The country's transition from a centrally planned economy to a market economy was expected to have a beneficial impact on the environment, as many past government policies were a major cause of environmental degradation.
Bulgaria's economic situation at the outset of the reform process was more difficult that in other transition economies. Its high dependence on trade with the former Soviet Union and other Council for Mutual Economic Assistance (CMEA) countries (accounting for 70% of Bulgaria's foreign trade) left the country economically weakened after CMEA trading arrangements broke down. What followed was a rapid decline in exports to traditional markets while the terms of trade deteriorated sharply as the prices of imported fuels moved to world market levels. Total output declined by over 25% from 1990 to 1992 while unemployment increased from less than 1% in 1990 to over 15% in 1993. Unemployment for 1994 is estimated to be 20% and is not expected to drop significantly. Value added in the industrial sector fell by about 40%, while value added in the agriculture and service sectors fell by 7% and 20% respectively.
Despite this extremely harsh economic environment, the country made significant progress during 1991 and 1992 on two fronts: market liberalization and macroeconomic stabilization. Most prices were liberalized in February 1991, simultaneously with the creation of a floating foreign exchange regime for the Bulgarian Leva in the newly established inter bank market. The budget deficit was brought down from 8.5% of Gross Domestic Product (GDP) in 1990 to less than 4% in 1991. However, since 1992, mounting budgetary pressures have reversed this progress with an increase in the budget deficit to 14% of GDP in 1993. For this year it is expected to be 6.5% of GDP.
The privatization process, although very slow, led to the transfer of a number of enterprises, mainly small ones, from the state to the private sector. This raises the issue of environmental liability for past damage caused by these enterprises.
Many new small enterprises emerged, mostly in the light industry sector, in the service sector, and most significantly, in the food processing sector. This growth was stimulated by land restitution and price liberalization of non-basic food products. This development makes the monitoring and enforcement of environmental regulations related to food processing especially difficult.
Despite the adversity of the transition period and the general economic crisis affecting the country, in early 1992 the government of Bulgaria adopted a National Environmental Action Plan (NEAP) based on the Environmental Strategy Study (ESS) carried out with the assistance of the World Bank and the United States government (the US Agency for International Development and the US Environmental Protection Agency).
The Environmental Strategy Study, carried out in 1991-1992, laid out the principles for environmental policy, reviewed the country's main environmental problems, and proposed a number of recommendations in response to these problems. It concluded that past economic and management policies were a major cause of environmental degradation, so that market-oriented reforms would produce environmental improvements. The ESS outlined the institutional, legislative and regulatory reforms required to implement its recommended policy, stressing a decentralized and participatory approach to environmental management and the importance of establishing a balance between a "command and control" approach and market mechanisms.
In 1994 the government of Bulgaria requested that the World Bank add updated information about Bulgaria to the ESS. In preparation for the update, the Ministry of Environment reviewed and assessed progress in the implementation of the original action plan. A series of meetings was held with experts from different ministries and other official institutions as well as municipal authorities and environmental non-governmental organizations (NGOs). A public hearing and discussion of the updated NEAP and the adopted Action Plan is scheduled for early 1995.
The Ministry of Health and its 28 Hygiene and Epidemiology Inspectorates (HEI) monitor the quality of air, drinking water, some specific and toxic industrial activities (galvanic, pharmaceutical, etc.). The number of HEIs corresponds to the old territorial administrative structure of Bulgaria.
Other institutions are responsible for particular sectors that significantly affect the environment: the Ministry of Territorial Development and Construction, for solid domestic wastes and water supply systems; the Ministry of Agriculture, for soil erosion and pure food production; the Committee of Energy, for the major power sources and energy production; the Committee of Forests, for the green system and forests.
Legislative power is concentrated in the Environmental Commission of the Parliament. The Office of the President cannot initiate environmental legislation.
Bulgaria is divided into 9 regions which include 255 municipalities. The larger ones have their own environmental departments. The local authorities have the right to adopt and enforce local standards and environmental taxes.
The business sector does not play any significant role in environmental protection at the national level.
In accordance with the Lucerne Declaration, the government will place the highest priority on minimizing damage to human health when setting its agenda for the Environmental Action Plan (EAP). Stopping environmental degradation of the type that damages natural resources and physical capital and/or causes considerable amenity loss is an important issue but is not as urgent as addressing health concerns. The recommended short-term strategy aims to address the most health threatening environmental "hot spots" and to continue advancing the design and implementation of an institutional, legal and regulatory framework consistent with the evolving character of the economy.
