DANGO PROJECT CONSULT LTD

1618 , 165 A “Tsar Boris III” Blv., phone/fax: 02/955 98 98, cell phone 088 8934 772 е-mail: [email protected]; www.dangoltd.com

NON-TECHNICAL SUMMARY

of

UPDATED REPORT

FOR ENVIRONMENTAL IMPACT ASSESSMENT OF INVESTMENT PROJECT FOR THE CONSTRUCTION OF

“” - FROM KM 210+100 TO KM 325+280

Sofia September, 2009 Non-Technical Summary of Updated EIA Report – Trakia Motorway section „Stara Zagora - Karnobat” from km 210+100 to km 325+280

Background ...... 1 І. General information ...... 3 1. Information about the Assignor ...... 3 2. Location of the investment project ...... 3 3. Connection to other existing and approved territorial pplans or other activities. Foreseen investment intentions within the scope of the motorway route ...... 6 ІІ. Resume of the investment project for construction, activities and technologies ...... 7 1. Structure, site route and main technological characteristics ...... 7 2. Main characteristics of the construction activities. Raw materials and materials – types, quantities, sources ...... 10 3. Areas required for the realization of the investment project ...... 11 ІІІ. Alternatives investigated with regard to the location and/or the technologies and justifiation decisions made, with regard to the enviromental impact, inclusive of the “zero alternative” ...... 11 1. Location alternatives ...... 11 2. Alternatives of proposed technologies ...... 15 3. Zero alternative ...... 15 ІV. Description and analysis of the components and factors of the environment and the cultural heritage, which will be significantly influenced by the investment project, and the interaction between them ...... 15 1. Ambient air ...... 15 2. Groundwaters and surface waters ...... 19 3. Geological environment ...... 24 4. Earth and soils ...... 24 5. Flora and fauna ...... 27 6. Waste ...... 36 7. Dangerous substances ...... 42 8. Physical factors ...... 43 9. Landscape ...... 44 10. Cultural heritage – expected impact on immovable cultural valuables within the scope of the investment project ...... 47 11.Health protection and hygienic aspects ...... 48 V. Description of the measures for prevention, abatement or, where possible, termination of significant harmful environmental impact. Plan for implementation of these measures ...... 49 VІ. Conclusion ...... 64

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LIST OF ABBREVIATIONS

ЕТЕС – Expert Technical and Economical Council GRA – General Road Administration MAC – Maximum Admissible Concentrations TLV – Threshold limit value MGC – Maximum ground-level concentration ELV – Emission limit value AAQ – Ambient air quality FPM – Fine particular matter WMA – Waste management act RIEW – Regional inspectorate of environment and waters RIPHPC – Regional Inspectorate on Public Health Protection and Control dca – decare

DANGO PROJECT CONSULT LTD 1 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280

Background The updated environmental impact assessment report on investment project for the construction of Trakia Motorway – section “Stara Zagora – Karnobat” from km 210+100 to km 325+280 has been elaborated on the grounds of the amendments in the Environment Protection Act - § 12а and 12b, SG 47/23.06.2009 and letter No. 05-00-78/09.07.09 of the National “Road Infrastructure” Agency for the elaboration of an Environmental Impact Assessment (EIA) of the investment project, and on the grounds of Article 10, para 1 of the Regulation on the terms and conditions for the carrying out of Environmental Impact Assessment (SG 25/2003, amen. and suppl. SG 3/2006 г.) (Appendix No. 1). The EIA Report was prepared in conformity with Article 96, para 1 of the EPA (SG 91/2002, amend.and suppl. SG 47/2009) and Article 10 and Article 11 of the Regulation on the terms and conditions for the carrying out of Environmental Impact Assessment (SG 25/2003, amend. and suppl. SG 3/2006). Terms of reference were also prepared on the scope and the content of the EIA Report for investment project for the construction of Trakia Motorway – section “Stara Zagora – Karnobat” from km 210+100 to km 325+280 in line with Article 95, para 2 and para 3 of the EPA (SG 91/2002, last amend. and suppl. SG 12, 19, 32, 35 and 47 of 2009) and Article 10, para 1 of the Regulation on the terms and conditions for the carrying out of Environmental Impact Assessment (SG 25/2003, amend. and suppl. SG 3/2006) where the scope is according to the provisions of Article10, para 3 of the Regulation. In line with the requirements of Article 95, para 1 of the EPA, written consultations were launched with all stakeholders – individuals and legal entities, to determine the scope and content of the EIA Report. Meetings were held with representatives of the municipal administrations and mayoralties of the villages through the lands of which the route of the motorway passes, regarding an additional investigation for existing and foreseen investment sites, whereof possible cumulative effects can be expected in combination with the realization of the current investment project. The ToR for the scope and content of the EIA Report accounts for the arguments and the recommendations of the MoEW regarding the elaboration of the EIA Report, as well as for the recommendations of specialized institutions and organizations and the stakeholders resulting from the consultations conducted in line with Article 95, para 3 of the EPA and Article 9, para 1 of the Regulation on the terms and conditions for carrying out of Environmental Impact Assessment. Regard was given to the fact that the proposed investment project also occupies a territory of potential areas of conservation BG 0002040 „Strandzha” under Council Directive 79/409/ЕЕС on the conservation of wild birds, and BG 0001007 „Strandzha” under Council Directive 92/43/ЕEC on the conservation of natural habitats and of wild fauna and flora. The areas have been affirmed as such by Resolution 122/02.03.2007 of the Council of Ministers, and the Compatibility Assessment Report was prepared as a separate paper – addition to the EIA Report, scoping strictly in line with the requirements of Article 23 of the Regulation on the terms and conditions for preparation of compatibility assessment of plans, programs, designs and investment projects against the scope and purpose of areas of conservation (SG 73/97). The company to which the Assignor – National “Road Infrastructure” Agency, assigns the elaboration of the ToR for the scope and the content of an updated EIA Report, respectively – the EIA Report, is DANGO PROJECT CONSULT LTD – city of Sofia. The team of experts assigned with the elaboration of the EIA Report consists of independent experts registered by the MoEW, pursuant to Regulation No. 1/26.02.2003 on the procedure for creation and maintenance of public register of experts, carrying out environmental

DANGO PROJECT CONSULT LTD 2 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 assessment and environmental impact assessment and the application procedure for registration – SG 22/11.03.2003, amend. and suppl. SG 100/2005. The authors of the EIA Report are independent experts registered pursuant to Regulation No. 1/26.02.2003 on the procedure for creation and maintenance of public register of experts, carrying out environmental assessment and environmental impact assessment and the application procedure for registration – SG 22/11.03.2003, amend. and suppl. SG 100/2005.

І. General information

1. Information about the Assignor Name: NATIONAL “ROAD INFRASTRUCTURE” AGENCY Address: 1606, Sofia, 3 “Macedonia” Blv BULSTAT: 000695089 phone.: 952 19 93 fax: 952 14 84 е-mail: [email protected] Contact person: Eng.Viktor Lebanov, tel.: 952 19 93

2. Location of the investment project According to the contemporary physical-geographic regionalization of Republic of , the region wherein the project “Construction of Trakia Motorway from km 210+100 to km 325+280” shall be realized, pertains to the Upper Thracian- region-Upper Thracian and Tundzhan-Burgas sub-regions. To the west and north the region borders with the Kraishte- region, to the north in its eartern part - with the Pre-Balkan-East Stara planina region, to the south – with the Western Rhodopes and the Eastern Rhodopes- Strandzha region, and to the east – with the . The change of topography landscape, hence of most components of the natural complex thereof, is distinctively expressed. The region features lowlands, valley widenings and occasionally - small hills. The altitudinal range is between 0 and 600 meters and spans over the lowland and the plain and hilly hypsometric belt. The entire region pertains to the transitional climate zone, and the waterside area is influenced by the Black Sea. From an administrative point of view the section passes through four administrative regions: Stara Zagora, , and Burgas. The route of the motorway section is divided into three lots: - Lot 2 – Stara Zagora – – from km 210+100 to km 241+900 The route of the section passes through the territory of the regions of Stara Zagora and Sliven affecting the following municipalities: Stara Zagora, and Nova Zagora (Attachment No. 2). - Lot 3 – Nova Zagora – Yambol – from km 241+900 to km 277+597 The route of the section passes through the territory of the regions of Sliven and Yambol affecting the following municipalities: Nova Zagora, Sliven, “” and Yambol (Attachment No.3). - Lot 4 – Yambol – Karnobat – from km 276+200 (= 277+597) to km 325+280. The route of the section settles on the territory of the regions of Yambol and Burgas and affects the following municipalities: “Tundzha”, Yambol, and Karnobat (Attachment No.4).

DANGO PROJECT CONSULT LTD 3 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280

A large number of settlements pertaining to 8 municipalities are situated around the motorway route – the municipalities of Stara Zagora, Radnevo, Nova Zagora, Sliven, “Tundzha”, Yambol, Straldzha and Karnobat. Closest to the route (less than 500 m) are the following settlements: village of Kolarovo (500 m), village of Zagortsi (375 m), village of Polsko Padarevo (400 m), of (300 m), village of Chokoba (175 m), village of Hadzhidimitrovo (250 m), village of (125 m), village of (500 m), village of Zheleznik (125 m).

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- Route of the motorway

ДАНГО ПРОЕКТ КОНСУЛТ ЕООД 5 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280

3. Connection to other existing and approved territorial pplans or other activities. Foreseen investment intentions within the scope of the motorway route The construction of the “Stara Zagora – Karnobat” section from km 210+100 to km 325+280 is in connection with other sections of Trakia Motorway which are already constructed and operational, namely: Sofia – Stara Zagora and Karnobat – Burgas. The construction of the motorway section observes the existing urban planning solutions of the adjacent settlements. The investment project for Lot 2, Lot 3, and Lot 4 of Trakia Motorway is to be constructed onto a territory whereon many infrastructural sites already exist.  Lot 2 - section „Stara Zagora – Nova Zagora” The village lands of the following villages are affected: Madzherito, , Kolarovo, Bozduganovo, Sarnevo, Pshenichevo, Benkovski, municipality of Stara Zagora; Sabrano, Zagortsi, Stoil Voivoda, Dyadovo, municipality of Nova Zagora. The village lands mentioned are of predominantly municipal and municipal public ownership. Private lands and lands of legal entities are also affected. These are cultivable lands (irrigated and non- irrigated), mainly ІІІ-rd, ІV-th, V-th and VІ-th category.  Lot 3 - section „Nova Zagora - Yambol” The village lands of the following villages are affected: Dyadovo, Ezero, Polsko Padarevo and Omarchevo – Municipality of Nova Zagora; Bikovo, town of Kermen, Skobelevo, Bozadzhii and Chokoba – Municipality of Sliven; Hadzhidimitrovo – Municipality of Tundzha.  Lot 4 - section „Yambol – Karnobat” The village lands of the following villages are affected: Hadzhidimitrovo, Drazhevo, Kabile, Zavoy, Veselinovo – Municipality of Tundzha; town of Zimnitsa, town of Straldzha, Vodenichane, Palauzovo, Malenovo – Municipality of Straldzha; town of Yambol – Municipality of Yabol; Devetak, Zheleznik, Krumovo gradishte, Dragantsi, town of Karnobat – Municipality of Karnobat.  and villages. Closest to the route of the motorway in the Lot 2 section are the village of Kolarovo - at 0.5 km., village of Zagortsi - at 0.375 km., village of Polsko Padarevo - at 0.4 km.; for Lot 3 – town of Kermen – at 0.4 km., village of Chokoba – at 0.4 km. and the village of Hadzhidimitrovo – at 0.350 km.; for Lot 4 - village of Malinovo and the village of Devetak – at approximately 0.5 km., in the immediate vicinity of the village of Zheleznik. When designing the route of the motorway the admissible distances from the settlements have been strictly observed with view of possible impacts both during construction, and during exploitation.  Roads pertaining to the “Republican Road Network” and agricultural roads. The route of the motorway is not in conflict with the existing road infrastructure, and, in line with all due requirements, the necessary connections and the reconstruction of existing road arteries securing to a great extent the connecting passages above and under the motorway, are provided for.  National Archeological Reserve “Kabile”. The route of the motorway has been coordinated with the National Institute for Cultural Monuments and the Archeological Institute and Museum and is not in conflict with the reserve.  Other investment sites in operation: - Existing asphalt plant at the operational quarry in the village lands of the village of Dyadovo - Active coal field “Dyadovo – Bomil” in the immediate vicinity of the motorway route near the village of Dyadovo.

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- Active coal field “Dyadovo – Binder” in the immediate vicinity of the motorway route near the village Dyadovo. - Active coal field “Dyadovo” east of motorway route near the village of Dyadovo. - Existing site of MELINVEST JSC – town of Kermen - Poultry products company, north of the village of Kolarovo - Pigsty buildings in the village of Bozduganovo - Fodder plant in the lands of the village of Mogila - Main gas pipe passing through the villages of Mogila Bozduganovo.

 Investment projects in the process of preparation or approval: - Grain base, flour-mill and storage farm north of the village of Omarchevo; - Coal field “Baba Todora” and coal field “Shilestia kayrak” on the village land of the village of Devetak - Coal field “Enevi mogili” in the vilage of Hadzhidimitrovo

ІІ. Resume of the investment project for construction, activities and technologies

1. Structure, site route and main technological characteristics The main feature of the project, in its entirety, consists in the extension of the motorway route, coming from , and its moving to the side of the existing first-class road network and the settlements, at the same time avoiding (where possible) the passing through high-quality land plots, irrigated fields, and terrains with established cultural and historical monuments. The section of Trakia Motorway herein discussed (Stara Zagora – Karnobat) begins from km 210+100 and ends at km 325+280. Its total length amounts to 115.180 km. The route unfolds in the main direction southwest – northeast, almost completely parallel to the existing E 773 main road. One special feature of the project is the four lane roadway with the central reservation and emergency lane, typical for motorways. The carriageway width is of the A-29 type for the whole stretch of the route. The main technical parameters of the motorway are: - Design speed - 140 km/hr - Carriageway width - 29 m - Central reservation - 3.50 m - Guiding strips - 4 х 0.75 m - Traffic lanes – 2x2 х 3.75 m - Emergency lane - 2 х 2.50 m - Shoulder - 2 х 1.25 m - Minimal radius of the horizontal curves - 1 400 m - Minimal length of circular curve - 350 m - Minimal radius of horizontal curves without transition curves - 3 000 m - Maximal longitudinal slope - 4% - Minimal radius of convex vertical curves - 36 000 m - Minimal radius of concave vertical curves - 20 000 m - Cross slope in straight section - 2.5% - Cross slope in horizontal curve with R = 5000 m – double-sided 2.5% - Cross slope in horizontal curve with R = 4000 m - single 2.5% The construction of the pavement has design parameters for 11.5 t/axis, traffic category “very heavy” and necessary modulus of elasticity - Ен = 340 МРа, where all

DANGO PROJECT CONSULT LTD 7 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 required check-ups for frost-resistance and tension strength of the asphalt layers and for cutting of the foundation bed have been performed. All crossings with national roads and agricultural ones are planned at two levels.

Construction type Dense split-mastic bituminous concrete pavement 0/11S - 4 cm Е = 1200 МРа Asphalt mixture for lower layer of the pavement - 6 cm Е = 1000 МРа Asphalt “A0” mixture for main layer - 12 cm Е = 800 МРа Cement-stabilized mixture layer - 20 cm Е = 600 МРа Crushed stone road bottoming with constant - 28 cm Е = 250 МРа granulometry 0 – 40 мм Modulus of elasticity of the earth base Ео = 45 МРа Total - 70 cm

For the construction of the section Stara Zagora – Karnobat the following facilities have been planned and construction is due – bridges, motorway overpasses and Sofia – Burgas railway overpasses, motorway underpasses, agricultural overpasses and underpasses, safety fencing, intersections with national roads, crossings with agricultural roads, culverts, temporary road connection at km 277+440, parking areas, road reconstructions, agricultural roads, drainage of crossings, irrigation channels, correction of the routing of Azmaka river at km 279+105 and at 283+650, pumping station at km 290+304.5, road junction ІІ-53 “Sliven- Yambol”, road junction І-7 “Zavoy - Veselinovo”, road junction ІІІ-895 “Karnobat - Dragantsi”, upgrade of engineering network – water-main, moving of cables of the National Company “Railway Infrastructure” for railway overpass, rearrangement of the overhead catenary, reconstruction of 20 kV and 110 kV transmission lines, rearrangement of TT cables, road signs and markings, landscaping and rehabilitation. In general, the nature of the terrain, which will be used for new construction, is predominantly plain. The territory through which the motorway will pass is intensively used for agricultural activities. The route has been so designed as to minimize the probability of affecting valuable cultivable land, gardens with perennial plants and irrigated areas. This is also valid for the forestlands. The information on planned land expropriation by category of the agricultural land, forests and non-categorized lands is taken from respective detailed parcel plans.

LOT № 2 STARA ZAGORA – NOVA ZAGORA- km 210+100 - km 241+900 Site route – the route of LOT 2 „Stara Zagora – Nova Zagora” starts south of the town of Stara Zagora where road junction of the same name is located in the village lands of the village of Zagore, unfolding eastwards, passing north of the villages of Kolarovo, Bozduganovo, Sarnevo and Pshenichevo, then curving into northeastern direction, crossing the village lands of the villages Benkovski, Zagortsi and Stoil Voivoda, remaining to their south, and ends just before the road junction north of the village of Dyadovo, where it crosses the international E-55 road (Ruse – – – Nova Zagora – ). From administrative point of view the route of the section passes through the territory of the Stara Zagora and Sliven regions.

DANGO PROJECT CONSULT LTD 8 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280

TRAKIA MOTORWAY before road junction “Stara Zagora”

A technical project has been prepared for this section on the grounds of already affirmed feasibility studies elaborated in the 1976–1991 period and Terms of Reference of the “Roads” Executive Agency of May 2000. The project includes direct route, road junction “Stara Zagora” km 210+550 at the point of crossing with road I-5, temporary road connection at km 241+900. Other projects have also been produced for national roads, crossing the route of the motorway, for agricultural roads, and installations and facilities of other establishments – electrical networks, cables, water and sewerage and irrigation systems, etc. The route of the motorway passes through a region of intensively developed agriculture and light industry. All large industrial sites are located slightly on the side of the route, but do influence the transport network. The number of overpasses needed to service the agricultural activities has been provided for, after due coordination with the responsible municipal authorities.

LOT № 3 NOVA ZAGORA- YAMBOL - km 241+900 - km 277+597 Site route. Lot 3 „Nova Zagora– Yambol” begins after the road junction north of the village of Dyadovo, unforlds eastwards, passing south of the village of Ezero, north of the villages Polsko Padarevo, Grafitovo, Omarchevo and Bikovo. Following an eastward direction the section passes south of the villages Konyovo, Mladovo and . South of the route are left the villages of Skobelevo, Bozadzhii, Chokoba and Hadzhidimitrovo, and the town of Kermen, after which the section ends at the road junction north of the town of Yambol, crossing road E-53 (Sliven - Yambol). In administrative aspect the section passes through the territory of Sliven and Yambol regions. The technical project was prepared on the grounds of discussed and approved feasibility studies and ToR of “Roads” Executive Agency of April 2000. The axis of Trakia Motorway crosses regions with expressed agricultural profile, predominantly irrigated lands on the territories of Sliven and Yambol regions. The route

DANGO PROJECT CONSULT LTD 9 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 passes through the village lands of the following settlements: Dyadovo, Ezero, Polsko Padarevo, Omarchevo, Bikovo, Kermen, Skobelevo, Chokoba and Hadzhidimitrovo. The number of crossings needed to service the agricultural activities has been determined (7 overpasses and 3 underpasses), after due coordination with the respective land commissions. Crossings with national roads are designed on two levels (5 road overpasses and one road underpass). In the beginning of the section discussed, at km 242+366.40, when crossing road III 534, an imperfect class II road junction has been designed. Where the section ends crossing road II-53 (km 277+766), another road junction is provided for, and it is to be designed within the next Lot 4. The tangential connection Sliven – Sofia оf the road junction is used as temporary road connection of the site, directing the traffic on road II-53 (Sliven – Yambol). At km 264+908 the section crosses the railway track Sofia - - Burgas near Kermen railway station (railway km 161+620). LOT № 4 – YAMBOL – KARNOBAT – km 276+200 (= 277+597) - km 325+280 Site route. Lot 4 „Yambol – Karnobat” begins after the road junction north of the town of Yambol. Unfolding eastwards the section passes north of the villages of Drazhevo, Kabile, Veselinovo, Charda, Vodenichene, Palauzovo, Zheleznik. North of the section are left the village of Zavoy, town of Zimnitsa, town of Straldzha, villages of Malenovo and Devetak. South of the section is left the town of Yambol. The route ends at the road junction for Karnobat, which is left to the north. In administrative aspect the route of the section passes through thhe territory of Yambol and Burgas regions.

