EKOTAN EOOD [email protected] mobile: 0889 855 869 mobile: 0889 895 805

Chief University Assistant D. Zahariev, Chief University Assistant N. Kodzabashev, Assistant Professor T. Michev, Prof. M. Stoyneva

ASSESMENT OF COMPATIBILITY OF INVESTMENT PROPOSAL on gravel and sand extraction from alluvial sediments in the bed of the River Kama Section (510.5 km. – 508.0 km.) In the area of Pirgovo Village, Ivanovo Munucipality With Natura 2000 sites BGSPA0002024 Mechka fisheries ROSPA0108 Vedea Dunare ROSCI0088 Gura Vedei-Saica-Slobozia

September 2012 Ecotan EOOD

1 CONTENTS

1. ANNOTATION OF THE INVESTMENT PROPOSAL ERROR! BOOKMARK NOT DEFINED.

1.1. Basic technical and technological characteristics of the investment site Error! Bookmark not defined.

1.2. Used raw materials, natural raw materials and resources and energy sources Error! Bookmark not defined.

1.3. Necessity of permits, linked with the investment proposal Error! Bookmark not defined.

1.4. Type and quantity of the expected wastes and emissions during the realization of the investment proposal Error! Bookmark not defined.

1.5. Characteristics of water sources and sources for water use for the site Error! Bookmark not defined.

1.6. Quantity and composition of waste water by flows – industrial, domestic and rain water. Treatment facilities Error! Bookmark not defined.

1.7. Closeness to protected territories and protected zones in Error! Bookmark not defined.

2. OTHER PLANS, PROGRAMS AND PROJECTS/INVESTMENT PROPOSALS, EXISTING AND/OR IN PROCESS OF DEVELOPMENT OR APPROVAL, WHICH IN COMBINATION WITH THE INVESTMENT PROPOSAL CAN HAVE UNFAVORABLE IMPACT ON THE PROTECTED ZONES IN THE REGION ERROR! BOOKMARK NOT DEFINED.

3. DESCRIPTION OF THE ELEMENTS OF IP, WHICH INDEPENDENTLY OR IN COMBINATION WITH OTHER PLANS, PROGRAMS AND PROJECTS/INVESTMENT PROPOSALS COULD HAVE SIGNIFICANT IMPACT ON THE REVIEWED PROTECTED ZONES OR THEIR ELEMENTS 23

4. DESCRIPTION OF THE PROTECTED ZONES, HABITATS, SPECIES AND OBJECTIVES OF MANAGEMENT ON NATIONAL AND INTERNATIONAL LEVEL AND THEIR REFLECTION DURING THE PREPARATION OF THE PLAN FOR THE INVESTMENT PROPOSAL 23

4.1. Protected zone BGSPA0002024 Fisheries Mechka 23 4.1.1. Description 24 4.1.2. Subject of conservation 25

4.2. Protected zone ROSPA0108 Vedea Dunare 26 4.2.1. Description 26 4.2.2.Subject of conservation 27

4.3. Protected zone ROSCI0088 Gura Vedei -Saica-Slobozia 27 4.3.1. The conservation aims of the protected zone are the following: 28 4.3.2. Subject of conservation 28

2 5. DESCRIPTION AND ANALYSIS OF THE LIKELIHOOD AND RATE OF IMPACT OF THE INVESTMENT PROPOSAL ON THE SUBJECT OF CONSERVATION OF THE REVIEWED PROTECTED ZONES 29

5.1. Protected zone BGSPA0002024 Fisheries Mechka 29 5.1.1. On the types of habitats 29 5.1.2. On the species, subject to protection 29 5.1.3. Description and analysis of the impact of the investment proposal on the wholeness of the protected zone, considering its structure, functions and nature protection objectives (loss of habitats, fragmentation, disturbance of species, disturbance of the species composition , chemical, hydrological and geological changes and etc.), as well as during the realisation and explo itation of IP 45

5.2. Protected zone ROSPA0108 Vedea Dunare 46 5.2.1. On the types of natural habitats 46 5.2.2. On the species, subject to protection 46 5.2.3. Description and analysis of the impact of the investment proposal on the wholeness of the protected zone, considering its structure, functions and nature conservation aims (loss of habitats, fragmentation, disturbance of species, disturbance of the species composition, chemical, hydrological and geological changes and etc.), as well as during the reali sation and exploitation of IP 55

5.3. Protected zone ROSCI0088 Gura Vedei -Saica-Slobozia 56 5.3.1. On the types of natural habit ats 56 5.3.2. On the species, subject to protection 57 5.3.3. Description and analysis of the impact of the investment proposal on t he wholeness of the protected zone, considering its structure, functions and nature conservation aims (loss of habitats, fragmentation, disturbance of species, disturbance of the species composition, chemical, hydrological and geological changes and etc.), as well as during the realisation and exploitation of IP 60 5.3.3.2. Functions and nature protection aims 61

6. MITIGATING MEASURES 63

6.1. Protected zone BGSPA000002024 Fisheries Mechka 63 6.1.1. During design 63 6.1.2. During construction 63 6.1.3. During exploitation 63

6.2. Protected zone ROSPA0108 Vedea Dunare 64

6.3. Protected zone ROSCI0088 Gura Vedei-Saica-Slobozia 65

7. ALTERNATIVE SOLUTIONS AND ASSESSMENT OF THEIR IMPACT 65

8. MAP MATERIAL 67

9. CONCLUSION ON THE TYPE AND RATE OF IMPACT ON BOTH PROTECTED ZONES

9.1. Characteristics of the investment proposal 67

9.2. Characteristics of other plans, programs and projects/investment proposals , existing or in process of development or approval, which in combination with the assessed investment proposal can have unfavorable impact on the reviewed protected zones 68

9.3. Characteristics of the protected zones 68

3 9.4. Area of impact 69 9.4.1. Protected zone BGSPA0002024 Fisheries Mechka 69 9.4.2. Protected zone ROSPA0108 Vedea Dunare 69 9.4.3. Protected zone ROSCI0088 Gura Vedei -Saica-Slobozia 69

9.5. Rate of impact on the types of natural habitats 69 9.5.1. Protected zone BGSPA0002024 Fisheries Mechka 69 9.5.2. Protected zone ROSPA0108 Vedea Dunare 69 9.5.3. Protected zone ROSCI0088 Gura Vedei -Saica-Slobozia 69

9.6. Rate of impact on the habitats and populations of species, subject to conservation 70 9.6.1. Protected zone BGSPA0002024 Fisheries Mechka 70 9.6.2. Protected zone ROSPA0108 Vedea Dunare 70 9.6.3. Protected zone ROSCI0088 Gura Vedei -Saica-Slobozia 70

9.7. Impacts on the nature conservation aims and on the wholeness of the protected zones 70

9.8. Likely mitigating and/or recuperation measures 70 9.8.1. Protected zone BGSPA0002024 Fisheries Mechka 70 9.8.2. Protected zone ROSPA0108 Vedea Dunare 70 9.8.3. Protected zone ROSCI0088 Gura Vedei -Saica-Slobozia 71

9.9. Availability of alternative solutions 71

9.10. Availability of reasons of primary public interest in the realization of the investment proposal or considerations in connection with human health , public security or positive impacts on the environment. 71

9.11. Proposed compensation measures 71

9.12. General conclusion 71 9.12.1. Protected zone BGSPA0002024 Fisheries Mechka 71 9.12.2. Protected zone ROSPA0108 Vedea Dunare 72 9.12.3. Protected zone ROSCI0088 Gura Vedei -Saica-Slobozia 72

10. INFORMATION ON THE USED METHODS OF RESEARCH, METHODS FOR PROGNOSTICATION AND ASSESMENT OF THE IMPACT AND SOURCES OF INFORMATION 72

11. METHODOLOGY FOR QUALITY ASSESSMENT OF THE NEGATIVE IMPACT ON THE SPECIES OF BIRDS-SUBJECT TO PROTECTION 73

12. SOURCES 76

13. ANNEXES 80

13.1. Scheme of island Каmа with location of IP 80

13.2. REFERENCE FOR PPP/IP ALONG RIVER DANUBE, submitted by RIEW-Ruse with decision №343/1.08.2012 (in bege color are marked the sites close to the region of t he reviewed IP) 81

13.3. Documents of Prof. Dr. Маya Stoyneva 85

4 This Investment Proposal was drawn up on the grounds of Article 31, para 4 of the Biological Diversity Act and Ordinance on the conditions and procedures for assessing the compatibility of plans, programs, projects and investment proposals with the objects and purposes of the conservation of protected areas (State Gazette issue 73/2007).