In developing its approach to environmental management, the government of Bulgaria was helped by a number of western countries, as well as by the Environmental Strategy Study and the National Action Plan from 1991-1992. These documents encouraged the exchange of ideas between the various branches of government and alerted them to the magnitude of the task ahead. In addition, progress was made in developing the legal framework for environmental protection and natural resources management. Many draft laws and regulations are awaiting consideration by the Parliament. Facilities for environmental monitoring have steadily improved with assistance from EU-PHARE and other donors. The Ministry of Environment has been restructured and its operation improved. National and municipal environmental protection funds were established from the revenues from pollution fees and fines. These funds finance a range of environmental activities.
The new Environmental Protection Law was passed in 1991 and subsequently amended in 1992. The new law introduced three basic principles:
The law defined the enforcement powers of national and local government agencies. A new framework for environmental standards was established, which allows regulations to be updated to meet health safety requirements, the use of the best available technology and experts, and harmonization with international statutes.
The law was followed in December 1992 by detailed regulations on performing Environmental Impact Assessments (EIAs).
Regulations on performing environmental audits are being prepared. These will cover existing enterprises, especially those subject to privatization.
Detailed work is proceeding on drafting specific regulations that will fill out the broad framework laid down in the Environmental Protection Law. Other regulations that need to be drafted include standards, permit monitoring, and other issues in the areas of air quality, water quality, waste management and natural resources. Ambient, emission and performance standards are being revised to fit into an enforceable regulatory framework. Five regulations covering water quality management and sewer discharge standards have been developed.
In order to improve the enforcement of these new regulations, particular emphasis has been given to the development of an efficient monitoring system and to improvements in the collection and dissemination of environmental data. A National System for Ecological Monitoring and Environmental Information was created and funded initially from the state budget. For this purpose, it is recommended that NSEMEI's funding be gradually shifted to the Environmental Protection Funds.
The level of pollution fines does not reflect pollution abatement costs; in addition, the fines have declined in real terms since 1989 as a consequence of inflation. Nevertheless, the system of fines and proposed pollution fees is a step towards implementation of the "polluter pays" principle. Enforcement of these penalties is hampered by the general economic decline, the grim financial situation of the worst polluters, and concerns about unemployment.
A nature conservation strategy was completed in early 1994. An action plan for its implementation is now needed.
Bulgaria signed and ratified the Convention on the Protection of the Black Sea in 1993. The Rio Convention on Biodiversity has been signed, but not yet ratified.
Emission standards for 9 air pollutants (dust, SO2, NOx, O3, various heavy metals) were updated and deposition standards for dust and heavy metals from air pollution were established.
The parliament is expected to adopt five pieces of draft environmental legislation (Sea Protection Law, Protected Areas Law, Waste Management Law, Forestry Law, Forestry Restitution Law). Seven other drafts (Air Quality Law, Water Law, Medical Plants Law, Noise Management Law, Game Law, Earth Treasures Law, Biodiversity Protection Law) are at different stages of preparation.
Although substantial progress was achieved in creating an appropriate legal and regulatory framework for environmental management, there is a need to improve legislative coordination. The Ministry of Environment is required to review all draft laws presented by other institutions before their submission to the Ministerial Council. This review process is supposed to provide the Ministry with the opportunity to integrate environmental considerations into new laws.
Unfortunately, the lack of an established procedure for incorporating comments from the review process undermines its effectiveness. As it stands, the initiating institution is able to either ignore or modify the Ministry of Environment's comments.
As a remedy for this, greater emphasis should be placed on integrating economic incentives in the core economic legislation that would encourage minimizing waste, emissions and discharges (currently, the only incentive for improved environmental performance is the duty-free import of environmental equipment).
Further hampering progress is the tendency of politicians to delay the adoption of environmental legislation, which they regard as a low priority. As a result of recent political changes, the environmental lobby is in a weakened position in the Parliament.
Since 1991, however, the number of Green Party deputies in Parliament has decreased significantly.
In 1992-1993 five Bulgarian NGOs (the Bulgarian Society for the Protection of Birds, the Bulgarian Society for the Protection of the Rhodope Mountain, Green Balkans, Ecoglasnost - Varna, Wilderness Fund) took part in the design of the Bulgarian National Biological Resources Conservation Strategy in cooperation with leading experts from the Bulgarian Academy of Sciences, the Ministry of Environment, the Committee of Forests, and other institutions. The strategy was carried out in partnership with three US NGOs - World Wildlife Fund-US, the Nature Conservancy, and the World Resources Institute. The project was sponsored by the US Agency for International Development.