2. Main characteristics of the construction activities. Raw materials and materials – types, quantities, sources The investment project provides for new construction of a motorway section of the republican road infrastructure and is part of Trakia Motorway. The preparation of the route prior to construction includes a number of activities, and the more important of these are – setting up of temporary traffic organization and safety measures for the main construction traffic flow transporting earth, humus, disposing of unusable material, delivering usable material, asphalt mixtures, concrete and metal constructions and materials; construction of temporary sites for outage of transport means and construction machinery, and of repair workshops, if needed; demolition and disposal of reinforced concrete and concrete construction waste; transportation and disposal of humus layers and their subsequent laying onto bevels, and lanscape planting of road-side areas; organization and management of the construction works within the section, obstructing the traffic on already existing roads as little as possible. The construction of the motorway requires the use of materials with the respective standard quality. During the construction the following main types of materials will be used – non-binding materials; bitumen binding materials; curbs; drain pipes – РVС; concrete pipes; precast concrete structures for “Italian” drainage chutes; concrete – different classes; concrete for facilities, reinforcement for facilities; safety fence rails; poles; safety net; road signs; shrubs; deciduous and coniferous trees; For the construction of the section discussed the creation of a new road construction is planned with the following profile: - compact asphalt concrete Type А, Е = 1200 МРа – 4 cm; - porous asphalt concrete Type Е = 1000 МРа – 4 cm; - bitumized crushed stone Е = 800 МРа – 7 cm; - unsized crushed stone with constant granulometry Е = 250 МРа – 35 cm; The exact quantity of raw materials is given in a Bill of quantities together with the elaboration of a technical project. Materials will be delivered from local construction plants.

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In the course of operation no natural resources will be used.

3. Areas required for the realization of the investment project Lot 2 – Stara Zagora – Nova Zagora begins south of Stara Zagora at Stara Zagora road juntion and ends before the road junction north of the village of Dyadovo. The length of the section is 31.800 km. The area required for its realization is 1743.343 dca. Lot 3 – Nova Zagora– Yambol begins after the road junction north of the village of Dyadovo and ends at the road junction north of the town of Yambol. The length of the section is 35.697 km. The area required for its realization is 1956.984 dca. Lot 4 – Yambol – Karnobat begins after the road junction north of the town of Yambol and ends at the road junction for Karnobat, which is left to the north. The length of the section is 47.683 km. The area required for its realization is 2614.082 dca. For section km 210+100 to km 325+280 of Trakia Motorway there are updated parcel plans available, corresponding to the currently active Bulgarian legislation. The realization of the project is linked to the carrying out of land expropriation procedures for lands situatied in the vicinity of settlements through which the route passes. According to the balance calculations of the territory, the total required area for the realization of the project is 6 314.409 dca, of which: - agricultural lands – 6 122.288 dca; - lands within the forestry fund – 192.121 dca. The lands of the following villages are affected - Madzherito, Zagore, Kolarovo, Bozduganovo, Sarnevo, Pshenichevo, Benkovski, Sarnevo, Zagortsi, Stoil Voivoda, Dyadovo, Ezero, Polsko Padarevo, Omarchevo, Bikovo, town of Kermen, Skobelevo, Bozadzhii, villages of Chokoba, Hadzhidimitrovo, Drazhevo, Kabile,. Zavoy, Veselinovo, town of Zimnitsa, town of Straldzha, villages of Vodenichane, Palauzovo, Malenovo, town of Yambol – municipality of Yambol, villages of Devetak, Zheleznik, Krumovo gradishte, Dragantsi, town of Karnobat. The expropriation of lands pertaing to the scope of Trakia Motorway, is made pursuant to a Council of Ministers’ Act, in line with Chapter three of the State Ownership Act, wherein the process of expropriation is described in details. An important part of the indemnification of expropriated land owners is the elaboration of a per dca market value assessment. This assessment is made by an independent licensed assessor on the grounds of documents received ex officio from the Registration Offices, certifying real transactions in the region of the expropriated property. This manner of indemnification calculation should guarantee that there are no landowners suffering ng losses in result of the expropriation. However, for owners who are not satisfied with the indemnification price per decare land, the law provides for an appeal procedure before the Suprime Administrative Court of Bulgaria, where the Court rules with a final decision binding for the investor.

ІІІ. Alternatives investigated with regard to the location and/or the technologies and justifiation decisions made, with regard to the enviromental impact, inclusive of the “zero alternative”

1. Location alternatives In substance, alternatives for the realization of investment project “Construction of TRAKIA Motorway”, are discussed in the EIA Reports produced in 1993 and 1997 period, when the final selection of a route was made among optional ones discussed in various Draft papers. For this section of Trakia Motorway (Stara Zagora – Karnobat) there are Decisions of

DANGO PROJECT CONSULT LTD 11 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 the Competent Authority (MoEW) available, about the final choice route. For its construction the respective Technical projects have also been elaborated. Alternative layouts for this section of Trakia Motorway (Stara Zagora – Karnobat) are herein under described:  Section Stara Zagora – Nova Zagora For the „Stara Zagora – Nova Zagora” section km 209+300 to km 242+000, there are two variants – ‘red’ and ‘blue’at the stage of „Feasibility studies” by „Patproekt” in 1988. The Draft has been assigned with a prior technical and economic ToR of the General Directorate Construction, Operation and Maintenance of NR"- GRA, confirmed by the Expert Technical and Economic Council at the General Road Administration with Record No. 1 of 28.01.1986. The variants are in conformity with the recommendations of the ETEC at GRA, reflected in Record No. 6 of 15.05.1987 and have been further developed in the directions explored during the previous phase “Preliminary studies”, adopted by ETEC with Record № 17 of 29.09.1977. The variants are as follows: Red variant from km 209+300 – km 241+650, length 32.35 km Blue variant from km 209+300 – 241+600, length 32.30 km The variants start at the „Stara Zagora” road junction at km 209 + 300, passing between the villages of Zagore and Kolarovo, north of the village Grudevo, north of the villages Sarnevo and Pshenichevo. The red variant passes closer to the two settlements, while the blue one is about 2 km away from them. The two variants then pass closely by the south parts of the villages Benkovski and Zagortsi and end crossing the ІІІ-534 road between the villages Ezero and Dyadovo. The variants, at two levels, cross the following road arteries: road I-5; road ІV-50041; road ІV-66029; road І І-57; road ІV-57005; railway track Nova Zagora– Radnevo and road ІІІ-534. The construction of bridge facilities is provided over the rivers: Bereketska, at km 215+900; Bedechka, at km 218+015; Azmak, at km 226+165; Oryahovska, at km 229+240; Blatnitsa, at km 241+200. In order to secure the connection of the motorway with other national roads, the construction of the following road junctions is planned: - road junction Stara Zagora on road І-5 (Е – 85), of the type „clover leaf”; - road junction „Sarnevo” at the crossing of road ІІ-57, of the type „partial clover leaf”; - road junction „Nova Zagora” on road ІІІ-534, of the type „partial clover leaf”. The initial design for two junctions is the “diamond” type, but due to better conflict- free solutions for busy traffic and smaller capacity, the adopted scheme is of the type „partial clover leaf”. When the variants are compared in their entireness, the red one proves to be more advantageous.

Parameters Measure Red variant Blue variant Minimal radius m 4 000 6 000 Longitudinal slope max % 1.53 1.35 Volume of the common m3 46 000 16 000 excavation Volume of the borrow m3 1 713 000 2 160 000 excavation

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Expropriation dca 1 338 1 634 – І cat. - ІІ cat. dca 305 63 - forests dca 148 152

For the next phase the development of a red variant has been proposed. The decision was made by the ETEC at GRA with Record No.13 of 21.07.1988, confirming the expert opinion of ETEC – Record No. 6 of 15.03.1987, also suggesting the red variant. A preliminary EIA Report was compiled for both variants. The recommendation of the team of the independent experts who prepared the assessment, was to allow the design works of the next phase of the route to continue according to the “red variant”, due to slightly better expressed environmental advantages compared to the „blue variant”. The competent authority issues an EIA Decision No.6 - 5/1998 allowing the start of the next section design phase as per the “red variant”.

 Section Nova Zagora– Yambol For the section Nova Zagora– Yambol, inclusive of section Yambol – Karnobat (to km 313+000) in 1993 a EIA Report was elaborated on the grounds of available feasibility studies. For this section three variants were developed: “red variant”, “blue variant”, and “green variant”. The route of Trakia Motorway in the section between Nova Zagora - Yambol from km 241+900 to km 277+597 passes through the Upper Thracian Tundzhan lowlands and covers partly the Stara Zogora and Yambol field, and the Sliven valley. The topographic monotony of the plain landscape is relieved by the Svetiiliiski heights to the south-southwest and the most eastern part of Sarnena Sredna Gora to the north. The altitude ranges mainly between 100 - 180 m. It only increases around the Svetiiliiski heights up to 210 m. (km 246 – 247 red variant) and at the crossing with the last spurs of Sarnena Sredna Gora – up to 220 m (km 264 red variant) and 280 m (km 268 – 269 blue variant). Until km 266 + 000 of the blue variant the route of the motorway crosses a sloping terrain as steep as 3°. From km 266 to km 271, related to the surmounting of the last spurs of Sarnena Sredna Gora, northeast of the town of Kermen, the actual slopes gradually get steeper reaching some 7° - 10°, and in sertain places – up to 15°. After km 271 + 000 the slope of the terrain again ranges between the regular 0° - 3°. The red variant from km 232+000 to km 246+000 follows a terrain sloped up to 3°. Between km 246+000 and km 247+000 the slope abruptly gets steeper reaching maximum values of 10-15°, then again returning to the range of 0° to 3° until km 263+000. From km 263+000 to km 265+000, surmounting the heights south of the town of Kermen, the slopes again get steeper reaching 10-15°. From km 265+000 to 270+000 the slope of the terrain is very small – 0° – 1°. Increase, although insignificant, is visible between km 270+000 and km 272+000 – from 3° to 5°, after which until the very end of the route, according to the red variant, the slopes are of not more than 3°. According to the green variant the values of the actual slopes along the entire route of the motorway are small – up to 3°. Exception from this trend are only the short sections from km 246+000 to km 247+000 and from km 281+000 to km 282+000, where the slopes of the lay are slightly steeper – from 3° to 5°. The analysis thus performed shows that the values of the actual slopes along the motorway route according to all three variants are predominantly very small – within the range 0° – 3°. Only in certain section they increase to range between 10° and 15°.

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The team of independent EIA experts which conducted the assessment of the three variants recommends one optimal combination for the construction of the route, as follows: °up to km 248+922 – green variant °from km 248+800 to km 276+516 – blue variant °from km 276+516 to km 285+498 – green variant °from km 285+498 to km 300+153 – blue variant °from km 300+153 to km 313+322 – red variant

 Section Yambol – Karnobat For section Yambol – Karnobat from km 313+322 to km 327+300 a preliminary EIA Report has been produced on the grounds of feasibility studies for the two variants – ‘green variant’ and ‘red variant’. The variants prepared for this section, are in line with the trends developed in the course of the previous phase “Feasibility studies”, adopted by ETEC with Protocol No. 17 of 29.09.1997. The Draft in the phase Technical and Economic Documentation (TED) for Preliminary Study Results (PST) of “Patproekt” of 1983 was approved with Protocol No. 10 of 12.04.1984. After the assignment of the investigation of additional variants for terrain inspection of Malenovo village, the Draft was approved with Protocol No.22 of 21.09.1984. The section begins at the road junction of „Straldzha” (km 300+050). Two variants were developed - „blue” and „red”. The blue unfolds north of the village of Malenovo, south of the village of Devetak and then overlaps with the red variant at km 311+845. The red variant was designed to run south of the village of Malenovo, south of the village of Devetak, north of the village of Zheleznik and of the village of Dragantsi and at km 327+300 it joins the route of the „Karnobat – Zhitarevo”, which is in the phase „Working project” and currently in the process of construction On the territory of the section discussed the following national roads cross at different levels: Road ІІІ-793 Straldzha – Vodenichane – km 299+835 Road ІV-79328 Straldzha – Malenovo km 305+950 Road ІV-79332 Devetak – Zheleznik km 315+100 Road ІV-60084 Zheleznik – Krumovo gradishte km 318+555 Road ІІІ-795 Karnobat – Draganski km 324+890 Road ІV-79514 Karnobat - Detelina km 327+225 Some of the bigger bridge facilities planned for construction are: Bridge over the river of Marash – km 302+350 Bridge over the river of Mochuritsa - km 309+500 In order to secure the connections between the motorway and the road network the construction of the following road junctions has been planned: According to the ‘red variant’: °Road junction „Karnobat” where the motorway crosses road ІІІ-795 Karnobat – Dragantsi - km 324+890. The junction is of the type „partial clover leaf”; °Road junction “Detelina” at km 327+225 of road ІV-79514, of the type „partial clover leaf”. According to the ‘blue variant’: °Road junction „Malenovo” at km 305 + 890 of road ІV-79322, of the type „partial clover leaf” Road junction „Karnobat” and road junction „Detelina” are the same as according to the red variant. Under the red variant there is no need to construct road junction „Malenovo”.

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With regard to the better indicators for the Draft during the next phase - “Technical project”, the proposed variant was the red one. The team of independent EIA experts which conducted the assessment, recommended to the competent authority to authorize the design in the next phase of the route according to the ‘red variant’. On the grounds of the environmental components impact assessment resulting from the realization and the operation of the investment project for the construction of Trakia Motorway route for Lots 2, 3 and 4, the competent authority (MoEW) authorized the designs in the next phase of the motorway as per the proposal of the experts. The technical projects for each section were developed in 2003 by the following road design companies: • Section Stara Zagora – Nova Zagora(Lot 2) - PATPROEKT LTD - Sofia; • Section Nova Zagora– Yambol (Lot 3) - RUTEX LTD – Sofia; • Section Yambol – Karnobat (Lot 4) - VIA PLAN BURDA – Sofia.

2. Alternatives of proposed technologies The technology for construction of motorways is stipulated in the “Road Design Standards” and the Technical specification for the respective A-29 m carriageway width.

3. Zero alternative The construction of the last section of Trakia Motorway brings about the solution of one key problem – the connection of the already constructed motorway sections with the layouts of Lot 2, Lot 3 and Lot 4. The assessments made with regard to the expected environmental impact attest to the eligibility of the investment project to be realized. Provided the above the application of a ‘zero alternative’ would mean retaining the current situation.

ІV. Description and analysis of the components and factors of the environment and the cultural heritage, which will be significantly influenced by the investment project, and the interaction between them

1. Ambient air For the purposes of making the calculations and estimations with regard to the quality of the atmospheric boundary layer, the concerned Trakia Motorway section is discussed conditionally divided into three discrete sections (each of which further divided into two sub- sections).

1.3.1. Section - Lot 2 Stara Zagora – Nova Zagora– from km 210+100 to km 241+900; The section includes two sub-sections and the route begins south of Stara Zagora (vlg. Zagore), unfolds eastwards, passing north of the villages Kolarovo, Bozduganovo, Sarnevo and Pshenichevo; - continuing in northeast direction, crossing the village lands of Benkovski, Zagortsi and Stoil Voivoda to the south, ending before the road junction north of Dyadovo, crossing there the international Е-85 road. The route of the motorway passes through the territory of Stara Zagora and Sliven administrative regions. The route is approximately 31.8 km long and does not pass through any settlements (it passes around them).

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1.3.1.1. Calculation section Lot 2 sub-section 2.1. - from Zagore to Pshenichevo from km 210+100 to km 230+500; The maximum MGC concentrations of nitric oxides along the motorway section are 130-145% of the respective limit, and the concentrations of all other pollutants of ambient air are low below the respective Maximum Admissible Concentrations. Nowhere in the settlements concerned the annual mean values of nitric oxides exceed the respective nitric oxides concentration limits for Human Health Protection standard (during 2020-2030), the only exception being the exceeding of this limit in-between 10 to 30 m on both sides of the road axis. The residential part of the village of Zagore is approximately 525 m away north of the route, and the exceeding of TLV or nitric oxides is in the strip up to 20 - 30 m. The residential parts of the village of Kolarovo is approximately 500 m away south of the route, and the exceeding of TLV for nitric oxides is in the strip up to 15 - 25 m. The residential part of the village of Bozduganovo is approximately 1 900 m away south of the route, and the exceeding of the TLV for nitric oxides is in the strip up to 25 m. The residential part of the village of Pshenichevo is approximately 900 m south of the route, and the exceeding of the TLV for nitric oxides is in the strip up to 10 - 25 m.

1.3.1.2. Calculation section Lot 2 sub-section 2.2. - from Benkovski to Dyadovo from km 230+500 to km 241+900; The maximum MGC of nitric oxides along the motorway section are 124-138% of the respective limit, and the concentrations of all other pollutants of ambient air are low below the respective MAC. Nowhere in the settlements concerned the annual mean values of nitric oxides exceed the respective nitric oxides concentration limits (for 2020-2030), the only exception being the varying of this limit in-between 20 to 40 m on both sides of the road axis. The residential part of the village of Benkovski is 1 200 m away north of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 35 - 40 m. The residential part of the village of Zagortsi is 375 m north of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 30 m. The residential part of the village of Stoil Voivoda is 1 875 m away north of the route, and the exceeding of of TLV for nitric oxides is in the strip approximately up to 27 m from the north side of the road. The residential part of the village of Dyadovo is approximately 600 m away south of the route, the residential part around the village of Ezero - 1 500 m southeast of the route, and the exceeding of the TLV for nitric oxides is in the strip up to 20 - 30 m.

1.3.2. Section - Lot 3 Nova Zagora– Yambol - from km 241+900 to km 277+597; The section includes two sub-sections and the route begins at the road junction (with the international road Е-85) north of Dyadovo, unfolds eastwards, passing north of the villages Polsko Padarevo and Bikovo, then making a southeastbound turn, going around the village of Kermen from the south; - continues to the east, between the villages Skobelevo and Chokoba,; - ending before the road junction, north of Hadzhidimitrovo, crossing there the ІІ- 53 (Yambol – Sliven) road. The motorway route passes through the territory of Sliven and Yambol administrative regions. The route is approximately 35.7 km does not pass through any settlements (it passes around them).

