Environmentally and Socially Sustainable Develonment and Central Asia Region 32051

Public Disclosure Authorized ENVIRONMENTAL SEQUENCING STRATEGIES FOR EU ACCESSION

PriorityPublic Investments for Wastewater Treatment and Landfill of Waste

*t~~~~~~~~~~~~~~~~~~~~~~~ Public Disclosure Authorized

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Fk - L - -. Public Disclosure Authorized

The World Bank

Public Disclosure Authorized May 2004 - "Wo BULGARIA

ENVIRONMENTAL SEQUENCING STRATEGIES FOR EU ACCESSION

Priority Public Investments for Wastewater Treatment and Landfill of Waste

May 2004

Environmentally and Socially Sustainable Development Europe and Central Asia Region Report No. 27770 - BUL

Thefindings, interpretationsand conclusions expressed here are those of the author(s) and do not necessarily reflect the views of the Board of Executive Directors of the World Bank or the governments they represent.

Coverphoto is kindly provided by the external communication office of the World Bank County Office in Bulgaria.

The report is printed on 30% post consumer recycledpaper. TABLE OF CONTENTS

Acknowledgements ...... i

Abbreviations and Acronyms ...... ii

Summary ...... iiM Introduction.iii Wastewater.iv InstitutionalIssues .xvi

Recommendations...... xvii Introduction ...... 1

Part I: The Strategic Settings for Compliance ...... 3

Part II. Implementation of Council Directive 1991/271/ EEC on Urban Waste Water...... 12 Requirements of the Directive.12 Implementing the Directive in Bulgaria.14 Investment Forecasts Full Cost Implementation.19 Financing.22 FinancingGap Full Cost Implementation Schedule.28 Investment Forecasts Least Cost Implementation.28 FinancingGap Least Costs Implementation Schedule .30 Conclusions and CriticalActions .31 Part m. Implementation of Council Directive 1999/31/EC on Landfill of Waste ...... 33 Summary Requirements of the Directive.33 Present Waste Quantities, Composition and Facilitiesand Present Waste Management Systems, Plans and Legislative Framework .34 Strategyfor Implementation of the Directive.41 Implementation Plan.59 Investment ForecastImplementation Planper Component .61 Total Investment Requirementsfor Fulfilling the Landfill Waste Directive.67 Financing.71 Conclusions and CriticalActions .76 Annexes ...... 78 References.125

LIST OF TABLES

Table 1: Summary of Estimated Investment Costs for WWTP and Sewerage Systems ...... v Table 2: Total Compliance Cost for Directive 1999/31/EC...... xiii Table 3: Growth in real GDP (% of GDP)...... 5 Table 4: Commitment Funding - ISPA and Cohesion Funds (projectionC million)...... 11 Table 5: Summary of EU Funds Received /Receivable and National Co-Financing(projection C million)...... 11 Table 6: Implementation Schedule ...... 18 Table 7: 1999-2001 Expenditure on Wastewater Treatment (MEUR) ...... 19 Table 8: Summary of Compliance Total Costs for WWTP and Sewerage Systems ...... 21 Table 9. Affordability Projectionsfor Future Wastewater/Sewerage Tariffs...... 27 Table 10: Settlements Discharge into Sensitive Zones ...... 29 Table 11: Summary of Compliance Least Costs Implementationfor WWTP and Sewerage Systems... 30 Table 12: Waste Accumulation in Bulgaria ('000 tons)...... 34 Table 13: Quantities of MunicipalSolid Waste ...... 35 Table 14: Municipal Waste A risingsfrom 1997- 2001 ...... 35 Table 15: Composition of Municipal Waste 1995-2001 ...... 36 Table 16: Generated and Landfilled Hazardous Waste ( '000 tons)...... 36 Table 1 7: Generatedand Landfilled Non-IndustrialHazardous Waste (not including mining waste) - ('000 tons)...... 36 Table 18: GeneratedHospital/Healthcare Waste ...... 37 Table 19: Percentageof Waste GeneratedGoing to Landfills in 2001...... 37 Table 20: Landfills Serving PopulationsGreater than 20,000 Inhabitants...... 38 Table 21: Review of Technological Conditions of Landflls ...... 38 ProposedRegions and Populations...... 43 Table 22: Collection and Set out Rate...... 45 Table 23: Breakdown and Targets of MunicipalBiodegradable Waste by Region based on 1995 Figures...... 48 Table 24: Strategy Implementation Plan...... 59 Table 24: Strategy Implementation Plan (Continued) ...... 60 Table 25: Actual Expenditure 1999-2001 ...... 61 Table 26: Administrative Costs (EUR)...... 62 Table 27: Cost of Thermal Treatment Facility...... 62 Table 28: Cost of Central CompostingFacility ...... 63 Table 29: Cost of Windrow Composting...... 64 Table 30: Landfill Costs ...... 65 Table 31: Total Cost Estimates...... 67 Table 32: Breakdown of Costsfor Implementation of the Strategy (EUR) ...... 69 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Acknowledgements

This report was prepared by a joint team of the World Bank and officials from the Bulgarian Ministry of Environment and Water. It is largely based on the review of background materials provided by the Department for European Integration of the Ministry of Environment and Water, and discussions with individuals and experts from the Ministries of Environment and Waters and Finance, and participants in the EU Accession Working group on Environment All assistance and support received from the Bulgarian counterparts is gratefully acknowledged. The following ECSSD staff worked on the report: Adriana Damianova, Team Leader, Anil Markandya, Lead Economist and Kateljin van den Berg, Young Professional, Environmental Economist. The team benefited from the guidance of Jane Holt, Sector Manager Environment and Marjory Anne Bromhead, Sector Manager Natural Resources. Pat Malony led a team of experts from ESB International and POVVIK Consult, Bulgaria, who collected the baseline information and carried out background analysis for the report. Anand Seth, Oscar de Bruyn Kops, Andrew Vorkink, Franz Kaps provided invaluable comments. Kirk Hamilton and Julia Bucknall were the peer reviewers. The report also benefited from the inputs and comments of Rosalina Quantanilla, and Anna Georgieva, Stella Illieva and Konstantin Pashev from the Country Office, and Sunanda Kishore, Consultant. Useful comments were received from Paul Dax, Environmental Finance Specialist and external reviewer advising the team on EU environmental accession requirements and financial plans.

The authors gratefully acknowledge the assistance provided by Irene Bomani for the preparation of the report. The team is also grateful to all institutions that provided immense assistance in data collection. Without their assistance it would have been impossible to complete the study. The team would like to thank Ms. Dolores Arsenova, Minister of Environment and Water, and Deputy Minister Fatme lliaz, and the Ministry team including Nona Karadjova, Slavitza Dobreva, Rositza Petrova and Vladimir Donchev.

i Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Abbreviations and Acronyms CEE Central and Eastern Europe CM Cabinet of Ministers BOD Biological Oxygen Demand COD Chemical Oxygen Demand EEA Envirommental Executive Agency EC European Commission EIA Environmental Impact Assessment EIB European Investment Bank EPA Environmental Protection Act EU EU Phare EU Financing Programme for Associated Countries GDP Gross Domestic Product FIDIC Federation Internationale des Ingenieurs-Conseils IF' s International Financing Institutions IPPC Integrated Pollution Prevention and Control ISPA Instrument for Structural Policies for Pre-Accession MoEW Ministry of Environment and Water MRDPW Ministry of Regional Development and Public Works REWI Regional Environment and Water Inspectorate NSI National Statistical Institute p.e./PE Population Equivalent (unit) PSP Private Sector Participation SAPARD Special Accession Program for Agriculture and Rural Development SEEPA State Enterprise for Environmental Protection Activities ToR Terms of Reference UWWTD Urban Waste Water Treatment Directive WWTP Waste Water Treatment Plant C&D Construction and Demolition CAPEX Capital Expenditure DEPA Danish Environmental Protection Agency D1Y Do It Yourself EBRD European Bank for Reconstruction and Development EEA Environmental Executive Agency M+E Mechanical and Electrical MHAT Multi Profile Hospitals for Active Treatment O&M Operation and Maintenance ppp Public Private Partnership

ii Bidgaria:Environmental Sequencing Strategiesfor EUAccession

Summary

Introduction

i. Bulgaria has accelerated the process of negotiating its accession to the European Union and is expected to become a member in 2007. This will entail compliance with the EU's Environmental Directives, since environmental protection has been elevated to the status of a "guiding objective" for the Union.

ii. Bulgaria accepts, and is ready to implement the acquis communautaire in the area of environment and has demonstrated a strong commitment to the protection of the environment, pollution abatement and preservation of natural resources. The Bulgarian Ministry of Environment and Water requested the World Bank to review and provide advice on the likely actions and investment costs for implementation of the environmental sequencing strategies for selected European Union (EU) Directives. There are severe constraints on public expenditure in Bulgaria; therefore this report will assist the Government on the priorities for sequencing public investments in the two areas demanding significant public resources -- wastewater treatment and solid waste management. The purpose of the report is to help the Government intensify internal dialogue on the planning of public finances for compliance with the Directives on Urban Wastewater and Landfilling of Waste. iii. Bulgaria has already made considerable effort and progress to advance compliance with the EU environmental acquis, especially in regard to the adoption of regulations and standards on air pollution, waste, water, chemicals and nature protection. Bulgaria's environmental legislation is framed under the new Environmental Protection Act (EPA) adopted in 2002 and is to a great extent compatible with the acquis. iv. Despite Bulgaria's progress to act in accordance with EU environmental Directives, full compliance with the Union's environmental acquis remains a challenge and requires a substantial investment program in environmental infrastructure and implementation activities in pollution abatement, waste management, wastewater management, and financing the associated operation and maintenance costs. v. The EU Commission has stressed the need for a realistic national and long- term strategy for implementation of the acquis in each sector and has encouraged candidate countries to mobilize significant domestic and foreign resources, especially private funding. In order to meet long-term EU compliance requirements beyond 2007, the Government of Bulgaria requested transition periods for implementation of some specific requirements of the EU Directives. It is estimated that the transition period will be extended to 2015. vi. This report provides guidance on assessment of the cost implications of adopting the EU Council Directive 91/271/EEC on urban wastewater treatment and the EU Council Directive 1999/31/EC on the landfill of waste, and for meeting the targets and requirements as set out therein. The study focuses on fnancial planning and only briefly looks into the contribution of the private sector. Although the focus remains on priority public investments for compliance, other issues, such as institutional responsibilities, resource planning and affordability are also touched upon

iiiI Bulgaria:Environmental Sequencing Strategiesfor EUAccession as they impinge on financial, organizational and management aspects of the compliance process. vii. The core audience of this report is professionals from the Ministries of Finance, Environment and Water, and Regional Development and Public Works who will take a leading role in the economic and financial planning and implementation of investment commitments for compliance with the EU Directives. The second audience will be the non-goverment organizations who will inform the public and facilitate the dialogue in the society on sound investment planning on the path to full compliance. Internally in the Bank the study will increase the understanding of environment, infrastructure and public finance staff of the compliance costs and investment needs with respect to the two referenced Directives.

Wastewater

Compliance vwith Directive 199112711EEC 98/15/EC-Urban Wastewater Treatment viii. The objective of this Directive is to protect the environment from the adverse effects of discharges of urban wastewater and wastewater from certain industrial sectors. The Directive sets out the requirements for the water sector specifically for collecting systems, treatment and discharge of wastewater, as well as the related legal provisions and deadlines for implementation. ix. Recognizing the significant investments and technical assistance needs for upgrading wastewater systems, the Government developed between 1999 and 2000, a national program for priority construction of the Urban Waste Water Treatment Directive (UWWTD) and sewerage networks for settlements with more than 10,000 population equivalent. The program's main focus is to improve municipal water services infrastructure in compliance with the Directive.

Present Situation on Compliance x. According to the National Statistical Institute (NSI) Yearbook, 785 million m3 wastewater was discharged in 2001 of which approximately 438 million m3 (56%) complied with the national effluent standards, which are close to the requirements of the Directive. 6% was partially treated, and 297 million m3 (30%) discharged without treatment. xi. The average connection rate for with a population equivalent' (p.e.) of more than 2,000 is 62%2. The remaining 38% will be connected to collecting systems during the 15-year period.

Costs of Full Compliance vwith EU Directive are Substantial Costs and Phasing of Investments xii. Total calculated investment costs for full compliance are estimated at around EUR2.9 billion. Bulgaria plans to implement Directive 91/271/EEC in 435 settlements grouped in three categories over the period to 2015. The first category

1Widely used measurement unit for the organic pollution of waste water equaling to the average pollution load of one person per day 2 The Directive applies only to settements with above 2,000 population equivalent (p.e.)

iv Bulgaria:Environmental Sequencing StrategiesforEU Accession includes 91 settlements exceeding 15,000 p.e., the second 30 settlements with a p.e. between 10,000 and 15,000, and the third, 314 settlements with a p.e. between 2,000 and 10,000. For the smallest towns an appropriate form of wastewater treatment, as defined in the Directive, will be provided. The Directive's requirements will be implemented in two stages: > By 2010 for municipalities above 15,000 p.e. (80.2% of population covered by the directive);

> By 2015 for municipalities with p.e. 2,000 - 15,000 p.e. (344 agglomerations, of which 30 towns have 10,000-15,000 populations). This group of Waste Water Treatment Plants (WWTPs) comprises 19.8% of the population covered by the Directive. It is assumed that the construction period of each WWTP will take approximately 3 years. This is in addition to the time required for preparation of the individual feasibility studies and to agree on funding, which can take up to an additional 2 years. Each investment stage, will thus take approximately 5 years. On this assumption, the feasibility studies and financing commitments for the 91 WWTPs that have to be completed by 2010, would need to be ready by 2007, which would imply the preparation of some 30 projects per year. An overview is provided in the following table. Table 1: Summary of Estimated Investment Costs for WWTP and Sewerage Systems

Population WWTP (MEUR) Sewerage (MEUR) Total equivalent (MEUR) 2,000 to 10,000 416 1,025 1,441 >10,000 648 541 1,189 TOTAL 1,064 1,566 2,630 Feasibility studies, Supervision & Project management cost (10%) 263 TOTAL 2,894 MEUR = Million FUR xiii. The burden of expenditures is highest in the period 2011-2015, with annualised wastewater costs from EUR 500 million in 2011 decreasing to EUR 340 million. In 2003, expenditures only amounted to EUR 43 million. The bulk of the investments in the period 2011-2015 are due to the preparatory phase, which takes 2 years in preparation time but are only 10% of total costs. If the target is anywhere near being met, preparation of the projects will have to start immediately. Technical assistance appears to be an urgent requirement.

Based on full cost implementation, a financing gap exists xiv. Based on the different available sources of finance for wastewater and sewerage investments: grant financing from ISPA/cohesion funds, national/municipal co-financing and revenues from tariffs for wastewater and sewerage treatment, as well as the projected necessary investments, and operational costs for full cost implementation of the Directive, a financing gap exists. This is presented in the following figure.

v Bulgaria: Environmental Sequencing Strategiesfor EU Accession

Full Cost Implementation

600 500 4Total of investment and r° 400 operational costs iS 300 -4-Total funds available from 2100 ISPA/cohesion/general tax Total available from tariffs

o OOo O@NO 'K,o0 Total funds available

Years

xv. The financing gap analysis shows that though the total funds available from ISPA/Cohesion Funds, National and Municipal co-financing and tariffs do increase substantially from year 2009 onwards, they are not sufficient to cover the total financing needs for investments and operational costs. This is further elaborated below. Cost will only be partly met by EU accession/cohesion funds xvi. Total funding from ISPA, Cohesion Funds and National Co-financing, is estimated at only EUR 302 million annually from 2009 onwards for both wastewater and solid waste together. However, available funding is insufficient to cover the entire investment and operating costs for wastewater, which comprise EUR 500 million in 2011 already. Available financial assistance from external and internal sources will cover about three quarters of the total investment costs associated with all wastewater treatment plants and approximately 45% of the investment costs for sewerage infrastructure. The latter will require additional efforts to raise funds to cover the short-run financing gap for large wastewater projects dominating in the plans during the next few years. xvii. Solving the problem of the shortage of funds and financial planning will be a critical factor in the success of compliance with the EU Directives. Other costs must be covered by either the (national or regional) budget and by consumers.

Costs Borne by the Budget

Government budgets are tight xviii. The State budget will remain the main source for capital investments in environmental infrastructure (see also paragraph 90 on private sector participation). It will provide matching funds to the co-financing of EU grants for the wastewater sector. The trend shows a slight increase in funds allocated from the State to investments in environmental infrastructure and projects since 1998. This increase should be sustained to meet the requirements for matching funding from the EU. xix. According to the Department of European Integration of the Ministry of Environment and Water, it plans to invest between 3-4% of the Gross Domestic Product (GDP) in environmental projects in the short to medium term. This target is a challenge since the level of gross domestic investments as a share of GDP has been low compared to other Central and Eastern Europe (CEE) countries. The implementation plans do not determine how such funds will be mobilized.

vi i Bulgaria:Environmental Sequencing Strategiesfor EUAccession

xx. There is close co-operation between the Ministry of Environment and Water, Ministry of Regional Development and Public Works and municipalities in the implementation of investment projects. The municipalities are the Ministry's most important partners in realizing environmental projects and activities. Municipalities contribute to project implementation with their knowledge of local needs, as well as with their financial resources or in-kind contribution. The size of these contributions is very limited and difficult to ascertain because the revenues from local taxes go to the central budget and later on are redistributed back to the municipalities. Municipalities' budgets face serious difficulties. There is little predictability in the system of central government transfers and grants. Accumulated arrears, mismatch between expenditure and revenue assignments pose significant constraints to investment plans. The future role of the local governments in implementing investment projects will increase as they become entirely responsible for providing public services. xxi. Bearing in mind competing sector demands for public funds and the limited contribution of different local sources, it is unrealistic to believe that Bulgaria can meet the requirements of the two Directives without relying on foreign assistance to mobilize the matching funds.

Capacityforexternal borrowing is limited xxii. Capacity for absorption of external borrowing and expansion of capital expenditure will be limited by the requirements of the currency board arrangements (CBA) 3 and the Maastricht criteria, which required current members' public debt to be brought close to 60% of GDP at the end of 2002. The CBA will remain until the introduction of the Euro, which is currently scheduled for 2009. xxiii. However, capital investment gaps for matching funds may require tapping additional resources from foreign lenders, which could require annual Parliamentary approval on the level of borrowing. Although the country's fiscal performance in 2003 has significantly improved4, in the medium run, increased borrowing for wastewater treatment (and waste management) could undercut the Government's macro-policies to achieve stable fiscal health. As indicated in the Public Expenditure and Institutional Review for Bulgaria 5, higher investments are needed for almost all sectors of the economy, while the ability of the budget to expand capital expenditure is limited under the existing spending inefficiencies at an intra- and inter-sectoral level. xxiv. Additional budget funds are now available through the recently registered State Enterprise for Environmental Protection Activities (SEEPA), which accumulates earmarked revenue from environmental resources taxes. These fall within the community-understood definition of an "Extra-Budgetary Fund". Funds from SEEPA will slightly decrease the burden on the State budget, however it is difficult to estimate how much SEEPA would finance in future projects through soft lending and

3The financial and poltical crisis in 1996-1997 led to the introduction of Currency Board Arrangement (CBA) on July 1, 1997. The Currency Board in Bulgaria has three major elements: a) a fixed exchange rate to the DEM (EUR); b) commitment by the central bank to exchange lev against the anchor currency upon demand and without limits, which implies that c) at any point of time the bank should have foreign exchange reserves that cover entirely its monetary liabilities. 4Third Review under the Stand-By Arrngement, RIF Country report No 03/206, July 2003 World Bank, Report No. 239790-BUL., August 2002

vii Bulgaria:Environmental Sequencing Strategiesfor EUAccession grants. On the basis of its annual revenue it could be estimated that SEEPA's annual contribution will not exceed EUR 20-25 million thus marginally bridging the financing gap. Additional questions remain on how efficiently the SEEPA funds are used. Costs Borne by Consumers

Problems with affordability xxv. Currently water supply and wastewater tariffs are administered by the State and cover drinking water, wastewater collection and wastewater treatment. The average water tariff in Bulgaria in 2002 was EUR 0.51/m3 of which EUR 0.41/m3 was for water supply, which implies that the current sewerage charge is in the region of EUR 0.10/m3. The average consumption of water amounts to 180 litres per capita per day. These charges are already at the intemational affordability limit of 4% of an average household income, with an average monthly household income of 170 EURlmonth and an average water consumption of 14 m3 per month per household.

xxvi. Income levels vary from municipality to municipality. The average level of income is generally sufficient to cover operating and maintenance costs of wastewater services. However, present wastewater tariff levels in the majority of towns are too low to support investment needs for infrastructure rehabilitation and expansion. Typically, wastewater charges are subsidized by drinking water tariffs. The tariffs cover the basic costs, but do not adequately allow for new investments.

xxvi. As a reference benchmark, payments for water and wastewater services are not to exceed 4% of the average household income. This sets an administrative lower limit of EUR 6.8 per month, per household with an average present monthly income of EUR 170-195. Hence, the present maximum socially acceptable water tariff would be EUR 0.48 /m3. With a present tariff of 0.41 EUR/m3 for water supply, there is not enough room for appropriate tariffs for wastewater, which are estimated to be around EUR 0.29/m3 for appropriate coverage of investment and operational costs. Because of income distribution patterns, "stepped" tariffs would not increase revenues sufficiently to overcome this broad affordability constraint.

xxvii. The affordability issue in Bulgaria in relation to cost recovery tariffs for the water and wastewater services is greater than in other countries preparing for compliance with the EU Directives due to the present low household income levels. Monthly household expenditures are approximately 40% lower in Bulgaria than in and 50% lower than in over the past 5 years. When household incomes increase due to economic growth, the potential for cost recovery tariffs will also increase.

xxviii. There is little incentive in water companies to invest in fixed assets, either, at a high rate of taxes on capital investments and low amortization levels. In addition, the collection of fees in some municipalities is ineffective. An increase in water tariffs will lead to a decrease in water consumption, this however may also result in a decrease in the water tariff collection ratio.

xxix. It is expected that over time a gradual increase in water tariffs is necessary to cover not only operation and maintenance costs, but also a part of the capital investments and loan finances where appropriate. Detailed analysis needs to be

vmi Bulgaria: Environmental Sequencing Strategiesfor EU Accession

performed in each municipality in order to ensure sufficient revenue for meeting the costs of operation and maintenance of the systems whilst ensuring that its share of the capital costs are repaid.

Private Sector Participation

xxx. The Government's 'Draft Strategy for Development and Restructuring of the Water Supply and Sewerage Sector' -- still under discussion -- provides for private sector participation options in the provision of water services. Concessions are considered for larger systems and the service or management contracts for smaller systems. The strategy needs to be developed further in order to provide viable options for all existing water utilities.

xxxi. Municipalities are not yet ready to attract private sector investments, due to: > The institutional set-up, this is discussed more in detail below. > Insufficient high levels of tariffs to cover investments and maintenance costs. However compliance requirements are achievable when markets for the development of public-private partnerships are in place to attract potential investors.

Investment Forecast Least Cost Implementation

xxxii. The UWWTD specifies that all settlements above 2000 p.e. are connected to the sewerage system and that the sewage collected should be treated to specific levels, depending on the characteristics of the receiving water. It states, however that "where the establishment of a collecting system is not justified either because it would produce no environmental benefits or because it would involve excessive costs, individual systems or other appropriate systems which achieve the same level of environmental protection shall be used."6 The Directive also requires member states to identify receiving waters that are sensitive to eutrophication, and discharges into sensitive water bodies must receive additional treatment to reduce the concentrations of total nitrogen (TN) and total phosphorus (TP). A precise definition and analysis of the sensitive areas make a big difference to the costs.

xxxiii. Since the Full Cost Implementation Analysis shows that even with substantial international grant finance, an increase in tariffs and planned national co-financing, there is still a substantial financing gap, therefore a least cost strategy should be pursued. A suggestion for such a least cost strategy is provided below. The assumptions used for the least cost implementation strategy are the following:

* River Basin - all settlements with more than 2000 p.e. will be provided with a WWTP (secondary treatment). * River Basin - for settlements from 2 to 10, 000 p.e only those discharging directly into the Danube river will be provided with a WWTP. The others will rely on septic tanks. * East and West Aegean Sea Basins - for settlements from 2 to 10 000 p.e. only those discharging into sensitive zones will be provided with a WWTP. The others will rely on septic tanks.

Bulgaria, The Challenges of Complying with EU Environmental Directives, World Bank, 2000

ix Bulgaria: EnvironmentalSequencing Strategiesfor EU Accession

The settlements discharging into sensitive zones are shown in the following table.

PE SENSITIVE RIVER BASIN TOTAL

Black Danube East West Sea Aegean Aegean

2,000 to 10,000 4 1 21 7 33

10,000 to 15,000 10 4 2 0 16

>15,000 17 30 18 5 70

xxxiv. Such a least cost strategy will bring substantial investment cost savings. An overview of the accompanying projected wastewater and sewerage investment costs is provided in the following table.

PE Number of WWTP Sewerage Total Settlements (MEUR) (MEUR) (MEUR)

2,000 to 10,000 102 124. 321 445

10,000 to 15,000 30 63 75 138

>15,000 91 585 466 1,051

TOTAL 223 772 862 1,634

Feasibility studies, Supervision & Project management (10%) 163

xxxv. Total financing required for capital investments for wastewater treatment plants is reduced to approximately EUR 772 million, and for sewerage systems approximately EUR 862 million for the period from 2000 to 2015. This includes the cost of feasibility studies, supervision and project management. The latter is estimated to comprise 10% of the total capital expenditure.

Financing Gap Least Cost Implementation Schedule xxxvi. Based on the same sources of finance for wastewater and sewerage investments: grant financing from ISPA/cohesion funds, national/municipal co- financing and revenues from tariffs for wastewater and sewerage treatment, the financing gap has been projected taking into account the Least Cost Implementation Schedule and accompanying investment and operational costs. This is presented in the following figure.

x Bulgaria: Environmental Sequencing Strategiesfor EU Accession

Least Cost Strategy -+--Total of investment and operational costs

400 -U--Total funds available 350 ______from O 300 ISPA/cohesion/general w 250 ~~~~~~~~~~~~~~~~~~tax ) 200 - Total available from u 150 tariffs 100 - 50 -______---- Total funds available

Years

xxxvii. The financing gap analysis shows that though there is still a financing gap in the early years, the gap is much smaller than in the full cost implementation plan and in 2010 and from 2012 onwards, the total funds available are enough for the investment and operational costs requirements. xxxviii. As a percentage of GDP the annual capital investment costs and expected costs for operation and maintenance for compliance with the wastewater directive are equivalent to an increase from 0.56% in 2003 to 1.18% in 2014 with a peak of 1.7% in 2011 for the least cost altemative.

Wastewater and Sewerage Expenditures as % of GDP

1.80% 1.60% 1.40% 1.20%

0~0.80% Co100% ln1 -* * ll *Annuai Operational and 0.60% | b Ma,lenance costs 0.40% OTotal wastewaTer and sewerage

0.20% m - * nvesMments 0.00% 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Years

xi Bulgaria: EnvironmentalSequencing Strategiesfor EU Accession xxxix. The initial calculations made by the European Commission in 1997 suggested that the CEE countries would have to devote on average about 5% of GDP to environmental related expenditures (investment and operations and maintenance). However, in their Pre-Accession Economic Programs (PEPs) most CEE Countries are putting forward medium-term fiscal strategies to improve budget balances and cut back taxation levels. The corollary is a need to bring down public expenditure by an average of 2.5% of GDP over the period 2000-2004. Reconciling these two sets of 7 objectives can only be done through deep cuts in regular expenditure programs

Waste Compliance with Directive 1999/31/EC-Solid Waste Disposal xl. The objective of the Directive is to provide measures, procedures and guidance for disposal of waste and prevent or reduce negative effects on ground water, soil and air. Given its complexity the Directive has been adopted throughout the Member states only over the last three years. Landfilling of waste to designated landfill sites occurs to varying extents throughout the EU. xli. Harmonizing waste management regulations with the EU principles is a priority. With the adoption of the new Waste Management Act, Bulgaria would rely heavily on simple disposal of waste to landfill. The Act will provide for full transposition and closing of the legislative gap on pre-treatment of waste, reduction of bio-degradable waste, and on groundwater EU standards. Like the other candidate countries, Bulgaria will also need a sizeable amount of external assistance from EU regional Funds to develop adequate waste management infrastructure. xlii. Bulgaria developed a National Waste Management Program in 1999, which provides for short to medium term perspectives for compliance with Directive1999/31/EC. This review highlights the need to improve the strategy for modernization of waste management and bring it in line with the sequencing requirement for the compliance period until 2015 and beyond. Priority should be given to planning for investment in landfill construction, rationalization and modernization of collection and transport services.

Present Situation with Regard to Compliance xliii. Landfilling is the base method for municipal waste disposal in the country. Pre-treatment of waste before land filling is not applied. Presently a total of 62 more landfills are planned to meet the country's waste disposal needs, a substantial increase over the current 58 landfills serving populations greater than 20,000. A preliminary examination of the proposed locations for landfill sites throughout Bulgaria indicates that there are many potentially overlapping service areas. The financial viability of many proposed landfill locations is also questionable given the low population base to be served and low potential for cost recovery.

Bemard Funck. World Bank Technical Paper no. 533. "Expenditure Policies. Toward EU Accession. 2002".

xii Bulgaria. EnvironmentalSequencing StrategiesforEU Accession

Costs of Compliance with Solid Waste Disposal Directive are Less Substantial

Costs and Phasing of Investments xliv. Total cost estimates to fulfill the Directive requirements amount to EURI.2 billion as outlined below:

Table 2: Total Compliance Cost for Directive 1999/31/EC (MEUR)

Years 2003-06 2007-10 2011-14 2015-20 Total Disposal Landfill Construction 33.5 14.0 51.0 351.5 450 Landfill Closure / Reclamation 13.5 7.5 14.0 5.0 40 Subtotal 4 7.0 21.5 65.0 356.6 490 Treatment and Collection Composting 7.0 106.0 32.0 145 Multiple-bin collecting 5.0 10.0 5.0 20 systems Incineration X 283.5 284 Subtotal 12.0 128.0 132.0 318.5 449 Hazardous Waste Treatment National Centre for Hazardous 40.0 40 Waste 4 Hazardous. Waste Landfills 13.0 27.0 40 Hospital-waste treatment 4.5 5.9 10 Subtotal 17.5 67.0 5.9 90

Planning and 6.7 1.3 7 1.3 10 Administration

GRAND TOTAL 83 218 203 677 1,039 xlv. The majority of investments are for construction, extension and rehabilitation of landfills and waste facilities and collection management. The dominating share is for construction and closure of landfills - EUR 450 million. Plans for landfill closure, which presently cover 563 ha will require EUR 40 million. Aftercare costs, which are not included, would raise these expenses to about EUR100 million. To comply with the Directive's requirement, Bulgaria has requested a transition period of two years for the reduction of biodegradable waste and 12 years, until 2015, to comply with the Directive for liquid waste for existing tailing ponds and similar facilities. Both these are reflected in the phasing shown in Table 2. xlvi. When looking at the overall annual environmental costs for waste (annualised capital costs and expected costs for operation and maintenance), the total annual costs will increase from EUR 8 million in 2003 to EUR 31 million in 2020, with a peak of EUR 173 million in 2018.

xiii Bulgaria:Environmental Sequencing Strategiesfor EU Accession

Costs as Percentage of GDP xlvii. The annual environmental costs for waste are equivalent to an increase from 0.05% of GDP in 2003 to 0.14% of GDP in 2020 with a peak of 0.81% of GDP in 2018 as shown in the following figure.

Annual Waste Expenditures as % of GDP

0.90%

0.80% X E*Annual OperaTional and 0.70% 0.70% I fL60% 0 _ CTotal wvaste ,nvesirnents : |

a> 0.50% '. , ;fi,*Pfz;i"1

0 0.40% *T ;- 9ltl---- 0.30% 0.20%

0.10% 0.00%

Years

Compliance costs are less but are not fully met by EU accession/cohesion funds xlviii. Though the costs for compliance with the Solid Waste Disposal Directive are less than compliance costs with the Wastewater Directive, (with a peak of EUR 87 million versus a peak of EUR 500 million respectively), committed funding from ISPA, Cohesion Funds and National Co-financing is not sufficient to cover foreseen costs for compliance. Other costs must be covered by either the (national or regional) budget and by consumers.

Costs Borne by the Budget xlix. Local revenue generation is limited by the lack of discretion to set tax rates, namely property tax rates. Revenue from local fees including from waste disposal charges is an insignificant portion of local revenues. This will require constitutional and legal amendments. Currently municipalities do not have the means and incentives to finance infrastructure investments, which diminish their capacity for absorption of EU funds. Local governments do not have much incentive to invest in water supply and wastewater treatment infrastructure either, unless legally they remain owners of the built infrastructure.

Costs Borne by Consumers

1. Affordability is also a key issue for appropriate sequencing of investment plans for landfill of waste. Its extent is limited by an assessment of the tariffs for

xiv Bulgaria: Environmental Sequencing Strategiesfor EUAccession waste collection and disposal that can be afforded in each municipality depending on income levels that differ and depend on the local socio-economic situation.

li. Waste tariff levels in the majority of small towns are too low to support investment needs in infrastructure. Besides, there is an administrative limit on how high the waste collection tariffs can be raised which stipulates that payment for waste management services shall not exceed 1% of the average household income. This sets the upper limit for the tariff for a household at a level of around EUR1.7 per month. Waste tariffs in Bulgaria, however, are calculated on the basis of taxation of property value. Instead, they should be calculated on the basis of associated costs per ton of waste i.e. reflecting the 'polluter pays principle'. This is strongly recommended for waste generated by the commercial sector. lii. The principle of waste tariff price formation should gradually change. In addition it should be based on associated operations and maintenance costs and should cover part of the capital investments for infrastructure and cost of borrowed investment capital, where appropriate. At the same time a sensitivity analysis should be performed in each municipality in order to ensure sufficient income to meet the costs of operating and maintaining the systems and pay off its share of the capital costs. There will however be a limit to how high the tariffs can be raised from an economic and social point of view. liii. By and large the collection of tariffs in most municipalities is ineffective (collection rate is about 70% on average), leading to losses in income for the operating companies. Increase in waste tariffs will not stimulate a decrease in waste generation rate at present, because as said earlier, tariffs are not related to the waste generation. Based on current designs and studies for new landfills it is estimated that the waste tariff per ton of waste is between EUR15.0 and 17.0 per ton. Assuming the generation rate is 0.505 tons per capita /per year and that households generate 1.2 tons per annum or 100 kg/month, this equals to EUR 1.5 - 1.7 per month/per household. This tariff is less than the maximum limit and should be economically affordable.

Several other problems for compliance with the directive exist liv. Waste quantities, characterization and composition: A review of the current status of waste arising within Bulgaria indicates that there is a need to develop a comprehensive and more accurate national waste database. Existing data falls short of the necessary content that is required to provide a sound basis for detailed future analysis and planning for waste management. Higher quantities of waste are reported due to lack of weighbridges for measurement of waste going to the landfills. In particular, existing data does not distinguish between household and commercial waste, which is all categorized as municipal, and the composition of these individual groups is unknown. Furthermore it is hard to obtain accurate information for different types of waste arisings. There appears to be a need for substantial assistance for improving the strategy for modernization of waste management and preparation of feasibility studies for Cohesion Fund support. lv. Efforts must be made to strengthen strategic regional planning to more accurately project future infrastructure requirements and capital expenditure costs to comply with the Directive. Comprehensive analysis should be accompanied by detailed and concrete regional planning. It is recommended that initially 28 area

xv Bulgaria: Environmental Sequencing Strategiesfor EUAccession waste management plans be developed from which 7 regional plans could be drawn up. lvi. One of the main stipulations of the Directive (Article 5) concerns the diversion of biodegradable waste from landfill. Possible avenues to achieve this have been explored and one has been developed in more detail with cost estimates. A more detailed assessment of the options should be incorporated into the overall strategy and planning process. To comply fully with article 5 of the Directive, it is recommended that a detailed national strategy on the treatment of biodegradable waste be developed. It is important to highlight however, that this should not be carried out independently of an overall integrated waste management system and development of a national waste database.

Institutional Issues lvii. By law, local governments are responsible for provision of public utilities, including sewage collection and wastewater treatment. The Ministry of Environment and Water (MOEW), through its regional divisions is responsible for developing and enforcing common policies for water protection and rational use.

lviii. The Environmental Executive Agency (EEA) is responsible for overall co- ordination and management of environmental monitoring systems. Responsibilities for monitoring the water quality are defined and include: (a) operators monitor discharges and their compliance with the standards; (b) Regional Environmental and Water Inspectorates (REWI) control discharges and monitor ambient water quality; (c) accredited laboratories or laboratories approved by the MOEW may carry out water quality tests. The Ministry of Finance (MoF) is responsible for the annual budget and capital investment plans in coordination with the Ministry of Economy (MoE) and the Ministry of Regional Development and Public Works (MRDPW), which may include provisions for bilateral grants, EU funds and loans. Local governments are responsible for co-financing, management and monitoring of the investment projects.

lix. The success of implementing the EU Directives hinges crucially on eliminating institutional and structural constraints. A large part of them are related to inter-governmental relations. Mobilizing investments for delivery of quality public services remains a challenge. A lot remains to be done for delineating central from local responsibilities in service delivery and putting central budget transfers and capital grants on a transparent and predictable basis through application of per capita standards. The role of local governments in the implementation of the water management strategy will increase as they become entirely responsible for the provision of public services.

lx. Currently municipalities do not have the means and incentives to finance infrastructure investments, which diminish their capacity for absorption of EU funds. Local governments do not have much incentive to invest in water supply and water waste treatment infrastructure either, unless legally they remain owners of the built infrastructure.

lxi. Bank experience through the LBRD-financed Water Companies Restructuring and Modernization Project has shown that greater fiscal and administrative autonomy at the local level is necessary for successful project implementation. Under the

xvi Bulgaria:Environmental Sequencing Strategiesfor EU Accession project, the municipalities owned part of the assets but did not have the ability to make independent decisions about raising tariffs or taxes and operations of the water companies. Experience under the project helped to highlight the importance of decentralization in the delivery of water service that led to the drafting of the amendment of the Water Law. In May 2002, the amendment to the Water Law changed the ownership structure of the Regional Water Companies (RWC). As per the amendment, the RWCs will be converted into an operating company and the network assets would be distributed between the State and the municipalities. The State would have full ownership of assets that relate to water resources or inter- municipality bulk water transfer. Each municipality would own 100% of the assets within its territory. Through this amendment, the operating company would be contracted by the owners (State and municipality) and be responsible for the delivery of quality service. Given that the operating company would not own network assets it will be easier to introduce the private sector within the company.

Ixii. Regulation of public services will be the responsibility of a regulatory body, which had to be established by the end of 2003. The Act on Water and Wastewater Services Regulator (AWWSR) under preparation, will specify the responsibilities of the regulator and regulated companies. The regulatory body will provide the methodology for setting service standards and tariff structure as well as general norms for the services provision. It will also monitor performance and have a role in dispute resolution between the companies and customers.

Ixiii. The Ministries of Environment and Water, Regional Development and Public Works, and Finance will remain the key institutions involved in environment and water management policy and investment planning. However, there are institutional constraints at the central level. The principles of program budgeting and mid term fiscal framework have been adopted and tested in MOEW, but have not been extended to MIRDPW. Second, the way of sharing responsibilities and the level of coordination between the Ministries needs to be substantially improved.

