Pirin National Park

• Development of a hotel and a ski resort (issue resolved)
• Project proposal envisaging the enlargement of the existing ski-zone within the World Heritage site

Previous deliberations:
Ninth session of the Committee (XIII.)
Tenth session of the Bureau (VI.j)
Fifteenth session of the Bureau (VI.29)
Fifteenth session of the Committee (VIII.)
Twenty-fourth session of the Committee – paragraph VIII.24 / Annex X page 112.

Main issues: ski development.

New information:  IUCN reviewed the information from the Minister of Environment and Water (MOEW) of Bulgaria dated 20 October 2000. No further information was provided by the State Party since. IUCN notes that the ski developments of 1985/86 were in compliance with the then existing Nature Protection Act and occupy an area of 48 ha.  On 18ha of this area, however, 2 ski runs and 1 chair lift do not function properly and there are consequent problems of overcrowding and traffic congestion on narrow roads.  The Territorial Development Plan (TDP) submitted to the MOEW in 1999 proposes 5 new ski runs totalling 30ha plus their facilities, car parks and a cable car joining the zone with the town of Bansko. The proposed new ski runs are all within the World Heritage site. The State Party reports that the local population supported the project while NGO’s rejected it completely. Following a positive EIA, a public hearing and an assessment by the Senior Environment Council to the MOEW, part of the TDP has been given approval. This includes:

• 2 new ski runs and a ski lift covering 13.5 ha.
• A study is to be carried out for another ski run and ski lift covering 7ha.
• Closing down and re-cultivation of 2 old ski runs with surface area of 18 ha and the dismantling of the ski lift.
• Construction of a cable car to the town of Bansko, terminating car access into the park and eliminating the need for parking lots.
• No approval for the other ski runs and lifts proposed.
• Regulation and limitation of accommodation facilities in Bansko in accordance with the capacity of the ski zone. No construction of accommodation within the Park.
• Technical plans are required to show the exact location of each ski run and facility approved and an EIA for each project, including public hearings in order to mitigate further any negative impacts.
• Expansion of the biosphere reserve within the Park in compensation.

IUCN has also received for review a letter from Bulgarian NGO’s dated 14 February 2001 in response to the State Party letter. This letter notes that:

• The Bulgarian National Parks Act emphasises nature conservation before the provisions of developments for tourism and recreation;
• A national conference was held in January 2001 attended by 180 environmental NGO’s. Participants supported an appeal to the Ministry of Environment and Water, Bulgarian Prime Minister and the President to repeal the decision of allowing construction of new ski runs in the Park.;
• No alternative solutions to the proposal have been considered;
• the EIA report notes that the forest that is to be clear-cut in the area of the planned ski zone is between 50 and 200 years old;
• The territorial management plan of the ski zone is in violation of a number of laws and Conventions, as well as the Park Management Plan;
• The plan to bring a further 1400 people to this area of the Park is contradicting the principle of the management plan for the decentralisation of tourism; and
• Conflict between the number of beds in the town and the capacity of the ski area is only an issue on weekends and holidays.

The BALKANI Wildlife Society recommends the promotion of soft tourism and the improvement of the capacity of existing ski facilities.

The Ministry for the Environment and Water submitted a report on the conservation status of Pirin National Park dated 12 September 2001, which was transmitted to IUCN for review.  The report includes the following information on the Territorial Development Plan (TDP) that was developed for the Bansko ski zone that lies within the site:

·       The TDP passed all the Environment Impact Assessment procedures set by the Bulgarian Protected Areas Law.  It was also subject to public hearing.  It was later submitted to the High Expert Ecological Council (HEEC) of the Ministry of Environment and Water.  The HEEC partially approved the TDP, while also requesting changes and protection measures aimed at improving the TDP. 

·       The final version of the TDP is 818.46 ha, with ski runs and facilities occupying 99.55 ha of this area.

·       The TDP is considered as the upgrade and development of an existing ski zone, the most significant element of which is a cable car.  It is considered to significantly reduce the negative impacts associated with crowding, traffic congestion, and rundown facilities. 

·       The development aims to ensure the achievement of one of the major goals of the National Park, namely encouraging ecotourism and generating income for the local people.  The TDP will contribute to the sustainable development of the Park by enrolling the local community into the idea of protection of the Park.  The State Party report noted that the local population is fully supportive of the TDP.

·       The Management Plan for the Park is to be developed with financial assistance from the ongoing Bulgarian-Swiss Biodiversity Conservation Programme.  This is expected to be complete in 2001.  It is expected that the Management Plan will take note of the main directives of the TDP and after the approval of the Management Plan, some of the TDP’s decisions may be changed.

·       On 12 July 2001, the sitting of the three-member High Administrative Court of Bulgaria ended with a rejection of the BALKANI Wildlife Society appeal against the decision of the Ministry of Environment and Water to grant permission for the TDP.  There was an appeal against the decision  with the  sitting of a five-member Court, and was subsequently rejected by the Court in late September.  The High Administrative Court is the final authority and avenue of appeal.

·       Prior to the High Court decision in July, the Ministry of Environment and Water opened the bid procedure for the concession for the TDP by advertising in the State Gazette, and a Commission was nominated to oversee the concession bidding process.

The State Party report invited a UNESCO/IUCN mission to the site.  IUCN also received the first Brief of the “Save the Pirin Campaign”, which involves a coalition of over 30 Bulgarian NGOs opposed to the development.  The Brief and subsequent Briefs will be used to inform European NGOs, Convention Secretariats, European institutions including the EC, the European Bank for Reconstruction and Development (EBRD) and European Parliament about the Campaign’s progress.  Members of the Campaign have met with the new Minister of Environment and Water, representatives of the potential project sponsor and representatives of the EBRD, which is also involved in project financing.  IUCN noted the State Party’s belief that “the only solution to the problem of the sustainable development of the Pirin NP is to bind the goals of the Park to the interests of the local people”, and that the TDP offers this opportunity.  IUCN acknowledges that it is important that local populations benefit, where possible, from World Heritage designation.  IUCN notes that any development in the World Heritage site must be carefully planned to minimise environmental impacts.  

IUCN questioned whether the TDP project in Pirin National Park can be classed as ecotourism and whether it is compatible with World Heritage status. It also noted that the total area covered by the TDP is 818.46 ha, whereas the current proposed ski runs and facilities cover less than 100 ha.  This is a substantial increase.