E1776

REPUBLIC OF v18 MINISTRY OF REGIONAL DEVELOPMENT AND PUBLIC WORKS

Public Disclosure Authorized

ENVIRONMENTAL IMPACT ASSESSMENT

ON THE COMPLETION OF CONSTRUCTION WORKS FOR LUDA YANA DAM Public Disclosure Authorized LUDA YANA DAM

Public Disclosure Authorized Public Disclosure Authorized

Sofia, May 2009, Final Document

Luda Yana Dam EIAS

CONTENTS

І. EXECUTIVE SUMMARY ...... 1 ІІ. LEGISLATIVE AND POLITICAL SYSTEM AND ENVIRONMENTAL MANAGEMENT ORGANIZATIONAL DIAGRAM ...... 6 ІІІ. OVERVIEW OF LUDA YANA DAM PROJECT ...... 7 ІV. OVERVIEW OF ENVIRONMENTAL COMPONENTS AND FACTORS ...... 12 4.1. AIR ...... 12 4.1.1 Climate ...... 12 4.1.2 Air Quality ...... 18 4.2. WATER ...... 18 Surface water ...... 18 Ground water ...... 20 4.3 GEOLOGICAL ENVIRONMENT ...... 21 4.5. WASTE ...... 24 4.6. HARMFUL PHYSICAL FACTORS – NOISE ...... 24 4.7. FLORA ...... 24 4.8. FAUNA ...... 26 4.8.1 Ichthyofauna ...... 26 4.8.2 Herpetofauna (Amphibians and Reptiles)...... 26 4.8.3 Mammal Fauna ...... 27 4.8.4 Ornitofauna ...... 30 4.9. LANDSCAPE ...... 33 4.10. SOCIAL AND CULTURAL ENVIRONMENT, HEALTH FACTORS...... 33 4.11. CULTURAL AND HISTORICAL HERITAGE ...... 34 V. EVALUATION OF THE EXPECTED ENVIRONMENTAL AND SOCIAL IMPACTS RELATED TO THE IMPLEMENTATION OF LUDA YANA DAM ...... 34 5.1. AIR ...... 34 5.1.1 Climate ...... 34 5.1.2 Air Quality ...... 34 5.2. WATER ...... 37 Surface water ...... 37 Groundwater ...... 43 5.3. GEOLOGICAL ENVIRONMENT ...... 43 5.4. SOILS ...... 44 5.5. WASTE ...... 45 5.6. HARMFUL PHYSICAL FACTORS ...... 47 5.7. PLANTS ...... 48

Luda Yana Dam EIAS

5.8. ANIMALS ...... 48 5.8.1. Ichthyofauna ...... 49 5.8.2 Herpetofauna (Amphibians and reptiles) ...... 50 5.8.3. Mammal Fauna ...... 50 5.8.4. Ornithofauna ...... 50 5.9. LANDSCAPE ...... 51 5.10. HEALTH FACTOR AND SOCIAL SIGNIFICANCE ...... 52 5.11. SAFETY OF THE LUDA YANA DAM ...... 53 5.12. TRANSBORDER EFFECT ...... 58 5.13. SOCIAL IMPACT ...... 59 VІ. ANALYSIS OF ALTERNATIVES ...... 59 VІІ. ENVIRONMENTAL MANAGEMENT PLAN ...... 62 VII.A. ENVIRONMENTAL MITIGATION PLAN ...... 62 VІІ.B ENVIRONMENTAL MONITORING PLAN ...... 64 VIII. PUBLIC HEARINGS ...... 66

APPENDICES

1. Annex 1 TOR for EIA 2. Annex 2 Environmental Mitigation Plan 3. Annex 3 Environmental Monitoring Plan 4. Annex 4 Methodologies and Sources Used and quoted in the Environment Impact Assessment Statement 5. Annex 5 Wastes classification 6. Regulations 7. Topographic map 8. Diagram of Panagurishte Water Supply Complex 9. Luda Yana dam map 1:1 000 10. Sredna gora Protected Area Map 11. Forest map including Luda Yana dam 1:10 000 12. Cross section of Luda Yana dam wall 1:500 13. Photos 14. List of Luda Yana Dam designs 15. Opinions and minutes of meetings held in Panagurishte municipality, and VIK EOOD Panagurishte in 2007 –2009. 16. Protocols of laboratory analysis of water

Luda Yana Dam EIAS

ABBREVIATIONS & ACRONYMS

AIM Archaeological Institute and Museum BAN Bulgarian Academy of Sciences BD Basin Directorate VIK Water supply and sewerage company EU European Union EEC Expert Environmental Council EPA Environmental Protection Act EEA Environmental Executive Agency IWI Institute on Water Issues IPP Institute for research and design MRDPW Ministry of Regional Development and Public Works MOEW Ministry of Environment and Water EIA Environmental Impact Assessment NGO Non Government Organizations ALV Admissible limit values DWTP Drinking water treatment plant RIEW Regional Inspectorate of Environment and Water RIHSC Regional Inspectorate on Health Safety and Control WSS Water supply system CMS Central measuring station KOPS Committee for Environmental Protection BCA Bulletin for Construction and Architecture UF University of Forestry UASG University of Construction, Architecture and Geodesy MS Methodologies and Sources

Luda Yana Dam EIAS

І. EXECUTIVE SUMMARY

BACKGROUND

The Environmental Impact Assessment report (EIA) on the completion of construction works for Luda Yana Dam has been developed following the submission of the Environmental Due Diligence Report (EDD) prepared in 2007 by the Ministry of Regional Development and Public Works (MRDPW) to meet the World Bank policy requirements on Environmental Assessment. This document is part of the documentation required for approval of the World Bank assistance requested by the Government of Bulgaria (GoB) to finance activities related to municipal infrastructure development through completion of the Luda Yana water supply dam.

This EIA report has been developed to meet the Bank requirements as stated in the ToR (Annex I) and to comply with the effective environmental legislation in the Republic of Bulgaria (RB).

OVERVIEW OF THE LEGISLATIVE AND PPOLITICAL SYSTEM AND ORGANIZATIONAL DIAGRAM REFERRING TO THE ENVIRONMENTAL MANAGEMENT

Environmental protection is a country policy priority. Depending on the classification of infrastructure projects they can be either subject to a mandatory EIA or subject to assessment of the need for an EIA. Luda Yana dam, which has a total capacity of 19,94×106 m3 would be subject to a mandatory EIA in accordance with the new legislation (2003) (Appendix 1 to the Environmental Protection Act – EPA), because the construction works have started prior to the establishment of the EIA procedure and the dam was already granted a construction permit based on which some works started; this construction permit has not been cancelled and is still valid. Therefore, no EIA would be required under Bulgarian law for completing the construction. However, an EIA is required for World Bank financing. This EIA report presents the current normative documents of the RB that have to be complied with in the course of work, as well as those required by the Bank. The organizational diagram referring to the environmental management is presented in Appendices (e.g., table in Regulations).

LUDA YANA DAM PROJECT

The construction of Luda Yana dam started in 1986 and its implementation continued throughout the years (Chapter III) in compliance with the technical detailed designs (following the design stages effective in those years) until its suspension in 2000 due to lack of financial sources. The design has been developed in line with the effective regulations applicable in 1986 with regard to the security and safety of the dam wall and the facilities thereto.

In 2007, based on a contract with Vodosnabditelen complex OOD, town of Panagurishte, a Comprehensive feasibility study for continuation and completion of construction works for Luda Yana dam - Panagurishte was prepared. This Feasibility Study incoroporated, to a large extent, the recommendations given in the Environmental Due-Diligence Report of 2007 including the existing situation and the performed construction, updating of hydrological information (Appendices 8: Designs for Luda Yana Dam).

The need for continuous normal water supply in the Municipalities of Panagiurishte, Pazardjik and Strelcha is urgent. During the summer low water period a water rationing regime is imposed in the Municipality, while during the spring and autumn high-water seasons the water quality is poor. Currently, the water transferred from the Maritza River terrace comes from a system with 20-year long service life, suffering of frequent accidents.

1 Luda Yana Dam EIAS

ENVIRONMENTAL BASELINE CONDITIONS AND CURRENT STATUS OF THE DAM SITE

The river eco system upstream of the dam will be transformed into a water reservoir eco system as 142 ha will be covered by water permanently. The dam wall, classified as ‗large‘, and requiring securing of operational safety, will be situated at 2 km above the town of Panagurishte (classification of dam walls by the International Committee of Large Dams according to which dams exceeding 15 m height are classified as large).

The partially constructed Luda Yana dam is located downstream the confluence of three tributaries of Luda Yana River (namely Okoshka, Muleiska, and Garmidol). The run-off of the river including these streams is uneven in seasonal terms and naturally has a very low or even zero flow for part of the year, especially during summer time. Currently, the natural flow of the river is unimpeded because its flow is maintained through an outlet constructed beneath the partially completed dam. During the construction, filling and operation of the dam, an environmental flow will be maintained. The volume of this flow, which will vary seasonally to approximate the natural hydrology, has been calculated, using an accepted methodology, to maintain good environmental conditions downstream. The construction and operation of the dam will not have a negative impact on any protected habitats or sensitive ecosystems. While complete details of the size and extent of the reservoir will only be known when the detailed designs are completed, based on existing information the MoEW confirmed that only the sanitary-protected zone and not the dam or any part of the reservoir itself will fall within the territory of a protected area (the Sredna Gora Protected Area, which is also a Natura 2000 site (code BG 0002054). The purpose of the sanitary-protected zone of the dam is to maintain natural vegetation cover to prevent erosion and sedimentation or pollution of the reservoir water. According to MoEW, the management regime of the sanitary-protected zone of the dam is consistent with the goals of the Natura 2000 and favorable to the management of protected area. Also, there are no endangered or protected species which will be adversely affected by the change in the hydrological regime resulting from construction and operation of the dam.

The status of the environment surrounding the Luda Yana dam site has been evaluated based on inspection of the territory, field research, review of the available technical data provided by the Regional Inspectorate of Environment and Water (RIEW) in the town of , other existing relevant literature and survey data. The area of the Luda Yana Dam is not in a natural state but has been significantly impacted by the construction works which were carried out in the past and then stopped due to lack of funds. The construction of the dam wall has been implemented up to 30 m high (elevation 568,25 m above sea level) out of a total design height of 43,50 m, which represents about 70% completion of the entire planned wall. Other construction works already finalized at the site include: those for the water intake tower, 70% of the counter filtration measures and other auxiliary or temporary works, the diversion tunnel, the stone quarry, the clay pit and the humus depot, which remained opened since the beginning of the works, the excavations of the spillway and the chute. Currently the project site is being used by Hydrostroy, the contractor of the dam wall. The road to the mountain chalet Bunay has been diverted to pass around the flooded area, but is currently not asphalted. Although a DWTP is envisaged to be constructed nearby the dam, currently there is no design available for its construction. The construction materials extracted at the quarries meet the current Bulgarian standards for dam construction and are adequate for dam wall constructions.

The river eco-system is currently negatively affected from the suspended dam construction. A substantial part of the forest has been cut and a considerable part of the humic soils has been cleared and deposited away from the site. This has contributed to an accelerated erosion process especially on the right bank after construction suspension in 2000. The eroded terrain, clearing of forest and removal of the humic soils have impacted the herpetofauna, the mammals and the ornitofauna at the dam site. The flow of the river is not currently impeded because it continues to flow through the diversion tunnel constructed in the past. However, the river at the dam site and downstream from the site naturally experiences strong fluctuations in flow volume, with high flows in spring and little or no flow during summer months. As a result the ichthyofauna is limited at the dam site.

2 Luda Yana Dam EIAS

From the most recent available information on groundwater and surface water quality collected from Municipality of and performed by the National Center for Hygiene, Medical Ecology, and Nutrition during 1995-2003, the water quality fails to comply with the drinking water requirements for oxidability, turbidity, ammonia and nitrite indicators, manganese concentrations, and microbial indicators. Recent local research study (2005) conducted analysis of waters of Luda Yana River from the region of ―Assarel-Medet‖ Company and the town of Panagyurishte and found increased levels of Pb, Cu, Cd and cyanide concentrations in the river waters in comparison with the current hygienic norms adopted for the country. This prompts to the need of treating the water before it is supplied to local consumers, although the ―Assarel-Medet AD‖, which has been privatized, is performing continuous monitoring of water, air and soil quality at the company site. Since 2005 Assarel-Medet has not been releasing waste water into the watershed of Luda Yana Dam and is not a possible polluter of the dam in the future. Air quality monitoring is carried out pursuant to the IPPC (Integrated Pollution Prevention and Control) Permit issued by the MoEW (a document required according to the Bulgarian law to permit operation of a facility). EEA at the MoEW carries out monitoring and controls compliance with the normative quality requirements stipulated in the permit. The Water Treatment Plant is envisaged to be constructed during project implementation. The current soil pollution at the dam site is not known but it will be analyzed during the update of the dam feasibility study and design. Based on land use and topography there is no reason to expect significant pollution of soil at the site will be found.

From a social perspective, the suspended construction of Luda Yana Dam has left the town of Panagurishte and settlements in the municipalities of Panagurishte, Pazardzhik and Strelcha with inadequate water supply. This issue became a major concern for the population during the summer of 2008, when the region was affected by the most severe water supply rationing that ever occurred in the country.

POTENTIAL ENVIRONMENTAL IMPACTS

The main environmental impact will be the creation of a lake upstream of the dam where the water would be stored. This will change the existing riverine ecosystem to a lacustrine ecosystem with impacts on the flora and fauna communities. However, the areas which will be converted do not include critical habitats or resources for endangered or protected species. The total volume of the reservoir (19,941×106 m3) is not expected to be significant enough to create seismic risks or other severe environmental damage. A substantial part of the potential negative environmental impacts resulting from the construction of Luda Yana dam have already occurred due to the works already undertaken, as described above. Most of the forest and other vegetation on and around the site has already been cut and has not regrown. Completion of the dam including restoration of the landscape and vegetation and specific counter-erosion measures will have a positive impact compared with the current situation. The existing dam wall (30 m already constructed) will provide for the settlement of runoff from the construction site during the completion of works for Luda Yana Dam, reducing the risk of polluting the river water. On the former agricultural lands a few fruit trees have remained and some lands have limited potential to be used as grazing land.

Overall, the construction related impacts for completion of the dam are likely to be localized and can be prevented by applying international construction practice and planning. Such potential impacts may be related to: (i) air pollution/dust, noise, vibration, and access restriction, (ii) improper disposal of construction related waste; (iii) temporary pollution of soil and surface waters due to accidental spillage of fuel and oil from construction activities; (v) safety hazards including worker safety; (vi) damage to remaining trees and vegetation, and (vii) chance finds of physical cultural resources. These impacts will be properly managed

1 Based on the previous design the volume of the reservoir was calculated as 19.94 million m3 but this included also the demand for both irrigation and water supply; storage volume may decrease at 19.55 million m3 under the revised design if water demand for irrigation is excluded.

3 Luda Yana Dam EIAS during the construction phase by the contractor and closely supervised by PIU and designated supervisor engineer.

Potential environmental effects due to the existence and operation of the future dam and its reservoir may be related to: (i) changes in downstream morphology of riverbed and banks due to altered sediment loads of the river that would result in increased local erosion; (ii) changes in downstream hydrology (total flows, seasonal flows, short-term fluctuations); (iii) changes in downstream water quality (e.g., nutrient load, temperature); (iv) reduction of biodiversity and river ecosystem due to blockage of movement of local species (e.g. fish); and (v) impacts on existing infrastructure such as roads and bridges. These potential impacts can be reduced and managed through mitigation and monitoring measures outlined in the Environment Management Plan (Section VII of this study; summary presented in the following section).

Completion and proper operation of the Luda Yana dam will have a positive impact as it will stabilize downstream flows of the Luda Yana River, with the ensured continuous release of the minimum acceptable runoff (environmental flow). This environmental flow was calculated in accordance with relevant Bulgarian legislation following a model based on determining the minimum flow required to maintain downstream species richness. This is expected to contribute to the formation of stable ichthyocenosis in the dam area. The population of the municipalities (45, 000 inhabitants) will get normal continuous water supply of potable water at good quality (the design of DWTP and its construction are forthcoming – page 6 of EIAS), and this will open opportunities for development of recreation and tourism related to the landmarks of history and archaeology in the area.

TRANSBORDER EFFECTS The Luda Yana River is a small tributary of the Maritsa River which enters Turkey and Bulgaria downstream of Bulgaria. The mean flow at the Luda Yana dam site is 790 l/sec, compared with a mean flow of 107,908 l/sec for the Maritsa river at the border where it exits Bulgaria. During the construction period there will be no interruption or reduction in flow of the river and measures will be taken to avoid pollution of the water. During the impoundment period there will be a reduction in the river flow downstream of the dam site as part of the flow will be captured to fill the reservoir. The amount of the reduction will depend on the reservoir size, filling period and precipitation levels but even with rapid dam filling (less than one year) the impact on the flow of the Maritsa river at the border would be less than 1%.

SUMMARY OF THE ENVIRONMENTAL MANAGEMENT PLAN (EMP)

The EMP provides a thorough presentation of mitigation measures proposed to reduce the adverse consequences resulting from the construction works and the operation of the future dam. The mitigation measures will be further refined once the FS and detailed designs for this dam works are updated. The measures during construction include: site management and institutional controls limiting access at the site during construction works and restricting land and water use where appropriate; health and safety protection for workers and population – air pollution monitoring, noise, use of protective working equipment, communications during works; contingency planning and emergency response including on-site and community emergency response, incident reporting, first aid procedures and equipment; waste management and soil removal and transport mitigation measures; protection of fauna and flora species (detonation works); and compliance with dam safety regulations. Mitigation measures for the operational phase include maintaining the required environmental flow, the sanitary protection zones and implementation of the dam safety plans.

The EMP also summarizes a series of environmental monitoring actions aimed at measuring contamination in air, surface and groundwater, drinking water and sediments in the river beds, during construction and during operation. Monitoring parameters, including specific physical and biological parameters, location and

4 Luda Yana Dam EIAS frequencies are also provided. The monitoring program will be refined based on the updated FS and detailed design to clearly define monitoring protocols for the various parameters on the basis of future dam operating rule including features built such as outlet valves, gates or relevant features that would physically allow environmental flow releases. This will ensure that the stipulated environmental flow of 0.17 m3/s calculated based on clear national procedural bases and following the EU Water Framework Directive is being met.

Institutional arrangement and estimated costs for implementing the mitigation and monitoring are also described, with costs to be refined with completion of the detailed design. Implementation will be primarily accomplished through a project management unit within the MRDPW and supported by staff and governmental and private agencies relevant to the project.

ALTERNATIVES CONSIDERED

This EIA identifies and evaluates several alternatives to the proposed project discussed during the earlier design phase, including the ―no action‖ alternative; alternatives related to location of the dam and of the drinking water treatment plants (e.g., building the dam on another river, further from the Panagurishte town, or building several smaller dams); type of dam wall and related facilities alternatives (considering the seismic magnitude; hydrological and geological information; need of intake water town or front spillway with chute); other alternatives considering rehabilitation of the existing water mains from Maritsa River or demolishing the partially constructed wall. The ―do-nothing‖ alternative was rejected since Luda Yana dam is considered the only feasible water supply source for the surrounding. The proposed location and design were selected based on technical, environmental and social considerations.

CONSULTATION WITH AFFECTED GROUPS

An extended public consultation process has been implemented for the proposed project at national and local levels on several occasions during project preparation; initial public meetings were held on the EDD Reports and social due diligence reports in the Panagurishte municipality in October and December 2007. Final public consultations were held in February 2009 when this report was discussed at the MRDPW premises and in the town of Panagurishte. Minutes of these meetings are attached in Appendix 15 (Discussions). The importance to finalize construction of Luda Yana dam in order to overcome the current negative environmental status resulting from the suspension of construction works and to establish healthy and comfortable living conditions for the population in the respective municipalities is underlined.

COMPLIANCE WITH WORLD BANK SAFEGUARDS

The project is rated as environmental assessment category A in compliance with Bank policies which call for a full environmental assessment to be carried out for the construction of a large dam. This EIA report has been prepared and submitted in compliance with all applicable World Bank safeguard policies relating to OP/BP 4.01. The Bulgarian dam safety requirements are in line with those of the Bank and for the project design, construction, and operation the Bulgarian legislation and the Bank policy OP/BP 4.37 Safety of Dams will be followed. Investigations during the EIA preparation process did not raise concerns regarding possible cultural properties at the proposed dam site, and therefore the Bank policy OP/BP 4.11 on Physical Cultural resources is not triggered. However, the EMP includes provisions to address impacts to cultural heritage and archeology if chance finds occur during the construction works. The Bank OP/BP 4.36 Forestry is also not triggered because no existing forest ecosystem will be affected. Although a small number of trees will need to be removed from the future reservoir basins once civil works will start, these trees are scattered individuals

5 Luda Yana Dam EIAS which were left in place when the area was cleared of vegetation years ago during the initial dam construction period.

The OP/BP 4.04 Natural Habitats will apply since a small part of the sanitary-protection zone of the Luda Yana Dam is expected to be located on the territory of Sredna Gora Protected Area (code BG 00002054) of the National environmental network (also a Natura 2000 site). However, as noted above, the construction site and the reservoir will not impinge on this area, and the nature of the sanitary protection zone is such that it will not have an adverse effect on ecological resources, flora and fauna in the area. In fact, the need to maintain the sanitary protection zone for the dam is expected to assist in ensuring the protection of the area. As part of the updating of the feasibility study and refinement of the EMP, further surveys will be carried out to confirm the situation on the ground and determine whether any measures are required to avoid or minimize effects on any biodiversity of the area.

The policy OP/BP 7.50 Projects on International Waterways is applicable because the dam is will create an impoundment on the Luda Yana stream - a tributary of the Maritsa River that forms a border between Turkey and Greece and finally discharges into the Aegean Sea. In accordance with the policy, the Borrower notified the riparian countries about the project goal and investments.

ENVIRONMENT-RELATED LOAN CONDITIONALITIES AND COVENANTS

Environmental loan conditionalities and covenants will relate to the implementation of recommended mitigation measures and monitoring activities. During project implementation, the EMP will be updated to reflect specific monitoring actions and indicators and estimated costs as a result of the update of the Feasibility Study and Detail design. The updated EMPs will be reviewed and approved by the Bank before the procurement for civil works are initiated. Respective covenants on EMPs have been integrated in the Financial Agreement.

ІІ. LEGISLATIVE AND POLITICAL SYSTEM AND ENVIRONMENTAL MANAGEMENT ORGANIZATIONAL DIAGRAM

Design and construction of Luda Yana Dam was implemented following a decision of the Council of Ministers in the 1980-ies. In 2000 a decision was taken to suspend dam financing due to the economic difficulties experienced by the country.

This EIA report has been implemented in compliance with provisions of the current Bulgarian regulations and the Bank safeguard policies relevant to Luda Yana dam, including:

1. ОР/ВР 4.01 Environmental Assessment 2. ОР/ВР 4.37 Dam Safety 3. ОР/ВР 4.04 Natural habitats 4. ОР/ВР 4.36 Forestry; 5. OP/BP 7.50 Projects on International Waterways 6. Environmental Protection Act (SG No.91/2002 ...... No 94/2008 ) 7. Water Act (SG No.67/1999 amended and supplemented No 70/2008) 8. Bio diversity Act (SG No.91/2002 ...... No.94/2007) 9. Waste Management Act (SG No 86/2003 ...... No 34/2006 ) 10. Fisheries and Aquacultures Act (SG No.4/2001 ...... No 108/2006 )

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11. Ordinance on the terms and conditions for performance of EIA (CoM Decree 59/2003 .... SG No.3/2006)

A full list of the laws, regulations and other legislative documents referring to this EIA report is presented in Appendix (Normative documents).

Control on the implementation of the measures for protection of the environment in the course of construction works is exercised by the RIEW in the town of Pazardzhik and by the Regional Inspectorate on Health Safety and Control (RIHSC) in case of signals related to human health risks. Furthermore, the environmental expert at Panagurishte municipality performs regular supervision of the implementation of measures and the status of the environment and submits reports to RIEW Pazardzhik. In case of failure to perform the measures, RIEW Pazardzhik may impose sanctions, define deadlines for implementation of the recommendations and, as a last resort, terminate the activity in violation of the recommendations.

The plan for environmental monitoring during the construction of the dam and its operation phase is developed before the construction and operation and is approved by the Basin Directorate (BD), RIEW and MOEW (Environmental Executive Agency – EEA). Such plan is updated and approved annually by the three authorities mentioned above. The environmental monitoring plan for Luda Yana will be updated as soon as the detail design and respective feasibility study will be reviewed in accordance with current situation. At the end of each year, annual statements are submitted, based on which either additional requirements may be included to the monitoring or others may be withdrawn. The monitoring period is determined in the EIA and specified in the Monitoring plan for the construction and operation period, which can be revised as many times as needed. Standing obligations are those of the Ministry of Health (MH) to control water quality through its regional unit RIHSC, Water and Sewerage EOOD, Panagurishte and, if needed, or in case the dam is included in the National Monitoring Network, of the MOEW (in compliance with a MOEW decision to come into effect after dam commissioning).

The dam operation unit shall be responsible for all waters supplied from the dam during its operation phase. The control on the quantity of environmental flow and run-off is exercised by Basin Directorate Iztochnobelomorski region - town of Plovdiv.

ІІІ. OVERVIEW OF LUDA YANA DAM PROJECT

Luda Yana Dam is situated at about 2 km northeast from the town of Panagurishte on the Luda Yana River, immediately after the inflow of the Stara reka (river) into the Muleiska reka (river). The design that was used to startup construction works was prepared by the Institute for research and design (IPP) Vodproekt in 1982 and 1984.

The purpose of the Luda Yana water supply system is to secure steady water supply for the town of Panagurishte and the villages of , , Popintsi, Banya, Bata, Levski, , mine Radka, the sites of Optikoelektron and Assarel mining area in the municipality of Panagurishte, and five additional settlements in the municipalities of Pazardzhik and Strelcha. According to this design, it is also technically possible to supply with water Lesichovo municipality. The estimates made cover a period up to 2020 and securing of potable water supplies for 45 000 inhabitants. At present, the region is supplied from the terraces of the Maritsa River at Zlokuchene village through a 45 km water supply pipeline, constructed 20 years ago. This pipe is physically decayed and the frequent failures created insecure delivery of water and thus water supply rationing. Technical problems are maintained at the expense of high operational expenditures, which coupled with the indispensable high power consumption for the five pumping stations result in a household water tariff of about 0,70 euro/m3 – one of the highest in the country. In addition to the water intake for the future dam, water catchments and water supply pipeline to the town of Panagurishte have been implemented. The flow of the system is instable and is affected by high water periods when water quality deteriorates. The

7 Luda Yana Dam EIAS general condition of water supply sources causes uncertainties in securing the needed water quantities both in low water and high water periods.

The main facilities of the overall Luda Yana water supply system are: dam wall, water intake tower, diverting tunnel, main water outlet, spillway, and Drinking Water Treatment Plant (DWTP).

Construction works for Luda Yana water supply system were implemented in different periods by Assarel Medet and Hydrostroy from 1986 to its suspension in 2000. As of 1986, Assarel Medet and Hydrostroy are state-owned companies.

The Luda Yana Dam is state public property under the MRDPW.

The future dam operator will be ―Water Supply and Sewerage – P‖ EOOD (ViK–P EOOD), town of Panagurishte.

Dam Wall

The dam wall was designed as an embankment type, constructed of local materials that meet the current construction standards. The watertight element is a central clay core cluster, located in the central part on the injection gallery, and a concrete foundation slab in the banks. On both sides of the core cluster are the support ballast prisms, connected to the clay by means of transition zones.

The injection gallery is fully excavated in the rock base. The grout curtain is implemented out of it in the central part. A concrete slab has been cast in the banks, at the basic rock, to serve for implementation of the grout curtain and connection with the base of the core cluster.