Ixiv. Limited institutional capacity and lack of experience in project management affects the effectiveness of public administration. While generally the establishment of new institutions or major reorganization is not imminent, improving management and implementation capacity at all levels would be critical. lxv. Solid Waste Disposal. Traditionally, many municipalities within Bulgaria have exercised their waste planning and management functions in isolation from each other and from other service providers, and essentially have acted as sole providers of public services and infrastructure in this area. In order to comply with the Directive, it is necessary to carry out waste management planning on a regional basis. Recommendations

Urban Wastewater (i) Affordability * Constraints. As a reference benchmark, payments for water and wastewater services are not to exceed 4% of average household income. This sets an administrative upper limit of EUR 6.8 per month per household, with an average present monthly income of EUR 170-195. Hence, the present maximum socially acceptable water tariff would be around EUR 0.48 /m3. With a present tariff of EUR 0.5 1/m3 of which EUR 0.4 1/m3 is for water

xvii Bulgaria:Environmental Sequencing Strategiesfor EUAccession

supply, there is no room for appropriate tariffs for wastewater, since the tariff is already at the maximum socially acceptable level. Tariffs of around EUR 0.29/m3 are estimated to be necessary for appropriate coverage of investment and operational costs. At present, the possibility of raising tariffs to include capital investment costs is therefore limited. In order to fully raise tariffs to cost recovery tariffs incorporating both operation as well as maintenance costs, household income growth is necessary. The 2002 growth rate of average household income in real terms was about 17%8. Adjusting the tariffs in phases to cost-recovery levels will encompass frequent (annually) adjustments of the tariffs to reflect the growths in household incomes. * Studying affordability levels on a regional basis with consideration of economic and financial costs and expectations of future developments will provide a sound basis for planning and phasing of investment projects. This will need to include studying the limit and impact on vulnerable groups before determining the degree to which criterion tariffs can be raised. Targeted social assistance programs are necessary to assist low-income households in paying water and wastewater charges and smooth the process of acceptance of tariffs increases. (ii) FinancingGap. In analyzing the government's full cost implementation plan, there appears to be a substantial financing gap looking at the investment and operational costs requirements and available financing from grants, co- financing and tariffs. This is a major problem in all candidate countries as it was in all EU member states. Bulgaria has additional challenges since its GDP per captial is smaller then in other accession countries (half that of Poland). In order to lighten the burden and enhance the implementation of the Directives, different options are proposed. * Pursue a least cost implementation plan. In order to lighten the investment burden, a least cost strategy is proposed. The least cost strategy closely looks into identifying sensitive and less-sensitive zones for the whole territory of the country and reduces the amounts of tertiairy treatments and sewerage systems necessary. The least cost implementation plan should also look carefully at the design capacity of the sewerage pipes. 180 liter/capita/day is higher than consumption patterns elsewhere in (Eastern) Europe. Public awareness campaigns for water saving will also assist in fulfilling the requirements of the EU Directive at more affordable levels. * Focus on the largest settlementsfirst. There are 30 towns with a p.e. between 10,000 and 15,000 and 314 settlements with a p.e. between 2,000 and 10,000 that fall under the target date 2014 and shall comply with the requirements of the UWWTD. Priority should be given to those with a p.e. between 10,000 and 15,000 where their infrastructure is already assessed and ready for preparation of a feasibility study. * Align investments with tariff increasepotential. Focus is on those settlements where average household income is higher and there are tourists or other business developments. Cost recovery issues will be better managed when investment planning of projects takes into account regional differences in

sAlthough it is very high compared to previous two years, part of may well be attributed to increased income from household plots and is subject to huge fluctuations depending on the weather conditions (in 2002, the weather conditions were exceptionally good)

xv..i Bulgaria:Environmental Sequencing Strategiesfor EUAccession

household income levels and the more prosperous municipalities are targeted in an earlier stage then their poorer counterparts. (iii) Institutional • Reinforcing institutional capacity for administration and technical implementation of investment plans; timely preparation of a project financing envelope to adequately absorb external finances, and efficient and transparent use of these funds. The government will need to ensure that it takes advantage of all available grant financing. Bulgaria is currently only able to spend 10% of the ISPA allocations. Hence the methodological and institutional capacity of MOEW for management of projects financed by EU Cohesion funds, should be strenghtened. Completion of institutional and administrative measures for implementing water sector management reform will be an integral part of this (Basin Directorate, MOEW Water Directorate). * Ensure better market opportunities. In order to sustain the costs necessary for compliance it is necessary to ensure better market opportunities for attracting potential investors. This includes development of appropriate legislation, change of market incentives, solution of problems associated with different shareholders and owners, introduction of cost-based accounting systems, improved control and better co-ordination among different participants in the decision making process. * Develop a register of industrial discharges of wastewater. Determine water quality objectives, monitoring needs and performance standards for monitoring. Enhance the permitting system by regularly updating wastewater discharge permits. lxvi Solid Waste Disposal Directive. Planning for the future must reflect a new approach to environmental management, involving constructive co-operation with local communities and neighboring municipalities, and utilizing the potential of the private sector to contribute to the delivery of public services. Planning must also be undertaken with a full appreciation of legislative and technological developments, which will have a critical bearing on the outcome. The implications of these new developments must be identified and quantified so that they can be factored into municipal/regional planning. lxvii Institutional challenges are not minor. Only 20% of landfills surveyed retain records. Many uncertainties exist with regard to the precise quantities of waste as well as the exact composition of the waste streams. lxviii. A National Waste Strategy is required. A national strategy for all the different waste streams would provide insight into the quantities, composition and technological and financial scenarios in order to fulfil the Waste Directive. The waste strategy should be prepared for all different government levels: local, regional as well as national, and contain a much more detailed investment forecast, taking into account regional differences, population densities and trends, transportation and logistic characteristics. The national waste strategy should put special emphasis on the regional planning of landfills, since many of the present proposed landfills do not have the sufficient population base for a financially viable regional operation.

Lxix. A Public Awareness Campaign is necessary to prepare the public to accept new waste management practices. Without positive public attitude, a successful

xix Bulgaria:Environmental Sequencing Strategiesfor EUAccession implementation program to comply with the Directive would be difficult to achieve, specifically since households will be partly responsible for implementing the Directive. The timing of the public awareness campaign should be streamlined with providing the technological options for citizens to reduce their waste, in order for the public not to be discouraged by lack of recycling/composting facilities.

xx Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Introduction

1. The Bulgarian Ministry of Environment and Water requested the World Bank to review and provide advice on the likely actions and investment costs for implementation of the environmental sequencing strategies for selected EU Directives. The purpose of the report is to help the Government intensify the internal dialogue on the planning of public finances for compliance with the Urban Wastewater and Landfilling of Waste Directives.

2. Public investment is a relatively weak point in public expenditure management in Bulgaria. Therefore, we believe this report wiUl guide the Government on the priorities for sequencing public investments in the two areas demanding significant public resources -- wastewater treatment and solid waste management. The study focuses on financial planning and only briefly looks into the contribution of the private sector. Although the focus remains on priority public investments for compliance, other issues, such as institutional responsibilities management and planning of resources, and affordability are also touched upon as they impinge on financial, organizational and management aspects of the compliance process.

3. The study commenced in late December 2002. The present document: Bulgaria Environmental Sequencing Strategies for EU Accession: Priority Investments for Wastewater Treatment and Landfill of Waste provides a review and elaborates on the Government's strategies for public expenditure required for compliance until 2015 in the two priority areas.

4. The study builds on the 2001 World Bank report "Bulgaria: The Chalenges of Complying with EU Environmental Directives", which provides an estimate of the overall compliance costs for implementation in fuUl of the EU environmental acquis. It also highlights key issues raised by the adoption and implementation of the EU legislation and standards, and assesses the implications for institutional arrangements, scope of investments and overall impacts on households. To address priority issues for wastewater treatment and waste management would require a significant amount of public resources and therefore the Government is expected to promote private participation in the financing and operation of municipal water and wastewater management, as well as of municipal solid waste management.

5. The core audience of this report is professionals from the Ministries of Finance, Environment and Water, and Regional Development and Public Works who wiU take a leading role in the economic and financial planning, and implementation of investment commitments for compliance with the EU Directives. The second audience will be the non-government organizations who wil inform the public and facilitate the dialogue in the society on sound investment planning on the road to full compliance. At the Bank we hope the study wil increase the understanding of environment, infrastructure and public finance staff of the compliance cost and investment needs with respect to the two referenced Directives.

6. The Government closed the negotiations on Chapter 22 on environment with the EU in mid 2003. Funding commitments of the European Union on which the estimates in this report are based, largely represent the Government's vision for the necessary compliance resources. Investment planning and negotiating financial support from EU and other donors will have to take into account efficiency and

1 Bulgaria:Environmental Sequencing Strategiesfor EUAccession affordability considerations. This paper hopes to provide some guidance in this respect.

7. Protecting the environment is the objective of EU environmental Directives. The same objective is the backbone of the national policies for compliance with EU environmental acquis. Past neglect of public investment in wastewater treatment and solid waste management and poor management led to the deterioration of municipal infrastructure and poor quality of environmental services. With the increasing demand for public resources from other sectors, mobilizing funds in the agreed amount and timeframe for meeting commitments of the implementation plans will be a challenge. Even with the projected economical expansion mobilizing resources in the required amounts (annual environmental investments) for meeting the requirements of the two Directives that shall range from EUR 51 million in 2003 to EUR 396 million in 2014 will be a challenge. This is equivalent -- with an increase from 0.4% of GDP in 2003-- to 2% of GDP in 2014 (assuming a GDP growth of 5% until 2006, and then slowly decreasing to 2.5% from 2009 onwards). Therefore, the Government should be selective in choosing its investment priorities, realistic in assessing implementation difficulties laying ahead, and innovative in mobilizing sufficient resources to cover total investment costs associated with treatment of urban wastewater and solid waste management. Furthermore, compliance requirements are achievable when markets for the development of public-private partnerships are in place to attract potential investors when public resources are limited.

8. What might seem to be achievable today may be demanding tomorrow. There are three reasons why the provision of reliable implementation plans which are realistic, compatible and consistent with the country's economic potential, and supported by strategic planning of resources, are of utmost importance for Bulgaria:

> They would allow alignment of the prioritization of public investments for compliance in the two areas with the potential of the state budget to raise sufficient funds during the compliance period; 0 They would provide a baseline for better integration of investments from various financing sources; and

> They would provide valuable information to decision makers at all government levels and for engaging the public in a dialogue on policy issues such as cost recovery and affordability of environmental services.

9. The report is organized in three parts. The main report starts with an overview of the strategic setting for Bulgaria's compliance with EU environmental Directives compliance potential. Part two lays out the requirements of the Directive on urban wastewater treatment; implementation plans, financing plans and strategic recommendations. Part three provides separately an analysis and details of the implementation plans, estimates of the compliance costs and technical requirements for implementation of the Directive for land filling of waste. Additional information and details on wastewater treatment plans, sewerage system, sensitivity status of larger settlements within the main river basins, guidance on landfill construction, area waste management plans, and landfill permits are included in the annexes.

2 Bulgaria:Environmental Sequencing Strategiesfor EUAccession Part 1: The Strategic Settings for Compliance

10. Bulgaria has accelerated the process of negotiating its accession to the European Union. For the EU, environmental protection is a priority and this priority is exemplified through the 1987 Single European Act, which provides the power to act on all environmental matters and, further through the 1997 Amsterdam Treaty, through which environmental protection has been elevated to the status of a "guiding objective".

11. As a working hypothesis, the Government expects Bulgaria to become a member of the EU in 2007. The EU Commission has stressed the need for a realistic national and long-term strategy for implementation of the acquis in each sector and has encouraged candidate countries to mobilize significant domestic and foreign resources, - especially private funding. To meet long-term EU compliance requirements beyond 2007, Bulgaria requested transition periods for implementation of some specific requirements of the EU Directives. It is estimated that the transition period will extend until 2015, which was taken as an assumption for the analysis of the report. The report provides guidance on the strategic implementation requirements on wastewater treatment and landfill of waste outlining investment needs and public financing sources. In doing so it pays special attention to the realism of forecasts and provides analysis of the affordability to the extent the data made available to the team provided for that.

12. Bulgaria accepts, and is ready to implement the acquis communautaire in the area of environment and has demonstrated a strong commitment to the protection of the environment, pollution abatement and preservation of natural resources. Bulgaria has already made considerable effort and progress to advance compliance with the EU environmental acquis, especially in regard to the adoption of regulations and standards on air pollution, waste, water, chemicals and nature protection. Bulgaria's environmental legislation is framed under the new Environmental Protection Act (EPA) adopted in 2002 and is to a great extent compatible with the acquis. The new EPA calls for a stronger integration of environmental protection with other areas of national policy. The government has updated the State environmental policy to include full transposition of the framework directives dealing with air, water, waste, nature protection and chemicals. Procedures for Environmental Impact assessments (EIA) as set out in the EPA are consistent with the EU directives on EIA. Bulgaria has adopted several acts that are specific to environmental media such as air, water and waste.

13. Transposition of EU environmental legislation started as early as the mid 1990s. Bulgaria adopted the Law on Limitation of the Harmful Impact of Waste on the Environment together with the accompanying by-laws, which creates the basis for transposition, and implementation of the EU legislation in the waste management sector. The requirements of Directive 99/3 1/EC on landfill of waste are transposed to a large extent in Regulation No. 13 on the conditions and requirement for construction and operation of waste landfills.

14. The general principles of the EU policy in the water sector are introduced by the new Water Law, which employs the principles of integrated water resources management on a river basin principle. In addition, by-laws regulating the permit regime for water users and water use from water bodies, including discharges of municipal wastewater have been enforced. Regulation No. 6 on Emission Standards of Harmful Substances in Wastewater Discharges introduces norms for collecting

3 Bulgaria:Environmental Sequencing StrategiesforEUAccession systems, effluent standards for wastewater from municipal WWTP and industries, treatment of sludge. Regulation No. 12 provides the requirement, which must be met by the water treatment facilities. Regulation No. 7 sets up the requirements for discharging industrial wastewater into municipal collections system.

15. Despite the progress made by Bulgaria to act in accordance with EU environmental directives, full compliance with the Union's environmental acquis remains a challenge and requires a substantial investment program in environmental infrastructure and implementation activities in pollution abatement, waste management, wastewater management, and financing the associated operation and maintenance costs. The process of harmonization and coalescing policies needs to be undertaken for all sectors and in all areas of economic activity. It also applies to the colossal task of taking stock of the current environmental concerns in the country and bringing them in line with the objectives set forth under the EU accession policy. In doing so, key challenges and issues for Bulgaria for the adoption and implementation of the EU standards in the two areas will be highlighted in this report. Implementation strategies must be developed bearing in mind the potential impacts on Bulgaria's economic priorities. As compliance with the acquis requires huge investments in particular sectors in Bulgaria, there is a need to assess the implications for their institutional arrangements, cost issues and feasibility of investments, the scope for managing investments efficiently and fmally, their relevant implications for the households. This report will review these issues to the extent possible based on the data made available to the team by the Government counterparts.

16. Investment Estimate. In terms of implementation of the EU environmental investment requirement, Bulgaria has made considerable progress. The environmental expenditure has been relatively stable ranging between 0.9 and 1.3% of GDP. In 1998, EUR 142 million or 1.3 % of GDP was allocated for environment. For the pre- accession period, the EU also promised assistance to candidate countries for investments in several sectors through the EU Financing Program for Associated Countries (PHARE), Instrument for Structural Policies for Pre-Accession (ISPA) and Special Accession Program for Agriculture and Rural Development (SAPARD).

17. However, EU support and other external assistance are limited to meet the needs for all acquis chapters. Expenditure on environmental protection has increased in most candidate countries. It is expected that for Bulgaria the investment costs, irrespective of the length of the period granted to achieve them would be very high, ranging from C 5.5-8 billion (in 1998 prices). The overall annual environmental costs including discounted investment costs and operation and maintenance to keep up with capital spending, will range between EUR 1.2-1.7 billion or EUR 149-205 per capita per year at the end of the investment period2 . This is equivalent to 4.9-6.7% of forecast GDP (assuming GDP growth of 5% and 2015 is the estimated year for full compliance) or 11-16% of 1998 GDP (higher than most other countries in the region which are also vying for accession to the EU). It is expected the private sector will assume 50% of the costs.

18. Macroeconomic and Social. The implementation strategy for EU Directives should be developed with the social-economic situation in mind, and paced with the transition period required to achieve full compliance by 2015. Key consideration must be given to affordability, and capacity of the State budget to allocate resources

2 Bulgana The Challenges of Complying with EU environmental Directives (2001), The World Bank 4 Bulgaria:Environmental Sequencing Strategiesfor EUAccession under a currency board arrangement 3(CBA) in order to respond to competing sector needs. The Government is committed to keep the CBA until accession to the EU. The CBA provides a stable nominal anchor and facilitates the political economy of reforms. It has served Bulgaria well in the last 6 years and was instrumental in achieving macroeconomic stability and sustained growth. Since 1997 real GDP has grown by over 22%, and in 2002 for the first time the pre-crisis level was exceeded. At the same time inflation has been contained to single digit levels averaging 5.8% in 2002, and the external position has been stronger than initially expected, with the external current account deficit declining to 4.4% of GDP in 2002 from 6.2% a year earlier. This allowed further growth in domestic savings and increased investment. There have been major structural changes in the economy, with the private sector share of GDP exceeding 64% and the share of private sector banks in the banking system increasing to 83% at end-2002. Based on Bulgaria's GDP growth in the past and the forecasted future economic developments, the following GDP growth scenario (in real GDP) has been taken as a basis for the calculations:

Table 3: Growth in Real GDP (% of GDP)

1992 1993 1994 1995 1996 1799 1998 1999 2000 2001 2002

-7.3 -1.5 1.8 2.9 -9.4 -5.6 4.0 2.3 5.4 4.1 4.8

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2012

5 5 5 4 4 3 2.5 2.5 2.5 2.5 2.5

2013 2014 2015 2016 2017 2018 2019 2020

2.5 2.5 2.5 0 0 0 0 0

Source: NationalInstitute of Statistics

19. Bulgaria's fiscal policy, which is the primary instrument for keeping macroeconomic stability under a CBA, has supported the growth and poverty reduction objectives of the Government. Fiscal deficits have been kept at less than 1% of GDP over the last 6 years, and public debt to GDP ratio has declined from over 100% before the crisis in 1996/1997 to below the Maastricht criterion of 60% lately. In general, Bulgaria has made important progress towards achieving sustainable growth in the process of EU accession. In its 2002 regular report the European Commission (EC) recognized Bulgaria as a functioning market economy and endorsed 2007 as a target accession year, backed by a detailed roadmap and increased 4 financing. The roadmap specifies the benchmarks against which progress will be

3 The financial and political crisis in 1996-1997 led to the introduction of Currency Board Arrangement (CBA) on July 1, 1997. The Currency Board in Budgaria has three major elements: a) a fixed exchange rate to the DEM (EUR); b) comnmitment by the central bank to exchange lev against the anchor currency upon demand and without limits, which implies that c) at any point of time the bank should have foreign exchange reserves that cover entirely its monetary liabilities.

42002 Regular Report on Bulgaria'sProgress Towards Accession, Commission of the European Communities October 2002; Roadmapsfor Bulgariaand , November 2002. (Bulgaria has provisionally closed 24 of the 29 chapters of the acquis conununautaire, and announced plans to complete negotiations by mid 2004.)

5 Bulgaria:Environmental Sequencing Strategiesfor EUAccession monitored and provides for increased pre-accession financing to help the country meet the membership criteria. The roadmap also recognizes the fact that environmental considerations are not often thoroughly considered in the context of other economic issues and the need to focus on investments particularly with regard to waste management, water quality, industrial pollution and risk management.

20. The economic recovery has been instrumental in reducing poverty by nearly two-thirds compared to the level in 1996/97. However, the poverty rate in 2001 is more than double the 1995 pre-crisis level and growth dividends have not reached all groups. Pockets of poverty and vulnerability with strong ethnic, regional, or age dimensions dominate the social landscape. In addition, unemployment at 17.7% of the labor force in 2002 remains relatively high. By mid-2003 unemployment declined by close to 4 percentage points as a result of active labor market programs and sustained economic growth. However, the increasing duration of unemployment is still a concern, with 55% of the unemployed out of work for more than one year. High unemployment rates and low household incomes will impact the ability of consumers to bear the cost of increasing utility tariffs if environmental investment cost is passed on to consumers. The impact will be far larger as it will limit efficiencies and ability to generate matching investments to fully absorb EU funds. Therefore compliance and financial strategies will have to be developed with consideration of affordability and protection of consumers' economic rights.

21. Another challenge Bulgaria faces is the low level of investment, which has just recently started to grow. Gross domestic investment as a share of GDP in Bulgaria has been slightly more than half of the levels in other CEE countries, where it has been close to 30% of GDP. In addition to catching-up with long-deferred expenditures to rehabilitate its infrastructure and to cope with the stringent requirements for accession, Bulgaria will need a sharp increase in new investments in the medium term. Government capital expenditures have also been lower compared to other CEE countries, and the so-called Cohesion countries. Capital expenditure in Bulgaria collapsed to below 1% of GDP in 1996, and grew to about 4.5% in 1999 and 2000, but subsequently declined to 3.2% in 2002. Environment and infrastructure investments, along with general public services have absorbed the lion's share of capital expenditure. The poor condition of environmental and utilities infrastructure and maintenance backlog will, however, require considerable capital investments to support growth and EU accession requirements. However as indicated in the Public Expenditure and Institutional Review for Bulgaria, higher investments are needed for almost all sectors of the economy, while the ability of the budget to expand capital expenditure is limited under the existing spending inefficiencies at an intra- and inter- sectoral level. In addition, the low capacity to evaluate and prioritise investment projects is further constraining the growth of public investments.

22. While fiscal policy is basically appropriate to ensure macroeconomic stability, the main fiscal challenge is to work towards an improved allocation of expenditures to achieve a balanced budget in the medium-term, while lowering the overall tax burden - especially payroll taxes - to boost investment and employment, and reducing external indebtedness. So far fiscal adjustment has been made possible by revenue expansion rather than expenditure rationalization. A decade long neglect of investments in basic infrastructure has been exacerbated by several years of declining capital and maintenance expenditures and expenditures in operations and maintenance which have borne the brunt of expenditure cuts. The fiscal strategy will also need to adjust to the decline in privatization revenues, a main source of fiscal financing, as the privatization program is soon to be completed.

6 Bulgaria:Environmental Sequencing Strategiesfor EU Accession

23. The medium term macroeconomic framework centered on the currency board arrangement is expected to support rapid and sustainable economic growth in the coming years. The medium term outlook9 envisages robust growth of about 5-5.5% per annum (2003-2005), low inflation of around 4% annually, gradual narrowing of the external current account deficit, a further reduction in debt-to-GDP ratios, and a balanced budget by 2005. Growth would be driven by a continuous rise in investment and improved export performance in line with the expected recovery in external demand from the EU and increased competitiveness of Bulgarian goods on international markets. Consistent with the planned upgrades in infrastructure sectors and continued progress towards EU accession, investment is likely to grow at a higher speed and reach at least 22% of GDP in 2005. Despite the continuing slow growth among Bulgaria's main trade partners so far, macroeconomic performance has been good and is expected to improve further in 2004-2005 as EU economies may start their recovery and the cumulative effect of structural reforms in Bulgaria start to pay off.

24. Investment forecasts in this report take into account the mid-term growth projections of GDP. It is estimated that environmental expenditure for accession will increase to 4.9% and reach 6.7% of GDP by 2015, although currently they are slightly over 2%. For comparison the average for CEE accession countries is about 4% of GDP, which is twice as high as the percentage for existing EU member countries.

25. The gross average monthly income grew, on average by 11.7% in 2001, compared to the respective period in the proceeding year. In September 2002 it reached EUR 74/month. Household income was estimated to be 195 Euro/month in 2002. Productivity in industry rose by 15.7% in the period 1997-2001. Household spending on utilities accounted for 13.7% of household budgets in April 2003 and is steadily increasing mainly due to the adjustment of household prices for electricity and district heating in 2002 -2004 to cost recovery levels.

26. Regional growth disparities are significant. Differences in GDP, income, investments and employment vary significantly among municipalities. Large municipalities like Sofia city, , , Varna, Russe, , , and show higher growth rate. Municipalities of Montana, , , Turgovishte, Smolian, and Pazardjik show a relatively low growth rate.

27. The success in achieving compliance goals hinges critically on eliminating structural constraints related to intergovernmental relations. The delayed fiscal decentralization reform is perhaps the most controversial and challenging issue in public service delivery. Delineating central and local responsibilities and putting central transfers on a transparent and predictable basis through application per capita standards will ensure autonomous functioning and accumulation of adequate local income for infrastructure financing of solid waste and wastewater treatment. Local revenue generation is limited by the lack of discretion to set tax rates, namely property tax rates. Revenue from local fees including from waste disposal charges is an insignificant portion of local revenues. This will require constitutional and legal amendments. Currently municipalities do not have the means and incentives to finance infrastructure investments, which diminish their capacity for absorption of EU funds. Local governments do not have much incentive to invest in water supply and

9 Bulgaria: Third Review under the Stand-By Arrangement, IMF Country report No 03/206, July 2003

7 Bulgaria:Environmental SequencingStrategies for EU Accession wastewater treatment infrastructure either, unless legally they remain owners of the built infrastructure.

28. Institutional. The Ministries of Environment and Water, Regional Development and Public Works, and Finance will remain the key institutions involved in environment and water management policy and investment planning. However, there are institutional constraints at the central level. On one hand the principles of program budgeting and mid term fiscal framework have been adopted and tested in MOEW, but have not been extended to MRDPW. Second, the way of sharing of responsibilities and the level of coordination between the Ministries needs to be substantially improved.

29. The role of local governments in the implementation of a water management strategy will increase as they become entirely responsible for the provision of public services. They will be engaged with the implementation of investment projects included in the implementation strategies. Regulation of public services will be the responsibility of a regulatory body, which will be established by the end of 2003. The Act on Water and Wastewater Services Regulator (AWWSR) under preparation will specify the responsibilities of the regulator and regulated companies. The regulatory body will provide the methodology for setting service standards and tariff structure as well as general norms for the services provision. It will also monitor perfonmance and will have a role in dispute resolution between the companies and customers.

30. Population. Bulgaria's population at the end of 2002 was 7.8 million. The average population has decreased by about 8% over a decade. This is mainly due to relatively high emigration and negative population growth. The total fertility rate of Bulgaria at 1.14 in 2002, is just over half of the level required to maintain the population size constant over the long term. Population size has been eroded by net out-migration in the last two decades. Population growth is negative averaging - 0.7% a year since 1990, which is one of the highest decreases experienced in the CEE countries, (see figure below). This is a significant overall decrease particularly when population is used as a factor in determining the amount of waste arising in Bulgaria and population covered by wastewater treatment facilities.

Population Growth in Bulgaria

10000000

60000008 1 . I

O 4000000 - _ :

2000000

1934 1946 1956 1965 1975 1985 1992 2001 Year

Source: National Statistics Institte

31. Financialand Investment Framework. Bulgaria's fiscal policy is oriented to maintain macroeconomic stability and support growth. Fiscal adjustment, however, will have to be made to provide space for higher EU pre-accession grants, which are

8 Bulgaria: Environmental Sequencing Strategiesfor EUAccession planned in the Roadmapl° for Bulgaria and Romania. The EU Commission's indicative financial assistance for the period 2004 - 2006 to support Bulgaria in "taking the remaining steps necessary to meet criteria for membership" are as follows: EUR 368 million in 2004, EUR 399 million in 2005, and EUR 430 million in 2006. It is estimated that the EU grants will increase progressively to reach an additional 40% by 2006. However, the increasing assistance is linked to the absorptive capacity of grant funds on a yearly basis and efficient management of the funds. Given that the basis for the increase is the average assistance during the period 2001-2003, the Government will have to double its efforts by the end of 2003 to achieve higher absorption of EU funds. Fiscal adjustment will hardly be possible without significant rationalization of expenditures and accelerated structural reforms. If the real GDP growth sustains at about 5% per year up to 2006 the possibility to increase budget capital investments by State budget and concession borrowing remains limited. This means that the primary investment costs for environmental compliance may be borne by EU grants and other external financing, however this will still require increased co- financing from the State.

32. A recent study of the EC estimates that EU enlargement could increase the growth of GDP of the acceding countries by between 1.3 and 2.1% annually, which would allow Bulgaria to have a more dynamic development in the years after 2007. Taking into account the current growth of GDP to 2006 and the assumption that GDP will continue to increase on an average of 5% (including the increase of GDP growth resulting from Bulgaria's membership of the EU) during the coming years, the essential resources for environmental investments and forecasted available financial sources from SEEPA, local, and central government have been calculated and given in Tables 4 and 5. National investment commitments from ISPA and the Cohesion Funds for the period 2000-2020 amount to a total of EUR 4,552 million, which include national co-financing plans. These projections are based on an assessment of the existing and potential financing sources and reflect the investment strategy developed by the Ministry of Environment and Water, Ministry of Regional Development and Public Works and Ministry of Finance. Projections for environment investments for the compliance period are EUR 3,867 million.

33. SEEPA is planning to finance EUR 20.4 million of its revenue on capital investments in waste management and water treatment plants. On the basis of its annual revenue and investments in similar projects in recent years it could be estimated that SEEPA would contribute approximately EUR 20-25 million per annum which will slightly decrease the burden the State budget has to bear in co-financing EU grants. Alternative matching sources such as from public-private partnerships have not been the forerunners in Bulgaria and are not likely to grow significantly in the short to medium term in the absence of clear regulatory provisions and economic incentives.

34. According to the Department of European Integration of the Ministry of Environment and Water it plans to invest between 3-4% of GDP in environment projects in the short to medium term. This target is particularly a challenge since the level of gross domestic investments as share of GDP has been low compared to other CEE countries. The implementation plans do not appear to determine how such funds will be mobilized. In addition the degree of under-investment for environmental

10 2002 Regular Report on Bulgaria'sProgress Towards Accession, Commission of the European Communities October 2002: Roadmapsfor Bulgaria and Romania, Brussels November 2002. (Bulgaria has provisionally closed 24 of the 29 chapters of the acquis commiunautaire, and anmounced plans to complete negotiations by mid 2004.)

9 Bulgaria:Environmental Sequencing Strategiesfor EUAccession services have caused significant deterioration of basic infrastructure, which will absorb significant initial costs. Today the vast majority of projects that have been approved by ISPA are committed at 75% ISPA funding and 25% national co- financing. Bearing in mind competing sector demands for public funds and the limited contribution of different local sources, it is unrealistic to believe that Bulgaria can meet the requirements of the two Directives without relying on foreign assistance to mobilize the matching funds.

35. Table 4 presents Grant financing available to Bulgaria through ISPA and Cohesion Funds, as well as the projected national co-financing. Table 5 presents the summary of actual EU funds received to date. From the tables it can be concluded that Bulgaria currently only spends 10% of the ISPA allocations possible.

10 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

Table 4: Commitment Funding - ISPA and Cohesion Funds (projection f million)

2000 Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Total

ISPA Funds 33 79 65 47 59 65 70 417

Cohesion 107 188 242 242 242 242 242 242 242 242 242 242 242 242 3,194 Funds

National 11 30 22 16 20 22 23 27 47 60 60 60 60 60 60 60 60 60 60 60 60 941 Co- Financing

Total 43 109 86 62 78 86 94 134 235 302 302 302 302 302 302 302 302 302 302 302 302 4,552

Cumulative 43 152 239 301 379 465 559 694 928 1,230 1,532 1,834 2,136 2,438 2,740 3,042 3,344 3,646 3,948 4,250 4,552 Total

Table 5: Summary of EIU Funds Received / Receivable and National Co-Financing (projection f million)

Year 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 lrotal

EU Funds 3 8 6 22 72 90 68 66 83 112 159 209 236 242 242 242 242 242 242 242 242 3,068

FNiationnalg Co- 0 0 0 12 25 31 23 21 23 29 40 52 59 60 60 60 60 60 60 60 60 799

Total 3.25 7.91 6.48 35 97 122 91 |86 106 141 199 1262 1295 1302 1302 1302 1302 1302 1302 1302 i302 3,867

11 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Part II. Implementation of Council Directive 1991/271/ EEC on Urban Waste Water

Requirements of the Directive

36. Directive 1991/271 sets out a number of requirements concerning collecting systems, treatment and discharge of wastewater as well as the related legal aspects and deadlines for implementation. Member States are required as of 1991 to:

(i) Provide within the 2.5 years"1 prior regulation and/or specific authorization by the competent authority or appropriate body for all discharges of urban waste water and industrial waste water from the particular sectors mentioned in the Directive, as well as for all discharges of industrial waste water into urban waste water systems12.

(ii) Designate sensitive areas according to one or more of the following criteria within the period of 2.5 years13:

a. Water bodies which are found to be eutrophic14 or which in the near future may become eutrophic if protective action is not taken; b. Surface freshwaters intended for the abstraction of drinking waters and which could contain more than 50 mg/l of nitrates, if action is not taken; c. Areas where further treatment is necessary to fuifill other Council Directives.

The list of sensitive and less sensitive areas must be reviewed every four years.

(iii) Ensure that within 9.5 years15 biodegradable industrial water from plants belonging to specific industrial sectors"6 shall, before discharge, respect the established conditions for all discharges from plants representing 4,000 p.e. or more;

37. Discharge from urban wastewater treatment plants shall satisfy the following requirements17:

* Waste water treatment plants shall be designed or modified so that representative samples of the incoming waste water and of treated effluent can be obtained before discharge to receiving waters;

11Laid down in the Article 11 of the Directive i.e. by December 1993 12 These regulations and/or authorizations should meet specific requirements identified in the Annex I (C) of the Directive and should be reviewed and if necessary adapted at regular intervals. 3 Article 6 of the Directive i.e. by December 1993 14 Enrichment of water by nutrients from nitrogen and/or phosphorus, causes an accelerated growth of algae and higher forms of plant life) called euthrophication of water bodies 15 Article 13 of the Directive ie. by December 2000 16 Listed in Annex mIof the Directive 1 7Provided that all waste water streams are properly collected and subjected to secondary or equivalent treatment before being discharged into estuaries or coastal waters and specifically all urban wastewater collecting systems (sewerage) and treatment plants for all agglomerations above 2,000 population equivalents.

12 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

* Discharges from urban wastewater treatment plants shall meet the necessary requirements with regard to Biological Oxygen Demand (BOD), Chemical Oxygen Demand (COD) and Suspended Solids (SS). These requirements are presented in Annex I. * Discharges from urban wastewater treatment plants to those sensitive areas, which are subject to eutrophication, shall in addition, meet additional requirements with regard to Phosphorus and Nitrogen. These requirements are presented in Annex I. * However, the treatment must be more stringent (tertiary treatment) for discharges to the relevant catchments areas or sensitive areas as identified by Member States and may be less stringent (primary treatment), under certain conditions of agreement, for certain discharges to coastal waters and estuaries identified as less sensitive areas. The deadline for this application depends on the size of the agglomeration and the sensitivity of the receiving waters.

38. The Directive requires that Member States ensure that: (i) All agglomerations are provided with collecting systems for urban wastewater in line with the following timetable: * For those with a p.e. of more than 15,000 within 9.5 years; * For those with a p.e. > 2,000 and < 15,000 within 14.5 years; (ii) For urban wastewater discharging into receiving waters which are considered "sensitive areas" Member States shall ensure that the collecting systems for agglomerations of > 10,000 p.e. within 7.5 year.

39. Collecting systems shall take into account the following wastewater treatment requirements:

(iii) The design, construction and maintenance of the collecting system shall be undertaken in accordance with the best technical knowledge not entailing excessive costs, notably regarding: * Volume and characteristics of urban waste water; * Prevention of leaks;

(iv) Ensure that urban waste water entering collecting systems shall before discharge be subject to secondary treatment or an equivalent treatment as follows: * Within 9.5 years for all discharges from agglomerations of > 15,000 p.e.; * Within 14.5 years for all discharges from agglomerations of > 10,000, but < 15,000 p.e.; * Within 14.5 years for all discharges to fresh-water and estuaries from agglomerations of > 2,000, but < 10,000 p.e.; * Provide that within 7.5 years disposal of sludge from urban waste water treatment plants is subject to general rules or reorganization or authorisation as well as ensuring that within 7.5

13 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

years the disposal of sludge to surface waters by dumping from ships, by discharge from pipelines or other means is phased out. * Ensure that the urban wastewater discharges and their effects are monitored. . Publish situation reports every two years and establish implementation programmes.

Implementing the Directive in Bulgaria

40. Full compliance with the Directive is yet to be achieved. According to the NSI Yearbook 785.0 million m3 wastewater was discharged in 2001 of which approximately 438 million m3 (56%) complied with national effluent standards, which 3 are close to the Directive requirements. 6% was partially treated and 297 million m (30%) discharged without treatment.

41. The average connection rate for towns with a p.e. more than 2,000 is 62%. This is the share of the population living in agglomerations addressed by the Directive that is connected to sewage collecting systems. The remaining 38%, or 2.3 million will be connected to collecting systems during the 15-year period.

42. Discharges from the territory of Bulgaria reach the Danube River, the Black Sea and the Aegean Sea. Sensitive areas have been identified only for the discharges that go to the Aegean Sea. Thereby, Bulgaria should provide collecting systems for all agglomerations of more than 2,000 p.e. ensure relevant treatment for all discharges from agglomerations of more than 2,000 p.e; and implement other relevant requirements of the UWWT Directive. For the towns with more than 10,000 p.e., the Directive requires removal of nitrogen and phosphorus before discharging to sensitive waters. It should be taken into consideration that in Bulgaria approximately 6 million people (or - 75% of the population) live in settlements with more than 2,000 p.e. load.

43. The implementation gaps identified in relation to the Directive's requirement are as follows: * P.E.s are not calculated for all agglomerations in Bulgaria; * Only 62% of the population has connection to wastewater collecting systems and must be increased; * Sensitive and less sensitive areas have not yet been identified; * Collecting systems will have to satisfy the requirements of the Directive; * WWTPs in agglomerations with a p.e. above 2,000 will have to comply with the requirements of the Directive; * Not all the wastewaters are subject to treatment as required by the Directive; and * Sludge disposal in many WWTPs does not correspond to the technical norms, which may affect freshwater and groundwater.

44. Technical requirements. To ensure compliance with the Directive investment projects should primarily focus on the following:

14 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

* Rehabilitation, upgrading or construction of waste water treatment plants, including sludge handling that will also facilitate the implementation of Sewage Sludge Directive; * Cleaning, renovation and extension of sewerage networks, including elimination of leakages that will reduce contamination of groundwater and will facilitate also implementation of the Groundwater Directive; * Rehabilitation, upgrading or construction of wastewater pumping stations; and * Upgrading of laboratory equipment.

Legislative Framework

45. In addition to the Water Act the following regulations in effect transposed the principles of the Council Directive: * Regaulation No. 6 on the emission limits for admissible concentrations of harmful and hazardous substances in the wastewater discharged into water bodies (SG 97/2000). * Regulation No. 7 on the conditions and the order for industrial wastewater discharge into urban sewerage systems (SG 98/2000). * Regulation No. 8 on the quality of coastalmarine waters (SG 10/2001). * Rezulation No. 10 on the conditions and orderfor issuing a permit for wastewater discharge into water bodies and determining the individual emission restrictionsfor point sources ofpollution (SG 66/2001). * Re-aulation for the order and the way for establishing the networks and for the activity of the nationalmonitoring system (SG 95/2000). * Regulation on the requirements for soil protection when using sludge originating from wastewater treatment plants for the purposes of agriculture(SG 101/2000).

46. A permit system is in place for all types of wastewater discharges setting effluent standards for discharging wastewater into natural water bodies issued by competent authorities. Permits are revised every 5 years or more often, as necessary. The Water Act requires that individual emission limits be updated every 3 years.

47. Industries discharging into municipal sewerage networks will have to conclude an agreement with the company that operates the collecting system and/or WWTP. The agreements should include limit values for substances in the wastewater. To meet these limits, industry has to pre-treat wastewater before discharging into collecting systems. Competent authorities are required to monitor water bodies where urban wastewater is discharged. Information about effluent discharges is collected and situation reports published.

48. The Environmental Protection Act requires all industries to have integrated permits. Notification that is required under the Directive is not relevant before accession, nevertheless general notification procedures are provided for by the Environmental ProtectionAct.

15 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

49. The Regulation on the requirements for soil protection when using sludge originating from wastewater treatment plants for the purposes of agriculture (2000) provides for reuse of sewage sludge. However, disposal of sludge is infrequently used because of fragmented fanning and psychological reasons. Disposal of sludge into surface water is not practised in Bulgaria. The requirement for provision of information to the EU is not applicable until accession, although it is included in the above-mentioned regulations.

Sectoral and Institutional Framework

50. There are 50 water companies, which provide water supply & sewerage services. 21 of these serve one single municipality and 29 are regional and serve from 3 to 20 municipalities.

51. There are 13 regional water utilities with 100% state ownership of assets, 15 with joint ownership (51% State and 49% municipal) and one with 51% State, 48% municipal and 1% private ownership. Restructuring of the companies continues and the process will be completed with the transfer of 51% of State shares to the municipalities. Principal responsibility for institutional development remains with the government as a major stakeholder.

