NATURA 2000 IN THE NEW EU MEMBER STATES ONE YEAR AFTER ACCESSION Status report for new and candidate Member States. QUESTIONNAIRE - Bulgaria

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1 NATURA 2000 IN THE NEW EU MEMBER STATES ONE YEAR AFTER ACCESSION Status report for new and candidate Member States QUESTIONNAIRE - Bulgaria Please answer the questions and add as much detail in comments as possible, especially in cases where you have indicated partial or inadequate implementation. A. Legislation 1) Have the Habitats Directive and Birds Directive been transposed into the national legislation of your country? Partially No Information Habitats Directive Birds Directive Comments: The texts of the Habitats and Birds Directives have been satisfactorily transposed into the national legislation, and more specifically into the Biological Diversity Act. At the same time, there are some omissions and weak points which need to be addressed. For example: there is no adequately transposed procedure for environmental assessment of the impact of plans and projects on Natura 2000 sites; there are discrepancies between Annex 1 of the Bulgarian Biological Diversity Act and Annex 1 of the EU Habitats Directive, which will seriously limit the scope of the Natura 2000 network in Bulgaria. Apart from this, the existing national legislation does not place under protection the habitats of some species listed in Annex 2 to Directive 92/43/ЕЕС and in Annex 1 to Directive 79/409/ЕЕС. The description of habitats in the EU Interpretation Manual does not fully correspond to the characteristics of Bulgarian territory, causing serious disagreements and conflicts of interpretation within and between academic institutions, the Ministry of Environment and Water (MoEW) and non-governmental organizations (NGOs). 2) Regarding concrete provisions in the legal acts transposing the Habitats and Birds Directives: i Is it clear in the legislation of your country how to designate SACs and SPAs (by law, decree, otherwise)? SPAs SACs Partially Comments: The procedure has been defined under the Biological Diversity Act: designation shall be ordered by the Minister of Environment and Water, based on lists approved by the Council of Ministers and proposed by the National Council on Biodiversity. An important note should be made here: the Bulgarian act does not make any distinction between the two types of areas. This fact could cause serious trouble in the determining their borders and correspondence to the two directives, as well as future problems for their protection. ii Is there general legal protection for SACs and SPAs according to the legislation of your country? Partially SPAs SACs

2 Comments: Bulgarian legislation envisages the precise identification of the administrative borders of areas designated for the protection of natural habitats and habitats of species listed in the annexes to the Biological Diversity Act. But the act does not envisage the development of obligatory general or private limitation regimes for these areas. The act only states the general purpose of protected areas as protection or restoration of the favourable status of natural habitats listed in the act, as well as of species within the natural region of their distribution". The act also only defines very vaguely "favourable conservation status". In this regard, the protection of areas will have to rely completely on the availability of a working assessment procedure for the impact of plans and programs on Natura 2000 sites and on area management plans. The management plans of designated protected areas are the only normative documents containing obligatory limitation regimes for protected areas, including measures for their active management. Owners and other stakeholders are allowed to appeal at administrative court offices against the decisions of administrative bodies concerning the designation of protected areas and the development of their management plans. In this regard, the necessary protection regimes could be excluded from management plans when placing limitations on ownership -- these limitations have not been legally settled. iii Is there a clear process for evaluating significant effects of plans/projects on sites (art. 6.3 & 6.4)?, following the EIA, independent from the EIA Yes, but inadequate Comments: The assessment process is not sufficiently clear. There is no practical experience in Bulgaria in this field. The Biological Diversity Act does not envisage a clearly defined decision-making process regarding the implementation of Articles 6.3 & 6.4 of the Habitats Directive. The Act refers the whole assessment procedure to the existing procedure for Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA). However, the two procedures envisaged in Bulgarian legislation do not allow for the implementation of the objectives set out in the Directive. The discrepancies between the objectives of Article 6 and operating procedures in Bulgaria are the following: Lack of all the obligatory stages of the procedure stated in Article 6 of the Habitats Directive and, more