COMPLAINT TO THE COMMISSION OF THE EUROPEAN COMMUNITIES CONCERNING RILA-BUFFER pSCI21.05.2008
Surname and forename of complainant:
Mr Toma Belev,
President of the Executive board of GREEN BALKANS Federation of Nature Conservation NGOs
160 Shesti Septemvry Blvd., 4000 Plovdiv, Bulgaria
Contact person: Alexander Dountchev
GSM:+359 885 511 022
This complaint is supported by the following Bulgarian nature conservation coalition: “Let nature remain in Bulgaria” which includes the following NGOs:
Balkani Wildlife Society
Borrowed Nature Association
The Bulgarian Association for Alternative Tourism
The Bulgarian Biodiversity Foundation
The Bulgarian Parks' Association,
The Bulgarian Phytocenology Society 2001
The Bulgarian Society for the Protection of Birds,
The Center for Environmental Information and Education
Green Balkans Federation
Information and Education Environmental Center of Sofia University "Sv. Kliment Ohridski"
National Movement Ecoglasnost
Nature Fund Association
“Save Irakli” Citizens' Movement
Shtastlivetsa Sofia Citizens' Movement
Za Zemiata Environmental Association
WWF Danube – Carpathian Program Bulgaria
“Citizens for Rila” Citizens’ Movement
Member States concerned: Bulgaria
Regions concerned: Alpine Biogeographical Region
1) Does the case have any direct link to European Community nature conservation legislation?
Yes X No
2) If yes to which directive?
79/409 (the Birds Directive) - articles 4(1) and (4)
92/43 (the Habitats Directive) - articles 4 (1); 6(2), (3) and (4)
Or which other legislation?
- 85/337/EEC (the EIA Directive)
- 2001/42/EC (the SEA Directive)
- Bulgarian accession treaty in conjunction with the agreed implementation of the Birds and Habitats Directives and related pre-accession agreements:
- CONF-BG13/01, Position of Bulgaria on Chapter Environment, 26 March 2001;
- CONF-BG 64/01, Additional information to position of Bulgaria on Chapter Environment, 25 October 2001;
- CONF-BG 02/03, Additional information to position of Bulgaria on Chapter Environment, 09 April 2003;
- CONF_BG 07/03, Addittional information to additional information CONF-BG 2/03, Position of Bulgaria on Chapter Environment, 19 May 2003;
- CONF-BG 14/03 Common Position of the European Union on Chapter Environment. Brussels: Conference on Accession of Bulgaria to the EU, 25 July 2003.
More particularly Bulgaria does not fulfil the following obligations:
1. Bulgaria has no transitional periods for the implementation of the Birds and Habitats Directive, according to the Accession treaty adopted by the Bulgarian Parliament in April 2005.
2. According to Article 4 (3) of Directive 92/43/EEC the list of sites referred in 4 (2) should be established within six years of the notification of this Directive and therefore the term of its application expired in 1998. In relation to this is also the date of application of Articles 6(2), (3) and (4) - according to Article 4 (5) sites referred in third subparagraph of 4 (2) should be subject to those paragraphs of Article 6. This means that their date of application also expires in 1998. The lack of a transitional period in the Accession Treaty means that these requirements should be met by Bulgaria at the date of accession.
- Bulgaria should implement Article 4 (1) of Directive 92/43/EEC prior to its accession in the Union and had to have submitted to the EU a draft list of potential Sites of Community Interest at the date of its accession. This obligation of Bulgaria was also communicated and agreed between the European Community and Bulgarian Government during the negotiation process (CONF-BG13/01/26 March 2001; CONF-BG 64/01/25 October 2001; CONF-BG 02/03/09 April 2003; CONF_BG 07/03/19 May 2003; CONF-BG 14/03/25 July 2003). Pursuant to Article 4(1) this draft list should be capable of leading to the establishment of a coherent European ecological network of special areas of conservation. The Commission must be provided with an exhaustive list of the sites of ecological interest on the national level which is relevant to the Directive's objective to preserve natural habitats and wild fauna and flora without jeopardising the realisation of this objective at Community level (C-371/98).