1.3.2.1. Calculation section Lot 3 sub-section 3.1. - from Dyadovo to Bikovo from km 241+900 to km 263+000; The maximum MGC concentrations of nitric oxides along the motorway section are 156- 179% of the respective limit, and the concentrations of all other pollutants of ambient air are low below the respective Maximum Permissible Concentrations. Nowhere in the settlements concerned the annual mean values of nitric oxides exceed the respective nitric oxides

DANGO PROJECT CONSULT LTD 16 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 concentration limits for Human Health Protection standard (for 2020-2030), the only exception being the varying of this limit in-between 15 to 30 m on both sides of the road axis. The residential part of the village of Dyadovo is approximately 600 m away from the route, and the exceeding of of TLV for nitric oxides is in the strip up to 30 - 35 m. The residential part of the village of Polsko Padarevo is approximately 400 m away south of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 25 m. The residential part of the village of Omarchevo is approximately 1 400 m m away south of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 15 - 23 m. The residential part of the village of Bikovo is 725 m away south of the route, and the exceeding of TLV for nitric oxides is in the strip up to 15 - 30 m.

1.3.2.2. Calculation section Lot 3 sub-section 3.2. - from гр. Kermen to Hadzhidimitrovo от km 263+000 до km 277+597; The maximum MGC of nitric oxides along the motorway section are 129-148% of the respective limit, and the concentrations of all other pollutants of ambient air are low below the respective Maximum Permissible Concentrations. Nowhere in the settlements concerned the annual mean values of nitric oxides exceed the respective nitric oxides concentration limits for Human Health Protection standard (for 2020-2030), the only exception being the varying of this limit in-between 15 to 45 m on both sides of the road axis. The residential part of the town of Kermen is 300 m away north of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 35 - 45 m. The residential part of the village of Skobelevo is 850 m away south of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 15 - 25 m (2030). The residential part of the village of Chokoba is 175 m away north of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 15 - 20 m on both sides of the road. The residential part of the village of Hadzhidimitrovo is approximately 250 m away south of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 25 m.

1.3.3. Section - Lot 4 Yambol – Karnobat- from km 276+200 (277+597) to km 325+280; The section includes two sub-sections and the route begins at the road junction north of Hadzhidimitrovo (road ІІ-53 section Yambol – Sliven), unfolds eastwards, passing north of the villages Drazhevo and Kabile, crossing a road junction with main road І-7 ( - Zimnitsa); passing straight eastwards, north of the villages Charda and Vodenichane; then making a northeastbound turn, going around of the villages Malenkovo and Devetak, then ending north of the village of Zheleznik before the road junction with ІІІ-795 road (Karnobat- ). The motorway route passes through the territory of Yambol and Karnobat administrative regions. The route is approximately 49.6 km and does not pass through any settlements (it passes around them).

1.3.3.1. Calculation section Lot 4 sub-section 4.1. - from Drazhevo to Charda km from 276+200 (277+597) to km 295+000; The maximum MGC of nitric oxides along the motorway section are 176-202% of the respective limit, and the concentrations of all other pollutants of ambient air are low below the respective Maximum Permissible Concentrations. Nowhere in the settlements concerned the annual mean values of nitric oxides exceed the respective nitric oxides concentration limits for Human Health Protection standard (for 2020-2030), the only exception being the varying of this limit in-between 30 to 42 m on both sides of the road axis. The residential part of the village of Drazhevo is approximately 125 m away again south of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 32 - 42 m from the south side of the road. The residential part of the village of Kabile is approximately 500 m away south of the route, and

DANGO PROJECT CONSULT LTD 17 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 the exceeding of of TLV for nitric oxides is in the strip up to 35 - 40 m on the southern part of the road. The residential part of the village of Zavoy is approximately 350 m away north of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 30 - 35 m on the northern part of the road. The residential part of the village of Charda is approximately 1 350 m away south of the motorway route, and that of the town of Zimnitsa is 1 450 m away north of the route , and the exceeding of of TLV for nitric oxides is in the strip up to 30 - 35 m.

1.3.3.2. Calculation section Lot 4 sub-section 4.2. - from vlg. Vodenichane to vlg. Zheleznik from km 295+000 to km 325+280; The maximum MGC of nitric oxides along the motorway section are 160-183% of the respective limit, and the concentrations of all other pollutants of ambient air are low below the respective Maximum Permissible Concetrations. Nowhere in the settlements concerned the annual mean values of nitric oxides exceed the respective nitric oxides concentration limits for Human Health Protection standard (during 2020-2030), the only exception being the varying of this limit in-between 25 to 40 m on both sides of the road axis. The residential part of the village of Vodenichane is 900 m away south of the route, and the exceeding of TLV for nitric oxides is in the strip up to до 35 - 40 m on the southern part of the road. The residential part of the village of Malenovo is 750 m away north of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 25 - 35 m on the southern part of the road. The residential part of the village of Devetak is 900 m away north of the route, and the exceeding of TLV for nitric oxides is in the strip up to 25 - 32 m. The residential part of the village of. Zheleznik is 125 m away south of the route, and the exceeding of of TLV for nitric oxides is in the strip up to 30 m.

Assessment of the impact on the quality of ambient air with regard to the limits and standards applicable in Bulgaria On the grounds of the AAQ modeling (TRAFFIC ORACLE – module EMISSIONS and EMEP/CORINAIR) it can be concluded (as concentrations in the relevant receptors) that the ABL concentrations recorded along the route of the motorway are connected with the above MPL values of nitric oxides at the following positions: - For section ІІ - Lot 2 Stara Zagora – Nova Zagora: - The maximum MGCs of nitric oxides along the motorway section are 124-145% of the respective limit. The exceeding of the annual mean limit values for nitric oxides (for 2020 – 2030) varies in a 10-40 m strip on both side of the road axis. - For section ІІІ - Lot 3 Nova Zagora– Yambol - from km 241+900 to km 277+597: The maximum ABL concentrations of nitric oxides along the motorway section are 202-317% of the respective limit. The exceeding of the annual mean limit values for nitric oxides (for 2020 – 2030) varryies in a 15-45 m strip on both side of the road axis. - For section ІV - Lot 4 Yambol – Karnobat - from km 276+200 (277+597) to km 325+280: - The maximum ABL concentrations of nitric oxides along the motorway section are 176-291% of the respective limit. The exceeding of the annual mean limit values for nitric oxides (for 2020 – 2030) varies in a 25-42 m on both side of the road axis. The surrounding inhabited areas are somewhat remote from the motorway (more than 125 m), therefore these are not affected by the MPL exceeding values quoted above. When accounting for the cumulative effect of combined operation of the motorway with that of the functioning adjacent quarries for construction materials, with their service roads and asphalt plants, evidence is found for significant increase of the ABL concentrations of nitric oxides and fine dust particles (FPM10), related to respective broadening of the strips with above the limit concentrations around the route of the motorway.

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For section ІІІ - Lot 3 sub-section 3.1. – villages of Dyadovo and Polsko Padarevo: - no increase above the limit values in the villages from the side of the motorway, both for nitric oxides (20-22% of MPL), and for fine dust particles (23% of MPL). For section ІІІ - Lot 3 sub-section 3.2. – villages of Drazhevo and Hadzhidimitrovo: - no increase above the limit values in the villages from the side of the motorway, both for nitric oxides (15-55% of MPL), and for fine dust particles (4- 43% of MPL). For section ІV - Lot 4 sub-section 4.2. – villages of Zheleznik and Devetak: - no increase above the limit values in the villages from the side of the motorway, both for nitric oxides (39-42% of MPL), and for fine dust particles (35- 55% of MPL). The results from the modeling with regard to the ambient air pollution in all settlements and in all sub-sections, inclusive of where combined cumulative effect is present, do not bear evidence for pollution of ambient air in residential areas, connected to the values of the following substances, which are above the mean annual limits: - for nitric oxides 3 3 - 0.04 mg/m ) and – fine dust particles (FPM10) - 0.02 mg/m . The other pollutants do not exceed the permissible limits and are found only close to the axis of the motorway. When accounting for the cumulative effect of the construction of the motorway route in parallel with the upgrade and the moving of communications of other establishments, a slight increase of the ABL concentrations of nitric oxides and FPM10 is expected, which does not result in a significant change of ambient air pollution parameters for the respective region. In the case of zero alternative (no constructed motorway) and with estimations for the same transport traffic load – in all settlements between Stara Zagora and Karnobat, through which the main road Е 773 passes, the values of the MGCs are expected to be above the limit. Only larger settlements with appropriate detouring roads can be protected from such pollution.

2. Groundwaters and surface waters Surface waters The route of Trakia Motorway from km 210+470 to km 325+280, comes under the scope of the upstream watersheds of river (more specifically – of tributaries of its left channel of Sazliika river) and of Tundzha river and its tributaries, mainly Mochuritsa river. The entire section is under the scope of management of East River Basin Directorate. Quite slightly, in the end of the motorway section (approximately from the region after the village of Zheleznik until the end – region (village lands) of the village of Dragantsi), the river valley of Rusokastrenska river is affected – its tributaries from the upper stream, where they come under the jurisdiction of the Basin Directorate for Water Management in the Black Sea region. The region of the investment project covers part of the middle river valleys of the rivers Maritsa and Tundzha and of the upper, close to the watershed, part of the catchment area of Rusokastrenska river. The main river arteries over which new bridges will have to be constructed from west to the east in the range of Lot 2 are the rivers Azmaka (Bereketska), Bedechka, Azmaka (Kolenska), Oryahovska and Blatnitsa, which are left tributaries of Sazliyka from Maritsa river basin, originating from the mountain flanks and the pre-hills of Sarnena Sredna Gora. The river valleys are slightly concave and partly drain the ground waters. The genesis of the river outlet has mainly pluvial (rain) feeding regime with big interannual fluctuations. High water – January – April, low water – July – October. From km 248 to 313 (Lot 3 and Lot 4) the motorway joins the watershed of Tundzha river and its biggest tributary as per catchment area region – river of Mochuritsa (1278 km2 and length - 55 km.). In the section of the motorway, in the river of Tundzha, the rivers Asenovska, Arka and Mochuritsa flow into Tundzha river. Kalnitsa river in its upper stream

DANGO PROJECT CONSULT LTD 19 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 drains the region between the villages Polsko Padarevo and Bikovo. High water period is between December and June characterized with too high water levels during the winter months, in result of the Mediterranean climatic influence. In the last part of the stage the route passes into the Tundzha-Strandzha heights zone, an integral part of which is the Karnobat- plain. It crosses the flat and low watershed between the rivers Mochuritsa and Rusokastrenska. Rusokastrenska river discharges in the Mandrensko lake near the village of Novoseltsi with catchment area - 522.2 km2, length - 65.4 km, multi-annual average water quantity - 1.05 m3/sec. The route crosses Gargata ravine and Selska river (left tributaries of Mochurizha river) and Erek ravine, Kalnishka river and left tributary of Kalnishka river – tributaries of Rusokastrenska river.

Sources of pollution of surface waters and groundwater. Drainage. Impact assessment. As main pollutants of the waters within the range of the linear objects are considered the emissions of harmful substances from motor vehicle traffic and the chemical substances, used for winter maintenance of the road. The draining of waters into the river basins causes the transfer therein of harmful substances accumulated along the route. The drainage of the motorway is surface and will be made by means of tile ditches (pre-cast reinforced concrete units ЕО-1.5/200(100) on sand blinding), concrete curb, trenches and culverts.

Expected impact during construction The investment project is not connected to use of waters, both during its construction and later - during the operation of the facility. During the construction within the motorway sections there will be no polluting caused by construction related effluent waters. No water will be used, apart from water for drinking and domestic use (bottled water), the quantities of which will be limited, and no negative impact can thereof be expected. Groundwater will be impacted during the construction of bridge facilities. For the different sections these are:  Section Stara Zagora - Nova Zagora The route of the motorway crosses consecutively (from east to west) the rivers Azmaka – Bereketska, Bedechka, Azmaka – Kolenska, Oryahovska and Blatnitsa, which are left tributaries of Sazliyka river, from the catchment basin of Maritsa river. The construction of five bridges is planned. - bridge over Azmaka river at km 216+620, L=2x18m - bridge over Bedechka river at km 218+720, L=2x24 m - bridge over Azmaka river at km 226+930, L=3x18 m - bridge over Malka reka river at km 230+046, L=12 m - bridge over Blatnitsa river at km 241+625, L=3x17 m  Section Nova Zagora– Yambol - bridge over Malenska river at km 249+955, span - 8 m  Section Yambol – Karnobat (19.10) - bridge over Tundzha at km 286+080 span L=18+3x20+18 m. - bridge over Marash at km 302+271.5 span L=3x18 m, - bridge over Mochuritsa at km 304+845 span L=3x18 m The construction of new bridge facilities will be connected with impact on the rivers’ hydrology and to temporary change of water quality. During the construction of bridge facilities local temporary influence over the regime of groundwater and surface waters is expected, which will only be evident during the

DANGO PROJECT CONSULT LTD 20 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 construction of the substructures of the pillars and the tiers of the bridges, if any water is extracted to serve the purposes of concrete works. Polluting of surface water flows can be expected upon excavation works. This can be mainly contamination with insoluble substances caused by turbidity of waters. To a limited extend polluting with fuel and lubricantsis also possible due to construction machinery failures and equipment in bad repair. Some drains and irrigation canals will be affected, in result whereof the upgrade or the moving of respective facilities will have to take place: - drain at km 210+140; - irrigation canal under Trakia Motorway at km 210+148; - drain at km 210+140; - irrigation canal parallel to Trakia Motorway from km 212+800 to km 213+100; - drain at km 214+600; - drain at km 217+000; - drain at km 219+080; - drain at km 219+240; - irrigation canal at km 0+567 of road junction – town of Nova Zagora- temporary road connection. Project solutions have been developed to provide for the take-off of the surface flow through the drain ditches before the surface flow reaches the irrigation canals and the drains. These impacts will be limited by special facilities for take-off of the surface water (tiled roadside ditches) to the places of discharge into the contiguous surface drainage system. The project does not provide for discharge of surface flow into water intakes.

Expected impact during operation The operation of the motorway section will not be connected to permanent discharge of effluent waters, taken-off and discharged into surface water basins. In its process of operation the motorway will represent a line source of pollution, due to the internal combustion engines emitting gases and aerosols. The emitted exhaust gases and aerosols can get directly into the river waters only near bridges and culverts. The quick scattering of air-borne pollutants will not allow for the presence of higher concentrations of pollutants in surface waters. It should be noted, that the neutral reaction of the river water obstructs the dissolving of heavy metals in it (transition into ionic form), which makes their moving possible only as an integral part of suspended substances. Furthermore, the most dangerous pollutant among aerosols – lead, is practically absent in contemporary ethylized fuels. The second possible source of water pollution is the use of harmful and dangerous substances against icing of the route during winter, and more specifically – during periods with frozen forms of precipitation, or periods with very low ambient air temperatures, which may cause icing of small or larger sections of the road. The use of salt and lye for winter maintenance of the traffic lane, also cannot cause significant changes in the quality of surface waters, provided the small quantities applied.

Risk of pollution caused by motor oil spills or dangerous freights. The most serious consequences with regard to pollution of surface waters could have the sporadic and local emergency pollutions, resulting from accidental spills of oil products and other liquid or loose dangerous chemical substances transported on the motorway. The scale of potential damages will directly depend on how quickly efficient measures for containment and elimination of the spill or the dangerous substance will be taken.

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The probability of occurrence of such direct contamination is extremely small, and the danger of directly affected surface waters is inversely proportional to the distance from the traffic lane to the adjacent surface water flows. Direct impact on surface waters in case of accidents is only possible in the area surrounding the bridges.

Groundwater The groundwater is of predominantly ground water table character and connected mainly to the Quaternary terrace sediments consisting of mix of gravel, clay and sand. The groundwater are fed mainly by atmospheric precipitation and crevice water from the underlying formation. Draining of alluvial ground waters can be either natural or artificial. The natural download of water is made through the tributaries of the rivers Maritsa and Tundzha in this part of their valleys. Very characteristic for the groundwater in the section discussed is the broad range in which their water level varies, which may increase significantly in spring due to snow melting, reaching the very terrain at some places.

Expected impact during construction The investment project, in case of normal progress of construction works and subsequent operation, should not have any negative influence on the quality of groundwater. This results from the fact that no use of groundwater is planned. There will be no effluent water discharge into groundwater basins – i.e. there will be no conditions for impact onto their quality (physical and chemical state) and quantity (due to excessive operation).

Expected impact during operation Main pollutants of soils, respectively of groundwater within the scope of the motorway, will be the emissions of harmful substances from the motor vehicles traffic and the chemical substances used for winter maintenance of the road. The aerosols deposited on the surface can release cations of heavy metals only in acidic medium. Their migration in depth, however, is immediately blocked by the ion- exchange capacity of the clay materials found in large quantities in the soil and the under soil layers, in result whereof contamination of groundwater with Pb and Cd through soils located over the water-bearing layers is almost impossible. The construction of the road leads to no risk of deterioration of groundwater quality in the region. Contamination of groundwater during the construction of the new sections can only occur, if the excavations reveal a water-bearing layer or an aeration zone with high permeability (e.g. karsts water-bearing massif), which is not possible in this section. Groundwater contamination can only occur in case of accident with a transport vehicle with dangerous and volatile freight. The construction and the operation of such motorway facility has also a significant ecological aspect to the extent it enhances the traffic safety. To this date there is absolutely no information available on such facilities having caused water pollution.. In the region around the town of Chirpan special-purpose tests have been performed proving that no negative impact on groundwater can be expected. One reason is that the massive soil cover has a buffer ion-exchange capacity big enough to counteract the inflow of pollutants into the deep-lying undergound water basins. In view of the above, with regard to the groundwater component, we can conclude that the probability of groundwater pollutions is small.

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We can, therefore, draw a general conclusion that the impact on waters – surface and groundwater, is insignificant and non-present in the long-term perspective.

Use of waters Water supply for the municipality of Stara Zagora (villages Madzherito, Zagore, Pshenichevo, Benkovski) is provided by “Water Supply and Sewerage” Enterprise - Stara Zagora using the water of four sources – water-supply complex “Yagoda”, “”, “Kolio Ganchevo” and “Besh Bunar” water sources. The main discharge point of untreated household waste water and industrial waste water from the town is Bedechka, which, on its turn, pollutes Sazliyka river. Water supply for the municipality of Radnevo (villages Kolarovo, Bozduganovo, Sarnevo) is mainly sourced from the water source in the village of Chervenyakovo, located some 35 km away. Four more water sources and four pump stations are also used. Water supply for the municipality of Nova Zagora(villages Sabrano, Zagortsi, Stoil Voioda, Dyadovo, Ezero, Polsko Padarevo, Omarchevo) is sourced from drinking water water sources from the water supply areas along the valley of Tundzha river and Dam “Zhrebchevo”. Water supply for the municipality of Sliven (villages Bikovo, Skobelevo, Bozadzhii, Chokoba, town of Kermen) is sourced from Dam “Asenovets”, where the waters of Asenovets river gather. Water supply for the municipality of Tundzha (villages Hadzhidimitrovo, Drazhevo, Kabile, Zavoy, Veselinovo) is provided by “Water Supply and Sewerage” LTD – town of Yambol. To a limited extent the future route will affect also Yambol Municipality – town of Yambol. The water supply of the town is provided by means of water wells located in the Ormana area and on the village lands of Kabile, in PS “Ormana” and PS ”Kabile”. Water supply for the settlement on the territory of Straldzha Municipality (towns of Zimnitsa and Straldzha, and the villages of Vodenichane, Palauzovo, and Malenovo). Water for this municipality is provided by 48 water sources which divide into local water sources and water supply complexes „Straldzha” and „Bakadzhik”. For local water sources it is typical that their capacity decreased during the summer months, thus causing interruption of water supply. Water supply for the municipality of Karnobat (villages Devetak, Zheleznik, Krumovo gradishte, Dragantsi) is sourced from local water sources and the “Kamchia” water supply system. Three water supply complexes are operational for the needs of the municipality: “Asparuhovo”, “Tserkovski” and "Karnobat". Water supply facilities in the region of Stara Zagora group together in one water supply system Stara Zagora, divided into two fields – Kazanlashko and Starozagorsko. The Starozagorsko field has a 325 000 dca capacity. The bigger part of the sewerage system is tiled, and the pumping facilities are unfit to use. This is also valid to a great extent for the irrigational facilities positioned along the route.