In 1993 an Independent Assessment of Environmental Assistance to Central and Eastern Europe was carried out by the Borrowed Nature Association in cooperation with various NGOs, including East West Environment, UK; the Romanian Association for Environmental Management and Sustainable Development; the Center for Environment and Development, Poland; the National Society of Nature Conservationists, Hungary; and TEREZA, Czech Republic. The study was prepared for the "Environment for Europe" Conference in Lucerne, April 1993. A large public discussion on the Bulgarian situation was organized in Sofia and more than 60 NGOs and mass media representatives took part in it. The findings of the conference were acknowledged in the Bulgarian Parliament and by several ministries.
At the end of 1993 the Borrowed Nature Association assumed the role of a coordinating body (or "focal point") for environmental NGOs in Bulgaria and Europe in the "Environment for Europe" process and in the preparation of the Sofia Ministerial Conference, as well as the parallel NGO Conference in 1995. A working group of Bulgarian NGOs (Academic Youth Ecological Club, EcoForum, Ecoglasnost, Environment Management Training Center, Green Balkans, Eco-Life Association-Troyan, Universe of Man Foundation, and others) interested in this process was formed.
The environmental problems of the Danube basin were first brought up by Ecoglasnost in 1991, which resulted in the initiation of the international NGO movement "Danube Forum". In 1994, representatives of Borrowed Nature, Ecoglasnost, Green Balkans, Academic Youth Ecological Club, together with leading experts and scientists, organized a public discussion on the Project for a Strategic Action Plan for the Danube River and put forward their recommendations to the Ministry of Environment.
A workshop and public discussion on the transition to environment-friendly industry was organized by the Green Future Club in 1994. Problems related to nuclear safety, transboundary pollution, shortage of drinking water, and other problems of high national priority (the Mesta River Project, Sofia Airport, Belene and Kozlodui nuclear power plants) were brought to public attention through the work of Ecoglasnost.
Representatives of Bulgarian NGOs Borrowed Nature, Ecoglasnost and Eco-Forum represented the NGO position in the Inter-Institutional Committee for Environmental Projects to the Council of Ministers of Bulgaria. Thanks to the NGO participants, the Committee Statute was improved with regard to both NGO and public participation in the environmental decision-making process.
In 1994, seven Bulgarian NGOs (Academic Youth Ecological Club, Borrowed Nature, EcoForum, Ecoglasnost, Green Balkans, the Environmental Management Training Center and Universe of Man Foundation) summarized and formulated the environmental priorities of Bulgaria and sent a letter to the United Nations Economic Commission for Europe and the OECD Task Force on EAP for Central and Eastern Europe.
Bulgarian NGOs make an important contribution to environment-friendly mass media programs. Furthermore, they are the most active facilitators in accomplishing one of the basic tasks of environmental protection - the investment in human resources - by organizing various workshops, environmental education courses and campaigns, and the publication of books and other literature.
Concerning environmental liability for past pollution (which is levied on the state, as a previous owner), the Ministry of Environment has succeeded in its proposal to establish a liability fund from privatization deals. According to the new privatization regulations, 5% of the revenues from privatization sales will go into this fund. The liability fund will be under the overall management of the National Environmental Protection Fund.
In the past, standards were set with little consideration for the cost of enforcement. They were regularly violated as a result, and polluters often escaped serious punishment. Many of the enterprises would incorporate the costs of non-compliance in their financial balance. Since 1990, the environmental and health authorities have taken steps to:
Pressure from environmental NGOs and politicians to avoid softening the former environmental regulations, as well as delays in passing the new environmental laws, create obstacles to the introduction of the new standards. As a result, the environmental authorities continue to tolerate cases of non-compliance when the polluter cannot possibly bear the compliance costs.
Two significant steps have been made: building an efficient monitoring system (with support from the PHARE program and other donors) and improving the collection and dissemination of information. Begining in 1989, an annual Green Book for the state of the environment was published. The National Center on Environment and Sustainable Development has started a New Quarterly Environmental report, built upon the indicators in the Green Book. Public access to information provides an additional incentive to enterprises to comply with environmental requirements.
A three-layer National System for Ecological Monitoring and Environmental Information has been created to provide day-to-day data on the state of the environment, to support the enforcement of environmental standards, and to generate analysis and forecasts for decision makers on national and local levels. The first layer of the system includes the Ministry of Environment and the National Center on Environment and Sustainable Development, the second - the 16 Regional Environmental Protection Inspectorates, and the third - the set of monitoring laboratories (for ambient and effluent air and water quality control, soil quality control, radiation control, noise control, waste control and control on the status of the protected territories). Both air and water monitoring equipment is being completed by the PHARE Program. A total of 14 automatic stations (of which 5 are mobile) have already been delivered and 4 are expected. A radiation control network is being established and will be completed in 1994-1995. The total surface and underground water quality monitoring is carried out by the Ministry of Environment, except for the monitoring of drinking water, which is done by the Ministry of Health.
