As such, a gas leak or explosion is very unlikely. However, the potential risks and impacts of unplanned events are assessed in the EIA and ESIA processes, and described in Chapter 20 Unplanned Events along with management and emergency response measures. Potential health risks related to incoming workers, prostitution, and the abuse of drugs and alcohol. All workers contracted or sub-contracted for this Project will be subject to a Worker Code of Conduct, and required to attend an awareness and education programme that covers the risks associated with sexually transmitted infections (STIs), prostitution, alcohol and drugs B-ESIA South Stream Transport will also work with local service organisations on issues related to worker and community health and safety, including organisations focused on commercial sex workers. Potential impacts are assessed in Chapter 16 Community Health, Safety and Security. Design and Schedule Questions about the duration of construction works and whether construction will occur during the summer season. The construction of the four microtunnels, including the entry and exit shafts, will take around one year, which will overlap with one summer season. The access to the beach and forest will not be restricted, although there may be some limitations in specific areas. The construction of the landfall section will take around nine months. The anticipated schedule is described in the EIA and ESIA reports in Chapter 5 Project Description.

99 Comments Consideration and Response Questions about the extent of the safety exclusion zones, and what areas will be fenced. In the sea, there will be a safety exclusion zone of approximately 2 km (1.1 NM) radius (depending on the depth of water and extent of the anchor spread) around the pipe-lay vessel during construction. During operations, this will decrease to 500 m on either side of each pipeline. On land, the construction corridor and construction areas will be fenced during construction for safety reasons. During operations, only the landfall facilities will be fenced, although safety exclusion zones around the landfall section will restrict certain types of development. Exclusion zones are described in Chapter 5 Project Description and impacts of these restrictions in terms of land and marine area use are assessed in Chapter 15 Socio-Economics. Questions about the activities that will be restricted by the permanent marine safety exclusion zone. To ensure that the subsea pipelines are not damaged by, or do not damage to, other equipment (e.g. anchors, fishing gear, etc.), there will be some restrictions on certain activities while the Pipeline is operational. In general, activities which could physically impact the Pipeline (e.g. bottom trawling, anchoring, oil and gas exploration) will be restricted, but other activities (e.g. line fishing, boating) will not be affected. The proposed exclusion zones will be agreed in consultation with the appropriate authorities. It is anticipated that the exclusion zone will extend to 0.5 km (0.27 NM) either side of the pipelines B-ESIA These exclusion zones are described in Chapter 5 Project Description, and potential impacts on marine activities are assessed in Chapter 15 Socio-Economics. Communities and Cultural Heritage Impacts on local economy and local employment opportunities related to the Project and the employment procedures for local jobs and business contracts. The majority of employment related to the construction of the Project will be highly specialised and managed by the offshore construction contractor. Some local employment opportunities may be available at the marshalling yards in either Varna or Burgas during construction, and local jobs may also be created in relation to construction of the landfall section; however, the amount of local employment generated by the Project is likely to be limited. Local procurement (goods and services) opportunities may also be available. Local employment and procurement benefits are described in Chapter 15 Socio-Economics. These topics have been discussed with various local businesses and associations.

100 Comments Consideration and Response Potential impacts on fish and fishing activities. Potential impacts on fish and fishing are assessed in both the EIA and ESIA processes, including a Fisheries Study that examined the effects of the Project on fish stocks, navigation and fishing activities. No significant impacts are anticipated during construction or operation of the Project. However, South Stream Transport will continue to engage with local authorities and fishing communities to keep them informed and monitor / manage potential changes and concerns B-ESIA These impacts and mitigation measures are described in Chapter 13 Marine Ecology, Chapter 15 Socio-Economics and Appendix Potential impact on shipwrecks and marine cultural heritage. Potential impacts on cultural heritage, including shipwrecks, were assessed in the EIA and ESIA processes. Underwater surveys were conducted within 1 km of the proposed route, with a goal of locating and identifying and avoiding these sites. Impacts and mitigation measures are described in Chapter 17 Cultural Heritage. All identified sites are being avoided by at least 150 m, and a Cultural Heritage Construction Management Plan (CMP) has been developed to address the identification of chance finds, archaeological excavations and archaeological conservation B-ESIA South Stream Transport is engaging with the relevant authorities (including the Centre for Underwater Archaeology) with respect to ongoing studies and management measures. Increase in construction traffic arising from the transportation of materials from the marshalling yards, resulting in deterioration of roads and disturbance to local residents of Rakitnika, Borovets, Kantara and Krushkite. The transportation route between the marshalling yards and the landfall construction site has been chosen in order to avoid passing through communities. All access roads used for the transportation of goods and materials will be appropriately upgraded (as needed) and suitable for the transportation of heavy goods B-ESIA Access roads are described in Chapter 5 Project Description. Traffic studies were conducted as part of the EIA and ESIA processes. This is described in Appendix 9.4: Traffic and Transport Study. Related noise, air quality and health impacts are assessed in the relevant chapters. Questions about the visual impact of the Project. The visual impact of the Project was assessed in the EIA and ESIA, and photomontages were created to show the visual changes during construction and operations. The cumulative effect of the combined South Stream Transport and SSB landfall facilities was also modelled. This assessment is provided in Chapter 14 Landscape and Visual. During operations, the landfall facilities may be visible from certain areas (e.g. parts of Borovets), but will be far away and largely below the horizon. Mitigation will include screening and painting the facilities so that they blend in with the landscape. No significant impact is expected. Construction Contractors