Impact on Sanitary Protection Belts around drinking water sources With respect to the region around the villages Hadzhidimitrovo, Drazhevo, Kabile and Zavoy, the check up made on permits issued for use of drinking water – table No. 2.1.3.-2, shows that these facilities are not in place. Regardless of that fact, the motorway does not affect the most inner belt I – for close guard from water damaging human factor, situated immediately around the water source and/or the facility.

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Furthermore, in Annex No. 2 to Article10, para.1 of Regulation No. 3 dated October 16, 2000, on the survey, design, approval and operation of SPA….., there is no prohibition, limitation, or limitation in case of proven necessity, on the construction of road facilities. Most probably these are small springs of small capacity, servicing, practically, only local demands. The data given in item IV.2 also provides for the drawing of a conclusion that these waters are limited in quantity and contamination unprotected. On the grounds of the data available, without being familiar with the specific reports on the operational resources of these facilities, it can be seen that these water sources do not have large feeding up areas, and provided the small values of the ground drain modules, it is obvious, that these cannot be seen as main sources of water for the region. The fact they are so many in number also shows that apparently this is a case of draining through descending springs of groundwater along a lithological border. These heights are the most eastern part of ground body of water BG3G00000K2030 Crevice waters – Brezovsko – Yambolska zone. Summarizing the information on the technical characteristics of the investment project and the state of the water objects - surface and ground one, it can be concluded that there will not be negative impact on waters in the region of the investment project, both during construction and during the operation of the motorway. Short-term and unavoidable impacts will mainly occur during the construction period.

3. Geological environment The investment project is located in a region of relatively homogenous - plain and slightly hilly terrain. This implies a small volume of excavation and backfilling works, respectively, the impact on the geological environment will be limited to the founding area. The route does not block any deposits of mineral resources or any search and/or research areas thereof. In principle, any region with alluvial deposits can be viewed as potentially eligible for such research activities. This also applies for regions wherein carbonate and volcanic rocks are found. The requirements for the materials to be used for the building of various elements of the route are strictly defined and during its construction they will have to be supplied from deposits where raw materials meet these requirements. Additionally, it is necessary to provide and coordinate with the municipal authorities the respective landfills, whereon the excavation masses will be stored. The route of Trakia Motorway within the section Stara Zagora - Karnobat from km 210 +100 to km 325 +280, has been studied from an engineering and geological aspect, according to the procedure and requirements to the investment designs. As a result of these surveys the rocks from the examined rock sections are differentiated by lithological types (engineering and geological types (EGT/), i.e. such, characterized by identical physical and strength-deformation characteristics, even in geological aspect these could relate to one and the same rock type. This distinction makes it possible to characterize each EG type according to its bearing capacity, and therefore, for each important facility on the motorway, a set of charateristics has been provided, as well as recommendations for the very construction of the facility. To sum up, it can be concluded that the impact on the geological environment will be limited and insignificant, but continuous.

4. Earth and soils With regard to the soils this section of Trakia Motorway – from Stara Zagora to Karnobat, 115.180 km long, comes under the region of the Middle Thracian-Tundzhan

DANGO PROJECT CONSULT LTD 24 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 province of the Balkan-Mideterrenean soil subregion. The Upper Thracian valley and the northern part of the Tundzhan low- and hilly lands also pertain to the province. It is characterized with a number of specificities of the soil cover. The eastern part of the province wherein the motorway section will be constructed is almost entirely covered with vertisols. Luvisols– cromic are also found.

Scale of damage of lands and soils. Change of land designation connected to the realization of the investment project The construction of the linear object is connected to the taking of large areas of land out of the land and forestry fund, and the carrying out of all procedures connected to the land expropriation. This project affects cultivable lands – mainly cultivated fields, pastures (common), meadows, agricultural roads. For this purpose a land register has been created and the respective parcel plans compiled, describing expropriations of agricultural land and exclusion of land from the forestry fund, as the requirements of the Detailed territorial plans stipulate, pursuant the Territory Planning Act (TPA) and Regulation No. 8/14.06.2001 on the volume and content of the territory plans and drawings. The lands needed have been expropriated and their purpose changed by DECISION No. КЗЗ - 4/27 of May 2003 of the agricultural lands committee – Ministry of Agriculture and Forestry, pursuant to Article 24, para. 2 of the Protection of Agricultural Lands Acts and DECISION No. КЗЗ -1/31.01.2005 of the agricultural lands committee - Ministry of Agriculture and Forestry, pursuant to Article 24, para. 2 of the Protection of Agricultural Lands Acts. For the construction of the motorway section „Stara Zagora – Karnobat” the lands affected are:  Lot 2 - section „Stara Zagora – Nova Zagora” The road section from km 210+100 to km 241+900 is 31.800 km long. Subject to change of designation will be 1 743.343 dca land, of which agricultural lands - 1573.750 dca and forestry fund – 169.593 dca. The village lands of the following villages will be afected: Madzherito, Zagore, Kolarovo, Bozduganovo, Sarnevo, Pshenichevo, Benkovski, municipality of Stara Zagora; villages Sabrano, Stoil Voivoda, Dyadovo, municipality of Nova Zagora. The lands are mainly of Nova Zagora. The lands are mainly municipal and municial public ownership. Private lands and such owned by legal entities are also affected. The lands are cultivated (irrigated and non-irrigated), mainly ІІІ-rd, ІV-th, V-th and VІ-th category.  Lot 3 - section „Nova Zagora– Yambol” The road section from km 241+900 to km 277+597 is 35.697 km long. Subject to change of designation will be 956.984 dca. All lands are cultivated agricultural lands – ІІІ-rd, ІV-th cat. V-th, VІ-th, VІІ-th, ІХ-th and Х-th category. The lands of the following villages are affected: - Dyadovo, Ezero, Polsko Padarevo and Omarchevo – municipality of Nova Zagora; - Bikovo, Skobelevo, Bozadzhii and Chokobaр and the town of Kermen – municipality Sliven; - Hadzhidimitrovo – municipality Tundzha.  Lot 4 - section „Yambol – Karnobat” The road section from km 276+200 (=277+597) to km 325+280 47.683 km long. Subject to change of designation will be 2614.082 dca, of which: - agricultural lands – 2591.554 dca ІІ-nd, ІІІ-rd, ІV-th cat. V-th, VІ-th, VІІ-th and Х-th category - forestry lands – 22.528 dca

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The lands of the following villages will be affected: - Hadzhidimitrovo, Drazhevo, Kabile, Zavoy, Veselinovo – municipality Tundzha; - Vodenichane, Palauzovo, Malenovo, towns of Zimnitsa and Straldzha – municipality Straldzha; - Town of Yambol – municipality Yambol; - Devetak, Zheleznik, Krumovo gradishte, Dragantsi, town of Karnobat – municipality Karnobat.

Expected impact during construction The main impacts on soil resulting from the realization of the investment project will be connected to disruption of the soil profile and change in the physical-chemical, water- physical and biological processes, local deterioration of the quality of the soil of lands adjacent to the road section. Additionally, the lands are also connected to the upgrade of facilities of other establishments, carried out in parallel with the motorway construction. Hence, some 19.092 dca of agricultural lands and 3.237 dca forests will be additionally affected. In TOTAL the lands affected by the realization of he motorway section from km 210+100 to km 325+280 and the reconstruction of the attending infrastructure of other establishments amount 6 336.738 dca, of which 6 141.38 dca are agricultural lands and 195.358 dca – in the forestry fund. The construction of the Trakia Motorway section will change the category of the land it passes through. After the realization of the project, the expropriated lands will be classified as disturbed lands, according to the adopted Classification of defected lands (Guidelines № РД- 00-11/13.06.1994 of the Ministry of agriculture and forestry). The construction of the motorway will be connected to permanent soil disturbance where soils will be irretrievably lost as a non-renewable natural resource. The affected agricultural lands are of ІІІ-rd, ІV-th, V-th, VІ-th, VІІ-th, VІІІ-th, ІХ-th and Х-th category of the land fund. Temporary disturbance of the soils will also occur where the outage sites for machinery and other construction equipment, construction materials disposal sites and removed humus sites are located. After the end of construction these sites will be rehabilitated. Other expected impact on lands and soils, such as „compaction”, are possible resulting from uncontrolled movement of constructional or transport machinery outside the runway and the special-purpose routes. Local pollution of soils with fuels and lubricants is also possible in case of machinery accidents. Pollution of adjacent lands with exhaust gases aerosols during construction will be insignificant and will not have an impact onto the quality of the lands provided the short construction terms.

Expected impact during operation During operation, adjacent soils will be polluted by exhaust traffic gases, by potential fuel and lubricants spills, by defrosting substances applied onto the road for winter maintenance which will drain into the soils together with the surface roadway water flow. In the process of operation the motorway will represent a line source of pollution, emitting: - continuously, with variable intensity COx, NOx, SO2 and other gases and aerosols, containing mainly Cd, soots and other engine constituents from the passing vehicles and from wearing of their tyres and of the very road surface. 2- + 2+ - periodically (during winter season) – Cl, SO4 , Na , Mg etc, from defrosting substances used agains roadway icing.

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In order to determine the condition of the soils with respect to any pollutants therein and along the motorway route in the „Stara Zagora - Karnobat” section, soil samples were probed out in the following sections: - Sample No.1 at km 211+000, LOT 2, south of Zagore village - Sample No. 2 at km 241+600, LOT 2, north of Dyadovo village - Sample No. 3 at km 271+500, LOT 3, south of Chokoba village - Sample No. 4 at km 279+500, LOT 4, north of Drazhevo village - Sample No. 5 at km 318+400, LOT 4, north of the town of Zheleznik The results from laboratory tests show that the background content of lead, zink, cadmium is significantly lower than the MPL concentration. The gases and aerosols emitted by cars moving along the motorway will go directly to the lands and soils around the road. The results from scatter pattern modeling show that at a distance 5 to 10 m away from the shoulder, the strip along the route of the section will be subject to pollution, where the greater the distance away from the road is (50, 100 m) the smaller the concentration of pollutants becomes. Pollution caused by salt and lye used to maintain the roadway during winter is also a factor for deterioration of lands around the roadway. Salt and lye cannot, however, cause significant change of quality of the soils (apart from spot limited change of pH), provided the small quantities applied. Local, but significant pollution of soils during road operation can occur in case of accidental spill of lubricants, petrol, dangerous substances.

5. Flora and fauna Flora According to the geobotanical regioning of Bulgaria, the motorway section belongs to the Macedonia-Thracian province of the European deciduous forests areas. The climate in the region is trans-continental with some differences in the different parts. From north the Balkan mountain range limits the incoming flow of cold atmospheric masses, and from south the Rhodope mountain stops the warm air flows. The route of the motorway section affects two regions: - Upper Thracian district and Starozagorski region This first region occupies a multiform terrain with heterogeneous vegetation cover, and is currently almost entirely occupied by cultivated lands – agrocenoses. Grain cultures are mainly grown (wheat, barley, maize, sunflower), and to a smaller extent vegetables and perennial plants. - Straldzhan-Aytos district, Straldzhan-Sliven region. The second region encompasses the territory around the town of Nova Zagora, Sliven and Yambol. Almost entirely the land is cultivated.

Impacts The route of the motorway passes mainly through agricultural areas – cultivated fields mainly for grain cultures – wheat, barley, maize, sunflower. Pastures (common) and meadows are also affected on which semi-natural, derivative grass vegetation communities are concern to a smaller extent.  Section Stara Zagora – Nova Zagora Of 1 743.343 dca of territory affected by the construction, only around 169.593 dca are forests. Forest communities are mainly represented by cerris, Hungarian oak, pubescent oak and hornbeam, and are strongly influenced by human activities. The majority of them have degraded and turned into bushes of oriental hornbeam with hawthorn and cornel-tree.

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Most of the affected areas are cultivated fields - agrocenoses, whereon mostly grain cultures are grown. Affected perennial plants (vineyards, orchards) are relatively rare. The common pasture lands falling within the scope of the motorway section are covered with derivative grass vegetation communities, antropogenically influenced by grass feeding of livestock.

 Section Nova Zagora– Yambol In this section of the motorway mainly cultivated agricultural lands are affected – artificial agrocenoses (1 956.984 dca). The cenoses of the common pastures affected, do not significantly differ from what was described above. Around the village of Bikovo the route crosses a territory covered by habitat 1530 “Pannonic salt steppes and salt marshes” Along the southern flanks of the Kermen heights the route passes through a territory covered with semi-natural grass formations “Eastern sub-Mediterranean dry grasslands (Scorzoneratalia vilosae)”, protected by the Biological Diversity Act  Section Yambol – Karnobat Of the territories affected by the construction which amount to 2 580.303 dca in total, 22.528 dca are lands from the forestry fund. Forest types here include Quercus pedunculiflora, cerris, Hungarian oak, field elm, narrow-leafed ash, acacia. The herbaceous cenoses on pasture lands are represented by formations of bulbous bluegrass and the Chrysopogon gryllus, which are of entirely derivative character, and influenced by antropogenic factors. On these territories the grass is entirely derivative, secondary formation. In the section between the villages Veselinovo and Zavoy the route of the motorway crosses the Tundzha river, affecting grasslands “Salix alba and Populus alba galleries” and “Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae), also protected by the law.

Expected impact during construction The main problems with regard to the green vegetation component will occur in the process of preparation of the motorway route for construction. During the construction of the motorway the main impacts on the vegetation component can be reduced to the following: - destroying of natural phytocenoses (forests, meadows, pastures); - in case habitats are displaced – possibility for infestation of ruderal and weed species onto the territories of destroyed natural cenoses and change of the floristic composition; - degradation processes in case of pollution caused by accidents. On the grounds of balance calculations it has been concluded that for the realization of the project a total of 6 314.409 dca is needed, of which: - agricultural lands – 6 119.738 dca; - lands in forestry fund – 194.671 dca There will be additional disturbance of the plant component and it will be connected to some changes of the facilities of other establishment – 23.329 dca. - agricultural lands – 19.092 dca; - forestry fund – 3.237 dca; In total the disruption of the plant component will be 6 336.738 dca, of which 6 141.38 dca are agricultural lands and 195.358 dca lands of the forestry fund.

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Temporary disruption of the vegetation cover will occur on sites where construction materials will be stored. Mainly agricultural lands are affected used predominantly for agricultural purposes (fields, meadows, pastures, perennial plants, field roads, ravines, other territories), wherein more or less antropogenic factors have caused change of the composition of the vegetation cover. In general, the disturbances expected to occur on the territories on which construction will take place, with regard to the vegetation component, will be direct, significant and durable. There are no protected plants and vegetation types among the ones found in the region. The impact caused by construction works will be expressed in direct and complete destruction of the vegetation. Expected impact during operation  Impact of dust and aerosoles emitted by the car traffic and the road maintenance regime - sanding/salting As a line source of pollution and an intensively busy road with motor vehicle traffic, the motorway will, in a different extent, cause negative impact on the plants component adjacent to the road route. It has been found (data from reference literature sources) that the strips on both sides of busy road sections stretching sideways as far as 150 m away from the carriageway, are usually most heavily contaminated. The amount of lead is 15 to 20 times the background values, that of cadmium – 2 to 3 times, and that of zinc – 6 to 10 times. The concentrations of heavy metals are biggest in a 50 to 60 meters wide strip alongside the carriageway. This lodgment of pollutants depends on the direction and the speed of the wind, and on the turbulent air flow created by automobiles. It should be noted that in Bulgaria there are no standards for levels of contaminants in the biomass. Sanitary standards for the content of harmful substances in the vegetation (vegetables) are defined by Regulation No. 5 of the Ministry of Public Health (Ministry of Health) of 1984. Pollution caused by use of lye and salt for winter maintenance of the roadway is also a source of contamination of soils, respectively, of the vegetation in areas adjacent to the road. These substances, however, cannot cause noticeable changes in the quality of vegetation provided the limited quantities used.  Introdution of new roadside habitats and interaction with existing ones. Biological reclamation The introduction of new roadside habitats is related to landscaping and the biological strengthening of roadside areas, bevels and embankments. The projects’ objective is, by planting trees, shrubs and grass, to obtain synergy between the road and the surrounding landscape and to achieve biological strengthening of road bevels. The plant species used should meet certain climatic and edafic conditions, and to be gas-retaining and gas-resistant. It should be noted that the choice of gas-retaining and gas-resistant species is somewhat conditional, since there are no plant species absolutely resistant to harmful gases. Their resistance ability varies in the course of their development - typically young plants have a lower resistance ability, which in adulthood increases, and during aging it again becomes lower. The creation of sustainable and viable plantation and plant groups requires maximum compatibility between the ecological requirements for species and the environmental conditions. The choice of plant species should be as closely connected as possible to the specific nature of the local flora and no import of invasive species should be allowed.

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The landscaping designs of the motorway route and biological strengthening of the roadside spaces provide for:

LOT 2 „Stara Zagora - Nova Zagora” Planting of 5 252 trees and 274 405 bushes and mixed-seed grassing of 688 945 m2 LOT 3 „Nova Zagora- Yambol” Planting of 5 011 trees and 326 730 bushes and mixed-seed grassing of на 569 460 m2 LOT 4 „Yambol - Karnobat” Planting of 4 780 trees and 426 530 bushes and mixed-seed grassing of 525 490 m2 Grassing and bush planting of dividing strip: - LOT 2 - Stara Zagora - Nova Zagora- 105 000 m2 - LOT 3 - Nova Zagora- Yambol - 104 220 m2 - LOT 4 - Yambol - Karnobat - 157 500 m2 Grassing of soft shoulder: - LOT 2 - Stara Zagora - Nova Zagora - 150 000 m2 - LOT 3 - Nova Zagora- Yambol - 105 785 m2 - LOT 4 - Yambol - Karnobat - 225 000 m2

Fauna According to the zoogeographical zoning of Bulgaria, this Trakia Motorway section falls within the Thracian zoogeographical region, in the plain and hilly belt and hilly-pre- mountain belt of oak forests. The Euro-Syberian and European species prevail, and there is also a significant number of Mediterranean species. The valleys of Maritsa and Tundzha rivers are natural corridors for entry of Mediterranean flora from the south. In order to assess of possible violations of animal species habitats a field research was carried out (terrain inspection of the areas). On such grounds and in view of the preferred habitats, of all species, the ones which are likely to be affected by the project implementation, are:  Fish (class Pisces). The investment project foresees the construction of new bridge facilities over rivers. The construction works will be connected to some activities in the river-bed and to impact on ichthyofauna. In the rivers affected by the construction the most commonly found types of fish are of the Cyprinidae family and the Cobitidae family, represented by: chub, Maritsa barbel, ordinary barbell, bitterling, asp, bleak, Danube gudgeon, Common Nase, cobitis taenia. Expected impacts The main impacts on ichthyofauna will occur in the process of construction of the motorway section, where the construction of bridges will take place. The impact will be expressed in temporary turbidity of the water which will have a negative impact on the ichthyofauna and the banishment of species away from the site of construction of the bridge facilities’ foundations. If construction works take place in the period when fish is spawing, it is possible that this spawn is destroyed (if attached to the bottom of the water basin or onto some water plantation). Possible indirect impacts will be expressed primarily in the risk of water contamination in irrigation canals connected to the rivers crossing the route of the motorway. In the process of operation impacts on ichthyofauna will only be possible in case of

DANGO PROJECT CONSULT LTD 30 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 accidents with transport vehicles and subsequent direct inflow of polluting substances into the water.  Amphibians (class Amphibia) The Lot 2, Lot 3 and Lot 4 section of the motorway has insignificant vertical landscape segmentation, i.e. it is almost entirely flat. It has a very slight slope from north to south (from Sredna gora to the valley of Maritsa river). Most river currents run from north to south, curving through many meanders. Most of them are enclosed by embankments, while others are adjusted (the riverbed is made fully upright). All rivers are very sluggish, marshy, with plenty of rush, reed and other surface and underwater vegetation. In many places along the river flows there are swampy ditches caused by extraction of inert materials. In most places along the rivers there are no trees (except for few), there are shrub communities, and in only one place – where Tundzha river flows, and where the designs provide for the construction of a bridge at km 286 +080, there are strips of old white poplars, willows and alders. The habitats of amphibians are concentrated mainly around the water currents and the pit ponds around them. In spring the river-bed and the pit ponds around it attract some types of frogs, which during the rest of the year, although in small numbers, inhabit the surrounding plains and the very villages - green and brown toads, Balkan spadefoot, and, to some extent, the tree frog. These migratory routes in most cases do not cross the motorway, but go in parallel to it, since the motorway’s main direction is from west to east, whereas the frogs go to the nearest point of the water current. Expected impacts During the construction of bridges, disruption of the marsh frog habitat may be possible. Clearing of vegetation around the shores of rivers according to the construction designs could cause damage also of the yellow-bellied toad and the tree frog habitats. Upon the utilization of the lands covered by the road route it may be possible to disturb the habitat of the green and the common toad.