The major parameters of the dam wall and the water reservoir are as follows: Wall type embankment with a clay core cluster Maximum height: from the natural terrain 43,50 m from the base of the core 47,00 m from the bottom of the injection gallery 51,00 m Crown length 458,00 m Crown width 6,00 m Total storage reservoir: 19,942×106 m3 Lake length 4500 m Effective storage capacity 17,74×106 m3 Unavailable storage capacity 2,20×106 m3 Water catchment area: 100,40 km2 Ponded area 142,00 ha Elevation wall summit (crown) 585,60 Elevation of the highest operational water level (HOWL) 584,00 Elevation of the highest water level (HWL) 585,35

2 This value is based on the previous design (2000). However, storage volume may decrease under the revised design if water demand for irrigation is excluded.

8 Luda Yana Dam EIAS

Elevation of the lowest operational water level (LOWL) 563,50 Maximum water quantity for water supply 300 l/s Total volume for water supply 6,00×106 m3 Watering volume (environmental water) 5,36×106 m3 Dam class I

Water intake tower, spillway and main water outlet

The water intake tower has been designed with several openings at various levels. The spillway is located on the left bank outside of the dam wall with dimensions Q0,1% = 280,00 m3/s. It has been designed as a front spillway with curvilinear form and a chute with ejector. The main water outlet is a steel pipe 1220 mm. It is installed in the diversion tunnel with D = 4.00 m and L = 160 m, and is meant for taking away of the river water amounting to 107,00 m3/s (Q5%) during the construction phase. To this purpose two parallel chambers have been envisaged at its end with two closing bodies – wedge gate valve for drainage of the lake and a throttle flap valve at the pipeline.

Drinking water treatment plant

No Drinking Water Treatment Plant (DWTP) was designed as of 2008. Its current location has also not been selected.

Current Situation at Luda Yana Dam

During the visual inspection of the dam and the facilities in 2007 and 2008 it was established that: the dam wall is constructed up to 30 m (70% of the proposed total height of 43.5 m; elevation 569,00 m), the excavation of the spillway and the chute is also executed, the construction part of the water intake tower is performed, the bumper on the upstream batter has been partially placed, part of the SCADA equipment (the equipment for measuring of settling) is installed up to the height of the embankment. Fully constructed are the diversion tunnel, the internal technological network, including the displacement of the road to Bunay chalet without the asphalt cover, a stone quarry, a ballast quarry and a clay and humus depots were uncovered.

The following construction activities need to be finalized for completion of the dam: on the wall – stone embankment, bumper on the upstream batter, clay core cluster, installation of the entire SCADA system; installation works on the water intake tower and the main water outlet; and asphalting the road to Bunay chalet. DWTP has not been designed nor has a site been selected as of 2008. A separate environmental assessment will be undertaken for the DWTP as part of the updating of detailed design.

All construction service roads from the stone quarry, clay quarry and the humus depot are in the bed of the future reservoir. They do not pass across settlements. The by-pass road of the town of Panagurishte will be used for transportation of the equipment for the water intake tower and the main water outlet, and the equipment for the DWTP, once the site for it has been selected. Wastes from the construction site will be transported to the landfill of Panagurishte in accordance with national regulations. The waste quantities and the implementation schedule for construction works are to be estimated during the update of the detailed design phase, and after the design of the DWTP the methods for treatment and discharge of wastewater will be defined. The diversion weir and the wall will secure settling of the construction waters during the construction works on the dam wall. For the completion of the spillway and the chute, the construction waters will have to be settled in a mechanical settling tank at the end of the chute.

9 Luda Yana Dam EIAS

The EDDR submitted to the Bank in 2007 specifies the activities to be performed prior to commencement of construction works for Luda Yana Dam, as follows:

Prior to the startup of construction works for completion it is necessary to perform the following: review of the as-built drawings of performed construction and installation works on the wall and the facilities, including protocols for hidden works, updating of available designs for the wall and the facilities; re-evaluation of the amount of high waters taking into account the hydrological data in the last 20 years and updating of the elevation of the wall crown in relation with the required freeboard; performance of micro seismic studies to determine the seismic hazards of the site and the dam wall; removal of the upper layer of the clay core cluster, the filters and the ballast embankment to reach the material with design density and water tightness; sampling of the embankment in the core, the filters and ballast prisms and assessment of the technical parameters of the embankment; checking of deposits for embankment materials in the used quarries; updating of the cross-sectional profile of the wall in view of the results from the geotechnical examinations, hydrological and seismic studies; checking of the condition of installed SCADA equipment and updating of the SCADA design; planning and shaping of implemented trenches for a spillway and a chute on the left slope and updating of the spillway design in compliance with the changes that have occurred; evaluation of the condition of the concrete facilities (water intake tower, diverting tunnel, concrete slabs under the clay core cluster on both banks) and rehabilitation of the concrete surfaces; design of DWTP, taking of soil samples from the dam lake for the purposes of quality analysis. If needed, this EIA will be revised in according with the findings of the above-noted studies.

Additional Studies Performed in Compliance with the Recommendations of the EDDR

In 2008, following a TOR of Vodosnabditelen complex OOD Panagurishte, ENERGOPROEKT – Hydroenergetika‖ OOD, developed a Comprehensive feasibility study for continuation and completion of construction works for Luda Yana dam - Panagurishte, which to a great extent meets the ЕА requirements for the studies to be performed prior to the beginning of construction, as follows:

Updating of Hydrological Studies

Updating of hydrological studies has been performed. Information was used for two base stations in the water intake of the Luda Yana river, with available 52-year series for one of them (until 2006), and a 58-series (until 1999) for the other. The latest 20 years were taken into account for determining of the hydrological parameters of the runoff for the range of Luda Yana Dam. Updating of high waters has been performed. The assessment of the silts quantity made in the study performed by Vodproekt was confirmed.

Wall Status

Inspections and a geodetic picture of the wall were made in order to determine the quality and quantity of the performed embankment works, as well as 9 prospecting pits in the body of the wall, from which samples were taken to establish the physical and chemical parameters of the input materials. 21 pocket samples and one shaft sample have been taken, and 12 samples were used to investigate the qualities of the clay core cluster.

The following conclusions have been made of the quality of implementation of embankment works:

 The results received from the laboratory samples taken during the control engineering and geological studies in 2007 comply with the results of the statistical and grapho-analytical processing of the results of all control samples taken since the startup of construction until the end of 1994. (The results of the additional laboratory analysis are comparable with those of 1994 and meet the standards set in the current regulations).

10 Luda Yana Dam EIAS

 In view of the parameters for water contents and degree of water saturation the built clay core cluster fails to meet the design requirements. The same holds good of the water content indicator for the support prisms. The remaining indicators comply with the design ones.  The support prisms materials are of very good granulometric content, high average volume density of the frame and good values of the angle of internal friction and cohesion.  For assessment of deformation-strength properties of the core cluster and the material of the support prisms in depth, sampling of these materials shall be envisaged through borehole methods.

Status of the Facilities

The status of the facilities as a result of the latest inspections is:  The condition of the diversion tunnel, the water intake tower and the injection heading and the slab providing connection between the clay core cluster and the rock base is good. It is necessary to check the properties of the base concrete slab in the banks.  Sample probes by means of water injections shall be made to establish the condition of performed counter seepage works.  Due to change in the class of the dam wall, additional excavation works after a new design will have to be performed for the spillway and the chute. The change in the size of high water for the required occurrence applicable for dam wall class І necessitates new construction decisions.

Change in the Technical Solutions

Due to the amendments to the regulatory framework after 1984 when the majority of the detailed designs for the wall and the facilities had been developed, the following changes occurred:  Under the original design the adopted class of the wall was II class. As a result of the amendments in the regulatory documents, the short distance to the town of Panagurishte, it was required to upgrade the dam wall class to class I; the upgrading from class II to class I may have specific implications for the design and operation of the dam such as a new design of the spillway.  The seismic grade of the region according to the map for seismic zones of Bulgaria determines that the site and the facility falls within a zone of seismic grade I = VІІІ and seismic ratio Kс = 0,15.

Requirement for Construction Changes in the Wall and the Water Facilities

Dam wall

The change in the class of the dam wall will change the occurrence of the high wave (described in para 5.11 – Hydrological risk).

In view of that the characteristic features of high walls, retention of the high wall and the crown elevation of the dam wall were checked. The results were Q0,01% = 395,00 m3/s and elevation HWL 0,01% = 585,80 m. The resulting crown elevation is 586,18 m and the elevation of the wave reversing railing is 587,20 m. Because of the small difference, the required excessive design elevation can only be achieved through changes in the construction of the crown.

Spillway facilities, water intake tower and the main water outlet

11 Luda Yana Dam EIAS

The spillway has been sized for Q0,1% = 280,00 m3/s. New hydraulic computations were made for maximum water quantity 395,00 m3/s and 90 m length of the crest. A new design shall be made for the spillway, including studies of hydraulic patterns for facility class I.

Water intake tower. The construction part has been implemented. Some reconstruction is needed and most likely the entire water extraction mechanical equipment shall be replaced since the old one was delivered to the warehouse 20 years ago.

The main water outlet has not been designed. A decision shall be made on the necessity to reevaluate the pipe material (whether to replace steel pipes for fiber-glass pipes). That would require a new design for the main water outlet.

Checking the Resistance of the Wall Batters

Checking of counter-sliding safety coefficients has been made in compliance with the effective design standards. Computations have been made for the full wall height. The received values meet contemporary requirements in terms of batters safety of earth facilities. At maximum safety coefficients (Bishop, Morgenstern-Price etc.):

For the downstream batter

 main combination FSmin = 1,50;  peculiar combination - earthquake FSmin = 1,20; For the upstream batter  peculiar combination – fast reduction of the water level FSmin = 1,30, The results are:

Main combination Peculiar combination Downstream batter 1,66 1,41 Upstream batter 1,52

The estimated maximum daily water consumption by 2025 has been confirmed to be 300 l/s.

The existing construction site under the dam wall will be used for completion of the construction works. The time required for site completion is assumed to be within 3 years, as per the preliminary time schedule. The workforce required for the implementation of construction is estimated at about 150 construction workers and mechanical operators. The site operation is to be managed by a maximum staff of 20 (including operation of the DWTP), which is based on data of similarly projects. The operational lifetime of the dam as per the regulatory documents shall be 100 years. The required foreign investment has been estimated at € 26 000 000, according to financial plan.

(Note in Appendices the following figures: Topographic map; diagram of Water supply complex Panagurishte; Luda Yana Dam layout; forest map including Luda Yana Dam, Luda Yana Dam cross sectional diagram, site photos)

ІV. OVERVIEW OF ENVIRONMENTAL COMPONENTS AND FACTORS

4.1. AIR

4.1.1 Climate

12 Luda Yana Dam EIAS

The climate in the region of Luda Yana Dam is transitory continental with specific features of the Zadbalkanski low-mountain climatic region (Sabev and Stanev). The area features complicated geometry i.e. strongly cut erosive folds that are out of level with the surrounding hills in the period prior to filling of about 170 m. The morphographic peculiarities of the region result in substantial differences in terms of some climatic characteristics of adjacent sections. The dam height above the sea level in case of normal flooding is 584 m.

As a whole the climate in the project area is softer compared to the climate in the Predbalkanski region, where the height above the seal level is similar. In order to get clear idea of the climate in the region different seasons have been considered based on data from the only representative meteorological station of Panagurishte.

Winter. The soft nature of the climate is best exhibited in wintertime. Taking into consideration the comparatively good protection against cold intrusions from northeast, but also from the prevailing western ones, and the specific thermal regime of the upper parts of slopes and heights, the average January temperatures are about -1,5C. In the deeper depressions, following a more lengthy stay of anticyclone weather in conditions of radiation cooling, minimum temperatures may drop below -19C.

The winter appears to be the driest season in the year with average seasonal amount of precipitation 104 mm, 50% of which snowfalls. Mild winter conditions are a prerequisite for the relatively short duration of the snow cover. On average it appears in the second ten-days of December and disappears in the first ten-days of March. On average the total number of days with snow cover is 36 days, of which 14 in January. The month with the highest amount of rainfall is December with average monthly precipitation 49,9 mm.

Winter is the windiest season with average monthly wind speed of about 2 m/s in January and February. In 40-50% of the days in the season the weather is gloomy – total cloudiness 8-10 units.

Spring. Springtime here is relatively cool and on average the date when temperature steadily shifts above 5C is 19 March. The average temperature in the mid-spring month of April is 10,1 C.

Rainfalls increase in springtime to an average amount of 178 mm for the season. The most humid spring month is May with monthly quantity of precipitation 79 mm, which is by 15% above that in July. The maximum daily rainfall in springtime may reach 78 mm (May).

Due to the active atmospheric changes springtime is the windiest season, with average monthly wind speed ranging from 1,8 m/s to 2,2 m/s. The number of gloomy days falls to 30% of the total number of days in the season.

Summer. Considering the height above the sea level, summertime here is relatively cool, featuring an average monthly temperature of 20C throughout the month mid-summer month of July. The average date when temperature steadily shifts above 15C is in the middle of the first ten-days of June. Seasonal distribution of rainfall exhibits a continental pattern expressed in rainfall winter minimum and summer maximum. Summertime is the season with the most rainfalls featuring an average amount of 195 mm. One of the specific peculiarities of the region is the relatively low (657 mm) annual amount of rainfall compared to the Predbalkanski region; however it is higher than in the Thracian lowland. The transitory nature of the climate is expressed in the moderate seasonal differences in precipitation. Though the rainfall maximum is in summertime, the difference between the summer and the winter rainfall does not exceed 10-12% of the annual amount of rainfall.

Autumn. Late summer and early autumn is the quietest period of the year. The prevailing steady anticyclone weather is the reason for the average monthly speed of 1 to 1,5 m/s. Autumn in the region is almost completely symmetrical to spring, with an average October temperature of 10,7С that is nearly the same as

13 Luda Yana Dam EIAS that in its spring counterpart of April. The average daily temperature falls steadily below 15C in late September. In 18-20% of the time weather is bright, and in September and October only in 20% of the days the weather is overcast. Autumn rainfalls amount to 149 mm, but in line with the prevailing bright and quiet autumn weather they are lower than in springtime.

The average annual temperature in the region is about 10С. To get a more truthful idea of the climatic conditions in the region for the purposes of proper dam management it is necessary to pay special attention to the potential evapo-transpiration and precipitation. The difference between the annual amount of precipitation and evapo-transpiration is insignificant. The annual evapo-transpiration is about 600-700 mm, and the annual amount of precipitation is about 650 mm.

The overview of the climatic background is illustrated and supplemented by the enclosed diagrams, based on data published in the Climate Reference Books of Bulgaria.

20.3 19.8 20 18 16.1 15.9 15.9 16 14 16.1 15.8 14.6 14 12.8 10.4 12 10.4 10.7 10.2

0 7.7

С 7.7 8 5.8 6.1 5.8 3.8 4.2 3.8 4 1 1.5 0.8 1 0 -0.6 -1 1 -1.62 3 4 5 6 7 8 9 10 11 -0.612 -1.6 -4 -3.4 -3.4 месец Tср мин. абс.мин.

Fig.1 Mean monthly, minimum and absolute minimum temperature- Panagurishte station

36 34.2 34.4

31.8 31 32 28.7 28.4 28.5 25.7 26.2 28 24.7 24.1 21.7 24 20.3 20.3 19.8 18.3 19.5

0 20 17.2 18 С 15.1 15.8 16 14.6 14.8 11.7 12.2 10.5 12 10.2 10.7 6.7 6.4 8 6.1 4 4.2 4 0.8 1.5 0 1 2 3 4 5 6 7 8 9 10 11 12 месец Tср макс. абс.макс.

Fig.2 Mean monthly, maximum and absolute maximum temperature- Panagurishte station

14 Luda Yana Dam EIAS

16 15.3

13.7 14 12.6

12 10 10

8 6.6 бройдни ясни 6 6.2 5.5 6 5 5 4.9 4.6

4

2 1 2 3 4 5 6 7 8 9 10 11 12 месец Fig.3 Mean monthly number of bright days by general cloudiness - Panagurishte station

83.8

80 79.4

70 64

60

мм 53.7 54.4 48.7 49.8 50 47.1 44.5 44.4 45.3

40 38

30 1 2 3 4 5 6 7 8 9 10 11 12 месец

Fig.4 Mean monthly precipitation quantity — Panagurishte station

85 85 84 82 80 80 77 76 75 74 73

72 72 %

70 69 67

65

60 1 2 3 4 5 6 7 8 9 10 11 12 месец

Fig.5 Mean monthly cloudiness — Panagurishte station

15 Luda Yana Dam EIAS

7

6

5 бал 4

3

2 1 2 3 4 5 6 7 8 9 10 11 12

обл 6.2 6.1 6 5.3 5.4 4.8 3.3 2.8 3.3 4.9 6.6 6.4 месец

Fig.6 Mean monthly relative air humidity — Panagurishte station

16 Luda Yana Dam EIAS

N N 50 35 40 30 NW NE NW 25 NE 30 20 20 15 10 10 5 W 0 E W 0 E

SW SE SW SE

S S

January /calm/--67.5% April/calm/-62.3%

N N 30 30 25 NW NE 25 20 NW NE 20 15 15 10 10 5 5 W 0 E W 0 E

SW SE SW SE

S S July/calm/-66.7% October /calm/ – 72.8 %

N 40 35 NW 30 NE 25 20 15

10 5 W 0 E

SW SE

S Annual /calm-/67.5% Fig.7 Wind Rose - Panagurishte station

17 Luda Yana Dam EIAS

4.1.2 Air Quality

Following the suspension of Luda Yana construction works the air quality in the region reverted to the condition it had prior to commencement of the project. Assarel Medet - an enterprise for extraction and processing of copper ore is also located in the region. The mountainous terrain in the region prevents transfer of harmful substances, including those from the operations at the Assarel-Medet AD mining site. The air quality is measured through a systematic monitoring network including 6 points of measurements for the region (EEA – MOEW, RIEW Pazardzhik – CO, SO, NO etc.). Assarel Medet AD, which has been privatized, is subject to continuous monitoring and the owner has taken on and observes the commitments for annual investments in protection of the environment (air, water, soils).

4.2. WATER

SURFACE WATER

The dam is constructed on Luda Yana River, which rises from the slopes of the Sredna Gora Mountains. The river runs further within the Panaghiuriste town, located at about 2 km downstream the dam site and then, in its lower course, it collects the waters of several tributaries, one of which is the Banska Reka River that empties into the Maritza River.

Hydrological Data

There are two hydrometric stations for registration of water quantities in the riverbed of the Luda Yana river – Hydrometric station (HMS) No 336 at the Strelchenska Luda Yana river and HMS No 251 at the Luda Yana river.

HMS No 336 was launched in 1956. It was removed two times – in 1960 and 1970, but the water intake has not been changed substantially – 95,1 km2. It is equipped with a limnograph.

HMS No 251 was launched 1941. In 1950 it was slightly shifted and the water intake, which totals 569,8 km2, did not change significantly. In 1960 it was equipped with a limnograph. In 1999 it was closed down.

HMS No 251 totals the runoff of Strelchenska Luda Yana River and Panagurska Luda Yana river, on which the Luda Yana Dam is constructed, and of the right inflow Of Banska Luda Yana river.

The station at the Strelchenska Luda Yana river has a 52-year array of actual monitoring data (until 2006), and that at Luda Yana river – a 58-year array.

Data for the natural runoff at HMS in the upper part of the riverbed of the Topolnitsa river has been used for the update of hydrological data (water intake basin is bordering that of the Panagurska Luda Yana river and the waters of both rivers originate in a common mountain area – Sashtinska Sredna Gora).

The computation period 1950/51-2005/06 comprises a complete cycle, containing the phase of high water (1951/52-1979/80) and the phase of low water (1980/81-2001/02), as well as two additional periods, complementing the cycles.

18 Luda Yana Dam EIAS

The updated hydrological parameters at the range of the Luda Yana Dam are:

Hydrological parameters at the range of Luda Yana Dam

F Hav. Qo Mo Wo W75% W85% W95% Point Cv km2 m m3/s l/s/km2 .106 m3 .106 m3 .106 m3 .106 m3 Luda Yana Dam - Panagurska Luda Yana 100 932 0.79 7.9 0.40 24.91 17.64 14.84 11.16 River

High waters

The data for registered high waters in the bed of the Luda Yana river show that they may occur at any time of the year, but most often the occurrences are in high water periods and in summer months. High waters are due to intensive rainfalls that for significant high waves and in certain conditions, waves of extraordinary order may occur.

Features of estimated high waters at Luda Yana Dam

Occurrence % 0,01 0,1 1 5 Parameters Water quantity Q (m3/s) 531 336 184 102 Volume of the wave W (.106 m3) 12,4 9,16 6,0 3,9 Total duration T (h) 22 26 31 37

Silt runoff

The update of the silt runoff does not change the quantity of the silts defined in the detailed technical design of IPP Vodproekt of 1982. The overall mean annual turbidity of Luda Yana Dam has been defined at 920 g/m3 with floating stilts of 800 g/m3, and bottom silts 15% of them, or 120 g/m3. The volume weight of deposits has been estimated experimentally at н = 1,45 t/m3.

The quality of the deposits has not been determined and the level of pollution if any in the water reservoir area has not been evaluated. This will be undertaken as part of the EIA for the water treatment plant. All wastewaters generated at Assarel Medet are taken beyond the watershed of Luda Yana Dam (VOKO – Panagurishte).

Water Quality

Laboratory analyses have been performed for the water quality in the water intake area of the dam. In 1995 at the request of Vodosnabditelen complex OOD in the town of Panagurishte water analysis was performed for the following rivers: the Elashka, Garmi dol, Okoshka and Muleiska, and a study of the chemical composition of ground water. Data from previous studies, as well as those of 1995 show that river waters variably meet the requirements ofBulgarian State Standard (BDS) for ―Drinking Water‖ 2823/83 (Appendix: Water Analyses Results).

19 Luda Yana Dam EIAS

The major physical and chemical indicators from the latest laboratory examinations of mixed water towards Luda Yana Dam (Protocol No 40/25.09.2003.) are:

 рН 7,24  Color 5-15%  Turbidity – dry residue 196 mg/l/O2  Oxidizability 5,4 mg/equiv./l  Alkalinity 2,60 mg/l  Ammonium 0,10 mg/l  Nitrites 0,02  Sulphates 33,0 mg/l  Iron 0,84  Manganese 0,26  Microbe number 2 – above 50  Coli titres 50 above 100  Phyto plankton random cells  Seston 33-100 cm3/m3

The results show that water fails to comply with the requirements of BDS 2823/1983 Drinking Water and Ordinance No 9 of the Ministry of Health (approximates the EU directives) for the following indicators: oxidizability, manganese, turbidity, and microbial population.

Recent protocols on water quality have been attached in the Annex. The water quality data confirms the required water treatment process prior to its supply to consumers thus the need to design and construct the DWTP.

The river runoff during summer low water level decreases up to semi-drying of the river flows (Fig. 9).

The construction of the dam wall has separated the upper river section from the lower sections. The river flows now from the upper to the lower section via the diversion tunnel. The partially drying of rivers within the watershed during summer is also typical downstream of the dam due to the fact that there are water intakes on the rivers. These water intakes draw water for the current water supply of the town of Panagurishte. These waters feature not only a fluctuating flow, but are also influenced by precipitations.

The dam bed is characterized by active natural erosion processes influenced also by cutting of the forest vegetation.

The elevation to which the dam has been constructed creates potential hazards for the population of the town of Panagurishte and the settlements downstream during high waters. Therefore Vodosnabditelen complex OOD Panagurishte and ViK EOOD Panagurishte perform regular inspections during intensive rainfalls.

There are no street collectors or wastewater systems in the watershed since the villages are using septic pits.

GROUND WATER

The groundwater in the dam area is fissure type. The host rocks are heavily fractured and weathered on the surface, and they are an excellent collector of groundwater. From the igneous rocks, the richest in water are the granites, granodiorite, etc. in the high mountain parts. The fractures in the rocks are hydraulically connected. Due to the deep fractures in the rocks, the precipitation waters feed the groundwater with deep circulation. These are usually cold waters with heightened mineralization. The springs fed by these waters have a small flow rate of tens to several hundred grams per second. Their mineralization ranges from 0.6 to

20 Luda Yana Dam EIAS

1.6 g/dm3, the water is alkaline and slightly hard. The mode of underground runoff Мur < 1 dm3/s.km2 defines the region as low in water capacity.

The fissure water pressure head system of Sredna Gora covers the massif of the Sredna Gora anticlinorium. The groundwater pressure is created in the high parts of the mountain range, and unload takes place on the main longitudinal fault zones – north and south. The springs near Strelcha, Krasnovo, Panagurska Banya spring from the north fault zone in the studied region. Their water is fresh, hydrocarbonate sodium sulfate with temperature from 23 to 55С.

The specified indicators from the available data characterize the quality of groundwater.

4.3 GEOLOGICAL ENVIRONMENT

Luda Yana dam is situated in central Sredna Gora. The dam wall is stone embankment. The geological base is from Paleozoic Sredna Gora granitoids, which are part of the South Bulgarian granites.

The magma development of the Sredna Gora granitoids is characterized by several intrusions of granitoid magmas. Three intrusive complexes are differentiated, and the region of Luda Yana dam is part of the First complex and the Smiloven pluton, in particular. It is accommodated among the rocks of the Precambrian metamorphic complex (Ardena group) and occupies an area of about 100 km2. It is divided in two by the Strelcha pluton incorporated later from the third intrusive pluton. North of the Panagurishte colonies, it crosses basic bodies from the initial stage and includes xenoliths from them. It is built up of porhyroid granites, granoidiorites, and tonalities, interconnected by a gradual passage. The most widespread are porhyroid granites and granodiorites. The pluton is connected with a rich vein phase, represented by various granitoids, many aplites and differentiated pegmatites of varied morphology.

The rocks in their upper part are deeply weathered and fractured, both horizontally and vertically. During their weathering, light loamy sand soils were formed with thickness from 20 to 100 cm, which are easily carried away by the surface runoff water and are a source of flood deposits.

The Quaternary is represented by alluvial, prolluvial and delluvial deposits of Holocenic age. The delluvial deposits are relatively limited in the foot of the mountain slopes. Prolluvial deposits can be found in the form of flood cones in the southern foot of the Panagurishte, Stralcha and Krasnovo hollows. The cone line is predefined to a large degree by the Panagurishte upcast and Krasnovo faults.

The alluvial deposits are concentrated mainly in the river valleys and beds (Luda Yana). They are represented mainly by fine cobble, gravel, unsorted sandy and clay material. There is an emphasized tendency of gradual decrease of the size of the grains along the river flow. In the Panagurishte valley, the alluvium comprises part of the riverbed where the flood terrace is.

The delluvial-prolluvial deposits fill the inter-cone spaces at the foot of the hollow. The homogeneous Quaternary deposits (delluvial, prolluvial, alluvial) are assumed to be from the Holocene age, and the mixed genetic types – Pleistocene – late Pleistocene.

Tectonics

The crystalline massif of Sredna Gora is a core from a large positive fault structure. In it, the southern limb of the anticlinorium is Panagurishte and Stara Zagora late Cretaceous line, whose Mesozoic mantle was later completely denuded.

In the Panagurishte and Stara Zagora lines south of the crystalline massif there is volcanogenic activity in the late Cretaceous, known only for this region. During the different stages of its development, the crystalline

21 Luda Yana Dam EIAS core of the Sredna Gora anticlinorium and maybe parts of its limbs rose up as dry land in the deeply lineamented late Cretaceous geosynclinal area. To the north, the Sredna Gora horst-anticlinorium is separated from the mountain structures through the zone of the post-Balkan deep fault and to the south, along the South Sredna Gora fault zone, it borders with the Bailovo-Panaguristhe syncline. It represents a convergently pressed graben structure, situated between the Sredna Gora (to the north) and Ihtiman (to the south) anticlinorium. Its length is about 80 km and it is from 6 to 12 km wide. In the Alpine magma saturation of the syncline, it played the role of first-class sub-parallel faults, which in their essence are magma-conduction channels. The block structures played an important role in the formation of the present-day tectonic appearance of the Panagurishte line. The longitudinal segmentation is defined by several faults with orientation 120–130 (Panagurishte, Krasna, Stefanchovo and Batenski), which form three blocks in the central part of the line. th The dam region falls within 8 seismic zone with seismicity coefficient Кs = 0.15.

