This state of conservation report follows up on issues that were not considered at the 32nd session of the World Heritage Committee for procedural reasons, as the extension of the property was withdrawn by the State Party. This report is also based on further information received from the State Party on 28 January 2009 in response to a letter from the World Heritage Centre.
Pirin National Park (PNP) has had a long history of discussion by the World Heritage Committee in relation to concerns regarding the impacts of ski development adjacent to and within the property. An extension was put forward for consideration to the 32nd session of the World Heritage Committee (Quebec City, 2008) addressed to the key conservation issues already identified within the property. The extension was recommended by IUCN for approval following the full IUCN evaluation process. Eventually the proposed extension was withdrawn by the State Party, and this also prevented the state of conservation issues noted within the existing property from being discussed. The World Heritage Centre and IUCN have agreed that, as a matter of procedure, in future all properties with state of conservation issues that are also nominated for extension, be considered by the World Heritage Committee under both the Agenda items on Nominations (item 8B) and state of conservation (item 7B). The situation is further complicated as the State Party has resubmitted the previously withdrawn extension following further community consultation, and this extension now re-enters the IUCN evaluation process and will be presented for the consideration of the World Heritage Committee at its 34th session in 2010.
In September 2008, the World Heritage Centre and IUCN received a letter from a coalition of 11 national and international NGOs drawing attention to a number of their concerns regarding PNP. These included inter alia, exclusion of territories from the World Heritage property that have been subject to ski development, a new authorization of ski development in violation of the current management plan, changes to the management plan by the consultative committee to the PNP that would facilitate ski development, a lack of enforcement and a reduction in the budget of PNP.
The State Party responded by letter from the Ministry of Environment and Water (MoEW) addressing the different points in detail. The exclusion of areas was considered in IUCN’s 2008 evaluation of the withdrawn extension. IUCN found that there were areas that had indeed been developed for skiing, creating a significant impact on the values of the existing property. Now that the extension proposal has been reinstated, the question of these excluded areas should again be considered by the World Heritage Committee at its 34th session in 2010.
In relation to the authorization of new development, the MoEW notes that an approval was recommended by the Regional Governor of Blagoevgrad in relation to a proposed development of a ski and golf complex by a private organization, the Balkanstroy Company, which would affect PNP and potentially be a critical impact to its values. The MoEW asserts that this development is not permissible considering the legal protection of the national park, and European legislation. The MoEW also states that there was no ongoing construction within the property at the time of the letter, although it is not clear that there is no possibility of such construction. IUCN noted in its 2008 evaluation that past development had taken place in the property beyond legal permissions, and is concerned that this matter is addressed as a key issue by the State Party. IUCN also considered that continued further development of ski facilities or extension of the tourism zones within the existing property would adversely affect its Outstanding Universal Value and integrity, and would lead to a situation where deletion of the property from the World Heritage List would need to be considered.
The MoEW also confirms that the consultative committee to PNP recommended a decision to alter the Park management plan in favor of further ski development. Such a decision would clearly not be in the interests of the conservation of PNP and would likely result in further loss of the Outstanding Universal Value and integrity of this property. However, the State Party report asserts that no process to amend the management plan in such a way has been undertaken, and that the consultative committee does not have an executive role in this matter.
The MoEW notes that there has been a reduction in State funding for the PNP Directorate but points to a significant increase in funds from other sources. The detailed impact of these changes is not clear, thus it would be essential to understand clearly the level and use of existing and new funds to make sure that essential tasks related to the planning, management, environmental and enforcement of planning laws are properly resourced.
The summary view of the World Heritage Centre and IUCN is that there remains a significant cause for concern regarding the continued pressure for even greater ski development in PNP. Whilst the stated intention of the State Party to resist this appears clear, the reality on the ground cannot be assessed. The key points that need to be verified include the following requirements:
- That the legal protection of PNP and the authority of the MoEW to implement this protection are both clear and effectively applied;
- That the spatial limits for ski development are clearly defined, have not been extended within the boundaries of PNP, and will be respected in the future;
- That land use planning, Environmental Impact Assessment is used consistently for decisions taking in relation to all proposals for development and activities within and outside the boundaries of PNP;
- That these responsibilities are shared with, are translated to all other levels of national, regional and local governance that might impact on the Park, and that the interests of PNP are also represented in decision taking on developments that could impact on it but are located outside its boundaries;
- That there is sufficient and increased capacity of the MoEW to implement its role effectively and this work is adequately resourced. In this regard the recent decrease in core budget for PNP should be reinstated to fully ensure the effective functioning of the protection regimes for the property.
These matters should be addressed as an intrinsic part of the forthcoming IUCN evaluation mission to the property, and this mission should provide the basis for both an evaluation of the extension, and as a state of conservation report on the existing property, which should both be considered by the World Heritage Committee at the 34th session in 2010.
Furthermore, the World Heritage Centre and Advisory Bodies recommend that a state of conservation report on (unextended) properties should always be prepared, when those properties are both evaluated for an extension and examined by the World Heritage Committee for issues affecting the existing unextended property. This process would ensure that the withdrawal of the extension does not prevent the existing state of conservation issues faced by the property from being discussed by the World Heritage Committee.