The guidelines contained in the letters of the Ministry of Environment and Waters with ref. No OVOSU 8862 and OVOSU 8863 dated 30.06.2011, and letter ref. No OVOSU - 8862, letter ref. No 8863/02.12.2011, the opinion expressed in letter ref. No OVOSU-8862/11.06.2012, and part of the recommendations made during the workshop in July 2012, presided by Deputy Minister Mrs. Evdokia Maneva were also taken into account.

In determining the cumulative effect of the realization of this investment proposal (IP) information provided by the Ministry, IAPPD and RIEW Rouse was used.

The following sources were used as scientific basis for the preparation of the current assessment:

Golemanski and others. (ed.). 2 011. Red Book of Bulgaria. Volume 2. Animals. IBER-BAS & MEW, , p. 383 Paspalev-Antonova, M. 1961b. Studying ornithology of the Bulgarian Danube bank. S. (dissertation candidate). Yankov, P. (ed.). 2007. Atlas of Breeding Birds in Bulgaria, Bulgarian Society for the Protection of Birds, Conservation serie s, book 10, p. 679 (in Bulgarian and English), p. 679 Lorenz-Liburnau, L., 1893. Ornithologische Bruchstucke aus dem Gebiete der Unteren Donau. - Orn. Jahrbuch 4: 12-23. Munteanu, D. 2005. Cartea rosie a vertebratelor din . Muzeul national de istor ie naturala “G. Antipa”, Bucresti, 260 pp, ISBN 973 -0-03943-7. Reiser, O. 1894. Materalien zu einer Ornis balcanica. II. Bulgarien. Wien. In Commission bei Carl Gerold's Sohn: 204 pp. Shurulinkov, P., I. Nikolov, D. Demerdzhiev, K. Bedev, H. Dinkov, G. Da skalova, S. Stoychev, I. Hristov & A. Ralev. 2008. On the actual breeding distribution and numbers of colonially nesting herons and cormorants in Bulgaria. - Orn. Mitteilungen 59 (11): 370—378 [PDF].

5 1. Summary of the proposal

The Investment Proposal is located on Bulgarian territory near the Romanian islands of Dinu and Kama between the 510.5 and 508.0 river kilometre. This compatibility assessment was drafted for a broader range - from km 512.0 to km 508.0.

1.1. General technical and technological characteristics of the investment site

Extraction of alluvium (sand and gravel) from the Danube River will be done by using floating multi-bucket dredger. Alluvium from the buckets will be transferred to a drying sieve and from there to self-propelled barges for transport to a wharf for unloading. Unloading on the wharf will be done by using grabbing jib crane with a 5 cc grabber on a longitudidinal e mbankment running parallel to the jib crane track. From the longitudinal embankment alluvium will be loaded by a front loader to road transport vehicles. The area for extraction will be divided during work into separate tracts for extraction sized 60x52 meters. Each tract will be marked with floating buoys anchored along the contour of the specified tract. The dredger will be positioned on the site of excavation works with the help of a self -propelled barge that will tow the dredge to the required locati on. This operation will take place twice a year: at the start of excavation works and at the end of the season in order to put away the dredge for the winter. The movement of the dredge within the specified tract will be controlled by a system of side and stern anchors located in the top left and right direction from the axis of the dredge. Movement is achieved by rolling anchor ropes on one side and releasing the anchor ropes on the other. Mining works in each individual tract will be done from east to wes t (upstream). Each tract will be mined in two layers, about 5 meters each. In order to observe the boundaries of the approved perimeters, the dredger will remove alluvium at an estimated distance from the boundaries ensuring a fill slope with an incline of 1:2.75, i.e. equal to the angle of slope stability of extracted alluvium in saturated condition. This naturally reduces the size of the developed area and further increased stability against coastal erosion. Depending on water levels, excavation works will take place in the lower or upper layer of the developed site.

6 Technology for alluvium extraction

The technology for extraction of alluvium from the Danube River is based on the use of floating multi bucket dredger type KS 250. It has no alternative i n the given conditions, the presence of 150 mm boulders. The dredger is equipped with endless multi bucket chain of buckets with capacity of 250 liters. The specific extraction process is carried out via scraping up of sediment material from the bottom of the river by means of scraping (250-liter) buckets. Alluvium extracted with scraping buckets will be dumped on the drying sieve of the dredger. Dry alluvium will be transferred to the self-propelled barges by a rubber belt conveyor.

Installed capacity: ● Diesel engine - 500 kW ● Generator - 620 kVA

Main engine power: ● Bucket chain operation - 2 x 90 kW ● drying sieve - 2 x 30 kW ● rubber belt conveyor -11 kW ● pulley chain of buckets - 2 x 15 kW ● maximum operating depth of the dredger for scrapi ng of alluvium is 12 m

Unloading of alluvial materials extracted by the buckets will be done directly on the drying sieve of the dredger. Drained water will be returned in the river and dried alluvial materials will be transferred to the self-propelled barges by a rubber belt conveyor. In the process of unloading of extracted ballast to the barge the solid phase remains at the bottom of the barge while water remains above. When the amount of useful material increases, the water level rises and reaches the holes in the barge walls from where excess water flows back into the river. There are drainage pipes at the bottom of the barge that drain the remaining water for maximum drying up of the alluvium. Drainage water will be pumped back into the river by pumps with maximum flow rate of 260 m3 / h.

 The barge is divided into two separate holds with freight volumes V 1 = 680 m3 and V2 = 627 m3 and a total carrying capacity of 1 000 t. Installed capacity is:

7  Diesel engine: 820 hp The vessels (dredger and barges) are equipped with fire alarm systems, drying kilns, sanitary installations (for process water and overboard water - water to wash the ship) and installations for the treatment of domestic and human waste waters.

Waste generated during operation will be levied on vessels and transported to the quay for further treatment.

The estimated dynamic reserves of ballast material in the outline of the approved area are nearly 6.534 million cubic meters, and quantities that can be extracted under the restrictive conditions are 5.355 million cubic meters.

The capacity of the extracted material will reach 600 000 cubic meters per year or 2 600 cubic meters per day if the work schedule includes 270 working days a year, 235 of which for dredging operations (9 months, 6 working days per week and 1 day a week for maintenance works ).

Transportation of extracted material

The transport corridor for transportati on of sand and gravel to the wharf site of the company is the Danube River. The site is located in the Eastern Industrial Zone of the town of Ruse and is a licensed and operating port for processing of general and bulk cargo . Transportation of raw material s will be done by using four special self -propelled barges for bulk material, each of them with a working load of 1 000 tonnes. Alluvium that cannot be dredged by the crane grabs is approximately 100 tons per barge. Each barge will make 1.5 runs per working day.