The specified features of the geological environment allow for input in the wall of the construction materials extracted from the quarries and foundation of the dam wall in compliance with the safety requirements.

Ores and minerals

The igneous formation is the main ore-generation factor for the Panagurishte ore region.

The granitoids of Sredna Gora and the plutons of Smiloven and Strelcha, in particular, are bound to pegmatite fields, mainly in the intrusive bodies and more rarely in the host rocks.

A number of ore bodies from the largest industrial deposits of porphyry copper and copper pyrite ore formations are related to the late Cretaceous magmatism.

The dam will collect water from the rivers Muleiska, Okoshka, Elashka and their tributaries, which are near to the dam (Fig. 8). They are mountainous in nature and have a large slope of the beds, steep rocky banks and active erosion activity, and consequently, transportation of deposits. It is estimated that an average of 64740 m3 will be deposited in the dam bowl. The dam wall is in an advanced stage of construction. The two slopes to which the wall is bound are built of strong granites. Their weathered part has been removed to the level of fresh rock.

In August 2007 several additional tests were carried out, comprising 9 prospecting pits, 12 samples from the clay core and 1 bank test. The samples taken established that the core and the backfill are well consolidated. The constructed clay core does not meet the design requirements in terms of the indicators water content and level of water saturation. The same applies to the indicator water content of the support prisms.

22 Luda Yana Dam EIAS

GEOLOGIC MAP М 1: 100 000

Lithology

Smilovenski pluton porfiroide granites and granodiorites

23 Luda Yana Dam EIAS

4.4. SOILS

The soils in the region of Luda Yana dam are of the Luvisols class, leached cinnamon forest soils. They are found in the lower vegetation belt and formed under the influence of xerothermic oak vegetation. On the terrains where this vegetation has been destroyed, the soils are subject to anthropogenic impact, which very often (as is the case with the dam area) causes intensive erosion processes.

The soils on the right slope of the dam are severely eroded and in places even the B-horizon is missing. In the dam bowl where the soil was relatively preserved (there was a shallow alluvial horizon), the humus layer was scraped and deposited, in implementation of the planned cleaning of the bed. On the right slope, the soils are shallow to averagely deep, loamy sand, highly to moderately stony, slightly eroded.

In the river terrace the soils are alluvial, sandy and deep. In many places of the flooded area, there are small sand quarries.

The change in land use of 142 ha was carried out under the respective legal procedure. It included moving the road Panagurishte – Bunay chaletabove the elevation of the highest water level (HWL).

The soils in the bed and the dam area are not contaminated with chemical substances and heavy metals. Due to the absence of sources of such pollutants no soil samples have been taken. Soil samples to define soil quality are to be taken from the bed of the dam in the course of design update. The environmental monitoring includes control soil sample-taking during the operation period. It is necessary to take measures against contamination with waste from settled areas in sanitary-security zones ІІ and ІІІ.

4.5. WASTE

The on-site inspection did not establish abandoned construction waste or unregulated landfills.

4.6. HARMFUL PHYSICAL FACTORS – NOISE

At present, there are no noise sources on the territory of Luda Yana dam, due to the fact that construction has been suspended. The noise background is the natural one of the environment. When single trucks from the sand quarry pass through (episodically), there is insignificant increase. On the construction site below the wall, due to the operating motor depot, the noise is higher, but it does not exceed the the admissible levels.

4.7. FLORA

In compliance with the forestry division of the country, the region of Luda Yana Dam falls into the Thracian forestry district, Gorna Trakia sub-district, and lower plain-rolling and rolling-foothill belt of oak forests, sub- belt rolling-foothill mixed deciduous forests (500-700 m above sea level).

The right slope of the future reservoir, as well as the areas above is barren, former agricultural lands – pastures, orchards and fields that have been ezproporiated. The trees remaining in the dam bowl are single fruit trees and some willows along the water flow – Salix Alba. The humus layer has been removed. The land is partially used as grazing land and is not cultivated. The left bank of the river that is much steeper is populated by natural broadleaved forest vegetation and some coniferous crops – mainly Scots pine (Pinus silvestris).

The natural vegetation around the dam bowl on the left slope pertains to the mixed mezoxerophyte oak phytocenoses (Querceta mixtum) with sprouting stands comprising: Durmast oak (Quercus dalechampii), Italian oak (Quercus conferta), European hornbeam (Carpinus betulus), cerris oak (Quercus cerris). The

24 Luda Yana Dam EIAS stands are not very dense; most of them are not in good health – 30-40% dry tops. Reconstruction has been planned (logging followed by afforestation). Coniferous are comprise mainly Scots pine (Pinus silvestris). Brush vegetation is represented by whitethorn (Crataegus monogina), hazel (Corylus avelana), dog rose (Rosa canina), traveler‘s joy (Clematis vitalba) etc.

Grass synusium is typical for the mixed oak phytocenoses and it does not comprise any species protected by law.

Afforested area affected by the construction of Luda Yana Dam belongs to Forestry Farm of Panagurishte. The areas falling in the bed of the dam have been expropriated in compliance with the legal procedure years ago and have been logged with and exception of a small plot (0,5 - 0,6 ha) Scot‘s pine stand, near the wall. The natural communities in the dam bowl have been affected by the construction works and the remediation (logging and removal of the humus layer).

The dam construction site is located under the dam wall and is currently used by the former Contractor. Below the dam wall and to the town of Panagurishte there are no plant species that are rare or threatened by extinction.

The presented data are based on a comprehensive inspection of the territory, examination of the available sources and the consultations given (Appendix: Forestry map showing the lands in the bed of the dam excluded from the forestry fund of SFE Panagurishte and the species of forest vegetation).

Protected Nature Areas

The Protected Area (PA) ―Luda Yana River‖ (code BG 0000426) Natura 2000 covers Banska Luda Yana (a tributary of Luda Yana River) and Luda Yana river below the town of Panagurishte. Therefore, the Luda Yana dam situated upstream of this town is outside the borders of PA BG 0000426 ―Luda Yana River‖ and it is not expected to have a direct impact on the subject and preservation goals in it. It was confirmed by MoEW that the dossier for the establishment of another Protected Area is in process (entitled ―Sredna gora‖, code BG0002054) which falls within the Natura 2000 framework (for birds). While the PA designation and development of respective Management Plan for this Natura 2000 site is still under investigation by MoEW in collaboration with related Regional Inspectorate of Environment (CoMD № 349/27.01.2009), MoEW confirmed that the water reservoir of the dam does not fall within the scope of the area under consideration. Therefore, the future dam operation and completion of construction works will not impact negatively any critical habitats or sensitive ecosystems in the Luda Yana dam zone.

In accordance with current national rules and procedures related to development of management plans for PA (SG7/2009), the regimes of the Natura 2000 PAs are advised to be assessed in corrdination with those of sanitary-protected zones; furthermore, in the case of full or partial overlap between the boundaries of a PA with the sanitary–protected zones of dams, the applicable restrictions for activities is coordinated with the Water Act. It is noted that construction of the Luda Yana dam started in 1986 prior to the designation of the Protected Areas at this site. Consultations carried out with the Directorate ―National service for nature protection‖ within the MOEW confirmed that for those sites for which a construction permit is in place and constructions have commenced, there is no need for a compatibility assessment with Natura 2000 (as per Art.4 of the Ordinance) on the terms and conditions for assessment of compatibility of investment proposals with the subject and purpose of conservation of Protected areas. However, it is also noted that the regime of management for sanitary-protected zones of dams is consistent with environmental protection objectives of Natura 2000 sites.

25 Luda Yana Dam EIAS

4.8. FAUNA

4.8.1 Ichthyofauna

The investigation for the EIA purposes was performed in 2007. The section of the Luda Yana River was visited in the area of the future dam, which included visual inspections and fishing by means of net devices. The analysis made also use of data collected in the fall of 2005 for evaluation of biological diversity in the Environmental Network NATURA 2000 (collected through the same methodology), as well as some survey data on the presence of certain species in the region. [MS 11, 12]

Current condition of the ichthyofauna

The upper flow of the Luda Yana River and its tributaries are a trout zone populated mostly by river trout Salmo trutta fario. The population is subject to amateur fishing and is maintained mainly through artificial fish stocking. A typical species for the river section below the town of Panagurishte is the Maritsa barbel Barbus cyclolepis, however represented by a small population. Other species registered in this section are:

Common minnow Phoxinus phoxinus (in the upper part) Chub Squalius Orpheus Gudgeon Gobio bulgaricus Bitterling Rhodeus amarus (in the lower part) Common roach Rutilus rutilus (in the lower part)) Golden spiny loach Sabanejewia balcanica Strumski loach Cobitis strumicae (in the lower part) Pumpkinseed Lepomis gibbosus (in the lower part)

Diversity of ichthyofauna species increases toward the lower part of the river flow, but in general the population density is low. The composition of the ichthyofauna downstream in the potentially affected area of the Luda Yana River features four species of conservation significance:

Barbus cyclolepis (Biological Diversity Act (BDA), Appendices 2 and 4; Directive 92/43/EEC, Appendix II (= Barbus plebejus) Rhodeus amarus (Biological Diversity Act (BDA), Appendix 2; Directive 92/43/EEC, Appendix II; BERN*, Annex III) Sabanejewia balcanica (Biological Diversity Act (BDA), Appendix 2; Directive 92/43/EEC, Appendix II; Cobitis strumicae (Cobitis taenia strumicae) (Biological Diversity Act (BDA), Appendix 2; Directive 92/43/EEC, Appendix II (= Cobitis taenia)

The operation of the dam is not expected to have a negative impact on the local population of these species. In connection with completion of the revised design this will be confirmed and the updated EMP will include any measures necessary to ensure the protection of these species.

4.8.2 Herpetofauna (Amphibians and Reptiles)

These data have been obtained as a result of the inspection performed on site and study of various sources on the herpetofauna within the scope of the territory of Luda Yana Dam [MS 13, 14, 15, 16, 17, and 18]. Table 1 includes the established and likely species in the area of the dam wall and the area planned for flooding, their status in terms of protection, and their habitat. The species observed during the visit in 2007 are marked with 4907 and those taken from available literature with VK.

26 Luda Yana Dam EIAS

The Smooth Snake is one of the species whose existence in the region of the dam is not certain but is likely. The European Pond Terrapin and the big Warty Newt is not present in the site now, might come to populate the future water reservoir.

Table 1 List of species, their conservation status and habitat location in the dam wall and reservoir areas

Nature conservation status Dir. Data Species Habitat location BDA IUCN BC source 92/43 Warty newt ІІ, ІІІ LR ІІ ІV near Panagurishte VK Yellow-bellied toad ІІ ІІ ІІ,ІV areas to be flooded 4907 Great toad ІІІ ІІІ areas to be flooded 4907 European tree frog ІІ, ІІІ LR ІІ ІV areas to be flooded 4907 Big water frog ІV ІІІ V areas to be flooded 4907 European pond tortoise ІІ, ІІІ LR ІІ ІІ, ІV the Luda Yana River by Panagurishte VK Wall lizard ІІ ІV Panagurishte VK near Panagurishte and areas to be VK Green lizard ІІ ІV flooded 4907 near Panagurishte and areas to be VK Grass snake ІІІ flooded 4907 Smooth snake ІІІ ІІ ІV Panagurishte VK Note: BDA – Biological Diversity Act (SG No 77/2002); Appendices No ІІ, ІІІ and ІV; IUCN – 2002 Red List of Threatened Species; LR – Low Risk; BC Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention) Appendices II and III; Dir. 92/43 Directive 92/43 of the EEC on the Protection of Natural Habitats of the Wild Flora and Fauna VK – Vasil Kovatchev.

The protection status of these species is not high. They are common animals well represented throughout the country. The Wall and Green Lizards and the Smooth Snake are common species that occur throughout the Sredna Gora Mountain.

Number and density of the populations of the species established in the area under consideration

In the territory to be flooded, nearly all the amphibians and the water snake are to be found in the swampy sections near the river that have originated as a result of the holes left from the previous excavations for sand and gravel. Comparatively dense is the population only of the big water frog (a dominating species in the region). About 40-50 big and about a hundred small, immature specimens have been established in the river and the swampy areas. However, their density compared to other locations in the country is insignificant.

Four specimens of the other three frog species were found including: the Yellow-bellied Toad; 2 specimens of the Great Toad after recent metamorphosis and one of specimen of the European Tree Frog after recent metamorphosis, and one Forest Frog – an adult individual. Such density, especially in a season shortly after the metamorphosis, can be described as very low. No doubt that some couples of the species distributed in the region spawn in the swampy areas by the river. One specimen was established from the Green Lizard and the Grass Snake. As for the species that have not been established, if any of them were to be found they would be in a very low number (some random or migrating specimen).

4.8.3 Mammal Fauna

In the area of the municipality of Panagurishte there are big natural forests of oak, hornbeam, durmast oak and Italian oak, and higher in the mountain – high-stemmed beech forests. Forests of Scots‘ and Austrian pine, red oak, walnut etc. have replaced forests that were destroyed in the past and on lands that are not

27 Luda Yana Dam EIAS

suitable for cultivation. Grazing lands are set up in all parts of the mountain. In spite of the existing urbanization and the strong anthropogenic impact on the environment, a certain number of animal species have been preserved on the territory of the municipality.

The hunting farm of Panagurishte covers an area of 17 500 ha, where red deer, fallow deer, wild boar, roe deer and mouflon can be found. There has been a recent trend for an increase of predators – wolves, foxes and jackals.

In zoogeographic terms the fauna in the region is of Palaearctic type, i.e. it is represented by species characteristic of temperate geographic zones. Here can be found both species characteristic of forest habitats, but also of open expanses, including agricultural lands. The fauna is represented by species characteristic mainly of Sredna gora region. Information on animal diversity in the region is very limited and scattered, or fully missing for most animal groups. This is most valid for the invertebrate fauna.

The methods used for evaluation of the current status are the route and survey method. Literature sources have been used. Data were collected by different specialists and are pertinent mainly in view of the future operations and planning of additional studies in this sphere. [MS 19, 20, 21, and 22]. No bat fauna has been found in the area.

The results of the studies in the region of Srednogorie and the vicinity of Luda Yana Dam show that they are inhabited mainly by Mid-European animal species. The large mammal species here are represented by the roe deer (Capreolus capreolus) and the wild boar (Sus scrofa), and after artificial spreading and successful accommodation, by the red-deer (Cervus elaphus), that is to be found in some regions of Srednogorieto. From the predators most often one can come across the fox (Vulpes vulpes), very rarely – the wolf (Canis lupus) and the brown bear (Ursus arctos), included in the Red List for 2000 of IUCN. Relatively more often one can see the hare (Lepus capensis), the beech martens (Martes foina), and the squirrel (Sciurus vulgaris).

The petty mammals are very common in that region: rodents (Rodentia) – various mice species (Apodemus spp. and Mus spp.), voles (Microtus spp.) and insectivorous (Insectivora) – hedgehog (Erinaceus concolor), very low in number are the moles (Talpa europaea) and shrews (Sorex spp., Crocidura spp.). It should be noted that the zoological investigations of the region are extremely scarce.

The mammal species to be found in the central part of Sredna Gora Mountain and the Panagurska pan valley, as well as along the river bed of the Luda Yana River and their nature conservation status are shown in Table 2.

Table 2 List of mammal species at the dam area and the Annex of the respective regulation where they are mentioned. The Bonn IUCN BDA/ The Red The Bern CITES Directive Conventio WW Species Annex Book of Convention Annex 92/43/ЕЕС LH n protected No. Bulgaria Annex No. No. Annex No. Annex No. species Hedgehog No 3; + Erinaceus eurоpaeus East European No 2 hedgehog Erinaceus concolor (Martin)) Common mole Talpa europaea Common shrew No 3; + No 2, 4 + Sorex araneus Bicolored white- + + No 2 toothed shrew Crocidura leucodon

28 Luda Yana Dam EIAS

The Bonn IUCN BDA/ The Red The Bern CITES Directive Conventio WW Species Annex Book of Convention Annex 92/43/ЕЕС LH n protected No. Bulgaria Annex No. No. Annex No. Annex No. species Lesser white-toothed + + No 2 shrew Crocidura suaveolens Souslik No 2; + +; Rez. 6 Spermophilus citellus Red squirrel (Sciurus No 3 + + vulgaris ) Forest mouse Sylvaemus sylvaticus House mouse Mus domesticus Water vole Arvicola terrestris Norway rat Rattus norvegicus House rat Rattus rattus European hare No 3; + + Lepus capensis Common vole Microtus arvalis Fox + Vulpes vulpes Badger No 3; + + Meles meles Beech marten No 3 + Martes foina Marbled polecat No 2, 3; Vormela peregusna + Weasel No 3; + No 3; + Mustela nivalis Otter No 2; 3; + No 2; + No 1; + No 2; 4 ;+ + Lutra lutra + Rez.6 Wild cat No 3; + No 2; + No 2; + No 4 + + Felis sylvestris Wild boar + Sus scrofa Wolf No 2; 4+ + No 2; + No 2; + No 4 + Canis lupus Rez.6 Bear No 2; 3; + No 2 + No 2 + No 2;4 + Ursus arctos + Rez.6 Jackal No 2 + No 2 + No 4 + Canis aureus Roe deer No 3 + + Capreolus capreolus Red deer No 3 + + Cervus elaphus Mouflon No 3 + + Ovis musimon Note: The ―+‖ after the annex number denotes that these species are covered by the respective regulation (e.g., The Bern Convention.

29 Luda Yana Dam EIAS

4.8.4 Ornitofauna

In the site area the ornitofauna (Class Aves), which is the best studied type of fauna, whose nature conservation status in Bulgaria is also best regulated, comprises species characteristic of broad-leaved forests and forest plantations in the low and middle parts of our low mountains, including Sredna gora, where due to the low height above the sea level and the availability of broad expanses, species characteristic of the lowlands can also be found. From zoogeographic perspective, the ornitofauna is of Palaearctic type, consisting of species dominating in the moderate geographic altitudes, but also some species inhabiting the southern areas of the European sub-continent. [MS 23, 24, 26]

Status of the ornitofauna in the project area

The following bird species (Aves) have been registered in the scope of the future water reservoir and the adjacent territories (List 1):

List 1 Existing bird species at the project site

1. Goshawk (Accipiter gentilis (L.)) 2. Sparrow hawk (Accipiter nisus (L.)) 3. Common buzzard (Buteo buteo (L.)) 4. Northern common buzzard (Buteo lagopus (Pontoppidan))) – in fall and winter 5. Golden eagle (Aquila chrysaetos (L.)) – overflying and soaring individuals 6. Hen harrier (Circus cyaneus (L.)) – in fall and winter 7. Hobby (Falco subbuteo L.) – overflying and soaring individuals 8. Merlin (Falco columbarius L.) – in fall and winter 9. Kestrel (Falco tinnunculus L.) 10. Partridge (Perdix perdix (L.)) 11. Woodcock (Scolopax rusticola (L.)) – during seasonal migration in fall and winter 12. Domestic dove (Columba livia (Gmelin)f. domestica) 13. Wood pigeon (Columba palumbus L.) 14. Collared dove (Streptopellia decaocto (Frivaldski)) – in towns 15. Long-eared owl (Asio otus (L.)) 16. Northern common buzzard (Buteo lagopus (Pontoppidan))) – in fall and winter 17. Tawny owl (Strix aluco L.) 18. Little owl (Athene noctua (Scopoli)) – mainly in towns 19. Swift (Apus apus (L.)) – when hunting 20. Pallid swift (Apus pallidus (Shelley)) – when hunting – nesting in towns and in the ―Assarel Medet‖ complex 21. Bee eater (Merops apiaster L.) – during seasonal migrations 22. Hoopoe (Upupa epus L.) 23. Green woodpecker (Picus viridis L.) 24. Greater spotted woodpecker (Dendrocopos major (L.) incl. In town 25. Syrian woodpecker (Dendrocopos syriacus (Ehr.)) – incl. in town 26. Lesser spotted woodpecker (Dendrocopos minor (L.)) 27. Crested lark (Galerida crastata (L.)) 28. Wood lark (Lullula arborea (L.)) 29. Sky lark (Alauda arvensis L.) 30. Swallow (Hirundo rustica L.) 31. Red-rumped Swallow (Hirundo dahurica L.) 32. House martin (Delichon urbica (L.)) 33. Crag martin (Ptyonoprogne rupestris (Scopoli))

30 Luda Yana Dam EIAS

34. Tree pipit (Anthus trivialis (L.)) – during seasonal migrations 35. Black-headed wagtail (Motachilla flava feldeggi Mihaheles) 36. White wagtail (Motacilla alba L.) 37. Grey wagtail (Motacilla cinerea Tunstall) 38. Wren (Troglodytes troglodytes (L.)) 39. Marsh tit (Parus palustris L.) 40. Sombre tit (Parus lugubris Temminck) - rare 41. Black tit (Parus ater L.) – in fall and winter 42. Blue tit (Parus caeruleus L.) 43. Great tit (Parus major L.) 44. Nuthatch (Sitta europaea L.) 45. Tree creeper (Certhia familiaris L.) 46. Wheatear (Oenanthe oenanthe (L.)) 47. Black redstart (Phornicurus ochruros (Gmelin)) – in town 48. Whinchat (Saxicola rubetra (L.)) 49. Nightingale (Luscinia megarhynchos C. L. Brehm) – including in town 50. Robin (Erithacus rubecula (L.)) 51. Blackbird (Turdus merula L.) 52. Song thrush (Turdus philomelos C. L. Brehm) 53. Mistle thrush (Turdus viscivorus L.) 54. Fieldfare (Turdus pilaris L.) – in fall and winter 55. Ggreat reed warbler (Acrocephalus arundinaceus (L.)) – in a small swamp with dense cattail by the right bank of the Luda Yana river 56. Blackcap (Sylvia atricapilla (L.)) 57. Whitethroat (Silvia communis Latham) 58. Lesser whitethroat (Sylvia curruca L.) 59. Chifchaff (Phylloscopus collybita (Vieillot)) 60. Wood warbler (Phylloscopus sibilatrux (Bechstein)) 61. Willow warbler (Phylloscopus trochilus (L.)) – during seasonal migrations 62. Forest dunnock (Prunela modularis (L.)) – rare 63. Spotted flycatcher (Muscicapa striata (Pallas)) – more abundant during seasonal migrations 64. Raven (Corvus corax L.) – single overflying specimen 65. Hooded crow (Corvus corax L.) – single overflying specimen 66. Jackdaw (Corvus monedula L.) – in town 67. Jay (Garrulus glandarius (L.)) 68. Oriole (Oriolus oriolus (L.)) 69. Red-backed shrike (Lanius collurio L.) 70. Starling (Sturnus vulgaris L.)- incl. in town 71. Tree sparrow (Passer montanus (L.)) – in town 72. House sparrow (Passer domesticus (L.) – in town 73. Green-finch (Carduelis chloris (L.)) – in the low parts of the region – incl. in town 74. Goldfinch (Carduelis carduelis (L.)) – in the low parts of the region – incl. in town 75. Siskin (Carduelis spinus (L.)) – in fall and winter, incl. in town 76. Common redpoll (Acanthis cannabina (L.)) 77. Chaffinch (Fringilla coelebs L.) 78. Brambling (Fringilla montifringilla L.) – in fall and winter 79. Serin (Serinus serinus (L.)) incl. in town during the nesting period 80. Bullfinch (Pyrrhula pyrrhula (L.)) 81. Hawkfinch (Coccothraustes coccothraustes (L.)) 82. Corn bunting (Emberiza calandra L.) 83. Yellow bunting (Emberiza citrinella L.) 84. Cirl bunting (Emberiza cirlus L.) 85. Rock bunting (Emberiza cia L.)

31 Luda Yana Dam EIAS

That composition of species characteristic at the small project site and the adjacent lands can be evaluated as rich and due to the diverse habitats. The most numerous out of the species nesting in the forest in the region are the chaffinch and the robin, significant are also the number, respectively the pairs of the dipper, the chifchaff, the blackcap and the great tit. The most numerous of the swallows is the red-rumped swallow, followed by the swallow. In the open grass territories with small quantity of sparse wood vegetation the highest number of nesting pairs is represented by the sky lark, the corn bunting, the red-backed shrike, and close to the town – also the crested lark. Most numerous in the urban areas are the house sparrow and the house martin; significant in number are also the domestic dove, the starling, the swallow, the tree sparrow (in urban outskirts) etc. The species in List 1 that are specified in the Biological Diversity Act, Annex 2 (of plant and animal species threatened by extinction, whose conservation is a priority) (SG No 77, Section II – Protected areas, Art. 6, item 4 (2) and (3)) are highlighted in List 2 below:

List 2 Protected Bird Species from List 1 listed in BDA (Annex 2).

1. Golden eagle (Aquila chrysaetos (L.)) – overflying and soaring individuals 2. Hen harrier (Circus cyaneus (L.)) – in fall and winter 3. Merlin (Falco columbarius L.) – in fall and winter 4. Northern common buzzard (Buteo lagopus (Pontoppidan))) – in fall and winter 5. Bee eater (Merops apiaster L.) – during seasonal migrations 6. Syrian woodpecker (Dendrocopos syriacus (Ehr.)) – in town 7. Wood lark (Lullula arborea (L.)) 8. Red-backed shrike (Lanius collurio L.)

None of these species is related to river habitats and therefore are not expected to be affected by the change of river to reservoir habitat. Of the first two species here – golden eagle and hen harrier – only over flying and hovering specimen have been registered, i.e. the site and the adjacent territories are not among their reproduction habitats. Specimen of the next two species – the merlin and the short-eared owl spend only the winter period in the region i.e. they are present here only in fall and winter. High flying and hovering flocks of the bee eater are registered most often during seasonal migrations, but the territory to be covered by the future water reservoir does not feature steep and high banks suitable for nesting.

Not only present but also nesting wood larks have been registered in the area of Assarel-Medet complex that is located in the adjacent area, to the west of the site, however no nesting pairs have been spotted in the scope of the adjoining river banks that will be covered by the site. The species features a significant number in various parts of the country, including in the region of Panagurishte.

The remaining two species in the list – the Syrian woodpecker and the red-backed shrike are quite numerous throughout the country, as well as in the project site. The Syrian woodpecker is the most popular woodpecker in urban areas and in the lowland rural areas in the country, and in this region it has been registered also as a nesting species in the area of Assarel Medet and in the town of Panagurishte. The Red-backed shrike dwells and nests in the low forest vegetation in open expanses or in the edges or thinned forest sections, including urban areas. This species is quite numerous in the country.

Mammal fauns and ornito fauna are mobile and after 1986 have been subject to strong anthropogenic pressure (construction works, suspension of construction works, harvesting of the forest vegetation and removal of the humus layer).

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4.9. LANDSCAPE

To a great extent changes have already occurred in the landscape and environment in the area under consideration. The dam wall of Luda Yana has been constructed to elevation 30 m, nearly the entire forest vegetation has been logged, the humus layer on the right bank has been removed. The stone quarry, and the sand and clay quarries have been developed and a construction site has been set up to the dam wall.

Suspension of construction works has a negative effect on the landscape because of the active development of erosion and as a consequence of the unfinished activities for remediation of areas disrupted by construction and the incomplete implementation of facilities.