Still, there is no designed and implemented program for information dissemination and public education.
The NSEMEI is financed from the state budget and currently is experiencing a shortage of funds to support the operation and maintenance of the existing monitoring equipment (Of the existing 105 monitoring sites, 60 are maintained and supported by the Ministry of Environment, while the Ministry of Health handles 36). Since the trend toward reduction of state subsidies is expected to continue, the funding for the NSEMEI should be shifted toward the National Environmental Protection Fund and be given higher priority.
Bulgaria has faced considerable economic difficulties since 1991, marked by a sharp decline in total output and value-added and a dramatic rise in unemployment. There has been significant progress in market liberalization and macroeconomic stabilization. However, energy price reforms are unbalanced and tend to encourage the use of low quality domestic coal. The decline in economic activity and industrial production was accompanied by a drop in energy consumption and was marked by a shift in the composition of industrial output from industries which are major sources of air pollution towards those which tend to discharge water pollutants. Estimates of the impact of economic restructuring on pollution loads since 1989 suggest that
An inventory of polluted agricultural lands, carried out in 1993, identified the character and quantity of lands polluted by heavy metals, radionuclides, and oil products, as well as land with severe acidity.
Bulgaria made substantial progress in the areas of coastal zone management and nature protection. However, the prospect of new regional transport growth patterns, further tourist development, and changing economic pressure on both protected and unprotected areas revealed weaknesses in the coordination of policies across the relevant ministries and agencies.
Implementation of the NEAP was hampered by delays in launching the economic reforms on which it was based, especially those concerning privatization and the decentralization of responsibilities to local governments. While commendable progress was made in developing the legal and regulatory framework, much greater participation by industrial and other interested parties is required to achieve an effective and workable system of environmental management. As a result, improvements in environmental quality since 1991 are largely associated with the reduction in the level of economic and industrial activity and could easily be reversed once the economy starts to recover.
Since 1991 a number of measures were taken to strengthen the regulatory and enforcement capacity of the Ministry of Environment. The Ministry enhanced its functions and structure by creating three new departments as well as an information and public relations division. An Environmental Impact Assessment unit was created in the Economics Department for implementation of the Environmental Protection Law and the Environmental Impact Assessment regulation. The staff of the Ministry was increased from 100 to 130 and all experts went through various training programs.
The present structure of the Ministry of Environment consists of 8 departments (Air Protection, Environmental Economy, Environmental Risk, International Relations, Mineral Resources and Soil Protection, National Service on Nature Protection, Urban Ecology, and Water Protection), 3 divisions (EU PHARE Program, Environmental Legislation, and Information and Public Relations). The National Center on Environment and Sustainable Development as well as 16 Regional Environmental Protection Inspectorates assist the Ministry in carrying out its functions.
The evolution of the Ministry of Environment into a true normative, monitoring and enforcement agency will require a strong commitment to reform and a clear vision of the steps leading to a modern and efficient institution. In order for the Ministry of Environment's success to continue, it must carry out a comprehensive institutional analysis to define objectives, assess the human and financial resources necessary to carry out those objectives, and prepare a technical assistance and training program for institutional strengthening (based on needs and absorptive capabilities). Technical assistance will be needed to:
The Ministry of Environment has initiated a dialogue with other government agencies on their activities with significant environmental impact, and on the steps necessary to improve the division of responsibilities and eliminate the existing institutional overlap in environmental management. A Memorandum of Understanding was signed with the Ministry of Regional Development and Construction, the Ministry of Health, and the Committee on Forests. Agreements for collaboration on specific issues were reached with the Ministry of Agriculture, the Ministry of Industry, the Ministry of Defense and the Metrology and Standardization Committee. Each of these agencies has discrete environmental responsibilities.
Due to increasing economic difficulties and budget constraints, as well as the low priority given to environmental concerns, some government institutions (the Ministry of Industry, the Ministry of Transport, the Committee of Tourism) closed or significantly reduced their environmental protection units over the last two years. The Ministry of Defense has recently created an environmental unit, in response to emerging environmental liability issues related to post Warsaw Pact defense adjustments.
In response to the endorsement of the Environmental Action Program for Central and Eastern Europe by the Ministerial Conference "Environment for Europe" in Lucerne, 1993, the Ministry of Environment initiated a Ministerial Council decree for establishing an Inter-Institutional Committee for Priority Projects in the field of environmental protection and rehabilitation. The Committee is chaired by the Prime Minister and includes ministers and committee chairmen, representatives of science, business and NGOs. Further, the Ministry of Environment aims to enhance the objectives of the committee in order to develop a high-level Council for Sustainable Development.