- Even if not yet classified as SCI according to article 4(2) all the potential future sites according to best available scientific data, should be provided with protection against disturbing species and damaging natural habitats, as otherwise the aims of the Article 4 (1) to submit in the EC an exhaustive list of sites capable of leading to the establishment of a coherent European ecological network of special areas of conservation could be jeopardised. As a matter of fact, if this is not the case, the species and habitats in the list may simply not exist at the time the potential SCI is designated as a SAC. This follows from the aim of the Habitats and Birds Directives, from the precautionary principle but it is also a matter of reasonableness, that if a network of sites is to be established, it is expected that all of the sites the network consists of shall not be deteriorated and the habitats destroyed before they are eventually designated as SCIs. The Member states, as well as the Commission, are obliged to interpret the Directives in such a way that enables the accomplishment of their goals. If the opposite was true and Art. 4(2) is interpreted in a way that Member States may allow the deterioration of the potential SCI, the site eventually may be designated as SAC when there is no subject of protection left in it or it is seriously damaged, which clearly will jeopardize the aim of the Directive. It is also a matter of prudence for the Governments of the Member States not to propose to the Commission sites for designation as SAC and to destroy or allow their deterioration in the meantime. Finally, if the Directive was meant to allow deterioration of sites in the period between their proposal and the final adoption as SCIs, this would result in some sites with no species and habitats left, which are included in the European Ecological Network Natura 2000 and receive the respective benefits, including financial, attached to their protection status. Simply habitats and species already scientifically evaluated according to the criteria set up in Annex III of the Directive 92/43/EEC, may already be non-existent or seriously damaged at the date of submission of the site and this would not be reflected in the information provided to the Commission (C-244/05). The preamble of the Directive 92/43/EEC also states that an appropriate assessment must be made of any plan or programme likely to have a significant effect on the conservation objectives of a site which has been designated or is designated in future.
- According to Article 4 (2) of Directive 92/43/EEC the Commission shall establish in agreement with each Member State, a draft list of sites of Community importance drawn from the Member States' lists. This obligation could not be met prior the date of accession as it requires an agreement between the Commission and an actual Member State, but not a candidate country. However, the obligation of the Accession Treaty to implement article 6 (2), (3) and (4) without transitional periods could be applied to the list of sites available at the date of accession. Respectively during the negotiation process the European Commission asked and Bulgaria agreed (CONF-BG13/01/26 March 2001; CONF-BG 64/01/25 October 2001; CONF-BG 02/03/09 April 2003; CONF_BG 07/03/19 May 2003; CONF-BG 14/03/25 July 2003) to apply Article 6 (2), (3) and (4) to the list of sites submitted in EC at the date of accession. In the light of the foregoing, where the national list remains incomplete, the Member states are advised to also ensure the non-deterioration of sites that, according to scientific evidence based on the criteria of Annex III of Directive 92/43/EEC, should be on the national list. One practical suggestion is to make correct use of environmental impact assessment (EIA) under Directive 85/337/EEC (impact assessment) in relation to potentially damaging projects. The European Court of Justice has already confirmed the importance which should be attached to sensitive natural sites when deciding whether projects should undergo an EIA under this directive.
3. According to Article 18 (1) of the Directive 79/409 EEC Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive within two years of its notification.
- That means that at the date of accession Bulgaria should have adopted list of SPAs. That list should comply with the requirements of the Article 4 (1) and Bulgaria should designate at that date all areas which contain the most suitable habitats for the species listed in Annex I and migratory species, based only on scientific criteria. Economical, social and other circumstances should not be taken into account in the process of defining of boundaries and designation. Bulgaria has no discretion to modify or reduce the extent of these areas and thus unilaterally escape from the obligations imposed on them by Article 4(4) of the Directive (C-355/90).
- Pursuant to this Bulgaria should provide with protection according to Article 4(4) all potential sites which according to best available scientific information are eligible for designation as SPAs even if they still have not been designated (eg C-374/98). If such sites are not provided with this protection, this can jeopardize the aims of Article 4 (1).
- According to Article 7 of Directive 92/43/EEC and in conjunction with the Accession Treaty Bulgaria should apply from the date of accession the article 6 (2), (3) and (4) to all SPAs submitted in the European Commission.
4. Bulgaria also has no transitional period in Implementation of Directives 85/337/EEC (the EIA Directive) and 2001/42/EEC (the SEA Directive). It should apply them for all projects/plans or programmes from the date of its accession.
3) Give a short summary of the subject of the environmental issue brought to the attention of the Commission:
The complaint raises two closely interrelated main violations of EU legislation, which demonstrate a total disregard by the Bulgarian authorities of their responsibilities towards the European legislation:
- Lack of sufficient designation of both pSCIs and SPAs in Rila Mountain grounded on purely economical arguments – existence of projects for construction of new ski runs;
- Lack of adequate protection in Rila Mountain of all sites not submitted and submitted in EU and construction and planning of new ski facilities and resorts without appropriate ecological assessments.