Unloading of alluvium on the wharf

Implementation of the investment plan will involve changing of th e existing infrastructure of the wharf site in the eastern industrial zone of the town of Ruse. Existing buildings on the wharf, owned by the company will be demolished and site for unloading of material and temporary storage for about 17 000 cubic meters of alluvium will be prepared.

8 Along the south wall will be the Administrative premises situated in caravans, including checkpoint, office, locker room with showers and toilets, dining rooms, kitchen ette, equipped with a system for chemical treatment of wa stewater for purifying municipal water and TP/1 x 650. The site will be equipped with a small treatment plant type ACO Clara 5 -10 with hydraulic load of 0.75 to 1.05 m3/day. Inflow and outflow of the plant will be gravity. Discharge after treatment will be done in the Danube, with the help of certified equipment parameters of the facility purifying water for first category water intake (the Danube is third category). The plan is to work in shifts, which require additional lighting for nighttime, a problem solved by erecting two projector mounting masts in the northern and southern ends of the site. In order to optimize the workflow and , in particular, the unloading of alluvium from the barges, one of the existing 5-ton jib cranes will be dismantled and a 15 -ton grapple crane will be erected, powered by electricity. According to the developed technological plan the grapple crane will unload the rubble directly from the tipper trucks. In rare cases, only in the absence of regular supply provided by tipper trucks, the grapple crane will unload the rubble on a pile along the length of the crane track. This will ensure independence of the process of unloading raw materials from the trucks at the industrial site equipped with washing, crushing and sorting plant as well as full capacity utilization of the crane. The purpose of the buffer depot is to provide certain quantities of raw materials during idle periods of mining transport and unloading facilities. The loaded material will be covered with tents and transport ed with four 27-ton tipper trucks to an industrial site owned by the company and equipped with crushing -washing-sorting plant for processing of alluvium from the Danube River and concrete unit in plot with identification No 63427.8.1076 from neighbourhood No 1 as per the plan of the town o f Ruse, eastern industrial zone, which is not subject to review by the present assessment. Alternatively, the extracted material will be dispatched with covered road transport vehicles to the market for processing by othe r entities or for direct consumption .

New road infrastructure or modification of the existing one

The transport corridor for transportation of sand and gravel to the wharf owned by the company will be the Danube river. The material from the longitudinal pile will be loaded onto four 27-ton dumpers by a front loader. The loaded alluvium will be transported with road vehicles.

9 The investment plan does not envisage a change in existing road infrastructure in the region or building of a new one. The site will be powered by existing technical communications. Programme of activities, including construction, operation and closure phase s, recovery and subsequent use

. 270 working days a year (235 days for extraction); . 7 working days a week including 6 days of extraction and 1 day for repairs and maintenance; . 9 working months; . 12 working hours a day. Preliminary project estimates on mining productivity reach 600 000 cubic meters a year or 2 600 cubic meters a day. Necessary human resources during operation: . 2 work shift foremen; . 12 persons required for the dredge; . 12 persons required for barges; . 2 persons required for the grabbing crane; . 4 persons necessary for the dispatch office; . 4 persons required for front loaders; . 8 persons required for the dumpers; The total number of persons employed in the activity equals 44.

Proposed methods of construction

The technology of process implementation during extraction of sand and gravel is directly related to the physical-mechanical characteristics of alluvial extracted alluvium. Alluvium consists of naturally deposited and thickened, but uncombined materials relating to a category of heavy soils of the earth. They can be extracted directly from their location using floating dredges. Transportation of raw materials will be done with specialized self -propelled barges for bulk material, each of them with a working load of 1 000 tonnes . Unloading of raw material from the barges to the coast will be done on the wharf by a jib crane with grabs.

10 1.2. Raw materials, natural materials, natural and energy resources River rubble: sand and gravel is a natural mineral resource, which actually is the subject of the proposed activity. The estimated dynamic reserves of alluvium in the outline of the approved area, subject of the investment proposal for extraction of sand and gravel in the Danube River are about 6.534 million cubic meters. No other natural resources will be used in the process of the proposed activity. Use of water resources is described in Item 2.5. Characteristics of water resources and water demand on site Bottled water will be used for drinking. Energy sources are:

• diesel fuel for extraction, transportation and storage of alluvium – 908 tons per year • oils – 24 tons per year • electricity supply for the unloading platform - 390 thousand kWh

1.3. Required permits related to investment project

For the realization of the project a permit for use of the Danube River for extraction of deposits under the Waters Act, and permit for use of the Danube River for discharge of treated household waste water will be required.

1.4. Type and quantity of waste and emissions expected in the implementation of the project

Waste Waste expected to be generated during the reconstruction of the existing port for handling of general and bulk cargo. The waste specified herein below will be generated once only during the reconstruction, which will last six months at the most. Different types of construction waste will be generated during the demolition of existing facilities on the wharf and its preparation for unloading of extracted alluvium from barges (destruction of buildings and concrete foundations, collection and transportation of waste from the existing concrete waste from the wharf). It includes waste bricks, concrete, tiles, and others which will be collected and temporarily stored in a designated area within the wharf. According to Ordinance No 3/01.04.2004 on the classification of waste the following types of waste will be generated during reconstruction of the existing por t:

11 • mixed construction waste from used building materials • Concrete, cement, gravel, etc.. - 17 01 01; • concrete, bricks - 17 01 02; • bricks, tiles and ceramics - 17 01 03, 17 01 07; • mixtures of concrete, bricks, tiles and ceramics other than thos e mentioned in 17 00 07; • Timber - 17 02 01; • Glass - 17 02 02; • Plastic - 17 02 03; • Iron and Steel - 7 04 05; • packaging and waste - 15 01 01 15 01 09.

Construction waste be transferred to a licensed company and transported to a landfill for construction waste as defined by the municipality of Rousse with transport of the Investor or a construction company. The estimated quantity is 1,000 t. Metal waste – shaped iron, construction iron and other that will be generated during demolition of buildings will be collected and temporarily stored in a designated area until their transfer to natural or legal persons holding a permit under Art. 37 of the WMA. Quantity - 20 t. During the demolition of buildings and site preparation for unloading of extracted r iver sediment household waste will be generated by the workers. Solid waste will be generated both during site clearance and operation of facilities. It will be collected in metal containers and transported to a landfill for municipal solid waste specified by within the territory of which the available investment plan provides extraction, transportation, unloading and loading of dumpers with alluvial materials, according to Art. 16, para. 1, para. 3, items 1 and 2 and the Ordinance under Art. 19 of the WMA. Solid waste from the dredge and barges will be stored on board of the vessels until its transportation to the shore. The waste will be disposed of in a landfill designated by Rousse Municipality.

Hazardous Waste During reconstruction of the existing port and its operation the following types of hazardous waste are expected to be generated:

• Waste motor, transformer and lubricating oils - 13 02 05; • waste of liquid fuels - gas and diesel - 13 07 01;

12 • oil waste not otherwise specified - 13 08 99; • packaging waste containing hazardous substances - 15 01 10; • absorbents, filter materials, wiping cloths, pro tective clothing - 15 02 02 etc.; • Discarded batteries - 16 06; • fluorescent lamps and mercury-containing lamps - 20 01 21.