On the local level, efforts were made to improve the enforcement capacity of the 16 Regional Environmental Inspectorates. Their staff was increased from 350 to 500 and supplied with new monitoring equipment. Training for operating the new equipment and in environmental policy and regulations was also provided. Most of the municipalities have strengthened their environmental units or positions in response to
Old technology and poor maintenance of the cement industry are major causes of pollution. Most of the industry's pollution-control equipment is old and needs to be replaced. There have been no substantial investments since 1991, except for the installation of improved technology in one plant.
The ferrous metallurgy industry is particularly energy-intensive. Air pollution from coke ovens, milling, and power generation is a principal concern of environmentalists. The industry's existing technology is far out of date, and an upgrading of all aspects is necessary. Some new equipment and structures have reportedly been purchased but were never installed, as resources were diverted to repairs and maintenance. Some new monitoring equipment was installed. The expenditure on pollution control was 80 million BGL in 1992, and 65 million BGL in 1993. A significant part of all these investments was provided by Bulgarian financial sources.
The composition of the food industry has changed dramatically since 1989. There are more than 1,000 state enterprises, and an unknown number of private ones, producing a great variety of food and beverage products. These enterprises are dispersed throughout the country. The emergence of numerous private enterprises makes monitoring and enforcement of environmental regulations more difficult, as these private operations are of recent origin and tend to be smaller. There have been no significant investments in pollution control since 1991. Waste water is discharged into streams or municipal sewers. Municipal treatment plants apparently provide the most cost-efficient means of controlling pollution.
Air pollution is the principal concern in the non-ferrous metallurgy industry. This industry creates particulates containing a high concentration of heavy metals and SO2. Some investments in modernization have been completed since 1991. Actual investments are small related to those in pollution control. Driven by public pressure, many investments in pollution control were completed or initiated since 1991, totaling 209 million BGL in 1992 and 170 million BGL in 1993.
Air pollution (SO2, NOx, hydrocarbons and hydrogen sulfide) created by the petrochemical industry is a principal concern. The contamination of the water supply and the disposal of processing sludge are also problems. Investments in modernization could increase processing efficiency and reduce emissions. Investments in pollution control have been minor since 1991, except for one plant in Pleven. It is cheaper for companies to pay fines than to invest in pollution-control equipment. For instance, in 1993 the plant in Bourgas paid $600,000 in fines, while the equipment to desulfurize the polluting heavy oil would cost $200 million.
There are a large number of plants which belong to the textile and related industries. Water pollution comes from pigments (in the case of textiles) and animal remains (in the case of leather). Water rates and charges for waste water treatment are too low to provide incentives for conservation and recycling. Minor investments in pollution control in these industries have been made since 1991. "Hot spots" problems related to the leather industry are concentrated in the Yantra river watershed and in the Danube towns downstream of Rousse.
There are 18 thermal power stations under the control of the Committee on Energy, 8 additional plants controlled by industry, and a number of smaller district stations which produce over 60% of the country's electric energy. Local lignite coal with low energy value, high sulfur and ash content is used as fuel. Air pollution (particulates, SO2, NOx and hydrocarbons) produced from these types of fuel is a principal concern. Although tall stacks partially reduce local problems, there is no flue gas desulfurization or control of NOx. No investments in modernization have been made since 1991.
Units 1-4 of the older reactors at the Kozlodui nuclear plant are considered unsafe by many western experts. While there have not been major environmental problems with these units, a potential danger exists. The environmental safety of both nuclear power production in Kozlodui and uranium mining have been extensively investigated by different international institutions. These institutions have pledged assistance to the Bulgarian government in these areas. The government of Bulgaria has made agreements with a number of international bodies that these units will be closed when alternative conventional generating capacity is available.
Over 19,000 hectares are polluted with heavy metals, 1,900 hectares with radionuclides, 25 hectares with oil products, and 400 hectares with very severe acidity. Outdated pesticides are stored in more than 1,400 different locations in 274 municipalities. This is a serious problem, and at present, there is no national strategy on how to resolve this issue. The problem is becoming increasingly significant because of land restitution.
Soil erosion, acidification, water logging, salinity, and heavy metal contamination have degraded about one-fifth of the country's total forest area. While Bulgarian forests seemed less affected by pollution than those in Central Europe, better forest management is a major concern. Timber cutting was prohibited under communism, therefore the main threat to Bulgaria's 280,000 hectares of protected areas was mining, development, and overuse by visitors.
In the last few years before the democratic changes, public discontent with both the grave environmental problems in this country and with the totalitarian system as a whole led to the establishment of the Committee for Ecological Protection of Rousse and the independent association Ecoglasnost, which gave birth to the present-day Ecoglasnost National Movement. A number of NGOs such as Green Balkans and the Bulgarian Association for the Protection of Birds subsequently emerged.