specifically, lack of assessment of alternatives, which makes the whole procedure irrelevant; Lack of any criteria related to Natura 2000 in the screening stage of the EIA procedure; There are no clear requirements in the developed EIA and assessments regarding the impact assessment of the favourable status of habitats and species. There are no clear standards regarding the definition of considerable impact on favourable conservation status; The precautionary principle is totally missing from Bulgarian legislation and therefore is not implemented during the EIA procedure; In administrative terms, the departments responsible for EIA implementation are different from the departments responsible for the management of protected areas; the latter do not have a decision making role for the definition of proposed decisions; Lack of any practice or legal mechanisms regarding the preliminary protection of potential Natura 2000 sites, which is directly related to Article 6 of the Habitats Directive as well as to Article 4 of the Bern Convention. The Bulgarian Ministry of Environment and Water takes the following approach: it takes all investment intentions to EIA, without making use of existing legal opportunities to stop or limit proposed activities. In practice, there are no negative EIAs or negative decisions of the Ministry on EIAs. Thus, the only result is the delay of investment intentions, and not their cancellation. Last but not least important, according to the national legislation Natura 2000 sites will become known no earlier than the date of accession (January 2007). No efforts are being made to protect identified potential sites, regardless of whether they have been identified within the framework of projects ordered by the Ministry of Environment and Water. iv Are there provisions for ensuring the ecological coherence of the network (art. 10)? Yes, but inadequate Comments: The protection of biological corridors has been legally defined and underlies the EIA procedure concerning plans and projects. Thus, the creation and protection of these biological corridors is totally dependant on the effectiveness of EIAs. In EIA procedures, there are no criteria regarding the screening of impacts of plans and projects on the favourable conservation status of habitats and species outside Natura 2000 sites. This fact will practically lead to the irrelevance of this general requirement. Another example could be given with the currently adopted territorial and forestry plans, which despite all requirements do not mention the issue. v Is the species protection regime (art. 12 to art.16) adequately transposed?

3 Partially Comments: 3) Are the Habitats and Birds Directives integrated into legislation governing sectoral policies? Sectors Yes No Inadequately No info Comments Agriculture Spatial planning Transportation Water management Forests Other: Comments: Sectoral programmes do not envisage concrete implementation activities with regard to biodiversity conservation. Potential protected areas are not supposed to be protected in advance. There are not sufficient economic mechanisms for stimulating environmental practices. There are no compensation mechanisms for private owners in protected areas and zones. 4) Any other or issues or general comments regarding legislation? With very few exceptions there is no practical and normative basis for the active granting of information in the field of environment. B. Site designation -- National list of sites 1) Concrete data: i ii iii iv v Number of SCIs proposed by the national government: The list is being currently developed. A list of potential Natura 2000 sites can be found at: date, the Bulgarian government has received 309 proposals, but only a part of them include maps and filled in standard data forms. The data are presented following the draft list, which is being prepared by the nongovernmental organisation Green Balkans under commission of the Bulgarian Ministry of Environment and Water. There is no certainty that the list will be approved by the government and submitted to the European Commission. Number of SPAs proposed by the national government: 191 = 69 SPAs type С (100 % overlapping between SPA and SCI). % of national surface of SCIs proposed + SPAs (avoiding double counting by overlap): Draft SCIs 29%, draft SPAs 19% % of coincidence with existing PAs of SCIs proposed + SPAs (avoiding double counting by overlap): The overlap between draft SCIs and draft SPAs covers 19% of the country's territory. This is a high percentage, which has to be taken into account during the assessment of sites only with regard to the two main types of sites (SCI and SPA). Thus, the potential Natura 2000 sites cover a total of 34% of the country's territory. The overlap between potential Natura 2000 sites and existing protected areas network could be 3% of the country's territory, i.e. the area covered by National and Nature parks. The overlap with other protected areas could not be determined, or it would be very difficult, due to the lack of digitalized borders for existing protected areas. Is digital data (shp, dxf, others) of the proposed SCIs and SPAs available? (if there is, please send it with the questionnaire): The digital borders of potential Natura 2000 sites currently mapped are available in shp format, WGS 84. As the national list is still not finalised, this information is not complete and has yet to be distributed. 2) Please rate the quality of scientific information used to prepare the list of proposed Sites of Community Importance: Good (inadequate) Fair (some changes needed)