3.1. Lack of sufficient designation of pSCIs and SPAs
The following sites which were scientifically identified and proposed by NGOs are situated in Rila Mountain:
- pSCIs “Rila” BG0000495, “Rilski manastir” BG0000496 and “Rila-buffer” BG0001188 (App. 18.104.22.168). They form one complex site, but are divided due to administrative reasons to make their management easier, whereby BG0000495 coincides with the National park and BG000496 with the Nature park.
- “Rila” SPA BG0002055 (IBA 055) (App. 22.214.171.124) includes all territories of the “Rila” National park, Nature park “Rilski manastir” and also buffer territories.
On 2 March 2007, pSCIs “Rila” and “Rilski manastir” were approved by Resolution No. 122/02.03.2007 of the Council of Ministers (CM). After being postponed by Resolution No. 122/02.03.2007, “Rila-buffer” pSCI was still not ratified by Resolution No. 802/04.12.2007 of the CM despite the fact that the site meets all ecological criteria of Annex III of the Habitats Directive for proposal and subsequent classification as an SCI and despite the positive Statement of the Bulgarian Academy of Sciences (App. 2.1.1). The rejection of the site was proposed by the Minister of Environment and Waters after a decision of his Biodiversity Council on 13 September 2007. At that Council a representative of the Ministry of EW Mr. Velichkov, head of the Nature Protection department, proposed to reject the site arguing that it protects only a small percentage of species and habitats and that in the site there are a number of already approved projects for new ski resorts which will be stopped by its designation. In fact, the site is a high quality site (according to ETC criteria) and has bigger importance than the existing Protected Areas (a National and a Natural parks) for at least 4 priority species (bear, wolf, stone crayfish, hermit beetle) and one habitat type (91E0), as the last covers mainly the foots of the mountain slopes. All representatives of NGOs, Universities and Scientific Institutes except one voted in favour of “Rila Buffer” pSCI applying an official Statement of Support by the Bulgarian Academy of Sciences (App. 2.1.1). Representatives of the relevant Ministries and Agencies voted against the site. By not ratifying the “Rila-buffer” pSCI due to economical considerations the Bulgarian government has failed to fulfil the obligations of Articles 4(1) of the Habitats Directive (C-371/98).
On 2 March 2007, the proposed “Rila” SPA BG0002055 was approved in 54% of the “Rila” Important Bird Area (IBA) by Resolution No. 122/02.03.2007 of the CM. The approved area (“Rila” SPA BG0000495), in fact, coincides with the territory of the “Rila” (pSCI BG0000495). The remaining 46 % are situated outside the “Rila” National park (“Rila Monastery” Natural park and the buffers of both parks are excluded). By its failure to legally designate “Rila” as a SPA on the whole area of “Rila” IBA and provide a legal protection regime capable in particular, of ensuring both the survival and reproduction of the bird species listed in Annex I to the Directive the Bulgarian government has failed to fulfil the obligations of Articles 4(1) of the Birds Directive (C-355/90, C-166/97, C-96/98, C-415/01).
The reduction of areas of “Rila” SPA and the complete rejection of “Rila-buffer” pSCI for economical reasons deprives these areas from protection under Articles 19 and 31-33 of the Bulgarian Biodiversity Act (BDA). The Article 19 of the BDA allows preventive protection of the future sites according to Article 6 (2) of the Habitats Directive, by issuing specific banning orders preventing deterioration of habitats and disturbance of species. The Articles 31-33 transpose Articles 6 (3) and (4) of the Habitats Directive. This way, the rejection of these sites deprives them from any protection according to the national laws and leads to breaking both obligations: to have a list of sites relevant to requirements of both Directives and to provide those sites with protection according to Article 6 (2), (3) and (4) of the Habitats Directive. In respect of insufficient designation of SPAs in Bulgaria (including “Rila” SPA in particular) a complaint is submitted to the European Commission on 17 September 2007 (Ref. N 2007/4850).
3.2 Lack of adequate protection (C-117/03, C-244/05)
The complaint for lack of adequate protection in Rila Mountain concerns two types of territories:
A. Territories of sites which since 02.03.2007 (the date of publication of the Counicl of Ministers order in the state gazette) appear on the national list transmitted to the European Commission (“Rila” pSCI and “Rila” SPA, both with designation number BG0000495) (App. 126.96.36.199 and App. 188.8.131.52).