After a period in which a large number of NGOs were born and flourished, there was a noticeable decline in public interest and involvement with environmental problems. This decline paralleled a stagnation in the ranks of the environmental movements themselves. The decline in the economy, lower living standards, and the everyday struggle for subsistence have had their negative impact on the further development of NGOs. This is directly reflected both in the difficulties for existing organizations, some of which were forced to disband, and in the process of the emergence of new NGOs. At present, there are reportedly over 140 environmental NGOs. They represent different types of non-profit organizations and cover a wide range of associations, unions, foundations and centers. On the basis of their spheres of operation, they can be subdivided into three categories: national (with established branches throughout the country), regional (with established structures in a specific geographic region) and local NGOs. According to the age, educational level and professional orientation of their members, NGOs can be classified as groups of students or young people; groups of naturalists and nature-lovers who are generally involved in the protection and preservation of the environment; groups of experts, scientists and researchers in the field of environmental protection and ecology; and NGOs of mixed type.
In spite of all the difficulties of the transition period, the organizations which found external support to survive continue to implement their programs. Some of them (Ecoglasnost National Movement, Green Balkans, Green Patrols, the National Ecological Club, Borrowed Nature, the Union for Nature Protection, the Association of Bulgarian Ecologists, and Danube Forum ) are currently working on projects connected with national environmental protection priorities. Others, such as the Independent Societies Ecoglasnost-Stara Zagora, Varna and Bourgas, the Ecoglasnost National Movements in Rousse and Plovdiv, the United Front for the Environmental Salvation of Kurdjali, the Independent Association for Environmental Protection of the Vit River, and the Association for Saving the Srebarna Nature Reserve, have directed their efforts toward solving regional problems. A third group, including the Bulgarian Society for Animal Protection, the Bulgarian Society for Protection of Birds, the Bulgarian Society for the Protection of Birds of Prey, the Bulgarian Lepidopterological Society, and other NGOs are engaged in projects for the protection of rare biological species.
The concept of integrating the efforts of different Bulgarian NGOs was put forward at two national conferences in 1993. While the importance of the issue was acknowledged, there was little follow through.
A "green parliament" was established in 1993 by 27 organizations, parties and associations as a permanent forum for environmental protection issues.
Several Bulgarian NGOs (the Academic Youth Ecological Club, Borrowed Nature, Ecoforum, Environmental Management Training Center, Ecoglasnost National Movement, Green Balkans Movement, the Universe of Man Foundation, Eco-Life - Troyan and others) have formed a "national working group" whose aim is to participate in the "Environment for Europe" process and the Sofia Conference preparation for cooperation with other European NGOs.
Since the beginning of the radical changes in Bulgaria, environmental problems have received attention from journalists. However, the media's coverage of environmental issues tends to follow a number of patterns:
However, a permanent interest in environmental protection problems is maintained by the Bulgarian National Television programs "Eco-camera" and "Planeta," as well as several radio stations of national and regional significance.
Business sector attention to environmental protection problems is marginal. Very few companies are making the transition to environment-friendly technologies; nor have any associations of companies interested in environmental issues been established. The number of jurists experienced in environmental protection is insignificant. Bulgaria does not yet have any lawyers' associations that lobby for environmental legislation.
In the present transition period a substantial number of scientists are undergoing difficult times. Some of them have scattered throughout the world or are trying to survive by turning to other activities. While the existing laboratory equipment and the established scientific schools offer a good opportunity to tackle many important environmental problems, the institutions and equipment are not being utilized efficiently. This is due not only to a simple lack of money, but also to a lack of initiative (a quality with was consciously suppressed by the past regime). Also, there is a lack of experience in managing a scientific institution in a market economy.
In addition, there are donor-funded activities (in monitoring, capacity building, abatement equipment, and pilot conservation projects).
All internal sources are severely restricted due to the economic recession, the considerable erosion of government revenues, the consequent sharp budgetary spending and investment decline, and the reluctance of the state government, the municipalities and the state and private enterprises to borrow for environmental projects.
Under these circumstances the Ministry of Environment relies heavily on revenues from pollution fines and has been working systematically on the development of a system of other market-based enforcement instruments, i.e. charges and taxes. Such a system is potentially effective in protecting the environment and natural resources without distorting economic efficiency.
There are various reasons, however, why it has so far not proven useful in the case of Bulgaria. First of all, fines for water, air, and soil pollution are related neither to the extent of environmental damage nor to the costs of abatement. In addition, assessments of the financial cost of various pollutants to health, agriculture, and recreation (tourism) are neither available nor accounted for. Secondly, the level of fines, although significantly increased with the new Environmental Protection Law, is well below the cost of abatement. Thirdly, the fines are not indexed for inflation, which encourages payment delays (since no interest is charged on the outstanding fines). Finally, environmental authorities have weak enforcement powers.