 Reptiles (Class Reptilia) The construction on the motorway will affect mainly cultivated farmlands, and to a lesser extent, virgin land areas where habitats of reptiles can be found. These are areas with only a few species, and reptiles that are to be found there are of the most common types. It should be emphasized that most land reptilians species in this category (whip snake, aesculapian snake, viper, four-lined snake, green lizard, wall lizard, Balkan wall lizard) do not inhabit cultivated areas and are only rarely found in the dry grasslands. These species are concentrated in riparian shrubs, water-meadows, embankments of dams and other places with better developed microrelief and abundant vegetation. There are no prerequisites whatsoever along the route of Lot 2, Lot 3 and Lot 4 of the motorway for the presence of habitats of tortoises. If any are to be found at all, these can be expected in forested areas and small rock openings on top of the hills through which the motorway passes. The whip snake and the viper probably inhabit the hilly places with more developed microrelief and abundant shrub vegetation. The riverside of Mochuritsa river and the marshy ditches along it are very suitable for the pond tortois.

Expected impacts The main negative impact on reptilians will be expressed in disturbance of existing habitats during the utilization of the motorway route. Ares of uncultivated lands are affected – common pastures and forest areas, which are the essential habitat areas for the species

DANGO PROJECT CONSULT LTD 31 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 mentioned and especially those subject to protection. The fragmentaion of the habitats and the populations will be inevitable. The process of construction will be connected also with temporary disturbance of some animal species and to their withdrawal towards neighboring territories. Due to the ability of most species to move quickly, the likelihood of for destruction of discrete specimen is minimal. The nature of the motorway, the traffic intesity during operation and any infrastructural objects, will inevitably cause serious fragmentation of habitats and populations living there.  Birds (Aves) The landscape within the scope of the proposed motorway construction is predominantly flat, where on both sides of the route, including very close to it, there are few hills of small altitude. The lower parts of the terrains are occupied by cultivated and uncultivated agrolandscapes. In order to assess the state of the ornithofauna, some direct field observations of birds were conducted, applying the line-transect method. Based on these observations and the nature of existing vegetation and the ecological requirements of species, the species composition of the ornithocenosis of the region was determined. There are 54 species of birds, temporarily or permanently inhabiting these territories. The majority of them are protected under the Biological Diversity Act. Within the scope of the most important river body – Tundzha river, which is crossed by a bridge at km 286 +080, species of water birds have been registered, breeding ones, wintering and migrating.

Expected impacts Undoubtedly, the construction of the motorwat and the infrastructure thereto will have a negative impact on ornithofauna in the region. In general, the possible impact of the construction of the motorway section on ornithofauna can be reduced to two aspects: direct impact – disturbance of habitats; indirect impacts - all possible negative impacts on birds, caused mostly during construction (disturbance of their reproductional behaviour, changes in the structure of populations, indirect influence on the status and structure of habitats). Most vulnerable to direct disturbances of habitats during construction will be the breeding birds living on the territory provided for the construction of the motorway route. The main feature of the road facility is its length, which affects mostly land areas, mainly agricultural land. The construction project affects breeding or potentially breeding habitats of mainly the following: Tawny pipit, red-backed Shrike, Ortolan bunting, Barred warbler. Of these, the only ground nesting one is the Tawny pipit. This species, although rarely, nests also in cultivated agrolandscape. The other live and nest mainly on trees and shrubs. The noise factor and the human presence during construction will also have an impact on birds especially in their nesting period. Given the diversity of species in the region and the presence of vulnerable one, it is very likely that the populations of some of them will be adversely affected. Some species are found frequently enough, i.e. there are sufficient specimen numbers in the region, hence the realization of the object will not seriously threaten them - nesting, food. It is possible, however, that certain species are scared away during the construction of the route and the facilities. With view of the mobility of birds and their ecological plasticity, after completion of the works they would return. Reduction of the parameters of ornithocenoses around the route can be expected due to noise and vibration. There would be no change of behavior of

DANGO PROJECT CONSULT LTD 32 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 migratory birds. Change may occur in the feeding habits of some predatory birds trying to avoid the construction sites. Given the size of the area affected by the investment project compared to that of the region, the construction of Trakia Motorway will not significantly affect in a negative aspect the feeding habitat of rapacious bird hunting in open areas during the day and the night. This is equally valid for some species feeding on these territories during their breeding period, during migration or when wintering in this region. This also applies to species feeding in open territories during autumn and winter: ducks and geese (wintering in this region and mainly feeding in corn plantations). The short length of the affected river section of Tundzha River, where a bridge is to be built, cannot adversly affect the habitat, the feeding areas, respectively, the population numbers and number of waterfowl species.

Mammals (Class Mammalia) The territory of Trakia Motorway from km 210 +100 to 325 +280 is occupied by agricultural land - intensively used cultivated land. There are almost no trees around it. The affected forest areas are small, hence the mammal species, the habitats of which may eventually be affected, are limited and mainly represented by the following: hedgehog, mole, Bicolored Shrew, Etruscan shrew, common vole, house mouse, field mouse, mouse-tailed dormouse, hazel dormouse, lesser mole-rat, badger, marbled polecat, weasel, bats. Expected impact during construction Disturbed habitats are likely to be expected in the process of absorption of the new sites for construction, which will lead to withdrawal of the species to adjacent areas. Impact will occur with regard to the food chain, due to further fragmentation of the territory. Increased noise levels caused by contstruction related traffic will also affect mammals. Expected impact during operation In general, the threats to fauna occuring during the operation of the road will be linked to increased anthropogenic and technogenic load onto the adjacent areas due to the road flow, the discharge of harmful emissions from vehicles, noise pollution, etc. Construction of the new homogeneous road section will lead to subsequent impacts associated with further fragmentation of habitats, deterioration of habitats in the vicinity of the route, road mortality. - Fragmentation of habitats will be more expressed in the case of slow moving animals: reptiles, small mammals, while birds and bats will be less affected. - To minimize these impacts the project provides for the construction of culvert pipes and arch culverts. They are secured with openings of 0.50 to 2.00 m, enabling the migration of species. Distances are enough to ensure the free migration of animals from both sides of the road. To reduce the chance of bats being hit by cars while flying over the road, guiding strips will be designed consisting of high vegetation leading to tunnels, underpasses and overpasses. It is necessary to preserve or restore the riparian trees vegetation near the bridges planned for construction, where particular attention should be paid to the so called “small marshy rivers”, where often no such vegetation is found. At the places where the motorway crosses main migratory routes of bats, guiding corridors will be planned of high-tree vegetation for the bats to fly unobstructed. Most often these places are the natural river valleys, through which bridges will be definitely built. - Deterioration of feeding habitats and the food availability. Impact on the quality of the habitats will occur near the route due to pollutants from vehicles and the winter road maintenance substances flushed away from the roadway with

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melting snow and falling rain. These impacts will be limited by special facilities for take-off of the surface water (tiled roadside ditches) to the places of discharge into the contiguous surface drainage system. The project does not provide for discharge of surface flow into water intakes. - Deteriotaion of adjacent habitats due to waste disposal. Waste pollution caused by passing or stopping cars covers a 10 m strip sidewards from the road. This kind of impact will lead to deterioration of habitats adjacent to the road to the extent that they will no longer be used by animals. - Deterioration of neighbouring habitats due to noise pollution and agitation. Road traffic is a factor significantly disturbing for animal species in areas immediately bordering the road route. On the one hand it is associated with the continuous presence of moving objects (cars), respectively, human presence, and on the other, with the generation of loud noise. The sensitivity of different species depends on their ecological characteristics. In this respect the sensitivity of birds compared with that of other animals is greater. It has been found that increasing traffic is the reason why birds nesting or living near the roadway decrease in number, and even disappear. In open spaces noise impact affects larger areas. Noise pollution and disturbance of animals has an expressed cumulative effect in places where the route passes near settlements and other infrastructure. - Road mortality. Death of animals caused by collision with cars is a documented fact. Most vulnerable in this respect are the slow moving reptiles (tortoises), small mammals (mostly hedgehogs) and rodents active by night, which often go out on the roadway, and are not only preferred prey for hunting predators, but also victims of road traffic. With regard to birds, songbirds and young birds are most vulnerable. Songbirds often hunt for insects along the roadway or low above it. Furthermore, they fly low when they move from one place to another and cross the roadway following a trajectory which increases the probability of direct collision with cars. Young birds are more often the victims of road traffic, because of the fact they are just learning to fly and cannot evaluate the threat of moving cars. Bat mortality caused by collisions with vehicles is very common. The high speed of the motorway traffic, and of heavy-duty trucks especially, causes strong turbulent airflow, which captures near flying bats, some of which weighing not more than 10-15 grams. Bats get attracted close to the motorway by the abundance of insects near the lights fixtures, the lights of vehicles or by illuminated roadside objects - billboards, parkings, restaurants and petrol stations. Of the ten bats species, the four of the Pipistrellus genu ones, together with the Savi’s pipistrelle, can be categorized as the "critical species" in terms of the likelihood for collision with vehicles. These are species often flying low and close to the ground. Very often they are attracted by nighttime lighting. The Common noctule and the Serotine bat are also at risk of collision, but the threat with them is relatively small, due to the greater height at which they hunt. The other species are too rarely found in the area of the investment intention, therefore we can conclude that their populations are not threatened.

Protected areas The route of the motorway section - LOT 2 „Stara Zagora - Nova Zagora” affects a protected area as construed by the Protected Areas Act - PA „Bozduganovska kuria”. It has been declared a Historical site pursuant to an Order No. 3718/28.08.1975 of the Ministry of

DANGO PROJECT CONSULT LTD 34 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 forests and environment protection, re-categorized into a Protected locality pursuant to Order No. РД-860/18.09.2002 of the MoEW. Area of PL 310.8 ha. It pertains to the village lands of Bozduganovo, municipality of Stara Zagora and will be affected by the motorway construction. Characteristic for this Protected locality is the mixed deciduous forest of cerris (Quercus cerris), Hungarian oak (Q. frainetto), Tatar maple (Acer tataricum).

Elements of the National ecological network The route of section „Stara Zagora - Karnobat” of Trakia Motorway affects six protected areas, pursuant to Article 6, para.1 of the Biological Diversity Act, endorsed by a Council of Ministers’ Decree No.122/02.03.2007 (SG 21/2007). - BG 0000425 „ Sazliyka River” PA under Directive 92/43; - BG 0000441 „Blatnitsa River” PA under Directive 92/43; - BG 0000418 „Kermenски Heights” PA under Directive 92/43; - BG 0000192 „Tundzha 1 River” PA under Directive 92/43; - BG 0002094 ”Adata – Tundzha River” PA under Directive 79/409; - BG 0000196 „Mochuritsa River” PA under Directive 92/43;.

Pursuant to a DECISION No. 89-ОС/2008 of the Minister of environment and waters, the investment project for Trakia Motorway LOT 2, section „Stara Zagora - Nova Zagora” from km 210+100 to km 241+900 has been agreed, concluding that there is no probability for the investment project to have a significant negative impact onto natural habitats and habitats of species, subject to protection within protected areas BG 0000425 „Sazliyka River” and BG 0000441 „Blatnitsa River” under Directive 92/43/ЕЕС for conservation of natural habitats and of wild fauna and flora, included in the protected zones list, approved with Decision No. 122/02.03.2007 of Council of Ministers (SG 21/2007). On the grounds of EIA Decisions No. 13/1993 and No. 6-5/1998 of the Minister of environment and waters, the section from km 210+100 to km 241+900, pasing through PA „Bozduganova kuria”, which is a protected territory according to the PAA, has been agreed as eligible for construction, pursuant to Article 12, para.4 of the Regulation on the terms and conditions for preparation of compatibility assessment of plans, programs, designs and investment projects against the scope and purpose of areas of conservation (State Gazette 73/2007). As to the degree of impact of the project on protected area BG 0000441 „ Blatnitsa River” PA, BG 0000418 „Kermenski Heights ”, BG 0000192 „Tundzha 1 River”, BG 0000196 „Mochuritsa River”, PA, with view of the conservation of natural habitats of wild flora and fauna, and BG 0002094 ”Adata - Tundzha” PA, with view of conservation of wild birds, approved with Decision No. 122/02.03.2007 of the Council of Ministers, a Compatibility assessment against the scope and purpose of areas of conservation (Appropriate assessment), pertaining to the scope of LOT 3 - km 24+900 - km 277+597 and LOT 4 - km 277+597 - 325+280 has been performed, demanded with DECISION No. 02-ОС/2009 of the Minister of environment and waters. The report received a positive quality grade, pursuant to Article 24, para. 7 of the Regulation on the terms and conditions for preparation of compatibility assessment of plans, programs, designs and investment projects against the scope and purpose of areas of conservation (SG 73/2007) Pursuant to Decision No. 104 ОС/10.09.2009 on the Compatibility assessment the Minister of environment and waters agrees the investment project for construction of Trakia Motorway Lot 3 „Nova Zagora – Yambol” from km 241+900 to km 277+597 and Lot 4 „Yambol - Karnobat” from km 276+200 to km 325+280.

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6. Waste Expected types and quantities of waste generated during the construction and the operation of the investment project. Waste classification The investment project provides for the construction of the currently incomplete section of Trakia Motorway (Stara Zagora - Karnobat) from km 210+100 to km 325+280. The total length of this section is 115.180 km. The route of the unconstructed motorway section is divided into three Lots: - Lot 2 – Stara Zagora – Nova Zagora– from km 210+100 to km 241+900; - Lot 3 – Nova Zagora– Yambol – from km 241+900 to km 277+597; - Lot 4 – Yambol – Karnobat – from km 276+200 (= 277+597) to km 325+280. The types and quantities of waste generated during the construction and the operation of the route will be presented and classified, with names and codes, in line with Annex No. 1 to Article 5, para. 1 of Regulation No. 3 of 01.04.2004 for classification of waste, of MoEw and MH (SG 44/2004).

Expected generation of waste during construction During the construction of each motorway section and the upgrade and relocation of ancillary motorway facilities, different types of waste will be generated during the cleaning and the preparation of the construction sites, excavation activities, construction of the road, sites for storage of building materials, temporary mounting sites, junctions, sites for machinery outage and unscheduled repairs of transport, road construction and assembly machinery and equipment, as well as places of temporary residence of the workers. Expected types of waste to be generated for the three sections (Lot 2, Lot 3 and Lot 4) are of the same type and differ only with view of expected quantities.

А/ DANGEROUS WASTE Classified as dangerous waste generated during the construction of linear objects and the upgrade and relocation of ancillary motorway facilities, will mainly be the waste generated due to maintainance of the road construction machinery, the vehicles and mounting equipment used for large scale construction works. Waste hydraulic oils Waste hydraulic oils will be generated in case of technological or emergency/unscheduled replacement of hydraulic oils from hydraulic systems of the transport, construction and mounting machinery. Composition of waste – slop oils, high molecular-weight hydrocarbons. Mineral-based non-chlorinated engine, gear and lubricant oils Waste oils from engines and reduction gearboxes will be generated in case of technological or emergency/unscheduled change of oils of the transport, construction and mounting machinery. Composition of waste – slop oils, high molecular-weight hydrocarbons. Oil filters Used oil filters will be generated in case of technological or emergency/unscheduled change of engine oils of the transport, construction and mounting machinery. Composition of waste – slop oils, high molecular-weight hydrocarbons, impregnated cellulose. Brake fluids Waste brake fluids will be generated in case of emergency replacement of brake fluid from faulty brake systems of vehicles and construction machinery and equipment. Composition of waste – slop oils, high molecular-weight hydrocarbons. Antifreeze liquids

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Waste antifreeze liquid will be generated in case of emergency replacement of the engine coolants from the faulty cooling systems of vehicles, construction and mounting machinery and equipment. Composition of waste - ethylene glycol, chemical ingridents. Storage batteries Waste will be generated in case of replacement of depreciated batteries from transport, construction and mounting machinery and equipment. Composition of waste - lead, sulfuric acid. Asphalt mixtures Waste will be generated during the milling of existing asphalt pavement and removal of existing asphalt pavement. Residues of asphalt (asphalt binder layer and wear layer) in case of surface application of asphalt pavements. Composition of waste - mineral fractions, mineral flour, bitumen, tar, asphalt and polymers.

B/ CONSTRUCTION WASTE Earth and rock masses Different types of waste such as earth and rock masses will be generated during excavation works (total excavation, excavation for facilities; excavation for drainage) for the construction of the motorway section and attending facilities - bridges, overpasses, underpasses, riverbed correction, reconstruction and moving of motorway facilities, etc. Some of these earth and rock masses are suitable for the embankment of the very section. Composition of waste - earth soil, rock soil, rock material. The contractor of the construction activities will use the appropriate earth and rock masses to construct the embankment of the object itself, where for the embankments borrow excavations will also be used (earth and rock masses supplied from other site). For excess earth and rock masses (considered inappropriate material for the construction of this section) temporary storage site will be made available in line with all due requirements, and these will be used for new earthworks for the construction of other roads or sites. Unsuitable materials as construction waste Unsuitable materials will be generated in the break up of concrete curbs, concrete bearing slabs, concrete culverts, break up of concrete and cement trenches. Other type of unsuitable material will be the crushed stone generated from the break up and the removal of existing road bottoming, as well as the mixtures of earth and inert materials generated during the clean up of sites for temporary storage of construction materials after completion of the project. In the process of demolition or repair of bridges, steel-concrete blocks will be generated and demolished. Composition of waste - concrete, reinforced concrete, crushed stone/inert materials, other earth masses, etc. Metal waste Metal waste will be generated during the construction of bridges, overpasses, underpasses, safety rails, safety fences and other framework activities. Iron and steel will fall off the steel reinforcement and the high-strength reinforcing steel. Composition of waste - steel. Wood material Waste wood material(beams, planks) will be generated in the course of framework activities upon the construction of bridges, overpasses, underpasses, drainage facilities, retaining walls, curbs, other facilities of the motorway section. Unused tyres

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Unused tyres will be generated after the replacement of torn or road unworthy tyres of the transport and construction machinery. Composition of waste - solid waste, elastomers, hydrocarbons. Parts of disassembled motor vehicles Depreciated parts from cars and construction machinery and equipment, parts of motor vehicles and mounting machinery, as well as waste equipment from vehicles and construction machinery, will be generated after emergency repairs of transport and construction machinery. Solid waste. Brake linings Depreciated friction products will be generated in case of emergency replacement of brake linings from faulty brake systems of motor vehicles and construction machinery. Composition of waste - elastomers, non-ferrous metal chips and filings, etc.