B. Territories of scientifically evaluated sites which are eligible for designation as pSCI or SPA but still not included in the national list - “Rila” pSCI and the part of “Rila” IBA outside “Rila” SPA BG0000495. Prior to this date, 02.03.2007, all sites have been scientifically evaluated sites, eligible for designation as pSCI or SPA (App. 184.108.40.206 and App. 220.127.116.11).
The first scientific information about the potential Natura 2000 sites in Rila Mountain was lodged in the MoEW in the beginning of 2005. Despite that fact, in the period 2005-2008 the Bulgarian authorities disregarded this information and adopted projects and plans in four ski resorts, greater part of which fall within eligible Natura 2000 sites and which already have lead (App.18.104.22.168-7) or could lead to interventions which incur the risk of seriously compromising the ecological characteristics of those sites (C-244/05). Most of the authorization procedures were deliberately accomplished before the Accession date of 1.1.2007 but were proved to be carried out with a great number of administrative and legal offences. The most striking offences are the authorization of projects and plans without an EIA/SEA, falsification of cadastral plans and the borders of the sites, authorization of clear cuts without legal grounds, etc. Still, the realization of these projects started mainly after 1.1.2007 but without further review of permits under Art. 6(2) (point 58 of judgement C-6/04), as follows:
1. The construction of the ski resort “Panichishte-the Lakes-Kabul peak” (called “Super Panichsihte”) started in 2006 after its project and SEA were rejected by the MOEW. Presently, investors are building a village with hotels, roads, reservoir, ski runs and a lift without EIAs (incl. screening procedures) (App. 1.1). Directly affected and already deteriorated are natural habitats and the habitats of wild species in “Rila” pSCI, “Rila” SPA, “Rila” IBA and “Rila-buffer” pSCI (territories in points A and B) (App. 2.2.6 and 2.3.1). The Bulgarian government denies that the construction activities are illegal (App. 2.1.21, 22.214.171.124. and 126.96.36.199) despite numerous sanctions imposed by the “Rila” National park directorate (App. 188.8.131.52). The thorough expert analysis (in English) of the NGO coalition about the case “Super Panichishte” is sent to the Council of Ministers and EC (App. 2.1.22).
2. The construction of a cabin lift and a ski run in the ski resort “Kartala” was authorized in 2006 without an accomplished EIA/Article 6 Assessment procedure (App. 1.2). Directly affected and already deteriorated are natural habitats and the habitats of wild species in “Rila” IBA that is proposed as SPA, and “Rila-buffer” pSCI (territories in point B) (App. 2.2.6 and 2.3.2). The Bulgarian government acknowledges that the construction activities are illegal but refuses to take legal actions (App. 1.2).
3. The final SEA of the General Spatial Plan (GSP) of the project “Samokov - Borovets -Beli Iskar” (called “Super – Borovetz”) forbade construction of new ski faculties in the National park. However, assessment of the impacts, including cumulative ones, on habitats and species from Annex 1 and 2 of the Habitats Directive (in “Rila-buffer” pSCI) and Annex 1 and 2 of the Birds Directive (in “Rila” IBA/proposed SPA) was not carried out (App.184.108.40.206 and 220.127.116.11). A new ski run was constructed in 2005 without EIA whereby a priority Pinus mugo-habitat in “Rila” pSCI was deteriorated (App. 2.3.3.). The construction of the first lift station of a cabin lift started in 2007 without an EIA or Article 6 procedure for the lift (App. 1.3.3.). RIEW Sofia authorized unknown number of village projects in “Rila” pSCI and outside the urban areas defined in the GSP “Super Borovets“ with screening-based estimates stating there is no need of EIA and thus disregarding the GSP(App. 1.3.4). Further deterioration and fragmentation of natural habitats and the habitats of wild species is expected in “Rila” pSCI, “Rila” SPA, “Rila” IBA/proposed SPA and “Rila-buffer” pSCI (territories in points A and B) (App. 2.2.6).
4. A project of a lift and a ski run in ski resort “Treshtenik” was authorized after an EIA in 2006 (App. 1.4). No assessment of the impacts on habitats and species from Annex 1 and 2 of the Habitats Directive (in “Rila buffer” pSCI) and Annex 1 and 2 of the Birds Directive (in “Rila” IBA/proposed SPA) was carried out. The construction of the facilities started in 2007 what lead to destruction of habitats in “Rila buffer” pSCI and “Rila” IBA/proposed SPA (territories in point B) (App. 2.2.6).