4 Poor (clearly inadequate) Comments: In some fields (habitats, for example) the information is incomplete or of poor quality. The work is not carried out systematically. There are no maps of the distribution of natural habitats/species, there are no assessments of their national areas/populations. The selection of sites is not representative, it is based on expert opinions, entailing insufficient protection of some species, habitats and regions. The faunistic and, more specifically, ornithological information, is of much better quality than any other data (collected with similar efforts per unit area). The information about habitats in the two field seasons (2003 and 2004) in which inventories were made has been described following two different lists and still has to be reviewed. 3) Please evaluate the list of proposed sites: Good (sufficient) Fair (some changes needed) Poor (clearly insufficient) Please justify your evaluation referring, for example, to % of area proposed by scientific or NGO list not included in the official list, species and habitats missing, regional imbalances, etc.: The list of draft sites is being developed by environmental NGOs with the active participation of scientific experts from the Bulgarian Academy of Sciences and universities. The potential Natura 2000 sites were identified using the following data: the borders of sites according to CORINE Biotopes, Ramsar sites (existing and potential ones), Important Bird Areas (1997 version) and more than 130 draft areas proposed by NGO experts and scientific institutes. 4) Any other or issues or general comments regarding Site designation? There is no adequate co-ordination between NGOs working about site designation, particularly in the fields of birds and of natural habitats. C. Financing 1) Is there a cost estimate for implementing Natura 2000 in your country? Author or institution Date of estimate Overall amount Comments Ministry of Environment and Water February million The amount is insufficient for the implementation of commitments related to Natura 2000, including the commitments envisaged by national legislation (management plans, compensation of damage caused by protected species, etc.). When will there be? Comments: The assessment was carried out within the framework of the Action Plan for the Protection of Biological Diversity ( ). As of February 2005, the Plan had not been adopted and the quoted figures might differ from the actual ones. 2) Is there a national plan for financing Natura 2000? When will there be?

5 Comments: As mentioned above, funds for Natura 2000 have been envisaged within the framework of the Action Plan for the Protection of Biological Diversity ( ), which is currently being developed. The funds for Natura 2000 envisaged within the framework of the Plan will be used directly for management purposes as well as for increasing the legal and administrative capacity. However, the budget lines are too general and unclear, and there is no prioritisation of activities. The Plan only envisages resources from external donors financing activities strictly related to biodiversity, and funds from the budget of the Ministry of Environment and Water. No funds are envisaged from other budget lines or from other external donors. 3) Are there provisions in the national budget for financing implementation of the Habitats and Birds Directives? Yes No Comments: To date, there is no detailed governmental budget for the separate financial years which could be used for biodiversity conservation, including the implementation of the two EU directives. 4) Natura 2000 and the EU funds for the period : i Are there specific lines for financing the implementation of Natura 2000 in the National Development Plan of your country? Please describe briefly how: No specific mention of Natura 2000, but there are financing opportunities anyway (please comment below) Comments: Not relevant as Bulgaria is expected to join the EU in January ii Are there specific lines for financing the implementation of Natura 2000 in the Sectoral Operational Plans of your country? Please describe briefly how: No specific mention of Natura 2000, but there are financing opportunities anyway (please comment below) Comments: iii Are there specific lines for financing the implementation of Natura 2000 in the Rural Development Plan of your country? Please describe briefly how: No specific mention of Natura 2000, but there are financing opportunities anyway (please comment below) Comments: iv Have pre-accession funds been used for implementation of Natura 2000, or are they currently being used?