52. The Sofia municipal water utility granted the first concession to an international operator for the provision of water supply and sewerage services. The remaining municipal companies are of a small scale and face serious managerial and financial problems.

53. Basic institutional systems and other arrangements necessary for the implementation of the Directive are established. For agglomerations of more than 2,000 p.e., competent authorities and responsible institutions have been identified. By law local governments are responsible for providing public utilities, including sewage collection and wastewater treatment. The MOEW, through its regional divisions is responsible for developing and enforcing common policies for water protection and rational use. The MOEW and the River Basin Directorates are responsible for issuing environmental permits and water use permits.

54. The Environmental Executive Agency is responsible for overall co-ordination and management of environmental monitoring systems. Responsibilities for monitoring water quality are defined and involve: (a) operators monitor discharges and their compliance with the standards; (b) Regional Environmental and Water Inspectorates control discharges and monitor ambient water quality; and (c) accredited laboratories or laboratories approved by the MOEW may carry out water quality tests. The Environmental Executive Agency publishes quarterly and annual reports on the 'State of the Environment' and provides information on the quality of surface waters. Annual information on the quantities of wastewater discharged and treated is published in the NSI Yearbook. MRDPW formulates the policy and strategy for development of water services in the municipalities.

55. The Ministry of Finance is responsible for the annual budget and capital investment plans in coordination with the Ministry of Economy and MRDPW. Investment plans may include provisions for bilateral grants, EU funds and loans. Local governments are responsible for co-financing, management and monitoring of

16 Bulgaria:Environmental Sequencing Strategiesfor EUAccession the investment projects. An overview of the different institutional responsibilities for implementation of investment strategies is provided in Annex II.

56. Limited institutional capacity and lack of experience in project management affects the effectiveness of public administration. While generally the establishment of new institutions or major reorganization is not imminent, improving management and implementation capacity at all levels would be critical.

57. While institutional arrangements are already in place in Bulgaria, focusing on practical implementation and institutional development will require improvement of the permitting system; development of a regulatory system for tariff setting and cost recovery of water services; improvement of monitoring and laboratory facilities; and introduction of models for effluent limit and pollution values in urban waste water on the basis of standard water quality norms.

58. The Government's 'Draft Strategy for Development and Restructuring of the Water Supply and Sewerage Sector' -- still under discussion -- provides for private sector participation options in the provision of water services and highlights the specifics of the sector in Bulgaria. Concessions are considered for larger systems to gain an economy of scale and the service or management contracts for smaller systems. The strategy needs to be developed further in order to provide options for all existing water utilities and include an implementation plan. Implementation Framework

59. The Directive stipulates a number of deadlines for acceptable effluent standards that must be met by member states. These deadlines are primarily related to construction of sewerage systems and wastewater treatment facilities. It is estimated that capital investments for full compliance is achievable by 2015 taking into consideration affordability constraints and current rate of investment. Regulation No.6 on the Emission Limits for Admissible Concentration of Harmful and Hazardous Substances in the Wastewater, Discharged into Water Bodies specifies the same period for compliance. In order to identify investment priorities all agglomerations have been classified into 3 categories and different implementation deadlines have been set for each category 18

(a) Agglomerations of more than 15,000 p.e., where the Directive has to be implemented by the year 2010, in 91 agglomerations with 4,883,515 population (80.2% of the population covered by this Directive); (b) Agglomerations with a p.e. between 10,000 and 15,000, where Directive requirements will be implemented by 2015 in 30 agglomeration with 216,794 population (3.6% of the population covered by this Directive); (c) Agglomerations with a p.e. between 2,000 and 10,000 discharging into fresh waters or river estuaries the Directive will be implemented by the year 2015 in 314 agglomerations and 990,662 population (16.2% of population covered by this Directive)' 9

IBRegulation No. 6/9 November 2000 on emission norms for allowable content of harmful and hazardous substances in the wastewater discharged into water objects. 19 Number of organic pollution units i.e. person equivalent (p.e) has not been calculated for all agglomerations yet. By the stated target dates the poliution load to the WWITP will be higher in comparison to current load, which should be used as a basis for p.e. recalculation. Therefore, for classification purposes the number of total inhabitants multiplied

17 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

60. The National Program for Priority Construction of WWTPs in urban areas with the population above 10,000 p.e. was adopted in 1999. The program includes priority projects for construction, rehabilitation and extension of WWTPs to comply with the requirements of the Directive. A similar program was prepared for sewerage collecting systems. A comprehensive program for settlements with populations between 2,000 and 10,000 p.e. is yet to be developed. However the strategy falls short in evaluating options for utilisation of limited funds available to achieve the target dates for implementation of the requirements of the EU water sector directives. Consensus on the strategy and optimisation of priorities at all government levels and international community is key. The implementation stages are outlined in Table 6 below:

Table 6: Implementation Schedule

Year 2004-2006 2007-2010 2011-2012 2013-2015

'WWTPs serving PE abo%,e 15.000

WWTPs serving PE between 10.000 and 15.000

WWTPs serving PE betv-een 2.000 and 10.000

61. The implementation strategy includes the following stages:

> Feasibility Stage. Feasibility studies will confirm priorities, technical solutions and costs based on long-term sustainability and cost-effectiveness of the proposed investments. An assessment of local institutional and financial capacities for implementation of projects will be carried out, which will identify gaps and propose recommendations for institutional development. A review and approval by the "High Expert Council" will confirm the relevance of the priority project.

> Raising Funds. Priority financing will be provided for projects in accordance with Regulation No. 6 and target dates for 3 categories of agglomerations corresponding to the pollution load. The first order of priority will be cities with more than 15,000 p.e. considering the limited factor for investment size and affordability level. Preparation of tender documents, procurement, implementation and monitoring will follow the approval of the project feasibility study. Preparation of projects for ISPA financing carried out in 2000 followed specific selection criteria in accordance with the National ISPA Strategy in the Environmental Sector. The ISPA funding program for the coming years is based on guidelines resulting from the verification of basic assumptions of environmental policy prepared by the Government and on the formal requirements contained in the Regulation on ISPA.

by a factor 1.35 has been used reflect the pollution load from industries to classify cities and towns under 3 categories. Such an approach has been used taking into account the planned increase in the number of population connected to wastewater collecting systems till 2015.

18 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

62. Implementation for EU Funded Projects. Approved implementation plans trigger the preparation of Terms of Reference (ToRs) for consultancy services for preparation of Tender Documents for the construction works or design-build contract. Implementing units are responsible for the process in consultation with all the parties involved. The implementing units also participate in procurement procedures, contract negotiations and contract award and further supervision. Implementing units prepare ToRs for engineering supervision as necessary and are responsible for implementing the contract to the desired outcome.

63. Timeline for Preparationand Implementation. On average the construction period of each WWTP is assumed to take approximately 3 years. This will be in addition to the time required for preparation of feasibility studies and mobilization of financing which can take up to 2 years. The investment cycle thus, will take approximately 5 years. On this assumption, the feasibility studies and financing commitments for some 91 WWTPS would need to be ready by 2007, which implies the preparation of some 30 projects per year. The time for preparation and completion of WWTPs should take into account the additional time for 128 sewerage collection projects, which will have to be completed between 2003 and 2011.

64. It is reasonable to start during the first stage urgent rehabilitation, extension and upgrading of facilities. Construction of new WWTPs will be prioritized on the basis of cumulative environmental impact on environment and population coverage. However, prioritization must take into account impacts on households and affordability constraints when implementing the Directive's requirements in each thus aiming at achieving full compliance gradually and in stages.

65. A detailed overview of implementation responsibilities for the Directive is provided in Annex II.

Investment Forecasts Full Cost Implementation Present Expenditures on Investment and Operational Costs

66. In retrospect, annual expenditure made for wastewater treatment during the period 1999 was in the range of EUR 20 million distributed as follows:

Table 7: 1999-2001 Expenditure on Wastewater Treatment (MEUR)

Year 1999 2000 2001

Total Urban Waste Water 19.3 23.7 21.9 Treatnent Plants

Capital Expenditure only MIEUR % MEUR % IEUR

8.8 45% 8 34% 5.2 24%

Operadon and MEUR % MEUR % MEJUR % Maintenance cost (O&M)

10.5 55% 15.7 66% 16.7 76% Source: National Statistical Bulletin 2002

19 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

67. The data in Table 7 shows a large share of the expenditures were spent on O&M costs, most probably, as utility subsidies, while capital investments in new assets were very insignificant. The State budget and former National Environmental Protection Fund (currently SEEPA) mainly financed investments.

Full Cost Implementation Forecast

68. The full cost implementation forecast assumes that sewerage and wastewater treatment coverage increases to 100% of the population living in settlements of more than 2,000 p.e. (approximately 75% of the total population) and it assumes that 100% of the Bulgarian area is considered to be sensitive, which causes the need to add tertiary treatment. The assumption for the full cost implementation forecast and analysis for the period including 2015 include: * GDP will grow with projected growth of 5% until 2005 and then gradually slow down to 4% in 2006 and a constant 3% from 2008 onwards; * Priorities for construction of WWTPs and sewerage networks will not change and financing for the environmental sector will gradually increase; * Changes in institutional structures and responsibilities will not affect the water management strategy or the proposed implementation plan; * Development of legislation will facilitate implementation of the strategy.

Wastewater Treatment Cost Estimates

69. A significant percentage of the investment in the environmental sector will be for wastewater treatment. It is estimated that wastewater management projects will amount to approximately 50% of the total environmental investments. The methodology used to calculate the costs is based on the relationship between the capital expenditure to operational cost (CAPEX/OPEX) and the population equivalents using the figures produced in twelve recent feasibility studies made available. The range of these studies was from 10,000 to 250,000 p.e. and Extended Aeration Technology was the preferred option. Since there were no figures for CAPEX and OPEX below 10,000 p.e. it was decided to use the values at the low p.e. end from the EU treatment model reported in "Provision of Technical Assistance in the Approximation of Water Legislation for Bulgaria - BUL 110" prepared by HALCROW in 1999. Annex I provides some details on the costing methodology and Annex m1an overview of the data used to derive CAPEX and OPEX for wastewater treatment full cost estimates.

70. Investments, broken-down by wastewater treatment plants and sewerage networks for meeting the requirements of the Directive, are illustrated in Table 8 and will substantially be for: construction, extension and rehabilitation of the sewerage network; construction and reconstruction of the sewage pumping stations, and construction, upgrading and reconstruction of wastewater treatment plants. The average consumption of 180 lI/c/d is taken as a basis for consumption.

71. For settlements discharging directly into the Danube River and Black Sea as well as those discharging into already identified sensitive areas the costs are increased by 15% to enable the provision of tertiary treatment. An additional percentage of 20%

20 Bulgaria. EnvironmentalSequencing Strategiesfor EU Accession

for industrial p.e. for settlements between 2,000 and 10,000 was assumed. The breakdown of costs by settlements for WWTPs is shown in Annex III.

Sewerage Cost Estimates

72. The length of the sewerage network remaining for completion was multiplied by the average unit cost of 1km sewerage network. The following approach is applied to determine the length of sewerage networks for completion: > For settlements with a p.e. between 10,000 and 15,000 and above 15,000, the length of the sewerage systems for completion has been taken from the National Programfor Construction of Sewerage Systems for settlements with more than 0, 000 p. e. > For settlements with a p.e. value between 2,000 and 10,000 the calcuations are based on the following assumptions: * Where data was available for the length of street network and sewerage completed as percentage of street network, the length of sewerage for completion was calculated assuming that it should be equal to the length of the street network; * Where there was no data of the length of street network, the average length of a street network per number of inhabitants was extrapolated using available data for other settlements. This resulted in ]Om per inhabitant for the settlements with 2,000 to 5,000 population, and 6m for the settlements with 5,000 to 10,000. The total length for completion was then calculated by multiplying the number of population by the respective factor.

73. The average cost per km of sewerage used for the costing is EUR 150,000. For the analysis, the review uses the figure from a number of recently completed projects. The costs were produced by multiplying the length of the sewerage network for completion by the average cost per km. The breakdown of costs for sewerage is given in Annex IV.

Table 8: Summary of Compliance Total Costs for WWTP and Sewerage Systems.

Population WWTP Sewerage Total equivalent (p.e.) (EUR Million) (EUR Million) (EUR Million)

2,000 to 10,000 416 1,025 1,441

>10,000 648 541 1,190

TOTAL 1,064 1,566 2,630

Feasibility studies, Supervision & Project management cost 263 (10% of total)

TOTAL 2,894

21 Bulgaria: Environmental Sequencing Strategiesfor EU Accession

74. Total financing required for capital investments for wastewater treatment plants is approximately EUR 1,064 million, and for sewerage systems approximately EUR 1,566 million for the period from 2000 to 2015. This includes the cost of feasibility studies, supervision and project management costs. The latter is estimated to comprise 10% of the total capital expenditure.

Annual Investment and Operational Costs

75. A comparison is made between the necessary capital investments and operational costs and the overall GDP. When looking at the overall annual environmental costs for wastewater (annual capital financing), investment costs and expected costs for operation and maintenance, the total annual costs will increase from EUR 86 million in 2003 to EUR 252 million in 2014. The estimated operational costs are the total of the present operational costs with the additional operational costs necessary for the new investments. This is equivalent to an increase from 0.56% of GDP in 2003 to 1.18% of GDP in 2014 with a peak of 1.69% of GDP in 2011 as shown in the following figure:

Wastewater and Sewerage expenditures as % of GDP

1.80%

1140% AMh

120%.

0 MAnnual Operational and O 0680% Maintenance costs

080%

0 40%

020% IATotal wastewater and sewerage investments 0 00% 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Years

76. The peak of the investment costs is around 2011 since this is the last year in which investments can be started to reach the compliance period of 2015. The high range of percentages of GDP suggests that financing of these investments will be quite a challenge.

Financing

77. Financing for the necessary wastewater and sewerage investments will consist mainly of the following three components: a. Grant financing from ISPA/cohesion funds b. National/municipal co-financing c. Revenues from tariffs for wastewater and sewerage treatment

22 Bulgaria:Environmental Sequencing Strategiesfor EU Accession

ISPA/Cohesion Funds

78. Financing from the EU ISPA20 (Instrument for Structural Policies for Pre- Accession) fund from 2000 to 2006 and Cohesion Fund from 2006 onwards is available for assisting in the implementation of EU requirements in the wastewater sector. ISPA funds allocated for environmental projects in Bulgaria is between EUR 290 and 430 million (in 1999 terms) over a 7 year-period, or an average of EUR 42-62 million per annum. The assistance, which will be made available from the Cohesion Funds during the period 2007-2020, is estimated to be EUR 3,194 million, which equals on average to EUR 228 million per year. Approximately 75% of the EU assistance is expected to be allocated to meet the requirements of the UWWT Directive.

79. According to the Roadmap for Bulgaria "the Commission proposes that assistance for Bulgaria should increase progressively to meet the level of an additional 40% in 2006. The increase will take as a baseline the average assistance under Phare/ISPA/SAPARD in the period 2001-2003." This increase will be 20% in 2004, 30% in 2005 and 40% in 2006. For the investment projections it is assumed that the average assistance in the period 2001-2003 will be EUR 59 Million and it is taken as a basis for the increase in forecast of ISPA funds. The preparation of investment projects is well on track. However, according to the Ministry of Finance utilization of ISPA investment funds to date is rather slow2l.

80. The ISPA financing can increase to 75% of the total project costs. The Cohesion Fund will finance 80-85% of the total cost. The total cost of each project shall in principle not be less than EUR 5 million for ISPA granted projects and EUR 10 million for projects funded by the Cohesion Fund.

81. After 2006 the Cohesion Fund will operate under procedures and criteria. Assistance from the Cohesion Fund is estimated on the basis of comparison with the funds allocated to Hungary22 and the following sources of information: Inforegio News in November 2002 identified the "New Member States to receive EUR 23 billion in Structural and Cohesion Funds between 2004 and 2006" and a Financial Framework for enlargement agreed in Copenhagen for the period 2004-2006.

2 Largely ISPA financing criteria are: (i) Community dimension of investments, (ii) Systematic approaches (no isolated ad hoc interventions), (iii) Concentration on projects with impact on a aximwum number of people, and (iv) Maximum financial leverage. ISPA assistance concentrates on the "investment heavy" directives, i.e. Directives that are costly to implement, and, to deal with the worst environmental problems, are on: drinking-water supply, treatnent of wastewater, solid-waste management, and air polution. Small parts of the ISPA budget may also be used to fund preparatory studies and technical assistance where clear link must be shown between these measures and the projects funded by ISPA. Technical assistance wiUl have a crucial role in guaranteeing high quality projects, in terms of both management and impact, and wilU allow research results to be incorporated in the relevant sector as far as is feasibly possible. ISPA funds may not be combined with other Pre-Accession Instruments.

The following disbursement schedule of ISPA funds at the national level wiU apply: 10% advance payment upon signature of the financial memorandum (Year 1); 10% advance payment upon signature of works contract (Year 2), 35% intermediate payment on reimbursable basis (Year 3), 35% intermediate payment on reimbursable basis (Year 4); and 10% final payment (6 months after work completion) (Year 5). 21 Utilization rate of ISPA funds at end July 2003 dropped to 9.72 percent compared to 11.89 from previous month due to slow disbursements. Bulgaria and ISPA signed 16 ISPA memoranda since 2000 for a total of EUR 909 miilion of which 11 for environmental projects. 2 Under ISPA distributions scheme Hungary and Bulgaria are the closest countries in terms of financial resources alocated to them. ISPA assistance allocated to Bulgaria is 14-20% higher than the assistance committed to Hungary. EU distributes financial resources on the basis of the countries' GDP,,, total population and area. These indicators are relatively stable for Bulgaria and Hungary, and thus, the project team assumes that Bulgaria wiU receive 14% higher assistance than Hungary from the Cohesion Fund

23 Bulgaria: Environmental Sequencing StrategiesforEUAccession

National and Municipal Co-financing

82. Since ISPA finances up to a maximum of 75% of the project costs and the Cohesion Fund up to a maximum of 80%-85%, national co-financing will be necessary to realize the investment program. The European Commission may also consider loans by International Financing Institutions as an equivalent to or substitution of national public funds. Co-financing assumptions for the remaining years include the following: * The State's contribution will increase gradually after 2004 and until 2013 under steady economic growth to respond to the EU requirements for co- financing; * Local non-budgetary resources such as SEEPA (former National Environmental Fund) will continue to contribute substantial amount of resources;

83. The State budget will remain the main source for capital investments in environmental infrastructure. It will provide matching funds to the co-financing of EU grants for the wastewater sector. The trend shows a slight increase in funds allocated from the State to investments in environmental infrastructure and projects since 1998. This increase should be sustained to meet the requirements for matching funding from the EU. However, in the short run this increase may well be limited, as the increase in expenditure must be accommodated in the overall expenditure envelope without a sharp rise in the expenditure to GDP ratio.

84. The overall amount of investments for developing the wastewater sector could be increased in the future through borrowing. In the short run, however, the central government will have serious constraints in using external borrowing for co-financing ISPA projects as it is targeting a 0% fiscal deficit by 2005, and after accession the deficit should be consistent with the currency board arrangements (CBA) and the requirement of the Maastricht Agreement, which required current members' public debt to be brought close to 60% of GDP at the end of 2002. The CBA will remain until the introduction of the Euro, which is currently scheduled for 2009.

Special Funds

85. The National Environmental Protection Fund, recently transformed to SEEPA, continues to finance environmental projects at the national and regional levels in compliance with national environmental strategies. SEEPA finances priority construction of municipal wastewater treatment plants for cities with over 10,000 residents and construction of municipal landfills. The main sources of revenue from the funds come from environmental fines and fees. SEEPA financing plans for 2003 include capital investments for EUR 20.4 million in waste management and wastewater treatment plants. This will slightly decrease the burden the State budget will have to bear in co-financing EU assistance.

Budgets ofMunicipalities and MunicipalEnterprises

86. There is close co-operation between the Ministry of Environmental and Water, Ministry of Regional Development and Public Works and municipalities in the implementation of investment projects. The municipalities are the Ministry's most important partners in realizing environmental projects and activities. Municipalities

24 Bulgaria:Environmental Sequencing Strategiesfor EUAccession contribute to project implementation with their knowledge of local needs, as well as with their financial resources or in-kind contribution.

87. The size of these contributions is very limited and difficult to ascertain because the revenues from- local taxes go to the central budget and later on are redistributed back to the municipalities. Municipalities' budgets face serious difficulties. There is little predictability in the system of central government transfers and grants. Accumulated arrears, mismatch between expenditure and revenue assignments pose significant constraints to investment plans. In addition, weak management capacity and fnancial control within a number of municipalities lower the level for appropriation of investment grants and lead to increasing current expenditure, to the detriment of investments.

88. Income levels vary from municipality to municipality and depend on the local socio-economic situation in each. The average level of income is generally sufficient to cover operational costs of water services. Present water and sewerage tariff levels in the majority of towns is too low to support the investment needs in infrastructure. In most cases wastewater charges are subsidised by drinking water tariffs. The tariffs cover the basic costs, but do not adequately allow for new investments. There is little incentive in companies to invest in fixed assets either, at a high rate of taxes on capital investments and low amortization levels. In addition, the collection of tariffs in some municipalities is ineffective, leading to losses in income for the companies. Similarly, an increase in water tariffs often leads to a decrease in water consumption. This however may result in a decrease in the water tariff collection ratio. Detailed analysis needs to be performed in each municipality in order to ensure sufficient revenue to meet the costs of operations and maintaining the systems whilst ensuring that its share of the capital costs are being repaid.

89. Local financing institutions that may lend money for wastewater infrastructure development projects are commercial banks. However, wastewater projects would not meet the lending criteria of such institutions in the short to medium term. The legal framework for municipal borrowing is unclear. Currently municipal borrowing is limited to current expenditure. The responsibilities for capital infrastructure and investment budgeting call for legislative revisions to authorize long- term borrowing for capital investments.

Private Sources

90. A public private partnership could be considered as an opportunity to reduce State budget contributions provided it can demonstrate "transparency, equal treatment and competition" according to the Commission of Interpretative Communication on Concessions under Community Law (OJ C 121, 29.4.2000). A strategy should be undertaken to analyze where and how the different forms of private sector participation could be applied to the wastewater sector as well as possible constraints that could inhibit such participation. This includes development of appropriate legislation, solution of problems associated with ownership of assets, shareholding issues, introduction of cost-based accounting systems, improved control and better coordination among different participants in the decision making process.

91. Another constraint for attracting private sources of capital is the low tariffs set for wastewater and sewerage services that only barely cover operating costs. Raising tariffs is constrained by affordability considerations (see below).

25 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Revenues from Tariffs

92. Currently, water supply and wastewater tariffs are administered by the State and cover drinking water, wastewater collection and wastewater treatment. The average water tariff for 2002 was EUR 0.5 1/m3, of which EUR 0.4 1/m3 was for water supply and EUR 0.10/m3 for sewerage and wastewater treatment. An overview of wastewater and treatment and sewerage charges of selected water companies is provided in Annex VI. However such estimates are approximates in the lower range since a significant number of municipalities do not cover recurrent costs, and have no operating wastewater treatment facilities. By and large, the total current water tariffs by regions do not adequately cover the associated operating and maintenance costs and are insufficient to cover investment expenses. The standard design water supply norm is 180-liter/per capita per day. Monthly per capita consumption amounts to 5.4m3 The average household consumes 14.26 m3 per month.

93. To take into account internationally agreed affordability limits, payment for water and wastewater services should not exceed 4% of average household income. This sets up a limit of approximately EUR 6.8 per month per average household given an average monthly household income of EUR 170.

94. Based on a prognosis of an increase in household incomes streamlined with expected growth in GDP, an overview of affordable tariffs for wastewater and sewerage is presented in Table 9.

26 Bulgaria: EnvironmentalSequencing Strategiesfor EU Accession

Table 9. Affordability Projections for Future Wastewater/Sewerage Tariffs

Affordability projections, households Affordability______projections, _____households___ Unit 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Average household income EURO/month 170 179 187 195 203 209 214 219 225 230 236 242

Present unit tariffs Water tariff EUR/m3 0.41 Wastewater and Sewerage tariff EUR/m3 0.10

Presentcharges Total charges water EURO/month 5.74 Total charges wastewater EURO/month 1.4 Total charges EURO/month 7.14 As percentage of HH income % of HH income 4.20%

Increase of HH income % 5.0% 5.0% 5.0% 4.0% 4.0% 3.0% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5%

Potential wastewater/sewerage charges based on present water tanff Household limit for (waste)water services EURO/hh/month 6.80 7.14 7.50 7.80 8.11 8.35 8.56 8.77 8.99 9.22 9.45 9.69 Total acceptable (waste)water charges EURO/m3 0.48 0.50 0.53 0.55 0.57 0.59 0.60 0.62 0.63 0.65 0.67 0.68 Total water charges based on present EURO/m3 0.41 0.41 0.41 0.41 0.41 0.41 0.41 0.41 0.41 0.41 0.41 0.41 Total possible charges forwastewater/sewerage EURO/m3 0.07 0.09 0.12 0.14 0.16 0.18 0.19 0.21 0.22 0.24 0.26 0.27

Potential wastewater/sewerage charges based on (40%)/(60%) division Household limit for (waste)water services EURO/hh/month 6.80 7.14 7.50 7.80 8.11 8.35 8.56 8.77 8.99 9.22 9.45 9.69 Total acceptable (waste)water charges EURO/m3 0.48 0.50 0.53 0.55 0.57 0.59 0.60 0.62 0.63 0.65 0.67 0.68 Total water charges based on 40% EURO/m3 0.19 0.20 0.21 0.22 0.23 0.24 0.24 0.25 0.25 0.26 0.27 0.27 Total possible charges for wastewater/sewerage (60%) EURO/m3 0.29 0.30 0.32 0.33 0.34 0.35 0.36 0.37 0.38 0.39 0.40 0.41

27 Bulgaria: Environmental Sequencing Strategiesfor EU Accession

95. The analysis shows that, unless revenues can be rerouted from the water supply, it will take some years before household tariffs can be increased to such levels that they start to contribute to investments recovery. This is due to the affordability constraints as described above. Only after some years of substantial economic growth, will it be possible to increase the tariffs sufficiently.

Financing Gap Full Cost Implementation Schedule

96. Based on the described sources of finance for wastewater and sewerage investments: grant financing from ISPA/cohesion funds, national/municipal co- financing and revenues from tariffs for wastewater and sewerage treatment as well as the projected necessary investment and operational costs for full cost implementation of the Directive, a financing gap analysis has been performed and presented in the following figure:

Full Cost Implementation

600 500 - Total of investment and O 400 operational costs -- Total funds available from Luj 300 E 200 ISPA/cohesion/general tax 100 Total available from tariffs

¢5,s ,4z ,4z hi ,No ,x9 ,so ¢--- Total funds available

Years

97. The financing gap analysis shows that though the total funds available from ISPA/Cohesion Funds, National and Municipal co-financing and tariffs does increase substantially from year 2009 onwards, it is not sufficient to cover the total financing needs for investments and operational costs.

Investment Forecasts Least Cost Implementation

98. The Urban Wastewater Treatment Directive specifies that all settlements above 2000 p.e. are connected to the sewerage system and that the sewage collected should be treated to specific levels, depending on the characteristics of the receiving water. It states however, that "where the establishment of a collecting system is not justified either because it would produce no environmental benefit or because it would involve excessive costs, individual systems or other appropriate systems which 23 achieve the same level of environmental protection shall be used." The Directive also requires member states to identify receiving waters that are sensitive to eutrophication, and discharges into sensitive water bodies must receive additional treatment to reduce the concentrations of total nitrogen (TN) and total phosphorus (TP). A precise definition and analysis of the sensitive areas make a big difference to the costs.

2 Bulgaria, The Challenges of Complying with EU Environmental Directives. World Bank. 2000

28 Bulgaria. Environmental Sequencing Strategiesfor EU Accession

99. Since the Full Cost Implementation Analysis shows that even with substantial international grant finance, an increase in tariffs and the planned national co- financing, there is still a substantial financing gap, therefore a least cost strategy has to be pursued. A suggestion for such a least cost strategy is provided below. The assumptions used for the Least Cost Implementation strategy are the following:

* Black Sea River Basin - all settlements with more than 2,000 PE will be provided with WWTPs (secondary treatment). * Danube River Basin - for settlements from 2 to 10,000 PE only those discharging directly into the Danube River will be provided with WWTPs. The others will rely on septic tanks. * East and West Aegean Sea Basins - for settlements from 2 to 10,000 PE only those discharging into sensitive zones will be provided with WWTPs. The others will rely on septic tanks.

The settlements discharging into sensitive zones are shown in the following table:

Table 10: Settlements Discharge into Sensitive Zones

RIVER BASIN TOTAL

Black Sea Danube East West Aegean Aegean

2,000 to 10,000 4 1 21 7 33

10,OOOto 15,000 10 4 2 0 16

>15,000 17 30 18 5 70

100. Such a least cost strategy will bring substantial investment costs savings. An overview of the accompanying projected wastewater and sewerage investment costs is provided in the following table:

29 Bulgaria: Environmental Sequencing Strategiesfor EU Accession

Table 11: Summary of Compliance Least Costs Implementation for WWTP and Sewerage Systems.

PE Number of WWTP Sewerage Total Settlements (MEUR) (MEUR) (MEUR) 2,000 to 10,000 102 124. 321 445

10,000 to 15,000 30 63 75 138

>15,000 91 585 466 1,051

TOTAL 223 772 862 1,634

Feasibility studies, Supervision & Project management (10%) 163

101. Total financing required for capital investments for wastewater treatment plants is reduced to approximately EUR 772 million, and for sewerage systems approximately EUR 862 million for the period from 2000 to 2015. This includes the cost of feasibility studies, supervision and project management. The latter is estimated to comprise 10% of the total capital expenditure.

Financing Gap Least Cost Implementation Schedule

102. Based on the same sources of finance for wastewater and sewerage investments: grant financing from ISPA/cohesion funds, national/municipal co- financing and revenues from tariffs for wastewater and sewerage treatment, the financing gap has been projected taking into account the Least Cost Implementation Schedule and accompanying investment and operational costs. This is presented in the following figure:

Least Cost Strategy 4Total of investment and operational costs

400 --- Total funds available 350 from 0 300 ISPA/cohesion/general 250 _____tax D 200- - + * Total available from 100 - tariffs; <; ; w a 100 --- Total funds available

Years

103. The financing gap analysis shows that though there is still a financing gap in the early years, the financing gap is much smaller than in the full cost implementation

30 Bulgaria:Environmental Sequencing Strategiesfor EUAccession plan and in 2010 and from 2012 onwards, total funds available are enough for the investment and operational costs requirements.

Conclusions and Critical Actions

Technical/financial * Affordability constraints. As a reference benchmark, payments for water and wastewater services are not to exceed 4% of average household income. This sets an administrative upper limit of EUR 6.8 per month per household, with an average present monthly income of EUR 170-195. Hence, the present maximum socially acceptable water tariff would be around EUR 0.48 /m3. With a present tariff of 0.51 EUR/m3 of which 0.41 EUR/m3 is for water supply, there is no room for appropriate tariffs for wastewater, since the tariff is already at the maximum socially acceptable level. Tariffs of around EUR 0.29/m3 are estimated to be necessary for appropriate coverage of investment and operational costs. At present, the possibility of raising tariffs to include capital investment costs is therefore limited. In order to fully raise tariffs to cost recovery tariffs incorporating both operation as well as maintenance costs, household income growth is necessary. The 2002 growth rate of average household income in real terms was about 17%24. Adjusting the tariffs in phases to cost-recovery levels will encompass frequent (annually) adjustments of the tariffs to reflect the growths in household incomes. * Studying affordability levels on a regional basis with consideration of economic and financial costs and expectations of future developments will provide a sound basis for planning and phasing of investment projects. This will need to include studying the limit and impact on vulnerable groups before determining the degree to which criterion tariffs can be raised. Targeted social assistance programs are necessary to assist low-income households in paying water and wastewater charges and smooth the process of acceptance of tariffs increases. * Financinggap. In analyzing the government's full cost implementation plan, there appears to be a substantial financing gap looking at the investment and operational costs requirements and the available financing from grants, co- financing and tariffs. This is a major problem in all candidate countries as it was in all EU member states. Bulgaria has additional challenges since its GDP per capita is smaller then in other accession countries (half that of Poland). In order to lighten the burden and enhance the implementation of the Directives, different options are proposed. * Pursue a least cost implementation plan In order to lighten the investment burden, a least cost strategy is proposed. The least cost strategy closely looks into identifying sensitive and less-sensitive zones for the whole territory of the country and reduces the amounts of tertiairy treatments and sewerage systems necessary. The least cost implementation plan should also look carefully into the design capacity of the sewerage pipes. 180 liter/capita/day is higher than consumption patterns elsewhere in (Eastern) Europe and public awareness campaigns for water saving will also assist in fulfilling the requirements of the EU Directive at more affordable levels.

2 4 Although it is very high compared to previous two years, part of may well be attributed to increased income from household plots and is subject to huge fluctuations depending on the weather conditions (in 2002, the weather conditions were exceptionally good)

31 Bulgaria:Environmental Sequencing StrategiesforEUAccession

* Focus on the largestsettlements first. There are 30 towns with a p.e. between 10,000 and 15,000 and 314 settlements with a p.e. between 2,000 and 10,000 that fall under the target date 2014 and shall comply with the requirements of the UWWTD. Priority should be given to those with a p.e. between 10,000 and 15,000 where their infrastructure is already assessed and ready for feasibility study preparation. * Align investments with tariff increasepotential. Focus is on those settlements where average household income is higher and there are tourists or other business developments. Cost recovery issues will be better managed when investment planning of projects take into account regional differences in household income levels and the more prosperous municipalities are targeted at an earlier stage then their poorer counterparts.

Institutional

* Reinforcing institutional capacity for administration and technical implementation of investment plans; timely preparation of a project financing envelope to adequately absorb external finances and efficient and transparent use of these funds. The government will need to ensure that it takes advantage of all available grant financing. Bulgaria is currently only able to spend 10% of the ISPA allocations. Hence the methodological and institutional capacity of MOEW for management of projects financed by EU Cohesion funds should be strenghtened. Completion of institutional and administrative measures for implementing water sector management reform will be an integral part of this (Basin Directorate, MOEW Water Directorate). * Ensure better market opportunities. In order to sustain the costs necessary for compliance it is necessary to ensure better market opportunities for attracting potential investors. This includes development of appropriate legislation, change of tariffs, solution of problems associated with different shareholders and owners, introduction of cost-based accounting systems, improved control and better co-ordination among different participants in the decision making process. * Develop a register of industrial discharges of wastewater. Determine water quality objectives, monitoring needs and performance standards for monitoring. Enhance the permitting system by regular updating of wastewater discharges permits.

32 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

PART Ill. Implementation of Council Directive 1999/311EC on Landfill of Waste

Summary Requirements of the Directive

104. The overall objective of the Directive is to provide for measures, procedures and guidance to prevent or reduce as far as possible negative effects on the environment, in particular the pollution of surface water, groundwater, soil and air. The main articles as outlined in the Directive are summarized below as they apply to Bulgaria.

105. Each landfill must be classified into one of the following: * Landfill for hazardous waste * Landfill for non-hazardous waste * Landfill for inert waste

106. Bulgaria must set up a national strategy for implementation of the reduction of biodegradable waste going to landfills, not later than two years after the date in article 18(1) and notify the commission of this strategy. The strategy shall ensure: * Not later than 2008, biodegradable municipal waste going to landfills must be reduced to 75% of the total amount (by weight) of biodegradable waste produced in 1995. * Not later than 2011, biodegradable municipal waste going to landfills must be reduced to 50% of the total amount of biodegradable waste produced in 1995. * Not later than 2018, biodegradable municipal waste going to landfills must be reduced to 35% of the total amount of biodegradable municipal waste produced in 1995.

107. Bulgaria shall take measures to prevent the landfilling of the following wastes: * Liquid waste * Waste, which in the conditions of landfills, is explosive, corrosive, oxidizing, highly flammable or flammable * Hospital and other clinical wastes arising from medical or veterinary establishments which are deemed to be infectious * Whole used tires by 2007 * Any other type of waste not fulffiing the acceptance criteria in accordance with the Directive.

Diluting mixtures of waste solely in order to meet the waste acceptance criteria is prohibited.

108. Waste to be Accepted in the Different Classes of Landfill (Article 6)

* Only waste that is subject to treatment is land filled.

33 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

* Only hazardous waste that fulfills the criteria set out in accordance with annex 2 of the Directive is assigned to a hazardous landfill. * Landfill for non-hazardous wastes may be used for: - Municipal waste - Non-hazardous waste of any other origin - Stable, non-reactive hazardous wastes (e.g. solidified, vitrified) * Inert waste landfill sites shall be used only for inert waste.

Directive conditions in relationship with the permitting of landfills, waste acceptance procedures, control and monitoring procedures and closure and aftercare procedures as well as provisions relating to existing landfill sites and obligation to report are provided in Annex X.

Present Waste Quantities, Composition and Facilities, Present Waste Management Systems, Plans and Legislative Framework

Quantities of Waste

109. The total amount of waste in Bulgaria has declined substantially over the past 5 years. Table 12 illustrates this decrease in the total amount of waste arising in Bulgaria between 1997 and 2001. The primary reason for this decline is caused by the decrease of waste arising from mining and industrial activities. The overall decrease has been 62%.

Table 12: Waste Accumulation in Bulgaria ('000 tons)

1997 1998 1999 2000 2001 Hazardous waste 1,098 548 853 758 756 Non-hazardous 8,508 8,389 7,719 8,165 8,184 industrial waste Waste resulting from 222,161 210,048 166,990 84,170 78,213 exploration, minig, dressing and further treatment of minerals and quarry Municipal waste 3,628 3,197 3,213 3,318 3,211 Total 235,390 222,182 178,775 96,311 90,364 Source: NationalInstitute of Statistics

Municipal Waste

110. With regard to municipal waste, it is difficult to assess the accuracy of the existing data on the waste arisings although there were several surveys that have been undertaken in the past to quantify waste with varying success. There have been considerable variations in estimation of waste pre capita, which questions their overall validity of data. The following is an extract from the National Waste Management Program (Report) produced in 1999 by the Ministry of Environment and Water.

34 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Table 13: Quantities of Municipal Solid Waste

Year 1989 1990 1991 1992 1993 1994 1995 1996 1997 Total 8,428 '8,022 8,503 8,067 7,357 6,052 4,495 4,031 3,628 (thousand tons)

Population 8,994 8,669 8,595 8,485 8,460 8,427 8,400 8,341 8,283 (thousand citizens)

Standard 937 892 947 945 870 718 508 483 436 generation (ckgapita/ year)

Source: Annual StatisticalBulletin 1997

111. The percentage decrease in population between 1989 and 1997 is 7.9% but the overall decrease in quantities of municipal waste produced is estimated from the above figures as an overall decrease of 56%. This probably reflects the changing economic climate in Bulgaria during the transition period when household incomes declined dramatically and availability of goods was also limited.

112. The 'Draft Green Book' for Bulgaria provides information on waste arising and landfill utilization for 2001. For 2001 a total of 3,037,960 tons of household waste has been reported collected from 6,673,146 inhabitants. This is equivalent to 455 kg per capita.

113. If one is to examine the information supplied by the Environmental Executive Agency, the reported amount of municipal waste produced differs slightly. The following are estimated waste arising for municipal waste from 1997-2001.

Table 14: Municipal Waste Arisings from 1997 - 2001 (kg/h/year)

1997 1998 1999 2000 2001

Collected municipal waste 570 498 506 518 505 per capita, served by municipal services - kgiliyear

Source: EnvironmentalExecutive Agency (EEA) - Bulgaria

114. For the purpose of this document the averaged figure of 505 kg/head/annum will be used as the most recent accurate figure for the amount of municipal waste produced.