C/ Solid domestic waste During the construction of the discussed three sections of Trakia Motorway domestic waste will be generated by the workers residing on construction sites and the three sections, temporary camps and outage sites for transport, construction and mounting machinery and equipment. Humus layer Any humus layer removed prior to all excavation works implied by the construction of motorway sections, new facilities and new road drainage system, will be disposed (continuously stored) and then part of it will be used on the relevant constructed section whenever humus needs to be laid onto road bevels or in rehabilitation activities. The rest of it will be stored and used for rehabilitation of other road sections or other sites.

Generation of waste during operation Dangerous waste - Hydraulic and engine oils, lubricants, gear oils, brake fluids, antifreeze liquids and other spills and leakages from broken or faulty vehicles; - Leakages from tank trucks and trucks carrying dangerous substances, incl.fuels; - Parts from motor vehicles and outworn parts thereof, spare parts, oil filters, etc. Other waste generated in the process of operation - Leakages from tanks truck and truck carrying liquid or wetted materials; - Friction particles produced from the wearing out of tyres; - Outworn and torn tyres; - Road kill – dogs, cats, bird, etc. Solid domestic waste - domestic waste discharged on or sideways of the road; - plastic, glass, metal or paper packings of food, drinks and cigarettes, thrown out of cars. Spilled waste liquids and thrown waste on and aside the road are in small quantities, and most of them will be blown away by the wind or washed by the rains. Some of the waste will remain near the road and in the roadside ditches. With view of containing the pollution along the roadside, the respective road maintenance authorities remove the waste accumulated in the ditches. Emergency pollution occurs only in case of road accidents or break-down of transport vehicles, caryying dangerous substances or dangerous waste, or in case of illegal disposal of dangerous waste. In emergency situations, the competent authorities are immediately

DANGO PROJECT CONSULT LTD 38 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 informed (Police, Regional Directorate “Fire Safety and Protection of Population Service”, General Directorate “Fire Safety and Protection of Population Service”, Civil Protection National Service, Regional Inspectorate of Environment and Waters, Ministry of Environment and Waters, Regional Inspectorate for Public Health Protection and Control, and Ministry of Health) in line with the requirements of the Waste Management Act, Article 23, and Resolution of Council of Ministers No. 53/19.03.1999 on the handling and transportation of industrial and dangerous waste and the Regulation for its application thereof, with the relevant annexes, wherein the first measures for containment of harmful impact are described. Collection, transportsation, utilization and disposal of waste during construction The construction company implementing the construction works of the new Trakia Motorway sections should perform scheduled repairs of the construction and transport machinery, as well as scheduled change of oils, storage batteries, tyres and other car components and components of transport and construction machinery in its own service- station. А/ DANGEROUS WASTE In case of accidental/unscheduled change of hydraulic oils, engine oils, gear oils, antifreeze and brake fluids of the transport, construction and mounting machinery, at the machinery outage sites or at the construction site, all generated waste shall be collected into sealed metal tanks. In case of accidental/ unscheduled change of oil filters and electrolyte storage batteries of the transport and construction and mounting machinery, at the machinery outage sites or at the construction site, all generated waste shall be collected into sealed metal tanks. Emergency/unscheduled replacement of car parts should be carried out on sites with thickened insulating flooring preventing the penetration of slop oils into the soil. During the construction of each of the three motorway sections, oils collected in sealed tanks, parts of the transport machinery, remaining unused or no longer usable (collected in metal tanks/containers) will be transported to the main plant of the contractor. Asphalt mixtures remaining unusable after the technological milling of existing asphalt pavement, breaking up or removal of existing asphalt pavement and construction of new roadways, will be collected and stored temporarily on specially desginated locations. Part of the asphalt mixtures will be transported to the asphalt plant of the contracter for future use. Residues of asphalt (asphalt binder layer and a wear layer) remaining from surface application of asphalt pavements, will be collected in metal containers and transported to the main plant of the contractor for future use. Pursuant to the Waste Management Act - Article 4, para. 1, item 1, item 3 and para. 2, Article 7, Article 12, para. 1, item 1 and Article 18, the organization connected to the collection activities, transportation, temporary storage, utilization or disposal of different types of dangerous waste during the construction activities of the relevant sections of the motorway, will be handled by the construction contractor.

B/ CONSTRUCTION WASTE Materials suitable for future use, such as earth and rock masses (from common excavation, excavation for facilities and drainage excavation) will be disposed of at specially designated sites before being used for the making of an embankment. Excessive earth and rock masses will be stored on temporary storage sites prior to being transported and used for the construction of other road sections and other construction sites, or will be disposed of at a special site as instructed by the municipality. Materials unsuitable for future use will be generated during the break up of concrete curbs, concrete bearing slabs, concrete culverts, break up of concrete and cement trenches.

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Other type of unsuitable material will be the crushed stone generated from the break up and the removal of existing road bottoming, as well as the mixtures of earth and inert materials generated during the clean up of sites for temporary storage of construction materials after completion of the project. In the process of demolition or repair of bridges, steel-concrete blocks will be generated and demolished. Generated waste will be collected and stored on temporary sites, then transported by their owner (the constructing company), in line with Article 18, para. 1 of the Waste Management Act and disposed of on a special site designated for that purpose by the municipality on the territory of which the construction waste has been generated, as provided by Article 16, para. 3, items 4 and Article 19 of the WMA. Waste spare parts and unusable tyres of motor vehicles will be collected in metal containers and transported to the main plant of the contractor constructing each discrete section of the motorway. Metal waste will be generated during the construction of bridges, overpasses, underpasses, safety rails, safety fences and other framework activities. Iron and steel will fall off the steel reinforcement and high-strength reinforcement steel high-strength reinforcing steel. Waste will be transported to the main plant of the contractor constructing each discrete section of the motorway Solid domestic waste will be collected in metal containers and transported to a specially designated solid waste landfill of the municipality on the territory of which the construction of the motorway takes place, as provided by Article 16, para. 1 and Article 19 of the WMA. The humus layer (formed usable material) will be collected and stored on a temporary site/storage facility until part of it is used for laying onto road bevels and rehabilitation works. The remaining humus will be kept in store until used of other road sections and other construction sites. Part of the waste generated during construction will be suitable for further utilization. After milling, the asphalt pavement will be collected and transported to the plant of the construction contractor. After due processing is will be used for the making a stabilized road shoulders. Another possible form of utilization of milled asphalt pavement will be the recycling in asphalt plants, where mixed with bitumen and homogenized the material could be used for patching of asphalt road pavement, asphalting of pedestrian areas, etc. The road bottoming left unusable after being broken and removed (crushed stone) can be processed and used in other construction works.

Collection, transportation and disposal of waste during operation Different types of waste generated during emergency situations occuring on motorway or car accidents were scattered/spilled out on the roadway and the roadside areas. Spilled liquid waste will be collected through adsorbents. Thus formed agglomerates of waste and adsorbents will be collected in metal containers/tanks and will be removed and handed over to entities licensed under Article 37 of the Waste Management Act or holders of permit for disposal of such waste. Spilled waste and waste discarded along or sideways of the road is in small quantities, in their major part blow away by the wind or washed away by rains. Part of the waste is retained in the area around the road or in the roadside ditches. In order to reduce pollution of the roadside space, authorities responsible for the maintenance of roadside will remove the solid waste generated during operation of the motorway and accumulated in the ditches, and will forward it for subsequent treatment or disposal.

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Carcasses of animals killed on the motorway during operation can be disposed of as recommended below – the road maintenance authorities will collect the carcasses of dead animals and transport them to incinerating establishment for due disposal. Solid domestic waste generated during operation of the motorway will be transported (by the road maintenance authorities) to the designated disposal site. During the operation of the motorway - the management of the waste will be handled at municipal level, pursuant to Article 16 and Article 19 of the WMA.

Transport arrangement for transportation of construciton waste. Temporary storage sites. Site suggestions for temporary storage of construction materials The route for transportation of waste to be generated during the construction and the operation of the motorway should be agreed with the municipality mayor and the mayors of the settlements, through the administrative territories of which the route of the motorway will pass, as instructed by Article 18, para. 2 of the Waste Management Act. This transport arrangement for transportation of construction waste provides for the use of temporary service roads, main agricultural roads and national roads, after due coordination with the mayors of the affected settlements. Temporary construction materials storage sites (inert materials, earth and rock masses for construction of embankments, humus for bevels) can be designated by the construction contractor of each motorway section (upon elaboration of Plan for organization and implementation of construction works) in line with the tender documents prepared by the Investor. All temporary sites should be approved by municipal authorities through the territory of which the route passes, as instructed Article 16, para. 3 items 4 and Article 19 of the WMA. Disposed of quantities construction and suitable materials will be stored and kept until subsequent use for the construction of the respective motorway section. Upon completion of the motorway construction activities the temporary disposal sites should be cleaned up, and due rehabilitation activities should be carried out, including technical rehabilitation and biological reclamation. Possible locations for sites for temporary storage of materials and waste will be coordinated with the municipal administrations, and endorsed by the respective RIEW, RIPHPC and the Regional road administration, on the territory of which the constructed section is located, together with the elaboration of Construction works Organization Plan (Health Protection and Safety Plan – HPSP). After completion of construction works, the sites will be cleaned up and reclaimed. Sites suitable for temporary storage of construction materials are sites located on land owned by the municipality, along the route of the motorway.

Lot 2 Site for temporary storage of humus and earth masses, situated north of the village of Pshenichevo, at km 228+500. Site for temporary storage of construction materials (inert materials), situated northeast of the vilage of Bozduganovo (former village of Grudevo), at km 217+000. Site for temporary storage of construction waste, situated northeast of the village of Bozduganovo (former village of Grudevo), at km 220+400. Lot 3 Site for temporary storage of humus and earth masses, situated south of the town of Kermen, western flank of the “Sreden bair” locality, at km 263+800. Site for temporary storage of construction materials (inert materials), situated in a former farmward in the village of Skobelevo, at km 267+000.

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Site for temporary storage of waste, situated northeast of the village of Dyadovo, on a quarry slope – km 244+000. Site for disposal of excessive unusable earth masses and/or construction waste, situated south of the town of Kermen, former quarries of “Boz bair”, at km 264+700. Lot 4 Site for temporary storage of construction waste, situated south of “Keramichna kashta Straldzha” JSC, territory of saline soils, at km 300+000. Site for disposal of excessive unusable earth and rock masses, situated south of the village of Malenovo, near Mochuritsa river, at km 305+000. Site for temporary storage of humus and construction materials, situated on a quarry slope between the villages of Zheleznik and Devetak, at km 315+000.

Assessment of the environmental impact of waste The impact of the waste generated during the construction of the motorway route, the reconstruction and relocation of ancillary facilities, and during the very exploitaion of Trakia Motorway from km 210 +100 to 325 +280 on the various components of the environment can be classified as insignificant, temporary (for the duration of the construction), constant (during operation), and of small territorial range. Separate collection of waste generated during the construction of the motorway route, the reconstruction and relocation of ancillary facilities, and during the very operation of the motorway, its transportation and forwarding to individuals or legal entities authorized to carry out activities involving the utilization and/or disposal of waste under Article 37 of the Waste Management Act or holder of a relevant complex permit, does not imply any negative impacts on human health and the environment.

7. Dangerous substances Types of harmful or dangerous substances used during the construction and the operation of the investment project. Classification. Storage. No provision has been made for the use of dangerous chemical substances, preparations and products, subject to prohibition or restrictions for trade and use, and included in Appendix to Article 1, para. 2 of the Regulation to Council of Ministers’ Ordinance No. 130/01.07.2002 (SG 69/17.07.2002), during the construction of the three sections of Trakia Motorway, the reconstruction and relocation of ancillary motorway faclities and the operation thereof. The classification of all dangerous substances has been made observing the relevant REGULATION on the order and manner of classification, packaging and labeling of chemical substances and preparations. During the construction of the discrete sections of the motorway, the reconstruction and relocation of ancillary motorway facilities and the operation thereof, dangerous chemical substances will be used such as fuel - gasoline, diesel, LPG, natural gas. Toxicological caharacterisics of fules used during the reconstruction of the road section and its operation Toxicological characteristics of the fuel used by motor vehicles, the construction and mounting machinery. Petroleum products - high concentrations of hydrocarbons are lethal. Lower concentrations cause headache, nausea and agitation. Chronic poisoning cause functional disorders. High concentrations of vapors may cause instant death. Loss of consciousness preceeds quick death if the person remains in the poisoned atmosphere.

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Alkalines (propane and butane) are very strong narcotics, but their impact on the human body weakens due to low solubility in blood. In the general case, they are practically harmless. During the construction of motorway sections and its operation afterwards, no dangerous subtances will be stored . During the operation of the roadways dangerous chemical substances, preparations and products will be transported, which are subject to prohibition or restrictions of trade and use, and listed in the Annex to Article 1, para. 2 of the Regulation to Council of Ministers Ordinance No. 130/01.07.2002 (SG. 69/17.07.2002). The types and characteristics of these substances can not be specified at this time, given their variety. It is necessary to comply with the requirements of the BASEL CONVENTION (SG 8/ 1996) for the Control of Transboundary Movements of Hazardous Wastes and their Disposal, and the requirements of Council of Ministers’ Ordinance No.129/01.07.2002 adopting a Regulation on the order and manner of import and export of dangerous substances, preparations and products in the Republic of Bulgaria and the Council of Ministers’ Ordinance No.166/04.08.2000 regarding the adoption of a Regulation on the cases for which permits are required for entry, take out and transit of waste and on the conditions and procedure for issue of such permits (SG 66/2000).

8. Physical factors Within the section discussed Trakia Motorway passes along a new route currently without any traffic. The route is divided into three sections: I-st section - Stara Zagora - Nova Zagora, II-nd section - Nova Zagora-Yambol and III-rd section Yambol - Karnobat. The terrain is predominantly plain, and the territory - agricultural land for which no requirements are set as to the noise regime. The noise background around the future route is the natural surrounding noise background, except where national roads, and the cars moving on them are the sources of noise. A source of outdoor noise during the construction of the motorway is the road construction machinery (excavator, bulldozer, roller, asphalt paver, trucks, etc.) stationed on the relevant section of the road route (construction site). High levels of noise can be expected near the machines when they are operational – at times reaching as high as 90 dBA. The construction activity will take place during daytime. Closest to the future route are the residential areas of the villages Drazhevo and Zheleznik (125 m away from the site) and the village of Chokoba (175 m). Expectations are that the noise from the construction activity, reaching these residential areas, will exceed the daytime noise level limits. Exceeding varry from 2 to 5 dBA. For other settlements around the route of the motorway, no exceeding of the hygienic noise level limits is expected during construction.

During the road construction and the reconstruction of the supporting engineering infrastructure (reconstruction of a gas pipeline near the village of Drazhevo and reconstruction of electrical conduits and new electric poles near the village of Zheleznik) temporary impact of the cumulative effect of the two types of noise sources is expected (construction noise from the roadway and noise from construction site of the respective facility). During the reconstruction of the other ancillary infrastructural sites along the motorway route no violation is expected of the acoustic environment on the territory of the villages surrounding the motorway, because their residential areas are far enough from it.

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Vehicles servicing the construction activities will use the main roads throughout the region and the newly constructed route. If necessary, vehicles will pass through respective settlements. The level of noise generated by this transport will depend on the number of daily routes During the operation of the motorway, one of the sources generating noise in the environment, will be the traffic flow on it. A forecast for the noise parameters of the flow has been made on the grounds of data provided by NRIA on the expected traffic development by 2030. Calculations have been made for 2020 to 2030 period and estimated noise levels for 2030 are: daytime - 72 dBA , night-time - 63 dBA. The distance at which the hygiene standards for noise are reached is determining for the width of noise protection zone around the route of the motorway. A decisive factor is the requirement for night-time levels. For residential areas for 2030 this distance is 300 m. In the EIA Report only settlements that fall within the range of the noise protection zone are addressed. These are – the town of Kermen, and the villages Chokoba, Hadzhidimitrovo, Drazhevo and Zheleznik. For each of these settlements a minimum distance from the route has been given, as well the expected exceeding of gygienic noise level limits for day-time and night-time. The report recommends measures for prevention of excessive noise impact on residential areas of settlements, both during the construction and during operation of the respective section. In the case of settlements wherein impact of the motorway treaffic noise is to be expected, its interaction with that of existing and newly occuring noise sources in the region was also accounted for, when making the above mentioned calculations. However, no cumulative effect of the impact of these sources and Trakia Motorway is to be expected due to the big distances between them and their different positioning in relation to the settlements’ territories (objects of impact).

9. Landscape The route of the discussed section of Trakia Motorway from km 210+100 to km 325+280 passes through a terrain of plains and low hills.

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Kermenski Heights

According to the regional landscape zoning of the country, the territory of the site falls within the In-mountain zonal area of South Bulgarian lowlands and low mountains, the Upper Thracian sub-region, Syutliysko-Sazliyski region. It is characterized by: Class - plain and lowland landscapes between mountains; Type - landscapes sub-Mediterranean meadow-steppe and forest-meadow-steppe in- mointain lowlands; Group - landscapes of meadow-steppe in-mountain plains over unconsolidated Quaternary sediments with a high degree of agricultural utilization. Within the scope of the route of this motorway section there is no an area of fully preserved primary landscape. The natural vegetation is predominantly herbaceous, and the trees - mostly deciduous, without dominating the landscape. The lanscape is dominated by flat and slightly hilly plains covered mainly with grass and shrub vegetation and subjected to erosion processes. The dominating anthropogenized landscapes are the residential agglomerations and the agrolandscapes.

Assessment of expected change of landscape The realization of the motorway section will be connected to two phases of change in the landscape. In the process of construction - the construction machinery employed for all construction works, as well as for all earthworks, connected to the construction of the new layouts. This first phase will have a temporary impact onto the general condition of the landscape. The second phase will be associated with the operation of the road together with the new technogenic landscape elements - new road crossings, overpasses and bridges, road signs. This phase will involve a permanent change in the environment and visual changes of the landscape resulting from the construction of the motorway. Technogenic structures will

DANGO PROJECT CONSULT LTD 45 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 stand out against the background of the surrounding landscape and will reproduce and enhance the urban environment. Expected impact during construction Roads, in general, form linear landscapes with specific content and characteristics. They are industrial structures spectacular for their ever-changing character within the overall appearance of the surrounding environment. The creation of such modern communication systems results in significant ecological changes in the landscape due to changes in relief, the disturbance of natural habitats of plants and animals, increasing the environmental pollution. Technogenic structures, which are to be realized, as a rule, should fit naturally in the existing landscape. Environmental issues include primarily the conservation of one of the most precious resources - land, as technogenic structures and the technical infrastructure thereto take up ever larger territories. The realization of the project will be associated with disturbance of another 6 314.409 dca of land, changes in the lithogenic basis during the construction of new road structures, destruction of existing vegetation. The construction of the republican transport system is the largest land consuming process. The construction of the new motorway sections will bring about a change in the existing agricultural and forest landscapes. These will be expressed in the form of interference in the organization of territories, and will be to the expropriation of agricultural lands and forests. Along with that, the construction of the road sections will be connected to the removal of the available humus horizon, by means of which soils function as a unique earth battery and distributor of energy, associated with humus and necessary for the proper exchange and circulation of substances in nature. The removal of the humus horizon will completely destroy the existing vegetation. The vegetation cover within the scope of construction is relatively homogenous. The destruction of natural and semi-natural meadow and woodland vegetation will be significant. During the construction of the new motorway sections there will be irreversible mechanical disruption of the geological environment. Such disruptions will be significant. The construction of the motorway sections will include excavation and backfilling activities associated with the maintenance of a special construction for the moving of heavy equipment and machinery. This whole process will be linked to a local and temporary change in the overall state of the environment, as well as with significant changes in the relief and the structure of the landscape in certain areas. These activities will be associated with impaired visibility of the population permanently or temporarily residing in the area of construction. The duration of this impact will be relatively short and limited – until the end of construction works, and will varry depending on the specific climatic conditions.