6 Funding source Yes Comments/description PHARE ISPA SAPARD Other European Commission Only for two sites with a total area of about ha, and as a secondary activity Small grants about governmental and non-governmental organizations for local capacity building Comments: In 2003, the Ministry of Environment and Water has submitted to PHARE a 3-year project ( ) for the establishment of Natura 2000, but the comments to the project were discussed with EC representatives only in February Now the same project has been reviewed for the period and has been financed with 2 million. v Have any other funding sources been used for implementation of Natura 2000, or are they currently being used? Funding source Yes No No info Comments/description Govt Aid Agencies Enterprise for the Management of Nature Conservation Activities (Bulgarian government) National Forestry Board (NFB) PIN MATRA Programme of the Government of Netherlands Private sources Financing started as late as 2005 with the projects of two NGOs (Green Balkans 310,000 and Bulgarian Society for the Protection of Birds 65,000), which will be implemented in the course of the year and will prepare the necessary documentation for the list of potential Natura 2000 sites. Financing of activities only within the borders of nature parks (200,000 ha), which is not a targeted financing and falls under the available budget of the NFB departments. An NGO project (of the Center for Environmental Information and Education) for the site identification/establishment of Natura 2000 in the foothills and mountain areas of northwestern and southwestern Bulgaria in the period Others Danish Environmental Protection Agency WWF-Danube Carpathian Programme In ,000 were provided for site identification and preparation activities for the establishment of Natura WWF has been financing activities since 2002, in 2004 with partial support of 16,000 from the Austrian Life Ministry. Comments: Until 2005, the main sources of financing for establishment of the Natura 2000 in Bulgaria were from external, foreign sources was the first year in which the national budget allocated funds for the elaboration of the lists with draft sites. 5) Is it planned to include specific and sufficient financial lines for the implementation of Natura 2000 in the planning instruments for the next programming period ( )? Planning document Yes No No info Comments National Dev. Plan Sectoral Operational Plans Not developed yet Funds for the additional expenses related to the protection of Natura 2000 sites and of biological corridors (for maintaining the integrity of the network) have not been envisaged in any of the plans (for

7 Energy, Infrastructure, Regional Development). Funds for the carrying out of assessments according to Article 6, points 3 and 4 of the Habitats Directive 92/43 are not planned. Rural Dev. Plan There is still no information regarding how and indeed whether the Agriculture Policy will include measures related to Natura Comments: These plans are not yet ready and there is no information whether Natura 2000 will be included in them. 6) Any other or issues or general comments regarding financing for Natura 2000? In Bulgaria there is no government policy for the financing of Natura 2000 for the current nor the next ( ) EU programming period. D. Management 1) Does the Government have staff dedicated specifically to Natura 2000? Main activity Sites list elaboration Art. 6.3 and 6.4 assessments Site/species management Scientific studies Communication Others (please specify) Approx. no. of civil servants 1-2 at the National Nature Protection Service to Ministry of Environment and Water and 1 at the National Forestry Board 20 biodiversity experts working at the Regional Inspectorates on Environment and Water, but they are generally responsible for biodiversity and not only for Natura at the National Nature Protection Service, but they are generally working for management plans for species and not only for Natura people at the management bodies of protected areas, which are potential Natura 2000 sites; these people are not specifically dedicated to working on Natura 2000 but rather are responsible for the management of protected areas as a whole Comments: Of the above-mentioned staff, only 2 people are specifically dedicated to work on Natura 2000 issues -- 1 at the Ministry of Environment and Water, and 1 at the National Forestry Board. The person working at the Ministry is a junior expert. 2) Have principles, management guidelines and planned management measures based on Favourable Conservation Status been established for habitat and species? Will be ready by: Comments: Apart from the several management plans for species with very unclear implementation, there are no substantial activities in this regard. Resources need to be planned in the framework of the National Action Plan for Biological Diversity , but until now the government has no position on this issue. NGOs have proposed to include in the Plan a discussion to reach official interpretation of the "favorable conservation status" of species and habitats, as well as measures for its achievement. 3) Are there going to be management plans specifically dedicated to Natura 2000 sites and species in your country? Sites Species