As in other former socialist countries, extra-budgetary funds (EBFs) are well established in Bulgaria. These funds are financial accounts held outside the framework of the state or municipal budgets, funded from assigned revenues (taxes or other sources, e.g. fines and charges), and earmarked for particular programs or activities. Currently a total of 14 such funds exist, some of which were inherited from the centrally planned system (including an environmental protection fund); others were created to facilitate the transition to a market economy or to cushion the social impact of restrictive budgetary policy. An earmarked environmental protection fund was established at a national level, and some municipalities have also created such funds.
Earmarking usually distorts public financial management and undermines budgetary discipline. In the case of environmental protection, however, three factors favor the EBFs existence:
The lax application of environmental regulations and the failure to recover full costs for environmental services (such as sewerage, waste water treatment and waste disposal) create the need for subsidies or soft loans to encourage pollution prevention and finance critical environmental investments.
According to the new Environmental Protection Law, earmarked revenues from pollution fines and charges are directed to the National and Municipal Environmental Protection Funds. 70% of the revenues from fines go to the National Funds, and 30% go to the Fund in the violator's municipality. Revenues from charges and taxes (which are included within various environmental laws and Municipal Council regulations, but are yet to be approved) will also be shared, with 60% going to the National Fund and 40% to the Municipal Funds. The charges and taxes currently proposed include water pollution charges, product charges (for leaded gasoline), tariffs for visiting protected areas, and fees for collection of medicinal plants.
Both the National and the Municipal Environmental Protection Funds are managed by elected boards, with transparent operating procedures for the allocation of expenditures.
As in other transitional economies, both budgetary funds and earmarked revenues for environmental protection are very limited. Following a request from the Bulgarian Ministry of Environment, the World Bank assisted in early 1994 in the development of a proposal for a debt-for-nature swap. Further work developing the scope and institutional mechanisms for such a swap with Bulgaria's main debt holders is expected.
With regard to the operation of the newly created Inter-Institutional Committee for Priority Projects in the field of environmental protection, an official procedure of project assessment was adopted. Project approval depends on:
After reviewing the full range of environmental problems, it is recommended that particular attention be given to the following five issues:
These have been identified as environmental priorities by applying the criteria developed for the EAP.
The key recommendations concerning policies and institutional developments focusing on these environmental priorities are:
The main objective of the National Environmental Protection Fund (NEPF) is to support the implementation of a national environmental policy by providing financial assistance (grants or interest-free loans) to municipalities, companies and research institutions. The spending priorities of the NEPF included monitoring and control (40.5%), municipal and industrial waste water treatment (32.3%), reduction of air pollution (14.4%), research and development (5.5%), construction of solid waste disposal sites (3.9%) and support for conferences and publications (2.2%). Support for environmental NGOs accounts for 0.5%. Most of the expenditures (77%) are on a grant basis and only 23% are in the form of interest-free loans to enterprises, which allows multiple use of funds (revolving funding).
There are a number of drawbacks to the current structure of environmental funding which relies heavily on the earmarked National and Municipal Environmental Protection Funds (EPFs):
Even taking into consideration the affordability of the fines cannot assure a high collection rate. Currently the rate of collection is estimated to be approximately 50% of the fines imposed. Presumably, the low level of the fines should increase the collection rate for financially-strapped enterprises. However, this is rarely the case, since some of these enterprises are virtually bankrupt. On the other hand, they decrease pollution as a consequence of output decline. Some of these enterprises may not survive the economic restructuring, which makes them a low priority for environmental regulation. Enterprises which can afford to pay the fines are also the ones with a better financial performance. Therefore, the fines should be targeted toward these enterprises, providing them with an incentive to invest in pollution abatement and mitigation measures. A combination of higher fines and leniency, if feeble plans for pollution reduction are proposed, should be put in place.
That is why, on the revenue side, efforts should focus on incentives such as taxes and charges, rather than fines. On the expenditure side, disbursement priorities of the EPFs should be redirected from subsidies to regulatory development and increased monitoring and enforcement capabilities. The government should gradually withdraw from investments and subsidies as appropriate incentives are put in place for private sector investment. On the management side, supervision of environmental expenditures could be further improved through an advisory committee representing various experts and interested groups.
The World Bank, PHARE Program, EBRD, European Investment Bank and the Dutch and US governments provided the first energy loan to Bulgaria ($112.55 million) which included both policy and investment measures to support energy conservation.