The site in question is expected to generate waste electrical and electronic equipment. This waste will be treated in accordance with the "Regulation on the placing on the market of electrical and electronic equipment, transportation and treatment of waste elec trical and electronic equipment" (State Gazette issue 36/2006). Hazardous waste generated on the investment project site need to be separately collected and temporarily stored at predetermined locations on the invrestment project site . To this end, the detailed design for IP is to decide the question of their temporary storage, as required by law. The investor, in turn, must obtain a permit under Art. 37 of the WMA for temporary storage of the generated "hazardous" waste and to enter into contracts with lic ensed companies for their disposal. The amount of used lubricating oils will be equal to the one required to charge the facilities - 24 t / yr. Used lubricating oils will be forwarded to the companies with permission to handle such waste. The EIA report is to assess the impact of waste on the components of the environment during reconstruction and operation of the IP due to the presence of hazardous substances and hazardous waste in IP.

Atmospheric emissions Emissions to the atmosphere in the process of re construction of the existing port will be mostly dust particles, as well as emissions produced during operation of the engines of construction machinery and mounting equipment. The specific technology of extraction of aggregates does not involve significa nt impacts on atmospheric air quality (AA). The extraction of gravel and sand from the bed of the river will not lead to dust emissions in the AA. Since the extracted material is wet/damp the processes of transporting, unloading, temporary storage and load ing will not lead to the formation of dust emissions. The sites of implementation of the investment project have neither industrial or domestic sources of emissions nor heavy traffic of vessels or vehicles. Therefore, emissions of harmful substances in the air will be formed solely by the operation of equipment for extraction and

13 transportation of materials: harmful substances typical of the types of transportation equipment (and fuel types respectively) will be emitted, namely:

. Dust (including soot); . Nitrogen oxides; . Sulfur oxides; . Carbon oxides; . Hydrocarbons (methane and non -methane); . Heavy metals: Hg, Cd, Pb; . Polycyclic aromatic hydrocarbons (PAH); . Dioxins and furans (DIOX); . Polychlorinated biphenyls (PCBs).

The last four types of pollutants w ill be emitted in negligible quantities.

Potential source of emissions of dust in the air (due to dispersal of aggregates) can be the buffer depot for storage of nearly 17 000 tons of alluvium, which will be located on the wharf property of the company.

Harmful physical factors Noise during reconstruction of the existing port: construction activity is associated with demolition of existing buildings on the wharf of the town of Ruse and clearing of a site for temporary storage of unloaded alluvium. The sources of noise are standard machines and equipment for carrying out different types of construction activities on site (excavator, bulldozer, loader, trucks) with noise levels of 80 dBA to 105 dBA. All sources will be focused on the territory of the prop osed site. During certain periods equivalent noise level can reach 85 to 90 dBA near the working equipment on the construction site.

During operation sources of noise will be:

. equipment, located in the extraction area: floating multi bucket dredge KS 2 50 diesel aggregate group (diesel engine, generator), electric motors (7 pcs.) , self-propelled barge, and conveyor belt;

14 . machinery and equipment necessary for the operation of the wharf in the eastern industrial zone of the town of Ruse: grabbing jib -crane, front loader (2 pcs.) dumpers (4 pcs.);

The investment proposal provides for application of good manufacturing practices in this area at present, which means inclusion in the process of manufacturing facilities and installations with good technical and environmental performance indicators, including acoustic ones. According to the information provided by the Investor, the acoustic performance of the facilities meets the requirements of the Ordinance on essential requirements and conformity assessment of machinery and equipment, working outdoors in terms of noise emitted by them in the environment (SG. 11/2004).

Vibrations and radiation During execution of construction works for implementation of investment projects, vibrations form a factor in the working environment when carrying out certain specific activities. During construction works and wharf operation no sources of vibration or radiation will be emitted in the environment.

1.5. Characteristics of water sources and water use on the site

The investment proposal does not provide for the construction of water supply facilities using either surface or groundwater. Extraction will be carried out by dredging, and transportation by barges.

Quay, unloading platform The investment proposal does not prov ide for the construction of water supply facilities using either surface or groundwater.

For the realization of the project will be used:

Drinking water Drinking water for the workers on the dredger and barges will be provided from an external source by the company carrying out the extraction and transport.

15 Quay, unloading platform Bottled water will be delivered for the personnel working on site – 10 persons at the most.

Process Water Under the scheme adopted for extraction, transport and storage of alluvium, such water will not be required.

Domestic water The necessary water quantities for domestic use will be stored in special containers, and on the dredge and barges respectively. They will be refilled only at certain areas, as agreed on by the external company, owner of the dredge and barges.

Quay, unloading platform The necessary water quantities during operation for staffing for up to 10 people would be about 0.5 m3 per day. Water will be supplied by the urban water supply system to the administr ative and residential section of the site.

1.6. Quantity and composition of waste water in streams - industrial, sewage and stormwater. Treatment facilities

As a result of the implementation of the project the following waste streams will be released.

Industrial Wastewater: Given the technology of extraction, transportation and unloading, we believe that industrial waste water will not be formed.

Municipal Wastewater: Municipal wastewater will be generated on the extraction equipment (dredge) and transp ort barges. They will be owned by a third party company, which will be employed. Under the provisions of the IP the extraction site will be processed consistently. The crew of the dredge consists of 6 people, and that of the barge of 3. Four barges will transport extracted alluvium. Experts calculate the total amount of wastewater will amount to approximately 0.9 m3 per working day.

16 Article 9.03, paragraph 1 of the "Rules for Sailing along the Bulgarian Section of the Danube River” and the specific recommen dations of the Danube Commission to the competent authorities of the Danubian states for implementation of the Basic Provisions relating to Navigation on the Danube River (supplement to SG 55/2005) prohibit the discharge or spillage of wastewater into the water route. Wastewater must be disposed of at specifically indicated points for collection, according to Art. 9.05, paragraph 4 of the said Rules. Article 9.07 allows disposal of wastewater treated on the vessels sailing along the waterway if the maximum concentration contained therein remains constant and without predilution complies with the requirements set out in Art. 9.06 of the Rules. Article 9.06, paragraph 1 states that wastewater treated on board water vessels is not considered contaminated in terms of protecting the waters of the Danube, if the indicators of pollution fall within the following limits: • Coli-Index - 1000; • suspended matter - 50 mg / l; • ВОD5) – 50 mg/l; • ССО-Cr) – 150 mg/l. These indicators are achieved through special water tr eatment process in which dilution with water is not allowed. According to Art. 9.07 discharge of wastewater treated on board vessels is allowed if the maximum concentration contained therein remains constant and without predilution complies with the requirements set out in Art. 9.06 of the Rules, i.e. with the indices specified herein above.

Quay, unloading platform Under the project, during the reconstruction of the site there will be no generation of municipal wastewater. Chemical toilets operated by a specialized supplier will be provided. Municipal wastewater will be generated during extraction. This will be done in the residential and administrative section, where the facilities will be located. Quantities, given the number of staff being no more than 10 people, will not exceed 0.5 m3 per day. The site will be equipped with a small treatment plant type ACO Clara 5 -10 with capacity from 0.75 to 1.05 m3/day. For discharge of treated household wastewater a permit for use of the Danube River will be required.

17 Rainwater The site is located in the bed of the Danube River and formation of stormwater is not expected.

Quay, unloading platform The investment proposal does not addressed the issue of treatment of stormwater on site.

1.7. Proximity to protected territories and zones in Bulgaria The nearest protected area under the Bulgarian Biodiversity Act (BDA) is the protected area BGSPA0002024 "Mechka Fisheries" on the right bank of the Danube River in Bulgaria. It is located about 3.3 km east of the eastern b oundary of the protected area. The IP terrain is near the southern borders of two protected areas on the left bank of the Danube River in Romania:

• Protected area ROSPA0108 "Vëdea Dunare" and • Protected area ROSSI 0088 "GuraVëdei -Saica-Slobozia" Both protected areas include the islands of Cama and Dinu and the adjacent aquatory (see Section 8).