4.10. SOCIAL AND CULTURAL ENVIRONMENT, HEALTH FACTORS

The population of Panagurishte municipality, on whose territory Luda Yana Dam is situated amounts to 27156 inhabitants. The municipality has potential for economic development due to the availability of significant industrial enterprises in the municipality or very close to it. Assarel Medet - one of the leading mining companies for extraction and processing of copper ore is located in the region. There are more hi-tech enterprises in the sphere of optics, optical equipment, and textiles in Panagurishte. There are good conditions for agriculture and livestock breeding.

The town of Panagurishte and the municipality are rich in archaeological, historical and architectural landmarks they offer recreation facilities, which may be conducive to development of active tourism in the region. The economic downturn in the country has affected the municipality, but now the existing base is to be expanded to serve for development of recreation and tourism in relation to the historical and archaeological heritage.

The Luda Yana river does not provide conditions for fishing neither above, nor in the vicinity of the town of Panagurishte because of the unfavorable conditions (para 4.8.1).

Transport infrastructure is good. There is a railway line from Plovdiv to the town of Panagurishte. Road infrastructure in the region is being improved. The town is connected by road to the whole country. Nevertheless the population is decreasing, and the negative growth is higher than the average value for the country (Table 3).

Table 3 Demographic data at the project area (2006).

Population Births Deaths Growth Urban centre (number) (per 1000) (per 1000) (per 1000) 1. For the country 7 679 290 9,6 14,7 -5,1 2. Towns 5 425 332 10,1 12,2 -2,1 3. Villages 2 225 985 8,3 20,7 -12,4 4. Panagurishte 27 156 8,1 15,5 -7,4 Municipality

Leading among death causes are blood circulation diseases – myocardial infarction, brain-vascular diseases, and hypertension. Secondly are registered malignant diseases and diseases of the respiratory system.

Contagious diseases that can be spread via water in the region of Pazardzhik vary in terms of: dysentheria (shigelosis) from 9,4 to 11,8 per 100 000 for 2005-2006 ; Hepatitis A virus - from 65,0 to 166,0 for the same period. There is no data about connection between these diseases and the mining operation because the water intakes draw water from the pure river sectors. These values do not differ from the mean values for the country. There are no data on the link between these diseases and water quality. Hazardous infections

33 Luda Yana Dam EIAS disseminated via the water tract, such as cholera and abdominal typhoid, have not been established in the country for over 40 years.

4.11. CULTURAL AND HISTORICAL HERITAGE

There are no data of any historical, archaeological or architectural finds on the territory of the dam. None of the above has been registered during the construction of the Luda Yana dam to this point. Visual observations and consultations with authorities undertaken during preparation of this report did not indicate the presence of any such features. Should any finds be uncovered on site in the course of dam completion and reservoir remediation, the procedures envisaged in the Law on Monuments of Culture shall be undertaken by the Institute of Archaeology and the Archaeological museum. Water supply system ―Luda Yana‖ is not connected and does not impact cultural, archeological and architectural landmarks in Panagurishte municipality.

V. EVALUATION OF THE EXPECTED ENVIRONMENTAL AND SOCIAL IMPACTS RELATED TO THE IMPLEMENTATION OF LUDA YANA DAM

5.1. AIR

5.1.1 Climate

Dam construction will inevitably result in changes in the thermo-physical properties of the base surface, and hence of the microclimate in the area surrounding the dam. The impact of artificial water reservoirs on the environment has been a subject of long-standing examinations in Bulgaria. A methodology has been developed for evaluation of microclimate features in areas surrounding dams [MS 8, 9, and 10]. According to the preliminary studies in Bulgaria, that change affects only the area of the dam since the gradient of the meteorological elements is great and that may have only a favorable impact on the unaffected flora and fauna. The availability of a huge water volume will cause a reduction in daily temperature differences, as well as to improved conditions for humidification. At the same time, the availability of an artificial water reservoir of the size of Luda Yana Dam (lake area of 142 ha and length 4500 m) will not change the climate in the relevant climatic region.

The recent decades feature significant climate fluctuations exhibited in alteration of dry and wet years, as well greater frequency of extreme phenomena such as long periods of high temperatures, lengthy draughts and heavy rains. Numerous examinations of climatic changes in Bulgaria exhibit significant statistic trends toward decrease of rainfalls and increase of temperatures, which results in reduced humidity. Luda Yana Dam will not affect adversely local climatic conditions in the region. The management plan for the water supply facility and the recommendations and measures will secure normal conditions for operation of Luda Yana Dam.

5.1.2 Air Quality Determining the type and quantity of air pollution emissions related to completion of Luda Yana Dam

During construction works

The completion of Luda Yana Dam is related to the application of technologies that are the main source of the considerable dust emissions (incl. of fine particulate matter, FPM). These will occur during excavation of earth and its loading, transportation and disposal, as well as during extraction and transportation of rock and

34 Luda Yana Dam EIAS other construction materials, necessary for completion of the site and the accompanying transportation and logistics infrastructure.

Emissions will also occur when using on site powerful construction equipment mainly with diesel traction. The latter will emit in air various harmful substances, whose quantities will be proportionate to the power and time of operation of the equipment.

The same emissions will occur when technology transportation is used for supply of raw materials and materials needed for the overall dam completion. In this case the type and quantity of emissions will be proportionate to the volume of the required loads and length of the roads along which they are to be supplied.

All three-emission factors may generate quantities that may cause temporary negative impacts on the environment during the construction works.

The availability of rock quarry materials in the flooded area of the future dam means that the application of blast technologies will be a significant factor for air pollution during the construction phase. The extraction will satisfy the requirements to form the crest and the lagging for completion of the dam.

The type and quantity of harmful substances due to extraction and transportation of construction materials (including blast technologies) may reach tens of milligrams per cubic meter of air and will depend strongly on the manner of extraction, physical and chemical properties of materials (e.g. humidity) and type of blast substances.

According to data received from Ministry of Health laboratory, referring to a similar site, air dust may reach 10 mg/m3, which exceeds the admissible limit value for a working environment.

Emissions from construction machinery

The machine fleet of construction machinery shall include:

Excavators for excavation works Bulldozers for shoveling of earth; Vybro rollers – for compaction of the embankments; Fadroma – for rehabilitation of construction roads; Compressors – for local energy operations.

The total installed capacity of the enumerated machines is estimated at 1000 kW.

The estimated quantities of gas emissions are made based on expert estimates of mean values:

Of the time in operation of the machine fleet within the planned construction period; Ratio for intense utilization of working time (per shift)

The data obtained as a result of the above conditions are specified in Table 4.

Table 4 Emissions from Construction Machinery at Reduced Operational Capacity.

Transportation regime Harmful substances SO2 NO2 VOS CH4 СО Soot Per hour g/h 2808 3400 490 12,0 1100 0,04 Per shift Kg/10h 3,3 40 70 0,1 13 0,006

35 Luda Yana Dam EIAS

Thus capacity in operation is reduced substantially. The data computed in Table 4 is based on 235 kW and specific fuel consumption from 0, 25 to 0, 30 kg/kWth. Soot from the incomplete burning of the fuel has been added to them [MS 3].

The emissions due to site transportation (Table 5) have been computed for one vehicle with diesel traction and maximum 10-km mileage for transportation of materials [MS 6].

Table 5 Emissions from Technological Transportation.

Emissions SO2 NO2 VOS CH4 СО СО2 10 km g/race 10 109 21 0,6 90 7900 Linear emission g/km 1 11 2,08 0,06 8,7 800

Based on the data in Table 5 the emissions of the listed harmful substances produced by one or two trucks for the following distances can be computed:

1. Rock quarry – the dam wall 500 m; 2. Ballast quarries – the wall three ballast quarries at a distance of 4 km 3. Clay – the dam wall up to 5 km

They will be in operation only until the project completion.

The nature of the relief – openness to the waterside of the water reservoir bed, to a great extent is conducive to quick reduction of the pollutants density and prevents their accumulation.

During the operation phase

There will be no emissions of harmful substances in the atmospheric air during the operation phase of Luda Yana Dam due to absence of pollution sources.

Defining the Strength of Impact on Air Quality

During construction works

The construction of Luda Yana Dam will be accompanied by emissions of hard particulate matter and harmful gases, both from operation of machinery and of the technological transport. In the first case, the total quantity of harmful gasses will exceed 126 kg per shift, and in case there is no natural ventilation (no wind) that may cause concentrations in ambient air on site that would exceed the admissible air values. If no measures are taken, there will be direct impacts on the environment, including a cumulative effect due to the synergy of the simultaneous presence of dust and sulphur oxides.

This impact will be temporary, and only during the construction phase, if the recommended measures are not implemented.

The distance from Luda Yana Dam to the closest settlement the town of Panagurishte, is 2 km considering the available natural shielding provided by the rolling relief. Immediately after the dam wall the river goes round an afforested hill on the left bank, which serves as a natural barrier to the town. There will be no need to pass through settlements for the transportation of construction materials for the dam wall. The gravel, sand and clay quarry are in the bed of the dam lake and they can be reached by the road to Bunay chalet. The only transportation vehicles that will pass through the town of Panagurishte will be carrying equipment, cement and additional materials for the concrete farm and will follow routes approved in advance by the municipality.

36 Luda Yana Dam EIAS

The strongly disrupted relief in the region prevents transmission of harmful substances, including from the site of Assarel Medet, established through systematic monitoring at 6 points of the air control network for the region. The same geographic factors will contribute also against transmission of pollutants from the construction site to the town of Panagurishte.

During the construction of Luda Yana Dam no change will occur in air quality in Panagurishte and the rest of the settlements around due to their remoteness from shielding of the site.

During the operation phase

There will be no harmful impacts on the population and the environment due to absence of emissions of harmful substances in the atmospheric air during the operation phase.

5.2. WATER

SURFACE WATER

During construction works

The water quantities required for construction needs and the respective water sources have been calculated. They will provide for the site until the year 2000 and can supply it until its complete construction. Water sprinkling against dust pollution is performed by water cistern cars which can take water from any available water sources. The problems of domestic wastewater from the construction site (canteen, kitchen, bathrooms) currently used by ―Hydrostroy‖ have been solved. A temporary settlement for the construction workers is not to be built. The organization of construction works is preserved from the time of implementation of the constructed part of the wall, during which the construction workers were recruited from the nearby settlements and spent the night in their homes.

The excavation works on the dam wall have been carried out and the construction of the dam wall to a height of 30 m ensures preservation of the water quality of the river during the further construction of Luda Yana dam. During the construction of the front spillway and chute in the stilling pool, it is necessary to construct a mechanical settling tank, where the construction waters will settle.

The movement of construction machinery and transportation vehicles should be strictly limited on the territory of the construction site. Transport routes should be marked. The technical condition of the machines must be inspected before each shift and those in faulty technical condition should not be operated. In case of potential emergency oil leakage, it is necessary to carry out an immediate deactivation of the soil through mechanical removal against contamination of surface and groundwater and soils. The use of the equipped and operated machinery on the Hydrostroy construction site provides the possibility for servicing the machinery park of the site.

Chemical toilets are placed on the construction sites of the quarries and the dam wall and a contract is signed with a company to service them.

During construction, safe operation is provided of the water catchments and the water supply network in the lakebed for water supply of the town of Panagurishte.

37 Luda Yana Dam EIAS

During operation

Changes in the condition of the Luda Yana riverbed

The completion of Luda Yana dam forms an artificial lake with a volume of 19,55×106 m3. The water level will rise to an elevation of 584,00 m (the highest working water level – HWWL). A dam is created with a slowed water exchange despite the continuous supply of water quantities for water supply. At the same time, the dam will stop the erosion processes in the bed. It will stop the drying up of the river section after the dam during the summer period.

Water Quality

The data from the analysis of the water quality of the tributaries and the total runoff indicate that a DWTP should be constructed. Its design and allocation of the site are pending. The DWTP will be designed, constructed and the control on the quality of the water supplied after it will be in compliance with contemporary conditions and legal requirements.

In order to ensure the quality of the dam water, cleaning vegetation and organic material from the reservoir bowl and design of sanitary security zones (SSZ) І, ІІ and ІІІ is recommended. The design and allocation of the zones is under Ordinance No. 3 on the conditions for analysis, design, approval and operation of SSZ around water sources and facilities for domestic drinking water supply.

The initial designation of the zones was carried out in the preliminary developments from 2007. The precise planning of the cleaning of the lake bowl and the zones will be carried out in the technical working design following the geodesic survey.

The two abandoned summer houses mentioned in the ЕDDR of 2007, whose structure is in a poor shape, are to be demolished (the owners were compensated). The law requirements on all related problems are presented in the documents of the Ministry of Regional Development and Public Works. The remains of the buildings will be deposited in a landfill as pointed out by the mayor of Panagurishte municipality. The terrain under the buildings will be removed to a certain depth, which will guarantee the purity of the earth foundation.

In zones І, ІІ and ІІІ, there is strict regulation of the prohibition and restrictive activities, the observation of which is controlled by the Ministry of Healthcare (MH) through its units – the Regional for Protection and Control of Public Health (RIPCPH).

Sedimentation

The design of IPP ―Vodproekt‖ and the updated hydrological data of ―Energoproekt – Hydroenergetika‖ OOD do not distinguish the defined deposits, and the dead volume is preserved to the amount of 2,2×106 m3. There are no data on the quality of the sediment load of Luda Yana River. During the detailed design phase samples of the deposits in the river flow before the dam wall will be taken. After cleaning of the lakebed and the constructed SSZ І, ІІ and ІІІ, there is limited danger of contamination of the deposits. In these conditions, the existing and future land use in the watershed does not change the operation and operation life cycle of the dam.

The environmental management plan of Luda Yana dam will include the possibility for cleaning the lake of sediment deposits when the main water outlet is put in operation in the event of high water when the turbidity in the river increases naturally.

In order to reduce the size of deposits coming into the dam as a result of erosion, during construction and operation a ―Technical plan for erosion containment‖ should be implemented, developed by the planning

38 Luda Yana Dam EIAS organization ―Agrolesproekt‖ EOOD. The plan is being implemented by State Forestry Enterprise Panagurishte.

Defining the Ecological Flow Regime

The construction of Luda Yana dam disturbs the regime of the natural river runoff of Luda Yana River. In order to preserve the river ecosystem of Luda Yana River in the construction of the water supply system, the design envisages the discharge of ecological water quantity to the amount of 0.170 m3/s. This value was obtained based on model analysis explained below and represents about 20% of the mean annual river runoff in natural conditions (known to be of 0.79 m3/s). An additional model analysis was carried out to specify the ecological runoff under a methodology developed in the Republic of Bulgaria [MS 1, 2, 4 and 5].

A mathematical model is used, based on the dependency of the total number of the zoobenthos on the runoff. The change of the total number is viewed as a probability process. In order to determine the model parameters, data are necessary on corresponding values of the total number and the average monthly water quantity, covering an overall vegetation period. To this end, summarized data were used from long-term nature monitoring for the whole territory of Bulgaria. The Fisher criterion and the change of the zoobenthos cenosis in different regimes of the ecological runoff are used. A program has been developed, with the help of which the calculations were made.

The regime of the ecological runoff is determined under the following scheme:

 Modeling the development of the zoobenthos in natural runoff regime (Figure 11).  Modeling the disturbed runoff regime after the dam, under a balanced method in different ecological runoff regimes (Figure 10).  Modeling the development of the zoobenthos in the obtained different regimes of disturbed runoff (Figure 11).  Comparison of the obtained rows of average monthly values of the total number of zoobenthos in a disturbed regime with that obtained in a natural one, in order to select a suitable ecological runoff regime.

For Luda Yana Dam the model has been evaluated for the proposed runoff of 0,170 m3/s envisaged in the design.

The runoff norm for the dam range was defined by the designer in the amount of 0.79 m3/s. To obtain the monthly values, HMS No. 71 250 on Strelcha Luda Yana River was used as analogue. A hydrological row of monthly values for the period 1955 – 2006 was calculated. Figure 8 shows the hydrograph of the average annual runoff for the period in question. Figure 9 shows the average annual hydrograph.

Figure 10 compares the average annual hydrographs of the runoff in a natural and in a disturbed regime after water balance computations have been made.

The ecological runoff proposed in the design amounting to 0.170 m3/s has been defined in compliance with the conditions created in the river following a number of anthropogenic impacts in the region. The analysis of the results from the model study shows that the proposed ecological runoff will maintain a stable ecosystem in the river after the dam wall (Figure 11).

To the present moment, due to the activities of ―Assarel-Medet‖ and the presence of a number of economic water consumers, the water balance of Luda Yana River is disturbed. A runoff of 0.170 m3/s will maintain Luda Yana River in good ecological condition after the dam wall – of the river and forest ecosystems and natural areas downstream. The ecological runoff will actually preserve the river during the period of low

39 Luda Yana Dam EIAS water levels, when it almost dries up in the section under review, and will ensure its good sanitary condition within the town of Panagurishte.

The thus defined ecological runoff is in compliance with § 125 of the Transitory and Final Provisions of the Law for Amendment and Supplement of the Water Act: ―Until the methodology under article 135, item 1 is issued, the minimum admissible runoff in rivers is defined as 10% of the average multi-year water quantity, but not less than the minimum average monthly water quantity with availability 95% to the point of each facility for runoff regulation or water intake.‖ This regulates by law the minimum admissible runoff in rivers in case their natural regime has been disrupted as a result of construction works on water supply facilities. For Luda Yana Dam the Qec. = 0,170 m3/s corresponds to 21,5 %Qo.

1.6 Q, m3/s 1.4

1.2

1

0.8

0.6

0.4

0.2

0 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005

Year

Figure 8

1.600 Q, m3/s 1.400 1.200 1.000 0.800 0.600 0.400 0.200 0.000 1 2 3 4 5 6 7 8 9 10 11 12

Month

Figure 9

40 Luda Yana Dam EIAS

1.600 Q, m3/s 1.400

1.200 undisturbed conditions 1.000 disturbed conditions 0.800 0.600 0.400 0.200 0.000 1 2 3 4 5 6 7 8 9 10 11 12

Month

Figure 10

400 total benthos 350 abundance 300

250 simulated data under 200 undisturbed conditions 150 simulated data under disturbed conditions 100

50

0 4 5 6 7 8 9 10 11

Month Figure 11

The development of a model for determining of the environmental runoff (minimum admissible runoff) in river flows after construction of water supply facilities has been launched in the 1980-ies of the former century by a team comprising a hydroengineer and hydrobiologists. In 1986 the model was presented and adopted by a Scientific Council with the Research Center at the Environmetnal Protection Committee (the present MOEW). In 1987 a doctoral thesis was defended [MS 4] on the topic. The model is based on the connection between the water quantities flowing through the river and the total number of zoobenthos (the abundance of zoobenthos). Zoobenthos is recognized as an indicator for the status of the river eco-system and its abundance releates directly to the water quantity in the river. The model applies hydrological indicators, and is not based on hydraulic parameters. It allows by means of various regimes of disturbed natural river runoff to determine the size of the disturbed runoff, at which the river eco-system preserves its biological integrity. Since 1987 the panel of experts who prepeared the EIAS for Luda Yana Dam and hydrobiologists from the Institute of Zoology at the Bulgarian Academy of Sciences have been carring out a research of the condition

41 Luda Yana Dam EIAS of river flows at one of the largest hydro-technical facilities in the country – ‗Batashki vodnosilov pat‘ (after all dam walls and water intakes). The impact of disturbed runoff on zoobenthos has been established (at ‗Batashki vodnosilov pat‘ no water quantity had been let after the facilities, which were commissioned in operation in 1957-1959).

At the same time it was observed that the river flow recovers along the river sections after water containment facilities as a result of the additional water confluence, as well as the impact on the ground water, land eco- systems and residential areas. Monitoring activities were launched on many of the large rivers in Bulgaria by means of hydrobiological sample-taking for zoobenthos. Data was collected for different rivers ranging from 1 to 20 years (Osum, Vit, Iskar, Yantrs, Arda, Mesta, Vucha). It was established that zoobenthos in the rivers of northern and southern Bulgaria is identical. That made it possible to apply the model in 1995 to the 14 largest rivers in the country for a ―Strategy on the utilization of water resources and water protection in the Republic of Bulgaria‖ [MS 1]. The mathematical model was upgraded in that period and in 2000 its application was expanded to the ―Master plans for water utilization in basin management areas of the Republic of Bulgaria‖ [MS 2]. The upgrading of the mathematical model was defended in a doctoral thesis in 2004 [MS 5]. Based on the results achieved from monitoring of both natural river flows, and below disturbed water supply facilities, including such where the model has been applied to an EIAS and the proposed minimum admissible runoff is secured, it is recommended that the adopted size should be Qек.  10%Qo. This Condition underlies §125 of the Water Act (2007). The panel of experts is currently performing monitoring under the operationg hydro-technical facilities (the Iskar river, the Arda river, the Vucha river) and very good results are being achieved due to the secured minimum admissible runoff recommended in the EIAS for those sites, while for each specific case additional conditions are being considered.

In the last 10 years, different possibilities have been studied for discharge of these waters from the dams. In Luda Yana dam, this will take place from the water intake tower to a depth of 10m from the water level of the lake.

At 300 m below the dam wall the Luda Yana river flows into a left tributary, and in the town of Panagurishte gets additional left and right tributary, by which the seasonal fluctuations of the runoff are followed, in addition to the overflows from Luda Yana Dam.

The environmental runoff for Luda Yana Dam has been estimated to 0,170 m3/s taking into account past anthropogenic impacts and the location of Panagurishte 2 km below the dam, with the purpose of getting the river in good environmetal shape in the town.

Release of high waters

The release of high waters is carried out through the spillway to the wall. The updated hydrological information indicates the need of a new design of the spillway, chute and stilling pool. This will be accommodated in the detail design.

Transformation of the river ecosystem

The construction of Luda Yana dam and the formation of a water reservoir will have both a negative and a positive impact on the river inhabitants and the transformation of the river ecosystem immediately above the dam into the system of a water reservoir (still water). Gradually, the formation of a habitat typical of still water reservoirs will take place.

The negative impact comprises:

 Significant reduction of the reobionte (river species), and respectively, the species, biocenotic and functional diversity due to the decrease of the flow speed (this concerns the dam lake).

42 Luda Yana Dam EIAS

 Changes of the nature of the ground under the dam.  Possibility of appearance of eutrophication.

Positive impact comprises:

 Settling of the suspended insoluble matter.  Large-scale development of limnophila species, so that the impact is not a net loss of species richness and diversity, but instead a conversion from one type of aquatic community to another.  Increase in the trophic resources and, respectively, productivity of the ecosystem.

No studies have been carried out in Luda Yana River in terms of the macro-zoobenthos.

The studies in Austria and Bulgaria of Zhrebchevo dam show that under the dam walls, the river condition is at least one saprobe degree better than that of the respective dam lake (Prof. B. Russev, Institute of Zoology to the Bulgarian Academy of Sciences).

If the management plan of Luda Yana dam is observed and taking into account the environmental factors (eutrophication, environmental runoff, deposits, etc.), there will be no deterioration of the water quality and biological value of the river ecosystem downstream of the dam, and if the measures prescribed in the EIA report are applied, an improvement of the overall ecological condition of Luda Yana river can be achieved.

Cumulative effect

In the vicinity of the Luda Yana water supply system there are no hydro-technical facilities constructed or planned for construction other to contribute to a cumulative effect from its completion.

The construction of Luda Yana dam ensures adequate water supply for the population in the municipalities Panagurishte, Pazardzhik and Strelcha, creates the possibility for achieving a ―good‖ ecological condition of Luda Yana river, containment of the erosion in the zone of impact of the water supply system, development of certain recreation activities, and as a whole contributes to the economic development of the town of Panagurishte, including as a tourist destination.

GROUNDWATER

Control is necessary on water infiltration through, under and along the wall, and especially of the waters filtrating through the wall, for presence of suffusion. Control is exercised through a piesometric system, which is a part of the control and measurement sytem at the water power facility for monitoring and evaluation of the dam wall condition.

5.3. GEOLOGICAL ENVIRONMENT

During construction

The technical and geological studies (para 4.3) prove the feasibility of construction of the selected dam wall type.

Despite the good results from the engineering-geological and hydrological surveys (in the design and in 2007), it is recommended that three test drills be made through the whole core trunk and test filtration studies be made in them. For the stability calculations of the dam wall, it is necessary to obtain strength deformation parameters for the clay core and the material from the support prisms in depth. To this end, it is necessary to plan sample taking from these material with drill developments.

43 Luda Yana Dam EIAS

The study of the quarries in 2007 proved the availability of the necessary quantity and quality of the material to be put in the wall.

During construction, it is forbidden to dispose domestic and construction waste, fuel and oil materials, or other pollutants in an illegal manner.

During operation

Regular monitoring should be carried out of the regime of inflow in the dam bowl and runoff from it, in order to prevent emergency situations during heavy rainfall and intensive snow thaw.

The inbuilt in the wall control and measurement equipment should monitor the wall behavior. This comprises deformations in the wall and base, state of the diaphragms, sinking and shift of the crown, berms and geological base.

Contingency plans should be developed to guarantee dam security in the event of emergencies. The dam is located in a seismicity zone of 8th degree.

5.4. SOILS

During construction

The change in land use was carried out in accordance with legal procedures. Expropriation of the terrains was completed in compliance with the active normative base (State Forestry ―Panagurishte‖).

Because of existing active erosion in the lake bed and adjacent territory it is necessary that the implementation of the ―Technical Plan for Erosion Containment‖ developed by Agrolesproekt EOOD should begin as soon as possible when with dam construction resumes.

The impact of completion of Luda Yana dam on soils is related to the fact that the water supply system will be constructed on terrains under severe anthropogenic impact.

The forest and other vegetation have been felled and a large part of the humus layer has been removed and deposited in the humus depots. The depots are for temporary storage of humus until it is used under the reclamation plan. The height of the humus depots must not exceed 10m. It is obligatory that no contamination or destruction of the humus layer be allowed. The total volume of removed humus layer is estimated at about 22 000 m3.

A new construction site is not planned. The ―Hydrostroy‖ site will be used that has been constructed for the needs of the construction works in 1986 and where the auxiliary plants are located: concrete unit, motor- depot, warehouse and other areas and buildings relevant to construction works..

The soil contamination on adjacent lands with dust, gas fumes and blast works during construction is insignificant and conclusions are based on experience in construction of similar dam walls, as specified in Chapter VІІ А.

During operation

The total flood territory amounts to 142 ha, which under the forest development plan of SF ―Panagurishte‖ of 2002 are part of it, but have been excluded for dam construction. The expropriated agricultural lands are abandoned and are not used.

44 Luda Yana Dam EIAS

5.5. WASTE

Type, character and quantity of generated waste

The forecast assessment of the type and character of generated waste in dam completion is related to the construction completed to present date and the need for activities to be carried out during implementation of construction works for site completion.

Generated waste resulting from implementation of the construction and mounting works in dam completion can be viewed in two stages:

1. During the construction of the remaining part of the site. 2. During site operation.

During construction domestic and construction waste is generated. No new site is planned for daily storage of suttering, fittings and construction machinery. The ―Hydrostroy‖ site built in 1986 will be used for this purpose.

During dam operation mainly domestic waste and waste from repair works will be generated. Their collection, storage and transportation should also be in compliance with the Waste Management Act.

In the completion of Luda Yana dam, waste will be generated which could be divided into:

 Domestic waste, generated by the construction workers and staff involved in site operation.  Construction waste. These will be generated during excavation, embankment, formwork, strengthening, concrete and formwork works on the site. These comprise mainly:  Waste from forestry. These result from the felling of the remaining forest vegetation (Scots pine culture) on a small remaining area of about 0.5-0.6 ha and from completion of the cleaning of the lake on an area of 142 ha. The amount of this type of waste will be small.  Hazardous waste

A small amount of moderately hazardous waste is generated both in the implementation of the investment proposal and during its operation. It comprises as follows:

 Laminated boxes from paint and polish.  Packaging containing remains of hazardous substances or contaminated with such.  Glue packaging.  Spent engine oil from construction machinery  Waste from oil and liquid fuel.  Mixed packaging from raw materials and materials  Luminescent lamps

The individual types of waste with their codes, under Ordinance No. 3 of MEW and MH of 2004 on waste classification (SG, v. 44/25.05.2004), generated during the implementation of the investment proposal and operation of Luda Yana dam are shown in Annex 5.