Composition of Waste

115. The reported composition of municipal waste varies considerably from municipality to municipality.

35 Bu7garia: EnvironmentalSequencing Strategiesfor EUAccession

Table 15: Composition of Municipal Waste 1995-2001

Type 1995 1996 1997 1998 1999 2000 2001 Paper, 12.00 11.00 11.00 11.00 8.52 8.68 9.95 cardboard Textiles 3.00 3.00 4.00 4.00 3.13 3.25 3.77 Plastics 7.00 6.00 7.00 7.00 8.07 8.81 9.45 Glass 6.00 6.00 6.00 6.00 5.26 5.25 5.08 Metals 4.00 4.00 3.00 4.00 2.45 2.25 2.34 Organic 38.00 35.00 38.00 41.00 41.57 39.88 38.73 Material Other waste 30.00 35.00 31.00 27.00 31.00 31.88 30.68 Source: National Institute of Statistics

116. Table 15 provides information on the municipal waste but it does not distinguish between household and commercial waste. It is imperative that such a distinction is made for future planning purposes. This is important when predicting the amount of household biodegradable waste, which must be diverted from landfills. Furthermore the quantities of paper/cardboard produced by commercial enterprises will be much greater than the average household. To adopt separate reporting on waste arisings for commercial waste will also be important for the Packaging Directive. The table states that the paper/cardboard composition for 2001 was 9.95%, this is below the European average, particularly if a lack of distinction between household and commercial is taken into consideration.

117. As a basis for projection of waste arising in the next 17 years to comply with the Landfill Directive, a reasonable estimate of the average composition for municipal waste in Bulgaria must be adopted.

118. The following Tables illustrate the amount of generated and landfilled hazardous waste and non-hazardous and industrial waste in Bulgaria.

Table 16: Generated and Landfilled Hazardous Waste ('000 tons)

1997 1998 1999 2000 2001 Generated 1,098 548 853 758 756 Landfilled 780 237 517 478 518 Source: Executive Environmental Agency

Table 17: Generated and Landfilled Non-Industrial Hazardous Waste (not including mining waste) - ('000 tons)

1997 1998 1999 2000 2001 Generated 8,508 8,389 7,719 8,165 8,184 Landfilled 8,198 8,060 7,173 7,581 7,450 Source: Environmental Executive Agency

36 Bulgaria:Environmental Sequencing StrategiesforEUAccession

Table 18: Generated Hospital/Healthcare Waste

Type of hospital No. of hospitals No. of beds Waste Quantities (kg/day) (0.4 x no. of beds) Multi-profile hospitals 127 37,474 14,990 for active treatment Specialized hospitals 73 12,186 4,874 for active treatment Psychiatry clinics 11 3,075 1,230 Dispensaries 50 4,348 1,739 Total 261 57,083 22,833 Source: NationalPlanfor the Disposal of Healthcare Wastes

119. According to the Environmental Executive Agency around 78 million tones of mining waste was produced in 2001 with almost 100% going to landfills. There is no specific data regarding construction and demolition waste arisings in Bulgaria. It is assumed however that the majority of this waste is disposed of in landfils with the remainder being reused for construction purposes.

Present Waste Management Facilities

Landfills

120. Waste is dumped at 278 landfills with a total area of 563.2 hectares. Most of the landfills are documented as household waste landfills, but in practice they are often used for dumping construction, industrial and in some instances, hazardous waste.

Table 19: Percentage of Waste Generated Going to Landfills in 2001

Waste Type Percentage Municipal 99% Hazardous 68% Non-hazardous Industrial 98% Mining 99% Construction and Demolition* 90% Sources: EEA Note: Much of the C&D waste is put to beneficial use on landfill sites. This waste stream is used as landfill cover, capping matenal and as construction material for site roads

The following is a summary of available data on the landfills that serve populations greater than 20,000.

37 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Table 20: Landfills Serving Populations Greater than 20,000 Inhabitants

node REWI Landfills Occupied Served Population Collected area settlements household waste number Ha Number Number Total per capita.

01 Blagoevgr 6 17.2 43 250,959 131,743 525

___ ad 02 Burgas 5 24.9 33 371,712 117,182 315 03 Varna 3 36.0 13 476,212 175,218 368 04 Veliko 5 30.3 13 259,423 151,113 582 Tamovo 05 Vratsa 1 1.1 1 76,596 11,419 149 06 Montana 3 8.7 4 151,177 48,690 322 07 Pazardjik 4 12.4 12 210,313 111,830 532 08 3 15.4 23 254,390 142,137 559 09 Plovdiv 3 31.5 10 458,491 135,588 296 10 Ruse 3 35.0 6 278,170 104,826 377 11 1 1.8 14 38,867 11,687 301 12 Sofia 8 48.3 105 1 638,543 646,726 395 13 Stara 5 24.5 17 498,016 147,354 296 Zagora 14 Haskovo 5 15.7 11 237,700 164,880 694 15 3 5.2 6 177,047 66,533 376 TOTAL 58 308 311 5,337,616 2,166,9 405 26 Source: Regional environmental and water Inspectorates

121. Again it is important to reiterate that the word 'household' is being used to describe municipal waste arisings. This is incorrect and distinction must be made between household, commercial and municipal. The above table 20 illustrates that 58 landfills, based on 2001 figures, serve 5,337,616 people or 67% of the total population. A further 220 authorized landfills serve the remainder or 33% of the population. Furthermore, it is estimated that a total of 4,830 illegal/unauthorized 'waste dumps' or landfills exist at present in Bulgaria. Prior to 2001 no information was collected regarding the conditions of the 278 authorized landfills. However during 2001 data regarding technological conditions of 135 landfills was collected. The following Table summarizes this information.

Table 21: Review of Technological Conditions of Landfills

Technological data for household waste landfills number of landfills Fencing - partial or complete 61 Guards - daytime or 24 hrs 69 Entrance control 50 Weighing bridge for incoming waste 14 Daily coverage of the waste with soil 16 Weekly coverage of the waste with soil 14 Annual coverage of the waste with soil 50 Record book under Regulation No.10/98 20 Monitoring performed by the landfill operator 10 (self monitoring)

38 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

122. An important finding is that less than 20% of landfills surveyed retain records, which is required under current Regulation No. 10/98. It is not possible to comply with the landfill Directive if adequate recording is not in place. Furthermore, lack of data from written records and weighbridges makes it difficult to make an accurate estimate of the amount of waste being landfilled. A requirement of the Directive is that all operating landfills will have to apply for an operational permit. At present, no existing landfill is operated to the required standard to enable a permit to be issued. Another requirement is that all disposal of waste to the 4,830 illegal/unauthorized landfills must cease. Approximately 33% of the population is served by some 220 landfills. Based on the most recent census data (7,928,901 inhabitants recorded in 2001), each landfill serves approximately 12,000 inhabitants. The magnitude of the required investments for the compliance period until and beyond 2015 is enormous and if utilization of such 'localized' waste management infrastructure (58 municipal landfills serving 70% of the population) continues, it will be economically difficult to comply with the key stipulations of the Landfill Directive. A major effort for regionalization of the landfills will be required. At present no authorized designated landfills exist exclusively for the disposal of hazardous and inert waste.

Composting

123. There is little experience with composting. One trial project is being carried out in the town of . About 200 households have been selected to take part in the pilot for home composting. The project is in its initial phase and data is not yet available. Plans have been made for composting plants to be located at two new regional landfills serving Plovdiv and /. These projects are presently at the feasibility study stage.

Thermal Treatment

124. Presently thermal treatment is not used as a form of waste treatment in Bulgaria.

Present Waste Management Practices

125. Waste management in Bulgaria continues to be dominated by landfills. Prevention and minimization are increasingly recognized as the more desirable solutions, but overall progress in this direction is yet to be seen.

I Waste services are generally the least developed of the environmental services traditionally delivered by local authorities. * With very few exceptions, municipalities have not so far delivered or applied integrated management techniques or innovative technology solutions. * Public perception of municipality performance on waste is poor because of the environmental impact and visibility of waste and the nuisance, which poorly managed and overflowing landfills can cause.

126. From the above it is clear that the burden of responsibility regarding waste management must be shared by the municipalities/regions and hence, also the responsibilities regarding compliance with the landfill directive. Traditionally, many municipalities within Bulgaria have exercised their waste planning and management functions in isolation from each other and from other service providers, and

39 Bulgaria:Environmental Sequencing Strategiesfor EUAccession essentially have acted as sole providers of public services and infrastructure in this area. Planning for the future must reflect a new approach to environmental management, involving constructive co-operation with local communities and neighboring municipalities, regional planning of waste disposal and utilizing the potential of the private sector to contribute to the delivery of public services.

Status of Implementation Plans for 1999-2002

127. One of the primary goals of the implementation program until 2002 was the construction of 37 new regional landfills by 2002. A list of the proposed landfills, with those highlighted either presently operational or under construction is provided in Annex IX. As part of the implementation plan for the National Waste Management Program, it was proposed to carry out a study for the construction of regional landfills for waste disposal after 2002. This takes into consideration the listing in Annex IX as well as 25 extra facilities and sites. This listing has now been completed outlining the towns that are to be served by each landfill, total population and reasons for building.

128. A summary of the status of the remaining proposed projects as outlined in the implementation plan 1999-2002 contained within the National Waste Management Program, of which would have direct influence with successful compliance with the Landfill Directive is provided in Annex VIII.

129. Furthermore, the implementation plan of the National Hazardous Waste Management Plan envisages 'Environmentally sound waste disposal' through:

* Prevention and reduction of waste production. * Reuse and recycling. * Improving the organisation of waste collection and transportation. * Minimisation of the risk from old contaminated sites. * Legal regulation of waste management. * Public awareness and participation in waste management issues. * Improving the system for monitoring, data collection and control.

130. Although the above may not be directly related to the Landfill Directive, all do however have a significant role to play. The ultimate goal of the Landfill Directive is to protect the environment. The most effective way of doing this is by diverting as much waste as possible from landfills (not just the biodegradable fraction). Therefore prevention, reduction, recycling etc. all have a significant contribution to make in the overall diversion of waste from the nation's landfills.

Existing Legislative Framework

131. The existing legislative requirements concerning waste disposal stipulated in Regulation No. 12 on the requirements which must be met by the waste treatment facility site, and Regulation No. 13 on the conditions and requirements towards the construction and operation of waste landfills do not meet the full requirements of the Landfill Directive. Regulatory provisions for preliminary waste treatment; non- acceptance of used tires; diversion from landfill of the required amounts of biodegradable waste as stipulated under the Directive; standards for the sampling of

40 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

surface water, groundwater and leachate as stipulated in the Directive are not adequate. The regulations are not explicit on the financial provisions and guarantees by operators and disposal operations to ensure that the obligations arising under the permit issued are exercised and closing procedures are enforceable.

132. The legislative harmonization and full transposition into the national law of the Directive 1999/3 1/EC will be completed with the adoption of the proposed Waste Management Act and the proposed amendments to Regulation No. 13 on the conditions and requirements towards the construction and operation of waste landfills. Strategy for Implementation of the Directive

133. In order to comply with the Directive, it is imperative that Bulgaria develop an in depth strategy for implementation. The following outlines a first step into setting up such an implementation plan. Such a strategy must be laid out before the exact steps that will be taken can be decided upon. It is important at this point, to reiterate that the following is not an overall waste management strategy for Bulgaria nor is it a series of ultimate solutions.

Promotion of Public Awareness

134. The importance of an intensive and effective public awareness campaign for successful compliance with the Directive cannot be underestimated. A knowledgeable and willing general public are essential to the acceptance of new waste management practices. Without positive public attitude, a successful implementation program to comply with the Directive would be difficult to achieve. Households in Bulgaria will also be partly responsible for the implementation of the landfill Directive and everything that this may entail. General community acceptance of the requirements of the Directive is of the utmost importance. The public must assist in the detection and prevention of unauthorized tipping and other undesirable waste management practices. More specifically the public also has a vital role to play in the diversion of biodegradable waste from landfills as well as other wastes and recyclables.

135. Public attitude in transition countries generally reflects the belief that the environment and waste are not their responsibility. Challenging this oftentimes misguided attitude, through education and communication, is the ultimate objective of a public awareness and information campaign. Educating the general public of the options open to them for example, on recycling and recovery facilities or of their responsibilities would reinforce public support to compliance efforts. Therefore a public awareness campaign is essential.

136. International experience shows that the timing of a public awareness campaign is of critical importance. Public information messages concerning desired recycling or separation activities need to be tied to the actual possibility for recycling or separation. When public messages do not coincide with an actual offered possibility of recycling and separation, the public can easily get disinterested in the process and turn away, something that has happened in many Western European countries.

137. NationalInitiative. The Ministry has already taken strides with regards to the above with the establishment of an Environmental Awareness Center in the Ministry and Regional Environmental Inspectorates. A campaign at a more local level is just

4 1 Bulgaria: Environmental Sequencing Strategiesfor EUAccession as; if not even more, important than it is at the national level where the public is more familiar and comfortable.

138. Local Initiative. The responsibility at the local level should lay with the municipality or region, depending upon whose responsibility it is to develop the local waste management plans. Those designated with the responsibility in each area will be available for meetings with both the general public, schools, as well as companies, businesses etc. on the requirements of the Landfill Directive as well as other environmental issues.

National Structure of Regional Planning

139. Waste management planning on a regional basis is vital for complying with the Directive. Without regional planning it will be impossible to successfully comply 25 with the Directive. Planning must be initiated at the municipal level (272), progressing to the administrative level (28), to regional level (6 plus the city of Sofia, which amounts to 7) and finally reaching a national scale. Municipalities should be encouraged to adopt a regional approach to waste management planning, with a view to the more efficient provision of services and infrastructure. Significant economies of scale and therefore more cost-efficient waste disposal solutions are the main benefits accruing from this regional approach. This in turn will provide:

* A viable framework in planning and volume terms for the development of integrated and innovative waste management solutions, facilitating segregated collection and incorporating materials recycling, organic waste composting, other treatment technologies and residual landfill. * A favourable climate for the creation of beneficial partnership arrangements between municipalities and the private sector.

140. If the 28 areas are in the process of making individual waste management plans, a serious concern may arise that the waste disposal solutions chosen are not cost-efficient since they do not take economies of scale into account. Accordingly, the areas should, prior to the development of individual plans, ensure that there is an adequate degree of co-ordination with neighboring areas. The following table outlines the 28 areas subdivided into 7 larger regions.

25 For the purpose of this document in order to avoid misunderstanding: the 272 municipalities will be refereed to as municipalities; the 28 administrative areas as Areas, and the larger six provinces/regions as well as Sofia as Regions.

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Proposed Regions and Populations

Region Included Municipalities Population

North East 137,689 Shumen 204,395 152,417 Varna 462,218 215,232 Silistra 142,003 Sub Total 1,313,954

South East Sliven 218,474 Yambol 156,080 Burgas 423,608 Sub Total 798,162

North Central Pleven 312,018 Lovech 169,951 Gabrovo 144,150 293,294 Ruse 266,213 Sub Total 1,185,626

South Central Pazardjik 310,741 Plovdiv 715,904 Smolyan 140,067 Kardjali 164,019 Haskovo 277,483 370,665 Sub Total 1,978,879

North West Vidin 130,094 Montana 182,267 Vratsa 243,039 Sub Total 555,400

South West Sofia Region 273,252 149,856 162,622 Blagoevgrad 341,245 Sub Total 926,975

Sofia City Sofia City 1,173,988 Source: PopulationBook 3 NationalInstitute for Statistics.

141. To fully comply with the Landfill Directive, it is important that regional waste management plans with realistic goals and objectives, are prepared and include information on the present situation, waste management policy objectives, anticipated developments, implementation plan of the waste management policy for the entire duration of the plans.

43 Bulgaria:Environmental Sequencing Strategiesfor EU Accession

142. Local Consultation. Waste management planning is clearly a task, which should be addressed for each area by the local government structures. All technical bodies should provide technical information and assessment of options as a basis for preparation of waste management plans, and chart a broad course of action which seems most appropriate for each area involving consultations on adoption of a waste management plan. This can best be achieved on the basis of good preparatory studies and effective public consultation and participation.

143. Short-term Flexibility. There may be situations where areas face an imminent shortage of disposal capacity, with some situations so acute as to require action in advance of the outcome of the current strategic planning process. A commitment to the provision of new landfill facilities, in isolation from the broader issues, which must be addressed, should as far as possible be avoided. Every effort should be made to develop interim solutions, which do not prejudice the outcome of the longer-term strategic solutions. Where immediate landfill capacity problems exist, action to extend the life of existing landfill facilities, rather than to provide new landfill sites, should be a priority. This can be facilitated by:

* Diverting as much waste as possible to composting and materials recovery * Diverting water treatment and sewage sludges for use in agriculture and forestry * Seeking access to landfill capacity available in neighbouring municipalities

144. Where an area determines that it has no option but to provide additional landfill capacity in advance of completion of the strategic planning process, consideration should first be given to the phased development of small scale cells, on or adjacent to existing facilities, rather than the acquisition and development of large green-field landfill sites for new landfills with a lengthy lifespan.

Waste Collection

145. There are basically two distinct types of collecting systems for recyclables and biodegradable waste which could be considered in a future strategy:

(i). Bring systems, which entail the provision and servicing of 'bring banks' for the collection of glass, metals, paper, plastics and textiles and 'civic amenity' facilities where the public can additionally deposit bulky waste items such as electrical goods and DIY waste as well as hazardous materials such as batteries and waste oils (ii). Collecting systems, where a special vehicle is provided for the collection of recyclable waste materials that have been segregated at source. This includes both 'kerbside' (domestic) and 'commercial' collections.

146. Collecting systems are the most appropriate with regards to biodegradable wastes. The type of collecting systems employed must reflect the recycling scenario to be pursued. A significant proportion of municipal waste is organic material; either separate or alternate bin collection is necessary to allow this material to be efficiently segregated and diverted to a central composting/incineration facility. Different approaches may be utilized in order to segregate materials for recovery purposes including: (i) the use of multiple bins or other containers; (ii) alternate collection

44 Bulgaria:Environmental Sequencing Strategiesfor EUAccession schedules, (iii) kerbside collecting systems. Systems (i) and (ii) are suitable for the collection of the organic fraction of the biodegradable waste stream whereas (iii) is more appropriate for paper and cardboard. Factors that require consideration in choosing the individual components of collecting systems include: population density, financial implications, and the extent of public participation.

147. Realistic recycling options for paper/cardboard depend very much on the product market, which can vary both geographically and overtime. The variation of world prices for paper, for example, sometimes makes its collection and sorting a very profitable business and sometimes results in losses. The following is one of a number of scenarios and avenues that can be followed and explored with regard to the segregation of biodegradable waste and recyclables.

148. Domestic Waste Collection. It is necessary for waste collection services to implement a 2-bin collecting system. Each region can decide how to operate this system to deal with its own individual circumstances and requirements. However, the system must be capable of collecting household organics and paper waste separately to the remaining waste streams. Each region can choose the type of container for collecting the organic waste. A rotation system could be developed if collection of the different types of waste is to occur on different days or weeks, in order to optimize the use of the collection vehicles. A common color coding system for bins/receptacles needs to be used throughout the region, as this will assist the public awareness campaign.

149. It should be noted that, where practical, towns/areas with a population of less than 1,500 should initially, be open for consideration of a 2-bin system on a case-by- case basis, rather than a compulsory requirement, due to financial constraints.

Table 22: Collection and Set out Rate

Residual Dry recyclables Organic Hazardous Total waste waste Waste 2-bin

Extra waste 1 bins No. of 26 0 52 0 76 collections Iper yearI

Set out rate 65% -65% _

The above illustrates that an initial extra 26 collections (2-bin system) will be necessary. It is envisaged that a 2-bin collecting system for the collection of organic waste will only be necessary for the second reduction period of 50% of diversion in 2015, hence starting around 2012 (see below under organic waste). Commerciallindustrial Waste

150. It is recommended that commercial/industrial waste be separated into three separate fractions from the outset: (i) dry recyclable, (ii) organic waste, (iii) residual waste. It is however recommended to develop a public-private sector strategy for this type of waste. Regulations and licensing are necessary to stimulate waste recovery

45 Bulgaria:Emnironmental Sequencing Strategiesfor EU Accession initiatives and prevention of commercial/industrial waste in public landfills. These regulations would make the sector itself responsible and liable for achieving satisfying waste disposal solutions.

Recyclables

151. Kerbside collection in this instance refers to the separate collection of paper and cardboard for recycling. Statistics with regard to the paper/cardboard stream show that 10% of municipal waste consists of paper/cardboard, which is probably too low, specifically since the composition between household and commercial waste is not known. There will be a big stream of paper/cardboard arising from commercial waste.

152. Since there is no differentiation between household and commercial waste, it is assumed that 20% of household waste is deemed to consist of paper/cardboard. If it is assumed that there is a an initial collection efficiency of 50% for kerbside collection increasing to 70% by 2012 for urban areas which constitutes 70% of the overall population of Bulgaria (national statistics) that implies that around 50% of the overall recyclable waste stream from households will be recycled by 2012, which in turn implies that around 10% from the overall municipal waste stream will be recycled. This would equate to approximately 350,000 tons per annum of paper/cardboard recycled.

153. Furthermore, the Packaging Directive26 94/62/EC will certainly aid in the overall recycling and reuse of packaging waste, which will have a significant impact on the paper/cardboard element of the biodegradable waste stream. The Directive's priorities are preventing the production of packaging waste, reusing packaging, recycling and other forms of recovering packaging waste and, hence, reducing the final disposal of waste. If the figures from both the Kerbside collection and the consequences of implementation of the Packaging Directive are to be combined, an optimistic scenario is 15% of the municipal waste stream being recycled. However a full analysis of the potential markets for recyclables must, firstly be carried out before any of the above strategies are implemented. If the actual percentage of paper/cardboard in municipal waste would be actually around 30% with 58% originating from commercial activities, the packaging Directive could have a direct influence on about 17% of all municipal waste produced.

Organic Waste

154. Article 5 of the Directive stipulates a significant diversion of biodegradable waste from landfill. All planning must be based on 1995 figures. The main target years, if it is presumed that Bulgaria will apply for a transition period of 4 years, are: * 25% reduction in the amount of biodegradable waste going to landfill, (based on 1995 figures), by 2012; * 50% reduction in the amount of biodegradable waste going to landfill (based on 1995 figures), by 2015; * 65% reduction in the amount of biodegradable waste going to landfill (based on 1995 figures), by 2022.

2 Article 6 of the Packaging Directive states that not less than 5 years after the date by which the Packaging Directive has been implemented into national law, 25% - 45% of all packaging waste must be recycled.

46 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

155. The primary target therefore is 2012. This is an achievable target, but to do so will need a great deal of planning and regional co-operation. One of the easiest ways of doing this is waste separation at source and separate collection of the resulting separated wastes. This obviously applies to all recyclables as well as merely the biodegradable fraction, all of which aids considerably in the overall objectives of the Directive.

156. The following outlines the possible strategy for dealing with biodegradable waste. It is based on the country being divided into 7 regions. This is a much more 'manageable' scenario than dealing with the problem on a national basis. Furthermore it is consistent with the targets stipulated in the Directive. For example, to comply with the targets set out in the Directive, more diversion may occur in one region with less diversion of biodegradable waste occurring in another but still meeting the national targets. The composition of waste is different in urban (e.g. Sofia) and predominantly rural areas. This again raises the importance for the development of a comprehensive national waste database based on sound figures and a national strategy for the treatment of biodegradable waste.

157. Article 5 of the Directive states that diversion of biodegradable waste diverted from landfills should be a percentage of the total amount (by weight) of biodegradable municipal waste produced in 1995 or the latest year before 1995 for which standardized Eurostat data is available. An extra 488,844 tons was produced in 1995 in comparison to present, more recent figures. For the purpose of complying with the Directive therefore, it is important that all recommendations, strategies and financial calculations are based on the Eurostat 1995 figure of an overall waste production of 4,495,000 tons. However due to the big reductions of waste generation in Bulgaria after 1995, this Article of the Directive might be subject to further negotiations on the precise amounts of biodegradables that need to be diverted.

158. The following table outlines the accumulations in each region, if the deficit between the 1995 and 2001 figures is spread equally over the 7 regions. Therefore an extra 69,834 tons is added to each region to get a total of 4,495,000 tons (figure of total municipal solid waste produced in 1995). Presuming that 50% of the municipal waste produced consists of biodegradable waste27 the following table outlines the breakdown and targets of municipal biodegradable waste by region if the burden was to be shared equally by all regions.

27 Consisting of 20% paper/cardboard and 30% organic waste

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Table 23: Breakdown and Targets of Municipal Biodegradable Waste by Region based on 1995 Figures

Region Municipal % Bio- waste 25% 50°o 650o Diversion waste (1995) Diversion Di-version produced NE 733,379 366,689 91,672 183,344 238,347 SE 472,905 236,452 59,113 118,226 153,693 NC 668,573 334,286 83,571 167,143 217,285 SC 1,069,164 534,582 133,645 267,291 347,478 NW 350,309 175,154 43,788 87,577 113,850 SW 537,956 268,978 67,244 134,489 174,835 Sofia City 662,120 331,060 82,765 165,530 215,189 Total 4,495,000 2,247,500 561,874 1,123,750 1,460,875

159. Looking at the implementation of the Packaging Directive and kerbside collection of paper and cardboard, the amount of biodegradables that need to be diverted from landfills can be between 10%-20% lower than estimated in the table above.

160. However it is not to be expected that the percentages of streams of collected organic waste will be the same in all regions, and differentiation in the quantities of expected organic waste per region will be necessary and are to be expected. Especially in urban areas collection of organic waste is much more difficult and costly. Hence the following strategy is proposed:

Start with a focus on easy streams that are already separated and/or those streams that are easy to collect and where the potential for cross-contamination with other waste is low. These can be the following:

* Organic streams from farms, fruit and vegetable markets and shops etc * Garden waste from rural areas, and towns where people have gardens (probably excluding Sofia, which is quite a big city with expected difficult collection.

161. Experience from other European countries shows that approximately 25% of the organic waste streams can be collected through such easy separate collection of bio-waste streams. This would amount to approximately 285,000 tons of organic waste per year. Another advantage is that these streams are quite pure and will be suitable for composting and use in farms due to low expected contaminations of other waste. Dependent on local logistics and expected participation of households, landscapers and fruit and vegetable markets and shops, a second bin collecting system can be introduced specifically for the collection of garden waste in those areas where garden waste is available or civic amenity sites can be built as bring sites where garden and farm waste can be delivered.

162. It is envisaged that with collection of the "easy" bio-waste streams the first Directive benchmark of 25% diversion of biodegradables can be met, especially with

48 Bulgaria: Environmental Sequencing Strategiesfor EU Accession the simultaneous introduction of paper and cardboard curbside collections. Only for the second reduction period in 2015, with 50% of necessary diversion of biodegradables, will it be necessary to introduce total diversion of biodegradables from household waste. This can be done through the introduction of the 2-bin collecting system as described above. In this collecting system, separate collection of households organic waste will be implemented. However, this can also be done through mechanical sorting at the final destination. Whether a choice is preferable between separate collections versus mechanical sorting, will depend on the expected participation and assistance of the domestic population 28, the resulting cleanness of the fractions and the existing markets for composted organic waste. If markets for compost appear not to be very feasible, the organic waste will need to be incinerated, hence the cleanness of the sorted fractions is not that important.

Composting Technologies

163. There are two principal forms of biological treatment: aerobic treatment commonly known as composting and anaerobic treatment, commonly known as bio- gasification. For the purpose of this review and the goal of diverting biodegradable waste from landfills, composting will be examined. There are however, a number of other alternatives that should be examined closely as part of a national strategy for the treatment of biodegradable waste.

164. The composting process is based on microbiological and aerobic treatment (in the presence of oxygen). This process generally transforms the carbon in the waste to carbon dioxide CO 2. This process takes place at a higher temperature than the surroundings due to the energy released in the carbon transformation. Shredding, venting and irrigation regulates the composting process.

165. Composting of waste can basically be divided into three main steps, namely: (i) pre-treatment, (ii) composting, and (iii) screening and disposal. Reactor composting is a high-tech process that appears in various guises but primarily as tunnel composting29. Pile composting and windrow composting use low-tech methods. The difference between pile and windrow composting is that pile composting is only suitable for park and garden waste while windrow composting can treat household organic waste, including vegetable and animal matter as well as garden and park waste. The process takes 8-12 months.

Home Composting of OrganicHouseholdWaste

166. The local and regional waste management plans should provide for the introduction of a home composting program for organic waste in rural areas. Home composting is equally suitable for urban areas provided that sufficient garden space is available. Home composting has the potential to reduce significantly the volume of waste presented by households for collection and treatment by the relevant agencies.

2S Some cities in have given up on the separate collection of organic waste from households and shifted to mechanical separation instead. Also some cities have shifted from composting the separated domestic orgamc waste to incineration of separated domestic organic waste due to a low demand of agricultura farmers for such compost. 29 Reactor/Tunnel Composting. Reactor composting takes place in a ventilated building, under more controlled conditions than the low-tech composting technologies mentioned above. Reactor composting is a much faster process but there are high investment and treatment costs.

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167. Due to the high apartment occupancy, the impact that home composting may have on the overall diversion may be limited. The population in Bulgaria is approximately divided into 70% urban and 30% rural. With an existing population of around 7.9 million and an average household occupancy of 2.5 implies a total of 3.16 million households with less than a million in rural areas.

168. However, it must be emphasized, that home composting must still be encouraged and promoted. Schools, hospitals and other such institutes must also be encouraged to compost their organic waste on site. The actual composting of organic waste is a particularly important activity for schools. Not only do many schools possess sufficient land on which to initiate suitable composting initiatives, but also the actual composting process itself is highly relevant to the wider science curriculum and provides a focus for awareness-raising. Municipalities should be encouraged to develop these initiatives.

169. Natural composting of well-blended and graded organic waste typically takes 12 months provided that a supply of air is available and the appropriate proportions of carbon and nitrogen are present within the constituent materials. However, the maturation time can be reduced to approximately 6 months through the appropriate and efficient use of compost unit containers.

Windrow Composting

170. Windrow facilities could be set up initially, within each of the 28 areas to cater for all garden-waste and organic wastes being produced by the rural communities. These facilities should be constructed at recognized waste disposal locations, preferably at existing or planned municipal landfills. They should also make up a part of civic amenity sites (which should form a part of an overall national waste management strategy). The capacity of each should be a minimum of 2,000 tons per annum, but preferably bigger to reduce investment costs. Such facilities can contribute by diverting up to 300,000 tons per annum nation-wide (25% of total municipal streams). These facilities would be geared more towards servicing the private householder or businesses such as landscapers, farms, and fruit and vegetable markets and shops as a form of 'bring bank' for the treatment of green or garden waste. Alternatively, large bins specifically aimed for the collection of garden waste could be integrated in the collecting system.

Central Composting (Tunnel)

171. It is proposed to start with a few composting facilities for the "clean" streams of garden waste and the separate bio-streams from landscapers, farms, fruit and vegetable markets and shops etc.

172. For the purpose of this report composting facilities with a capacity of 25,000 tons per annum are presumed for each proposed facility. Larger facilities could be developed in regions taking into consideration the individual demographics and transport infrastructure of each region. Furthermore, due to economies of scale, larger plants, where deemed suitable, would be more cost effective and less expensive in terms of overall capital cost. Numbers and costs of transfer stations as well as their location are not determined since not enough is known about individual demographics and transport infrastructure. With minimum capacity of 25,000 tons and one facility per region, the number of composting facilities will be between 7-20 depending on the

50 Bulgaria: Environmental Sequencing Strategiesfor EUAccession size of the composting plants. For this strategy an initial amount of 15 composting facilities has been assumed but this figure needs to be verified.

Proposalsfor Developing a National Strategy on Biodegradable Waste

173. A National Strategy on Biodegradable Waste would provide for the measures contained in plans for the management of biodegradable waste, including paper and textiles. Particularly it should focus on details and cost for: * Infrastructure for biodegradable waste outlined in the local, regional and national waste management plans; * Introduction of separate collecting systems for segregated garden municipal streams, biodegradable recyclables (e.g. paper, textiles) and in a later stage segregated municipal organic streams and the extent of coverage proposed; and * Other initiatives on biodegradable waste management already initiated by local authorities and the private sector.

174. The strategy will have to consider the following areas in a cohesive and focused manner: ) A quantification of the benefits and the costs for the separate collection and treatment of "green" wastes (i.e. mainly garden wastes) and "kitchen" wastes (i.e. mainly food wastes). 0 An assessment of the potential collection options for urban/rural and single/multi dwelling households, together with associated costs. ) Evaluation of the home composting schemes implemented in the various regions and an identification of the factors that have resulted in success and an evaluation of the extent, and the manner of implementation, to which home composting should be pursued to facilitate the achievement of the required targets set out in Council Directive 1999/3 1/EC on the landfill of waste. 0 Investigate the relative merits of, and constraints on the treatment of biodegradable waste arising from municipal and industrial sources in conjunction with agricultural wastes, with particular regard to Regulation (EC) 1774/2002 of October 3, 2002 which lays down health rules concerning animal by-products not intended for human consumption. An account should be taken of the different circumstances that may exist across the various regions. > Examine the merits of the various treatment methods for municipal biodegradable waste (including but not limited to material recycling, composting, anaerobic digestion, annelid conversion, ethanol production as well as incineration). The suitability of each treatment method should be assessed in the Bulgarian context and estimated costs and application possibilities and recommendations should be made as to a preferred procurement method, taking into account: - Measures and instruments used in other European countries to achieve the levels of diversion from landfills required under the Landfill Directive; and

51 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

- The options available for procuring centralized composting, anaerobic digestion and other appropriate treatment facilities.

> Estimate the future levels of conventional material recycling of municipal biodegradable waste materials (e.g. paper, textiles), together with the costs associated with the various collection and treatment options; 0 Provide recommendations in relation to the future infrastructure required for the management of biodegradable waste in each region. An inventory of the infrastructure should be prepared, including: -the capacity currently available, -the future infrastructure required in each region to enable Bulgaria to achieve the targets stipulated in the Directive. > Present clear guidance regarding the environmental standards and requirements which will need to be applied in the authorization of biological treatment facilities, with particular regard to the proposed European Community Initiative on the Biological Treatment of Biodegradable Waste; > Develop clear guidance on the regulatory controls and requirements necessary for health and food safety which will need to be applied in the authorization of biological treatment facilities, with particular regard to Regulation (EC) 1774/2002 of October 3, 2002 which lays down health rules concerning animal by-products not intended for human consumption;

> Identify the issues relevant to determining the end use and production of marketable high-quality products; and > Consider and identify the need for any adjustments to the current regulatory system in the interests of effective implementation of the draft National Strategy on Biodegradable Waste once adopted.

175. It is clear from the above, that to successfully develop such a strategy a significant amount of information gathering and planning is necessary. This report has touched on many of the issues, but cannot be considered a fully developed strategy.

Energy Recovery from Waste

176. Mass burn Waste to Energy (WTE) plays a major part in municipal waste management in many EU countries. In general, materials recycling and WTE incineration are fully compatible in an integrated approach to waste management. While landfill disposal of residues will always be required and is less expensive than incineration, mass burn WTE is effective in diverting over 70% of municipal waste away from landfills and, if properly controlled has a considerably lower environmental impact than landfills.

177. WTE facilities involve a relatively higher initial capital outlay and until recent years were viable only on a very large scale (-400,000 tons per annum (tpa) input, 30MW power output). Available technologies have now advanced so as to make small to medium scale WTE plants (75,000 tpa input 5.5 MW per output) viable. Accordingly, it is possible that this technology has a role to play within an integrated waste management program and therefore in meeting the requirements stipulated in the Directive.

52 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

178. Incineration processes have undergone major technical developments in recent years and emission-scrubbing systems are now capable of achieving very high environmental standards, albeit with high cost implications. In the medium to long term, emission control standards applicable to municipal waste incineration within the EU may be expected to increase significantly to a level comparable with those currently applied to hazardous waste incineration.

179. Where markets for recyclables are uncertain, or the recycling sector cannot reasonably be expected to cater for the volumes of waste diverted from landfills in accordance with EU or national targets, WTE could prove to be a beneficial option. Care is necessary, however, to ensure that the development of WTE capacity does not militate against long-term investment in materials recycling, recovery and composting.

180. There is scope for the use of waste (and residual materials from certain waste treatments) as a fuel in other combustion processes, including power generation and cement manufacture, subject to appropriate controls and emission standards. Elsewhere in the EU, cement kilns have traditionally burned a wide range of wastes including tires, oils and plastics, and this option merits investigation where circumstances are appropriate

Strategyfor Waste to Energy

181. Plans are in place to develop this form of waste disposal. However, at present there are no such facilities in the country. Waste to Energy/Incineration is a contentious issue throughout many member states at present. Ideally, Bulgaria could be planning to develop such a treatment facility for each of the seven regions. Realistically, however, due to the significant capital costs involved and forecasted public opposition to such projects, Waste to Energy may not appear as a viable option in the short to medium term but should be considered as a viable option in the long term, i.e. post 2015. Furthermore, to meet the requirements under article 5 of the Directive, pertaining to the diversion of 65% of biodegradable waste by 2022 (assuming a 4-year transition period), some form of thermal treatment will be necessary.

182. The above outlines the problems that Bulgaria will face in the future if reliance on landfills is maintained. It is therefore proposed that thermal treatment is introduced as an alternative to landfilling. For the purpose of this review in order to give an indication of the task ahead and costs that will need to be incurred, it is assumed that each region constructs one thermal treatment plant capable of receiving 250,000 tons per annum. This requirement should be regarded as a general approach as more detailed studies will indicate the optimum size of thermal treatment plants required and optimum areas to be served once further analysis and research has been undertaken in catchment areas to be served, transport costs, the development of transfer stations, transshipment yards etc.

183. The initial capital costs are high but nevertheless the impact on the environment will be minimal due to modern technology and with time, energy will be recovered to reduce costs. Landfilling will always be necessary (even for residual waste produced by the thermal treatment facilities) but with the introduction of thermal treatment, the extent of reliance on it as a form of disposal can be reduced.

53 Bulgaria: Environmental Sequencing Strategiesfor EU-Accession

184. Due to opposition issues against incineration throughout Europe, it is imperative to plan well in advance for such projects in order to build up confidence within the public regarding the technology proposed. Public educational and awareness campaigns must be developed in the near future to avoid opposition at a later stage, hence the significance of a comprehensive public awareness campaign, the importance of which has already been highlighted. It is for these reasons, that planning for the introduction for thermal treatment should begin at the earliest opportunity.

185. Furthermore, site selection for such a process will be a one off event unlike the landfill scenario where suitable land will become exhausted within the regions. The exact capacity and location of the proposed plants will be dependent on detailed regional waste management planning. Initially consideration should be given to the provision of 7 regional thermal treatment facilities as proposed. Following the development of more detailed planning the optimum sizes and locations for thermal plants required to meet the projected needs can be determined.

186. It is evident that a more rigorous analysis of the utilization of thermal treatment/incineration is necessary. Much of this analysis should be carried out as part of the recommended regional waste management plans as these plans, although planning directly for a 4-5 year period, should also look to the long term. Furthermore, the information gathered for and contained within such plans would form the basis for analyzing the viability of thermal treatment/incineration.

Management of Hazardous Waste

187. On transposition of the Directive into Bulgarian Law classification of landfills into the following categories will be required as to the following: (i) Hazardous, (ii) Non-hazardous, (iii) Inert.

188. Plans are already in place to develop a central hazardous waste treatment facility and 4 hazardous waste landfills. However, a full National Hazardous Waste Management Plan should be developed in order to describe and quantify the problems facing Bulgaria concerning not only hazardous waste but also contaminated land. At present an estimated 518,000 tons of hazardous waste is being landfilled in Bulgaria. Although the quantity for disposal is significantly less than other wastes the costs of hazardous waste disposal and treatment is higher. Each region should have some basic hazardous waste treatment facility. This could be either a designated landfill or designated cells within a municipal waste landfill facility and would very much depend on the location of the proposed central treatment facility and the quantities of hazardous waste produced in each region. It is therefore important that a comprehensive national hazardous waste management plan is drawn up addressing these problems.

189. Objectives of National Hazardous Waste Management Plan. The primary objective of a National Hazardous Waste Management Plan is to prevent the production of hazardous waste and to minimize the effect of hazardous waste on the environment. The secondary objective is to manage hazardous waste, which cannot be prevented, in such a manner as to ensure that the impact on the environment is minimized and not transferred from one environmental medium to another. The objective should be to bring about a qualitative reduction in the quantity of hazardous waste requiring management. The objectives of a National Hazardous Waste

54 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Management Plan should introduce the polluter pays and precautionary principle to environmental risks, and inter alia include the following: > Inventory and prediction of hazardous waste by type, quantity and origin, its movement within, into and out of the country and facilities available for the collection, recovery and disposal of waste. > Objectives and, where appropriate, targets in relation to the prevention and minimization of the production of hazardous waste, the minimization of the harmful nature of such waste and the recovery or disposal of such waste. > As appropriate, the identification of sites at which waste disposal activities with hazardous waste have been carried on, the assessment of risk of environmental pollution and the recommendation of measures to prevent or limit such pollution or identification of remedial measures.