Expected impacts during operation The operation of the motorway will be connected to two main aspects: how traffic participants visually perceive the road and the surrounding big road facilities and facilities for road traffic organization, and how contaminants migrate throughout the landscape. The shaping of landscape area adjacent to the roadway will be necessary in order to improve the optical tracing, covering up unsightly views, directing the eye to certain accents and points of visual support for the driver. The optical tracing of the road is a significant factor for the orientation of drivers on the direction and the situation while driving. This is related to the implementation of the project for traffic organization providing for the installation of road signs and marking. A system of optical supporting elements is set up along the route to give information on any changes, slants and traffic conditions, which should be aesthetically relevant to the road and

DANGO PROJECT CONSULT LTD 46 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 the surrounding landscape. These elements pertain to road technical infrastructure - guiding boards, road signs, illuminated information signs, guiding marking, etc. According to the project, standard light-reflective signs shall be used in compliance with Bulgarian traffic signs standards, furnished with props and foundations to be used for two-lane roads and motorways, as well as non-standard light-reflective signs, etc. Other major optically supporting elements, apart from the signs, will be the pavement and the marking thereon – white thermoplastic one with reflective beads, solid and broken lines; hatched – line areas where traffic is not allowed; arrows. The optimal density and variety of objects keep attention alert. The number of objects, attracting drivers’ attention depends on the general appearance of the landscape, the quality of focal points, the individual level of concentration on the road lane or elsewhere in the surroundings. There is a separate project prepared, for landscape modeling of the new route. The main objective of the project is to achieve harmonious unity between the road and surrounding landscape by using trees, shrubs and grass. This will also support the biological strengthening of the new roadside bevels, which, in certain sections, reach up to 6 m of height. The migration of pollutants throughout the landscape is predetermined to a great extent by the particular climatic and hydro-meteorological situation. The specific wind situation is determining for the airborne pollutants, and the accumulative pollution of roadside areas’ soils with aerosols, in particular. It can be accepted, allowing certain approximation, that the maximum relative transfer of pollutants corresponds to the 100-meter-wide strip affected by the accumulating aerosol pollution. Pollution decreases exponentially as one moves away from the road lane. The relief, forestation, traffic density, etc. also play a significant role for the level of pollution. Part of the road passes through a hilly relief which means that the pollutants’ transfer will not be of great scale, whereas in plains this transfer will be more intensive. Transfer of waterborne pollutants is directly dependent on rainfall being the main source for feeding of surface and ground waters. The transfer of heavy metals from exhaust gases, of substances used for winter road maintenance and of oil products by means of groundwater down through the hydrogeochemical landscapes is obstructed by a number of natural geochemical barriers. Their transition as cations in water solution is possible only in acidic medium. The soils in the region have 5.00 to 6.00 pH values. The next type of selective geochemical barrier is formed by the living plants which 2- + very intensively store in their tissues S (from SO4 ) and Cl, intensive Na , and not so intensively - Cd and Pb. Different plant types have different capacity to store these pollutants. It depends mainly on the morphology of the leaf blade.

10. Cultural heritage – expected impact on immovable cultural valuables within the scope of the investment project All Reports on Environmental Impact Assessment (EIA) of various sections of Trakia Motorway, prepared so far, invariably focus on the high frequency of occurrence of archaeological cultural monuments on the territory of the motorway’s route. In accordance with a contract signed with the National “Road Infrastructure” Agency, exploration and search for immovable cultural monuments have been conducted along the route of the motorway. In result, dozens of archaeological sites have been registered as potentially endangered, to a different extent, by the pending construction works. The necessary measures for the protection of all sites situated near the route of the motorway have been identified in accordance with the requirements of the Bulgarian legislation in the field of protection of cultural heritage. Special measures are determined for each particular site depending on its

DANGO PROJECT CONSULT LTD 47 Non-Technical Summary of Updated EIA Report – ‘Trakia Motorway’ section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 features and the level of endangerment. Most often prospecting explorations and rescue excavations within the easement boundaries are performed. Comprehensive archaeological studies are less common. The decisions for ceasing of explorations, submission of terrains for construction or for implementation of other protection measures are taken by a interdepartmental commission appointed by the Head of the National Institute for Protection of Immovable Cultural Monuments. Such a commission is convened once a year, after the end of the archaeological season. The last commission appointed by Order No Р-52/07.07.2009 held its meetings at the end of July 2009. Reports on the results from the rescue explorations conducted at 36 archaeological sites were submitted to the committee. After familiarizing with the documentation submitted and on-site examinations, the committee decided that archaeological studies at 25 of the sites have been definitively completed and their territories can be submitted for the carrying out of construction activities. The remaining 11 sites shall be further studied until the complete exhaustion of archaeological structures. The term for the completion of the archaeological studies of these sites has been prolonged with a month or month and a half. When the term expires and a report is prepared by the Director of studies, the route section in question is released for construction. For one of the archaeological sites it has been provided that earthworks shall be carried under the observation of the Director of archaeological studies. Due to the nature of the primary archaeological studies – terrain inspection without any destructive interference thereon, there is a probability that not all existing archaeological sites have been registered. The presence of certain archaeological sites, for example necropolises or cult pits could be identified only by carrying out of earthworks. Therefore, explicit decision of the commission requires that archaeologists from the museums the territory is crossed by Lots 2, 3 and 4 of Trakia Motorway to conduct regular on-site checks of the entire route as stipulated in Article 161, para 2 of the Cultural Heritage Act. In case a previously unregistered archaeological site is found during observation of works, due to its specific features, actions shall be undertaken in line with the provisions in Article 72 and Article 73 of the Cultural Heritage Act. The protection measures, concerning the cultural heritage monuments endangered by the construction of Trakia Motorway in the section “Stara Zagora – Karnobat” from km 210+100 to km 325+280 have been almost completely implemented. Rescue excavations of dozens of archaeological sites located along the route of the motorway in this section were conducted in the period from 2007 to 2009. Archaeologists from the National Archaeological Institute and Museum at Bulgarian Academy of Sciences (BAS), “St. Kliment Ohridski” University of Sofia, the museums in Stara Zagora, Nova Zagora, Yambol, Karnobat and Burgas were involved in the excavations. Actual work proves that the methodology established during the working process is adequate and due to its application archaeological sites and structures of great importance have been rescued and hundreds of valuable archaeological finds have enriched the regional museums’ exhibitions. In conclusion, it should be noted that in regard to the protection of the cultural heritage, during the construction of Trakia Motorway, all necessary measures required by the specialized normative regulation have been undertaken. The operation of the motorway will not have directly negative impact onto the cultural heritage sites.

11.Health protection and hygienic aspects The region wherein the Construction of Trakia Motorway km 210+100 to km 325+280 project will takes place is part of the Upper Thracian valley.

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TRAKIA motorway is a significant transport connection of national and international importance. It is a part of the Pan-European Transport Corridor VIII (from Macedonia and Albania to the Black Sea ports of Bulgaria). The main purpose with view health protection during the implementation of the project is to ensure safety of traffic along the road section as well as safety of population in the its vicinity in the cases of proved and estimated high intensity of traffic along the new section. The general hygiene analysis of the motorway route finds that the maximum of opportunities have been provided for the avoidance of the road crossing residential and industrial areas. The central and the eastern part of the country in the direction Sofia – Plovdiv – Burgas is an immediate area of influence by the motorway. The implementation of the project will allow the creation of an modern ground communication connection being the solution of major currently existing technical problems –traffic passing through the main streets of many towns/villages, causing high levels of noise and large emmissions of harmful substances in the air. Main risk factors for the health of the workers employed in the implementation of the investment project are the dust, toxic harms, noise, general and local vibrations, unfavorable microclimate and work-load. Work in the tunnel implies a high risk for developing pulmonary dust diseases. Risk factors for the health of local population during construction and operation of the motorway are mainly the potentially polluted air environment and the noise levels exceeding limit values. On the whole, however, the future negative noise and gas-dust impact of the motorway will be significantly lower compared to the present situation. The prognosis results regarding the air pollution in all towns/villages and all sub- sections, including the ones with registered cumulative effect, do not indicate air pollution in residential areas connected to the exceeding of the annual mean values specified as follows: - 3 nitrogen oxides from 0.04 mg/m ) and – fine dust particles particles (FDP10) from 0.04 mg/m3. The rest of the pollutants are found in low concentration also at the road axis. From the point of view of community services and hygiene, the project takes into consideration the requirements for health safety of the population. The specified route for the construction of the motorway and the area around it do not provide for a possible combined effect of other factors along with these implied by the specific features of the site (noise, dust pollution). The Trakia Motorway site from КМ 210+100 to КМ 325+800 can be accomplished without any threat to the health of the workers or the population of the towns/villages nearby in long-term aspect. This is due to the good and up-to-date technical and technological parameters of Lots 2, 3 and 4 of the motorway, and limitation of noise levels, dust and toxic and chemical emissions within safe limits. Provided that all planned measures for protection of the construction activities and operation are observed, a low level of possible health- environmental risk is expected.

V. Description of the measures for prevention, abatement or, where possible, termination of significant harmful environmental impact. Plan for implementation of these measures  Ambient air The measures for the reduction of negative after-effects are directly connected to the expected impact on the ambient air with its characteristics – type, scope, duration and reversibility, as well as the level of pollution.

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Measures taken during construction During implementation of construction works, the ambient air along the route and the sites for reconstruction of communications and facilities of other establishments (attending infrastructure) will be polluted by dust and exhaust gases from the internal combustion engines (ICE) of the construction machinery and equipment, and of the freight vehicles performing the earthworks, the modeling of the road bottoming, the backfilling, loading and unloading of loose construction materials, earth masses and construction waste. The sites used for temporary storage of loose material and construction waste will be the source of uncontrolled emissions in dry and windy weather. The measures to be taken in order to reduce the negative impact on the environment are as follows: The grounds for temporary storage of loose building materials and construction waste (from the road foundations) should be moistened in dry and windy weather to reduce uncontrolled emissions of dust; After completion of construction works in a particular section, the sites for temporary storage of inert materials and construction waste should be duly cleaned, and the waste transported to the respective construction waste disposal site; Road construction machinery and vehicles with faulty ICEs should not be operated; Overloading of vehicles with loose materials (sand, earth masses, etc.) should not be allowed. The equipment for preparation and spreading of asphalt mixtures on site should not be heated or burnt after completion of works in order to reduce the emissions of organic substances contained in the road construction bitumens.

Measures during operation During operation, the air will be polluted mainly by products of fuel combustion from the vehicles’ ICEs and by uncontrolled emissions of dust along the traffic lanes. Harmful substances from the engines are subject to treatment at the annual technical check-ups of trucks and to the ongoing control of the Traffic Police authorities. The Road Traffic Act stipulates mandatory requirements to vehicles allowing their operation only with engines in good repair with regard to exhaust gases. The issue of uncontrolled emissions of traffic dust are caused by spillage of loose materials and earth masses when trucks are overloaded and to the transportation of powder – like substances without the necessary equipment. Reduction of that type of uncontrolled emissions can be achieved by the timely cleaning of the dirty areas on the road, carried out by the respective community services, as well as by not allowing overloading with loose or powder-like substances. The maintenance of the road easement boundaries and the grassing of the so called critical area on both sides of the road – with appropriately selected vegetation which can endure air pollution, and use of preparations typical of the autumn and winter period, will to a great extent reduce the pollution effect the ABLair layer around the motorway.

 Waters - during the construction of bridge facilities faulty equipment should not be allowed to operate in order to avoid pollution of rivers with oil products. - Projects should be implemented for the take-off of the surface water flows away from the motorway in the sections of reconstruction of drains and irrigation canals.

 Soils

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Storage of the removed humus layer as specified in the Prevention of Soil Pollution Act and its use for rehabilitation in compliance with the requirements of Regulation No 26 for rehabilitation of disturbed terrains. The site for temporary storage of construction materials and waste shall be cleared and reclaimed after the completion of construction works.

 Biodiversity The following additional measures resulting from suggestions made during public hearings of the initial EIA Report, have been included in the final EIA Report. 1. Drainage culverts designed as a green corridors to be used by reptiles and small mammals; 2. Provide for roadside fencing in the sections where new bridges are build, to prevent small mammals and herpetofauna species from going out on the traffic lane; 3. Take out suggested invasive tree species- American ash, Boxelder maple and amorpha from the dendrology list of the landscaping projects; 4. Construction activities in river beds and on the adjoining river banks within the near bridging areas should be designed and implemented as non-invasively as possible. No additional road or hydrotechnical facilities (props, dykes, support facilities on the bottom and the banks, spillway chutes etc.) should be installed apart from these related to constructive safety; 5. River crossing by construction and transportation machinery should not be allowed unless within the technological requirements of the construction works; 6. Disposal of inert materials in river beds, washing of transport and construction machinery in rivers and canals should not be allowed, so as to prevent pollution of rivers and damaging of the river bottom habitats.; 7. During construction of the motorway in the areas of the river bridging, the shrubs along the river banks should not be cut down so as to mitigate and fragment the habitats and to protect rivers as the only biocorridors for the passage of some mammals; 8. Maximum conservation of tree vegetation in the immediate proximity of the motorway route; 9. Provide safety fencing (including against hares), for all sensitive zones affected by the motorway route in order to prevent mammals going out on the traffic lanes; 10. Do not allow the use of the territory for temporary disposal of earth masses, construction materials and waste, except on specially designated sites; 11. Do not allow uncontrolled disposal of domestic waste, thus leaving free access for birds and animals The waste can also cause pollution of soils and deterioration of neighbouring habitats of flora and fauna; 12. Mark correctly the approach routes to the construction sites so as to prevent further destruction of vegetation and disruption of adjacent land.; 13. Build smooth-surface vertical fine-meshed net with outward-bent upper edge stretching closely to the steel motorway fencing, so as to prevent amphibians and reptiles going out on the road lane, thus minimizing the impact when constructing facilities on irrigation canals and when building new bridges. These sections of the route should be grassed and planted with shrubs in order to resemble, to the extent possible, the natural migration environment of the species.;

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14. Timely clearing of materials brought by the river flow in the regions of new bridge construction on the rivers Tundzha, Mochuritsa and Marash, in order to prevent silting up of rivers and interruption of migration routes of fish passages; 15. Where possible, construction works should start before the breeding season of animals, which usually begins in April and ends in June, in order to avoid disturbing the habitats of breeding birds. The most appropriate time for commencement of construction activities is early spring (February), when birds and other animals have not yet occupied their breeding territories; 16. Limit as much as possible the presence of construction machinery on construction sections during the breeding season of animals. The peculiarities in bats’ biology, namely the fact that they are flying mammals, active mainly at night and using echolocation for their orientation, determine the specific nature of their vulnerability during the motorway operation. These peculiarities require the planning of special measures for the reduction of impact on their populations, mainly the interruption of migration and communication corridors and direct death caused by collision with vehicles. - To reduce the probability for collision of bats when flying over the route, the creation of guiding strips of high trees toward the built tunnels, underpasses and overpasses should be planned. These tree strips (poplars recommended) shall follow the road access points to the facilities in two rows, for at least 100 m on both sides of the access point. It has been established that in open cultivable agricultural territories every tree group functions as an attraction point for bats. The linear positioning of the trees is a natural landscape element, defining to a great extent the direction of the 24-hour migrations. Due to that fact we suggest the creation of linear strips of high-tree vegetation at the access points of the following agricultural underpasses and overpasses: Overpass at km 278+730 of an agricultural road Overpass at km 288+480 of an agricultural road Overpass at km 294+980 of an agricultural road Overpass at km 297+960 of an agricultural road Overpass at km 304+360 of an agricultural road Overpass at km 308+397 of an agricultural road Overpass at rkm317+032 of an agricultural road Overpass at rkm320+220 of an agricultural road Underpass at km 279+875 of an agricultural road Underpass at km 291+980 of an agricultural road Underpass at km 302+100 of an agricultural road Underpass at km 302+400 of an agricultural road Underpass at km 304+980 of an agricultural road Underpass at km 311+060 of an agricultural road Underpass at km 313+700 of an agricultural road Underpass at km 318+150 of an agricultural road Underpass at km 318+510 of an agricultural road Underpass at km 322+320 of an agricultural road

In our opinion, the planting of linear strips of tree vegetation at the abovementioned 18 facilities of the motorway along with the construction of wide bridges over the rivers will provide for the unhindered movement of bats thus considerably decreasing the effect of fragmentation of their habitats.

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- It is necessary to preserve or restore the riparian trees vegetation near the bridges planned for construction, where particular attention should be paid to the so called “small marshy rivers”, where often no such vegetation is found. At the places where the motorway crosses main migratory routes of bats, guiding corridors will be planned of high-tree vegetation for the bats to fly unobstructed. Most often these places are the natural river valleys, through which bridges will be definitely built. - The installation of motorway lights fixtures and the strong lights from roadside sites and billboards will lead to greater concentration of insects, especially during the summer, which is a precondition for increased activity of bats as they feed on insects. The proximity to the main traffic on the motorway can increase the risk of collision with vehicles and direct death of bat specimen. To lower the risk, it is necessary to place light fixtures at least 5 meters away from the shoulder at a recommended height of at least 10m. Whenever it is necessary to install lights over the road lanes (e.g. near road junctions) the height should be at least 12 m. The illuminated advertising billboards shall be installed at a distance of at least 10 m away from the shoulder; - Conduct awareness campaign among the participants in the construction in order to protect biodiversity; - Due to lack of necessary information on the impact of highways on biodiversity and, in particular, on Protected areas – provide for the elaboration of a Monitoring program for the impact of the motorway on wildlife - ichthyofauna, herpetofauna, birds, mammals and the possible invasion of anthropophites during operation.

 Waste - The contractor implementing the construction works should forward all generated dangerous waste to individuals or legal entities – holders of permit allowing them to perform waste management related activities, including the transport, temporary storage, utilization and/or disposal of waste, pursuant to Article 37 of the WMA, or holders of registration document under Article12 of the WMA, or a Complex permit under IPPC Directive (Integrated Pollution Prevention and Control Directive) on the grounds of a written contract; - The transportation route for the waste generated during construction and the operation of the motorway should be agreed with the municipal mayor and mayors of the settlements, through the administrative territory of which the motorway passes, pursuant to Article 18, para. 2 of the Waste Management Act; - In the case of oils spill or other pollutants, it is necessary to immediately remove the contaminated earth masses and transport them to a landfill designated for this type of waste; - Waste generated during the construction of the route and the reconstruction of the facilities accompanying the motorway, should be collected separately and stored on temporary sites with thickened insulation surface until transported for further treatment;

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- Mineral-based non-chlorinated hydraulic oils and mineral-based non-chlorinated engine, lubricating and gear oils based should be collected in a manner allowing their regeneration - in chemical-resistant sealed containers, to avoid spills or leakage, where these containers should be marked and stored indoors; - Use of roadworthy vehicles for the transportation of dangerous and industrial waste within the construction site and outside of it; - The road maintenance authority should collect separately the discarded solid waste; - Prepare a Waste Management Programme in accordance with Article 29, para. 1, item 3b and c of the Waste Management Act.

 Noise The Trakia motorway route in the particular section has been designed so that noise produced on it affects the minimum number of settlement. During construction - Prepare a plan for organization of service traffic with view of limiting frequency of passage through residential areas, by using existing local main agricultural roads, and coordination of this plan with the respective municipalities and town halls; - Previde for and use of temporary noise-insulating barriers between the residential areas of the villages Drazhevo and Zheleznik and the construction sites of the relevant road sections and the sites for reconstruction of the existing infrastructure of other establishments; - Observe the speed limit for trucks passing through residential areas. - Construction activities on the road and reconstruction of engineering infrastructure supporting the motorway, should take place during the day – from 07.00 am to 19.00 pm.