8 Will be ready by: Comments: According to the national legislation, management plans must be developed for the areas falling within Natura With regard to SPAs, the development should start from the date of accession (2007) and go on for 3 years. With regard to SCIs, the development of management plans is envisaged to start with the adoption of the final list and scope of SCIs by the European Commission and only after they have been designated as SPAs. In , two non-governmental organizations, Green Balkans and the Bulgarian Society for the Protection of Birds, developed management plans for 6 bird species listed in Annex 1 of the EU Birds Directive 79/409/ЕЕС and submitted them to the Bulgarian Ministry of Environment and Water. To date, the plans have not been approved according to the national legislation. Balkani Wildlife Society, in partnership with the Ministry of Environment and Water, is expected to finalise the management plan for the brown bear until the end of The plan must then be approved by the Ministry of Environment and Water. There are several action plans related to habitats listed in Annex 1 of the Habitats Directive. These are for example the Action Plan for the Protection and Restoration of Floodplain Forests on the Danube Islands, developed by the Bulgarian Ministry of Agriculture and Forests, the Ministry of Environment and Water, and WWF; as well as the National Chestnut Forests Plan. Generally speaking, there are many unclear aspects regarding the connection between the two types of management plans and between them and the procedures assessing the impact of plans and projects on Natura 2000 (EIA in this case). The management plans for species lack adequate information regarding the definition of requirements for maintaining favourable conservation status, the necessary map information for the planning of measures regarding species habitats as well as specific measures allowing the integration of conservation activities into other sectors. 4) Are there specific methodologies for developing Natura 2000 management plans? Will be ready by: Sites Species Comments: There are common methodologies for all Special Protected Areas listed in Annex 1 of the Bulgarian Biological Diversity Act and for the species listed in Annex 2 to the same act. Adapted methodology of EUROSITE for protected areas will be used for the sites. The methodology for species will be taken from Article 54 of the Biological Diversity Act. Regarding management plans for sites, the provisions of the Guide for Interpretation and Implementation of Article 6 of Directive 92/43/ЕЕС (Habitats Directive) have been incorporated into the Order for Protected Areas Management Plans. The Ministry of Environment and Water has made a commitment to support the compilation of data, inventory and monitoring of habitats and species listed in the Birds and Habitats Directives (92/43/ЕЕС and 79/409/ЕЕС). The Terms of Reference for management plans (developed in 2005) for 15 forest protected areas include strict requirements regarding the collection of information and filling in of a standard Inventory form (Natura 2000 Standard Data Form). They also include practical guidelines for working with it according to the nationally approved methodology. 5) Is the procedure for assessing projects and plans (art. 6.3, 6.4) adequately implemented? Inadequately Comments: More information regarding the related legislation is included in section A of this questionnaire. There is no practical experience in Bulgaria regarding application of this article, not even as a preliminary instrument for the protection of potential Natura 2000 sites through EIA procedures. The Ministry of Environment and Water does not apply the principles of Article 6 of the Habitats Directive to potential sites, often stating that a general EIA is not be carried out for activities

9 causing permanent damage to potential sites (i.e. small hydropower stations, river regulations, excavation of inert materials, logging, introduction of alien species). 6) Is there any methodology for monitoring? Will be ready by: 2006 Comments: It is very probable that the monitoring programme could be impossible to implement because of the complexity of envisaged activities. It might not deliver quality information about the relation between impact (threats) and response (status of species and habitats), because of the unsystematic approach, the lack of threats analysis and lack of knowledge of the objectives of the monitoring programme. 7) Any other or issues or general comments regarding management for Natura 2000? There are many illegal activities related to illegal logging and game poaching in the country, which often affect habitats and species listed in the directives. There are no practical measures against them. We need to establish well-prepared specialized structures to fight with these violations. We also need an effectively working court and punitive system. E. Communication and public participation 1) Has there been a public participation process for i ii Designation of SPAs? Yes, but inadequate Comments: Though a legal requirement, it has not been implemented in practice. It is a legal obligation to carry out public hearings before submitting the proposed Natura 2000 list of sites to the European Commission. Because of the short period until accession, it seems now difficult to implement this obligation in a proper manner. Therefore, the Bulgarian government, following the initiative of the Ministry of Environment and Water, has proposed to Parliament a bill for the amendment of the Biological Diversity Act that suggests excluding public hearings from the Natura 2000 site designation and amendment processes. The NGO community has reacted very negatively to this proposal and started a campaign against it (campaign site in Bulgarian) Proposal SCI list? Yes, but inadequate Comments: There is no legal procedure for making proposals for Sites of Community Importance. Although proposals for individual Sites of Community Importance must, according to Bulgarian law, be consulted separately with the public, the contents of the final list to be submitted to the European Commission will be a matter of administrative decision and of some consultations with experts. 2) Is public participation planned for i Elaboration of management plans?