2. Other plans, programs and projects/investment proposals, existing and/or in the process of development or approval, which in combination with the assessed inv estment proposal may have an adverse effect on local protected areas .

In connection with determining the cumulative effect the investor has requested information from several agencies with letter No AO3978/05.07.2012. Information was supplied by the Ministry of Environment and Water (letter No 26-00-1830/04.07.2012), the Agency for Maintenance and Exploration of the Danube (reg. No VIII-5-570/09.07.2012) and RIEW Ruse (No 2163/01.08.2012, Decision No 343/01.08.2012 - see Appendix 13.2). Resulting information is summarized on the website of the Executive Agency for Exploration and Maintenance of the Danube River (Table 2 -1):

Table 2-1. Quarries on the Bulgarian Danube bank, according to the website (www.appd - bg.org) of the Executive Agency for Exploration a nd Maintenance of the Danube River

18 authorized No Permit location from km To km area geographic coordinates yield 43°41‘38.3“ Mechka 1 25°44‘36.5“ Village, 43°41‘44.1“ Municipality 2 25°44‘31.9“ 1 РВО-18/08.08.2011 Ivanovo, 521,0 519,3 283 33 43°42‘10.9“ Region 3 25°45‘37.0“ Rousse 43°42‘07.2“ 47977 4 25°45‘39.8“ 43°47'27.1" 1 Rousse, 25°54'10.3" Rousse 43°47'50.3" 2 Municipality, 25°54'24.9" 2 РВО-19/08.08.2011 503,5 502,7 79 100 Rousse 43°47'49.0" 3 Region, 25°54'29.0" 63427 43°47'25.7" 4 25°54'14.2" 43°45'33.8" 1 24°31'24.8" 43°45'24.4" Zagrazhden 2 24°32'08.6" village, 43°45'16.8" Gulyantsi 3 24°33'24.1" 3 РВО-20/08.08.2011 Municipality, 629,1 626,0 543 330 43°45'10.6" 4 24°33'22.1" Region, 43°45'18.1" 30199 5 24°32'06.8" 43°45'27.7" 6 24°31'21.8" 43°38'19.0" 1 25°28'28.0" Vardim 43°38'22.9" 2 village, 25°28'40.6" Municipality 43°38'27.6" 3 Not larger than Svishtov, 25°29'14.5" 4 РВО-21/08.08.2011 544,0 543,0 213 the renewable Region 43°38'21.2" 4 supply Veliko 25°29'15.9" Turnovo, 43°38'16.6" 5 10118 25°28'42.4" 43°38'12.7" 6 25°28'30.0" 43°53'56.0" 1 22°50'21.8" 43°53'54.0" РВО-22/08.08.2011 2 22°50'30.3" Dounavtsi 43°53'13.0" town, 3 22°50'12.6" Municipality Not larger than 43°52'30.9" 5 Vidin, 780,4 778,0 645 4 the renewable 22°50'08.8" Extended with resolution Region supply 43°52'31.1" Vidin, 5 22°49'55.4" 10118 43°53'16.1" 6 22°50'00.0" No 76/03.10.2011 43°53'40.9" 7 22°50'19.7" Dounavtsi 43°55'21.9" не по-голям от 6 РВО-23/08.08.2011 г. 783,0 782,0 318 1 town, 22°50'31.0" възобновяемия Municipality запас 2 43°55'20.3"

19 authorized No Permit location from km To km area geographic coordinates yield Vidin, 22°50'40.8" Region 43°54'41.6" 3 Vidin, 24061 22°50'51.1" 43°54'40.6" 4 22°50'45.0" 43°55'01.9" 5 22°50'29.0" 43°55'04.7" 6 22°50'42.6" Dragash 43°42'37.9" 1 Voyvoda 24°57'04.2" village, 43°42'39.6" 2 02150021/30.11.2010 Nikopol 24°57'04.1" 7 592,0 591,2 90 30 MEW municipality, 43°42'44.2" 3 Pleven 24°57'30.1" Region, 43°42'39.7" 4 23193 24°57'30.7" 43°48'30.6'' 1 Rousse, 25°54'44.2'' Rousse 43°48'41.1'' 2 Municipality, 25°54'51.9'' 8 РВО-24/11.10.2011 501,4 501,0 70 7 Rousse 43°48'39.6'' 3 Region, 25°54'59.5'' 63427 43°48'28.4'' 4 25°54'52.1'' 43°40'28.4'' 1 Batin village, 25°41'20.9'' Borovo 43°40'54.0'' 2 Municipality, 25°42'46.5'' 9 РВО-25/19.12.2011 525,1 523,0 103 22 Rousse 43°40'52.4'' 3 Region, 25°42'47.2'' 02854 43°40'27.0'' 4 25°41'22.0''

Of all four quarries 9 sites with a total area of 535 acres are adjacent to the area of IP development and should be taken into account when considering the cumulative impact on the protected area BGSPA0002024 "Mechka Fisheries." These are the sites under No 1, 2, 8 and 9, which are included in the letter of the same agency (reg. No V -1-344 dated 11.04.2011). They are listed below in Table 2-2:

Table 2-2. Issued and existing permits for extraction of inert materials by the Executive Agency for Exploration and Maintenance of the Danube River Site Location area (decares) Location along the Danube Luylyak 1 Island km 501.4 – km 501.0 36.963 below IP Luylyak 2 Island km 503.5 – km 502.7 78.871 below IP Below Batin Island km 521.0 – km 519.0 338.942 Above IP Batin Island km 525.1 – km 523.5 ? Above IP total 1 318.81

20 The location of these four quarries is shown in the following Fig. 2 -1 (to the East of the IP area) and Fig. 2-2 (to the West of the IP area).

Fig. 2-1. Satellite image with location of the existing quarries to the east of the area of the Investment Proposal (Lyulyak island 1 quarry is marked in yellow, Lyulyak island 2 is marked in cerise). The boundaries of the Protected Areas along the left coast of the Danube River are marked with green and red lines respectively .

21 Fig. 2-2. Satellite image with location of the existing qu arries to the west of the area of the Investment Proposal (the boundaries of BGSPA0002024 „Mechka Fish-ponds” are marked in yellow, Batin island quarry is marked in dark green and the quarry below Batin island – in violet) The abovementioned information sh ows that the boundaries of BGSPA0002024 „Mechka Fish-ponds” fall, partially or wholly, into two quarries (Batin quarry and the quarry below Batin on Fig. 2-2). The area of the assessment of this Investment Proposal is located approximately 3.3 km to the east of the eastern boundary of the Protected Area and downstream the river. With such a location of the Investment Proposal it can be guaranteed that it shall not have a significant adverse impact on the Protected Area BGSPA0002024 „Mechka Fish-ponds” and all components thereof. An important circumstance is however the favourable location of the Investment Proposal of approximately 3.3 кm downstream the Danube River, i.e. below the Protected Area.

Based on the hereinabove mentioned it can be concluded tha t the implementation of the Investment Proposal shall not increase the cumulative effect on the Protected Area BGSPA0002024 „Mechka Fish-ponds”.

The 4 quarries described (Batin quarry, the quarry below Batin, Lyulyak island quarry 1 and Lyulyak island 2 quarry of Fig. 2-1 and Fig. 2-2) together with this Investment Proposal are located outside the boundaries of the Protected Areas ROSPA0108 „Vëdea Dunare“ and ROSSI 0088 „GuraVëdei-Saica-Slobozia. Therefore, it can be concluded, that they shall not have a significant

22 adverse impact on the objectives and the subject of conservation, the structure, the fragmentation and the remaining components of the mentioned Protected Areas.