Methods of collection, transportation, storage, detoxiacation, treatment, recycling and disposal

Collection, transportation, temporary storage, detoxication, treatment, recycling and disposal shall be performed compliance with the requirments of the Wastes Management Act.

45 Luda Yana Dam EIAS

Description, analysis and assessment of the supposed significant impact on the population and environment, resulting from waste generation and creation of discomfort

During the completion of Luda Yana dam, there is a risk that the waste generated during site construction and operation will have an impact on the individual components of the environment (ambient air, landscape, surface and groundwater, soils, wildlife) and human health, if the measures for their reliable management under the normative framework (the Waste Management Act) are not implemented.

Possible impact during construction

During construction, more construction waste will be generated compared to the domestic waste. This waste should be treated in compliance with the normative waste management framework adopted in Bulgaria. Possible impact can be summarized as follows:

Air Quality

Harmful impact on the air could be generated by potential unregulated and illegal incineration of some types of construction waste instead of their separate collection and storage, transportation and detoxification in an environmental way. Their incineration could result in harmful emissions, which will contaminate in an uncontrolled way the air in the site region for a certain period of time. This type of waste includes packaging from polyethylene, wood materials, composite multi-layer packaging, mixed packaging from raw materials and materials, residue from paint, inks, glues, adhesives and resins containing hazardous substances, wood material from construction, paper and cardboard packaging, packaging containing residue from hazardous substances or contaminated with hazardous substances.

Landscape

In the event of uncontrolled disposal of construction waste, the surrounding landscape will be disturbed on adjacent terrains as a result of the anthropogenic impact of this waste on it. A result of dissemination by the wind of small fractions of this waste at large distances and their detention in shrubs and trees, a negative visual effect will be observed. The predominant part of this scattered waste is hardly degradable in the course of many years and will result in sustainable damage of the landscape.

Water

There is a risk of water contamination in the event that during construction generated waste is not collected, stored, transported and deposited in the depot in the town of Panagurishte. First, the ambient water running along the slopes of the waste stored on site and not transported will be contaminated. It, in turn, can contaminate the surface water, in this case – the water in Luda Yana River – or some of it can infiltrate down to the subsurface aquifers and cause significant and sustainable contamination in some aquifers.

Soil

Some of the waste generated during construction is classified as hazardous. If irresponsible and uncontrolled disposal (storage) of this waste is allowed on site territory, as a result of the flow of ambient water down the slopes or their infiltration through the waste, the underlying soil will be contaminated.

Wildlife

The uncontrolled disposal (storage) of waste allows free access of animals and birds to it. This free access to illegally deposited waste, the use of the surrounding vegetation and the waste itself for food can lead to the

46 Luda Yana Dam EIAS spread of diseases at undetermined distances, as well as the death of some animals and birds. In this way, the biodiversity in the region will be disturbed.

Possible impact during operation

During operation, mainly waste would be generated from repair works. Taking into account, however, the fact that repair works will be required rarely, it can be said that their generation will be one-time, they will be small in quantity and the collection, storage and transportation for detoxification will not pose a problem. As for domestic waste – during operation this will be insignificant in quantity. It is necessary to place suitable containers for their collection and storage and organize their transportation to the waste depot in the town of Panagurishte.

Cumulative impact

If the prescriptions and conditions in the normative framework for waste management are observed, the impact of the waste generated on site territory on the individual components of the environment will be insignificant and without cumulative impact.

5.6. HARMFUL PHYSICAL FACTORS

Noise

During construction

The sources of noise in the environment are most types of works related to the completion of the water supply system (excavation, embankment, concrete, formwork, mounting, drill and blast, transport). The levels of noise emitted by the main used machines and equipment are: excavator – 8091 dBA; bulldozer – 97105 dBA; motor-crane – 9298 dBA; asphalt mixer – 84 dBA; concrete mixer – 8893 dBA; roller – 87 dBA; vibromass – 98106 dBA; stone grinding installation – 8896 dBA; drill hammers – 105120 dBA; heavy automobiles heavy-weight automobiles – 8590 dBA; compressors – 8699 dBA. During blast works, impulse noise is emitted with levels depending on the blast system. Construction equipment is concentrated on specially designated territories and sites: terrain for construction of the main site – dam wall, the DWTP, auxiliary and production facilities – stone quarry, ballast quarries, clay pit, concrete facility. The expected equivalent levels of noise on the individual construction sites in the immediate vicinity of the groups of operating machinery and facilities are around, and sometimes above, 90 dВА.

The technological road network for the transport vehicles servicing the construction has been completed. The heavy-duty vehicles, depending on the intensity of traffic, will generate noise with an equivalent level of about 60-61 dВА, at a distance of 7.5 m from the axis of traffic.

The limit values of the noise level for the different territories and zones regulated in Ordinance No. 6 on the indicators for noise in the environment (MH, MEW, 2006) are: for residential territories: day – 55 dВА, evening – 50 dВА, night – 45 dВА; for production and storage zones: day, evening and night – 70 dВА.

The nearest settlement – the town of Panagurishte – is about 2 km away from the site of the future dam. Due to the sufficient distance of the town, the construction activity on the site will not be a source of noise for it. The transport servicing the construction will move only from the lakebed to the wall and will not pass through settled areas. The freight vehicles delivering equipment, cement, fittings and transporting waste will pass through approved routes in the town of Panagurishte and will not have an impact on the noise regime on its territory.

47 Luda Yana Dam EIAS

During operation

During site operation, a source of noise will be the equipment of the future DWTP (pumps, mixers, blowfans, hydrophore, etc.). According to their technical characteristics, the levels of emitted noise are within the range of 70-75 dВА. The equipment will be placed in a massive building with concrete construction, with expected sound insulation of the façade walls not lower than 35 dВА. Noise levels outside the building higher than 45 dВА are not expected, which is quite below the hygiene norm of 70 dВА. The DWTP and the two possible sites are at a distance sufficiently away from the town of Panagurishte.

5.7. PLANTS

During the construction period

During the construction of the Luda Yana dam felling of the remaining small area (0.5-0.6 ha) of Scots pine plantation near the dam and the rehabilitation of the lake with an area of 142 ha must be completed.

No impacts on the forest tree, grass and brush vegetation (outside the floodplain) are expected during the construction period.

The particular vegetation on the DWTP site that will be affected will be known after the project is developed. The selection of the site for the DWTP will take into account the need to avoid damage to any ecologically significant vegetation.

During the operation

The project requires flooding of 142 ha toward the Panagurishte State Forestry Board (the lake is designated in white color on the map), and this area has been excluded from the state forestry board area for the construction of the water reservoir.

The studies carried out in 2007 for the Due Diligence report established that the forest tree vegetation (except for 0.6 dca Scots pine plantation) had been cleared, and the top-soil had been stripped over a large part of the lake bed area. In these circumstances no rare or endangered species were found among the plant species, in accordance with the regulations.

Securing of the minimum admissible flow in the Luda Yana river during low-water summer periods, the overflow of the dam and the additional water inflows (three river flows) will impact favourably the affected 2 km section.That will be conducive to the development of typical riverside vegetation and may indirectly affect positively the eco-system of the river below Panagurishte, as well as its adjacent territories.

5.8. ANIMALS

The forecasts for the impact of the Luda Yana dam on the animals was based on the assessment of the status made in item 4.8 in consideration of the significant anthropogenic activities in the area and in the Luda Yana River itself. No threatened or endangered species are expected to be affected and most animals presently located within the reservoir basin are expected to move to other locations. The creation of the lake upstream of the dam and the assured continuous environmental flow downstream will lead to increase of some water- related species.

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5.8.1. Ichthyofauna

Assessment of the impact on the ichthyofauna Expected impact on the river ichthyofauna

1. No direct impacts on the ichthyofauna along the middle stretch of the river is expected during the construction works for completion of the dam. 2. The commissioning of the Luda Yana dam will be conducive to the stabilizing of the flow regime along the middle stretch of the Luda Yana river by means of controlled releasing of the ecological flow and will, therefore, have a positive effect on ichthyofauna in this area. The expected improvement of the population of Maritsa barbell is particularly important because this species is indicative of the ecological status of the water body. 3. The filling of the reservoir will enable the creation in the basin and in the upper stretches of the river of a stable fish community based on a brook trout population with its attendant species. The brook trout population may be established naturally by the entry of the fish from the upper stretch of the river, and by artificial stocking.

Potential threats

Although the riparian biota along the middle stretch of the Luda Yana River is subject to significant negative anthropogenic impacts, there are two specific forms of potential negative impacts from the management of the future water reservoir:

 Insufficient water in the river bed;  Releasing of water from the lower layers of the water reservoir with constantly lower temperature and increased concentrations of nutrients.

The prevention of the potential negative effects and the improvement of the ecological status of the affected river stretch require measures for the achieving of good ecological status of the surface water bodies:

 Ensuring of sufficient water in the riverbed downstream of the reservoir (170 l/s during the low- water periods).  Location of the water extraction facilities, to be developed in the course of the detailed design, at a depth of no less than 10 m in order to ensure the ecological minimum.  Development of a management plan of the water in the Luda Yana river basin inclusive of measures for restoration and conservation of the biological potential of the river (waste water treatment, restoration of the habitats of fish, amphibians and invertebrates, prevention of flood events causing destruction of benthic habitats and flood plains, etc.) is ongoing as confirmed by MoEW The development of these plans has been requested under CoM Decree No. 349/27.01.2009 in the Ordinance on the terms and conditions for development and approval of Protected areas management plans (of the Luda Yana river after the Banska Luda Yana river). The current evaluation confirmed that the only site that falls under the Natura 2000 is the sanitary-protected zone of the dam (and not the water reservoir).

The above potential impacts on the ichthyofauna may be prevented completely by the implementation of the proposed measures.

49 Luda Yana Dam EIAS

5.8.2 Herpetofauna (Amphibians and reptiles)

Assessment of the impact on the amphibians and reptiles

Observations of other water impoundments with the characteristics and regime of the one under construction show that the prevalent ―thriving‖ species is the large water frog. This species may become abundant in several years from the damming of the reservoir. The remaining amphibian species will use this water impoundment for spawning and development of larvae. It is likely that grass snakes and tortoises will exist in low numbers in the less accessible areas. No substantial change of the populations of the 3 species of terrestrial reptiles will occur.

According to research data, approximately 70% of the species on the Luda Yana dam area inhabit the riverside sections of small water reservoirs (Institute of Zoology at the Bulgarian Academy of Sciences).

The population of herpetofauna in the reservoir area and around the dam is very low. The completion of the water reservoir, the rehabilitation and restoration of the vegetation around the lake will make this territory a more suitable and more acceptable herpetofauna habitat. It is particularly important to guarantee the envisaged flow downstream of the dam during low water periods.

The construction and operation of the Luda Yana dam will have no negative effects on the populations of amphibians and reptiles in the floodplains and near-by areas. Seven of the 10 established and most likely species are related to water; among those are the three species included in the IUCN Red List. No special measures for protection and subsequent monitoring are required for those species.

5.8.3. Mammal Fauna

Assessment of the impact on the mammal fauna

The study has shown that there will be no negative effects on the fauna, which is relatively mobile and would move up to higher altitudes as early as the construction phase. No substantial loss of habitats is expected with completion of the dam construction since the main flooded area is already unfavorable to most of the species. . The comparatively limited period left for the construction works, of which approximately 70% are complete, means that the remaining construction works will have relatively short duration and is not expected to have a major effect on these populations. Blasting work will not take place during the reproductive period (April/May).

5.8.4. Ornithofauna

Assessment of the impact on the ornithofauna

The construction of the dam and of adjoining facilities has already affected the land surface and the covering vegetation, as well as the habitats of a certain number of individuals of the inhabiting bird species. However, the flooded area is small in comparison to the overall extent of habitat for these species in the region.

Of the species listed in Annex 2 of the Biodiversity Act (BA), only the red-backed shrike and, to a much lesser degree, the Syrian woodpecker habitats will be affected by the construction works and flooding of the site, however, these species are much more abundant in other parts of the country, and in this area too. The pairs whose nesting areas will be affected are expected to move to new areas adjacent to the future water reservoir where there are adequate nesting areas for such species. Regarding the remaining species listed in

50 Luda Yana Dam EIAS

Annex 2, the flooded area comprises a negligibly small part of their trophic base and its destruction would not impact their existence in this part of the country to a significant extent.

A year-round releasing of the minimum admissible water quantity of 170 l/s required for the normal functioning of the river ecosystem is envisaged. Therefore, after completion of the construction there will still remain river water for drinking and bathing and foraging along the banks and in the shallows of the river, for river dependent species such as the white wagtail and gray wagtail. There are no areas within the dam system with regular (annual or seasonal) concentration of large numbers of certain bird species.

The damming may be followed by the appearance and subsequent increase of fish species that are typical of standing or slowly flowing water, which will result in an increased trophic base of certain bird species diving for fish, such as grebes (Podicipedidae), cormorants (Phalacrocoracidae), smews (Mergus albellus L.), red- crested pochards (Netta rufina (Pallas), Aythya sp. etc.) etc. The lake may attract individuals of certain other water bird species – ducks (Anas sp.), storks (Ciconia sp.), herons (Ardeidae) etc., to establish nests in the vicinity. This would be a significant increase in the ornithofauna in this part of Bulgaria, especially during the autumn and winter, which would be a positive development.

With its parameters (142 ha in area and 4.5 km in length), the reservoir is incapable of having any detrimental effect on the migrating birds in this part of Bulgaria, and once its fish stock increases, can only be conducive to the migration and wintering of piscivorous species.

This assessment means that no negative changes of the state of the species of significance for conservation and of their habitats can be expected as a result of the water reservoir. The area used for the lake is of insignificant size and will not cause any significant reduction in the trophic base of the bird species inhabiting the area, and will even increase the trophic base of a certain numbers of water fowl and piscivorous species.

The partially constructed Luda Yana dam is located downstream the confluence of three tributaries of Luda Yana river (namely Okoshka, Muleiska, and Garmidol). The run-off of the river including these streams is uneven in seasonal terms and naturally has a very low or even zero flow for part of the year, especially during summer time. Currently, the natural flow of the river is unimpeded because its flow is maintained through an outlet constructed beneath the partially completed dam. During the construction, filling and operation of the dam, an environmental flow will be maintained. The volume of this flow, which will vary seasonally to approximate the natural hydrology, has been calculated, using an accepted methodology, to maintain good environmental conditions downstream. There are no protected habitats or sensitive ecosystems or species which will be adversely affected by the change in the hydrological regime resulting from construction and operation of the dam.

5.9. LANDSCAPE

The appropriate architectural design, site reclamation and dam flooding will create the new landscape. The evaluation of the self-cleaning potential and recovery of landscape in the region in question underlines its substantial capacity for inclusion and harmonization of the water supply system of Luda Yana within the nature environment. Lakes are no foreign element to mountains and the newly created artificial lake will match the nature landscape.

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5.10. HEALTH FACTOR AND SOCIAL SIGNIFICANCE

During construction works

Concerning the population

There are no inhabited places in the vicinity of the site where the Luda Yana dam is being constructed. So non-organized noise sources from construction and transportation machinery, dust and exhaust gas emissions will have no negative impact on the population‘s health.

Concerning the construction workers

During the works negative health impacts could be produced by a number of factors, occurring in the working environment during the construction process, namely:

Non-favorable microclimate Work will be going on in all four seasons in the open, in both excessive heat and cold. Excessive heat could be a risk factor for incidents such as heat and/or sunstroke. If prolonged, such conditions could lead to dehydration, loss of salts and microelements and heat exhaustion. Excessive cold contributes to increased incidence of colds, muscular and bone complaints and disturbances of the peripheral nervous system.

Noise Drivers of heavy machinery and excavator operators will be exposed to excessive noise level to the tune of 80 - 90 to 100 dB/A. This could have negative consequences for the central nervous system, sleep disturbances, neurosis-type complaints and is a risk factor for arterial hypertension as well.

Vibrations The drivers of the heavy trucks will be exposed to general and local vibrations. Given the new technology to be used, those vibrations maybe will not exceed the admissible levels. The use of some, mostly outdated machinery may cause excessive levels of vibration, and hence damages to the vestibular system, the locomotory system and the parenchyma; also the s. c. ―vibration disease‖ may occur, which is a common occupational disease in this field of work.

Air pollution Drivers of heavy machinery and excavator operators will be exposed to exhaust gasses emissions. No harmful health effects are expected in this case, as they work in the open air. Furthermore, excavation works will be limited in volume.

Dust Construction workers are exposed to non-organized dust emissions. Large dust particles can only have an irritation effect on the upper respiratory system.

Exposure to metal aerosols and noxious gasses During welding operations various quantities of carbon oxide, carbon dioxide, nitric gases and metal aerosols (manganese, lead, iron or others, depending on the type of welding material) are emitted. If welding is performed in closed premises or inside large pipes those emissions can cause chronic occupational disturbances of the lungs (chronic bronchitis, pneumoconiosis of the siderosis type).

Traumas Construction workers suffer from the highest incidence of occupational traumas during excavation and assembly works.

Heavy labor Notwithstanding the fact that a large part of the construction operations are performed by machinery, still heavy physical labor is required in a number of operations, including the lifting and carrying of excessive weights. Another unfavorable aspect of construction work is that a lot of the operations are

52 Luda Yana Dam EIAS performed in a difficult position, requiring considerably tension of muscles and limbs. This leads to micro- traumas, diseases of the locomotory system, the nervous system and the muscles.

Conclusion The site is located away from inhabited places and no unfavorable health effects on the population can be expected during its construction. The working environment will exert certain impact on the health of the construction workers during construction works, of a temporary nature. It can be minimized by taking adequate health and safety protection measures.

During operation

No changes in air humidity or the climate or expected during the operation of the dam. It is expected to have a favorable impact for the population as new jobs will be created and new recreational spots will be set up in its vicinity. Improved water supply will guarantee the elimination of epidemic via water contamination. The fact that the population will make use of drinking water, which meets Bulgarian and European standards of quality, will have an indirect positive health impact for the population.

5.11. SAFETY OF THE LUDA YANA DAM

5.11.1 Dam Safety practice in Bulgaria

According to ICOLD3 definition, there are 215 large dams in Bulgaria. 200 dams are of the embankment type, 15 are concrete structures. The total water storage in the country is 7.6 km3.

The dams proposed within the Municipal Infrastructure Development Project are regulated by the Water Sector Department of the Ministry of Regional Development and Public Works. Such ministry is in charge of all water supply dams, for both domestic and industrial uses, in the country. Hydropower and irrigation dams are regulated by different ministries.

There is clear separation between:

a) Dam Onwer: municipal water agencies; b) Dam Regulator: Ministry of Regional Development, and c) Independent panel of experts: academics and practitioners.

Dams are classified in accordance to the potential hazard that they represent. The classification follows the one developed by ICOLD. Dam safety procedures are the same for all dams, irrespective of the hazard classification.

At each dam, permanent monitoring staff is responsible for:

 instrumentation readings;  periodic geodetic survey work;  visual inspections, and  routine maintenance works.

An operation manual contains instructions for observations and measurements to be carried out following special of extraordinary events such as large floods and earthquakes.

3 International Commission on Large Dams

53 Luda Yana Dam EIAS

Each dam has a program of technical control, which includes measurements, frequency and places of measurement for the various kinds of phenomena occurring during operation. A procedure is in place for the interpretation of observations and measurements, and for action taking based on the findings thereof. Data from the control/ measuring systems are visualized and analyzed during the same day. In case of observation of abnormal parameters and deviations from the usual values, additional measurements are carried out. At periodic intervals, generally one year, the responsible staff in the head office prepares a report on the technical performance of the dam. That report is reviewed by an expert council with participation of leading specialists. The council makes decisions about needed measures pertaining to maintenance of the dam, repairs or improvements, modifications to the program of technical control, etc.

Every dam in Bulgaria has an emergency plan, which is strictly inspected by the Regulator. Each dam site is permanently connected to the head office, the civil defense, and local government representatives. The Department of Civil Defense is responsible for the establishment of emergency preparedness plans, including evacuation. In case of emergency, the dam owner immediately informs the Department of Civil Defense on the type of risk or occurrence.

On every dam site there are emergency stockpiles of the necessary materials for handling emergency situations.

5.11.2 Specific norms and regulations

The safety of the dam is of considerable economic, social and ecological significance. Safety of Luda Yana is a consideration embedded back in the very investment proposal for the dam.

In Bulgaria dam design is regulated by the following regulations: norms for embankmentdams, published in 1986. The fundaments of design norms for hydro-engineering facilities in 1985, Norms for load and impact of waves, ice and navigation for hydro-engineering facilities in 1988, Design norms for buildings and facilities in earthquake zones in 1989. As the above-listed regulations are not recent, and given the lack of an EC code on hydro-engineering facilities design, internationally recognized standards are also used, such as those of the Fepartment of the Army US Army Corps of Engineers, German standards and others. Also followed are Bulgarian regulatory documents and standards for construction design, which are described in the design Contract. Various risks are being considered in the process of design, such as the hydrological risk of large floods, with the respective precautions envisaged and seismic risk from an earthquake of a given intensity. The designs comprise a section on a control and measurement system (CMS). Upon commissioning the site, the designs feature also a Program of Surveillance and Measurements by means of a CMC, Operations Guidelines and Emergency Action Plan (Crises Management Plan) for the duration of construction works and subsequent operation of the site. The Luda Yana dam wall is category I, hence the high safety requirements.

When the State Approval Committee checks the site to be approved for operation, it also checks whether all normative requirements have been met (Ordinance № 2/2003 on commissioning construction sites in Bulgaria and minimum warranty terms on approval of construction and assembly works (State Gazette 72/2003). The operational staff is employed at the beginning of construction and the specific teams are defined as the site is being commissioned. The duration for dams being operable is deemed to be 100 years (the time for the established volume to be filled by deposits).

To ensure safety of dam facilities, Ordinance № 13/29.01.2004 on the conditions and procedures for technical operation of dams and related facilities is to be followed. At each stage of the operation the Surveillance and Measurement Program is being updated. On the basis of the measurements the security of construction and engineering works is being assessed, as well as the impact of the dam wall on the environment (degree of danger to the natural and material goods and human health and life). Safety is assessed for normal operational mode, for work under extreme conditions and for emergencies. Two times per year the operational teams perform a visual check on the wall, the water area and the related facilities and issue a protocol with

54 Luda Yana Dam EIAS respective recommendations. The engineering analysis of the dam status is performed by a person responsible for the technical operation of the site and is based on the results of the engineering checks and measurement and control for a period of three years at most, and is approved at an expert engineering board, appointed by the owner. Inspections to evaluate the safety of the dam walls and related facilities are carried out by experts, which are not on the payroll of the person, responsible for the site‘s technical operation. The first inspection is to be carried out before reservoir filling, then at the end of the first operational period, not later than the 5th year of regular operation, and later on – by decision of an expert engineering board, appointed by the owner.

In case of high waters of a level close or equal to the highest water level (hydrological risk), and if an earthquake of a magnitude above VI by the МSK-64 scale (seismic risk), inspections are to be carried out and full measurements taken by all measurement and Control System tools for all facilities, in accordance with the Program on Status Analysis and Registration.

In extreme and emergency conditions the Crises Management Plan is to be implemented, which formulates all tasks, relationships and responsibilities of the institutions, whose responsibility it is to react in times of crises under the Crises Management Act.

Responsible for the safety of the dam wall are the technical operation team, the managers of the operational unit and the company, which ensures the dam‘s operation (ViK P Ltd, Panagurishte), as well as the respective state authority (the Ministry of Regional Development and Public Works). The Center for Early Warning is responsible for early warning in cases of disasters. The operational unit is responsible for the technical operation of the dam and the facilities therto, aquatic area of the lake and the river 500 m below the dam, in compliance with the requirments of Ordinance № 13/29.01.2004.

Risk

The risk is a possibility of certain damages occurring during an event of a given probability of occurrence. In terms of operating the Luda Yana dam, the following need to be considered:

 Hydrological risk;  Seismic risk;  Ecological risk.

Hydrological risk

The hydrological risk is the probability of certain damages caused by large floods with very low probability of occurrence. To manage such risk, the following is needed (these points will be addressed in the updated EMP prepared as part of detailed design):

 The expected flood should be defined and taken into account in calculating the type and category of the facility to be constructed (calculations provided in the updated hydrological description).  The dimensions need to be established of the facilities needed to safely discharge the large flood described above (the spillway and the chute need to be designed anew).  Emergency rules and action plan need to be formulated (Operational Guidelines, Crises Management Plan).

55 Luda Yana Dam EIAS

Seismic risk

The seismic risk is defined as the probability of certain damages occurring if earthquakes of a given magnitude take place. To rreduce, to the maximum extent possible, the damages from occurring, the following should be done as part of the detailed design review:

 A micro-seismic study of the river area where the Luda Yana dam is envisaged to be built is a must;  The geological survey for the sites, including the updated geological report should include an assessment of possible consequences on dam foundations in the event of a heavy earthquake;  Facilities should be designed and built in such a way as to provide for a safe outcome in the event of a rated seismic impact;  Rules and action plan in case of heavy earthquake during operation need to be formulated (Operational Guidelines, Crises Management Plan).

The assessment of the possible negative impacts that the existing environment can have on the investment proposal should feature both in the micro-seismic study and when the hydrologic parameters are being determined, taking into account meteorological factors and climate characteristics (provided in the updated hydrology study).

Environmental risk

The environmental risk for the dam wall and related facilities is linked to the risk of changes in the quality of the environmental components, as discussed in the EIAS. The environmental risk for the Luda Yana dam is assessed in the Risk Assessment Table on the basis of forecast.

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Table on the Environmental Risk-related to the Construction and Operation of the Luda Yana dam

Environmental Component/Factors Impact sources Atmospheric Geological Health Water Soils Waste Noise Flora Fauna air environment factor In the course of construction Dam wall and Luda Yana water + + + + + + + + + reservoir Transport routes, water supply + + + + + + + + + system During operation Dam wall and Luda Yana water + + + + + + + + + reservoir

+ low level expected ++ medium level expected

The indicated “low level”of risk is based on the overall information, presented in the Environmental analysis section and on the conclusions that have been drawn and prognoses formulated thereon.

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Luda Yana Dam EIAS

5.12. TRANSBORDER EFFECT

The Luda Yana dam is located at 2 km above the town of Panagurishte, district of Pazardzhik. The Luda Yana River is a tributary of the Maritsa River which is shared with Greece and Turkey downstream. As the dam is located in the interior of the country there will be no direct physical transborder impacts. Potential transborder effects relate to the quality and quantity of water in the Maritsa River where it leaves Bulgaria, but these will be negligible, as explained below.

Luda Yana Dam was designed in 1982 for drinking and industrial water supply and irrigation. Today, in the beginning of the 21st century, with the dynamic climate changes and emerging water shortage during the current and following decades, the reservoir volume is a strategic reserve of drinking water for the Pazardzhik district. This determines the function of Luda Yana Dam as a water supply one.

Construction Period: During construction there will be no impact because water flow will not be interrupted or reduced. The normal flow will continue through a diversion channel and measures will be taken as outlined in the EMP to prevent pollution of water from construction activities.

Impoundment Period: During the impoundment period of the dam there will be a significant reduction in the flow of the Luda Yana River at the dam site. The amount of the reduction cannot be known precisely at this time as it will depend on certain factors to be determined through the feasibility study as well as the actual amount of precipitation. The proposed volume of the reservoir at present is 19.94 million m3. The feasibility study will evaluate options for the rate of reservoir filling. For illustrative purposes, the following table provides estimated impacts on the volume of the Maritsa River at the Bulgarian border based on filling periods of one year and four years. These estimates are based on a reservoir capacity of 19.55 million m3, the mean baseline flow rate of the Luda Yana River at the dam site equal to 0.79 m3 /sec, and the baseline mean flow of the Maritsa River at the Greece border equal to 107.9 m3 per second (3,403 million m3 per year). Based on these estimates, the reservoir could potentially be filled in about one year while still maintaining the required minimum ecological flow of 0.17 m3/sec (i.e. retaining .62 m3//sec during the impoundment period) with less than 0.6% flow reduction at the border.