In 2008, during representations of the problems in “Rila” pSCI, “Rila” SPA and “Rila-buffer” pSCI throughout Bulgaria and on internet, more than 140 000 citizens have undersigned a petition urging the Bulgarian state to apply the Bulgarian and European environmental legislation in these Natura 2000 sites. Despite numerous complaints sent to the competent state authorities and despite the growing number of citizens’ protests throughout Bulgaria in 2007 and 2008, the Bulgarian Government repeatedly refused to take legal action and stop the illegal construction of infrastructure, buildings and facilities in “Rila” National park and adjacent territories. Evidently, the Bulgarian government violated Article 6(2) and 6 (3) of the Directive 92/43/EEC (in the territories of point A.) and article 4 (4) of the Directive 79/409/EEC (in the territories of point B. - SPA or IBA/proposed SPA) by not taking appropriate measures to avoid, by any of its acts, the deterioration of the habitats and significant disturbance to the species (resp. birds) for which the sites were proposed for designation and before the SCI/SPA designation process is finalised. So far, only the construction of the ski runs in Panichishte was halted by the State Forestry Association because of severe violations of the Bulgarian Forestry Law.
Moreover, the natural habitats and the wild species found on the territory of the scientifically identified sites “Rila-Buffer” pSCI, “Rila” SPA and “Rila” pSCI are additionally threatened by another four planned ski resort projects (App. 18.104.22.168) in Rila Mountain. Two of them (“Iskrovete-Govedartsi-Maljovitsa” and “Semkovo”) were initiated officially before 1.1.2007 but still not authorized and the other two (“Dolna bania-Ibar peak” and “Kostenets-Belmeken peak” ) were just announced in the Strategies for Development of two municipalities in 2006.
Detailed information about the eight ski resort projects planned in Rila Mountain and their impact on the scientifically identified sites “Rila-Buffer” pSCI, “Rila” SPA, ( “Rila” IBA/proposed SPA) and “Rila” pSCI is summarized in Table 1 and 2 of App. 2.1.31 and on the maps in App. 22.214.171.124-24. Some projects encompass already existing small ski resorts or individual ski facilities (App.126.96.36.199).
3.3 Consequences of the inadequate protection of species and habitats protected under the Birds and Habitats Directives
The realization of the referred projects in the four planned ski resorts Panichishte, Kartala, Borovets and Treshtenik (with total area of planned ski-facilities estimated at not less than 500 ha and total capacity of more than 70 000 tourists) endangers the conservation of the natural habitats and wild species hosted within or in the direct proximity of the ski resorts by:
1. Direct destruction of Annex 1 habitats and habitats of Annex 2 species caused by the realization of the project elements (mainly after 1.1.2007):
- Construction of buildings, infrastructure (roads, water reservoirs, ducts) and ski-facilities (lifts and ski runs) causing loss of natural habitats *4070, 4060, 95A0, 6150, 62D0, 9410, 91BA, 91CA (from 1.1.2007 to 1.5.2008 – total direct damaged area in “Rila” pSCI /SPA - 5 ha and more than 20 ha in “Rila buffer” pSCI / excluded part of “Rila” IBA/proposed SPA); Affected will be 91BA, 91CA, 9410, *91D0, 95A0, *4070, 4060, 6150, *6230, 62D0, 6410, 6430, 8110, 3130. For large carnivores – particularly bear and wolf all habitats encompassed in urbanised areas or ski zones are accepted as directly destructed.
2. Affecting structure and functions of the Annex 1 habitats.
- Degradation of habitats and alteration of the vegetation composition (e.g. conversion of xero- or mesophile to hydrophile/nitrophillous plant communities under ski runs (62D0, 6230, 6150). It is a result of: - nitrogen pollution from snow additives, very vulnerable are grasslands used as ski slopes and especially plant communities naturally poor in soluble nitrogen; - higher level of water supply (artificial snow); - prolongation of the snow-melting period on the ski runs; - trampling and soil compaction behind the ski slopes.