101 Comments Consideration and Response Questions about the responsibilities of the Contractor/s and the management of the Contractor s personnel. South Stream Transport will select and manage an overall construction contractor, who will be responsible for the construction of the Pipeline. South Stream Transport will work with the contractor to ensure that the commitments of the ESIA and other documents are implemented by the contractor. The Contractor will also be responsible for managing their personnel engaged in construction works and will implement a local code of conduct procedure to manage potential interactions between the Project workers and the local population B-ESIA Concern that by splitting up the Project means that contractors who are ultimately responsible for implementation of management and monitoring plans will not have the whole picture of the Project. Questions about where non-local workers be housed. South Stream Transport is working closely with SSB and to jointly manage impacts in the vicinity of the landfall facility. This will include ensuring that all contractors work under an overarching set of management plans. In addition to EIA and ESIA reports, this information has frequently been discussed in meetings with stakeholders, including community meetings. During the peak of construction, an estimated 330 workers may be employed on the landfall facilities. There will be no accommodation camp. It is expected that any non-local workers will be lodged Varna. After workforce accommodation is further defined, a rapid appraisal of socio-economic and health impacts will be undertaken. This information is included in Chapter 16 Community Health, Safety and Security. Complete.

102

103 Appendix E: Copy of Public Announcements

104 Scoping Report Disclosure Announcement in national and local newspapers (Narodno Delo and Cherno More) English Translation South Stream Offshore Pipeline Project Bulgarian Sector Scoping Report Publication South Stream Transport B.V. announces the publication of the Scoping Report for the impact assessment of the South Stream Offshore Pipeline Project Bulgarian Sector ( the Project ). Project Information The proposed South Stream Offshore Pipeline Project will comprise four adjacent and parallel 32- inch (813 mm) diameter steel pipelines, extending approximately 930 kilometres through the Black Sea from the Russian coast near Anapa, through the Turkish Exclusive Economic Zone (EEZ), to the Bulgarian coast near Varna. Commercial operations are planned to start by the end of The Bulgarian Sector of the South Stream Offshore Gas Pipeline will be approximately 230 kilometres in length. The pipelines will come ashore 11 kilometres south of the city of Varna. They will run underground for about three kilometres, before connecting to the onshore system of South Stream Bulgaria AD. From there, natural gas can be transported through Bulgaria, and further into South-Eastern and Central Europe. Environmental and Social Impact Assessment South Stream Transport is undertaking an Environmental Impact Assessment (EIA), in accordance with Bulgarian national regulatory requirements for EIA. An Environmental and Social Impact Assessment (ESIA) is also being undertaken following the standards and guidelines of international financial institutions. South Stream Transport has published a Scoping Report that provides information about the Project, including preliminary findings from surveys and that will serve as the basis of planned impact assessment studies. The document has also been submitted to the Ministry of Environment and Water as the Terms of Reference for the Bulgarian EIA procedure. Submitting Comments on the Scoping Report Stakeholders with an interest in the Project may review the Scoping Report and provide comments to South Stream Transport. Feedback will be considered in the development of the impact assessment reports (EIA and ESIA). The Scoping Report and a Non-Technical Summary are available online: Copies are also available at the offices of the Asparuhovo and Priseltsi mayoralties, in the Varna region. South Stream Transport will also hold two open meetings to discuss the Scoping Report: Galata: Wednesday, 6 February, at the Galata Cultural Centre. Time: 15:30-19:30 Priseltsi: Thursday, 7 February, at the Priseltsi Cultural Centre. Time: 15:30-19:30.