190. The strategy should make recommendations with respect to the management of hazardous waste, regarding priorities, measures and programs which could be pursued, infrastructure, facilities or other physical resources considered to be necessary, functions of any relevant public authorities.

191. In order to ensure adequate hazardous waste landfill capacity, a number of options exist. The current practice of disposing of hazardous waste at non-engineered and unlined landfill facilities is not sustainable and is in breach of the Landfill Directive. On the basis that there is no engineered commercial hazardous waste landfills in Bulgaria, the following options must be considered: ) Export all hazardous waste for which landfills are the only option; 0 Construct dedicated engineered hazardous waste landfills; > Construct engineered hazardous waste cells adjacent to existing facilities; and w In the long term the export of the waste is not a viable option as EU policy is to discourage the export of waste for disposal.

192. The total amount of generated waste as outlined in the "Waste Survey"30 for the Ministry in 2001 is 528,318 tons. Out of this total amount, 168,000 tons are proposed for treatment at the proposed National Hazardous Waste Center. That leaves around 360,000 tons to be disposed or treated at other locations. Furthermore it is expected that a further 700,000 tons is currently in storage and will also need to be disposed.

193. The construction of dedicated landfills in Bulgaria is considered a viable option where the absolute minimum economic scale for such a facility is in the region of 25,000 tons per annum. Plans are already in place, as outlined in the 'National Waste Management Program 1999' to develop 4 such designated hazardous waste landfills.

30 In the preparation for the establishment of a National Hazardous Waste Center, the quantities of hazardous waste being produced, was estimated In the estimation, the waste produced by Neftochim was excluded as this company has its own incinerators and a new project, handling the internal generated waste, is currently under way. Also miing waste has been excluded as the quantities are deemed to be too large to be considered in the study. As well as the proposed construction of the afore mentioned center, designated regional hazardous waste landfills should be considered.

55 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

194. The construction of hazardous waste landfill cells adjacent to an existing landfill facility offers a less expensive option. However, only certain types of hazardous waste as stipulated under Article 6 can be accepted at such cells i.e. non- reactive hazardous wastes (e.g. solidified, vitrified), with leachate, which fulfill the criteria set out in accordance with Directive.

195. Immobilization of such waste by binding it into a matrix prior to landfill disposal may be appropriate in such circumstances. The primary objective of waste immobilization is to reduce the possibility of hazardous substances leaching from the waste. In effect, the solubility of the waste is reduced thus decreasing the chance of substances being transferred to the liquid leachate phase.

196. Comprehensive information of the composition of hazardous waste is not available therefore the amount of waste that should go to a designated landfill or waste that would need immobilization then disposed in a designated cell at a municipal landfill cannot be predicted. It is recommended to develop the 4 planned designated hazardous waste landfills. Furthermore immobilization plants must also be considered. The equipment required for an immobilization plant includes cement silos, mixers, conveyors and containers. It is not clear, however, due to the lack of the actual composition of the hazardous waste arisings, as to how many plants or of what capacity would be required.

197. It is estimated therefore that, based on the figure of 518,000 tons of hazardous waste, the construction of the National Hazardous Waste Center (capacity 168,000 tons per annum) and 4 designated landfills (capacity of circa 90,000 tons per annum) should be adequate in the short to medium term. However, as stated earlier the actual composition of the waste is unclear and therefore the amount of waste that would be suitable for designated cells at municipal landfills cannot be predicted. Furthermore it is not possible to calculate the amount of waste that would require immobilization. The lack of information and planning in this sector again reiterates the importance of developing and adopting a National Hazardous Waste Management Plan, the contents of which have been briefly highlighted above.

HospitaUMedical Waste

198. The following is a breakdown of the amount of medical waste produced in Bulgaria:

Type of hospital No. of hospital beds No. of beds Waste Quantities (kg/day) (0.4 times number. of beds) MHAT 127 37,474 14,990 SHAT 73 12,186 4,874 Psychiatry clinics 11 3,075 1,230 Dispensaries 50 4,348 1,739 Total 261 57,083 22,833 Source:National PlanforHealth Care Waste

199. A range of development scenarios for implementing improved health care waste management practices, and complying with legal requirements, has been projected in the proposed national plan for healthcare waste. This document is however still in draft form and has not been formally adopted by the Ministry. It must be noted that, as stressed in the plan, that these development scenarios are intended to

56 Bulgaria:Environmental Sequencing Strategiesfor EUAccession be notional, i.e. they are not fixed statements of what will be developed, but options which represent a range of possible solutions.

200. The following development scenarios have been projected and assessed within the health care waste management plan3' for Bulgaria: * Scenario 1: Development of autoclave or microwave treatment facilities (and supporting collection infrastructure) in each of the 28 administrative regions by 2005, and replacement with similar facilities in year 2013. * Scenario 2a: Development of autoclave treatment facilities (and supporting collection infrastructure) for 9 groups or administrative regions by 2005, and replacement with autoclaves in years 2013. * Scenario 2b: Development of autoclave treatment facilities (and supporting collection infrastructure) for 9 groups of administrative regions, and replacement with autoclaves and incineration facilities in year 2013.

For the purpose of this report, in order to project costs, scenario 2a will be chosen. However, it is suggested to develop the facilities in the 7 regions already recommended rather than the 9 proposed within the health care waste management plan, in order to tie in with the already recommended structure of the 7 regions. Construction and Demolition (C&D) Waste

201. There is no specific data regarding Construction and Demolition waste arisings in Bulgaria. It is assumed however that the majority of this waste is disposed of to landfills with the remainder being reused for construction purposes. However, according to the Directive, such waste must now be disposed of to designated landfills for inert waste if not suitable to be reused for reconstruction purposes. Mobile facilities for the treatment of C&D are however, available. A mobile plant 32 processes some 250,000 tons of material per annum.

202. Within Bulgaria, there is no main construction & demolition waste-producing center. Accordingly, mobile systems could be built, one for each of the proposed 7 regions. These could be located at existing waste facilities such as landfills and in the long term at proposed transfer stations. The added advantage of these locations, is the degree of supervision available, otherwise poor quality problematic waste could be stockpiled, causing processing difficulties.

203. In the short term, recovered material from the construction & demolition waste can be used in landfill restoration. In the long term, specifications at the national level are required which would permit this material to be used in, for instance, local road schemes.

204. It is however recommended to develop a public-private sector strategy for this type of waste. Regulations and licensing are necessary to stimulate waste recovery initiatives and prevention of commercial/industrial waste in public landfills. These

31 Refer to the "Draft Report on the Assistance in Development of National Plan for Hospital Waste Management 2002" for further details 2 C&D Mobile plant producing the following materials for reuse: 150-100mm granular material, 100-50mm granular material, 50-Olmm subsoil type fines material

57 Bulgaria:Environmental Sequencing Strategiesfor EU-Accession regulations would make the sector itself responsible and liable for achieving satisfying waste disposal solutions.

Landfilling of Waste

205. If the goals of composting are achieved by 2015, some 2.5 million tons of municipal waste will still be required to be landfilled or incinerated annually. The landfilling of this material will require a minimum of 30 additional regional landfills each receiving 100,000 tons per annum to be constructed every 15- 20 years.

206. The examination of the future planning of landfills outlined reveals many overlapping service areas. Many of the proposed landfills do not have the sufficient population base for a financially viable regional operation. Modem and cost effective waste management is built around regional landfills which are serviced by transfer stations from outlying population centers and would probably be a more cost effective solution in the majority of the locations listed in Annex IX. The bigger the size of the landfill the more economies of scale are possible to achieve.

207. The list of proposed landfils including locations and proposed populations served is outlined in Annex IX. 58 (plus 4) landfills are proposed, some of which are already at construction stage. It is evident that there is need for a detailed and critical analysis of the existing landfill construction plan to study capacity needs, forecasts, technical solutions and associated investment costs. This particularly should take into consideration the landfills which don't have a sufficient population base to support them and of landfills with overlapping areas. It is estimated that there is in excess of 4,500 illegal and unauthorized dumping sites in Bulgaria. Proposals must be drawn up to close all such sites as soon as possible.

208. There are 278 authorized landfills covering an approximate area of 563.3 hectares. All operators must be made aware of their permitting requirements as stipulated under the Directive. Details of what a permit application should contain, is outlined in the following section. If the landfills do not meet the necessary requirements as laid down in the Directive, they must cease activities. Furthermore, these landfills when closing, as well as those nearing full capacity must be done in accordance with the requirements as stipulated in the Directive. It is therefore recommended that the Ministry of Environment and Water produce four landfill manuals as guidance documents outlining the requirements with regards to all aspects of landfill design, closure etc. The proposed landfill manuals are: site selection, site design, operation and monitoring and restoration and aftercare.

Waste Management Licensing and Permitting

209. The Directive stresses the need for a proper and controlled licensing and permitting system for landfills. At present the Regional Environmental Inspectorates attached to the Environmental Executive Agency are responsible for reviewing the permits, with the Ministry actually responsible for issuing the permits. There is a functional overlap of the organizations involved in the process. Responsibility of inspection, reviewing and granting of the permits must be given to a single body i.e. the Ministry or the Executive Agency.

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LMPLEMENTATION PLAN

The implementation plan presents in sequence recommended priority actions for the period 2003 - 2015 and extended completion until 2020. Table 24: Strategy Implementation Plan

Project 200200004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Administration Public Awareness Campaign ili i MEimEiT i MijEMi[Si imILllml1iEM= Full legislative transposition

28 waste management plans

7 regional plans

National waste database

National hazardous waste management strategy

National Strategy on biodegradable waste

Waste licensing and permifting * * U U B U U E U K U U

Development of landfill manuals

Continuedoverleaf

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Table 24: Strategy Implementation Plan (Continued)

Probect 2003 2004 2005 2006 2007 12008 2009 201 011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Treatment and Collection Home composting

Construction of 15 central composting sites

VWndrow composting/civic amenity sites

Introduction of 2 bin system -

Hospital waste facility

National center for hazardous waste

Waste to energy

Disoosal Proposed landfills *** ****** **** * **

Proposed 4 hazardous waste landfills - fl * * *

Landfill dosure

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Investment Forecast Implementation Plan per Component

Present Expenditures on Investment and Operational Costs

210. According to the National Statistical Institute the following expenditures were made in the waste sector in Bulgaria from 1999-2001:

Table 25: Actual Expenditure 1999-2001

Year 1999 2000 2001 Total Expenditures in Municipal 27.9 26 34 (Million Euro) MEuro % MEuro % MEuro % Capital Expenditure 5.2 19% 6.7 26% 14 41% MEuro % MEuro % MEuro % O&M 22.7 81% 19.3 74% 20 59% Source: National Statistical Institute

Most of the sources were spent to cover O&M costs, most probably as subsidy, while capital investments were very limited. It was not possible to determine the specific projects that incurred this capital expenditure. The State budget and the National Environmental Protection Fund mainly financed these investments. Very little investments have actually taken place under the ISPA Program to date. It is estimated that works contracts will be signed in 2003 for 7 Regional landfills with an estimated combined cost of around EUR75 million. The profile of investments required will have to be revised and updated by the responsible Ministry annually. Investment Forecast

211. Costs estimates have been included for the following elements

* General administrative and planning costs * Thermal treatment plant * Decentralized composting * Central composting * Garden waste composting and home composting * Landfiling

General Administrative Costs

212. The following table is a summary of the initial costs required for each main administrative and planning requirement for successful compliance with the Directive. However these costs are primarily concerned with getting the initial plans completed.

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Table 26: Administrative Costs (EUR)

Item Unit cost Total Public awareness campaign 2,300,000* Area waste management plans - 28 150,000 4,200,000

Regional waste management plans - 7 200,000 1,400,000 National waste database 300,000 National hazardous waste management plan 200,000 National strate on biodeadable waste 80,000 Development of landfill manuals - 4 10,000 40,000 TOTAL 8,520,000 *The costs for a public awareness are spread over the 13 years from 2003 - 2020

Construction & Demolition Waste Handling

213. It is assumed that C&D waste arisings in each region will be treated in a mobile crusher plant moving from site to site in each region. However the costs for establishing and operating plants are not included in the estimates since this is proposed to be a public-private solution, where regulations and licensing are necessary to stimulate waste recovery initiatives and prevention of construction and demolition waste. These regulations would make the sector itself responsible and liable for achieving satisfying waste disposal solutions.

Thermal Treatment

Table 27: Cost of Thermal Treatment Facility

Key Figures Throughput/year ('00O)Tons/year 250 Annual operating period h/year 8,000 Throughput t/h 31.25

Initial investment incL Land and acquisition Million euro 81

Equivalent annual amortisation costs Mill/year 6.4

Thermal key figures Gross power output MW 22 Gross power output GWh/year 175 Gross heat output GWh/year 0

Operating and Maintenance costs Constant operating costs Thousand Euro/ year 787 Constant maintenance costs Thousand Euro /year 72 Variable operating costs Thousand Euro /year 2,399 Variable maintenance costs Thousand Euro /year 1,536 Total O&M costs Thousand euro /year 4,795

Total Investment and Operating Costs Thousand euro/ year 11,172

214. It is recommended that each of the 7 proposed regions develop thermal treatment for a capacity of 250,000 tons/annum. This comes to a total capital investment of EUR567 million. However, by 2020, it is estimated to have the

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construction of 3-4 of the 7 planned thermal treatment plants completed resulting in a total investment cost of approximately EUR300 million by 2020. Further strategic planning on this issue will be necessary. Central Composting

215. Organic waste arisings from households is assumed composted in a tunnel composting plant. The cost estimates for establishing and operating a 25,000 tones/year plant are as follows:

Table 28: Cost of Central Composting Facility

Capital Costs EUR Site selection and acquisition 380,921 Civil works costs 3,466,384 Machinery and Power 4,159,661 Renewals 20 years 476,151 Total capital costs 8,483,117 Operating costs EUR Staff (I shift, 8 persons) 255,979 Power (35kWh/ton) 38,885 Maintenance civil at 1% 28,886 Maintenance M+E at 4% 138,665 Maintenance Air at 1.5% 51,995 Miscellaneous costs 63,486 Total operating costs/year 577,889 Insurance @ 0.25% 19,223 Total operating costs per year 597,112 Total operating cost per ton 24

216. It is recommended to construct 15 such sites initially in order to meet the target as stipulated in Article 5 of the Directive by 2015. The total investments costs will therefore rise to approximately EUR127 million by 2015.

217. The introduction of intensive integrated waste management taking consideration of minimisation, recycling, recovery etc. could impact the number of proposed composting facilities. Furthermore, once a national strategy on the treatment of biodegradable waste is carried out it will become evident that certain population centres and regions will require larger or smaller facilities or will meet targets through other means. Therefore the above is an estimate, which may change once various proposed plans and strategies come to fruition. Windrow Composting

218. The cost estimates for establishing and operating a 2,000 tons/year plant are as follows:

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Table 29: Cost of Windrow Composting

Capital costs EUR Site selection and acquisition 31,743 Construction costs 190,460 Other costs 25,394 Renewals 20 years 253,947 Total investment cost 501,544

Operating cost EUR Total operating cost/annum 57,138 Total operating cost per ton 28.5

219. It is recommended that initially, one windrow treatment facility be developed in each of the 28 administrative areas resulting in a total investment cost of approximately EUR14 million by 2020. These may be considered as pilot operations as, at this stage, until a national strategy on biodegradable waste is carried out, it is not possible to quantify the exact impact that these operations may have on the communities they serve.

Home Composting

220. The investment cost for supplying a home composting bin to each household is estimated to be EUR 20/bin assuming an average bin lifetime of 10 years. It is estimated that bins will be distributed to about 500,000 households & schools over a 5-year period; this would require a total capital investment of EUR10,000,000.

Collection Costs

221. It is assumed that the collection costs per ton of household waste will be constant throughout the period. An additional 26 collections per year will be required after the implementation of the 2-bin system. However it is not possible to determine, without further planning, the impact a 2-bin system will have on collection from apartment complexes. Furthermore it is not known how many households are contained within such complexes. It is recommended that a detailed study be carried out to predict the financial impact that the introduction of a 2-bin system may have on the cost of collection and transport. Until such a study is carried out it is not possible to determine the extra costs involved. Indeed such a study should be part of any regional waste management plan. Furthermore as the exact locations of future composting facilities and the transport distances involved are not known, it is not possible to quantify the costs for additional vehicle and container requirements. For this reason only the investment costs to supply the actual bins will be included.

222. The investment cost for supplying 1 additional bin to each household is estimated to be EURlO/bin assuming an average bin lifetime of 10 years. It is estimated that there are approximately 1.5 million households within suitable urban areas i.e. greater than 1,500, therefore a combined capital outlay of EUR15 million is expected.

National Center for Hazardous Waste

223. A full feasibility study has been carried out regarding the development of a national center for hazardous waste. The 1999 National Waste Management Program

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estimates costs of such a plant, as a result of the feasibility study, to be in the region of EUR40 million.

Hospital Waste Treatment

224. A full investment analysis has been carried out for the treatment of hospital waste (refer to the National Plan for Bulgarian Hospital Waste for further details). The most viable option proposes a total outlay of EUR10.3 million.

Proposed Landfills

225. At an approximate cost of EUR12-14 million per landfill a capital investment of up to EUR 360-420 million will therefore be required every 15-20 years.

226. It is assumed that waste will be landfilled in the existing and planned landfills from 2003-2020. The cost estimates for establishing and operating a landfill with an approximate throughput of 50,000 tons per year with a total capacity of 850,000 tons are as follows:

Table 30: Landfill Costs

Capital Costs EUR Site selection & acquisition 1,250,000 Site development costs 3,174,345 l phase construction 1,269,738 4 further phases over 20 years 5,078,952 Total investment costs 10,773,035 Total investment cost Per ton 12.6

Operating costs EUR/lons Leachate treatment (1.7kw hrs/ton) 0.3 Diesel consumption (1 litre/ton) 0.5 Leachate disposal (200 litres/ton) 3.2 Gas control 1.0 Licence compliance 3.6 Labour 4.3 Plant & Machinery 3.2 Sundry materials 1.7 Daily cover 3.9 Specialist services 1.7 Total Operating Cost Per Ton 23.5

From the above, capital costs are estimated to be in the region of EUR12.6 per ton disposed of over the lifetime of the landfill. Such capital costs would decrease per ton as the size of the landfill increases.

227. Sofia with a population of about 1.2 million accounts for about 15% of the population. It is presently served by one large landfill and there are plans presently in place for large investments for capacity expansion. The next five largest cities - Plovdiv (350,000 inhabitants), Varna (300,000 inhabitants), Bourgas (200,000 inhabitants), Rousse (170,000 inhabitants) account for a further 15% of the population. None of these have at present EU compliant landfills. Each of them needs to be served by landfills, which handle between 75,000 and 150,000 tons per

65 Bulgaria:Environmental Sequencing Strategiesfor EUAccession year. The unit cost per ton of waste disposed of to such larger landfills will be significantly smaller than the unit cost of smaller landfills due to the economies of scale in landfill construction. The next fifteen towns of Bulgaria, with populations between 50,000 (Kyustendil) and 125,000 (Pleven) together account for another 1.2 million inhabitants and again another 15% of the population. For these towns a landfill with an annual 50,000 towns is relevant.

228. The above shows that around 50% of the population can be served by approximately 21 designated landfills. Future planning should show that these landfills could also serve between 20-30% of the remaining population in their hinterland through the utilization of, for example, transfer stations. Taking economies of scale into consideration, if on average, each of the 21 landfills were to be constructed at a value of £14 million, a total capital cost investment of EUR294 million would cover the landfill requirements of about 70% of the population.

229. If an indicative figure of EUR12 per ton is used in determining the capital investment for the remaining population until 2020 (with waste arisings set at 505 kg/head/annum), anywhere in the region of EUR200-250 would be necessary. It is not possible, however to determine accurately the actual requirements due to lack of planning and up-to-date data, so these figures must be regarded as estimates only. Detailed planning and analysis is necessary to elaborate further on the above and to provide more accurate estimates. From the above therefore, around EUR500 million is estimated until 2020 for landfill development. This figure would drop considerably taking into consideration recycling initiatives, composting, thermal treatment etc. all of which would significantly contribute to the diversion of waste from landfills. It is difficult to quantify the exact impact that all these future technologies will have on the overall waste stream until concrete planning is in place. Nevertheless if the diversion of the biodegradable fraction is achieved either by composting or other means 11 million tons will be diverted from landfills by 2020 with possible savings on landfill development of around EUR50 million giving an overall cost estimate of EUR450 million.

230. Restoration and aftercare will not be considered for these landfills, as the facilities are still likely to be operational. However, if restoration (not including aftercare) is to be necessary for the proposed landfills it is estimated to cost in the region of EUR2.5/ton or EUR6/m 2.

231. If the restoration of the 278 authorized landfills in operation covering 536 ha is estimated at EUR60,000/hectare, the costs involved in adequately capping and restoring all landfills would amount to a total investment of circa EUR35 million. No provision is made in that figure for aftercare. If sufficient aftercare is to be included for a period of 30 years for each of these landfills, the total costs would increase to EUR100 million.

232. It is recommended that costs for transfer stations and transshipment yards should be incorporated into estimates for landfill development. However, in this instance it is not possible to determine the requirement of either particularly when it is necessary to consider suitable location, transport costs, population served, distances etc. This again highlights the importance of regional planning.

233. It is important to note, however, that the expected costs for the landfilling of non-hazardous industrial waste have not been included. As previously mentioned in

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excess of 8 million tons of such waste is produced per annum for which private solutions have to be found through legislation and licensing. Hazardous Waste Landfills

234. Four designated landfills for hazardous waste are planned under the program for implementation contained within the National Waste Management Program 1999. An estimated cost for such landfills is approximately EURI0 million each. However, little is known about where such landfills will be located and the actual capacity therefore of these estimates may be slightly optimistic. Nevertheless, a total investment of EUR40 million has been estimated to cover the costs of the development of the four designated hazardous waste landfills.

Total Investment Requirements for Fulfilling the Landfill Waste Directive

235. The investments for waste management comprise a significant part of overall environmental investments. About 25% of the investments in the environmental sector are for waste management projects. Total costs needed to fulfill the Landfill Directive requirements are shown in the table below.

Table 31: Total Cost Estimates

ACTIVITY Total (EUR) Administration 9,760,000 Public Awareness Campaign 2,300,000 28 waste management plans 4,800,000 7 regional plans 1,800,000 National waste database 400,000 National hazardous waste management strategy 300,000 National Strategy on biodegradable waste 120,000 Development of landfill manuals 40,000

Treatment and Collection 498,800,000 Home composting 10,000,000 Construction of 15 central composting sites 120,000,000 Windrow composting/civic amenity sites 15,000,000 Introduction of 2 bm system 20,000,000 National center for hazardous waste 39,900,000 Hospital waste treatment 10,400,000 Waste to energy 283,500,000

Disposal 530,000,000 Regional landfills 450,000,000 Landfill closure and restoration of 278 existing landfi 40,000,000

Proposed 4 hazardous waste landfills 40,000,000

TOTAL: 1,038,560,000

67 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

A breakdown of annual costs needed for implementation of the Landfill Directive requirements is further illustrated in the following implementation Table 32. The most substantial investments to meet the Directive are for:

(i). Construction, extension and rehabilitation of landfills; and (ii). Waste treatment facilities and collection activities

236. Implementation deadlines to be met by the member countries are set out in the Landfill Directive. They have not yet been transposed into Bulgarian law, but should be introduced as soon as possible. Responsible authorities should consider carefully, available technical and financial resources prior to the setting of any deadlines.

237. Capital expenditure for full compliance with the Directive will have to be invested over a number of years. Bearing in mind affordability constrains and the current rate of investment, it is considered that full compliance will at best be achieved assuming a completion target at 2020. The first priority in further project implementation is given to the larger municipalities, followed by others.

238. It is assumed that the construction period of each project will be about 3 years. This will be in addition to the time required for preparation of the individual feasibility studies and to agree on funding which can take up to 2 years. Each investment stage, thus, will take approximately 5 years. The first stage of investments would target urgent rehabilitation, extension and upgrading needs, as well as closure of landfills. New landfills are prioritized on the basis of the effect they have on population and environment. Due to affordability constraints, full compliance with the Directive requirements in each municipality will be gradually reached in stages.

239. An overview of the required investments per year by component is provided in the following table:

68 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

Table 32: Breakdown of Costs for Implementation of the Strategy (EUR)

2003 2004 2005 2Ot6 200- 3008 2000 2010 2011 2012 2013 2014 2015 2016 210/ 2018 .'0Ov 2020

Administra-

Public 250,000 250,000 100,000 100,000 150,000 150,000 100,000 150,000 150.000 100,000 100,000 100,000 Awareness 100,000 100,000 100,000 100,000 100,000 100,000

Ful lepgislative

tr np sition ______28 waste 2,100,000 2,100,000 _ _ _ _ 200,000 200,000 management 200,000

plans _____ 7 regional 500,000 500,000 400,000 200,000 200,000 plans_ __ _ _ Nationa waste 100,000 100,000 100,000 50,000 50,000 database I_____ National 100,000 100,000 50,000 hazardous 50,000

Maneagment

National 40,000 40,000 20,000 Strategy on 20,000 biodegradable waste______Waste licensing and

Development 20,000 20,000 of landfill manuals _ Treatment and Collection ______Home 1,000,000 2,000,000 3,000,000 2,000,000 2,000,000

Consftuction 30,000,000 30,000,000 30,000,000 30,000,000 Of' 15 central composting sites _ _ _ Windrow 5,000.000 2,000,000 8,000,000 cornposting.- civic amenity sites _ _ _ Introduction of 5,000,000 5,000,000 5,000,000 2 bin system 5,000,000 ______National center 5,000.000 20,000,000 14,900,000 for hazardous

H al waste 2,000,000 2,500,000 treatm ent 3,000,000 2,900,000 ______6 W aste toi ______1130,000,000 1130,000,000 2'3,500,000

69 Bulgaria:Environmental Sequencing StrategiesforEUAccession

energyy ______I Disposal______18,000,000 16,000,000 14,000,000 150,000,000 150,000,000 31,500,000 6,000,000 Proposed 7,000,000 21,000,000 5,000,000 500,000 1,000,000 3,000,000 1,000,000 9,000,000 5,000,000 12,000,000 landfills 5,000,000 1,000,000 1,000,000 1,000,000 1,000,000 1,000,000 500,000 500.000 Landfil 500,000 5,500,000 7,000.000 500,000 1,000,000 2,000,000 1,000,000 3,500,000 3,000,000 5,000,000 cosure and

278 existing

Proposed 4 6,000,000 7,000,000 15,000,000 12.000,000 bazardous __. waste landfills 26,100,000 20,000,000 15,00,000 15,142,000,0 15,1100,000 162,600,000 136,600,000 29,00,000 Total Annual 780,000 29,110,000 27,920,000 18,100,000 21,550,000 77,150,000 62,000,000 44,970,000 40,350,000 17,100,000 _ _ _0 ______I__7 I Expenditure I ______I_

70 Bulgaria: Environmental Sequencing Strategiesfor EU Accession

Annual Investment and Operational Costs as % of GDP

240. The total annual investment costs in waste management projects will increase in the period 2008 - 2009 and will be the highest in the period 2015 -2020. The implementation of a comprehensive National Waste Management Strategy will extend beyond the preset compliance date 2015. When looking at the overall annual environmental costs for waste (expected waste investments costs and expected costs for operation and maintenance), the total annual investments will increase from 0.05% of GDP in 2003 to 0.43% of GDP in 2008, the bulk of the investments falls between 2015 and 2020, when the total of waste investments and operational costs increases to around 0.75% of GDP. This is presented in the following chart.

Annual Waste Expenditures as % of GDP

0.90%

0.80% _- EAnnual Operal,onal and ______Mantenarice costs 0-70% 1 °Total waste investmenLs

0.60% -:------r-! _ =

0.50% -.- - ______

o 0.40% - ______

0.30%

0.20% -----

0.00%

XoOV XoO o43 300t 4>5 XO2t 'p, f)o6 ,>0 {Tp ' '-p° 'P° 'P° 'PZ° 'P,N 'v°@" Years

Financing

241. The financing for the necessary waste investments will consist mainly out the following three components: a. Grant financing from ISPA/cohesion funds b. National/municipal co-financing c. Loans d. Revenues from tariffs for waste treatment and disposal Grant Financing ISPA/Cohesion Funds

242. Financing from the EU ISPA (Instrument for Structural Policies for Pre- Accession) fund from 2000 to 2006 and Cohesion Fund from 2006 on, are available for assisting implementation of EU requirements in the waste management sector.

71 Bulgaria: Environmental Sequencing Strategiesfor EU Accession

The planned allocation of funds from ISPA for environmental projects in Bulgaria is between EUR290 and EUR430 million (in 1999 terms) over a 7 year-period, or an average of about EUR42-62 million per annum. The assistance available from Cohesion Funds in the period 2007-2020 is estimated to be EUR3,194 million, which equals on average EUR228 million per year. In the period 2003-2015 most of EU assistance should be allocated to the Urban Waste Water Treatment Directive, because it is a priority for Bulgaria as it is at a more advanced level. However, a small part of this assistance will be spent on waste projects in this period. In the period 2015-2020 almost all of the EU assistance will be allocated to the waste management sector as the Urban Waste Water Treatment Directive requirements are expected to be met by 2015.

243. According to the roadmap for Bulgaria: "the EC proposes that assistance for Bulgaria and Romania should increase progressively to meet the level of an additional 40% in 2006. The increase will take as a baseline the average assistance under Phare/ISPA/SAPARD in the period 2001-2003." This increase will be 20% in Year 2004, 30% in Year 2005 and 40% in Year 2006. In this report it is assumed that the average assistance in the period 2001-2003 will be EUR59 Million and it is taken as a basis for an increase in ISPA funds forecast.

244. The rate of community assistance granted under ISPA can go up to 75% of the total cost of expenditure by public bodies. The Cohesion Fund finances 80-85% of the total cost. The total cost of each project shall in principle not be less than EUR5 million for ISPA granted projects and EURIO million for Cohesion Fund. The EC may also consider loans by International Financing Institutions to these governmental bodies to be equivalent to national public funds. ISPA funds may not be combined with other Pre-Accession Instruments.

245. It is expected that after completion of ISPA in 2006, Cohesion Funds will replace it from 2007 on. It will operate under similar requirements, procedures and criteria. The assistance from cohesion funds is estimated on the basis of comparison with the funds allocated to Hungary. Under the ISPA distribution scheme, Hungary and Bulgaria are the closest countries in terms of financial resources allocated to them. ISPA assistance allocated to Bulgaria is 14%-20% higher than the assistance committed to Hungary. The EU distributes financial resources among the countries on the basis of their GDP, total population and area. These indicators are relatively stable for Bulgaria and Hungary, and thus, it is assumed that Bulgaria will receive from the cohesion funds, an amount corresponding to 14% higher than the assistance received by Hungary.

246. Inforegio News in November 2002 identified that "new member states [are foreseen] to receive EUR23 billion in structural and cohesion funds between 2004 and 2006" in the financial framework for enlargement agreed in Copenhagen for the period 2004-2006.

Bilateraland other Donors

247. Bilateral and other donors have so far participated in financing the preparation of Feasibility Studies, technical assistance for institutional building and training activities, tender documents, construction supervision, co-financing of investment projects and institutional strengthening components. Based on previous priorities displayed, it would appear that such donors are potential sources for financing waste

72 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

administration costs, which total EUR 9.76 million in the period 2003-2020. The most important bilateral donors in municipal waste management projects are DEPA (Danish Environmental Protection Agency), Dutch government, German government etc.

National/Municipal Co-financing

State

248. The State budget is the main national financing source for environmental infrastructure projects. It participates as a co-financing institution to the main EU environmental assistance in the waste sector. The general trend shows an increase in funds allocated from the State budget to investments in environmental infrastructure and projects since 1998. This increase will continue, since EU assistance is increasing and local co-fmancing is required to balance the total project costs. However, this increase in State funding may well be limited due to the difficult economic climate in Bulgaria. It is assumed that the State contribution will change in the years following the EU requirements for co-financing and macroeconomic trends.

249. The State is participating in co-financing of environmental investment projects. The amount spent varies from year to year and it depends on the political priorities of the Government. As the public financial resources and external grants are not sufficient to cover total investment costs associated with the Landfill Directive, the government should ensure better market opportunities for the development of public-private partnerships and attract other potential investors in the waste sector. This includes development of appropriate legislation, adjustments of waste tariff, public involvement and consultations on investment priorities, dispute resolution mechanism for problems associated with different shareholders and owners, introduction of cost-based accounting systems, improved control and better co- ordination among different participants in decision making process.

250. The local specialized financing institution is the National Environmental Protection Fund - currently under reorganization as the State Enterprise for Environmental Protection Activities (SEEPA). It finances environmental projects at both a national and regional level, which are in compliance with national environmental strategy. It provides priority funds for construction of municipal wastewater treatment plants in population areas with over 10,000 residents and for construction of municipal landfills. The main projects co-financed by the fund in the waste sector are the municipal landfills of the following towns: Gotze Delchev, Vratza-, , village of Tsalapitsa, Madan, , , - 1St stage, - 1t stage, Aksakovo, .

251. As mentioned previously in 2003 an amount of EUR20.5 million of SEEPA's revenues will be spent mainly on capital investments in waste management systems and water treatment plants. SEEPA will decrease slightly the burden that the State budget has to bear in co-financing EU assistance. In view of the uncertainties of this source of funding in the wake of its reorganization as a State Enterprise for Environmental Protection Activities, it is difficult to forecast the likely financing from this particular source.

252. An overview of the forecasted available financing from ISPA/Cohesion funds and national co-financing is presented in the following table:

73 Bulgaria:Environmental Sequencing StrategiesforEU Accession

All figures 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 are in

_ vM L1FRO ______Total I 4.5 0 3 II 12 6 8 13 16 23 amailable financing _ ISPAICohesion o 4.5 0 2 8 8 5 6 I( 13 19 Fumds _ _ National Co- o 0 o0 3 3 I 2 3 3 5 financing_ I _ I_I_ 2011 2002 2013 2014 2015 2016 2017 2018 2019 2020 Total available 21 24 26 23 142 142 142 14-2 14 14'- fimancing ISPA/Cobesion 16 20 2I 19 113 113 113 113 113 113 Funds Nationa Co- 5 5 5 5 28 28 28 28 28 28 financing Source: Ministry of Environment

Municipal Budgets and Municipal Enterprises

253. The co-operation between the Ministry of Environmental and Water, Ministry of Regional Development and Public Works and municipalities in project implementation is improving. Municipalities are the Ministry's key partners in environmental projects and activities. Municipalities contribute to project implementation their extensive knowledge of local circumstances and needs, as well as their own financial resources and contributions.

254. The funds collected into the municipal budget are spent to cover different needs a municipality may have. The distribution of such funds is in accordance with the decision of the Board of Municipal Supervisors. Each municipality has its own policy and priorities to spend accumulated funds. It is, however, not possible to accurately ascertain or forecast likely financing from this source for the waste sector in Bulgaria.

255. The short-term investment program is limited by an assessment of the tariffs that can be afforded in each particular municipality. Tariff levels reflect to a large extent income disparities by region. By and large the average income is generally sufficient to cover costs of waste services. However present waste tariff levels in the majority of towns are too low to support the cost of compliance investments. Tariffs are not based on cost accounting principles. They cover the basic costs, but run short on generating adequate resources for new investments. In addition, the collection of tariffs in most municipalities is ineffective (collection rate is about 70% on average), leading to losses in income for the operating companies. Increase in waste tariffs will not stimulate a decrease in waste generation rate, because it is not related anyway to the waste generation. Instead, it can potentially lead to an additional decrease in the tariff collection ratio, therefore, increasing losses of the operating companies. Waste tariff price formation should be changed and based on associated cost. A sensitivity analysis should be performed in each municipality in order to ensure sufficient income to meet the costs of operating and maintaining the systems and pay off its share of the capital costs. There will however be a limit to how high the tariffs could be raised to cover economic costs. Mechanisms to protect vulnerable groups and spread burden between different income groups will have to be established.

74 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

256. Other sources of co-funding for municipalities could be matching grants from:

> National Eco-Trust Fund - it was established to serve the swap deal "debt- environment" between the Bulgarian and Swiss Governments in 1997. In the period 1997-2002 the Fund spent around EUR1 1,500,000 in the environmental sector. None of this however, was in the waste sector. The fund does not plan to finance projects in the waste sector in short to medium term. > "Ecolinks" Program - financed by the US Government > "Municipal Forum" Program - financed by the Swiss Government

257. The size, however, of the above funds is insignificant. The funds are distributed among municipalities after completing a rigorous application procedure. It is difficult to accurately ascertain and forecast the actual amount and sources of municipal funding due to the uncertainties associated with the sources and the insignificant contribution that such sources presently make to the environmental sector.

Loans

258. The total amount of investments for the waste sector development can be increased by loan finance. There is a possibility to combine loan components from more than one source. However, considering the fiscal policy of the countly and its target to reduce Debt/GDP ratio, as well as affordability aspects, loans are not a very attractive source of finance in the short run. For the investments necessary in the period after 2015, however, loan financing might be more attractive.

259. Local financing institutions that may lend money for the waste development projects are commercial banks. However, waste management and recycling projects do not meet their financing criteria in the short to medium term. Private Sources

260. Private sources of financing could be attracted for recycling, recovery and collection activities. At the later stage different forms of public - private partnership could be used, including concession of waste collection and/or treatment activities, particularly thermal treatment, regional landfills and material recovery facilities. Currently there are waste activities managed by concessionaires in bigger towns in Bulgaria. Although there are notional indications of private interests, their financial contribution is not clearly identified.

261. Public Private Partnership (PPP) should be considered as an opportunity to reduce State budget contributions provided it can demonstrate "transparency, equal treatment and competition" according to Commission Interpretative Communication on Concessions under Community Law (OJ C 121, 29.4.2000). Shareholding issues, ownership of assets must first be resolved in order to attract potential private investment.

75 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Revenues from Tariffs for Waste Treatment and Disposal

262. Affordability is a key issue in determining an appropriate program for implementation. Its extent is limited by an assessment of the tariffs that can be afforded in each municipality. There is an administrative limit on how high the tariffs can be raised. The payment for waste management services shall not exceed 1% of the average household income. Presently this sets the upper limit for the tariff for a household at a level of around EUR1.7 per month. Waste tariffs in Bulgaria, however, are calculated on the basis of taxation evaluation of the property. Based on current designs and investigations it is estimated that waste tariff per ton of waste is between EUR15 and 17 per ton. Considering that the generation rate is 0.505 tons per capita per year it means that a household generates 1,2 tons/annum or 100 kg/month, which equals to EUR1.5 - 1.7 /month per household. This tariff is still lower than the maximum 1% and should be economically affordable. However the current waste tariffs do not cover all associated operating and maintenance costs. Waste tariffs should gradually increase to cover not dnly O&M costs but also at least part of the capital investments in infrastructure and the cost of borrowing, where appropriate. A full affordability analysis has not been executed due to the long-term horizon of the planned investments. The weight of most of the investments is felt within the time- horizon 2015-2020, which makes household income projections fairly unreliable. Furthermore, the investment program contains many degrees of uncertainties and different options, which would change the affordability considerably.

Conclusions and Critical Actions

263. Planning for the future must reflect a new approach to environmental management, involving constructive co-operation with local communities and neighboring municipalities, and utilizing the potential of the private sector to contribute to the delivery of public services. Planning must also be undertaken with a full appreciation of legislative and technological developments, which will have a critical bearing on the outcome. The implications of these new developments must be identified and quantified so that they can be factored into municipal/regional planning.

264. Institutionalchallenges are not minor. Only 20% of landfills surveyed retain records. Many uncertainties exist with regard to the precise quantities of waste as well as the exact composition of the waste streams. 265. A National Waste Strategy is required. A national strategy for all the different waste streams would provide insight into the quantities, composition and technological and financial scenarios in order to fulfil the Waste Directive. The waste strategy should be prepared for all different government levels: local, regional as well as national and contain a much more detailed investment forecast, taking into account regional differences, population densities and trends, transportation and logistic characteristics. The national waste strategy should put special emphasis on the regional planning of the landfills, since many of the present proposed landfills do not have the sufficient population base for a financially viable regional operation.