Impoundment Gross Volume Water retained Average flow Flow of Maritsa Flow reduction at time annually during rate River at Bulgaria border (ratio column impoundment time border 2:column 3) 12.4 months 19.94 mill m3 19.55 mill m3 0.62 m3/sec 3,403 mill 0.57% m3/year

Operational Period: The flow at the border has been calculated in the General Scheme on water use for the regions of the water basin management for the Republic of Bulgaria to amount to 3403×106 m3/per year. In the water collection area of the Maritsa river some 500 smaller or bigger dams have been constructed (the largest reservoirs are the Vucha dam, volume 226×106 m3, Belmeken - volume 144,04×106 m3, and Batak - volume 305,830×106 m3). According to the design, the maximum demand for water supply in the area is 6x106 m3/year. Assuming (as stipulated in the sewerage dimensioning rates in Bulgaria) that approximately 80% of the water fed to the water supply system is returnable, that is, it returns to the rivers through the sewer systems, the water retained in the territory of R. Bulgaria amounts to 1.2x106 m3/year , in other words about 0.035% of the run-off of the River Maritsa at the border. The Republic of Bulgaria has no treaty with the Republic of Turkey for submission of certain water quantities from the Maritsa River at the border. Bulgaria notifies Turkey through the Center for Early Warning in case of any high water creating threats for overflow of the dams along the Maritsa River.

As required by World Bank policy, in March 2008 the World Bank (on behalf of the Government of Bulgaria) sent letters to the Governments of Greece and Turkey and to the Danube Commission, notifying them of the intended project and its implications for downstream water flow. Following the initial

58 Luda Yana Dam EIAS notification, several letters have been exchanged between the Government of Turkey and the World Bank relating to the Government‘s general concerns regarding potential adverse impacts of the project on water quality and quantity, bio-capacity for cropland, grazing land and forests downstream of the proposed dams. Both Governments will receive this final EIA report and monitoring information as requested on water quality and quantity during the dam operation.

5.13. SOCIAL IMPACT

The construction of the Luda Yana dam will solve a major social problem in the municipality of Panagurishte by providing regular water supply for the population. Opportunities will be created for economic development, reduction of unemployment, and increased incomes through tourism. The municipality of Panagurishte can become an attractive cultural tourism centre with its archaeological and historic monuments and its links to the major future tourist destination ―the Valley of the Thracian Kings‖. Eco-tourism is also a major prospect for development of the region.

The project has the following advantages: no resettlement of the population is needed, no new loss of agricultural lands or pastures (those have already been expropriated when construction had begun1). Forests in the area have also been expropriated and felled (with the exception of a 0,5-0,6 ha pine grove). The humus layer has been taken away, to a large extent. The anthropogenic impact within the vicinity of the dam wall and the reservoir has mostly been exerted already.

No infrastructure sites are to be affected. The road to the Bunay chalet (an interesting tourist itinerary) has been re-routed due to the fact that it remains in the part of the reservoir that is subject to flooding. There is a legal obligation to build up a new path to the tourist site. In the course of the construction works compulsory requirements will be met concerning the normal operation of the water supply network from the dam to the town of Panagurishte. No road infrastructure is affected, and the bridges along the national road network and sound enough to permit the heavy traffic, carrying machinery and building materials. The same bridges have been used in the first stages of construction. No waste depots, irrigation or drainage systems exist on the site‘s territory.

The Luda Yana dam has a positive impact on the river eco-system under the wall by providing ample water. Favorable conditions are created for the fish population both in the reservoir and below it. The minimum flow ensured under the wall creates gradually opportunities for habitats to be created, enriching the fauna of amphibians and reptiles, mammals and birds along the river. The sanitary status of the Luda Yana river within the town of Panagurishte will be considerably improved.

VІ. ANALYSIS OF ALTERNATIVES

Possible alternatives for the Luda Yana dam construction have been considered in the ЕDDR of 2007. The studies on the possible alternatives for the Luda Yana dam construction date back to the 1980-ies. The following alternatives have been considered:

In terms of location: Several sites have been studied; the possibility of building the dam on another river; to upgrade an existing dam or to build several smaller dams. The site on the Luda Yana River proved most acceptable from an economic and an ecological point of view, and also because of the developed road network in the area. Two sites have been discussed for the Drinking Water Treatment Plant – below the dam wall or at the site of the existing DWTP servicing the town of Panagurishte. The location of the DWTP will be decided during the design process and subject to an environmental assessment.

The alternative that is closer to the town of Panagurishte is the preferred one, because it is by far the more efficient solution as compared to the existing 45 km water supply pipeline from the Maritsa river. The location of the Luda Yana dam even back in the 80-ies provided for improving the ecological status of the Luda Yana River, which suffers considerable anthropogenic pressures as a result of the economic

1 See separate Land Acquisition Policy Framework

59 Luda Yana Dam EIAS activities in the region and the needs for water supply, met by drawing water from the river. It was confirmed by MoEW that the future reservoir will be situated in a territory, which does not affect any rare or endangered flora and fauna species. Only the sanitary-protected zone of the dam will fall in the National Ecology Network (BG 0002054) which is considered to have compatible regime with those of Natura 2000.

Feasibility studies for the DWTP have been made back in 1989, but those have not been considered, as no final decision has been taken about the location and respectively, the type of the site (the choice being between a site that necessitates the water to be pumped from the dam to the DWTP and a site with gravity water supply to the network, or gravity water supply to the DWTP and pumping the water to the supply network).

In 1980 no procedure for EIA existed in Bulgaria, so environmental issues were not discussed at that time; an EIA was only made in 2000 due to which the environmental problems of the 1980-ies have not been discussed. An integrated permit is required for sites that are sources of environmental pollution through their operation. No integrated permit for ‖Luda Yana Dam‖ is required. The construction permit gives the right to start-up construction works. Such a permit was issued for Luda Yana Dam in 1986 and is still valid.

In terms of quantity of water to be fed to the water supply system Various development prospects have been considered for the regions of the towns of Panagurishte, Pazardzhik and Strelcha, as well as possibilities to provide water supply for other inhabited places (Lesichkovo). The adopted alternative for Qw = 300 l/s corresponds to the economic and demographic projections for the development of the municipalities by 2025 (it has been confirmed in the updated hydrologic data).

In terms of type of dam wall and related facilities The type of dam wall has been chosen following an analysis of the economic and operational safety indicators of a several wall types for a seismic magnitude VIII and a category II facility. The selection of the related facilities (intake water tower, front spillway with chute) was determined by the terrain and the parameters of the spillway. The updated hydrological information, the geological report and the proximity of the dam to the town of Panagurishte have changed the category of the dam wall to category I, hence the need for a new design for the spillway and the chute, and a change in the wall crown, dictated by the modified upper limit for the highest water level.

A zero option of taking “no action” has also been considered but has been rejected; as it has been proven that the Luda Yana dam is the only possible water supply source in the regions under consideration. The scarcity of water in 2008 and the strictest water supply rationing for almost 2 months proved that the zero option is not possible, and the only possibility for the region to have regular water supply is to finish the construction of the dam.

Currently the dam wall has reached a height of 30 m, and construction works have been halted for 7 years.

Possible alternatives at present time:

In view of the advanced stage of construction, at this time the alternatives which could be considered are: preserving the status quo (no further investment), completing, completing the dam at its current height (30 m) rather than at the proposed height (43 m); demolishing the dam wall and restoring the site as much as possible to its original condition. In the case of options which do not involve completing the dam, it could be considered to rehabilitate the water supply pipeline from the Maritsa river terrace.

The need to have Luda Yana dam built

All data, collected by the team, the update of the project, where the needs till 2025 have been formulated, the public discussion in the town of Panagurishte and the demand projections of ViK – P Ltd, Panagurishte indicate that there is still need for water to be supplied to the above-mentioned towns. ViK – P Ltd., Panagurishte had daily problems with breakdowns along the water supply pipeline from the Maritsa rive (it has been used for 20 years now, and has 5 pumping levels). The 45 km of pipeline from

60 Luda Yana Dam EIAS the Maritsa terrace incurs high operational costs, as it needs constantly to be controlled and consumes energy. The water from the catchment areas within the location of the future dam lake has no constant flow, is of a low flow rate or, in high water periods, of bad quality. The town of Panagurishte and the villages in the district have great potential for cultural and ecotourism to be developed, as there are considerable archeological and historical monuments in the area (not affected by Luda Yana Dam), so a regular good quality water supply is indispensable. The population considers the Luda Yana dam to be the only possibility to provide the water needed and none of the project versions included the possibility of abandoning the construction works. The only reason for them to be halted was the lack of finance, although at certain periods investments have been made on the part of the Assarel – Medet Company. Other alternatives will cause new water supply sources to be sought, but prospecting in the region for over 25 years has shown that no such sources exist there.

Environmental impacts

Preserving the status quo. In this case an update needs to be made of the wall status (2/3 of the site has been finished), and it should be conserved with adequate safety measures, hence – costs. A spillway needs to be constructed (the existing one is not usable), and a possibility should be provided for high water to be fed to the lower sections of the river, by building a power stifling pool and correction. Operational staff needs to be available to control the wall status via an updated MCS. Re-cultivation needs to be done of the quarry and the depots. A plan should be drawn up to mitigate the visual impact from the stone embankment. Other remaining issues are the dewatering of the section below the wall, the critical conditions of the ichthyofauna, progressing erosion, negative environmental impacts on the river ecosystem below the wall and the sanitary conditions of the river flowing through the town of Panagurishte.

Partial completion. A partial completion would mean to find an additional water source as the reservoir would not be adequate to meet the needs, but such an additional source has been proven to be lacking. Thus the main social issue – water supply – remains open. And as with the option described above, the additional engineering works will need to be done, at respective costs; the wall design will need to be updated in conformity with existing regulations. This option is no less investment-intensive, as new mitigation facilities will need to be built. Operational costs will be almost the same without the benefit of providing water for the three municipalities. It is not possible to compare the environmental impacts, as it is not clear what the wall height will be if it is decided to be partially completed. The same negative environmental impacts will occur as the ones described for option I.

Should an additional water supply source be sought (no such source has been proven to exist in the vicinity), new negative ecological impacts will be caused on another territory.

Demolishing the dam wall. Demolishing the dam wall will have environmental consequences which are hard to predict, because a natural passage way will have to be provided for the high waters, and some 430 000 m3 of embankment will have to be taken away and disposed of at an appropriate location. Concrete structures will have to be demolished and the territory will have to be re-cultivated. New operational guidelines and a Crisis Management Plan will have to be formulated for the duration of the works. The bad ecological status of the Luda Yana river below the dam wall will be perpetuated with all the respective consequences for the flora, fauna and for the town of Panagurishte. Anti-erosion measures will have to be implemented on a much larger scale. This option would require considerable investment without solving the water supply problem.

Rehabilitation of the water pipeline coming from the Maritsa river terrace. The water pipeline has been used for 20 years, it is 45 km long, passing through relatively difficult terrain, and has 5 pump stations. Frequent breakdowns cause often interruptions in water supply. According to ViK –P Ltd, it is not economically efficient to rehabilitate it, because, among others, energy will be used for the pumping stations, which causes the price of water to rise; even now the water price in the region is one of the highest in the country. The pipeline broke down also in 2008, and its operational limits have almost been exhausted, given its current status.

61 Luda Yana Dam EIAS

To combine the rehabilitation of the existing 45 km of water pipeline and one of the three options as proposed will not solve the problems of water supply in the region, because surface sources (components of the water supply system) have variable flow rate and do not contribute to improving the ecological status of the Luda Yana river. Rehabilitation of the water pipeline requires a major overhaul and reconstruction, which is extremely expensive and will cause the town to suffer water scarcity and a regime of lowered water supply for a long time, without providing guaranteed for its future operation.

The four options considered here are not justified and are not acceptable for Bulgaria, both in social and ecological terms. To develop the project on finishing the dam wall, which is subject to the EIAS, would mean to approve and implement all environmental impact mitigation measures.

Thus the only option is to finish the construction of the Luda Yana dam, which does not necessitate a change in the methodology, the calculations for investments (including foreign), the operational costs, the measurement and control system (the monitoring facilities) as a whole, and the benefits and costs analysis. All of those already feature in the project of finishing the construction of the Luda Yana dam in the version proposed by the Bulgarian side.

VІІ. ENVIRONMENTAL MANAGEMENT PLAN

VII.A. ENVIRONMENTAL MITIGATION PLAN

The proposed Environmental Mitigation Plan including specific mitigation actions, institutional responsibilities and some related estimated costs is presented in Annex 2.

A substantial part of the impacts on the environment have already occurred as a result of the construction of the dam Luda Yana Dam wall stopped at a height of 30 m.

70% of the construction works for the dam wall were completed by 2000: excavation works, embankment of 30 m, diverting weir, diverting tunnel, approach galleries on both slopes; construction part of the water intake tower, switchgear; 70% of the counter seepage measures and other auxiliary or temporary sub sites; the trench for the spillway and the chute was made; the rock, sand and clay quarries and the humus depot were uncovered; the road to Bunay chalet was rerouted. Road network has been implemented 100%. The remaining works comprise: the dam wall up to crown elevation, spillway and chute to the wall, installation works on the machinery and equipment of the facilities.

The construction of the dam wall to 30m already will prevent the waters of Luda Yana river from pollution through sedimentation during completion of the dam wall. During the construction of the spillway, at the end of the energy stifling pool, it will be necessary to construct a mechanical settling tank for setting of construction waters.

The remaining construction works require compliance with the technology for consequential implementation of the dam wall and quality control. These are dam activities in which the construction companies in the country have the required experience (in the country there are 16 big rock fill walls – Belmeken Dam – 98 m, and 98 big earth fill walls – Ogosta Dam – 59 m). This is the background for proposal of the Environmental Mitigation plan. It includes the required measures both during the construction phase and during the operation phase of Luda Yana water supply system.

Air

7.1. Restriction of the impacted area within the construction period. 7.2. Use of mobile sprinklers to suppress dust emission along temporary construction roads and routs through residential areas, construction sites and quarries for extraction of inert materials and rock fill.

62 Luda Yana Dam EIAS

7.3. Regular adjustment of diesel and petrol engines during the time of use of construction machinery and vehicles; compliance with the daily construction schedules in view of maximum compaction of the operational regime; limiting to a minimum the so-called „idle motion‖ of machines. 7.4. Checking of the technical condition of the construction equipment and vehicles for eventual failures, or leakages at each shift. 7.5 Emergency clean up measures for accidental spills of hazardous or polluting materials

Water

7.5. Construction of measuring profile in a suitable place below the dam, after discharge of environmental waters to control the size of environmental water quantity and securing the supply of minimum environmental flow of 0,170 m3/s from the level of the water intake tower at an appropriate depth (up to 10 m from the lake surface). 7.6. Maintaining of sanitary protection zones І, ІІ and ІІІ around the dam. 7.7. Remediation of the dam bed – felling and removal of the remaining tree vegetation and removing of the humus 7.8. Provision of chemical toilets during the construction phase, and consider a solution combined with a treatment module for the operation phase. 7.9. To maintain water supply from the lake bed during the construction phase, and disconnect the system at the appropriate stage of commissioning in operation. 7.10. Construct a mechanical settling tank for setting of construction waters prior to their discharge in the Luda Yana River during the construction of the energy stifling pool.

Geology

7.11. Drive three research probes through the stem of the core and carry out trial filtration tests in them. 7.12. Sampling of the clay core cluster and the material of the support prisms with boreholes for acquisition of their deformation-strength properties in view of the computations of the dam wall robustness.

Soils

7.13. Cleanup of pollutants in case of emergency spillages and leakages from mechanical equipment and vehicles to prevent soil pollution. 7.14. Compliance with the requirements for waste management in order to avoid soil pollution in adjoining areas. 7.15. Perform regular supervision of the water area of the lake for establishing of any land erosion or collapse during operation. 7.16. Remove the humus layer and dispose it to the two depots. 7.17. At the beginning of construction works a Technical design for erosion control shall be launched.

Harmful physical factors – noise

7.18. Heavy transportation vehicles used for construction shall comply with the admissible speed limit on passing through residential areas and the speed on the roads shall be coordinated with the municipalities work schedule.

7.19. Construction equipment and the activities shall be focused on the main construction sites.

Wastes

7.20. The provisions of the Waste Management Act shall be complied with during construction and operation. 7.21. Construction works shall be launched on the site after the Employer‘s submission of a contract with a licensed company for transportation and disposal of hazardous and non-hazardous wastes that will be generated during the construction and operation.

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7.22. Collection and proper storage of any generated wastes in the course of construction works and transportation after special agreement of the construction wastes to the landfill of Panagurishte. 7.23. The generated ―hazardous‖ wastes shall be collected, stored in environmentally friendly manner and submitted for disposal by licensed companies. 7.24. Unregulated burning of flammable construction wastes shall not be allowed.

Flora

7.25. Blast works at the stone quarry shall be performed following a ‗ no debris‘ technology. 7.26. Species appropriate for the climatic conditions in the region and with the relevant landscaping qualities shall be used for the biological remediation envisaged for the areas impacted by construction works. No invasive non-native species will be used

Fauna

7.27. Blast works at the stone quarry shall not coincide with the reproduction period of fauna (end of April and May). 7.28. Maintain the required environmental flow, varied as appropriate according to season

Landscape

7.29. Design and implement a landscaping spatial plan for the territory. 7.30. Perform at the end of the construction works remediation of the impacted areas beyond the facilities. 7.31. The building of the DWTP and the administrative building at the crest of the wall shall have a proper architectural solution and shall be painted in a proper color. 7.32. At the end of construction works the impacted section of the national road network shall be repaired.

Health

7.33. Proper bath, toilet and kitchen facilities, working outfit, personal protection kits and work and rest balance shall be secured for the workers and drivers at the dam wall. The operational personnel at the DWTP shall be equipped with the necessary protection means, including in case of emergency. 7.34. Implementation of Ordinance No 13/2004, Operational Manual and Emergency Action Plan The Emergency Action Plan shall be developed at the beginning of the construction works – for the construction period, and as of the commissioning in operation – for the operation period. It comprises all actions and situation related to industrial emergencies and natural disasters – high water, earthquakes etc.

VІІ.B ENVIRONMENTAL MONITORING PLAN

The Environmental Monitoring Plan including proposed monitoring actions, locations of sampling and frequency of collection as well as institutional responsibilities and some estimated costs is presented in Annex 3.

Prior to construction and operation the Contractor, the Implementation Unit and the Owner shall update the project environmental monitoring plan, including specifying targets and standards (for noise, water quality, etc.) to comply with the requirements in the regulatory base specified in chapter 2 and in accordance with the feasibility study and updated design.

The Monitoring Plan shall be updated, implemented, reported and controlled in compliance with Chapter II. The Project control unit established with the MRDPW shall receive all the documentation related to environmental management. The regular reports will be forwarded to the World Bank quarterly.

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Institutional responsibilities for application of the impact mitigation measures and environmental monitoring for Luda Yana Dam

During construction works

Taking of decisions on monitoring Responsibilities for Reporting implementation measures impact mitigation and (accountable person – Accountable implementation of accounting person – Operations institutions and monitoring frequency) persons MRDPW (Employer) The construction supervision Implementation Contractor RIEW Pazardzhik and RIEW, RIHSC (as per the of measures for Construction REGIONAL Monitoring Plan) impact mitigation supervision INSPECTORATE ON Construction supervision of and Employer (MRDPW) HEALTH SAFETY AND MRDPW implementation RIEW; RIHSC CONTROL (RIHSC) PIU with MRDPW to the of monitoring BD MOEW (EEA) Bank (quarterly) Iztochnobelomorski If needed – from the Region, Plovdiv accredited laboratory PIU at MRDPW to the Bank

Institutional responsibilities for application of the impact mitigation measures and environmental monitoring for Luda Yana Dam

During the operation phase

Responsibilities for Reporting Taking of decisions on monitoring impact mitigation and (accountable person to implementation measures implementation of accounting person – Accountable institutions Operations monitoring frequency) and persons VIK-P EOOD VIK-P EOOD Panagurishte Implementation VIK-P EOOD Panagurishte RIEW Pazardzhik of measures for Panagurishte RIEW Pazardzhik BD Iztochnobelomorski impact mitigation RIEW Pazardzhik BD Iztochnobelomorski Region, Plovdiv and RIHSC Region, Plovdiv as per the monitoring plan implementation BD Iztochnobelomorski of monitoring Region, Plovdiv

Environmental management is performed by the competent institutions, i.e. MOEW, BD, and EEA to MOEW, RIEW, and RIHSC. The procedure for development, evaluation and acceptance of EIA, as well as control on the implementation of adopted decisions in Bulgaria are regulated by law and are observed strictly. They are harmonized with the European directives. The MOEW comprises a Directorate on ―Prevention Activities‖ and a line deputy minister, while RIEW comprise departments on ―Prevention Activities‖. The authority of the above-mentioned bodies and their actual activities show their professional competence. There have been many cases in which they have rejected EIAS or have returned them for a revision, they have imposed sanctions, suspended construction works and operation of sites because of failure to implement their decisions, and they have withdrawn rights under EIA in case of failed deadlines. Competent authorities cooperate actively with the municipalities and through them with the population and the NGOs. The mayors of municipalities affected by the investment proposal and representatives of NGOs are members of the Expert environmental councils for consideration of EIA.

Control on use of water and water facilities, as per the decision for water intake and use of a water facility, is under the competences of the BD.

At local level recruitment of personnel for implementation of environmental management is done on a competitive basis. All employees within the system are subject to annual training at national or local

65 Luda Yana Dam EIAS level. Once per year the knowledge and skills of the operational personnel is checked and they get ‗no objection‘ to proceed with the implementation of their tasks at work.

Thanks to state financing and support under EU programs, EEA and RIEW have been equipped with modern devices for laboratory control on the status of environmental components and factors. EEA with MOEW has been accredited for performance of environmental monitoring at national level. An annual Bulletin is issued on the condition of all components.

Water and Sewerage Company of Panagurishte will take over the operation Luda Yana Dam (the dam wall and the adjoining facilities, water area and 500 m of the river section under the dam wall). It will set up an operation unit with the required skills and responsibility (Water Act, Ordinance № 13).

VIII. PUBLIC HEARINGS

Public hearings were carried out at the time of EDDR development. as follows: A public hearing was carried out on 18.10.2007 in the town of Panagurishte on the Municipal Infrastructure Development Project, including the Environmental Due Diligence Report for implementation of the requirements for this procedure (public notification was posted at the town hall and in the local media). The attendants raised the following issues: effects of future climate change, operational safety of the water supply system, risk of water level reduction in the water supply boreholes of Optikoelektron. The team provided answers to all questions asked.

The public supports the construction of Luda Yana Dam because of the urgent need to secure normal water supply in the municipalities of Panagurishte, Pazardzhik and Strelcha. During summer low water period the municipalities are on water supply rationing and during spring and autumn high water the water is of poor quality. The water pumped from the terrace of the Maritsa river comes from a system that has been in operation for 20 years and features frequent bursts and high water cost. The town has potential for development of recreational and traditional tourism, however that is not possible without a steady quantity of drinking and sanitation water.

Consultations have been made with the administrative and competent authorities:

1. RIEW – Pazardzhik. 2. Municipality of Panagurishte – meeting with Georgi Gerginekov, mayor of Panagurishte who on behalf of the municipality expressed the support of the population for the completion of the dam and its foremost importance for the water supply of the municipality and its economic development. (Appendix: Opinion). 3. VIK –P EOOD Panagurishte – At a meeting with the manager eng. G.Lulchev it was established that in 2000 an EIAS was developed for Luda Yana and a public hearing was carried out in the town of Panagurishte where no objections had been raised by the public. After its submission to the MOEW it was returned to be included in a Report for the DWTP that was not designed. No final decision has been issued by a competent authority. (Appendix: Opinion of VIK –P EOOD – Panagurishte).

The Environmental Due Diligence Reportof 2007 was submitted to Panagurishte municipality for a detailed presentation to the community. Board notifications and announcements in the local media secured access to the document. VIK- P EOOD - Panagurishte, in their capacity of a future operator, have published it on their web site.

A national public hearing on the project, including the Environmental Due Diligence Report, attended by media and NGOs took place on December 12, 2007 at the MRDPW. There have been no comments and recommendations to the Environmental Due Diligence Report that has been published on the web site of MRDPW within the deadline stipulated by law.

The recommendations made during the consultations and hearings in 2007 have been reflected in the EIAS.

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After the preparation of the EIAS (February 2009) a national hearing on the EIAS for Luda Yana Dam was carried out on 02.02.2009 at MRDPW. The Minutes of the discussion is attached herewith.

On the part of the representatives of the administrative authorities, the public and the NGOs the EIAS received a positive evaluation and approval and support for the completion of Luda Yana Dam.

The EIAS has been published on the web-site of the MRDPW within the deadline stipulated by law. A public hearing on the EIAS for Luda Yana Dam was carried out on 12.02.2009 in the town of Panagurishte. The Minutes of the public discussion is attached herewith.

The public hearing in Panagurishte has been announced in the media. The discussion was directly broadcast on the local radio and TV. Positive written opinions were presented by Vodosnabditelen complex OOD Panagurishte and the Association of Entrepreneurs – Panagurishte. The mayor of the municipality, Mr. G.Gerginkov, has deposited a subscription of 3000 citizens of Panagurishte in support of the dam completion. All the attendees gave a positive evaluation of the EIAS and their support for the completion of ‖Luda Yana‖ dam.

A meeting was held between the mayor of Panagurishte Municipality – Mr. G.Gerginkov and representatives of ViK EOOD, Panagurishte who give their approval for the EIA and support the completion of Luda Yana Dam.

As a result of the status evaluation and the envisaged insignificant environmental impact during the construction completion phase and future operation of Luda Yana Dam, in view of the social significance and improvement of the health and sanitary conditions in the municipality of Panagurishte, it is considered that the completion of Luda Yana Dam is imperative.

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Annex 1

BULGARIA MINISTRY OF REGIONAL DEVELOPMENT AND PUBLIC WORKS MUNICIPAL INFRASTRUCTURE DEVELOPMENT PROJECT

TERMS OF REFERENCE FOR

ENVIRONMENTAL IMPACT ASSESSMENT FOR DAMS’ CONSTRUCTION COMPLETION

I. BACKGROUND

1. The Government of Bulgaria (GOB) has requested the assistance of the World Bank (the Bank) in financing activities under the Municipal Infrastructure Development Project (MIDP) that will help the country meeting the EU directives on water and wastewater environmental protection, which are eligible for EU Structural Funds and not covered by other EU grants. The overall Project objective aims to improve the provision of water supply through sub-projects that will: (i) complete three water supply dams (Neikovtsi dam, Plovdivsti dam, and Luda Yana dam) where construction has ceased in the last decade, and rehabilitate a dam wall of an existing functioning dam (Studena dam); (ii) rehabilitate the water supply network in six water companies (Dobrich; Razgrad; Sliven; Smolyan; Stara Zagora; and Targovishte); and (iii) prepare projects that would be eligible to receive EU Structural Funds for water and wastewater investments needs. The above objective is fully in line with Bulgaria‘s National Strategy on Environment (2005-2014) which intends to ―provide good quality and sufficient quantity of water for various purposes‖.