10 Comments: Most probably yes, if the tradition and spirit of Management Plans for Protected Areas is respected. Public participation finds expression in the obligatory implementation of public discussions (it is obligatory for sites, but not obligatory for species) and in the potential opportunity for NGOs to be responsible for or to participate in the preparation itself. ii Evaluation of significant effects of projects and plans over sites? Comments: Yes for the EIA procedures, no for the ecological assessment procedures. The answer is yes, but inadequately. The general EIA and SEA procedures include consultations, but not in a manner that satisfies the aims of Article 6 of the Habitats Directive. For instance, public participation is not foreseen in the screening stage, which is actually the crucial stage for identification of potential major impacts and on which the decision whether to proceed with a full EIA depends. Public participation in the proposals for alternatives during later consultations is also formal because only the investor estimates which alternatives to assess, without having the obligation to take into account even the opinion of the local administration. 3) Does the government have a communication/awareness raising strategy on Natura 2000?, but inadequate Expected by: Comments: The only activities in this regard are small NGO projects financed by foreign donors. The topic is not reflected in the educational system. 4) Any other or issues or general comments regarding communicating Natura 2000? It is necessary to introduce simple and practical public consultation procedures for the list of sites of the national ecological network and Natura 2000, as well as for Article 6 assessments and future management plans (with borders, aims and regimes). F. Known threats 1) Please note if there has been any complaint to the EU regarding implementation of Natura 2000 in your country: Regarding Complaint Status (rejected, in Court, no info ) Brief description Site designation Transposition of legislation Activities negatively affecting sites Others Comments: 2) Please note any activities (or the lack of them) that could negatively impact existing or potential Natura 2000 sites that you are aware of: Location/site Activity Expected impact EU co-financing? Entire Black Sea coast and all higher mountains in the country Construction works for ski and sea tourism development - extension of existing or Significant (40-100% of the national territory) direct destruction of a large number of mountainous and sea-related habitats as well as habitats of Ursus arctos and Lynx lynx. The construction of accommodation infrastructure in the area of Bansko is carried out with funds

11 construction of new infrastructure and facilities (ski and golf). under SAPARD Ograzhden Maleshevo, Southern Pirin, Bellasitca, Western Stara planina Old growth forest cuttings and application of unsustainable forestry practices Direct destruction of old growth forests or of forests, which are in the process of restoration. Concerns significantly habitats 91W0, 9110, 9130, 9150, 9410, 91AA #, 9260, 9270, 9530, 91CA # Northern Black Sea coast Entire country Construction of wind power stations Construction of motorways, roads, railways Direct destruction of habitats due to the construction works (steppic, Testudo graeca habitats), very high mortality rate of migration birds (located on one of the two main migration routes in the country - Via Pontica). Direct habitat destruction due to the construction works Kresna gorge, Ropotamo, Alepu, Black Sea coast. Fragmentation of habitats and populations of species from the Natura 2000 network Lynx lynx, Ursus arctos, etc. High mortality rate on roads Spermophilus citellus, Sicista subtilis, Mustela eversmannii, Lutra lutra, Testudo graeca, Testudo hermanni, Elaphe quatorlineata, Elaphe situla, Emys orbicularis, Mauremys caspica The construction of the motorway and railway through the Kresna gorge is an EU priority project for the Trans-European Network for Transportation. Higher and middle stretches of all rivers in the country. Construction of small hydropower stations Direct habitat destruction because of the construction works and deterioration due to draining or flooding of riparian areas. If the national small hydropower station programme is implemented, under threat would be habitats 3260, 3270, 3280, 3290, 6420, 6430, 91E0, 92A0, 92C0; and species Lutra lutra, Elaphe situla, Emys orbicularis (местообитания в течащи води), Mauremys caspica (местообитания