266. A Public Awareness Campaign is necessary to prepare the public to accept new waste management practices. Without the public's positive attitude, a successful implementation program to comply with the Directive would be difficult to achieve, specifically since households will be partly responsible for the implementation of the Directive. The timing of the public awareness campaign should be streamlined with

76 Bulgaria:Environmental Sequencing Strategiesfor EU Accession providing the technological options for citizens to reduce their waste, in order for the public not to be discouraged by lack of recycling/composting facilities.

77 Bulgaria: Environmental Sequencing StrategiesforEUAccession

ANNEXES

ANNEX I

Technical Requirements of CouncilDirective 1991/271/EEC on DischargefromUrban Wastewater TreatmentPlants and Areas Subject to Eutrophication Methodologyfor Calculatingthe Costs of Wastewater Treatment

Parameters Concentration Minimum Percentage of Reference Method of Reduction' Measurement

BOD5 at 200 25 mg/i 02 70 - 90 Homogenized, unfiltered, un- C without decanted sample. nitrificafion2 Determination of dissolved oxygen before and after 5-day incubation at 20° i1° in complete darkness. Addition of nitrification inhibitor.

COD 125 mg/i 02 75 Homogenized, unfiltered, undecanted sample Potassium dicbromate.

Total 35 mg/i 3 903 Filtering of a representative sample suspended ugh a 0,45 m filter membrane. solids (SS) ing at 10° C and weighing.

- Centrifuging of a representative sample (for at least five min. with mean acceleration of 2 800 to 3 200 g), drying at 1050 C and weighing. Reduction in relation to the load of the influent.

2 The parametercan be replaced by anotherparameter: TOC or TOD if a relationshipcan be estimated between BOD5 and the substituteparameter.

3 This requirement is optional.

78 Bulgaria:Environmental Sequencing StrategiesforEUAccession

Requirementsfor Dischargesfrom Urban Waste Water Treatment Plants to Sensitive Areas, which are Subject to Eutrophication

Parameters Concentration Minimum Percentage Reference Method of of Reduction33 Measurement

Total 2 mg/l P 80 Molecular absorption phosphorus (10 000 - 100 000 p.e.) spectrophotometry

1 mg/i P (more than 100 000 p.e.)

Total 15 mg/l N 70-80 Molecular absorption nitrogen34 (10 000 - 100 000 p.e.) spectrophotometry 10 mg/ N (more than 100 000

CostingMethodology Used in the Study

The methodology used to calculate the costs is based on the relationship between the capital expenditure to operational costs (CAPEX/OPEX) and the population equivalents using the figures produced in twelve recent feasibility studies made available. The range of these studies was from 10,000 to 250,000 PE and Extended Aeration Technology was the preferred option for treatment. Since there were no figures for CAPEX and OPEX below 10,000 p.e., it was decided to use the values at the low PE end from the EU treatment model reported in "Provision of Technical Assistance in the Approximation of Water Legislation for Bulgaria - BUL 110" prepared by HALCROW in 1999. Thus the data in the table below was used to derive CAPEX and OPEX for wastewater treatment cost estimates for a the following WWTP:

No WWFP Populadon CAPEX OPEX Equivalenl Capital Expenditures Operatonal Eapenditur (M ElIR) (M EURam) 1 EU model 2,000 0.810 0.056 2 EU model 5,000 1,300 0.060 3 Madan 9,750 2.724 0.064 4 Rudozem 9,767 2.790 0.064 5 13,740 3.930 0.204 6 28,735 6.204 0.241 7 Asparuhovo 51,667 9.840 0.700 8 Meden Rudnik 58,000 9.024 0.734

33 Reduction m relation to the load of the influent 34 Total N means: the sum of total Kjeldahl-mtrogen (organic N + NH3), nitrate (N03)-nitrogen and nitrite (NO2)-nitrogen; 35 Alternatively, the daily average must not exceed 20 mg/l N. This requirement refers to a water temperature of 12 C or more durng the operation of the biological reactor of the wastewater treatment plant. As a substitute for the condition concernmg the temperature, it is possible to apply a limited time of operation, which takes into account the regional climatic conditions.

79 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

OPEX No %%WTP Populadon CAPEX Equivalent Capital Expendirures Operational Expenditures (Ni E1R) (M ElIJR/a) 0.314 9 Dimitrovgrad 70,350 8.098 0.986 10 Targovishte 106,000 13.366 0.607 11 Haskovo 109,600 14.941 12 Blagoevgrad 150,000 14.295 0.879 1.045 13 Pazardjik 216,660 15.850 1.045 14 Stara Zagora 256,300 22.930

Based on the different points that were plotted graphically, the relationships between PE and CAPEX/OPEX are represented by the following equations.

22.559 2.6 OPEX= PE-O34250X6 - 5-9725 CAPEX PE+2.99.10' PE. 345716 1+ e 118370.4 1+ e -77166.52

Vhereby: CAPEX= Capital Expenditures OPEX= Operational Expenditures PE= Population Equivalent

80 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

ANNEX HI

InstitutionalResponsibilitiesfor Implementation of Investment Strategies Policy Development and InstitutionalImplementation

tnstitution Responsibilit)

Municipalities . Provide inhabitants with the public services - centralized water supply and collection and treatment of wastewater;

Ministry of Regional . Conducts the national policy for the implementation of the Strategy for Development and Public integrated water management in Bulgaria, coordinates and prepares Works program for water supply, sewerage and water treatment; . Provides spatial coordination for rational and efficient use of water resources; coordinates and controls the establishment of sanitary- protective zones around water sources; . Prepares draft acts in the field of water supply, sewerage, and water treatment;

. Develops and coordinates the implementation of investment program for rehabilitation and construction of water supply, sewerage and water treatment projects;

* Coordinates the activities of the companies operating in the field of water supply, sewerage, water treatment and engineering services; develops strategies for restructuring and decentralization of the water utilities;

. Coordinates the implementation of bilateral and multilateral contracts and agreements includmg the Agreement with the World bank for restructuring and modernization of the Water companies; a Coordinates and prepares proposals for rehabilitation and development of water supply systems, financed under the PHARE Program - Economic and social cohesion;

Ministry of Environment and . Develops strategies and programs for rational management and use of Water waters;

a Manages the National Environmental Protection Fund, National system for environmental monitoring, National water monitoring system and National geo-fund; * Responsible for usage and protection of waters. * Coordination and participation in development of national strategies and programs in the field of environment: . Preparation of regulatory acts in the field of water use, protection and management.

Executive Environment . Administers the environmental monitoring network Agency (EEA) . Carries out environmental analyses and assessments

. Creates and maintains environmental data base

81 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Institution Responsibility * Prepares periodical and annual bulletins for the state of environment * Prepares draft integrated permits

on the need for Regional Inspectorates on * Carries out project screening and makes decisions Environment and Water Environmental Impact Assessment (RIEW) objects with public state River Basin Directorates . Set the boundaries of the waters and water (RBD) ownership; . Organize the preparation of river basin management plans; * Issue water use and wastewater discharge permits and collects the fees; . Monitor water quality at river basin level; . Organize water and water economic cadastre and develop a register of the issued permits; * Supervise the status of the water systems and facilities . Issue and circulate periodical bulletin for the status of the water resources within the scope of the river basin; . Report to the Minister of environment. Preparation of Monthly and annual reports.

to the municipalities; Water utilities . Provision of water supply and sewerage services . Ensures compliance with wastewater effluent and other standards; . Register effluent quality and quantity data for submission to NSI; * Pay water use fee.

Responsibilities for Investment Planning and Financing

Institution Responsibilites budget, short-term and Ministry of Finance a Conducts state policy in the field of long-term finance, taxes and customs; • Negotiates, coordinates and controls external finance and state guaranteed credits * Participates in preparation of the country for accession to the EU * Manages the EU grants together with Bulgarian financial resources from the state budget and other sources for co- financing from different memorandums. * Controls procedures for reporting of the executive agencies, and collects reports on financial condition of the program, tenders, schedules and terms of the approved agreements.

82 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

Institution Responsibilities

* Participates in development of the legislation associated with EU grants

* Drafts laws and regulations within the auspices of the Ministry of Finance * Financial management of ISPA funds.

National Fund (within the * Financial management of EU grants and subsidies from the Ministry of Finance) National budget.

* Ensures and controls observance of the Executive agencies reporting procedures.

* Collects the reports on a program's financial status, the forthcoming tender schedules, the tender evaluations and the approved contracts. Prepares information and monthly inquiries on the projects financial status; * Prepares agreements for EU grants.

ISPA Implementing Agency * Responsible for ISPA projects technical implementation, tender (within Ministry of procedures, negotiations and payments. Environment) . Preparation of ISPA applications

National ISPA Co-ordinator * Responsible for ISPA; (Minister of Finance) * Submission of ISPA applications to the European Cormnission; * Supervision of implementation of ISPA projects in accordance with Financing Memorandum; * Ensures a link with EU accession process; * Co-ordination of ISPA projects with other finance instruments of EU.

Ministry of Environment and . Prepares investment programmes for construction of Directive; Water * Attracts funding from donor countries, international organisations, financial institutions and organises projects funded by EU pre-accession funds; * Prepares the national ISPA strategy in the field of environment; * Prepares projects in the field of wastewater treatment.

Municipalities * Provide loan guarantees;

* Co-financing of projects.

Water utilities * Participate in implementation of projects; * Co-financing of projects.

83 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

ANNEx m Wastewater Treatment Plants Full Cost Implementation Settlements of 2,000 - 0,000 p.e.

Riverbasin Catchment Area Sensidive Resident Capital Operational Population PE cost costs M[Euro JVM Settlement Name Name (River Valley) zone MELro

0.100 1 (t) Black Sea Aitoska No 5,138 6,166 1.746 2 Chemo more (v) Black Sea Atanasovsko Lake Yes 2,353 2,824 1.372 0.072 3IRudnik (v) Black Sea Atanasovsko lake No 3,489 4,187 1.420 0.078 4 (v) Black Sea Black Sea Yes 2,269 2,723 1.353 0.071 5 Aksakovo (v) Black Sea Black Sea No 7,269 8,723 2.160 0.128 6 (t) Black Sea Black Sea No 2,122 2,546 1.147 0.060 7 Chaika-Varna (qt) Black Sea Black Sea No 5,000 0.059 8 (v) Black Sea Black Sea No 2,044 2,453 1.131 9 (t) Black Sea Black Sea No 5,394 8,168 10 Drujba 2 (r) Black Sea Black Sea No 5,000 11 Duni (r) Black Sea Black Sea No 5,000 _ 12 Elenite (r) Black Sea Black Sea No 5,000 13 (v) Black Sea Black Sea No 3,963 4,756 1.514 0.085 14 Konstantin& (r) Black Sea Black Sea No 5,000 _ 0.072 15 (v) Black Sea Black sea Yes 971 2,800 1.368 16 Lozenets (v) Black Sea Black sea No 467 5,000 17 (v) Black Sea Black Sea No 2,395 2,874 1.202 0.064 18 Rusalka (r) Black Sea Black Sea No 5,000 1.555 19 (t) Black Sea Black Sea Yes 4,008 6,003 20 (r) Black Sea Black Sea No 264 4,000 1.389 0.076 21 Topoli(v) Black Sea Black Sea No 3,044 3,653 1.332 0.072 22 Varvara (v) Black Sea Black Sea No 4,000 1.389 0.076 23 Todor Ikonomovo (v) Black Sea Dobrudza pl. No 2,094 2,513 1.141 0.060 24 Kableshkovo (t) Black Sea Dry guley No 2,817 3,380 1.286 0.069 25 Vetren Black Sea Dry guley No 2,297 2,756 1.182 0.062 26 Gradets (v) Black Sea Kamtchiya No 3,932 4,718 1.508 0.084 27 Grozdiovo (v) Black Sea Kamtchiya No 2,465 2,958 1.216 0.065 28 Kotel (t) Black Sea Kamtchiya No 6,934 8,321 2.096 0.124 29 (t) Black Sea Kamtchiya No 2,758 4,154 30 Ruen (v) Black Sea Kamtchiya No 2,049 2,459 1.132 0.059 31 Smiadovo (t) Black Sea Kamtchiya No 4,430 6,740 32 Staro Oriahovo (v) Black Sea Kamtchiya No 2,710 3,252 1.265 0.068 33 Tsonevo (v) Black Sea Kamtchiya No 2,457 2,948 1.214 0.064 34 (t) Black Sea Kamtchiya No 3,668 4,402 1.456 0.081 35 Yablanovo (v) Black Sea Kamtchiya No 2,893 3,472 1.301 0.070 36 t Black Sea Provadiiska No 4,774 5,729 1.675 0.095 37 (t) Black Sea Provadiyska & No 3,689 4,427 1.460 0.081 Devnenska 38 Yasenkovo (v) Black Sea Sazlaka No 2,075 2,490 1.137 0.059 39 (t) Black Sea Stara No 3,692 5,574 0.320 40 Malko Tamovo (t) Black Sea No 2,946 3,535 1.312 0.071 41 (v) Danube Archar No 2,624 3,149 1.248 0.067 42 (t) Danube Bregovitsa No 3,111 3,733 1.345 0.073

84 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

Rherbasin Caichment Area Sensitive N2 Settlement Resident Capital Operational Name Name (River Valley) zone Population PE cost costs MEuro MEuro

43 Kula (t) Danube Chichilska No 4,018 4,822 1.525 0.085 44 (t) Danube Danube No 2,122 2,546 1.147 0.060 45 Belovets (v) Danube Danube No 2,178 2,614 1.158 0.061 46 -h-I (r) Danube Danube No 4,000 47 Brest v Danube Danube No 2,830 3,396 1.289 0.069 48 Brestovene (v) Danube Danube No 3,026 3,631 1.328 0.072 49 Diankovo (v) Danube Danube No 3,040 3,648 1.331 0.072 50 Glodjevo (v) Danube Danube No 3,953 4,744 1.512 0.085 51 Kalipetrovo (v) Danube Danube No 5,361 6,433 1.790 0.103 52 Marten (v) Danube Danube No 4,273 5,128 1.576 0.089 53 Nikolovo (v) Danube Danube No 3,352 4,022 1.393 0.077 54 Nikopol (t) Danube Danube No 4,512 5,414 1.623 0.092 55 Nova cherna (v) Danube Danube No 2,038 2,446 1.130 0.059 56 Oresh (v) Danube Danube No 2,147 2,576 1.152 0.060 57 Oriahovo (t) Danube Danube No 6,107 7,328 1.935 0.113 58 Ostrov (v) Danube Danube No 2,042 2,450 1.131 0.059 59 Ostrovo (v) Danube Danube No 2,413 2,896 1.205 0.064 60 Ovcha mogila (v) Danube Danube No 2,123 2,548 1.147 0.060 61 Pirgovo (v) Danube Danube No 2,185 2,622 1.159 0.061 62 Riahovo (v) Danube Danube No 2,079 2,495 1.138 0.059 63 Selanovtsi (v) Danube Danube No 4,623 5,548 1.645 0.093 Slivo 64 pole (v) Danube Danube No 3,359 4,031 1.394 0.077 65 Smimenski (v) Danube Danube No 2,863 3,436 1.295 0.070 66 Srebarna (v) Danube Danube No 854 1,025 0.890 0.042 67 Tetovo (v) Danube Danube No 2,533 3,040 1.229 0.065 68 (t Danube Danube No 3,588 4,306 1.440 0.080 69 Dragoman (t) Danube Dragomansko blato No 3,755 4,506 1.473 0.082 70Aidemir (y) Danube Dry gulley No 7,683 9,220 2.240 0.133 71 Borovo (t) Danube Dry guRey No 2,620 3,144 1.247 0.067 72 Chernolik (v) Danube Dryguley No 2,371 2,845 1.197 0.063 73 Dve mog i(t) Danube Dry gulley No 4,714 5,657 1.663 0.095 74 (t) Danube Drygulley No 2,065 2,478 1.135 0.059 75 (t) Danube Gradska No 5,816 6,979 1.879 0.109 76IGramada (v) Danube Gramadanska No 2,111 2,533 1.145 0.060 77 Bistritsa (v) Danube No 3,729 4,475 1.468 0.082 78 Bojurishte (t) Danube Iskar No 5,182 6,218 1.755 0.101 79 Brenitsa (v) Danube Iskar No 2,383 2,860 1.199 0.063 80 Buhovo (t Danube Iskar No 2,928 3,514 1.308 0.071 81 Chepintsi (v) Danube Iskar No 2,440 2,928 1.211 0.064 82 Dolni (v) Danube Iskar No 2,367 2,840 1.196 0.063 83 Eln - station Danube Iskar No 3,915 6,000 _ - 84 (t) Danube Iskar No 6,690 8,028 2.048 0.121 85 German (v) Danube Iskar No 2,307 2,768 1.184 0.062 86 Gigen (v) Danube Iskar No 2,834 3,401 1.290 0.070 87 Iskar (t) Danube Iskar No 4,107 4,928 1.543 0.087 88 Iskrets (v) Danube Iskar No 2,396 2,875 1.202 0.064 89 Kazichene (v) Danube Iskar No 4,487 5,384 1.618 0.092 90 Koiare (t) Danube Iskar No 5,103 6,124 1.739 0.100 91 Litakovo (v) Danube Iskar No 2,010 2,412 1.124 0.058

85 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

_ ~~~~~~~~~~~~~~~~~~~~~~CapitalOperational Riverbasin Catchment Area Sensitive ResidentCailOprtol N2 Settlement Name RivName (River Valley) zone Populaidonnos PE costs MEuro

92 Lozen (v) Danube Iskar No 5,751 6,901 1.866 0.108 93 Novi Han (v) Danube Iskar No 2,410 2,892 1.205 0.064 94 Petarch (v) Danube Iskar No 2,263 2,716 1.175 0.062 95 (t) Danube Iskar Yes 4,730 7,160 96 Roman (t) Danube Iskar No 3,553 4,264 1.433 0.079 97 (t) Danube Iskar No 7,965 9,558 2.294 0.137 98 Stavertsi (v) Danube Iskar No 2,269 2,723 1.176 0.062 99 Svetovrachene (v) Danube Iskar No 2,266 2,719 1.176 0.062 100 Trudovets (v) Danube Iskar No 3,494 4,193 1.421 0.078 101 Vakarel (v Danube Iskar No 2,291 2,749 1.181 0.062 102 (t) Danube Iskar No 5,000 6,000 1.719 0.098 103 Vladaia (v) Danube Iskar No 3,595 4,314 1.441 0.080 104 Voluiak (v) Danube Iskar No 2,689 3,227 1.261 0.068 105 Vrachesh (v) Danube Iskar No 3,812 4,574 1.485 0.083 106 Zverino (v) Danube Iskar No 2,087 2,504 1.140 0.059 107 Dolna bania (t) Danube No 4,787 5,744 1.677 0.096 108 (t) Danube Maritsa Yes 2,669 3,203 1.445 0.077 109 (t) Danube Nishava No 5,020 6,024 1.723 0.099 1 10 Boichinovtsi (t) Danube No 2,070 2,484 1.136 0.059 111 Borovan (v) Danube Ogosta No 2,761 3,313 1.275 0.069 112 Butan (v) Danube Ogosta No 3,343 4,012 1.391 0.076 113 (t) Danube Ogosta No 2,370 2,844 1.197 0.063 114 Galiche (v) Danube Ogosta No 2,406 2,887 1.204 0.064 1u1 Glojene (v) Danube Ogosta No 3,150 3,780 1.353 0.074 116 Hairedin (v) Danube Ogosta No 2,125 2,550 1.147 0.060 1 17 Harlets (v) Danube Ogosta No 2,428 2,914 1.208 0.064 118 Krivodol (t) Danube Ogosta No 3,832 4,598 1.488 0.083 119 Krushovitsa (v) Danube Ogosta No 2,193 2,632 1.161 0.061 120 Lehchevo (v) Danube Ogosta No 2,370 2,844 1.197 0.063 121 Malorad (v) Danube Ogosta No 2,380 2,856 1.199 0.063 122 (t) Danube Ogosta No 4,069 4,883 1.535 0.086 123 Popitsa (v) Danube Ogosta No 2,142 2,570 1.151 0.060 124 Tarnava (v) Danube Ogosta No 2,875 3,450 1.298 0.070 125 Aleksandrovo (v) Danube Osum No 2298 2,758 1.182 0.062 126 (t) Danube Osum No 3,918 4,702 1.506 0.084 127 Obnova (v) Danube Osum No 2,611 3,133 1.245 0.067 128 Oreshak (v) Danube Osum No 2,384 2,861 1.199 0.063 129 (t) Danube Osum No 2,390 2,868 1.201 0.064 130 Slavianovo (t) Danube Osum No 4,829 5,795 1.685 0.096 131 Borovets-yaitseto (r) Danube Danube No 6,000 1.719 0.098 132 Ezerche (v) Danube Rusenski lom No 2,213 2,656 1.165 133 Getsovo (v) Danube Rusenski lom No 2,038 2,446 1.130 0.059 134 (t) Danube Rusenski lom No 3,181 3,817 1.359 0.074 135 (v) Danube Rusenski lom No 2,565 3,078 1.236 0.066 136 Shltraldevo (v) Danube Rusenski lom No 2,801 3,361 1.283 0.069 137 Strajets (v) Danube Rusenski lom No 2,012 2,414 1.125 0.058 138 Tsar Kaloian (t) Danube Rusenski lom No 4,205 5,046 1.562 0.088 139 Yasenovets (v) Danube Rusenski lom No 2,511 3,013 1.225 0.065 140 Medkovets (v) Danube Tsibritsa No J 2,464 2,957 1.215 0.065

86 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Riverbasin Catebment Area Sensitive Resident Nb Settlement Capital Operational Name Name (River Valley) zone Population PE cost costs MEuro MEuro 141 (t) Danube Tsibritsa No 4,800 5,760 1.680 0.096 142 Yakimovo (v) Danube Tsibritsa No 2,390 2,868 1.201 0.064 143 Bukovlak (v) Danube No 3,308 3,970 1.384 0.076 144 (v) Danube Vit No 2,625 3,150 1.248 0.067 145 Dolna Mitropolia (t) Danube Vit No 3,603 4,324 1.443 0.080 146 (t) Danube Vit No 5,229 6,275 1.764 0.101 147 Galata (v) Danube Vit No 2,436 2,923 1.210 0.064 148 Goma Mitropolia (v) Danube Vit No 2,156 2,587 1.154 0.060 149 Gomi Dabnik (v) Danube Vit No 2,004 2,405 1.123 0.058 150 Guliantsi (t) Danube Vit No 3,827 4,592 1.487 0.083 151 Krushovitsa (v) Danube Vit No 2,220 2,664 1.166 0.061 152 Milkovitsa (v) Danube Vit No 2,334 2,801 1.189 0.063 153 Sadovets (v) Danube Vit No 2,823 3,388 1.287 0.069 154 (t) Danube Vit No 5,085 6,102 1.736 0.100 155 (t) Danube Vit No 3,161 3,793 1.355 0.074 156 (t) Danube Vit No 3,098 3,718 1.342 0.073 157 Yasen (v) Danube Vit No 2,674 3,209 1.258 0.067 158 (v) Danube Voinishka No 3,141 3,769 1.351 0.074 159 (t) Danube No 3,688 4,426 1.460 0.081 160 Biala Cherkva (t) Danube Yantra No 2,869 3,443 1.297 0.070 161 (t) Danube Yantra No 4,413 5,296 1.603 0.091 162 Djuliunitsa (v) Danube Yantra No 2,371 2,845 1.197 0.063 163 Draganovo (v) Danube Yantra No 2,958 3,550 1.314 0.071 164 Elena (t) Danube Yantra No 6,449 7,739 2.002 0.117 165 (t) Danube Yantra No 2,556 3,067 1.234 0.066 166 Parvomaitsi (v) Danube Yantra No 3,256 3,907 1.374 0.075 167 (t) Danube Yantra No 2,278 2,734 1.178 0.062 168 Polikraishte (v) Danube Yantra No 2,375 2,850 1.198 0.063 169 (t) Danube Yantra No 5,199 6,239. 1.758 0.101 170 Resen (v) Danube Yantra No 2,475 2,970 1.218 0.065 171 (v) Danube Yantra No 2,014 2,417 1.125 0.058 172 (t) Danube Yantra No 2,515 3,018 1.226 0.065 173 Tsenovo (v) Danube Yantra No 2,046 2,455 1.131 0.059 174 (t) Danube Yantra No 2,671 3,205 1.257 0.067 175 (t) East Aegean No 3,720 4,464 1.466 0.081 176 Chepintsi (v) East Aegean Arda No 2,143 2,572 1.151 0.060 177 Chorbadjiisko (v) East Aegean Arda Yes 2,014 2,417 1.294 0.067 178 Djebel (t) East Aegean Arda No 2,839 3,407 1.291 179 Ivailovgrad 0.070 (t) East Aegean Arda No 4,420 5,304 1.605 0.091 180 (t) East Aegean Arda No 5,239 6,287 1.766 0.102 181 Madan (t) East Aegean Arda Yes 6,575 9,750 2.673 0.160 182 (t) East Aegean Arda Yes 7,948 9,538 2.634 0.157 183 (t) East Aegean Arda No 5,143 6,172 1.747 0.100 184 Rudozem (t) East Aegean Arda No 4,255 9,767 2.327 0.139 185 Startsevo (v) East Aegean Arda Yes 2,749 3,299 1.464 0.079 186 Aleko Konstantinovo East Aegean Maritsa No 2,913 3,496 1.305 0.071 _ (v) 187 Bania (v) East Aegean Maritsa No 3,904 4,685 1.503 0.084 188 Batak (t) East Aegean Maritsa No 4,143 4,972 1.550 0.087

87 Bulgaria:Environmental Sequencing StrategiesforEUAccession

Riverbasin Catchment Area Sensitive Resident capital Operational zone Population PE cost costs MEuro .Nb, SeftJement Name Name (River Valley) MELUo

1.636 0.093 189 Belovo (t) East Aegean Maritsa No 4,578 5,494 190 Belozen (v) East Aegean Maritsa No 4,364 5,237 1.594 0.090 0.069 191 Boliartsi (v) East Aegean Maritsa No 2,766 3,319 1.276 1.272 0.068 192 (v) East Aegean Maritsa No 2,745 3,294 193 Branipole (v) East Aegean Maritsa No 2,625 3,150 1.248 0.067 0.061 194 Bratanitsa (v) East Aegean Maritsa No 2,204 2,645 1.163 195 (t) East Aegean Maritsa No 4,815 5,778 1.683 0.096 1.510 0.084 196 Brestovitsa (v) East Aegean Maritsa No 3,939 4,727 1.137 0.059 197 (t) East Aegean Maritsa No 2,075 2,490 0.068 198 Chalakovi (v) East Aegean Maritsa Yes 2,063 2,476 1.305 0.107 199 (t) East Aegean Maritsa No 5,670 6,804 1.850 0.064 200 Chemogorovo (v) East Aegean Maritsa No 2,429 2,915 1.208 1.341 0.070 201 Cheshnegirovo (v) East Aegean Maritsa Yes 2,219 2,663 1.172 0.062 202 Dalgo pole (v) East Aegean Maritsa No 2,250 2,700 2.214 0.132 203 Devin (t) East Aegean Maritsa No 7,548 9,058 1.332 0.072 204 (v) East Aegean Maritsa No 3,044 3,653 1.900 0.108 205 Draginovo (v) East Aegean Maritsa Yes 4,658 5,590 1.247 0.067 206 Glavinitsa (v) East Aegean _ Maritsa No 2,619 3,143 1.482 0.080 207 Gradina (v) East Aegean Maritsa Yes 2,829 3,395 1.142 0.060 208 (v) East Aegean Maritsa No 2,097 2,516 1.329 0.072 209 loakim Gruevo (v) East Aegean Maritsa No 3,032 3,638 1.369 0.075 2 10 Ivailo (v) East Aegean Maritsa No 3,229 3,875 1.223 0.065 211 (v) East Aegean Maritsa No 2,499 2,999 1.218 0.065 212 Kaloianovo (v) East Aegean Maritsa No 2,479 2,975 1.444 0.077 213 Katunitsa (v) East Aegean Maritsa Yes 2,666 3,199 1.130 0.059 214 Korten (v) East Aegean Maritsa No 2,041 2,449 1.591 0.090 215 (v) East Aegean Maritsa No 4,351 5,221 1.580 0.089 216 (v) East Aegean Maritsa No 4,296 5,155 1.209 0.064 217 Kovachevo (v) East Aegean Maritsa No 2,434 2,921 1.621 0.089 218 Krumovo (v) East Aegean Maritsa Yes 3,436 4,123 1.893 0.110 219 (v) East Aegean Maritsa No 5,891 7,069 1.298 0.070 220 Kurtovo Konare (v) East Aegean Maritsa No 2,874 3,449 1.297 0.070 221 Luki (t) East Aegean Maritsa No 2,871 3,445 1.712 0.098 222 Malo konare (v) East Aegean Maritsa No 4,963 5,956 1.342 0.073 223 Manole (v) East Aegean Maritsa No 3,097 3,716 2,700 1.172 0.062 224 Markovo (v) East Aegean Maritsa No 2,250 1.161 0.061 225 Merichieri (t) East Aegean Maritsa No 2,193 2,632 1.142 0.060 226 Mokrishte (v) East Aegean Maritsa No 2,097 2,516 1.154 0.060 227 Nova Mahala (v) East Aegean Maritsa No 2,159 2,591 1.228 0.065 228 Novo selo (v) East Aegean Maritsa No 2,528 3,034 1.155 0.060 229 Obruchishte (v) East Aegean Maritsa No 2,163 2,596 1.255 0.067 230 Ognianovo (v) East Aegean Maritsa No 2,661 3,193 231 (r) East Aegean Maritsa NO 7,000 X _ _ 1.477 0.082 232 Parvenets (v) East Aegean Maritsa No 3,772 4,526 1.795 0.104 233 (t) East Aegean Maritsa No 5,387 6,464 1.216 0.065 234 Popintsi (v) East Aegean Maritsa No 2,467 2,960 1.335 0.073 235 Rogosh (v) I East Aegean Maritsa No 3,063 3,676 1.506 0.084 236 Rozino (v) East Aegean Maritsa No 3,919 4,703 1.432 0.077 237 (t) East Aegean Maritsa Yes 2,612 3,134

88 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

Riverbasin Catchment Area Sensitive Resident Capital Operational .N2 Settlement Name River ValAey zone Ppaion PE cost costs MEuro Name (River Valley) zone Population 'EUTo

238 Saedinenie (t) East Aegean Maritsa No 6,407 7,688 1.994 0.117 239 Semchinovo (v) East Aegean Maritsa Yes 2,077 2,492 1.308 0.068 240 Siineonovgrad (t) East Aegean Maritsa Yes 7,790 9,348 2.599 0.155 241 Sinitovo (v) East Aegean Maritsa No 2,258 2,710 1.174 0.062 242 Skutare (v) East Aegean Maritsa No 2,222 2,666 1.167 0.061 243 (t) East Aegean Maritsa No 4,785 5,742 1.677 0.096 244 Striama (v) East Aegean Maritsa No 3,373 4,048 1.397 0.077 245 Topolovo (v) East Aegean Maritsa No 2,989 3,587 1.321 0.072 246 Trud (v) East Aegean Maritsa No 4,038 4,846 1.529 0.086 247 Tsalapitsa (v) East Aegean Maritsa No 4,841 5,809 1.688 0.096 248 (v) East Aegean Maritsa No 2,263 2,716 1.175 0.062 249 Ustina (v) East Aegean Maritsa No 2,344 2,813 1.191 0.063 250 Varvara (v) East Aegean Maritsa Yes 2,440 2,928 1.392 0.074 251 Vetren (v) East Aegean Maritsa No 3,888 4,666 1.500 0.084 252 Yagodovo (v) East Aegean Maritsa Yes 3,299 3,959 1.590 0.087 253 (t) East Aegean Maritsa No 5,789 6,947 1.873 0.109 254 Zvanichevo (v) East Aegean Maritsa No 2,260 2,712 1.174 0.062 255 Samitsa (v) East Aegean Mesta No 3,650 4,380 1.452 0.081 256 Buzovgrad (v) East Aegean Yes 2,513 3,016 1.409 0.075 257 Enina (v) East Aegean Tundzha Yes 2,679 3,215 1.447 0.078 258 (t) East Aegean Tundzha No 3,029 3,635 1.329 0.072 259 Jeliu voivoda (v) East Aegean Tundzha No 2,695 3,234 1.262 0.068 260 (t) East Aegean Tundzha No 3,757 4,508 1.474 0.082 261 (t) East Aegean Tundzha No 2,207 2,648 1.164 0.061 262 Koprinka (v) East Aegean Tundzha No 2,847 3,416 1.292 0.070 263 Kran (v) East Aegean Tundzha No 3,636 4,363 1.450 0.080 264 Krushare (v) East Aegean Tundzha No 2,146 2,575 1.152 0.060 265 Maglij (t) East Aegean Tundzha No 3,629 4,355 1.448 0.080 266 (t) East Aegean Tundzha No 2,965 3,558 1.316 0.071 267 Pavel bania (t) East Aegean Tundzha No 3,077 4,646 268 Samuilovo (v) East Aegean Tundzha No 2,097 2,516 1.142 0.060 269 Sheinovo (v) East Aegean Tundzha No 2,002 2,402 1.123 0.058 270 (t) East Aegean Tundzha No 3,835 4,602 1.489 0.083 271 Straldja (t) East Aegean Tundzha No 6,220 7,464 1.957 0.114 272 (t) East Aegean Tundzha Yes 3,691 4,429 1.680 0.093 273 Tenevo (v) East Aegean Tundzha Yes 2,001 2,401 1.291 0.067 274 Topoichane (v) East Aegean Tundzha No 2,885 3,462 1.300 0.070 275 (t) East Aegean Tundzha No 6,703 8,044 2.0511 0.121 276 Tvarditsa (t) East Aegean Tundzha No 6,001 7,201 1.915 0.112 277 Yagoda (v) East Aegean Tundzha No 2,883 3,460 1.299 0.070 278 Zimnitsa (v) East Aegean Tundzha Yes 2,009 2,411 1.293 0.067 279 Bania (v) West Aegean Mesta No 2,818 3,382 1.286 0.069 280 (t) West Aegean Mesta No 3,305 3,966 1.384 0.076 281 Breznitsa (v) West Aegean Mesta No 3,339 4,007 1.390 0.076 282 Debren (v) West Aegean Mesta No 2,241 2,689 1.171 0.062 283 (v) West Aegean Mesta No 3,016 3,619 1.326 0.072 284 (t) West Aegean Mesta No 2,767 3,320 1.276 0.069 285 Hadjidimovo (t) West Aegean Mesta No 2,925 3,510 1.308 0.071 286 (v) West Aegean Mesta No 3,043 3,652 1.331 0.072

89 Bulgaria:Environmental Sequencing StrategiesforEUAccession

Riverbasin Catchment Area Sensitive Resident Capital Operational Settlement Name Name (River Valley) zone Population PE cost costs MEuro Ni NIEuro

0.061 287 Kraishte (v) West Aegean Mesta No 2,187 2,624 1.160 288 Musomishta (v) West Aegean Mesta No 2,333 2,800 1.189 0.063 0.066 289 Ribnovo (v) West Aegean Mesta No 2,559 3,071 1.235 0.063 290 (v) West Aegean Mesta No 2,350 2,820 1.193 0.059 291 Slashten (v) West Aegean Mesta No 2,072 2,486 1.137 0.065 292 (v) West Aegean Mesta No 2,527 3,032 1.228 0.114 293 (v) West Aegean Mesta No 6,192 7,430 1.952 0.067 294 Ablanitsa (v) West Aegean No 2,615 3,138 1.246 295 (t) West Aegean Struma Yes 2,638 3,166 1.438 0.077 0.123 296 Bobovdol (t) West Aegean Struma No 6,904 8,285 2.090 0.090 297 (t) West Aegean Struma No 4,332 5,198 1.587 0.068 298 Divotino (v) West Aegean Struma Yes 2,069 2,483 1.306 1.142 0.060 299 Dragichevo (v) West Aegean Struna No 2,100 2,520 0.069 300 (t) West Aegean Struma No 2,799 3,359 1.283 0.060 301 Kolarovo (v) West Aegean Struma No 2,156 2,587 1.154 302 Kovachevtsi (v) West Aegean Struma No 303 3,000 1.174 0.062 303 Krainitsi (v) West Aegean Struma No 2,260 2,712 0.096 304 (t) Westean Struma Yes 3,849 4,619 1.716 0.064 305 Krupnik (v) West Aegean Struma No 2,392 2,870 1.201 1.163 0.061 306 Mikrevo (v) West Aegean Struma No 2,201 2,641 0.087 307 Parvomai (v) West Aegean Struma Yes 3,302 3,962 1.591 0.073 308 Rila (t) West Aegean Struma No 3,094 3,713 1.342 0.104 309 Sapareva banja (t) West Aegean Struma Yes 4,420 5,304 1.846 2.459 0.146 310 (t) West Aegean Struma Yes 7,154 8,585 0.068 311 Studena (v) West Aegean Struma Yes 2,046 2,455 1.301 0.069 312 Tran (t) West Aegean Struma No 2,792 3,350 1.281 1.180 0.062 313 Yahinovo (v) West Aegean Struma No 2,285 2,742 314 (t) West Aegean Stnuma No 2,216 3,305 22.628 _ TOTAL 990, 662 1,269,395 415.862 *Note: Existig WWTP are not costed

90 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

WWP 10 - 15,000p.e.