- Development of water and wind erosion of the soil as a result of the ski run constructions and soil compaction behind the ski slopes (extremely vulnerable are 6150, 62D0, 6230);
- Changes in the microclimate of the ecosystems – affect mainly habitat 9410 and 91BA – strongly sensitive to increased light and strong winds (often observed is mass tree fall after strong winds along the ski slopes);
Evidently, despite the relatively small area of the habitats directly destroyed up to now (ca. 25 ha out of at least 500 ha planned ski facilities) (Table 2 in App. 2.1.31), the integrity of the sites (incl. structure and functions of the habitats) will be significantly affected in the long term by the enhanced anthropogenic pressure, as well as the negative influence and the cumulative effect of the construction and exploitation activities within the project land areas - more than 30 000 ha in total.
3. Deterioration of habitats of the species listed in Annex 2 of the Habitat Directive and Annex 1 of the Bird Directive due to the disturbance:
- Wildlife avoidance. The most important impact arising from any type of urbanisation and from facilitating the access of people and motor vehicles in natural habitats, high noise levels induced by machines, people and facilities, lights in the night. Very sensitive are large carnivores (their breeding habitat – areas suitable for burrows) and mountain forest species of birds (Balkan Grouse Capercaillie Tetrao urogallus, Pigmy Owl Glacidium passerinum, Tengmalm’s Owl Aegolius funereus, Golden Eagle Aquila chrysaetos, etc). The estimation of the area of wildlife avoidance is based on scientific research and computer models, which are used to define the reference value of bear and wolf and other species and are used to fill the NATURA 2000 data base (best scientific knowledge). The areas of negative influences are assessed as buffers around the elements of the projects.
- Fragmentation of key habitats and creation of migration barriers for vulnerable species such as Brown bear Ursus arctos, Grey wolf Canis lupus, Balkan Chamois Rupicapra rupicapra balcanica, Caprecaile Tetrao urogallus, Haselgrouze Bonasa bonasia, White-backed Woodpecker Dendrocopos leucotos, Tree-toed Wodpecker Picoides trydactilus, Pigmy Owl Glacidium passerinum, Tengmalm’s Owl Aegolius funereus, etc. Habitats of the priority species Grey wolf and Brown bear (area of the habitats, their structures and functions) were significantly deteriorated at least on local level.
In detail: The assessment of the impact of the ski resorts on the wolf and bear includes assessment of:
1. The direct destruction and damage of habitats quality due to wildlife avoidance.
2. The damage of habitats quality due to habitats fragmentation and due to appearing of unviable patches of habitats.
3. The barrier effect on biocorridors, especially on bottleneck areas on the biocorridords.
(N.B.)Methodology of the assessment of the impact of ski resorts on the populations of the priority species grey wolf and brown bear:
1. Considered elements of ski resort projects affecting bear and wolf:
1.1 Ski facilities and ski runs.
Ski facilities and ski runs are leading to direct destruction of unfragmented and unanthropogenesed habitats suitable for the establishment of individual home ranges and burrows for both species. The existence of these facilities leads to enriching the area with people, which also leads to disturbance of these species and to the effect of wild life avoidance around the existing ski facilities.
1.2 Hotel complexes and buildings.
Similarly to ski facilities they lead to direct destruction of habitats and to wildlife avoidance in the surrounding habitats.
1.3 Roads and other infrastructure
They can be situated outside of the ski zone but could impact the habitats of the species and their biocorriodors. The barrier effect should be added to direct destruction and wildlife avoidance.
2.1 Area polygons of ski resorts
For the purpose of the impact assessment all three elements are mapped on GIS and the area polygons of the individual elements are summarized in joint polygons. As directly affected habitats are accepted all habitats within or in the proximity of the ski facilities, thus forming one area polygon of the ski resort. These area polygons are mapped in scale 1:100 000 based on maps published by the investors or on the written description of the existing and planned ski facilities, hotels and infrastructure.
2.2 Buffer areas
The assessment of wildlife avoidance is based on the number of people which will be concentrated in these urban areas. The bigger the number of people (the capacity of hotels and/or ski facilities), the wider the affected areas (buffers) surrounding the ski resort which reflect the behavior of both species in Bulgaria. This impact is divided in three steps assessments and the specific thresholds in terms of relation between number of people and area affected is derived from the field observations during the preparation of the bear action plan and the field observations on wolf. The thresholds of this impact applied in our assessments reflect the developed draft parameters for defining FCS of both species (under development of the BBI Matra project).
The same parameters were applied also as predictors of the developed habitat viability models (App. 2.1.25) for both species which were afterwards used as reference for filling the consensus Natura 2000 database developed in March, 2008 for the means of the biogeographic seminar.
The thresholds assessing wildlife avoidance impact on unfragmented habitats and suitable for establishing of burrow and home ranges are as follows:
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