в течащи води), Aspius aspius, Barbus peloponnesius, Gobio albipinnatus, Gobio uranoscopus, Rhodeus amarus, Cobitis taenia (sensu lato), Mizgurnus fossilis, Sabanejewia balcanica. Potential funding of one of the projects in the Kresna gorge by the European Bank for Reconstruction and Development 3) Any other or issues or general comments regarding threats to existing or future Natura 2000 sites? G. Main priorities for implementing Natura 2000 Which in your opinion are the main priorities for implementing Natura 2000 in your country (one per line)? Exhaustive transposition of the Birds and Habitats Directive into the Bulgarian Biological Diversity Act and resource legislation, including the Acts on Water, Forests, Mineral Resources, etc. including associated normative documents,; ensuring effective implementation of legislation, especially regarding regulating the coherence and connectivity of the Natura 2000 network. Timely finalization of a representative and complete national list of Natura 2000 sites reflecting the rich biological diversity and natural conditions of the country. The list must be consulted with all interested stakeholders. Timely and adequate national financial planning for funding the finalization of the national psci list preparation and the Natura 2000 network management in the period from national sources and EU funds. All interested stakeholders should be able to participate in the planning process. Quick and prioritized activities to improve expert capacity of the state administration and some other key players regarding Natura employment of additional personnel, training and education, hardware and software supply (also for GIS); exchange of experience and practices with other countries. Ensure through the application of the precautionary principle that habitats and species within potential Natura 2000 sites are protected before the national psci list is ready and submitted to the EC. Elaboration of criteria for the favorable conservation status of each species and habitat type (including limitation of activities and uses). Elaboration of a practical assessment procedure according to Article 6 (3) and (4) of the Habitats Directive.

12 H. Accession and candidate countries: Romania, Bulgaria, Croatia and Turkey To the extent that you have not already done so in the questionnaire above, please provide a snapshot of preparations for Natura 2000 in your country, including: 1) General progress made by the Government in site list preparation: There is progress in the site list preparation, but it is insufficient. Expert estimations point out that ca 30% of the potential sites have been mapped to date, meaning that the main workload will fall on the field seasons of 2005 and 2006, which will put an enormous pressure on the state authorities. The main risk is that omissions and gaps will occur in the list due to lack of time. 2) Resources dedicated by the Government (human/financial national/international) for site list preparation: Until 2005, very insufficient financial (only foreign) and almost no human resources; from improvement of the financial (almost 400,000 from national sources for one year!) and slight improvement in terms of human resources (two experts for Natura one in the Ministry of Environment and Water, and one in the Ministry of Agriculture and Forests). 3) Involvement of NGOs and other actors in preparing for Natura 2000: The legislation provides for this and the Ministry of Environment and Water is to some extent open to this. Since 2005, the preparation of the psci list has been delegated to two NGOs - Green Balkans and the Bulgarian Society for the Protection of Birds. 4) Other issues or general comments: It is a very crucial period now where all actors need to take intensive and coordinated actions - the list of psci must be finalized in a timely and adequate manner, and consulted with all stakeholders concerned; the Natura 2000 issues must be communicated adequately to the public and especially local authorities, private land and forest owners; the financial planning for the network management must be proceeded quickly and with the involvement of all stakeholders concerned. People involved in answering the questionnaire Country Bulgaria Name (last, first) Organization/Institution Simeon Marin Green Balkans office@natura2000bg.org Andrey Kovatchev BALKANI Wildlife Society akovatchev@balkani.org Toma Belev Association of Parks in Bulgaria, Chairman toma_belev@abv.bg Vesselina Kavrakova WWF Danube-Carpathian Programme kavrakova@wwfdcp.bg