River basin Catcbmeni Area .N Sensitive Resident Capital Operation Settlement Name Name (River Valley) zone population PE cost, al cost MEuro MEuro

1 (t) Black Sea Black Sea Yes 1,192 14,000 3.439 0.211 2 (r) Black Sea Black Sea Yes 13,500 0.320 0.205 3 (t) Black Sea Black Sea Yes 8,058 12,149 1.000 0.189 4 Biala- (t, t) Black Sea Black Sea Yes 4,078 15,000 3.616 0.222 5 Devnia (t) Black Sea Black Sea Yes 8,733 13,199 0.500 0.201 6 (t) Black Sea Black Sea No 8,105 12,239 0.165 7 Kamchia (r) Black Sea Black Sea Yes 11,000 0.320 0.175 8 (t) Black Sea Black Sea Yes 9,641 14,646 3.554 0.218 9 Zlatni Piasatsi (r) Black Sea Black Sea Yes 14,000 0.320 0.211 10 (t) Black Sea Kamtchiya Yes 6,887 10,448 0.500 0.168 11 (t) Black Sea Kamtchiya No 8,759 11,418 2.588 0.157 12 Veliki Preslav (t) Black Sea Kamtchiya Yes 9,306 15,000 3.616 0.222 13 (t) Danube Danube No 9,069 10,939 2.513 0.152 14 (t) Danube Dobrudzha pl. No 7,328 10,992 2.521 0.152 15 Bankia (t) Danube Iskar Yes 8,458 11,089 2.917 0.176 16 (t) Danube Iskar Yes 8,604 11,192 2.936 0.177 17 (t) Danube Ogosta Yes 7,271 10,907 0.500 0.174 18 Drianovo (t) Danube Yantra No 8,696 11,366 2.580 0.156 19 Straiitsa t Danube Yantra Yes 5,278 10,000 0.320 0.163 20 (t) East Aegean Arda No 7,942 14,000 2.991 0.183 21 (t) East Aegean Maritsa Yes 9,183 12,972 3.256 0.199 22 Hisaria (t) East Aegean Maritsa No 8,347 12,816 0.320 0.171 23 Kostenets (t) East Aegean Maritsa No 9,954 13,958 2.984 0.183 24 (t) East Aegean Maritsa No 8,535 11,201 2.554 0.154 25 Lyubiinets (t) East Aegean Maritsa Yes 8,226 10,761 2.858 0.172 26 (t) East Aegean Maritsa No 8,421 10,960 2.516 0.152 27 (t) East Aegean Maritsa No 8,473 11,099 2.538 0.153 28 (t) East Aegean Maritsa No 9,005 12,718 2.792 0.170 29 Sopot (t) East Aegean Maritsa No 9,924 13,975 2.987 0.183 30 (t) West Aegean Mesta No 9,321 12,123 2.699 0.164 31 TOTAL 216,794 369,667 62.557 5.377

91 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

WWTP > 15,000 p.e

River basin Catchment Area Sensitive Resident Capital Operation Ne Settlement Name Name (River Valley) zone population PE cost a] cost MEuro MEUro

1 Aitos (t) Black Sea Black Sea Yes 21,339 32,142 6.454 0.405 2 Asparuhovo-Varna Black Sea Black Sea Yes 23,771 48,406 8.830 0.552 _ (qt) 3 Balchik (t) Black Sea Black Sea Yes 12,509 70,000 9.603 0.710 4 Bourgas (t) Black Sea Black Sea Yes 192,390 289,974 5.000 1.214 5 (t) Black Sea Black Sea Yes 11,520 17,382 0.500 0.250 6 Meden Rudnik- Black Sea Black Sea Yes 56,849 90,000 13.718 0.826 _ Bourgas (qt) 7 Pomone (t) Black Sea Black Sea Yes 13,649 20,565 0.500 0.285 8 -Kiten (t) Black Sea Black Sea Yes 3,295 25,000 1.000 0.333 9 --SI. Black Sea Black sea Yes 10,322 65,000 0.133 0.677 _Briag (v, t, r) 10 t) Black Sea Black sea Yes 4,358 30,000 6.119 0.384 11 (t) Black Sea Black Sea Yes 5,877 25,000 5.315 0.333 12 Varna (t) Black Sea Black Sea Yes 312,889 420,000 5.000 1.241 13 Dobrich (t) Black Sea Dobrudzha p1. No 100,000 150,569 0.913 14 Shoumen (t) Black Sea Kamtchiya Yes 89,214 151,841 18.585 1.053 15 Targovishte (t) Black Sea Kamtchiya Yes 40,659 62,460 10.660 0.659 16 (t) Black Sea Provadiyska & No 13,494 20,403 2.779 0.246 Devnenska 17 (t) Black Sea Provadiyska & Yes 14,229 21,542 0.500 0.296 Devnenska 18 Popovo (t) Black Sea Rousenski Lom Yes 17,948 37,717 7.301 0.458 19 (t) Black Sea Tundzha Yes 20,587 31,068 6.286 0.395 20 (t) Danube Danube Yes 9,986 15,033 3.622 0.223 21 Kozlodui (t) Danube Danube Yes 14,892 22,506 4.903 0.306 22 Lom (t) Danube Danube Yes 27,767 41,846 7.906 0.496 23 Rouse (t) Danube Danube Yes 161,453 243,192 22.502 1.187 24 Silistra (t) Danube Danube Yes 41,952 63,230 10.754 0.664 25 (t) Danube Danube Yes 30,507 45,887 8.481 0.531 26 (t) Danube Danube Yes 10,369 15,558 3.714 0.229 27 Vidin (t) Danube Danube Yes 57,395 86,421 13.357 0.808 28 Dulovo (t) Danube Dobrudzha pl. No 7,018 35,000 5.994 0.376 29 (t) Danube Dobrudzha pI. No 10,000 30,000 1.500 0.334 30 (t) Danube Iskar Yes 21,545 32,480 5.000 0.409 31 ChervenBriag (t) Danube Iskar Yes 16,036 24,140 5.174 0.324 32 (t) Danube Iskar Yes 11,384 17,213 4.003 0.248 33 Kneza (t) Danube Iskar Yes 12,808 19,268 4.357 0.271 34 (t) Danube Iskar Yes 12,220 18,330 4.196 0.260 35 Kremikovtsi (qt) Danube Iskar Yes 16,232 48,696 0.500 0.554 36 Lukovit (t) Danube Iskar Yes 10,027 15,155 3.644 0.224 37 Mezdra t Danube Iskar Yes 12,445 18,771 4.272 0.265 38 (t) Danube Iskar Yes 13,445 20,168 4.510 0.281 39 (t) Danube Iskar Yes 27,546 58,500 0.630 40 Sofia (t) Danube Iskar Yes 1,091,772 2,037,000 21.250 1.247 41 (t) Danube Ogosta No 15,553 23,556 4.415 0.276 42 Biala Slatina (t) Danube Ogosta No 13,923 20,885 4.027 0.251

92 Bulgaria:Environmental Sequencing Strategiesfor EU Accession

River basin Catchmeni Area Sensitive Resident Capital Operation Ng Settlement Name River Valcey) zone population PE cost al cost NameValley (Rivr zone poulation Euro MEuro

43 Montana (t) Danube Ogosta Yes 49,176 120,345 16.405 0.958 44 Vratsa (t) Danube Ogosta Yes 68,975 104,135 0.500 0.894 45 Levski (t) Danube Osum No 12,198 18,321 3.647 0.226 46 Lovech (t) Danube Osum Yes 44,146 85,667 13.279 0.803 47 Troyan (t) Danube Osum Yes 23,332 32,570 6.520 0.409 48 Razgrad (t) Danube Rousenski Lom Yes 38,948 60,000 0.500 0.641 49 Pleven (t) Danube Vit Yes 121,880 183,224 0.500 1.117 50 (t) Danube Vit Yes 11,498 17,381 4.032 0.250 51 Biala (t) Danube Yantra No 10,074 15,176 3.172 0.195 52 Gabrovo (t) Danube Yantra Yes 67,065 101,025 0.500 0.880 53 Gorna Oriahovitsa- Danube Yantra Yes 48,096 102,535 14.906 0.887 Liaskovets-Dolna Oriahovitsa (t, t, t) 54 (t) Danube Yantra No 12,949 19,521 3.826 0.238 55 Seviievo (t) Danube Yantra Yes 24,775 53,333 9.494 0.591 56 Triavna (t) Danube Yantra No 11,223 16,916 3.436 0.212 57 Veliko Tamnovo (t) Danube Yantra Yes 66,897 95,000 1.250 0.852 58 Kurdjali (t) East Aegean Arda Yes 45,659 68,594 11.398 0.701 59 Smolian (t) East Aegean Arda Yes 33,091 69,500 11.505 0.707 60 (t) East Aegean Maritsa Yes 51,936 78,174 12.484 0.761 61 (t) East Aegean Maritsa No 18,171 27,398 4.960 0.311 62 Dimitrovgrad (t) East Aegean Maritsa Yes 45,768 246,425 22.594 1.189 63 Harmanli (t) East Aegean Maritsa Yes 19,927 30,195 6.149 0.386 64 Haskovo (t) East Aegean Maritsa Yes 80,303 130,000 17.133 0.991 65 (t) East Aegean Maritsa Yes 13,593 20,567 0.500 0.285 66 Karlovo (t) East Aegean Maritsa No 25,494 38,573 6.459 0.405 67 (t) East Aegean Maritsa Yes 25,220 38,180 0.500 0.463 68 (t) East Aegean Maritsa No 19,994 25,000 4.622 0.289 69 Parvomai (t) East Aegean Maritsa Yes 15,370 23,285 5.033 0.315 70 Pazardjik (t) East Aegean Maritsa Yes 78,855 216,666 21.649 1.162 71 (t) East Aegean Maritsa No 19,411 29,469 5.248 0.329 72 Plovdiv (t) East Aegean Maritsa Yes 338,224 662,590 1.000 1.247 73 (t) East Aegean Maritsa Yes 14,496 21,807 0.500 0.299 74 Rakovski (t) East Aegean Maritsa No 16,264 24,671 4.575 0.286 75 Stamboliiski (t) East Aegean Maritsa Yes 12,580 19,005 4.312 0.268 76 Stara Zagora (t) East Aegean Maritsa Yes 143,420 251,000 22.719 1.193 77 (t) East Aeg Maritsa No 19,093 28,640 5.133 0.322 78 Velingrad (t) East Aegean Maritsa Yes 24,818 37,514 7.271 0.456 79 (t) East Aegean Tundzha Yes 12,394 18,627 4.247 0.264 80 (t) East Aegean Tundzha Yes 53,770 80,000 0.500 0.772 81 Sliven (t) East Aegean Tundzha No 100,366 106,000 0.320 0.784 82 Yambol (t) East Aegean Tundzha Yes 82,649 124,386 16.716 0.973 83 (t) West Aegean Mesta Yes 20,426 30,800 6.244 0.392 84 (t) West Aegean Mesta No 12,738 20,926 6.400 0.251 85 Blagoevgrad (t) West Aegean Struma Yes 71,144 184,722 20.340 1.119 86 (t) West Aegean Struma Yes 38,127 57,485 0.500 0.623 87 Kyustendil (t) West Aegean Struma No 49,919 75,365 0.500 0.647 88 Pemik (t) West Aegean Struma Yes 85,991 129,200 0.600 0.989 89 (t) West Aegean Struma Yes 29,606 44,678 8.311 0.520

93 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

River basin Catecment Area Sensitive Resident Capital Operation Name Name (River Valley) zone population PE cost a] cost _2 Settlement MEuro MEuro

90 Radonir (t) West Aegean Struma Yes 15,785 23,753 0.500 0.320 91 Sandanski (t) West Aegean Struma No 26,507 40,043 6.647 0.417 51.214 TOTAL I _ I 4,883,515 8,610,291 585.903 *Note: Capital Costsfor Existing WWTP are takenfrom the MOEWprogram

94 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

ANN:EX IV

Sewerage Systems Full Cost Implementation Settlements of 2,000 - 1 0,000 p.e.

Sewerage Sewerage Total _ Settlement Name River basin Catehment Area Resident as % of extension capital .Ns Settlement Name Name (River Valley) population PE street lzn cost network MEURO 1 Kameno (t) Black Sea Aitoska 5,138 6,166 60 11.6 1.740 2 Chemo more (v) Black Sea Atanasovsko lake 2,353 2,824 0 0 3.530 3 Rudnik (v) Black Sea Atanasovsko lake 3,489 4,187 20 0 4.187 4 Aheloy (v) Black Sea Black Sea 2,269 2,723 0 0 3.404 5 Aksakovo (v) Black Sea Black Sea 7,269 8,723 6.542 6 Balgarovo (t) Black Sea Black Sea 2,122 2,546 0 19 2.850 7 Chaika-Varna qt) Black Sea Black Sea 5,000 0 0 0.000 8 Chemomorets (v) Black Sea Black Sea 2,044 2,453 76 0 0.736 9 Dalgopol (t) Black Sea Black Sea 5,394 8,168 52 12.2 1.830 10 Druiba 2 (r) Black Sea Black Sea X ___=_ 5,000 0= 0 0.000 11 Duni (r) Black Sea Black Sea X 5,000 0 0 0.000 12 Elenite (r) Black Sea Black Sea 5,000 0 0 0.000 13 Igatievo (v2 Black Sea Black Sea 3,963 4,756 0 0 5.945 14 Konstantin&Elena (r) Black Sea Black Sea 5,000 0 0 0.000 15 Kranevo (v) Black Sea Black sea 971 2,800 53 8.899 1.335 16 Lozenets (v) Black Sea Black sea 467 5,000 0 0 0.701 17 Obrochishte (v) Black Sea Black Sea 2,395 2,874 0 0 3.593 18 Rusalka (r) Black Sea Black Sea 5,000 0 0 0.000 19 Shabla (t) Black Sea Black Sea 4,008 6,003 8 43.312 6.497 20 Sinemorets (r) Black Sea Black Sea 264 4,000 42 4.000 0.600 21 Topoli (v) Black Sea Black Sea 3,044 3,653 0 0 4.566 22 Varvara (v) Black Sea Black Sea 4,000 0 0 0.000 23 Todor Ikonomovo (v) Black Sea Dobrudza pL. 2,094 2,513 0 0 3.141 24 Kableshkovo (t) Black Sea Dry gulley 2,817 3,380 31 4.650 25 Vetren Black Sea Dry gulley 2,297 2,756 0 3.446 26 Gradets (v) Black Sea Kamtchiya 3,932 4,718 50 0 2.949 27 Grozdiovo (v) Black Sea Kamtchiya 2,465 2,958 10 0 3.661 28 Kotel (t) Black Sea Kamtchiya 6,934 8,321 17 37.018 5.553 29 Loznitsa (t) Black Sea Kamtchiya 2,758 4,154 31 24.15 3.623 30 Ruen (v) Black Sea Kamtchiya 2,049 2,459 30 0 2.151 31 Smiadovo (t) Black Sea Kamtchiya 4,430 6,740 22 43.580 6.537 32 Staro Oriahovo (v) Black Sea Kamtchiya 2,710 3,252 0 0 4.065 33 Tsonevo (v) Black Sea Kamtchiya 2,457 2,948 0 0 3.686 34 Varbitsa (t) Black Sea Kamtchiya 3,668 4,402 0 15 2.250 35 Yablanovo (v) Black Sea Kamtchiya 2,893 3,472 0 0 4.340. 36 Suvorovo (t) Black Sea Provadiiska 4,774 5,729 8 39.56 5.934 37 Kaspichan (t) Black Sea Provadiyska & 3,689 4,427 82 8.500 1.275 Devnenska . _ 38 Yasenkovo (v) Black Sea Sazlaka 2,075 2,490 0 0 3.113 39 Valchi dol (t) Black Sea Stara 3,692 5,574 30 18.9 2.835 40 Malko Tamnovo (t) Black Sea Veleka 2,946 3,535 75 4.75 0.713 41 Archar (v) Danube Archar 2,624 3,149 0 0 3.936 42 Bregovo (t) Danube Bregovitsa 3,111 3,733 0 42 6.300 43 Kula (t) Danube Chichilska 4,018 4,822 30 23.1 3.465

95 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

Sex-erage Se%erage Total capital Settlement Name River basin CaRchment Area Resident PE as % of extension .Nb Name (River V'aley) population street km cost nerwork MEURO 45 6.750 44 Alfatar (t) Danube Danube 2,122 2,546 0 0 3.267 45 Belovets (v) Danube Danube 2,178 2,614 0 0 4.245 46 Brest (v) Danube Danube 2,830 3,396 0 0 4.539 47 Brestovene (v) Danube Danube 3,026 3,631 0 0 4.560 48 Diankovo (v) Danube Danube 3,040 3,648 0 0 5.930 49 Glodjevo (v) Danube Danube 3,953 4,744 0 0 4.423 50 Kalipetrovo (v) Danube Danube 5,361 6,433 45 0_ 6.089 51 Marten (v) Danube Danube 4,273 5,128 5 0 5.028 52 Nikolovo (v) Danube Danube 3,352 4,022 0 0 2.640 53 Nikopol (t) Danube Danube 4,512 5,414 201 17.6 0 3.057 54 Nova cherna (v) Danube Danube 2,038 2,446 0 0 3.221 55 Oresh (v) Danube Danube 2,147 2,576 0 3.174 56 Oriahovo (t) Danube Danube 6,107 7,328 54 21.16 0 3.063 57 Ostrov (v) Danube Danube 2,042 2,450 0 0 3.620 58 Ostrovo (v) Danube Danube 2,413 2,896 0 0 3.185 59 Ovcha mogila (v) Danube Danube 2,123 2,548 01 0 3.278 60 Pirgovo (v) Danube Danube 2,185 2,622 0 0 3.119 61 Riahovo (v) Danube Danube 2,079 2,495 0 0 0.693 62 Selanovtsi (v) Danube Danube 4,623 5,548 90 0 5.039 63 (v) Danube Danube 3,359 4,031 0 0 4.295 64 Sminenski (v) Danube Danube 2,863 3,436 0 0 0.000 65 Srebarna (v) Danube Danube 854 1,025 100 0 3.800 66 Tetovo (vy Danube Danube 2,533 3,040 0 42 6.300 67 Zavet (t) Danube Danube 3,588 4,306 0 3.3 0.495 68 Dragoman (t) Danube Dragomansko blato 3,755 4,506 90 3.803 69 Aidemir (v) Danube Dry guley 7,683 9,220 45 4.230 70 Borovo (t) Danube Dry guley 2,620 3,144 40 28.2 0 3.557 71 Chernolik (v) Danube Dry gulley 2,371 2,845 0 1 41.58 6.237 72 Dve mogHii(t) Danube Dry guUey 4,714 5,657 2.295 73 Glavinitsa (t) Danube Dry guUey 2,065 2,478 15 15.3 0.158 74 Belogradchik (t) Danube Gradska 5,816 6,979 95 1.05 43 6.450 75 Gramada (v) Danube Gramadanska 2,111 2,533 0 0 5.594 76 Bistritsa (v) Danube Iskar 3,729 4,475 0 0 0.746 77 Bojurishte (t) Danube Iskar 5,182 6,218 84 0 0.000 78 Borovets-h-I Rila (r) Danube Iskar 4,000 100 0 0.000 79 Borovets-yaitseto (r) Danube Iskar 6,000 0 0 3.575 80 Brenitsa (v) Danube Iskar 2,383 2,860 0 0 4.392 81 Buhovo (t) Danube Iskar 2,928 3,514 0 0 3.660 82 Chepintsi (v) Danube Iskar 2,440 2,928 0 0 3.551 83 Dolni lukovit (v) Danube Iskar 2,367 2,840 0 0 5.873 84 Elin Pelin - station Danube Iskar 3,915 4,698 0 6.000 85 Elin Pelin (t) Danube Iskar 6,690 8,028 40 0 3.46 1 86 German (v) Danube Iskar 2,307 2,768 0 0 4.251 87 Gigen (v) Danube Iskar 2,834 3,401 0 31 4.650 88 Iskar (t) Danube Iskar 4,107 4,928 0 0 2.875 89 Iskrets (v) Danube Iskar 2,396 2,875 20 0 6.731 90 Kazichene (v) Danube Iskar 4,487 5,384 0 65 9.750 91 Koinare (t) Danube Iskar 5,103 6,124 0 0 3.015 92 Litakovo (v) Danube Iskar 2,010 2,412 0

96 Bulgaria: EmnironmentalSequencing StrategiesforEU Accession

Sewerage Sewerage Total .N Settlement Name River basin Catehment Area Resident PE as % of extension capital Name (River V'aIiey) population street k-m cost network MEURO 93 Lozen (v) Danube Iskar 5,751 6,901 0 0 5.176 94 Novi Han (v) Danube Iskar 2,410 2,892 0 0 3.615 95 Petarch (v) Danube Iskar 2,263 2,716 60 0 1.358 96 Pravets (t) Danube Iskar 4,730 7,160 85 27 4.050 97 Roman (t) Danube Iskar 3,553 4,264 5 19 2.850 98 Slivnitsa (t) Danube Iskar 7,965 9,558 85 6.9 1.035 99 Stavertsi (v) Danube Iskar 2,269 2,723 0 0 3.404 100 Svetovrachene (v) Danube Iskar 2,266 2,719 0 0 3.399 101 Trudovets (v) Danube Iskar 3,494 4,193 0 0 5.241 102 Vakarel (v) Danube Iskar 2,291 2,749 60 0 1.375 103 Vladaia (v) Danube Iskar 3,595 4,314 0 0 5.393 104 Voluiak (v) Danube Iskar 2,689 3,227 0 0 4.034 105 Vrachesh (v) Danube Iskar 3,812 4,574 0 0 5.718 106 Zverino (v) Danube . Iskar 2,087 2,504 0 0 3.131 107 Dolna bania (t) Danube Maritsa 4,787 5,744 72 8.4 1.260 108 Koprivshtitsa (t) Danube Maritsa 2,669 3,203 90 3.2 0.480 109 Godech (t) Danube Nishava 5,020 6,024 70 13.5 2.025 110O.Boichinovtsi (t) Danube Ogosta 2,070 2,484 0 26 3.900 111 Borovan (v) Danube Ogosta 2,761 3,313 0 0 4.142 112 Butan (v) Danube Ogosta 3,343 4,012 0 0 5.015 113 Chiprovtsi (t) Danube Ogosta 2,370 2,844 60 10.8 1.620 114 Galiche (v) Danube Ogosta 2,406 2,887 0 0 3.609 115 Glojene (v) Danube Ogosta 3,150 3,780 0 0 4.725 116 Hairedin (v) Danube Ogosta 2,125 2,550 0 0 3.188 117 Harlets (v) Danube Ogosta 2,428 2,914 0 0 3.642 118 Krivodol (t) Danube Ogosta 3,832 4,598 0 43 6.450 119 Krushovitsa (v) Danube Ogosta 2,193 2,632 0 3.290 120 Lehchevo (v) Danube Ogosta 2,370 2,844 0 0 3.555 121 Malorad (v) Danube Ogosta 2,380 2,856 0 0 3.570 122 Mizia (t) Danube Ogosta 4,069 4,883 0 33 4.950 123 Popitsa (v) Danube Ogosta 2,142 2,570 0 0 3.213 124 Tarnava (v) Danube Ogosta 2,875 3,450 0 0 4.313 125 Aleksandrovo (v) Danube Osum 2,298 2,758 0 0 3.447 126 Letnitsa (t) Danube Osum 3,918 4,702 70 9.6 1.440 127 Obnova (v) Danube Osum 2,611 3,133 0 0 3.917 128 Oreshak (v) Danube Osum 2,384 2,861 0 0 3.576 129 Pordim (t) Danube Osum 2,390 2,868 01 31 4.650 130 Slavianovo (t) Danube Osum 4,829 5,795 0 42 6.300 131 Ezerche (v) Danube Rusenski lom 2,213 2,656 0 0 3.320 132 Getsovo (v) Danube Rusenski lom 2,038 2,446 0 0 3.057 133 Opaka (t) Danube Rusenski lom 3,181 3,817 30 22.4 3.360 134 Rakovski (v) Danube Rusenski lom 2,565 3,078 0 0 3.848 135 Shtraklevo (v) Danube Rusenski lom 2,801 3,361 0 0 4.202 136 Strajets (v) Danube Rusenski lom 2,012 2,414 0 0 3.018 137 Tsar Kaloian (t) Danube Rusenski lom 4,205 5,046 0 32 4.800 138 Vetovo (t) Danube Rusenski lom 5,000 6,000 0 60 9.000 139 Yasenovets (v) Danube Rusenski lom 2,511 3,013 0 0 3.767 140 Medkovets (v) Danube Tsibritsa 2,464 2,957 0 0 3.696 141 Valchedram (t) Danube Tsibritsa 4,800 5,760 0 62 9.300

97 Bulgaria:Environmental Sequencing StrategiesforEU Accession

Sewerage Sewerage Total

River basin Catchment Area Resident PE as lo of extension capital Ngi Settlement Name Name (River VaDey) population street kIm cost network MEURO

142 Yakimovo (v) Danube Tsibritsa 2,390 2,868 0 0 3.585 143 Bukovlak (v) Danube Vit 3,308 3,970 0 0 4.962 144 Dermantsi (v) Danube Vit 2,625 3,150 0 0 3.938 145 Dolna Mitropolia (t) Danube Vit 3,603 4,324 0 24 3.600 146 DoIni Dabmik (t) Danube Vit 5,229 6,275_ 0 38 5.700 147 Galata (v) Danube Vit 2,436 2,923 0 0 3.654 148 Gorna Mitropoloia (v) Danube Vit 2,156 2,587 0 0 3.234 149 Gormi Dabnik (v) Danube Vit 2,004 2,405 0 0 3.006 150 Guliantsi (t) Danube Vit 3,827 4,592 20 24.8 3.720 151 Krushovitsa (v) Danube Vit 2,220 2,664 0 0 3.330 152 Milkovitsa (v) Danube Vit 2,334 2,801 0 0 3.501 153 Sadovets (v) Danube Vit 2,823 3,388 0 0 4.235 154 Trastenik (t) Danube Vit 5,085 6,102 0 43 6.450 155 Ugarchin (t) Danube Vit 3,161 3,793 23 26.95 4.043 156 Yablanitsa (t) Danube Vit 3,098 3,718 80 5 0.750 157 Yasen v Danube Vit 2,674 3,209 0 0 4.011 158 Dunavtsi (v) Danube Voinishka 3,141 3,769 0 36 5.400 159 Apriltsi (t) Danube Yantra 3,688 4,426 0 56 8.400 160 Biala Cherkva (t) Danube Yantra 2,869 3,443 0 28 4.200 161 Debelets (t) Danube Yantra 4,413 5,296 59 8.61 1.292 162 Djuliunitsa (v) Danube Yantra 2,371 2,845 67 0 1.174 163 Draganovo(v) Danube Yantra 2,958 3,550 93 0 0.311 164 Elena (t) Danube Yantra 6,449 7,739 64 11.52 1.728 165 Kilifarevo (t) Danube Yantra 2,556 3,067 30 16.8 2.520 166 Parvomaitsi (v) Danube Yantra 3,256 3,907 38 0 3.028 167 Plachkovtsi (t) Danube Yantra 2,278 2,734 9 28.629 4.294 168 Polikraishte (v) Danube Yantra 2,375 2,850 85 0 0.534 169 Polski Trambesh (t) Danube Yantra 5,199 6,239 80 9.2 1.380 170 Resen (v) Danube Yantra 2,475 2,970 3 0 3.601 171 Samovodene (v) Danube Yantra 2,014 2,417 60 0 1.208 172 Suhindol (t) Danube Yantra 2,515 3,018 78 7.92 1.188 173 Tsenovo (v) Danube Yantra 2,046 2,455 0 0 3.069 174 Zlataritsa (t) Danube Yantra 2,671 3,205 15 29.75 4.463 175 Ardino (t) East Aegean Arda 3,720 4,464 50 11 1.650 176 Chepintsi (v) East Aegean Arda 2,143 2,572 50 0 1.607 177 Chorbadjiisko (v) East Aegean Arda 2,014 2,417 0 0 3.021 178 Djebel (t) East Aegean Arda 2,839 3,407 80 3.6 0.540 179 Ivailovgrad (t) East Aegean Arda 4,420 5,304 15 21.25 3.188 180 Krumovgrad (t) East Aegean Arda 5,239 6,287 88 2.16 0.324 181 Madan(t) East Aegean Arda 6,575 9,750 45 14.356 2.153 182 Momcbilgrad (t) East Aegean Arda 7,948 9,538 55 11.7 1.755 183 Nedelino (t) East Aegean Arda 5,143 6,172 20 13.6 2.040 184 Rudozem (t) East Aegean Arda 4,255 9,767 70 7.887 1.183 185 Startsevo (v) East Aegean Arda 2,749 3,299 0 0 4.124 186 Aleko Konstantinovo East Aegean Maritsa 2,913 3,496 0 0 4.370 _ (v) 187 Bania (v) East Aegean Maritsa 3,904 4,685 78 0 1.288 188 Batak (t) East Aegean Maritsa 4,143 4,972 80 4.6 0.690 189 Belovo (t) East Aegean Maritsa 4,578 5,494 90 2.9 0.435

98 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Sewerage Sew%erage Total River basin Catchment Area Resident PE as °O of extension capital Name (River Valley) population street kn cost network MEURO 190 Belozem (v) East Aegean Maritsa 4,364 5,237 0 0 6.546 191 Boliartsi (v) East Aegean Maritsa 2,766 3,319 0 0 4.149 192 Borino (v) East Aegean Maritsa 2,745 3,294 90 0 0.412 193 Branipole (v) East Aegean Maritsa 2,625 3,150 0 0 3.938 194 Bratanitsa (v) East Aegean Maritsa 2,204 2,645 0 0 3.306 195 Bratsigovo (t) East Aegean Maritsa 4,815 5,778 95 1.5 0.225 196 Brestovitsa (v) East Aegean Maritsa 3,939 4,727 0 0 5.909 197 Brezovo (t) East Aegean Maritsa 2,075 2,490 0 46 6.900 198 Chalakovi (v) East Aegean Maritsa 2,063 2,476 0 0 3.095 199 Chepelare (t) East Aegean Maritsa 5,670 6,804 77 5.17 0.776 200 Chernogorovo (v) East Aegean Maritsa 2,429 2,915 0 0 3.644 201 Cheshnegirovo (v) East Aegean Maritsa 2,219 2,663 0 0 3.329 202 Dalgo pole (v) East Aegean Maritsa 2,250 2,700 0 0 3.375 203 Devin (t) East Aegean Maritsa 7,548 9,058 28 23.76 3.564 204 Dorkovo (v) East Aegean Maritsa 3,044 3,653 80 0 0.913 205 Draginovo (v) East Aegean Maritsa 4,658 5,590 0 0 6.987 206 Glavinitsa (v) East Aegean Maritsa 2,619 3,143 15 0 3.339 207 Gradina (v) East Aegean Maritsa 2,829 3,395 0 0 4.244 208 Graf ignatievo (v) East Aegean Maritsa 2,097 2,516 24 0 2.391 209 Ioakim Gruevo (v) East Aegean Maritsa 3,032 3,638 1 0 4.503 210 Ivailo (v) East Aegean Maritsa 3,229 3,875 0 0 4.844 211 Kalekovets (v) East Aegean Maritsa 2,499 2,999 6 0 3.524 212 Kaloianovo (v) East Aegean Maritsa 2,479 2,975 0 0 3.719 213 Katunitsa (v) East Aegean Maritsa 2,666 3,199 0 0 3.999 214 Korten (v) East Aegean Maritsa 2,041 2,449 0 0 3.062 215 Kostandovo (v) East Aegean Maritsa 4,351 5,221 78 0 1.436 216 Kostenets (v) East Aegean Maritsa 4,296 5,155 15 0 5.477 217 Kovachevo (v) East Aegean Maritsa 2,434 2,921 90 0 0.365 218 Krumovo (v) East Aegean Maritsa 3,436 4,123 0 0 5.154 219 Kuklen (v) East Aegean Maritsa 5,891 7,069 0o 0 5.302 220 Kurtovo Konare (v) East Aegean Maritsa 2,874 3,449 0 0 4.311 221 Luki (t) East Aegean Maritsa 2,871 3,445 60 6 0.900 222 Malo konare (v) East Aegean Maritsa 4,963 5,956 0 0 7.445 223 Manole (v) East Aegean Maritsa 3,097 3,716 5 0 4.413 224 Markovo (v) East Aegean Maritsa 2,250 2,700 0. 0 3.375 225 (t) East Aegean Maritsa 2,193 2,632 0 26 3.900 226 Mokrishte (v) East Aegean Maritsa 2,097 2,516 0 0 3.146 227 Nova Mahala (v) East Aegean Maritsa 2,159 2,591 80 0 0.648 228 Novo selo (v) East Aegean Maritsa 2,528 3,034 0 0 3.792 229 Obruchishte v East Aeean Maritsa 2,163 2,596 1 0 3.212 230 Ognianovo (v) East Aegean Maritsa 2,661 3,193 0 0 3.992 231 Pamporovo (r) East Aegean Maritsa 7,000 100 0 0.000 232 Parvenets (v) East Aegean Maritsa 3,772 4,526 0 0 5.658 233 Perushtitsa (t) East Aegean Maritsa 5,387 6,464 62 10.64 1.596 234 Popintsi (v) East Aegean Maritsa 2,467 2,960 15 0 3.145 235 Rogosh (v) East Aegean Maritsa 3,063 3,676 16 0 3.859 236 Rozino (v) East Aegean Maritsa 3,919 4,703 0 0 5.879 237 Sadovo (t) East Aegean Maritsa 2,612 3,134 0 51 7.650 238 Saedinenie (t) East Aegean Maritsa 6,407 7,688 0 55 8.250

99 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Sewerage Sewerage Total Settlement Name River basin Catchiment Area Resident PE as % of extension capital N2 Name (River Valley) population street kmi cost network MEURO

239 Semchinovo (v) East Aegean Maritsa 2,077 2,492 90 0 0.312 240 (t) East Aegean Maritsa 7,790 9,348 23 53.9 8.085 241 Sinitovo (v) East Aegean Maritsa 2,258 2,710 0 0 3.387 242 Skutare (v) East Aegean Maritsa 2,222 2,666 8 0 3.066 243 Strelcha (t) East Aegean Maritsa 4,785 5,742 50 10 1.500 244 Striama (v) East Aegean MaTitsa 3,373 4,048 0 0 5.060 245 Topolovo (v) East Aegean Maritsa 2,989 3,587 0 0 4.484 246 Trud (v) East Aegean Maritsa 4,038 4,846 80 0 1.211 247 Tsalapitsa (v) East Aegean Maritsa 4,841 5,809 0 0 7.262 248 Tsaratsovo (v) East Aegean Maritsa 2,263 2,716 5 0 3.225 249 Ustina (v) East Aegean Maritsa 2,344 2,813 0 0 3.516 250 Varvara (v) East Aegean Maritsa 2,440 2,928 90 0 0.366 251 Vetren (v) East Aegean Maritsa 3,888 4,666 90 0 0.583 252 Yagodovo (v) East Aegean Maritsa 3,299 3,959 0 0 4.949 253 Zlatitsa (t) East Aegean Maritsa 5,789 6,947 90 8.6 1.290 254 Zvanichevo (v) East Aegean Maritsa 2,260 2,712 0 0 3.390 255 Sarnitsa (v) East Aegean Mesta 3,650 4,380 0 0 5.475 256 Buzovgrad (v) East Aegean Tundzha 2,513 3,016 60 0 1.508 257 Enina (v) East Aegean Tundzha 2,679 3,215 0 0 4.019 258 Gurkovo (t) East Aegean Tundzha 3,029 3,635 40 11.4 1.710 259 Jeliu voivoda (v) East Aegean Tundzha 2,695 3,234 0 0 3.646 260 Kalofer (t) East Aegean Tundzha 3,757 4,508 72 9.593 1.439 261 Kermen (t) East Aegean Tundzha 2,207 2,648 0 48 7.200 262 Koprinka (v) East Aegean Tundzha 2,847 3,416 10 0 3.843 263 Kran (v) East Aegean Tundzha 3,636 4,363 50 0 2.727 264 Krushare (v) East Aegean Tundzha 2,146 2,575 0 0 3.219 265 Maglij t) East Aegean Tundzha 3,629 4,355 0 24.680 3.702 266 Nikolaevo (t) East Aegean Tundzha 2,965 3,558 0 16 2.400 267 Pavel bania (t) East Aegean Tundzha 3,077 4,646 60 11.6 1.740 268 Samuilovo (v) East Aegean Tundzha 2,097 2,516 0 0 3.146 269 Sheinovo (v) East Aegean Tundzha 2,002 2,402 25 0 2.252 270 Shivachevo (t) East Aegean Tundzha 3,835 4,602 14 30.96 4.644 271 Straldja (t) East Aegean Tundzha 6,220 7,464 5 39.9 5.985 272 Sungurlare (t) East Aegean Tundzha 3,691 4,429 20 20.8 3.120 273 Tenevo (v) East Aegean Tundzha 2,001 2,401 0 0 3.002 274 Topolichane (v) East Aegean Tundzha 2,885 3,462 0 0 4.328 275 Topolovgrad (t) East Aegean Tundzha 6,703 8,044 70 10.2 1.530 276 Tvarditsa (t) East Aegean Tundzha 6,001 7,201 15 32.3 4.845 277 Yagoda (v) East Aegean Tundzha 2,883 3,460 0 0 4.325 278 Zimnitsa (v) East Aegean Tumdzha 2,009 2,411 70 0 0.904 279 Bania (v) West Aegean Mesta 2,818 3,382 16 0 3.551 280 Belitsa (t) West Aegean Mesta 3,305 3,966 49 10.71 1.607 281 Breznitsa (v) West Aegean Mesta 3,339 4,007 63 0 1.853 282 Debren (v) West Aegean Mesta 2,241 2,689 0 0 3.362 283 Dobrinishte (v) West Aegean Mesta 3,016 3,619 85 0 0.679 284 Dospat (t) West Aegean Mesta 2,767 3,320 85 5.55 0.833 285 Hadjidimovo (t) West Aegean Mesta 2,925 3,510 62 0 1.667 286 Kochan (v) West Aegean Mesta 3,043 3,652 90 0 0.456 287 Kraishte (v) West Aegean Mesta 2,187 2,624 0 0 3.281

100 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

Sewerage Sew erage Total .Nb Settlement Name River basin Catchmeni Area Resident PE as % of extension capital Name (River Vafley) population street km cost network MEURO 288 Musomishta (v) West Aegean Mesta 2,333 2,800 0 0 3.500 289 Ribnovo (v) West Aegean Mesta 2,559 3,071 0 0 3.839 290 Satovcha (v) West Aegean Mesta 2,350 2,820 15 0 2.996 291 Slashten (v) West Aegean Mesta 2,072 2,486 70 0 0.932 292 Valkosel (v) West Aegean Mesta 2,527 3,032 70 0 1.137 293 Yakoruda (v) West Aegean Mesta 6,192 7,430 95 1.1 0.165 294 Ablanitsa (v) West Aegean Struna 2,615 3,138 0 3.923 295 Batanovtsi (t) West Aegean Strnma 2,638 3,166 45 13.2 1.980 296 Bobovdol (t) West Aegean Struma 6,904 8,285 92 4 0.600 297 Breznik (t) West Aegean Struna 4,332 5,198 60 10.8 1.620 298 Divotino (v) West Aegean Struma 2;069 2,483 20 0 2.483 299 Dragichevo (v) West Aegean Stnuna 2,100 2,520 30 0 2.205 300 Kocherinovo (t) West Aegean Struma 2,799 3,359 60 11.2 1.680 301 Kolarovo (v) West Aegean Struma 2,156 2,587 0 0 3.234 302 Kovachevtsi (v) West Aegean Struma 303 3,000 41 7.600 1.110 303 Krainitsi (v) West Aegean Struma 2,260 2,712 90 0 0.339 304 Kresna t) West Aegean Struma _ _3,849_ 4,619 80 5 0.750 305 Krupnik (v) West Aegean Struma 2,392 2,870 46 0 1.938 306 Mikrevo (v) West Aegean Struma 2,201 2,641 60 0 1.321 307 Parvomai (v) West Aegean Struma 3,302 3,962 0 0 4.953 308 Rila (t) West Aegean Struma 3,094 3,713 40 17.4 2.610 309 Sapareva bania (t) West Aegean Struma 4,420 5,304 20 23150 3.473 310 Simitli (t) West Aegean Struma 7,154 8,585 82 5.58 0.837 311 Studena (v) West Aegean Struma 2,046 2,455 35 0 1.995 312 Tran (t) West Aegean Struma 2,792 3,350 70 9.6 1.440 313 Yahinovo (v) West Aegean Struma 2,285 2,742 90 0 0.343 314 Zemen (t) West Aegean Struma 2,216 3,305 69 5.400 0.810 TOTAL 99, 662 1,268,093 1,025,130

101 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

Sewerage Systems 10 - 15,000 p.e.

Sewerage Sewerage Total

as Do of extension capital J.N Settlement Name Riverbasin Catchment Area Resident PE cost Name (River Vatley) population street km network 14,000 73 5.500 0.825 1 Ahtopol (t) Black Sea Black Sea 1,192 92 0.800 0.120 2 Albena (r) Black Sea Black Sea 13,500 50 14.845 2.227 3 Beloslav (t) Black Sea Black Sea 8,058 12,149 38 29.500 4.425 4 Biala-Obzor (t, t) Black Sea Black Sea 4,078 15,000 78 14.200 2.130 5 Devnia (t) Black Sea Black Sea 8,733 13,199 17 56.943 8.541 6 General Toshevo (t) Black Sea Black Sea 8,105 12,239 11,000 0.000 7 Kamchia (r) Black Sea Black Sea 29 37.752 5.663 8 Sredets (t) Black Sea Black Sea 9,641 14,646 14,000 100 0.000 9 Zlatni Piasatsi (r) Black Sea Black Sea 10,448 5 2.601 10 Dolni Chiflik (t) Black Sea Kamtchiya 6,887 20 2.785 11 Onmurtag (t) Black Sea Kamtchiya 8,759 11,418 86 2.020 0.303 12 Veliki Preslav (t) Black Sea Kamtchiya 9,306 15,000 10,939 71 51.347 7.702 13 Kubrat (t) Danube Danube 9,069 75 8.400 1.260 14 Tervel (t) Danube Dobrudzha pl. 7,328 10,992 11,089 13 __ _ 2.925 15 Bankia (t) Danube Iskar 8,458 11,192 28 2.462 16 Svoge (t) Danube Iskar 8,604 85 19.500 2.925 17 Kostenets (t) Danube Maritsa 9,954 13,958 62 5.315 0.797 18 Varshets (t) Danube Ogosta 7,271 10,907 67 12.400 1.860 19 Drianovo (t) Danube Yantra 8,696 11,366 57 4.000 0.600 20 Strajitsa (t) Danube Yantra 5,278 10,000 74 18.000 2.700 21 Zlatograd (t) East Aegean Arda 7,942 14,000 80 9.500 1.425 22 Galabovo (t) East Aegean Maritsa 9,183 12,972 47 23.352 3.503 23 Hisaria (t) East Aegean Maritsa 8,347 12,816 16 28.440 4.266 24 Krichim (t) East Aegean Maritsa 8,535 11,201 27 2.387 25 (t) East Aegean Maritsa 8,226 10,761 10,960 71 0.971 26 Pirdop (t) East Aegean Maritsa 8,421 11,099 40 2.021 27 Rakitovo (t) East Aegean Maritsa 8,473 12,718 54 1.647 28 Septemvr (t) East Aegean Maritsa 9,005 43 26.070 3.911 29 Sopot (t) East Aegean Maritsa 9,924 13,975 48 13.606 2.041 30 Bansko (t) West Aegean Mesta 9,321 12,123 369,667 75.022 =TOTAL 216,794

102 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

Sewerage Systems > 15, 000 p.e.