3. Descriptions of the Investment Proposal elements which alone or in combination with other plans, programmes and projects/ investment proposals could have a significant impact on the reviewed Protected Areas or the elements thereof.

The elements of the Investment Proposal which alone or in combination with other plans, programmes and projects/ investment proposals could impact the reviewed Protected Areas are as follows:  Dredging facilities for the bottom of the river -bed;  Vessels for transporting the extracted material ;  Areas for storing the extracted material . Data about these elements can be found in the Annotation (section 1). 4. Description of the Protected Areas, the habitats, the types and objectives of management at national and international level and their impact on the development of the investment proposal plan

4.1. Protected Area BGSPA0002024 „Mechka Fish-ponds“

The Protected Area “Mechka Fish -ponds” with code BG0002024 is declared by ordinance No. РД-561 dated 5th September 2008 promulgated in the State Gazette, issue 84 of 26.09.2008. According to the ordinance its total area is 2582.34 ha. It is located approximately 3.3 km to the west of the terrain of the Investment Proposal, i.e. upstream the Danube River (see also section 8).

The objectives of conservation of the Protected Area are as follows :  To protect the area of the natural habitats and the habitats of the species and their populations subject of conservation within the Protected Area .  To preserve the favorable state of the natural habitats and the habitats of the species subject of conservation within the Prote cted Area, including the natural range of species in these habitats, typical species and conditions of the environment .

23  To restore, if necessary, the area and the real state of the priority natural habitats and the habitats of species as well as of species populations subject of conservation within the Protected Area.

Within the Protected Areas it is forbidden :  To remove characteristics of the landscape (boundaries, single trees as well as group of trees ) when using agricultural land as such ; Afforestation of meadows and grasslands as well as their transformation into cultivable land and plantations of perennial plants;  To use pesticides and mineral fertilizers in grasslands and meadows ;  To eliminate island formations ;  To cut wood where there is a change of the natural alluvial forests;  To remove vegetation along the banks of irrigation / draining canals during the generative period (March - August);  To mow reed during the period 1 March to 15 August;  To fire glasslands and riverside vegetation .

4.1.1. Description

According to the Standard Data Form the Protected Area is „…a former marsh alongside the Danube river, that has transformed into fish-ponds overrun by marsh vegetation, including the mouth of a small river at its western part and the Danube river in the section between km 522-516 with two islands. It is located 4-5 km to the west of Mechka village. To the north its boundary coincides with the state boundary while to the south and the west it is encircled by the slopes of the high Danube coast, to the east it reaches an area zoned for summer houses in the Stalpishte site. Opposite the west end of the fish-ponds island Batin is located, while opposite the east end – the Nameless island. The appearance of the site is determined by the basins of the fish -ponds, overgrown by marsh hygrophytic and hydrophytic vegetation with prevailing common reed /Phragmites australis/, water chestnut /Trapa natans/, water lily /Nymphaea alba/, at some places - reed-mace /Typha spp./, various grasses and bushes. Along the embankments including the one alongside the Danube river fruit-trees and poplar trees are planted. Damp meadows spread around the fish -ponds where Meadow fescue /Festuca pratensis/, Poa sylvicola etc. prevail. The slopes are overgrown by broad-leaves mixed forests of South European Flowering Ash /Fraxinus ornus/, Silver Lime /Tilia tomentosa/, elm /Ulmus minor/ and at some places by field maple /Acer campestrе/ (Bondev, 1991). To the south of the slopes the terrain becomes even and covers agricultural land …“

24 4.1.2. Subject of conservation

4.1.2.1 Natural Habitats Types There are no species of habitats subject of conservation in the Protected Area . 4.1.2.2. Species The following 112 bird species are subject of conservation in Protected Area ”Mechka Fish - ponds” with identification code BG0002024:

Pursuant to Art. 6, Para 1, Item 3 of the Biological Diversity Act – 59 species: Pygmy Cormorant (Phalacrocorax pygmeus), Dalmatian Pelican (Pelecanus crispus), Great Bittern (Botaurus stellaris), Little Bittern (Ixobrychus minutus), Black-crowned Night Heron (Nycticorax nycticorax), Squacco Heron (Ardeola ralloides), Little Egret (Egretta garzetta), Great Egret (Egretta alba), Purple Heron (Ardea purpurea), Black Stork (Ciconia nigra), White Stork (Ciconia ciconia), Glossy Ibis (Plegadis falcinellus), Common Spoonbill (Platalea leucorodia), Whooper Swan (Cygnus cygnus), Lesser White-fronted goose (Anser erythropus), Red-breasted goose (Branta ruficollis), Ruddy Shelduck (Tadorna ferruginea), Ferruginous Duck (Aythya nyroca), Smew (Mergus albellus), Levant Sparrowhawk (Accipiter brevipes), European Honey Buzzard (Pernis apivorus), Black Kite (Milvus migrans), Long-legged Buzzard (Buteo rufinus), White-tailed Eagle (Haliaeetus albicilla), Short-toed Snake Eagle (Circaetus gallicus), Western Marsh-harrier (Circus aeruginosus), Hen Harrier (Circus cyaneus), Pallid Harrier (Circus macrourus), Lesser Spotted Eagle (Aquila pomarina), Greater Spotted Eagle (Aquila clanga), Golden Eagle (Aquila chrysaetos), Eastern Imperial Eagle (Aquila heliaca), Booted Eagle (Hieraaetus pennatus), Osprey (Pandion haliaetus), Red-footed Falcon (Falco vespertinus), Merlin bird (Falco columbarius), Spotted Crake (Porzana porzana), Baillon’s Crake (Porzana pusilla), Corn Crake (Crex crex), Common Crane (Grus grus), Black-winged Stilt (Himantopus himantopus), Pied Avocet (Recurvirostra avosetta), Ruff (Philomachus pugnax), Wood Sandpiper (Tringa glareola), Little Gull (Larus minutus), Caspian Tern (Sterna caspia), Common Tern (Sterna hirundo), Little Tern (Sterna albifrons), Whiskered Tern (Chlidonias hybridus), Black Tern (Chlidonias niger), Eurasian Eagle-Owl (Bubo bubo), Common Kingfisher (Alcedo atthis), European Roller (Coracias garrulus), Black Woodpecker (Dryocopus martius), Syrian Woodpecker (Dendrocopos syriacus), Aquatic Warber (Acrocephalus paludicola), Red-backed Shrike (Lanius collurio), Lesser Grey Shrike (Lanius minor), Ortolan Bunting (Emberiza hortulana); Pursuant to Art. 6, Para 1, Item 4 of the Law for Biological Diversity – 53 species: Little Crebe (Tachybaptus ruficollis), Great Crested Crebe (Podiceps cristatus), Red-necked Crebe (Podiceps grisegena), Black-necked Crebe (Podiceps nigricollis), Great Cormorant (Phalacrocorax