2. The overall proposed Project is considered Environmental Due Diligence Report (EDDR ) category A as per Bank policies. The Bank's safeguard policies and procedures triggered for the proposed project include: OP/BP 4.01 Environmental Assessment; OP/BP 4.12 Involuntary Resettlement; OP/BP 4.37 Safety of Dams; and OP/BP 7.50 Projects on International Waterways. Furthermore, adequate protection and maintenance of ecosystems downstream of the dams should be assessed during project preparation to determine the relevance of the OP/BP 4.04 Natural Habitats and OP/BP 4.36 Forestry safeguard policies. Also, given the possibility that proposed water companies might implement projects in cities with historic districts, the OPN 11.03 Cultural Property safeguard policy might be triggered. During the project preparation the GOB prepared the following documents (i) project Environmental Framework (EF) for all proposed sub-projects; (ii) Environmental Due-Diligence Report (EDR) which assess the environmental status of the sites and the potential environmental impacts associated with the completion and operations of the proposed three water supply dam sites‘ investments; (iii) Environmental Management Plans (EMPs) for the rehabilitation investments proposed at the Studena dam site as well as those related to water distribution networks, that specify civil works contract clauses related to application of technical standards and other environmental requirements related to the construction phase; (iv) project Land Acquisition Policy Framework (PF); and (v) Notification of riparian countries under OP 7.50 through Basin Commissions.

3. The designated project EDD category A requires the preparation by the GOB of a detailed Environmental Impact Assessment (EIA) for the sub-projects related to investments for the completion of three dams‘ construction and EMP for the wall rehabilitation works of Studena dam.

The draft Environmental Impact Assessment Reports (EIAR) will be discussed and disclosed by GOB in a Public Consultation meeting that will take place before the start of the dam construction completion works and will address the environmental and social impacts related to the proposed works and dam operation as well as related mitigation and monitoring measures.

II. TOR OBJECTIVES

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4. This TOR describes the assignment that the Consultant is expected to carry out in order to facilitate proper project implementation. Specifically, the assignment relates to the completion works of three water supply dams (Neikovtsi dam, Plovdivsti dam, and Luda Yana dam) and respective water treatment plants (WTPs). The Consultant will prepare full Environmental Impact Assessment Reports (EIAR) related to these three dam sites and respective WTPs in accordance with Bulgarian environmental laws and regulations and the requirements of the Bank safeguard policies.

5. The Ministry of Regional Development and Public Works (MRDPW) in collaboration with the respective water companies will be the main counterparts of the Consultant during this assignment. The MRDPW will ensure efficient coordination with relevant agencies, and particularly with the Regional Water Companies (RWC), dam operators and local authorities. Detailed description for each ToR phase is provided under section Scope of Consultant Work. The final ToR will include any comments and reviews provided on this draft ToR by the public, stakeholders, affected communities, and appropriate regulatory authorities.

III. SCOPE OF CONSULTANT WORK

The main task of the Consultant is to assist the GoB team (MRDPW) in conducting the Environmental Impact Assessment (EIA) and preparing and disseminating the full EIA reports for the above three water supply dams‘ construction completion works based on the final agreed ToR. For the tasks detailed below, the Consultant will visit the project locations (the three dam sites) and will be in constant coordination with appropriate local government authorities (Municipalities, Water, Environment, Agriculture, Public Works institutions, dam operators), NGOs and/or research institutes for collecting necessary environmental information relevant during dam construction phase as well as operation (e.g., noise; air, water, and soil quality; traffic flow; land use and cultural heritage aspects, land ownership, etc.). During the site visits particular attention should be paid to the local public (affected people) views on environmental and social effects imposed during the future construction works. The Consultant shall review all existing technical documents on environment, health and social benefits related to the proposed dam construction investments.

The scope of work for this ToR includes the following main actions:

Task 1: Description of the Proposed Project. The Consultant shall provide a brief description of the project purpose, background and scope, using maps or diagrams (at appropriate scale), and including the following information: location; general layout; size and capacity (status of the existing dam construction, dam and reservoir specifications, location of outlets, the area surrounding the reservoir, and downstream areas, related WTP, etc.); pre-construction activities; construction activities; schedule staffing and support; facilities and services; operation and maintenance activities; appropriate regulatory standards and specifications which the Project will meet; required offsite investments and associated infrastructure (e.g., traffic patterns and access/road infrastructure); and life span of the dam and reservoir.

Task 2: Description of the Existing Environment. The Consultant shall assemble, evaluate and present complete baseline data on the relevant environmental characteristics of the study area. The description will reflect the dynamics of the current environmental components and will identify trends in the context of predicted changes over time, where applicable. The information shall include:

a) Physical environment: geology; topography; watershed hydrology at the site of the dam and reservoir and downstream areas, especially floodplain; soils; sediment quality, climate and meteorology, ambient air quality and noise levels (near affected habitation); surface and ground water resources including receiving water quality and hydrodynamics; existing sources of water pollution discharges and air emissions; (e.g., current emission and effluent volumes and characteristics, including any points of discharge from storm water and sewer treatment and collection systems), and seismic activity.

b) Biological environment: flora and fauna; rare and/or endangered species (including species migratory patterns); fish habitats, species at risks and sensitive habitats, including parks or preserves, significant natural sites or protected areas (e.g. NATURA2000); species of commercial

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importance; and species with potential to become nuisances, vectors or dangerous; characterization of wetlands if applicable.

c) Socio-cultural environment: population, land use; planned development activities; community structure; employment; distribution of income, goods and services; recreational activities (e.g., fishing operations); zoning restrictions; transportation and associated infrastructure, public health and safety concerns; cultural heritage;, A similar description of pre-dam construction conditions will be included where such information is available.

Task 3: Applicable Legislative and Regulatory Framework. The Consultant shall describe briefly the pertinent regulations and standards governing the environmental assessment process including environmental quality, health and safety, protection of sensitive areas and endangered species, sitting, land use control at international, national, regional and local levels. Also, the consultant shall describe the overall methodological approach to the EIA process including the technical approach (e.g., water or sediment core sampling, fish survey, any modeling exercise), establishment of boundaries, and integration of cumulative environmental effects as well as the effects of environment on the project into the EIA report.

 Task 4: Impact Analysis. The Consultant shall predict and assess potential significant environmental and social impacts and related risks. Based on the above review and site visits and taking in consideration the preliminary findings of the Environmental Due Diligence (EDD) Reports developed during project preparation (September 2007), the Consultant will develop a list of potential impacts and risks during construction phase (temporary) as well as operation (permanent) related to the proposed dam investments. Assessment of potential significant impacts and risks shall include: (i) Positive and negative impacts at the local, regional and national levels; (ii) Impacts on flora and fauna; (iii) Air pollution and noise impacts (particularly on sensitive recipients such as hospitals, schools, residences located next to the investments); (iv) Impacts related to drainage, soil erosion, pollution of watercourses if any, and safety; (v) Off-site impacts (camp-sites for construction workers); (vi) Impacts on sensitive areas (natural habitats; sites of historic, cultural and conservation importance), urban/rural settlements, agricultural areas; (vii) Impacts on environmental flows to be maintained downstream. Predictions of positive and negative environmental effects will consider all aspects of the proposed dam constructions, as well as cumulative environmental effects, and those that may result from accidents or malfunctions; (viii) irreversible or unavoidable impacts and impacts which can be mitigated; . The Consultant shall focus on the assessment of the following impacts: a) Social and ecological effects of reservoir inundation (e.g., loss of agricultural, forestry and grazing land, population resettlement, effects on wildlife and wild lands). b) Effects on the hydrology and water and sediment quality of the river; c) Effects on river fisheries and potential for creating a reservoir fisheries resource; d) Effects on species at risk (fauna and flora) and migratory birds; e) Impacts of altering river flow regimes downstream on the ecology of the floodplain, and the economic activities/land use on the floodplain (agriculture, livestock production, etc.); f) Impact of altering water supply and seasonality on urban, industrial, and rural users (e.g., effects on groundwater and surface water resources); g) Impacts on existing infrastructure (e.g., changes in quality of or access to infrastructure such as water supply conduits, drainage works, landfills, bridges/roads, or other public infrastructure that may be affected by dam construction); h) Potential for increased incidence of water-borne and water-related diseases; i) Impact on terrestrial and aquatic wildlife, by creation of the reservoir, disruption of migration routes, alteration of floodplain ecology, and population impacts; j) Effect of dam construction on tourism and recreation activities as well as on labor and local economy; k) Effect of existing and predicted land use in the watershed on the functioning and longevity of the dam and reservoir.

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The assessment should also take into account how the existing environment could adversely affect the proposed investments (e.g., seismic events, meteorological conditions and climate variability).

Task 5: Analysis of Alternatives to the Proposed Project. The Consultant shall:  Describe the alternatives that were examined in the course of developing the proposed project and identify other alternatives which would achieve the same objectives. The concept of alternatives extends to sitting, design, technology selection, construction techniques and phasing, operation and maintenance procedures, and other associated dam works (e.g., river diversion during construction);  Compare the alternatives in terms of potential environmental impacts; capital and operating costs (including monitoring instrumentation); suitability under local conditions; overall dam safety issues and emergency preparedness, plans for construction supervision and quality assurance (if available), and institutional training and monitoring requirements;  To the extent possible, quantify the costs and benefits of each alternative, incorporating the estimated costs of any associated mitigating and monitoring measures, operation and maintenance procedures, instrumentation and emergency preparedness plans, including the alternative of not completing the projects..

Task 6: Development of Environmental Mitigation Plan. The Consultant shall:  Recommend technically feasible and cost-effective measures to prevent or reduce significant negative impacts to acceptable levels;  Estimate the impacts and costs of those measures, and of the institutional and training requirements to implement them;  Include a brief description of contingency measures (including emergency response plans) that have been proposed to address potential accidents and malfunctions that could result in spills or unplanned releases of contaminants to the environment (such as oil or lubricants spills etc.); Consider compensation mechanisms to affected parties for impacts which can not be mitigated and can be used in the event of an unforeseen accidental event;  Prepare an Environmental Mitigation Plan including proposed work programs, budget estimates, and schedules, institutional responsibilities to implement the plan, emergency preparedness plan, staffing and training requirements, and other necessary support services to implement the mitigations measures.

Task 7: Development of Environmental Monitoring Plan The Consultant shall: (i) prepare a realistic plan to monitor implementation of proposed mitigating measures and the impacts of the project during construction and operation; (ii) estimate operating and maintenance costs and provide brief description of other inputs (such as training and institutional strengthening) needed to be carried out.

Task 8: Assessment of Environmental Institutional Capacity to manage the EA process The Consultant shall (i) Describe the national institutional responsibilities related to environmental management; (ii) Review the authority and demonstrated capability of institutions at local, regional and national levels and recommend steps to strengthen or expand their capacity; (iii) Recommend management procedures and training, staffing, operation and maintenance training, budgeting and financial support that will allow a proper implementation of the monitoring plan.

Task 9: Public Consultation Meetings. The Consultant will assist the MRDPW in carrying-out public meetings with communities that are likely to be affected, other Governmental Agencies, NGOs and other stakeholders to obtain their views on the Draft EIAR. Public meetings will be held at the 3 dam sites where the draft ToR and the EIAR findings will be presented and feedback sought. The Public Meetings should be announced locally in mass-media timely and active NGOs as well as local authorities should be invited. Minutes including questions and answers from the public meetings will be included in the Final EIAR, as well as the names of participating people.

IV. REPORTS

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The Consultant shall prepare separate EIAR for each of the three dams: Luda Yana, Neikovtsi and Plovdivtsi. Annexes including updated maps of zone of the study, pictures taken during the site visit and/or public consultation meeting information as well as any relevant information should be attached to the final EIAR. Final and draft reports will be issued in English and Bulgarian.

The EIAR should include the following chapters:  Executive Summary;  Brief description of the legal and policy framework and institutional arrangements for environmental management;  Description of the proposed project (including map of project location);  Baseline information (including socio-economic data);  Significant Environmental Impacts (including cumulative effects);  Analysis of alternatives;  Environmental Mitigation Plan;  Environmental Monitoring Plan (including monitoring evaluation and reporting system);  Public Consultation procedures and Minutes of public meetings;  Associated annexes (including information on any modeling and analysis performed).

V. QUALIFICATION AND EXPERIENCE

The Consultant will have the following qualifications and experience:

 Knowledge and experience in conducting EIA related to dam sites, review of infrastructure projects, including economic and financial analyses;  Specific experience in hydrology (including modeling); terrestrial ecology (plant ecology, forestry and wildlife); acquatic ecology and fisheries; watershed management; soil science and geology (where relevant); public health, in particular water borne and water-related diseases;  Knowledge of current Bulgarian environmental legislation and procedures as well as Bank‘s guidelines, EA procedures and operational policies;  Significant knowledge on public consultations for major infrastructure projects, in particular for water and sanitation infrastructure;  Experience in participatory design and monitoring in at least one WB funded project is a plus;  Proficiency in English and in the use of computers, word processing, spreadsheets and other basic software.

It is anticipated that the Consultant would establish a strong coordination with the Project Implementation Team and the Project counterparts.

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Appendix 1. The World Bank Operational Manual – the EMP format

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ANNEX 2 – ACTION PLAN FOR ENVIRONMENTAL MANAGEMENT OF LUDA YANA DAM

Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 During the Construction Phase Limit the affected land Reducing the size of the Dam and PWPP No additional funds Construction areas within the affected and destroyed construction sites; are required. The Contractor supervisor, construction site areas permanently Panagiurishte boundaries. Municipality environmental expert, RIEW Use mobile water Prevention and reduction Dam, SQ, service roads; Included in the Construction sprinkling systems for of pollution with dust and in dry hot weather completion costs The Contractor supervisor, Air dust suppression on the improvement of Panagiurishte temporary service roads conditions on working Municipality and routes crossing sites environmental settlements, the expert, RIEW construction sites and at the aggregate material quarry;

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Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 The operation of Restriction of spent gases Dam, SQ, service roads; Included in the costs building machines and emissions and respective permanently. of machine fleet The Contractor Construction service transport pollution in the working maintenance supervisor vehicles shall be environment supported by regular adjustment of the diesel and gasoline units; observation of the daily construction schedules with a view to the best utilization of the working hours; minimization of the „idle running‖ of machines. Checks, on per shift Non-admission of air Dam, SQ, service roads, Included in the costs Construction basis, the condition of pollution with odours and national road network; of machine fleet The Contractor supervisor, RIEW, building machines and evaporations from oil permanently maintenance Panagiurishte transport vehicles for spills Municipality spills and leakages environmental every shift; in the event expert of accidents, sequestration of the pollutants Construction of a water Provision of required Lake tail in the river Included in the cost of meter station in the dam information on received sector; dam completion, with The Contractor Construction lake tail for metering of water quantities with Dam construction phase a view to inflow supervisor, RIEW, Water water inflow. view of dam management monitoring and East Aegean prevention of floods Region BD - Plovdiv

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Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 Construction, in an Guaranteeing discharge Downstream of the dam; To be included in the appropriate place of environmental waters Dam construction phase cost upon the design RIEW, East Water (cont‘d) downstream of the for comparison with the update minimal cost* - The Contractor Aegean Region BD environmental discharge state of the river 10 000lv. – Plovdiv, RIPCPH outlet, of a water gauge ecosystem station for monitoring of the ecological discharge quantity.

* A control strip is installed in measuring profile From the Design for Conservation of water As per requirements for To be included in the The Contractor RIEW, East sanitary protection purity in Luda Yana dam zone I ; cost upon the design Aegean Region BD zones І, ІІ and ІІІ Before the end of update – Plovdiv around the water construction reservoir - benchmarking of zone І.

Sanitization of the Conservation of water The whole lake basin; Included in the project The Contractor RIPCPH, East reservoir bed purity in Luda Yana dam Before commissioning cost. Include the Aegean Region BD additional work- – Plovdiv, RIEW offshoot clearing and humus stripping in the design update – 450 000lv. Secure delivery of Securing the required Intake tower level; During Included in the project The Contractor RIEW, East ecological discharge at water quality for the river intake tower erection cost. Aegean Region BD 0,170 m3/s from the ecosystem below the dam works – Plovdiv, intake tower level; environmental expert of Panagiurishte Municipality

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Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 Erect permanent Conservation of water At SQ, dam, PWPP Funds acc. to the The Contractor RIEW, chemical toilets during purity in Luda Yana river construction sites; contract with the firm environmental the construction Before the start of performing the expert of construction maintenance Panagiurishte Municipality Maintain the delivery of Secure water supply for Lake basin, permanently No extra funds water for water supply the population from the required The Contractor Construction purposes from the lake constructed water Supervisor, RIEW, basin and interrupt it at catchments within the RIPCPH an appropriate stage of water reservoir of the commissioning water supply system Build a mechanical Conservation of water downstream of the ski- clarifier below the ski- purity in Luda Yana river jump in the course of Minimal funds The Contractor Construction jump for precipitation of (increasing the turbidity) building the spillway, the 1 500lv. Supervisor, RIEW construction effluent chute and ski-jump before discharging it in the river. Geological Base Drill 3 test boreholes Assessment of the Dam core, upon start of Provide for funds in The Contractor Construction through the whole core filtration properties of the construction the design Supervisor stem and conduct test core with view of safety update100 000lv. filtration studies in them during operation Provide for drill samples Safety during operation In the dam wall and the Provide for funds in The Contractor Construction of the clay core and the support prisms the design update – Supervisor support prisms‘ material 150 000 leva in order to obtain their strength-deformation parameters for computing of the wall robustness

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Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 In the event of Protection of soils from On the roads, SQ, dam Included in costs for accidental spills and pollution with oils and PWPP; maintenance of the The Contractor Construction leakages from In the event of accidents machines. The cost of Supervisor mechanical or transport emergency equipment, perform sequestration will be sequestration of the determined by the pollutants. actual work volume

Soils Protection of soils from All over the construction Construction Meet the waste pollution with waste area, at temporary waste Measures within the The Contractor Supervisor, RIEW, management collection & disposal ―Waste‖ component environmental requirements to prevent sites; permanently expert of soil pollution in the Panagiurishte adjoining areas Municipality Remove the humus Securing water purity in From the reservoir bed Included in the project Construction layer and designate a the dam lake and humus before commissioning cost The Contractor Supervisor, RIEW site for humus storage for reclamation In the beginning of Managing erosion in the As per design Included in the project The Contractor Panagiurishte SF construction, start dam lake and around the cost performance of the dam Erosion Control Engineering Project The heavy-duty vehicles Protection of the health On the routes through Environmental serving the dam and comfort of the settlements; permanently No funds required. The Contractor expert of construction shall keep population Panagiurishte within the permissible Municipality, the speed limit while Mayor Harmful crossing the settlements, physical factors the speed and routes Noise being agreed with the municipalities.

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Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 The building equipment Minimum impact of noise On the construction site; and works shall be permanently No funds required. The Contractor Construction concentrated, as far as Supervisor possible, at the main construction sites. Conservation of the Collection, temporary Funds depending on Waste The requirements of the purity of atmospheric air, storage, transportation waste volume, landfills The Contractor Construction Waste Management Act water and soils. and disposal; permanent location and contracts Supervisor (items 7.20 to 7.24, Protection of plants, with them RIEW Chapter 7) shall be met wildlife and human health during the construction and operation phases Blasting works at the Protecting the vegetation On the SQ site; during Included in the project The Contractor Construction Flora quarry near ligneous around the quarry from blasting cost Supervisor vegetation shall be harm performed by a ―contained blast‖ technology. For biological No import of foreign or On construction sites and Provide for extra funds The Contractor Construction recultivation of all areas aggressive species on the areas subject to in the design update Supervisor affected by the territory designated for recultivation, in the end of RIEW construction as reclamation construction envisaged in the design, use species appropriate for the climate conditions of the region and possessing the respective ―landscaping‖ properties

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Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 The blasting works, as Protection of wildlife At SQ; Reflect in the The Contractor Construction Fauna far as possible, shall not during the breeding End of April-May construction calendar Supervisor RIEW coincide with the period plan for the period end breeding period (end of of April-May April - May); Ensure release of the Securing suitable water Intake tower; during Included in the project The Contractor Construction ecological discharge quality under the dam (t0) Intake Tower erection costs Supervisor from an appropriate for fishes and other water works level of the Intake inhabitants Tower (not exceeding 10 m) Good incorporation of In all areas affected by the Provide for extra funds Construction Design and implement a site in the landscape construction; At the end in the design update The Contractor Supervisor, RIEW, landscaping plan of the of construction environmental Landscape territory; expert of Panagiurishte Municipality

In the end of Restoration of affected In all areas affected by the Included in the project The Contractor Construction construction, perform areas outside the facilities construction; In the end of costs Supervisor, RIEW, recultivation of the construction environmental affected lands outside expert of the facility; Panagiurishte Municipality The PWPP building and Good visual impact of Dam, PWPP; During the Provide for additional The Contractor Construction the administrative sites construction funds in the design Supervisor building on the dam update – 50 000lv. crest shall be in an appropriate architectural style and color design.

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Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 In the end of Restoration of the good National road network; In Funds shall be The Contractor Construction construction, repair the condition of the national the end of construction provided for in the Supervisor, damaged sectors of the road network in order to design update– national road national road network provide for traffic (in 500 000lv. infrastructure event of registered damages from construction) Health Factor Proper hygiene and Provision of a healthy On dam and PWPP Included in the project The Contractor Construction living conditions, work working environment and construction sites, SQ; costs Supervisor, clothes, personal protection of the life of permanently RIPCPH protection means, and the construction workers regimen of work and rest shall be ensured for the construction workers and vehicle drivers. During the operation phase Conservation of water For dam and PWPP Funds acc. to the By the Operating The Owner, RIEW Water Erect permanent purity in Luda Yana dam operation staff; contract with the Team chemical toilets for the and Luda Yana river permanently maintaining firm operation phase or provide for wastewater treatment During operation, Managing abrasion and The lake area; by the Included in the project By the Operating The Owner, RIEW, Soils perform regular visual landfalls against increase observation and costs of observation Team East Aegean Region inspections of the lake of deposits in the lake measurement program and measurement BD - Plovdiv water area for possible program development of abrasion and landfall processes Implementation of the Administrative building Funds depending on By the Operating The Owner, RIEW Waste The requirements of the requirements of the Act of dam and PWPP waste volume, landfills Team Waste Management Act concerning pollution of operation; permanently location and contracts

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Impact Mitigation Environmental impact Place and time of Implementation Control functions Impact on: Person in Charge Measure performance Funds performed by: 1 2 3 4 5 6 7 shall be met environmental with them components and human health endangerment Health Factor The PWPP operating Securing healthy working PWPP; permanently Included in the By the Operating The Owner, RIPQPH staff shall be supplied conditions and protection operation costs Team with the required means of the life of the of protection, inclusive operational staff for events of accidents Dam Safety Compliance with Safety during operation On the dam and PWPP Included in the By the Operating Owner, RIEW, East Regulation 13/2004, of the dam wall and its site; permanently operation costs Team Aegean Region BD– Operation Instructions facilities during natural Plovdiv, Civil and the Accident Action disasters Defense Dept. at Plan Ministry of Disasters and Accidents

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ANNEX 3 – ENVIRONMENTAL MONITORING PLAN

When shall the How shall the indicator indicator be Which indicator is to be Where shall the Financing needed Body responsible for the Impact on be monitored (type, monitored monitored indicator be monitored (cost) monitoring monitoring equipment) (frequency/regularity of measurements) 1 2 3 4 5 6 7 During construction works The Contractor, Dust, gas emission pollutions Inspectorate. Construction Regular checking, or At the prices of the due to construction and At construction sites Measurements supervision, RIEW, Air following receipt of accredited transportation mechanical and construction roads implemented by an RIHSC, environmental signals laboratory equipment accredited laboratory expert of Panagurishte municipality The Contractor, Construction Pollution of water in case of At the prices of the Below the dam wall Inspection and sample Standing In case of supervision, RIEW, Water non-compliance with the accredited and at the DWTP taking incidents RIHSC, environmental envisaged measures laboratory expert of Panagurishte municipality Means for The Contractor, Occasional leakages and At the place of Soils Inspection Standing deactivation acc. to Construction emergency spills occurrence actual volumes supervision The Contractor, At the prices of the Construction Control measurement accredited supervision, RIEW, Noise Noise At construction sites implemented by an Regular checking laboratory for environmental expert of accredited laboratory control Panagurishte municipality The Contractor, Construction Collection, temporary storage, At the sites specified in supervision, RIEW, Wastes transportation and discharge of the Waste Management Inspection Standing No financing needed environmental expert of wastes Plan Panagurishte municipality

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When shall the How shall the indicator indicator be Which indicator is to be Where shall the Financing needed Body responsible for the Impact on be monitored (type, monitored monitored indicator be monitored (cost) monitoring monitoring equipment) (frequency/regularity of measurements) 1 2 3 4 5 6 7 The Contractor, Final remediation of the lake Standing during Bed of the lake Inspection No financing needed Construction bed operation supervision, RIEW The Contractor, Flora The estimated areas Construction Standing during Reclamation affected by Inspection No financing needed supervision, RIEW, BD operation construction Iztochnobelomorski region - Plovdiv The Contractor, In the period late Fauna Blast works Rock quarry Inspection. No financing needed Construction April - May supervision, RIEW Securing the required personal The Contractor, Health factor protection kits to constriction At construction sites Inspection Standing No financing needed Construction workers and machine operators supervision, RIHSC During the operation phase By means of the installed automated equipment for Automated measuring of meteorological station temperature, humidity, Standing, following a Included under the Atmospheric air Climate Climatic factors; close to the dam wall Operation unit wind direction and developed plan project above the water level speed, solar radiation, of the dam quantity and intensity of precipitation When updating the project funds shall Designated points During summer and Comprehensive examination of By an accredited be allocated at Air Quality around the water winter period – from Operation unit NH3, NO2, NO, SO2, H2S etc. laboratory prices of the reservoir three to five years accredited laboratory In compliance with the Continuous - three Included in the Water Inflow to the dam Water inspection point plan for inspection and Operation unit times per day project cost. monitoring

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When shall the How shall the indicator indicator be Which indicator is to be Where shall the Financing needed Body responsible for the Impact on be monitored (type, monitored monitored indicator be monitored (cost) monitoring monitoring equipment) (frequency/regularity of measurements) 1 2 3 4 5 6 7 Release of minimum runoff In compliance with the The minimum cost from the water intake tower Measured profile measurement At regular intervals shall be included in Operation unit (environmental water) requirements the project update Operation unit, RIHSC, Quality of water in the ViK Panagurishte, Minimum financing dam lake and control on Major chemical, bacteriological Water intake tower, the MOEW (EEA) if Sample taking In 10 days shall be included in occurrence of and hydrobiological indicators river at the lake tail covered by National the project update eutrofication monitoring

When updating the Locality of Kartal tepe project funds shall locality of Presveta In compliance with the be allocated at Operation unit, VIK Soil Quality Major chemical indicators Once per year Nedelya; locality of sample taking plan prices of the Panagurishte, RIHSC Kukla accredited laboratory In compliance with the In compliance with Dam wall safety and At Central measuring Implementation of the recommendations of the the plan for Included in the inspection of the water station along the bank Operation unit inspection and monitoring plan Monitoring and inspection and project cost. area line measurement station monitoring

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Annex 4 – Methodologies and Sources Used in the Environment Impact Assessment Statement

National Strategy for Utilization of Water Resources and Protection of Waters in the Republic of 1. Bulgaria, 1995 – MOEW, leader R.Nikolaeva Master plans of water use in the basin management regions in Bulgaria, Sofia, July 2000. –MOEW 2. – Institute on Water Issues – Bulgarian Academy of Sciences Volume I. ―General background, methodological baseline and principles, general assessments and major outcomes‖ Part VIII. Evaluation of water volumes for conservation of river ecosystems, team leader R. Nikolaeva 7.4. Methodology for water evaluation for conservation of river systems Volume IV. Iztochnobelomorski region