105 Comments on the Scoping Report may be provided until 22 February 2013, by or post, to: POVVIK AD for the attention of: South Stream Transport B.V. 12 Mihail Tenev Street Business Centre EVROTUR Floor 6, Office Sofia Bulgaria South Stream Transport B.V. for the attention of: ESIA & Permitting Team Parnassusweg LZ Amsterdam The Netherlands About South Stream Transport B.V. South Stream Transport B.V. is the international joint venture for the planning, construction, and operation of an offshore gas pipeline through the Black Sea. The Russian company OAO Gazprom holds a 50% stake in the joint venture, the Italian company Eni S.p.A. has a 20% stake, while the French energy company EDF and the German company Wintershall Holding GmbH (BASF Group) hold 15% each. For more information about the Project, please see

106 EIA Disclosure and Public Hearing Announcement in Cherno More on 18 November 2013 English Translation 3 The Contracting Authority, SOUTH STREAM TRANSPORT B.V., having its seat at Parnasseusweg 809, Amsterdam LZ 1082, The Netherlands Pursuant to Article 97(3) in conjunction with Article 81(1)(2) of the Environmental Protection Act HEREBY NOTIFY all natural and legal persons concerned of the public hearing meetings scheduled for discussion of the Environmental Impact Assessment (EIA) Report and all appendices thereto for the following development proposal: South Stream Offshore Pipeline: Bulgarian Sector The meetings will be held as follows: 19 December 2013, 16:00 h, at Archaeological Museum, Municipality of Varna, on the following address: Maria Luiza December 2013, 16:00 h, at the community centre in the Village of Priseltsi, Municipality of Avren, on the following address: Central community center Education 1927 The EIA report and the appendices thereto, including the Impact Degree Assessment Report, are available to the interested parties every business day from 9:00 to 17:00 h at - The building of the Municipality of Varna,43 Osmi primorski polk Blvd., Varna - The building of the Municipality of Avren, 8 Todor Noev St., Avren - The building of the MOEW, Sofia, 67 William Gladston str; - on the website of South Stream Transport B.V.: In addition to the above locations, the Appropriate Assessment Report (Appendix A to the EIA Report) is also available on the following website of the competent environmental authority: Written opinions may be submitted at the office of the Investor, South Stream Transport BV, address: Sofia, 53B Nikola Vaptasarov blvd, as well as at each Municipality providing public access to the report mentioned above or during the public hearings. Contact person of the Contracting Authority regarding the public hearing: Milena Hristova, 02/ , е-mail esia@south-stream-transport.com 3 The same announcement was also published in Narodno Delo on 18 November Follow-up reminder announcements were printed in both Narodno Delo and Cherno More on 18 December 2013.

107

108 EIA Disclosure and Public Hearing Announcement in National and Local Newspapers on 18 December 2013 (Narodno Delo and Cherno More) English Translation Anyone interested in learning about the South Stream Offshore Pipeline through the Black Sea is invited to attend: Public Hearings of the EIA Report for the Bulgarian part of the South Stream Offshore Pipeline. You are welcome on: at pm, in the Archeological Museum, Varna Municipality, address: 41 Marie Louise Blvd at pm, in Prosveta-1927 Community Center in Priseltsi, Avren Municipality, 29 Tsentralna Str. South Stream Transport B.V. and the environmental experts will present the project and the content of the EIA Report. In case of interest, you have access to the EIA Report and its annexes, including the Appropriate Assessment Report, in the opening hours of: -Varna Municipality Building, with address: Varna, 43 Osmi Primorski Polk Str. -Asparuhovo District Building, with address: Varna, 2 Narodni Buditeli Str. -Arven Municipality Building, in Spatial Planning Bureau in Infrastructure and Investment Policy Department, with address: Avren, 50 Yordan Noev Str. -The Mayoralty of Priseltsi, with address: Priseltsi, Avren Municipality, 27 Tsentralna Str. -The office of RIEW-Varna, with address: гр. Варна, ул. Ян Палах 4; -The Ministry of Environment and Water; address: Sofia, 67 William Gladstone str. The documents are also available on the internet site of South Stream Transport: In case of written comments you can send them to our office in Sofia: 53V Nikola Vaptzarov str. You can also bring them to the access places announced here above or straight to the public hearings. SOUTH STREAM TRANSPORT B.V., Parnasseusweg 809, Amsterdam LZ 1082, The Netherlands About the South Stream Offshore Pipeline The South Stream Offshore Pipeline is the offshore component of the South Stream Pipeline System. The offshore pipeline will have a length of 931 kilometres and run from Anapa in Russia, to Varna in Bulgaria, where it will connect to the onshore pipeline planned by South Stream Bulgaria AD. The South Stream Offshore Pipeline is planned and will be implemented by South Stream Transport B.V., an international joint venture based in Amsterdam, the Netherlands. Copyright South Stream Transport B.V. December 2013 Contacts connected with the upcoming Public hearing Milena Hristova, 02/ е-mail esia@south-stream-transport.com