In response to the NEAP, the World Bank approved a water and sanitation loan that will finance the completion of a number of drinking water and waste water networks and treatment plants. Support for the Bulgarian Government on coastal zone management, irrigation development, local government reform and various issues of environmental policy was also provided.
$1,162 million for the Danube basin clean up was provided by a number of international and national institutions: EBRD, World Bank, UNDP, European Investment Bank, USAID, Dutch and German governments, Cousteau Foundation, the Nordic Investment Bank and the Global Environmental Fund.
For Bulgaria, as a country especially rich in plant and animal life already extinct in other parts of Europe, it is crucial that funds be found to protect the country's unique biodiversity, and if possible, to resuscitate lost eco-systems.
A number of nature conservation projects are being carried out with the assistance of the governments of the USA (Srebarna lake), United Kingdom (eco-tourism), and Switzerland (protected areas), among others.
A biodiversity conservation project of $4 million is currently in preparation with the assistance of the US government. The Global Environmental Fund will provide an additional $150,000.
A number of Western governments and agencies provided technical assistance, policy advice and training in environmental economics, policy, risk assessment, and public participation, among other things.
PHARE assistance has helped the Ministry of Environment to retain more direct control over pollution monitoring.
The Ministry of Environment requested assistance from the World Bank to develop a proposal for a debt-for-nature swap in order to establish a new financial vehicle for environmental projects. Three factors are in favor of such a proposal:
In addition, the debt-for-nature swap is expected to facilitate the inter-ministerial dialogue on environmental project proposals, as well as to assist in the development of a transparent financial intermediary (a trust fund for the debt-for-nature transaction). Further development of this proposal is strongly encouraged.
As a result, environmental quality improved in general. Pollution levels were reduced in the "hot spots". In addition, the overall environmental management framework is better suited to undertaking further environmental measures. Nevertheless, implementation of the NEAP of 1992 was delayed by the slow tempo of the economic reforms on which it was based. Consequently, progress has been slower than anticipated, and other transitory environmental improvements have mainly resulted from the economic and industrial slow-down.
The update of NEAP, requested by the government of Bulgaria in preparation for the 1995 Sofia Ministerial Conference on Environment for Europe, is intended to assist the government in implementing the national environmental policy by focusing on three main objectives:
The IPRTD has formally designated one of its staff members to act as a liaison with NGOs and develop programs to enhance their relationship with the Ministry of Environment. NGOs generally feel that communication efforts on behalf of the Ministry have expanded, but there is still room for improvement. It is important to realize, however, that there are more than 140 NGOs and one person from the Ministry to provide outreach to the Third Sector is not enough. The NGOs cannot depend on the Ministry of Environment as their source of information.
Access by the public and NGO representatives to environmental investment decision-making forums is still not available.
Several donors have launched environmental training initiatives in Bulgaria. NGO representatives are among the most active participants in such issues. The Environmental Training Program, supported by the US Agency for International Development and the Environmental Management Training Center (supported by US Environmental Protection Agency), are running successful programs. The British Know-How Fund and the EU/PHARE program have also conducted helpful environmental training efforts. Also through PHARE, the University of Sofia and the Ministry of the Environment are developing an environmental studies program (within the TEMPUS program).
The Regional Environmental Center is supporting a series of NGO initiatives related to raising awareness of the public's "right to know" and increasing citizens' involvement in the environmental decision-making process.
Several recent NGO assessments (Bulgarian National Biological Resources Conservation Strategy - 1993, Independent Assessment of the Environmental Assistance to Bulgaria - 1993, as well as Independent Assessment of the Bulgarian Environmental Policy in the Transition Period, and Non-Governmental Assessment of the National Environmental Action Plan - both in progress, to be presented at the Ministerial Conference in Sofia in 1995) required active contacts with official institutions and extensive public involvement with environmental problems of national importance.
In connection with the Environmental Action Program for Central and Eastern Europe and the Bulgarian National Environmental Strategy (January 1995), as well as the preparation for the Ministerial Conference "Environment for Europe" and the parallel Conference of European Environmental NGOs, to be held in Sofia in October, 1995, both Bulgarian officials and NGOs are continuously improving the coordination and cooperation of their efforts.
The effects of economic restructuring on the environment might not, however, be entirely positive. To maximize the environmental benefits of economic reform, it is necessary to introduce appropriate regulations and economic incentives for pollution control. These would reinforce the impact of higher energy prices on emissions and ensure that resources were not transferred to industries that are considered internationally competitive only if no account is taken of the environmental damage that they cause. Thus, the NEAP should emphasize the need to combine command and control measures, including environmental impact assessments and emission permits enforced by legal sanctions for violations, with market-based investments such as pollution fees and user charges for natural resources.