Sewerage Sewerage Capital .N Settlement Name River basin Carchmeni Area Resident PE as lo of extension Cost Name (River Valley) population street km MEuro network 1 Aitos (t) Black Sea Black Sea 21,339 32,142 73 12.200 1.830 2 Asparuhovo-Varna Black Sea Black Sea 23,771 48,406 84 21.200 3.180 (qt) 3 Balchik (t) Black Sea Black Sea 12,509 70,000 44 32.278 4.842 4 Bourgas (t) Black Sea Black Sea 192,390 289,974 91 49.120 7.368 5 Kavama (t) Black Sea Black Sea 11,520 17,382 13 65.052 9.758 6 Meden Rudnik- Black Sea Black Sea 56,849 90,000 39 43.000 6.450 Bourgas (qt) 7 (t) Black Sea Black Sea 13,649 20,565 95 0.000 0.000 8 Primorsko-Kiten (t) Black Sea Black Sea 3,295 25,000 98 10.000 1.500 9 Ravda-Nesebar-Sl. Black Sea Black sea 10,322 65,000 66 53.596 8.039 Briag (v, t, r) 10 Sozopol (t) Black Sea Black sea 4,358 30,000 32 28.000 4.200 11 Tsarevo (t) Black Sea Black Sea 5,877 25,000 51 25.733 3.860 12 Vama (t) Black Sea Black Sea 312,889 420,000 94 24.000 3.600 13 Dobrich (t) Black Sea Dobrudzha pl. 100,000 150,569 96 6.100 0.915 14 Shoumen (t) Black Sea Kamtchiya 89,214 151,841 60 8.340 1.251 15 Targovishte (t) Black Sea Kamtchiya 40,659 62,460 65 50.647 7.597 16 Novi Pazar (t) Black Sea Provadiyska & 13,494 20,403 85 8.983 1.347 Devnenska 17 Provadia (t) Black Sea Provadiyska & 14,229 21,542 85 15.850 2.378 Devnenska 18 Popovo (t) Black Sea Rousenski Lom 17,948 37,717 65 31.140 4.671 19 Karnobat (t) Black Sea Tundzha 20,587 31,068 75 16.100 2.415 20 Belene (t) Danube Danube 9,986 15,033 12 63.407 9.511 21 Kozlodui (t) Danube Danube 14,892 22,506 69 21.876 3.281 22 Lom (t) Danube Danube 27,767 41,846 33 42.242 6.336 23 Rouse (t) Danube Danube 161,453 243,192 48 120.000 18.000 24 Silstra (t) Danube Danube 41,952 63,230 79 14.260 2.139 25 Svishtov (t) Danube Danube 30,507 45,887 68 6.610 0.992 26.Tutrakan (t) Danube Danube 10,369 15,558 78 10.070 1.511 27 Vidin (t) Danube Danube 57,395 86,421 81 14.400 2.160 28 Dulovo (t) Danube Dobrudzha pl. 7,018 35,000 41 21.244 3.187 29 Isperih (t) Danube Dobrudzha pl. 10,000 30,000 16 46.415 6.962 30 Botevgrad (t) Danube Iskar 21,545 32,480 54 31.602 4.740 31 Cherven Briag (t) Danube Iskar 16,036 24,140 97 2.996 0.449 32 Etropole (t) Danube Iskar 11,384 17,213 83 5.350 0.803 33 Kneza (t) Danube Iskar 12,808 19,268 14 78.889 11.833 34 Kostinbrod (t) Danube Iskar 12,220 18,330 81 13.800 2.070 35 Kremikovtsi (qt) Danube Iskar 16,232 48,696 75 0.500 36 Lukovit (t) Danube Iskar 10,027 15,155 14 71.819 10.773 37 Mezdra (t) Danube Iskar 12,445 18,771 89 3.000 0.450 38 Novi Iskar (t) Danube Iskar 13,445 20,168 75 20.000 3.000 39 Samokov (t) Danube Iskar 27,546 58,500 73 30.457 4.569 40, Sofia (t) Danube Iskar 1,091,772 2,037,000 75 0.000 58.125 41 Berkovitsa (t) Danube Ogosta 15,553 23,556 72 26.400 3.960 42 Biala Slatina (t) Danube Ogosta 13,923, 20,885 53 27.457 4.119

103 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Sewerage Sewerage Capital % of extension Cost .N Settlement Name River basin Catchment Area Resident PE as Name (River Valley) population street km MEuro network 78 20.600 3.090 43 Montana (t) Danube Ogosta 49,176 120,345 84 17.000 2.550 44 Vratsa (t) Danube Ogosta 68,975 104,135 91 5.148 0.772 45 Levski (t) Danube Osum 12,198 18,321 59 13.465 2.020 46 Lovech t) Danube Osum 44,146 85,667 37 35.510 5.327 47 Troyan (t) Danube Osum 23,332 32,570 54 68.762 10.314 48 Razgrad (t) Danube Rousenski Lom 38,948 60,000 93 15.145 2.272 49 Pleven (t) Danube Vit 121,880 183,224 7 70.918 10.638 50 Teteven (t) Danube Vit 11,498 17,381 74 9.426 1.414 51 Biala (t) Danube Yantra 10,074 15,176 33 93.945 14.092 52 Gabrovo (t) Danube Yantra 67,065 101,025 81 24.409 3.661 53 Gorna Oriahovitsa- Danube Yantra 48,096 102,535 Liaskovets-Dolna Oriahovitsa (t, t, t) _ _ _ 88 6.625 0.994 54 Pavlikeni (t) Danube Yantra 12,949 19,521 95 3.700 0.555 55 (t) Danube Yantra 24,775 53,333 34 31.539 4.731 56 Triavna (t) Danube Yantra 11,223 16,916 88 23.000 3.450 57 Veliko Tamovo (t) Danube Yantra 66,897 95,000 70 29.326 4.399 58 Kurdjali (t) East Aegean Arda 45,659 68,594 39 73.600 11.040 59 Smolian (t) East Aegean Arda 33,091 69,500 89 24.280 3.642 60 Asenovgrad (t) East Aegean Maritsa 51,936 78,174 84 12.000 1.800 61 Chirpan (t) East Aegean Maritsa 18,171 27,398 82 18.615 2.792 62 Dimitrovgrad (t) East Aegean Maritsa 45,768 246,425 89 7.800 1.170 63 Harmanli (t) East Aegean Maritsa 19,927 30,195 93 9.167 1.375 64 Haskovo (t) East Aegean Maritsa 80,303 130,000 95 15.500 2.325 65 Ihtiman (t) East Aegean Maritsa 13,593 20,567 99 2.155 0.323 66 Karlovo (t) East Aegean Maritsa 25,494 38,573 75 16.053 2.408 67 Nova Zagora (t) East Aegean Maritsa 25,220 38,180 85 10.795 1.619 68 Panagyurishte (t) East Aegean Maritsa 19,994 25,000 67 35.000 5.250 69 Parvomai (t) East Aegean Maritsa 15,370 23,285 63 82.870 12.431 70 Pazardjik (t) East Aegean Maritsa 78,855 216,666 99 1.000 0.150 71 Peshtera (t) East Aegean Maritsa 19,411 29,469 44 244.547 36.682 72 Plovdiv (t) East Aegean Maritsa 338,224 662,590 64 20.000 3.000 73 Radnevo (t) East Aegean Maritsa 14,496 21,807 4 63.620 9.543 74 Rakovski (t) East Aegean Maritsa 16,264 24,671 70 14.330 2.150 75 Stamboliiski (t) East Aegean Maritsa 12,580 19,005 89 16.146 2.422 76 Stara Zagora (t) East Aegean Maritsa 143,420 251,000 77 16.872 2.531 77 Svilengrad (t) East Aegean Maritsa 19,093 28,640 79 48.500 7.275 78 Velingrad (t) East Aegean Maritsa 24,818 37,514 77 10.176 1.526 79 Elhovo (t) East Aegean Tundzha 12,394 18,627 94 8.200 1.230 80 Kazanlak (t) East Aegean Tundzha 53,770 80,000 62 75.200 11.280 811Sven (t) East Aegean Tundzha 100,366 106,000 70 46.740 7.011 82 Yambol (t) East Aegean Tundzha 82,649 124,386 47 31.725 4.759 83 Gotse Delchev (t) West Aegean Mesta 20,426 30,800 66 20.145 3.022 84 Razlog (t) West Aegean Mesta 12,738 20,926 72 48.707 7.306 85 Blagoevgrad (t) West Aegean Struma 71,144 184,722 70 3.666 0.550 86 Dupnitsa (t) West Aegean Strurna 38,127 57,485 99 27.000 4.050 87 Kyustendil (t) West Aegean Struma 49,919 75,365 84 58.420 8.763 88 Pernik (t) West Aegean Struma 85,991 129,200 92 5.676 0.851 89 Petrich (t) West Aegean, Struma 29,606 44,678

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Sewerage Sewerage Capital N2 Settlement Name River basin Catecmeni Name Area Resident PE as %.of extension Cost (River V'alley) population street krn MEuro network 90 (t) West Aegean Struma 15,785 23,753 97 2.500 0.375 91 Sandanski (t) West Aegean Stnuna 26,507 40,043 92 4.100 0.615 TOTAL . 4,883,515 _ 466.213

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ANNEX V

Sensitivity Status of Settlements over 1 0,000 p.e within Defined TransboundaryRiver Basins

Sensitive Area Gray Area Settlement Struma River Basin Pernik * Kyustendil * Dupnitsa * Radomir * _ _ Blagoevgrad Petrich * Sandanski Mesta River Basin *______Razlog *______Gotze Delchev Maritsa River Basin * Plovdiv * Nova Zagora * Stara Zagora _*_ Ihtiman * Asenovgrad * Svilengrad * Dimitrovgrad * Haskovo * ______Harm anli * Velingrad * Radnevo * Arda River Basin Madan * ______Kardiali * ______Smolyan Twndja River Basin * SShven * ______Kazanlak Yambol * Elhovo * Kamobat

106 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

ANNEX VI

2001 Data for Wastewater Treatment and Sewerage Chlarges Reported by Selected Water Companies

Water Company EUR Stara Zagora 0.18 Varna 0.23 Kustendil 0.24 Gabrovo 0.19 Pernik 0.10 Sliven 0.08 Dimitrovgrad 0.06 Average 0.16

107 Bulgaria:Environmental Sequencing Strategiesfor EU Accession

ANNEX VII

Specific EU Directive Requirements for Landfill Permits, Acceptance Procedures, Control and Monitoring, Closure, Provisions for Existing Landfill sites and Reporting

Applications for a Permit (Article 7)

Bulgaria shall take measures in order that application for a landfill permit contains at least the following:

* The identity of the applicant and of the operator when they are different entities. * The description of the types and total quantity of waste to be deposited. * The proposed capacity of the disposal site. * The description of the site including its hydrological and geological characteristics. * The proposed methods for pollution prevention and abatement. * The proposed operating and monitoring plan. * The proposed plan for the closure and after-care procedure. * The financial security by the applicant or any other equivalent provision.

Conditions of the Permit (Article 8)

Bulgaria shall take measures in order that the competent authority does not issue a permit unless it is satisfied that:

* The landfill project complies with all the relevant requirements of the Directive. * The management of the landfill site will be in the hands of a competent technically trained person. * The landfill shall be run in such a manner that the necessary measures are taken to prevent accidents and limit their consequences. * Adequate provisions have been or will be made to ensure that all obligations as outlined in the Directive will be made. * The landfill project is in line with the relevant waste management plan. * Prior to the commencement of disposal operations, the competent authority shall inspect the site in order to ensure that it complies with the relevant conditions of the permit.

Content of the Permit (Article 9)

The landfill permit shall state at least the following

* The class of the landfill. * The list of defined types and the total quantity of waste, which are authorized to be deposited in the landfill.

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* Requirements for the landfill preparations, landfilling operations and monitoring and control procedures as well as provisional requirements for closure and after care requirements. * The obligation on the applicant to report at least annually to the competent authority on the types and quantities of wastes been disposed off.

Waste Acceptance Procedures(Article 11)

Bulgaria shall take measures in order that prior to accepting the waste at the landfill:

* The appropriate documentation is presented to ensure that the waste in question can be accepted at the site. * The operator should visually inspect the incoming waste. * A register should be retained containing the quantities and characteristics of the waste deposited, including origin, date of delivery etc. * The operator of the landfill shall always provide written acknowledgement of receipt of each delivery accepted onto the site. * If waste is not accepted at the landfill the operator shall immediately inform the competent authority of the non-acceptance of the waste. * A register of the quantities of waste kept at the site must be kept. * Bulgaria shall ensure that information on the quantities and, where possible, the type of waste going to such exempted sites forms part of the regular reports to the Commission on the implementation of the Directive.

Control andMonitoringProcedures in the OperationalPhase (Article 12)

Bulgaria shall take measures that control and monitoring procedures in the operational phase meet at least the following requirements:

* The operator of the landfill shall carry out a control and monitoring program. * The operator shall notify the competent authority of any significant adverse environmental effects revealed by the control and monitoring procedures. * At regular interval, at least a year, the operator shall report all monitoring results to the competent authorities for the purpose of demonstrating compliance with permit conditions and increasing the knowledge on waste behavior in the landfills. * The quality control and analytical operations to be carried out by competent laboratories.

Closure andAftercare Procedures(Article 13)

Bulgaria shall take measures in accordance, where appropriate, with the permit, a landfill or part of it and shall start the closure procedure:

* When the relevant conditions stated in the permit are met

* Under the authorization of the competent authority at the request of the operator

* By reasoned decision of the competent authority

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* A landfill may only be considered as definitely closed after the competent authority has carried out a final on-site inspection. * After a landfill has been definitely closed, the operator shall be responsible for its maintenance, monitoring and control in the after-care phase. The operator shall notify the competent authority of any significantly adverse environmental effects revealed by the control procedures and shall follow the decision of the relevant authority on the nature and timing of the corrective measures to be taken. * For as long as the relevant authority considers that a landfill is likely to cause a hazard to they envirornment and without prejudice to any community or national legislation as regards liability of the waste holder, the operator of the site shall be responsible for monitoring and analyzing landfill gas and leachate from the site and the groundwater regime in the vicinity of the site. Existing LandfUll Sites (Article 14)

Bulgaria shall take measures in order that landfills which have been granted a permit, or which are already in operation at the time of the transposition of this Directive, may not continue to operate unless the steps outlined below are accomplished as soon as possible and within eight years after the date agreed.

* The operator of a landfill shall prepare and present to the competent authorities, for their approval, a conditioning plan for the site and any corrective measures, which the operator considers will be needed in order to comply with the requirements of the Directive. * Following the presentation of the afore-mentioned plan, the competent authorities shall take a definite decision on whether operations may continue. * On approval of the site-conditioning plan, the competent authority shall authorize the necessary work and shall lay down a transitional period for the completion of the plan.

Obligation to Report (Article 15)

At intervals of three years, Member States shall send to the Commission a report on the implementation of this Directive. This Report should pay particular attention to the national strategies to be set in pursuance of Article 5.

110 Bulgaria: Environmental Sequencing Strategiesfor EU Accession

ANNEX Vm

Status of Landfill Development September 2003

Projects Status

1 Construction of Landfill for municipal Construction completed solid waste - Sofia . 2 Extension and constnuction of regional Started consiuction in 1999 but now at a stand still due landfill for Plovdiv. Rodopi and to illegal dunping on river terace Stambolijisi 3 Completion of regional municipal solid Started constuction before the program but had no waste landfill - Haskova. Mineralni HDPE. Money for leachate treatnent fility but bari estimated wrong volume of leachate. May not comply with regulations 4 Completion of regional municipal wilid Overall waste nanagement improvement program Still waste landfill - Vratza, Mezdra under constuction 5 Completion of regional municipal solid Funds were made available for the up grading of the waste landfill - Smolian facility but the municipality has refused to accept funds and co-operate 6 Conuction of regional landfill - I" stage completed., completion by 2003 l Harmnli 7 Completian of rogional municipal solid In full operation waste landfill-- madan I Completion of municipal solid vaste In full opertion landfill - Rudozem 9 Constnictim of regional municipal Construction has started solid waste landfill - Rousse and Ivo Pole 10 Constuction of regional landfill - Constucted and fully operational Sandaski, Strunrjamn IrI Constuction of hndfill with separate Constuction has commenced cells for muimcipaL conucion, mdnslrial and hazardous waste - Serlievo _ 12 Conuruction of regional muiicipal Has been completed amd now in operaion landfill- Tlroyan, Apri tzi 13 Construction of regional landfl - 1' cell consucted, awaiting approval Goma Mahna, Elm Palin 14 Consmution of regional landfill - Started constuction durng 2002 Ckiahova, Mijaja

15 Costuction of regional municipal Large percentage of constuctiw completed. landfill - Omourtag Cosmd has smce ceased due to disptute with L ~~~~~~~~~~conhs -a 16 Construction of regional landfill - Public Opposition IBozhurishte, Slivnitza, Dragoman I S Reconstrucio and miodemis ion of Undxr Consruction. First Cell is ready. Full operation by muicipal solid waste lndfil - 2003 Sbunme l9? Completion of consatucto of regional Under constuction

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=_ landfill - Pietritch 20 Completion of construction of Proposed regional site. Dispute over land and location. municipal solid waste landfill - Veliko Transport costs a problem. Tarnova-Goma, Oryahovitza- Lyaskovetz 21 Construction of landfill for municipal Under tender process waste - Pernik, Breznik 22 Construction of regional landfill for Under Tender process municipal landfill - Silistra, Kajnardzha 23 Construction of regional landfill - No activity to date Zlatatograd, Nedelino and Kirknova 24 Construction of Regional Landfill - No activity to date. Municipality disputes Pomorie, Nessabar 25 Construction of regional municipal Under tender process waste landfill - Trsarevo, Primorsko 26 Costuci( of regional municipal Curntly in operation solid wate landfill - yambol, Tundzha 27 Re-construction and modernization of Under tender process municipal solid waste landfill - Montana 28 Rehabiliation of an opeicast uranium Under cons lciin mine through the const0uction cl municpl* solid waste lhll 29 Construction of regional landfill - No progress, site selection problem. Svoge, Kostinbrod 30 Construction of regional landfill - Under going tender procedure for construction Pirdop, Zlatitza, Chelopech 31 Reconstruction and modernization of Have prepared the project and now are seeking funding to municipal solid waste landfill - Pleven begin and implement 32 Reconstruction and modernization of Part of ongoing project municipal solid waste landfill - Sliven 33 Reconstruction and modernization of Under going tender procedure municipal solid waste landfill - Razgrad, Isperih, Kubrat 34 Reconsuction d mod of solid wate lIfill - Dobrich - 35 Ccmstructiui of municipal sobid wate Recently completed and now commencmg operation landfill - Karlovo 36 Conrcion of repmal munca Under consic To be completed by 2003

__ solid woast landfll - Lovetdh 37 Construction of regional landfill for No progress. Land ownership problems municipal waste - Panagjiurshte

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ANNEX IX Proposed Regional Landfills

REGIONAL LANDFILL MUNICIPALITY POPULATION TOTAL SERVED NQ POPULATION 1. AITOS AITOS 36,002 RUEN 34,090 70,092 2. ANTONOVO 8,450 8,450 3. ASENOVGRAD ASENOVGRAD 73,862 RAKOVSKI 29,382 SADOVO 15,951 BREZOVO 9,507 PARVOMAY 35,018 CHIRPAN 29,20 11,235 2,04,163 B ELENE BELENE 12,919 NIKOPOL 14,723 SVISHTOV 49,875 LEVSKI 27,947 ______PAVLIKENI 33,215 138,679 5. BELOGRADCHIK BELOGRADCHIK 9,504 3,503 ______N_ LAKRESH 3,127 16,134 6. BOROVO BOROVO 8,534 BYALA 18,506 13,166 TSENOVO 9,031 POLSKI TRAMBESH 21,629 ______OPAKA 8,701 79,567 7. BOTEVGRAD BOTEVGRAD 38,056 _.- ETROPOLE 14,961 ______PRAVETS 9,041 62,058 B. BURGAS BURGAS 227,488 SREDETS 18,693 ______0KAMENO 13,954 260,135 9. BYALA SLATINA 34_293 BOROVAN 7,381 __ ZKNEHA 18,086 59,760 10. VARNA AKSAKOVO 17,774 _ VARNA 330,681 348,455 i1. VELIKO TARNOVO VELIKO TARNOVO 99,845 ELENA 13,002 ZLATARITSA 5,593 17,273 59,722 ______STRAZHITSA 17,674 213,109 12. "IN VIDIN 90,851

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TOTAL SERVED REGIONAL LANDFILL MUNICIPALITY POPULATION POPULATION N_ BREGOVO 8,501 BOYNITSA 2,596 KULA 7,974 GRAMADA 3,642 NOVO SELO 4,535 9,585 RUZHINTSI 6,24 133,933

97,137 13. VRATSA VRATSA 28,130125267 ______MEZDRA GABROVO 84,098 14. GABROVO 99,761 regional landfill and 15,663 household waste treatment faility

6,918 15. GORNA MALINA GORNAMALINA 23,387 30,305 ______ELIN PELIN 33,640 16. GOTSE DELTCHEV GOTSE DELTCHEV GARE EN 14,848 19 O HRADIDMOVO 11,905 60,393 114,857 17. DOBRICH DOBRICH DOBRICH-SELSKA 28,993 T'ERVEL 20,884 NIKOLA-KOZLEVO 9,706 181,276 _ ~~~~~~~KRUSHARI 6,836 10,399 1 8. DOSPAT DOSPAT SATOVCHA 18,11] BORINO 4,643 14,478 47,631 ______DEVIN 22,913^ 1 9. ELHOVO ELHOVO 6,706 29,619 _ 6,202 20. ZLATrrSA ZLATITSA CHAVDAR 1,434 NIERKOVO 3,95E PIRDOP 9,658 CBELOPECH 1,835 ANTON 1,707 KOPRIVSHTITSA 2,935 27,727 15,413 21. ZLATOGRAD ZLATOGRAD NEDELINO 8,417 51,693 _ ~~~~~~~KIRKOVO 27,863 _18,020 22. KAVARNA KAVARNA SHABIA 7,300 GENERAL-TOSBEVO 22,322 24,071 71,713 _ ~~~~~~~BALCHIK

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REGIONAL LANDFILL MUNICIPALITY POPULATION TOTAL SERVED N_0 POPULATION 23. KAZANLAK KAZANLAK 9,1290 GURKOVO 6,046 NIKOLAEVO 5,147 16,539 13,332 _TVARDITSA 15,915 148,269 24. KARLOVO KARLOVO 76,072 ______HISARYA 17,299 93,371 25. K_ARNOBAT KARNOBAT 32,771 SUNGUIRLARE 16,191 48,962 26. KOSTENETS KOSTENETS 15,949 IE1TIMA,N 19,047 SAMOKOV 46,217 ______BANYA ______DOLNA 5,026 86,239 27. KOSTINBROD KOSTINBROD 17,076 SVOGE 25,216f SLIVNITSA 10,845 BOZEIURISHTE 6,704 GODECH 7,044 ______DRAGOMAN 6,709 73,594 28. KOCHVO KOCB EKOCHERINOVO 6,829 RELA 4,227 BOBOVDOL 13,056 KYUSTENDHL 78,427 NEVESTINO 5,265 BLAGOEVGRAD 84,598 SIMnITI 16,642 9,237 BOBOS_HEVO 4,490 DUJPNITSA 57,302 1,566 281,639 29._KARDJALI KARDJALI 83,725 CBERNOOC]HENE 10,542 DJEBEL 10,196 MOMCHILGRAD 26,567S KRUMOVGRAD _27,382 9,863 STAMBOLOVO 7,036 _ ~~~~~~~ARDINO 16,081 191,392 30. LOVETCH LOVETCH 68,373

LETNITSA 6,348 74,721 31. LUJKOVIT ROMLAN 8,715 YABLANITSA 7,240 39,342 LUKOVIT 22,833 78,130 ______TETEVEN 25,726

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SERVED REGIONAL LANDFILL MUNICIPALITY POPULATION TOTAL POPULATION N° 9,731 113,587 ______UGARCH1N 16,145 32. MADAN MADAN 16,145 5,656 33. MALKO TARNOVO 5,656 34. MONTANA MONTANA 68,708 KRIVODOL 12,818 12,909 BERKOVITSA 24,906 LOM 39,956 CHIPROVTSI 6,195 GEORGI-DAMYANOVO 4,996 7,325 MEDKOVETS 6,204 __ VARSBETS 10,755 YAKIMOVO 6,536 201,308 35. NESEBAR NESEBAR 19,288 POMORIIE 28,829 51,913 ______BYALA 3,796 36. OMURTAG ONf URTAG 30,440 VARBITSA 13,633 KOT'EL 25,305 69,378

37. 17,058_ VALCBEDRAM 14,415 24,031 HAYREDIN 7,451 MIYA_ _ t0,858 73,813 38. PAZARDJIK PAZARDJIK 135,203 PESHTERA 23,442 BELOVO 12,182 LSICBEVO 6,778 BRATSIGOVO 12,040 220,713 _ ~~~~~~~SEPTEMVRI 31,068 9. ANAGYUJRISHTE PANAGYURISHTE 32,038_ 6,435 38,473 ______STRELTCHA 4.PERNIK PERNIK 113,477 ZENIEN 5,028 TRAN 6,131 KOVATCHEVTSI 2,581 BREZNI1K 9,585 164,036 _ ~~~~~~~RADONMI 27,234 59,251 41. PEtTRICH PETRICH 59,251 42. PLEVEN PLE~VEN 1165,741 _ [~~~~~~SKAR 9,469

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REGIONAL LANDFILL MUNICIPALfTY POPULATION TOTAL * N9 SERVED POPULATION DOLNI DABNIK 15,981 ULYANTSI 18,858 DOLNA MlTROPOLIYA 27,578 ______. PORDIM 8,311 245,941 43. PLOVDIV LOVDIV 376,276 NSARITSA regional landfill 30,734 and KALOYANOVO 14,288 household waste treatment facility 23,508 RODOPI 41,862

PERUSHTITSA 5,565 SAEDNENIE 12,39' ______KRICHIM 9,36 PROVADIA 513,987 PROVADIA 28,365 DALGOPOL 16,044 egional landfill and VETRINO 7,240 ousehold waste treatment DOLNI CHIFLIK 20,804 aility BELOSLAV 12,716 AVREN 8,772 VALCHIDOL 13,906 SUVOROVO 7,992 ______DEVNYA 10,075 45. RADNEVO 125,914 RADNEVO 26,085 STARA ZAGORA 179,980 OPAN 4,468 GALABOVO 17,511 228,044

46 RAZGRAD RAZGRAD 67,975 LOZNIISA 16,833 *SPERIH 29,922 ZAVET 13,741 KUBRAT 28,272 ______SAMUIL 10,652 47. RAZLOG 167,395 RAZLOG 21,223 *BANSKO 13,991 ______BELITSA 11,943 47,157 48. RAKITOVO RAKITOVO 16,124 YAKORU_DA 11,189 BATAK 7,958 _VELINGRAD 44,164 79,435 49. RUDOZEM RUDOZEM 11,670 11,670 50. RUSE RUSE 201,844 VETOVO 21,135 IVLANOVO 12,31 ______L__o POLE 14,65_

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TOTAL SERVED REGIONAL LANDFILL MUNICIPALITY POPULATION POPULATION _- TSAR KALOYAN 9,804 259,752

45,463 51. SANDANSKI SANDANSKI KRESNA 6,764 7,586 59,813 ______STRUMYANI 46,647 52. SEVLEEVO SEVLIEVO 13,551 SUHINDOL 3,935 64,133 73,992 53. SILISTRA SELISTRA KAYNARDJA 6,145 SITOVO _ __ 8,043 DULOVO 36,444 _ 129,031 _ALFATAR 4,407 49,699 54. SMOLYAN SMOLYAN LAKI 4,919 BANITE 7,652 10,03 72,304 ______CHEPELARE 14,631 __ - 55. SOZOPOL SOZOPOL PRlMO0RSKO 4,117 11,11( 29,858 ______TSAREVO 1,223,884 1,223,884 56. SOFIA MUNICIPALITY SOFIA MUNICIPALITY 41,388 57. TROYAN TROYAN 4,45 45,840 _ APRI_LTSI 71,480 58. TARGOVISHTE TARGOVISHTE__ 41,245 112,725 ______POPOVO 31,078 59. HARMANLI HARMANLI MADJAROVO 4,079 LYUB_IMETS 12,173 TOPOLOVGRAD 17,715 SIMEONOVGRAD 11,285 27,096 103,426 ______SVILENGRAD 113,027 60. HASKOVO RASKOVO NIMIRALNI BANI 7,188 DIMITROVGRAD 74,003 194,218

122,941 61. SHUMEN SHUMEN 9,051 NOVI PAZAR 25,078 VELIKI PRESLAV 18,549 HrrRIlNO 12,189 20,447 KASPICHAN 12,014 13,301 233,570 ______VENETS 94,3451 62. YAMBOL YAMOL

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REGIONAL LANDFILL MUNICIPALITY POPULATION TOTAL SERVED Ng POPULATION "Solid household waste NOVA ZAGORA 47,946 processing factory" IUNDJA 33,447 SLIVEN 146,105 ______STRALDJA 17,286 339,129 63. NO ALTERNATIVE HAS GLAVINITSA 15,261 15,261 BEEN PROPOSED TUTRAKAN 21,948 21,948 TOTAL 1NIABITANTS: 262 municipalities 8,656,815' 8,656,815

119 Bulgaria: Environmental Sequencing StrategiesforEUAccession

ANNEX X

Status of other Waste management Project outlined in tihe 'National Waste Management Program 1999' Project Status Feasibility study for construction of a National Completed Hazardous Waste Treatment Centre Commencement of construction of national No progress hazardous waste treatment centre Construction of 4 landfills for hazardous waste Construction has commenced to develop disposal hazardous waste cells as part of the ISPA funded projects of Sevlievo landfill development and also at Rousse. However there has been no movement regarding actual designated hazardous waste landfills Further development of the system for separate Plan has been prepared but not adopted collection of hazardous hospital waste Study and construction of incineration plant for No progress hazardous hospital waste / Sofia, Haskovo, Vratza, Vama, Petrich Construction of centralised composting plants Site selection process commenced for two central composting units at Plovdiv and Yambool/Sliven Construction of incineration plant for municipal No progress solid waste - first stage

120 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

ANNEX XI

Suggested Content of a Regional Waste Managenent Plan Background The Plan should provide, as far as practical the following information regarding the service area:

* A general description including relevant topographical, geological, hydrological, and hydrological features * A description of the size and distribution of the population with reference to the number of domestic households * A description of the nature, scale and distribution of commercial, industrial and agricultural activity and other significant waste generating activities, such as tourism. * A description of transport Infrastructure * A description of groundwater usage and assessment of groundwater vulnerability * A summary of relevant land use considerations, including areas designated for environmental protection etc.

Current situation regarding waste management

Waste Generation

The Plan should specify, to the extent possible the quantities of waste arising within the area, classified under the following descriptions, insofar as is possible:

- Household waste collected by municipality - Household waste delivered to waste facilities and other bring facilities - Other household waste - Litter and street sweepings - Commercial waste - Industrial waste not elsewhere specified - Construction and demolition waste - Contaminated soils - Ash and other incineration residues - Mining and quarry waste - Medical wastes (clinical, dental, veterinary) - Sewage sludges - Water treatment sludges - Industrial sludges - Agricultural sludges

Waste movements throughout the area as classified above:

Quantities of waste arising with the area, classified under the following descriptions: * paper * glass * plastic * metals * textiles * putrescible waste

121 Bulgaria:Environmental Sequencing Strategiesfor EU Accession

The quantities of waste arising within the area, classified under the following descriptions: * electrical and electronic goods * batteries and accumulators * oils * polychlorinated biphenyls (PCBs) * tires * vehicles * packaging waste

Waste Collection operate The Plan should describe the waste collecting systems (including bring facilities), which within the area and their capacity, and specify arrangements for the segregation and separate collection of specific types of waste.

Waste Prevention and Minimisation out The Plan should describe measures in support of waste prevention and minimisation carried obtained, throughout the area and to the extent that information is available or may reasonably be by businesses and industries, and an assessment of the impact of such activities.

Waste Recovery the The Plan should describe and summarise waste recovery activities carried out throughout recovery area. It should specify the volumes and types of waste concerned and estimated waste rates, and outline the position regarding markets or uses for recovered materials or products.

Waste Management Facilities all The Plan should provide, to the extent possible, the following information in respect of which facilities for the collection, handling, storage, treatment, recovery and disposal of waste, are located throughout the area:

* Location * Operating Body * Process involved * Annual waste input capacity * Requirements regarding waste acceptance * Current waste input, under the headings specified above * In the case of a landfill facility, the estimated total remaining capacity * Where relevant, current output and utilization of recovered materials * Where relevant, current output and final disposal of residues

Other Relevant matters authority The Plan should specify the cost of waste management activities undertaken by the local in waste and revenues accruing to the authority from such activities, and indicate any deficiencies management infrastructure or any other matters, which inhibit optimum waste management

Anticipated Developments over the Period of the Plan

122 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

The Plan should provide an assessment of likely trends or developments which may be expected to have an impact on the quantities and types of waste arising, the need for waste recovery/disposal facilities, or other aspects of waste management, and this assessment should include:

* The effect of measures to prevent or minimise waste production or the harmfulness of waste * Trends in population distribution and activity in the commercial, industrial and agricultural sectors * Trends in waste management, including private sector involvement in waste collection, recovery and disposal * Pending Community acts in relation to waste management and environmental standards

Where appropriate and feasible, possible alternative scenarios should be described Waste Management policy

The Plan should provide an evaluation of policy options open to: * the provision of services and waste management facilities * in relation to the management of individual waste streams * should assess the environmental impact and cost implications of each option In stating the waste management policies and objectives of the area and the priorities assigned to them, the Plan should outline the reasons for their adoption and means for implementation of the waste management policy over the period of the plan. General

The Plan should:

* Outline proposals for monitoring of implementation of the Plan, in particular with regard to the achievement of waste recovery or other targets * Outline measures to provide ongoing and improved data and information regarding waste management

Roles and Responsibilities

The Plan should describe the respective roles of: * local authority * Other public authorities * Private interests * The public

In relation to waste management within the relevant functional areas * Describe organizational arrangements and institutional responsibilities i.e. between the various ministries and municipalities * Specify proposed nationwide measures to require encourage or support the involvement of private interests and the public in support of waste management policies

123 Bulgaria: EnvironmentalSequencing Strategiesfor EUAccession

Waste Prevention and Recovery

The Plan should include information with regard to:

* promotion of public awareness and dissemination of information and advice regarding waste prevention, minimisation, segregation and recovery, in liaison with other bodies as appropriate. * other measures in support of waste prevention, minimisation and recovery, including infrastructural development and the provision of support, assistance or incentives to householders and private interests * the need for co-operation with and assistance for voluntary organisations involved in waste activities * the segregation and separate collection of recoverable wastes, including legal requirements on waste procedures * home composting of organic household wastes * Involvement (through joint ventures or otherwise) by municipalities in waste recovery operations * the scope for energy recovery from waste * targets for waste recovery

Management of Packaging and Packaging Waste

The Plan should contain a separate section dealing with the management of packaging waste, outlining proposals in support of the objectives and measures specified in European Parliament and Council Directive 94/62/EC.

Waste Collection and Disposal

The Plan should include information on or otherwise have regard to:

* The rationalisation, development or improvement of existing waste collection, handling and disposal infrastructure, including the closure and aftercare facilities and the provision of new facilities * Measures including co-operation with all municipalities with a view to the application of the proximity principle, that is to say enabling waste to be disposed of in one of the nearest appropriate installations, by means of the most appropriate methods and technologies in order to ensure a high level of protection for the environment and public health * The application of the "polluter pays principle".

124 Bulgaria: Environmental Sequencing Strategiesfor EUAccession

References

Government of Bulgaria. 1999. National Program for Priority Construction of Urban Waste Water Treatment Plants for Populated Areas with over 10,000 equivalent Inhabitants in the Republic of Bulgaria, Ministiy of Environment and Water.

Government of Bulgaria. 2003. Implementation Program for Directive 91/271/EC Concerning Urban Wastewater Treatment. Ministry of Environment and Water Sofia. Bulgaria. Government of Bulgaria. 2003. Plan for Implementation of Directive 1999/31/EC on Landfill of Waste. Ministry of Environment and Water Sofia. Bulgaria.

Commission of the European Communities. Communication from the Commission to the Council and the European Parliament. Roadmaps for Bulgaria and Romania. Brussels 13.11.2002 Report COM (2002) 624.

Commission of the European Communities. Communication from the Commission. The Challenge of Environmental Financing in the Candidate Countries. Brussels, 8.6 .2001 Report COM (2001) 304 Final.

Commission of the European Communities. Directorate General for Enlargement. Accession negotiations. Bulgaria Draft Common Position. Negotiating Chapter 22.Brussels 3.7.2001.

Government of Bulgaria. Pre-Accession Economic Program 20022-2005. Agency for Economic Analysis and Forecasting. August 2002. Sofia. Bulgaria.

Government of Bulgaria. National Strategy. Environment Sector. Ministry of Environment and Water. October 2000. Sofia Bulgaria.

Government of Bulgaria. National Waste Management Program. Ministry of Environment and Water. June 1999.Sofia Bulgaria.

Government of Bulgaria. Intergovernmental Conference on the Accession of Republic of Bulgaria to the EU. Negotiating Position on Chapter 22:Environement. PHARE (1999D) BUL- 11l Development of the Bulgarian Implementation Program for the Approximation of the EU Environment Legislation. Prepared under PHARE contract no. 96- 0863.00. Final Report. Sofia Bulgaria.

PHARE (1999D) BUL-109. Provision of Technical Assistance in the Approximation of Waste Legislation. Prepared under PHARE contract No.96-0863.00.Final report. Sofia. Bulgaria. PHARE (1999D) BUL- 110 Provision of Technical Assistance in the Approximation of Water Legislation for Bulgaria. Prepared under PHARE contract No.96-0863.00. Final report. Sofia. Bulgaria.

PHARE (DM.BL.1401/HWM) Assistance in Development of National Plan for Hospital Waste Management: Bulgaria. Contract OSS BL-0081.00-14.01.Sofia. Bulgaria.

125 Bulgaria:Environmental Sequencing Strategiesfor EUAccession

Ministry of Environment and Water (2000B). Results of the Bilateral Screening, 5-9 July 1999. Chapter 22 Environment. Screening A list. Available also from the website of the MOEW.

National Statistics Institute (NSI) (1999 to 2001). The Annual Bulletin on Environment. Sofia. Bulgaria.

Ministry of Environment and Waters .1999A. ISPA Strategy Paper for Environment. Sofia. Bulgaria.

World Bank. Working Paper No.30. March 2001. Bucknall, Cestti, Damianova. Bulgaria The Challenges of Complying with the EU Environmental Directives

World Bank. Bulgaria Public Expenditure Issues and Directions for Reform. A Public Expenditure and Institutional Review: Report No. 239790-BUL. August 2002.

World Bank Technical Paper no. 533. Bernard Funck. Expenditure Policies. Toward EU Accession. 2002.

International Monetary Fund. IMF Country Report No.03/206. Bulgaria: Third Review Under the Stand-By Arrangement, Washington D.C. Also available http://www.imf.org

ECOTEC Research and Consulting in association with Milieu. Priority Environmental Projects for Accession (PEPA). Inception Report to DG ENV: Draft for Comments. 2000.

Ministry of Environmental Protection and Regional Development of the Republic of Latvia. Directive Specific Implementation and Financing Plan. Council Directive 91/271/EEC Concerning Urban Waste Water Treatment. 2001. Riga. Latvia.

EDC Ltd. and EPE asbl. (1997) Compliance Costing for Approximation of EU Environmental legislation in the CEEC. A Study commissioned by the EU Commission. Brussels. Belgium.

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