25 carbo), Grey Heron (Ardea cinerea), Mute Swam (Cygnus olor), Bean Goose (Anser fabalis), Greater White-fronted Goose (Anser albifrons), Greylag Goose (Anser anser), Common Shelduck (Tadorna tadorna), Eurasian Wigeon (Anas penelope), Gadwall (Anas strepera), Mallard (Anas platyrhynchos), Pintail (Anas acuta), Garganey (Anas querquedula), Northern Shoveler (Anas clypeata), Common Pochard (Aythya ferina), Tufted Duck (Aythya fuligula), Greater Scaup (Aythya marila), Velvet Scoter (Melanitta fusca), Common Goldeneye (Bucephala clangula), Red-breasted Merganser (Mergus serrator), Common Merganser (Mergus merganser), Eurasian Sparrowhawk (Accipiter nisus), Common Buzzard (Buteo buteo), Common Kestrel (Falco tinnunculus), Eurasian Hobby (Falco subbuteo), Common Moorhen (Gallinula chloropus), Eurasian Coot (Fulica atra), Eurasian Oystercatcher (Haematopus ostralegus), Little Ringed Plover (Charadrius dubius), Grey Plover (Pluvialis squatarola), Northern Lapwing (Vanellus vanellus), Temminck’s Stint (Calidris temminkii), Curlew Sandpiper (Calidris ferruginea), Dunlin (Calidris alpina), Jack Snipe (Lymnocryptes minimus), Common Snipe (Gallinago gallinago), black-tailed Godwit (Limosa limosa), Eurasian Curlew (Numenius arquata), Spotted redshank (Tringa erythropus), Common Redshank (Tringa totanus), Marsh Sandpiper (Tringa stagnatilis), Common Greenshank (Tringa nebularia), green Sandpiper (Tringa ochropus), Ruddy Turnstone (Arenaria interpres), Black- headed Gull (Larus ridibundus), Common Gull (Larus canus), White-winged Tern (Chlidonias leucopterus), European Bee-eater (Merops apiaster), Sand Martin (Riparia riparia), Caspian Gull (Larus cachinnans).

4.2. Protected Area ROSPA0108 Vedea Dunare

4.2.1. Description

The Protected Area is located on the left coast of the Danube River between river km 494 and 541. It also covers the river bed of a big river from the mouth to approximately the village of Cervenia. The strip is about 5 km wide from the floodplain of the Danube River which is also part of the Protected Area. The marshes that were numerous in the past are now drained as a result of the construction of a large embankment . Presently they occupy only 3% of its area, amounting to 22874.4 ha. The remaining habitats in the Protected Area are allocated as follows (Table 4.2-1): Table 4.2-1. Allocation of the various habitats in Protected Area ROSPA0108 Vedea Dunare by percentage in accordance with Standard Data Form (http://www.natura2000.eeaeuropa.eu ).

26 Land Cover Class % Coverage

Inland water bodies (Standing water, Running water) 11.00 Bogs, Marshes, Water fringed vegetation, Fens 3.00 Extensive cereal cultures (including Rotation cultures with regular fallow ing) 58.00 Improved grassland 10.00 Broad-leaved deciduous woodland 15.00 Woodland habitats (general) 3.00 TOTAL HABITAT COVER 100%

4.2.2. Subject of conservation

According to Standard Data Form subject of conservation in the protected area are the following bird species included in Annex 1 of the Council Directive 79/409/EEC on the conservation of wild birds– Table 4.2-2: Table 4.2-2. Bird species included in Annex 1 of the Council Directive on the conservation of wild birds (79/409/EEC)

Population Assessment Code Name Perma Spring species Conserva Summary Population Isolation nent Nesting Winter Migratory tion assessment A229 Alcedo atthis >12 p D C C C A209 Ardea purpurea RC D B C B A024 Ardeola ralloides 50-60 p D B C B A060 Aythya nyroca 25-34 p 300-400 i C B C B A031 Ciconia ciconia 33-40 p >180 i D B C B A030 Ciconia nigra 8-10 p >48 i D B C B A081 Circus aeruginosus 12-24 i RC C D B C B A082 Circus cyaneus >1 i D B C B A027 Egretta alba >26 p D B C B A072 Egretta garzetta RC D B C B A131 Himantopus himantopus 6-7 p RC D B C B A022 Ixobrychus minutus 20-24 p >20 i D B C B A020 Pelecanus crispus R C B C B A019 Pelecanus onocrotalus R C B C B A393 Phalacrocorax pygmeus >240 i >1000 i C A C A A034 Platalea leucorodia RC D B C B A032 Plegadis falcinellus RC D B C B A132 Recurvirostra avosetta RC D B C B

4.3. Protected Area ROSCI0088 Gura Vedei-Saica-Slobozia

Gura Vedei-Saica-Slobozia is declared as protected area by virtue of Directive 92/43/ЕЕС, code ROSCI0088 in the State Gazette, part 1, Issue 98 of 07.02.2008 (Monitorul оficial аl Rom âniei, Partea I, Nr. 98 bis/7.II.2008) and covers an area of 5813.00 ha.

27 4.3.1. The objectives of conservation of the protected area are as follows :

 To conserve the area of the natural habitats and the habitats of species and their populations subject to conservation within the protected area .  To conserve the natural state of the natural habitats and the habitats of species subject to conservation within the protected area including t he natural range of species in these habitats, typical species and conditions of the environment .  To restore if necessary the area and the natural state of the priority natural habitats and the habitats of species as well as the populations of species subj ect to conservation within the protected area.

4.3.2. Subject of conservation

4.3.1.1. Natural Habitat Types Subject of conservation in protected area „Gura Vedei-Saica-Slobozia“ with identification code ROSCI0088 is the natural habitat 92А0 – riverside galleries of Salix alba and Populus alba. 4.3.1.2. Species Subject of conservation in protected area „Gura Vedei-Saica-Slobozia“ with identification code ROSCI0088 are 10 fish species, 1 amphibian species, 1 reptile species, 6 mammal species. Fish: Aspius aspius, Gobio albipinnatus, Cobitis taenia, Gymnocephalus baloni, Gymnocephalus schraetzer, Misgurnus fossilis, Rhodeus sericeus amarus, Sabanejewia aurata, Zingel streber, Zingel zingel. During the implementation of the Investment Proposal all species coul d be affected, both directly and indirectly Amphibians: Bombina bombina – the species live in the riverside area, therefore it is not expected that it would be affected during the implementation of the Investment Proposal. Reptiles: Emys orbicularis – the species live in the riverside area, therefore it is not expected that it would be affected during the implementation of the Investment Proposal . During the reproduction period it goes away dozens to hundreds of meters away searching for a suitable terrain for egg hatching. The inclined slopes with well drained pads exposed to the east or the south are preferable. Mammals: Lutra lutra – only this mammal species might be affected in implementation of the Investment Proposal. The European otter is a very ad aptive big mammal which is explained by the

28 night activity and environmental flexibility of the species . The noise that is accumulated from the vessels is the main reason so far for the fact that the species is adaptable to this type of irritating factor. Miniopterus schreibersi, Myotis emarginatus, Myotis myotis, Rhinolophus hipposideros, Rhinolophus mehelyi. 5. Description and analysis of the probability and the degree of impact of the investment proposal on the subject and objectives of conservation of the reviewed protected areas So far, there is not an officially approved methodology of quantitative assessment of the adverse impact on the species subject of conservation in the protected areas under Natura 2000. Therefore, we have used herein the origin al methodology developed by us (see Section 11), which we have used successfully for a couple of years. It studies the bird species subject of conservation in two stages (qualitative and quantitative assessment). With the qualitative assessment based on th e strength of the species population in Bulgaria (Yankov, 2007), in the protected area (according to its Standard Data Form) and the terrain of the Investment Proposal (according to the data from the monitoring, if such has been conducted, or according to data of the inspection, scientific articles, personal data etc.) the relative weight of each adverse impact is reported (destruction, damage, aggrevation, disturbance, fragmentation, pollution, damage of bio corridors and violation of the geographical connection) during each period of the life cycle of the species (propagation, migration, wintering). The sum of all impacts gives the total qualitative assessment of the respective bird species.

5.1. Protected area BGSPA0002024 „Mechka Fish-ponds“

5.1.1. Natural Habitat Types

There are no natural habitat types subject of conservation in the protected area .