109 EIA Disclosure and Public Hearing Announcement presented on Radio Darek and Radio Varna (on 17 and 18 December 2013 three times per day) Всеки, който се интересува и иска да научи повече за морката част от газопровода Южен поток е поканен да присъства на Обществените обсъждания тази седмица. Очакваме ви в четвъртък, 19 декември, от 16 часа в Археологическия музей във Варна, и в петък, 20 декември в читалището на село Приселци, също от 16 часа. На събитията ще представим повече информация за Морския газопровд Южен поток и за заключенията на доклада за оценка на въздействието върху околната среда. Инвеститорът Саут стрийм транспорт и специалисти по околна среда ще са готови да отговорят на въпросите ви.. Anyone who is interested and wants to learn more about the offshore part of the South Stream pipeline is invited to attend the public hearings this week. You are welcome on Thursday, December 19th, from 4 pm, in the Varna Archaeological Museum and on Friday, December 20th, at the community center of the village Priselci, starting for 4 pm as well. The events will present more information about the South Stream Offshore Pipeline as well as the conclusions of the Environment Impact Assessment report. South Stream Transport and environmental specialists will be ready to answer your questions.

110 EIA Disclosure and Public Hearing Announcement Notice (placed in Asparhuhovo, Anapa, Avren, Priseltsi and Varna)

111 Appendix F: Comment Form

112

113 Comment Form South Stream Offshore Pipeline Project Environmental and Social Impact Assessment Date: Please write below any comments or concerns you have about the South Stream Offshore Pipeline Project Are there any particular actions you think the Project should take to protect the environment and the community? What is your attitude towards the proposed Project? (Please circle the one that best describes your attitude) 1 - Positive 2 - Neutral 3 - Negative 4 - I Don t know If you answered positive or negative, please add any reasons for that choice

114 What is the most convenient way for you to receive information about the Project? (Please circle one number only) 1 - Local newspaper 2 - Local radio/tv 3 - Local authority announcements 4 - Accessing South Stream Offshore s website 5 - (if you have provided an address overleaf) 6 - Local community centre/local non-governmental organisation, please specify: 7 - Place of worship, please specify: 8 - Other, please specify: 9 - I don t want to receive any more information Please write below any additional observations, comments or concerns you would like to make: Contact and Demographic Information (Optional) Name: Gender (M/F): Organisation Date: (if applicable): Postal address: Age group: 0-18 years years Telephone number: address: To be included on a Project list, please check here: 61 and above Please place this form in the box provided or send to: Povvik AD, Office 22, Floor 6, Business Center Evrotur 12, Mihail Tenev Street, Sofia 1784, Bulgaria Or South Stream Transport B.V., ESIA and Permitting Department, Parnassusweg 819, 1082 LZ Amsterdam, The Netherlands Or comments may be submitted by to: esia@south-stream-transport.com Your personal information will be recorded in our database for the purpose of data analysis of South Stream Transport B.V. s stakeholder consultations and/or,where relevant, respond to your requests for further information about South Stream Transport B.V. or the South Stream Offshore Pipeline Project. Yourpersonal information may be shared if necessary with other parties involved in the South Stream project, but will not be sold or distributed to any third party. You have the right to contact South Stream Transport B.V. at any time to obtain access to your personal information and to request South Stream TransportB.V. to rectify any personal information which you feel is not accurate.

115

116 Contact South Stream Transport B.V. Parnassusweg LZ Amsterdam, The Netherlands Phone +31 (20) Fax +31 (20) Commercial Register Number Information Centre - Varna, Bulgaria Open for visitors every Tuesday and Wednesday Black Sea Capital Building Tsar Simeon Street Varna, Bulgaria Phone: varna@south-stream-offshore.com