3. General diagram for use of water in the Maritsa river basin 3. Methodology for balance computation of pollutants released in the atmosphere, 2000 –MOEW Zarbova K. and team, Evaluation of certain environmental changes in case of disruptions in the 4. regime of the river runoff in the riverbeds of the Yantra and the Osum rivers, NVIC of KOPS, С., 1989. Zaharieva V., Mathematical models for establishing of flooding water quantity, Yearbook of the 5. University of Architecture, Construction and Geodesy, volume ХLI, section Hydroengineering 2003/04 С., 2004. 6. Euro-3 EU standards for emissions of harmful substances emitted by motor transports Study of the geodynamic processes in the region of the G.Dimitrov dam evaluation of the 7. anthropogenic impact, 1984-1990. Concept Note and Investigation Plan for Big Dams in Bulgaria, National conference 8. ―Environmental Status of Bulgaria and future projections, Sofia, 1990, NACID No18, page 7 – G.Gergov, А.Tsenkova, М.Tsenev Investigation of the components of the mass-energy exchange within the surface air layer around the ―Koprinka lake‖, A.S.Tzenkova-Bratoeva, J.N.Ivancheva, and B.Veleva; W.L.Smith and 9. Yu.M.Timofeev (Eds.), IRS 2000: Current Problems in Atmospheric Radiation. A.Deepak Publishing, Hampton, Virginia, 2001, 1360-1366 pp. Anna Tzenkova, Meteorogical investigation around the mountain reservoir. 24th International 10. Conference on Alpine Meteorology (ICAM 1996), Bled, Slovenia, 9-13 September 1996 Pehlivanov L., Vassilev, M. 2003. Feeding of Age-1 Perch (Perca fluviatilis) with a View to the 11. Diurnal Dynamics of its Distribution in the Alexander Stamboliiski Resevoir, Bulgaria. – Acta Zoologica Bulgarica, 55 (2): 81-90 Vassilev, M., L. Pehlivanov. 2005. Checklist of the Bulgarian Freshwater Fishes. – Acta zool. 12. Bulgarica, 57 (2): 161-190 Beshkov V. 1961 Contribution to the zoogeographic study of herpetofauna in Bulgaria – Institute 13. and museum of zoology Х 373-380 14. Beshkov V. 1972 Item III Examinations on ecology and distribution ХХХVІ 125-136 15. Beshkov V. 1985 Amphibian. Reptiles – В: Red Book of Bulgaria para.ІІ Animals 32-41 Casc J-P et all 1997 Atlas of Amphibians and Reptiles in Europe Paris Soc Europe Herpetol and 16. Mus.Nat.Hist Natur 95th authors of the various chapters, paragraphs, species reviews and distribution maps in the Atlas for Bulgaria – Beshkov V. 17. Beshkov В., K.Nanev 2002 Amphibians and reptiles in Bulgaria, Pensoft сс 1-120 18. Petrov B., P.Stoev, V.Beshkov 2001 Review of composition and distribution of Amphibia and

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Reptilia in the eastern Rhodopes Beltcheva, M., R. Metcheva. 1996. Methods for estimation the food eaten, the place and functional 19. role of small mammals in ecosystems. ―National Parks and their role in biodiversity protection on Balcan Peninsula.‖, Ohrid, 143-146 Metcheva, R., A. Artinian, E. Nikolova, M. Belcheva, R. Laleva. 1997. Estimation of environmental quality using monitor species small mammals from two regions with different antropogenic influence in Bulgaria. A. Bioaccumulation of toxic elements and their influence on 20. some hystological and hematological indices. Ecomonitoring in Rozhen Srednogorie - Bulgaria. Theory and Practice-Ministry of Environment, SDC - Swiss Agency for Development and Cooperation. Sofia,113 - 119 Mecheva, R., М. Topashka-Ancheva, M. Belcheva, Tsv. Yordanova 2004. Bioindicating capacity 21. of petty mammals in zoological monitoring - Lesovudska misal.1, v.10 (29): 135 – 143 Atanassov N., R.Metcheva, S.Gerassimov 1999 – Species composition and demographic structure 22. dynamic of main species in alfalfa fields (Nord Bulgaria). Contribution to the zoogeography of the eastern Mediterranean region. V.1, 37-44 Kuchukov D. Impacts due to the operation of Assarel Medet - AD on the bird fauna in the region. 23. Lesovudska misal, University of Forestry, Sofia, 1999, No 4, 78 – 98 Yankov P. Species composition of woodpeckers in residential areas in Bulgaria, Nature (Republic 24. of Bulgaria), 1986, № 5, 65-67 25. National plan for protection of bio diversity, 2000, MOEW. Data for evaluation of the need for EIA for small hydropower plants Polatovo, Milevo, and 26. Yabalkovo on the Maritsa river. Ornitofauna 2007 – team leader R.Nikolaeva 27. Ordinance of MOEW on Environmental Impact Assessment (SG, No. 3/2006)

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Annex 5 Waste classification Code under No Type of waste Ordinance No. 3 of 2004 1 2 3 І. During construction 1. Waste from mining of non-metal ores and minerals 01.01.02 Waste fine rubble/ ballast and rubble rock materials, different from those listed in 2. 01.04.08 01.04.07 3. Waste sand and clay 01.04.09 Waste from forestry – felling of tree vegetation (Scots pine culture) on a small 4. 02.01.07 remaining area and from completion of cleaning of the lake 5. Waste from liquid fuel – other fuels (including mixtures) 13.05.08* 6. Spent engine oil from construction machinery 13.08.99* 7. Paper and cardboard packaging 15.01.01 8. Plastic packaging 15.01.02 9. Packaging from wood materials 15.01.03 10. Metal packaging 15.01.04 11. Composite/multi-layer packaging 15.01.05 12. Mixed packaging 15.01.06 13. Glass packaging 15.01.07 14. Packaging containing residues from hazardous substances or contaminated with such 15.01.10* 15. Concrete waste 17.01.01 16. Waste from tiles, plates, faience and ceramic 17.01.03 17. Wood material used in construction 17.02.01 18. Plastic used in construction 17.02.03 19. Asphalt mixtures containing coal tar 17.03.01* 20. Asphalt mixtures containing other substances different from those listed in 17.03.01* 17.03.02 21. Mixed metal waste 17.04.07 22. Cables different from those listed in code 17.04.10 17.04.11 23. Soil and stones different from those listed in code 17.05.03 17.05.04 24. Excavated land masses different from those listed in code 17.05.05 17.05.06 25. Insulation materials different from those listed in codes 17.06.01 and 17.06.03 17.06.04 26. Construction plaster-based materials different from those listed in code 17.08.01* 17.08.02 Mixed waste from construction and demolition different from those mentioned in 27. 17.09.04 17.09.01, 17.09.02 and 17.09.03*

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Code under No Type of waste Ordinance No. 3 of 2004 1 2 3 28. Paint, ink, glue/ adhesives and resins containing hazardous substances 20.01.27* 29. Paint, ink, glue/ adhesives and resins different from those listed in code 20.01.27 20.01.28 30. Mixed domestic waste 20.03.01 31. Domestic waste not mentioned elsewhere 20.03.99 ІІ. During operation 32. Mixed metal waste – from repair works 17.04.07 33. Cables different from those listed in code 17.04.10 – from repair works 17.04.11 Insulation materials different from those listed in codes 17.06.01 and 17.06.03 – from 34. 17.06.04 repair works 35. Paper and cardboard 20.01.01 36. Fluorescent pipes and other waste containing mercury 20.01.21* Paint, inks, glue/ adhesives and resins containing hazardous substances from repair 37. 20.01.27* works and maintenance Paint, ink, glue/ adhesives and resins different from those listed in code 20.01.27* 38. 20.01.28 from repair works and maintenance 39. Plastic 20.01.39 40. Metals 20.01.40 41. Mixed domestic waste 20.03.01 42. Domestic waste not mentioned elsewhere 20.03.99

90 Luda Yana Dam EIAS

Regulations

1. Environmental Protection Act (SG No.91/25.09.2002 – amended and supplemented as of 12/2009) 2. Water Act (SG No.67/01.09.1999 – amended and supplemented as of 70/2008) 3. Biological Diversity Act (SG No.77/09.08.2002 amended and supplemented as of No.94/2007) 4. Fisheries and Aquacultures Act (SG No.41/24.04.2001 amended and supplemented as of 108/2006) 5. Waste Management Act (SG No 86/2003 amended and supplemented as of 34/2006) 6. Ordinance on the terms and conditions for performance of EIA (SG3/10.01.2006 ) 7. Forests Act (SG No.125/1997 – amended and supplemented No 6/ 2009) 8. Environmental Noise Protection Act (SG No.74/2005, amended and supplemented No 30/2006) 9. Act on the Cleanliness of Ambient Air (SG No 45/1996…..No 6/2009); 10. Red Book of Bulgaria volume 2 – 1985 UN Convention on bio diversity conservation (in force in Bulgaria as of 16.07.1996 – SG No 11. 19/1999 Order No RD-272/03.05.2001 for classification of surface waters in water sites or parts thereof – 12. MOEW. CoM Decision 122 of 02.03.2007 for acceptance of a list of protected areas for wild bird 15. conservation and list of protected areas for conservation of nature habitats of wild flora and fauna. 16. Law for regulation of water supply and sewerage services 2005. Ordinance No 13/2004 on the terms and conditions for technical operation of dam walls and 17. accompanying facilities thereto – MOEW, MH, MRDPW. Ordinance No 9/16.03.2001 of MH, MRDPW and MOEW on the quality of water for drinking and 18. household purposes. Ordinance No 3/16.10.2000 of MOEW, MH and MRDPW on the terms and conditions for investigation, design, approval and operation of sanitary protection zones around water reservoirs 19. and facilities for drinking water supply and around mineral water sources used for medicinal, prophylactic, drinking and sanitation purposes. Ordinance No 5/08.11.2000 of MOEW on the terms and conditions for creation and functioning of 20. the National system for water monitoring Ordinance No 10/03.07.2001 of MOEW for issuance of permits for discharge of wastewater in 21. water bodies and determination of individual emission limits at point sources of pollution. 22. Ordinance No 6 on indicators of noise in the environment – MH, MOEW (SG No 58/2006). 23. Ordinance №7 on the hygienic requirements for health protection of residential environment; Ordinance No 14/1995, amended and supplemented as of 2007 of MH and MOEW on ALV in air of 24. urban areas. Ordinance No 26/01.10.1996 (amended and supplemented as of 2007) for remediation of impaired 25. areas, upgrading of low productivity lands and utilization of the humus layer. 26. Technical manual on hazardous substances – MOEW, 2003. 27. Standards for sizing of embankment dam walls 1986, BSA books 1 и 6 28. Design standards for hydrotechnical facilities. General principles 1985, BSA book.11/85 29. Standards for loading and impacts of hydrotechnical facilities due to waves, ice and vessels (1988) 30. Standards for design and construction of facilities in seismic regions (BSA No.1/1989) Ordinance on the terms and conditions for evaluation of compatibility of plans and programs, 31. projects and investment proposals with the conservation objectives of protected areas (SG No.73/2007) 32. Directive 92/43 of ЕЕС of the Council for conservation of nature habitats and wildlife 33. Directive 79/409 of ЕЕС of the Council for wild bird conservation

91 APPENDICES

Topographic map with plotted Luda Yana Dam

Luda Yana Dam

Panagurishte

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Diagram of Panagurishte Water Supply Complex

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Luda Yana dam map 1:1 000

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Sredna gora Protected Area Map

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Forest map including Luda Yana dam 1:10 000

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Cross section of Luda Yana dam wall 1:500

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Photos

Bird‘s eye view of the dam

View of the upstream dam batter

View of the downstream dam batter Appendices Page 7 Luda Yana Dam EIAS

View of the river valley

View of the stone borrow pit

View of the intake tower View of the diversion tunnel inlet with bottom outlet

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Entrance to the grouting gallery

River of Panagiurska Luda Yana in River of Muleiska (right tributary of Panagiurska the low- water season Luda Yana) in the low-water season

River of Panagiurska Luda Yana downstream of the dam in the low-water season

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View of the town of Panagiurishte

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LUDA YANA DAM DESIGNS

1. FEASIBILITY STUDIES – INSTITUTE FOR RESEARCH AND DESIGN (IPP) VODPROEKT SOFIA – 1982 – IN 3 VOLULMES

2. DESIGN FOR LUDA YANA DAM – IPP VODPROEKT SOFIA – 1984 – IN 16 VOLUMES

3. FEASIBILITY STUDIES FOR DWTP OF PANAGURISHTE – VODOKANAL PROEKT (VODOKANAL ENGINEERING EOOD) SOFIA – 1989 (NOT ADOPTED);

4. FINAL EIA STATEMENT ON LUDA YANA DAM – 2000, WITHOUT IMPLEMENTATION OF THE PROCEDURE;

5. RESULTS FROM WATER SAMPLE ANALYSIS PERFORMED BY INDEPENDENT EXPERTS ON REQUEST OF VODOSNABDITELEN COMPLEX OOD PANAGURISHTE

6. COMPREHENSIVE FEASIBILITY STUDY ON CONTINUATION AND COMPLETION OF CONSTRUCTION WORKS FOR LUDA YANA DAM TOWN OF PANAGURISHTE – 7 VOLUMES, FEBRUARY 2007 - ENERGOPROEKT– HYDROENERGETIKA OOD, SOFIA

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Municipality of Panagyurishte Tel: 0357 – 37 83, email: [email protected]

STATEMENT OF OPINION

Of the Municipality of Panagyurishte regarding the completion of Luda Yana Dam financed by the World Bank

Panagyurishte Municipality supports the construction of the Luda Yana Dam in view of its importance of providing regular water supply for the settlements in the Panagyurishte and Strelcha municipalities. The construction of the dam will promote the development of the economy and of tourism on the territory of the Municipality. The community supports the construction of Luda Yana Dam.

September 4, 2007 Panagyurishte

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Stamp and signature: Georgi Gerginekov, Mayor of Panagyurishte Municipality

“Water Supply and Sewerage – P” Ltd. Panagyurishte, Tax Registration No.: 1132021291, National Statistics Registration: 112106795 email: [email protected]

―Water Supply and Sewerage – P‖ Ltd. supports the completion of the Luda Yana Dam. The dam shall guarantee the required volumes of good quality potable water for the Panagyurishte and Strelcha municipalities. It will also be of significance as to the development of the flora and fauna, as well as of tourism.

Stamp and signature: T. Lulchev, Dipl. Eng., ―Water Supply and Sewerage – P‖ Ltd.

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PROTOCOL From the local public discussion on the report for the assessment of the impact on environment for the completion of the Luda Yana Dam

Organizer: Panagjurishte Municipality February 12, 2009, 2 p.m. – Meeting hall of the Municipality Administration, Panagjurishte

Invitation for participation in the public discussion is published at the official site of Panagjurishte Municipality, the two local newspapers –„Oborishte‖ newspaper and „Vreme 2001‖ newspaper, the invitation was transmitted on the cable radio „Panagjurishte‖ and the local cable television „Astra-Pan‖; the event was announced also in the regional and national media: „Focus‖ – Pazardjik, Radio „Pazardjik‖, „Zname‖ newspaper and „Pazardjishka Maritza‖ newspaper, the information agency BGNES and others. Official invitations were sent to the member of Parliament eng. Marko Mechev, to the regional governor of Pazardjik region, to the municipality council – Panagjurishte, to the RIEIA – Pazardjik, to the „Water Station‖ – Pazardjik, to the mayor of Strelcha, mayors of villages in the municipality of Panagjurishte, Forestry Directorate – Panagjurishte, ViK – Panagjurishte, municipal service for agriculture and forests, manager of VOKO – Panagjurishte, Association of the Entrepreneurs – Panagjurishte, Rotary Club – Panagjurishte, „Asarel-Medet‖ AD, „Оprikoelectron Group‖ AD, „Optics‖ Ad and others.

The report for the EIA for the completion of the Luda Yana dam was published in the internet on the page of the Panagjurishte Municipality and was available for the citizens in hard copies in the department „Informatiion‖ of the MC – Panagjurishte.

With regard to the public discussion there was a subscription list organized for the collection of signatures from the citizens of the Panagjurishte Municipality. Within 5 days were gathered over 3000 signatures in support of the completion of the construction of the Luda Yana dam. The list of signatures was submitted to the MRDPW.

The participants in the public discussion in Panagjurishte were as follows: the member of the parliament eng. Marko Mechev, the mayor of Panagjurishte municipality Georgi Gerginekov, eng. Plamen Nikifororv – director of directorate ViK in the MRDPW, Orlin Dikov – representative of the World Bank, ass. prof. Rositza Nikolaeva – head of the team that has prepared the report for the EIA.

Also attending were: deputy mayors of Panagjurishte Municipality eng. Velko Sapundjiev and Ivanka Zhivkova, representative of the municipality council – Panagjurishte, the mayors of all populated settlements in the Municipality of Panagjurishte, representatives of the Association of the Entrepreneurs – Panagjurishte, of „Asarel-Medet‖ AD, of ViK – Panagjurishte, of State Forestry – Panagjurishte, of the Municipality Council of Agriculture and Forestry, of the municipality administration – Panagjurishte, and of the media and other organizations, citizens.

The public discussion was opened by the mayor of Panagjurishte Municipality who focused on the strategic importance of the project for the completion of the Luda Yana dam.

The project for the completion of the Luda Yana dam as well as the efforts of the government and the Panagjurishte Municipality for inclusion of the site as a priority for financing by the World Bank was presented by eng. Plamen Nikiforov from the MRDPW. Ass. Prof. Rositza Nikolaeva acquainted the audience with the main aspects of the report for the EIA and underlined that for the team that has prepared the EIA, the necessity of the completion of the construction of Luda Yana dam is proven and it is in the interest not only for the population in terms of water supply and development of the region, but is also valid for the improvement of the ecological situation specifying that at the moment the frozen construction activities not only influence negatively the environment but also make the site potentially dangerous. Statement was made by the member of the parliament eng.

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Marko Mechev and he summarized the huge preparation work done to the moment with regard to the project which in his words is to fulfill one dream for the Panagjurishte citizens.

The official position of VOKO and „Asarel-Medet‖ AD was presented by Ilia Tuhchiev who expressed unconditional support of the EIA and the conclusions drawn in the report .

The statement of the Association of the Entrepreneurs in Panagjurushte was expressed by Angel Ivanov. He thanked for the possibility to express his opinion in the public discussion and underlined his full support for the report of the EIA from behalf of the business.

During the public discussion several opinions were expressed and several questions were answered raised by citizens of the town: Deayan Enicherov, Kiril Zyapkov, Pavel Ruinekov, Georgi Deliradev, Petar Tuhchiev. All opinions expressed agreement with the EIA report and the unconditional conclusion that the completion of Luda Yana dam is of extreme importance and the only alternative for the water supply with enough water of good drinkable quality for the population of Panagjurishte Municipality and several other municipalities and that it will improve the ecological conditions in the region, will bring new possibilities and perspectives for development of Panagjurishte and will raise the standard of living. Ass. Prof. Nikolaeva, eng. Nikiforov and Orlin Dikov gave extensive, precise and clear expert answers to all raised questions. Question1 - Deayan Enicherov: Are the intensive space erosion taken into account? Answer – Nikolaeva: Yes, in the EIA report are discussed the probable erosion processes that are on the way on the area of the future reservoir and it is given tha necessity of the building the technical ―Erosion project‖. Finally after the realization the erosion process will be stopped. Question2 - Kiril Zyapkov: Will it be during the building period the existed intake structures of the Panagiuriste water supplay structures in the relatively good conditions? Answer – Nikolaeva: Yes. That is included as a obligatory activity to the builder! Question3 - Pavel Ruinekov: Will it be in use the old builded territory of the Hydrostroy Company? Answer – Nikolaeva: Yes. The building territory will be used during the process of the development of the building activities. Question4 - Georgi Deliradev : The talk in the town of Panagiuriste that the money from the World bank are already transferet to the Bulgaria and they are already USED! Answer – Nikiforov: That is not correspond to the true! At this moment we provide the sociality discussion of the EIA report. The discussin is a part of the World Bank procedure to borrow money from the Bank. After that the financing will be opened. Question 5 - Petar Tuhchiev: When the building will start? I will gave a monthly retort money for the reservoir building! Answer – Dikov, The Republic of the Bulgaria follow the World Bank procedure requests of the financing. Nikiforov, The building activities will begin in the second half of the 2009.

The public discussion organized by the Panagjurishte Municipality was directly transmitted on the cable radio „Panagjurishte‖ /with over 3000 subscribers/ and on the cable television „Astra-Pan‖ /with over 15 000 subscribers /.

Prepared by: Nevyana Katzareva, Chief Expert „Public Relations‖ Panagjurishte Municipality Panagjurishte – 4500 13 „20 April‖ Square tel.: 0359/357/600-41

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Water Supply Complex Ltd. - Panagyurishte Email: [email protected]

Statement of Opinion

Subject: Environmental Impact Evaluation of Luda Yana Dam Completion

The EIER has been prepared in compliance with requirements. The conducted studies of the territory, of existing construction, of available design documentation, and of required design components are detailed and comprehensive. We support the findings of the EIER that the completion of the Luda Yana Dam is justified and required. Planned activities will not damage the environment, and anticipated results are entirely positive. - A facility will be completed and commissioned that has been built over many years. This is needed because of the conclusion that no other better and sustainable alternative for supplying water to the affected settlements exists, on the one hand, and, on the other, that the current status of suspended construction is damaging with respect to the environment and that the prospective freezing of the wall is risky and dangerous; - The Luda Yana Dam new water supply system will provide sustainable and adequate water supply to a substantial part of the territory of the Pazardjik Region, and the existing water consumption-rationing regime will be cancelled. The potable water, following treatment, will be environmentally pure and with excellent qualities, because the dam catchment is free from industrial or farming activities or other polluters that may damage the soil or tributaries. - The microclimate of the region shall be improved; - Constant river flow along the Luda Yana until its confluence with the Maritza shall be guaranteed; - Vast opportunities for the development of recreational activities and tourism shall be promoted; All this will contribute greatly to the improvement of living standards of the population in the region that will benefit from the water supply, and local communities fully uphold the construction of the dam. We have to say that we do not fully agree with the findings of the Report in Section 5.2 – Surface Waters – p. 33, regarding the following: “… Assarel Ore Mine is a potential external polluter, especially in times of intense rainfall; therefore, the project provides for special measures for taking them away from the catchment of

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the dam. According to data of Assarel-Medet, planned activities have been completed and waters are taken out of the dam catchment…‖ For information purposes, we state that the waters from the Assarel site are not within the territory of the Luda Yana Dam catchment area at all because the confluences of the tributaries the Mareshka, the Assarelska, and the Panova with the Luda Yana are far after the wall of the dam. Assarel-Medet JSC, in its capacity of a company that has proven its responsible attitude towards the environment, implements a huge program of environmental measures to minimize negative impacts on nature and on people.

30.01.2009, Panagyurishte, Water Supply Complex Ltd., Il. Tuhchiev, Manager

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Association of Entrepreneurs - Panagyurishte Email: [email protected], tel.: 0357 63065

Association of Entrepreneurs, Panagyurishte

Statement of Opinion

This Opinion was voiced at the local public debate on the EIER regarding the completion of the Luda Yana Dam that took place on 12.02.2009 in Panagyurishte. The Association of Entrepreneurs in Panagyurishte, which comprises 54 companies of all sectors of economy represented in the Municipality of Panagyurishte, at its own session held on 11.02.2009, discussed the EIER connected to the completion of the above dam. The business representatives in the Association appreciate the opportunity to take part in the debate and regard this debate as an especially important phase of the undertaking prior to the beginning of the financing of the completion of the dam. The EIER includes studies related to the preservation of the environment and safeguards against damages and pollution associated with construction works and operation of the facility. We believe that the completion of Luda Yana Dam is a component that will improve the environment in the region and along the stream of the Luda Yana. In view of that, we uphold the findings, conclusions, and measures as per the EIER, as they are correct and scientifically sound. No businesses will be affected and will be damaged by the construction of the dam. We are especially happy with the fact that new prospects for the development of tourism and related business activities such as hotels, restaurants, and public services will be attendant upon the finalization of the project. This will definitely change the living environment in more than one way. Finally, we would like to attest our full support to the project of the dam completion because the construction of this water supply system is a well-understood necessity, as it was proved throughout the years of changing economic circumstances. The adequate water supply for the Municipality of Panagyurishte and for parts of neighboring municipalities of Strelcha and Pazardjik is a task that we have continuously brought to the attention of local authorities, since employers and business consider the improvement of living standards as a priority.

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We wish success to the World Bank, the GoB, and the Municipality of Panagyurishte in the completion of the undertaking.

11.02.2009 Panagyurishte

Stamp and signature: D. Dimitrov, Chair Association of Entrepreneurs

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Protocol No. 40/25.09.2003 By Environmental and Household Chemistry Laboratory

Subject: Analysis of four samples of water submitted to the National Center for Hygiene, Medical Ecology, and Nutrition (NCHMEN) on 23.09.2003 by a representative of the Municipality of Panagyurishte, to be screened as per the indicators pursuant to Regulation 12/18.06.2002, State Gazette issue 63/2002.

Description of samples:

1. Sample from the Okoshka River /Lab. No. 176/ 2. Sample from the Elashka Rriver /Lab. No. 177/ 3. Sample from the Muleiska River /Lab. No. 178/ 4. Sample from the mixed water of the confluences of the three rivers /Lab. No. 179/

Test setting:

 Stipulation of organoleptic indicators, ion composition, elements, etc. – by means of methods in compliance with Regulation 12 from 18.06.2002 on the quality requirements applicable to surface waters for drinking and household purposes.

RESULTS

3. Ion Composition

Okoshka Elashka Muleiska Water from all 3 No. Indicator river river river rivers /Lab. # 176/ /Lab. # 177/ /Lab. # 178/ /Lab. # 179/ 1 Active reaction, pH 7,46 7,15 7,46 7,24 2 Electric conductivity, µS/cm 307 154 325 263

3 Alkalinity, mg/l (HCO3) 110 61 135 105 4 Total hardness mgeqv/l 2,9 1 3 2,6

5 Calcium, mg/l (CaCO3) 37 14 46 35 6 Magnesium, mg/l (Mg) 12 3,6 8,5 9 7 Total dry residue at 105oC, mg/l 232 116 240 196

8 Nitrites, mg/l (NO2) 0,005 0,005 0,02 0,02

9 Nitrates, mg/l (NO3) 2,00 0,5 7 4 Permanganate oxidizability, mg 10 O2/l 4,8 5,6 4,8 5,4

11 BOD, mg O2/l 1,4 1,5 1,3 1,4 12 Chlorides, mg/l (Cl) 18 4 10 7

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13 Sulphates, mg/l (SO4) 46 16 45 33

14 Ammonia ions, mg/l (NH4) <0,05 <0,05 0,1 0,1

15 Phosphates, mg/l (PO4) 0,13 0,06 0,16 0,16 16 Lead, mg/l Pb 0,002 <0,0008 <0,0008 <0,0008 17 Selenium, mg/l Se <0,0002 <0,0002 <0,0002 <0,0002 18 Manganese, mg/l Mn 0,018 0,008 0,09 0,26 19 Sodium, mg/l Na 12 8 13 11 20 Zinc, mg/l, Zn 0,03 0,012 0,007 0,028 21 Cadmium, mg/l Cd <0,00006 0,00006 <0,00006 <0,00006 22 Copper, mg/l Cu 0,01 0,003 0,004 0,004 23 Iron, mg/l Fe 0,2 0,06 0,37 0,84 24 Arsenic, mg/l As 0,00023 0,00045 0,00027 0,00047

Remarks:

 ―MV‖ stands for ―maximum value,‖ as per Regulation 9 on the quality of water for drinking and household needs – State Gazette, issue 30/2001;  The ―<0.0…‖ symbol means that the [respective indicator] is not detected at the specified detection limits for the method;  The ―-― means that the respective indicator is not limited, pursuant to Regulation 9 on the quality of water for drinking and household needs – State Gazette, issue 30/2001;

Laboratories Chiefs /signed/: Tests ran by /signed/: 1. Zl. Bratanova 1. N. Vassileva 2. L. Mechkueva 2. M. Bakardjieva

Outgoing reference stamp of the NCHMEN: 4402-1785/800903

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