During operation - After the commissioning of the motorway - carry out control measurements of road noise levels reaching the borders of residential areas on the side of the road of the villages of Chokoba and Hadzhidimitrovo. In case measurement result exceed the maximum permissible limits – planting of a vegetation band of suitable width and composition so as to abate the impact of noise. - Install screen-walls alongside the carriageway of the motorway section up to the town of Kermen between the middle and the end hill, opposite to the adjacent residential buildings (the road is column supported). We recommend noise- absobing screen-rails from the side of the traffic; - Install screen-walls alongside the motorway carriageway in the sections up to the villages Drazhevo and Zheleznik; - Carry out control measurements of the level of traffic noise reaching the upper floors’ façade of the school in the village of Drazhevo. In case measurements exceed the maximum permissible limits – measures to increase the sound- insulation capacity of the façade walls by replacing old door and window joinery with new one, having the suitable sound reduction index. Thus the observation of the noise hygiene limits determined for classrooms shall be ensured. The positioning, the type and the design acoustic parameters of the screens (walls, rails) are subject to independent design work.

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 Health protection aspects Preventive measures with view of construction workers health protection The measures and recommendations regarding health protection are divided as follows: Technological – Strict observation of the technology of the different building stages of constructing the motorway. Technical – work with well-maintained construction machinery and trucks. Use of high quality fuels, emission control and periodical technical check-ups to ensure the good working repair of the different vehicles. Use of various kinds of fuel and lubricating materials in accordance with the prescribed technical maintenance activities. Medical – good cooperation with the responsible occupational medicine service: preliminary medical examination (professional selection) in accordance with the requirements through strict non-admission of persons unfit to the nature of work; regular medical examinations within the instructed timelines, exhaustiveness, and specialist competence; organization of rational work-rest schedule; organization of adequate daily meal schedule. Planned control of the use of personal protection equipment – masks, protective goggles, gloves, protective headphones, shoes, etc. The recommendations on the reduction of dust emissions (by additional anti-dust facilities, works organization, etc.) shall be fulfilled before the start of the motorway construction.) Preventive measures with view of population health protection Main risk factors for the health of population in the vicinity of the motorway route are the noise and dust factors. Health monitoring of the population should be planned for those living close to the motorway route and it can be focused onto the following areas of monitoring, taking into consideration factors related to the construction period and such relevant during operation: - during the construction period risk can be minimized by strictly defined itineraries for the traffic of construction machinery, only day-time operation, switching the equipment engines off when not in use, etc. The limit of 60 dB noise level should be observed. - carrying out of real noise measuring during motorway operation in order to provide for the undertaking of the necessary health protection measures and for the installation noise protection facilities, where possible. - maintain the traffic lane clean and in good repair so as to keep concentration levels of dust and particular matter low. - perform regular analysis of determining factors of the environment and with view of their quality and quantity description – investigate any possible causality relationship. - During the construction period and during the future operation of the motorway, the construction companies and the after that - the maintenance organizations, should develop emergency plans, mostly in case of transport accidents and spills of highly toxic substances, etc.

Plan for the implementation of measures under Article 96, Para. 1, Item. 6 of the Environment Protection Act (EPA)

No MEASURES Period/stage of RESULT implementation Ambient air 1. Control of the roadworthiness of freight During the entire Reduction of overall

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vehicles and construction equipment period of route harmful emissions construction and the reconstruction of the attending infrastructure 2. Control on the overloading of vehicles During the entire Reduction of the with loose materials. period of route additional dust construction and discharge the reconstruction of the attending infrastructure 3. Control on the temporary storage sites of During the entire Reduction of the loose materials and construction waste period of route additional dust which should be wetted in dry and construction and discharge windy weather to reduce uncontrolled the reconstruction emissions of dust. of the attending infrastructure 4. Clearing of the temporary storage site of Immediately after Reduction of the inert materials and construction waste. completion of additional dust construction discharge works 5. Control of the heating, preparation and After spreading Reduction of the spreading of asphalt pavement completion additional hydrocarbon load 6. Cleanness control of the traffic lane Ongoing Reduction of the additional dust discharge 7. Maintenance of the easement boundaries After completion Reduction of the impact and grassing of the critical zone of construction of the critical zone activities around the road axis Waters 1. When new bridge facilities are During Prevention of riverbed constructed, the activities shall be construction disruption restricted to the water sites where piers will be installed. 2. Operation of faulty equipment shall not During Water protection be allowed in order to avoid leakage of construction fuel and lubricats causing water pollution. 3. Implementation of all projects for take- During Water protection off of surface waters from the motorway construction away from the drains and irrigation canals reconstruction sites Soils 1. Storage of removed humus layer under During Reclamation of appropriate conditions and its use for construction embankments and rehabilitation. bevels along the new route 2. The temporary site for storage of During Rehabilitation of

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construction materials and waste should construction impaired terrains be cleared and reclaimed appropriately after the completion of construction works 3. Timely strengthening and rehabilitation During Prevention of erosion of road embankments in order to avoid construction processes. erosion. Biodiversity 1. Design draining culverts in a manner Currently Unhindered passage of allowing their use as a green corridor for designed animal species reptiles and small mammals 2. Provide for roadside fencing in the Currently Prevention of possible sections where new bridges are build, to designed accidents with animal prevent small mammals and species herpetofauna species from going out on the traffic lane 3. Take out suggested invasive tree Currently Conservation of local species- American ash, Boxelder maple designed biodiversity and amorpha from the dendrology list of the landscaping projects; 4. Construction activities in river beds and During Prevention of river on the adjoining river banks within the construction pollution and near bridging areas should be designed disturbance of river and implemented as non-invasively as bottom habitats. possible. No additional road or hydrotechnical facilities (props, dykes, support facilities on the bottom and the banks, spillway chutes etc.) should be installed apart from thise related to constructive safety. 5. River crossing by construction and During Prevention of river transportation machinery should not be construction pollution and allowed unless within the technological disturbance of river requirements of the construction works. bottom habitats 6. Disposal of inert materials in river beds, During Prevention of river washing of transport and construction construction pollution and machinery in rivers and canals should disturbance of river not not be allowed, so as to prevent bottom habitats pollution of rivers and damaging of the river bottom habitats. 7. During construction of the motorway in During Prevention of the areas of the river bridging, the construction fragmentation of shrubs along the river banks should not habitats and protection be cut down so as to mitigate and of rivers as being only fragment the habitats and to protect bio-corridors for the rivers as the only biocorridors for the passage of hazel passage of hazel dormouse, harvest dormouse, harvest mouse and Etruscan pygmy shrew in mouse and Etruscan “Tundzha 1” PA and the “Mochuritsa pygmy shrew in

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River” PA Tundzha 1 PA and Mochuritsa river PA 8. Maximum conservation of tree During Conservation of vegetation in the immediate proximity construction habitats of animal of the motorway route. species 9. Provide safety fencing (including During Prevention of catching against hares), for all sensitive zones construction and destruction of affected by the motorway route in order animal species to prevent mammals going out on the traffic lanes. 10. Do not allow the use of the territory for During Conservation of temporary disposal of earth masses, construction vegetation in adjacent construction materials and waste, except areas on specially designated sites. 11. Do not allow uncontrolled disposal of During Prevention of soil and domestic waste, thus leaving free access construction vegetation pollution for birds and animals 12. Mark correctly the approach routes to During Conservation of the construction sites so as to prevent construction vegetation in adjacent further destruction of vegetation and areas disruption of adjacent land. 13. Build smooth-surface vertical fine- During Reduction impact on meshed net with outward-bent upper construction amphibians and reptiles edge stretching closely to the steel motorway fencing, so as to prevent amphibians and reptiles going out on the road lane, thus minimizing the impact when constructing facilities on irrigation canals and when building new bridges. These sections of the route should be grassed and planted with shrubs in order to resemble, to the extent possible, the natural migration environment of the species. 14. Designate and mark the sites for During Prevent disruption of temporary disposal of excavation construction neihgbouring territories construction materials, after due approval and coordination with respective municipality mayors 15. Strictly adhere to fire safety rules. During Conservation of construction neighbouring areas 16. Timely clearing of materials brought by During operation Prevent silting up of the river flow in the regions of new rivers and interruption bridge construction on the rivers of migration routes of Tundzha, Mochuritsa and Marash, in fish order to prevent silting up of rivers and interruption of migration routes of fish passages. 17. Where possible, construction works During Prevent disruption of

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should start before the breeding season construction habitats of animals, which usually begins in April and ends in June, in order to avoid disturbing the habitats of breeding birds. The most appropriate time for commencement of construction activities is early spring (February), when birds and other animals have not yet occupied their breeding territories. 18. Limit as much as possible the presence During Limit the noise impact of construction machinery on construction and the agigation of construction sections during the animals in the breeding season of animals. neighbouring territories 19. Plant linear strips of high trees as During Limit the probability of approach route to the agricultural construction bats being hit by cars overpasses and underpasses: when flying over the motorway Overpass at km 278+730 of agr.road Overpass at km 288+480 of agr.road Overpass at km 294+980 of agr.road Overpass at km 297+960 of agr.road Overpass at km 304+360 of agr.road Overpass at km 308+397 of agr.road Overpass at km 317+032 of agr.road Overpass at km 320+220 of agr.road Underpass at km 279+875 of agr.road Underpass at km 291+980 of agr.road Underpass at km 302+100 of agr.road Underpass at km 302+400 of agr.road Underpass at km 304+980 of agr.road Underpass at km 311+060 of agr.road Underpass at km 313+700 of agr.road Underpass at km 318+150 of agr.road Underpass at km 318+510 of agr.road Underpass at km 322+320 of agr.road

20. Position the lights of roadside objects During operation Reduce probability of and roadside advertising billboards at car accidents and least five meters away from the roadway directl mortality shoulder, with recommended height of the installation – at least 10 meters 21. Conduct awareness campaign among the During Prevent accidents with participants in the construction in order construction animal species to protect biodiversity 22. Due to lack of necessary information on During operation Account for the the impact of highways on biodiversity motorway impact on and, in particular, on agricultural lands – flora and fauna provide for the elaboration of a Monitoring program for the impact of

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the motorway on wildlife - ichthyofauna, herpetofauna, birds, mammals and the possible invasion of anthropophites during operation. Waste 1. The contractor implementing the During Waste management in construction works should forward all construction of the conformity with the generated dangerous waste to road and the WMA individuals or legal entities – holders of reconstruction of permit allowing them to perform waste the supporting management related activities, including facilities the transport, temporary storage, utilization and/or disposal of waste, pursuant to Article 37 of the WMA, or holders of registration document under Article12 of the WMA, or a Complex permit on the grounds of a written contract 2. The transportation route for the waste During Waste management in generated during construction and the construction and conformity with the operation of the motorway should be during operation WMA agreed with the municipal mayor and mayors of the settlements, through the administrative territory of which the motorway passes, pursuant to Article 18, para. 2 of the Waste Management Act. 3. In the case of oils spill or other During Prevent pollution of pollutants, it is necessary to immediately construction and soils and water remove the contaminated earth masses during operation and transport them to a landfill designated for this type of waste 4. Collect generated waste separately and During Prevent waste stored it on temporary sites with construction of the scattering and pollution thickened insulation surface until road and the of soils and water transported for subsequent treatment reconstruction of the supporting facilities 5. Mineral-based non-chlorinated During Waste management in hydraulic oils and mineral-based non- construction of the conformity with the chlorinated engine, lubricating and gear road and the WMA oils based should be collected in a reconstruction of manner allowing their regeneration - in the supporting chemical-resistant sealed containers, to facilities avoid spills or leakage, where these containers should be marked and stored indoors 6. Use of roadworthy vehicles for the During Prevent spills and transportation of dangerous and construction of the pollution of soils and industrial waste within the construction road and the water. Waste site and outside of it; reconstruction of management in

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the supporting conformity with the facilities WMA 7. Separate solid waste collection During operation Possible recycling performed by the road maintenance authority 8. Prepare a Waste management Before Waste management in programme in accordance with Article commencement of conformity with the 29, para. 1, item 3b and c of the Waste construction WMA Management Act. works

Noise 1. Prepare a plan for organization of During Limit the noise impact service traffic with view of limiting construction of the on the residential frequency of passage through residential road and the territories adjacent to areas, by using existing local main reconstruction of the motorway agricultural roads, and coordination of existing this plan with the respective infrastructure municipalities and town halls;

2. Provide for and use of temporary noise- During Limit the noise impact insulating barriers between the construction on the territory of the residential areas of the villages villages Drazhevo and. Drazhevo and Zheleznik and the Zheleznik construction sites of the relevant road sections and the sites for reconstruction of the existing infrastructure of other establishments 3. Construction activities on the road and During Limit the noise impact reconstruction of engineering construction on the territory of infrastructure supporting the motorway, adjacent residential should take place during the day – from areas 07.00 am to 19.00 pm 4. Observe the speed limit for trucks During Limit the noise impact passing through residential areas. construction on the territory of residential areas adjacent to the transport routes servicing the construction 5. After the commissioning of the During operation In case measurement motorway - carry out control result exceed the measurements of road noise levels maximum permissible reaching the borders of residential areas limits – planting of a on the side of the road of the villages of vegetation band of Chokoba and Hadzhidimitrovo suitable width and composition so as to abate the impact of noise 6. Install screen-walls alongside the During operation Protect residential

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carriageway of the motorway section up buildings from to the town of Kermen between the motorway traffic noise middle and the end hill, opposite to the adjacent residential buildings (the road is column supported). We recommend noise-absobing screen-rail from the side of the traffic;

7. Install screen-walls alongside the During operation Protect residential motorway carriageway in the sections territories adjacent to up to the villages Drazhevo and the motorway Zheleznik;

8. Carry out control measurements of the During operation In case measurements level of traffic noise reaching the upper exceed the maximum floors’ façade of the school in the permissible limits – village of Drazhevo. measures to increase the sound-insulation capacity of the façade walls by replacing old door and window joinery with new one, having the suitable sound reduction index. Cultural heritage 1. Specialized archaeological research for Before cnstruction Registration of identitfication of possible archaeological endangered sites along Trakia Motorway. archeological sites

2. Carry out survey drillings at all Before cnstruction Establish the degree of endangered objects endangerment and the value of the cultural depositions 3. Conduct rescue excavations within the Before cnstruction Study of the easement borders and the construction archeological structures sites, wherein reconstruction is carried and cultural layers out of the communications of other establishments (ancillary motorway infrastructure).

4. Full archaeological survey of 7 Before cnstruction Complete removal of archaeological sites the archeological substance 5. Interdepartmental committees appointed Before cnstruction Assess the efficiency of by the Director of the National Institute conservation measures for Protection of Cultural Monuments 6. Monitoring during construction works During Preserve undiscovered on object 11 of Lot 2. construction archeological structures

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7. Regular surveys of construction works During Protect unknown along the entire motorway route and the construction archeological sites construction sites whereon reconstruction is carried out of the communications with other establishments (ancillary motorway infrastructure).

Health protection aspects Preventive measures with view of construction workers health protection

1. Use of personal protective equipment Ongoing Reduce workplace health risks 2. Use high quality fuels, emission control, Ongoing Reduce workplace roadworthy vehicles health risks

3. Provide workers with seasonal working Ongoing Reduce workplace outfits health risks

4. Technical - use of new, highly efficient Ongoing Reduce workplace and and reliable road construction machinery surrounding residential area health risks 5. Medical - good cooperation with the At regular Reduce workplace responsible occupational medicine intervals health risks service: preliminary medical examination (professional selection) in accordance with the requirements through strict non-admission of persons unfit to the nature of work; regular medical examinations within the instructed timelines, exhaustiveness, and specialist competence; organization of rational work-rest schedule; organization of adequate daily meal schedule

Preventive measures with view of population health protection 6. Introduce better working organization – During Reduce public health strictly defined routes for the road construction of all risks with view of noise construction machinery, limiting the road sections and and ambient air number of idle routes, day-time work especially when pollution. only, etc, especially near residential working near areas located close to the road. settlements

7. Two analysis of ambient air quality, one Before Assess public health

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before the start of road construction commencement risks with view of activities (existing situation), and second and after ambient air pollution - upon commissioning of the motorway - completion of and traffic-caused with priority for the content of nitric and construction pollution, for the two sulfuric oxides, common dust and fine works settlements. dust particles in close proximity to residential areas of adjacent settlements

8. Real measurements of traffic flow and After Assess the need to noise pollution after commissioning of commissioning introduce additional the motorway, performed near every measures so as to settlement along the motorway route. improve the noise insulation of residential buildings around the motorway through efficient methods such as noise protection walls, embankments, afforestation, replacement of existing windows joinery with better soundproofing one.

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VІ. Conclusion This Updated Report for the Environmental Impact Assessment of investment project of National “Road Infrastructure” Agency for the construction of Trakia Motorway section „Stara Zagora - Karnobat” from km 210+100 to km 325+280 (Lot 2, Lot 3 and Lot 4), including upgrade of existing communications and supporting engineering infrastructure, contains a detailed overview of the submitted investment project and its impact on environment and on human health. The report takes into consideration EIA decisions already available – requirements and terms regarding the discrete motorway sections in conformity with the legislation active at the time of their preparation. The present assessment confirms the variants recommended by the experts in the previous EIA Reports, and those elaborated during the next phase – technical project 2001 – 2003: - For Lot 2 – section Stara Zagora – Nova Zagora– from km 210+100 to km 241+900 – RED VARIANT. - За Lot 3 – Nova Zagora– Yambol – from km 241+900 to km 277+597 (≡ km 276+200 of Lot 4): . from km 241+900 to km 248+922– GREEN VARIANT; . from km 248+922 (≡ km 248+800) to km 276+516 – RED VARIANT; . from km 276+516 to km 277+597 (≡ km 276+200 на Lot 4) – GREEN VARIANT За Lot 4 – Yambol – Karnobat – from km 276+200 (≡ km 277+597 от Lot 3) to km 325+280:  from km 277+597 до km 285+498 – green variant  from km 285+498 до km 300+153 – blue variant  from km 300+153 до km 325+280 – red variant This Updated Report has been compiled in line with the requirements of the Enviromnment Protection Act, prom. State Gazette 91/25.09.2002, ……… amend. and suppl. 47/2009 Regulation on the conditions and the procedure for conduct of EIA (State Gazette 25/2003, amend. and suppl. State Gazette 3/2006) and other environment related Acts, Regulations, Rules and Normative documents. All conclusions and consultations with competent authorities on environmental issues, with municipal administrations and the stakeholding parties - legal and natural entities, have been taken into consideration when compiling this Report. Inspection of the project road route of Lot 2, Lot 3 and Lot 4 has been carried out. Analisys was made of the expected environmental and human health impact resulting from the realization of the investment project. Risk factors have been identified. Expert findings have been exemplified with photographs and relevant evidential material. On the grounds of this analysis measures have been proposed for the prevention and the abatement of negative environmental impacts, together with a plan for implementation of these measures. On the grounds of the assessment and the analysis made, and in conformity with the environmental legislation, the authors of this Updated EIA Report hereby propose to the esteemed Supreme Expert Ecological Council to allow the realization of the investment project for the construction of Trakia Motorway - section „Stara Zagora - Karnobat”, of route according to 2001 – 2003 technical project, from km 210+100 to km 325+280, including the upgrade of communications and the engineering infrastructure supporting the motorway.

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List of Attachments:

Attachment No. 1 Letter No. 05-00-78/09.07.09 of National “Road Infrastructure” Agency Attachment No. 2 Site route drawing of Lot 2 – Stara Zagora – Nova Zagora– from km 210+100 to km 241+900 Attachment No. 3 Site route drawing of Lot 3 – Nova Zagora– Yambol from km 241+900 to km 277+597 Attachment No. 4 Site route drawing of Lot 4 – Yambol – Karnobat – from km 276+200 to km 325+280

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