5.1.2. Species subject of conservation

These species are in total 113 (59 + 54). The assessment of the adverse impact on them is done in two stages. The first stage presents the adverse impact only in qualitative terms (not expected – expected) - Table. 5.1.2-1. Table. 5.1.2-1. The expected adverse impact on the bird species subject of conservation under items 3 and 4 (listed consecutively per items 3 and 4 in a taxonomic order) in the protected areas as a result of the implementation of the Investment Proposal.

29 Designation in column „Not expected because....”: 1. The species throughout the year or during certain seasons cannot be found in the habitats that are part of the terrain of the Investment Proposal or in its immediate proximity . 2. The species can be found in habitats that are part of the terrain of the Investment Proposal or in its immediate proximity, but on an irregular, episodic or random basis and/ or it has in the Standard Data Form of the protected area a summary assessment „D”. 3. The species throughout the year or in a separate season can be found regularly in the habitats of the terrain of the Investment Proposal but it does not use them b ecause they are close to an asphalt covered roads, residential areas or due to some other reasons. 4. The species regularly only flies over the terrain of the Investment Proposal during feeding or migration. 5. The species is a synanthropic one or unsusceptible to anthropogenic impact resulting from the implementation of the Investment Proposal . 6. The species is not established by Yankov (2007) as a nesting species in the UTM grid where the terrain of the Investment Proposal is located.

Adverse Impact No. Species – subject of conservation in PA „Mechka Fish-ponds Not expected Expected because: 1. Pygmy Cormorant (Phalacrocorax pygmeus) + 2. Dalmatian Pelican (Pelecanus crispus) + 3. Great Bittern (Botaurus stellaris) 2 4. Little Bittern (Ixobrychus minutus) 1 5. Black-crowned Night Heron (Nycticorax nycticorax) 2 6. Squacco Heron (Ardeola ralloides) 1 7. Little Egret (Egretta garzetta) 2 8. Great Egret (Egretta alba) 1 9. Purple Heron (Ardea purpurea) 1 10. Black Stork (Ciconia nigra) + 11. White Stork (Ciconia ciconia) 1 12. Glossy Ibis (Plegadis falcinellus) 1 13. Common Spoonbill (Platalea leucorodia) + 14. Whooper Swan (Cygnus cygnus) 1 15. Lesser White-fronted goose (Anser erythropus) 1 16. Red-breasted goose (Branta ruficollis) 2 17. Ruddy Shelduck (Tadorna ferruginea) 2 18. Ferruginous Duck (Aythya nyroca) 2 19. Smew (Mergus albellus) + 20. Levant Sparrowhawk (Accipiter brevipes) + 21. European Honey Buzzard (Pernis apivorus) 1

30 Adverse Impact 22. Black Kite (Milvus migrans) + 23. Long-legged Buzzard (Buteo rufinus) 2 24. White-tailed Eagle (Haliaeetus albicilla) + 25. Short-toed Snake Eagle (Circaetus gallicus) 2 26. Western Marsh-harrier (Circus aeruginosus) 1 27. Hen Harrier (Circus cyaneus) 1 28. Pallid Harrier (Circus macrourus) 2 29. Lesser Spotted Eagle (Aquila pomarina) + 30. Greater Spotted Eagle (Aquila clanga) 1 31. Golden Eagle (Aquila chrysaetos) 3 32. Eastern Imperial Eagle (Aquila heliaca) 1 33. Booted Eagle (Hieraaetus pennatus) 1 34. Osprey (Pandion haliaetus) + 35. Red-footed Falcon (Falco vespertinus) 2 36. Merlin bird (Falco columbarius) 2 37. Spotted Crake (Porzana porzana) 1 38. Baillon’s Crake (Porzana pusilla) 1 39. Corn Crake (Crex crex) 1 40. Common Crane (Grus grus) 1 41. Black-winged Stilt (Himantopus himantopus) 2 42. Pied Avocet (Recurvirostra avosetta) 2 43. Ruff (Philomachus pugnax) 2 44. Wood Sandpiper (Tringa glareola) 2 45. Little Gull (Larus minutus) 2 46. Caspian Tern (Sterna caspia) + 47. Common Tern (Sterna hirundo) + 48. Little Tern (Sterna albifrons) + 49. Whiskered Tern (Chlidonias hybridus) 2 50. Black Tern (Chlidonias niger) 2 51. Eurasian Eagle-Owl (Bubo bubo) 2 52. Common Kingfisher (Alcedo atthis) + 53. European Roller (Coracias garrulus) 2 54. Black Woodpecker (Dryocopus martius) 2 55. Syrian Woodpecker (Dendrocopos syriacus) 2 56. Aquatic Warber (Acrocephalus paludicola) 2 57. Red-backed Shrike (Lanius collurio) 2 58. Lesser Grey Shrike (Lanius minor) 2 59. Ortolan Bunting (Emberiza hortulana) 2 60. Little Crebe (Tachybaptus ruficollis) 2 61. Great Crested Crebe (Podiceps cristatus) 2 62. Red-necked Crebe (Podiceps grisegena) 2 63. Black-necked Crebe (Podiceps nigricollis) 2

31 Adverse Impact 64. Great Cormorant (Phalacrocorax carbo) + 65. Grey Heron (Ardea cinerea) 2 66. Mute Swam (Cygnus olor) 2 67. Bean Goose (Anser fabalis) 2 68. Greater White-fronted Goose (Anser albifrons) 2 69. Greylag Goose (Anser anser) + 70. Common Shelduck (Tadorna tadorna) 1 71. Eurasian Wigeon (Anas penelope) 2 72. Gadwall (Anas strepera) 2 73. Mallard (Anas platyrhynchos) + 74. Pintail (Anas acuta) 2 75. Garganey (Anas querquedula) 1 76. Northern Shoveler (Anas clypeata) 1 77. Common Pochard (Aythya ferina) 2 78. Tufted Duck (Aythya fuligula) 2 79. Greater Scaup (Aythya marila) 2 80. Velvet Scoter (Melanitta fusca) 2 81. Common Goldeneye (Bucephala clangula) 2 82. Red-breasted Merganser (Mergus serrator) 2 83. Common Merganser (Mergus merganser) + 84. Eurasian Sparrowhawk (Accipiter nisus) 2 85. Common Buzzard (Buteo buteo) 2 86. Common Kestrel (Falco tinnunculus) 2 87. Eurasian Hobby (Falco subbuteo) 2 88. Common Moorhen (Gallinula chloropus) 2 89. Eurasian Coot (Fulica atra) 2 90. Eurasian Oystercatcher (Haematopus ostralegus) + 91. Little Ringed Plover (Charadrius dubius) + 92. Grey Plover (Pluvialis squatarola) 1 93. Northern Lapwing (Vanellus vanellus) 1 94. Temminck’s Stint (Calidris temminkii) 1 95. Curlew Sandpiper (Calidris ferruginea) 1 96. Dunlin (Calidris alpina) 1 97. Jack Snipe (Lymnocryptes minimus) 1 98. Common Snipe (Gallinago gallinago) 1 99. Black-tailed Godwit (Limosa limosa) 1 100.Eurasian Curlew (Numenius arquata) 1 101.Spotted redshank (Tringa erythropus) 1 102.Common Redshank (Tringa totanus) 1 103.Marsh Sandpiper (Tringa stagnatilis) 1 104.Common Greenshank (Tringa nebularia) 1 105.Green Sandpiper (Tringa ochropus) 3

32 Adverse Impact 106.Ruddy Turnstone (Arenaria interpres) 1 107.Black-headed Gull (Larus ridibundus) 1 108.Common Gull (Larus canus) 1 109.Caspian Gull (Larus cachinnans). + 110.White-winged Tern (Chlidonias leucopterus) 2 111.European Bee-eater (Merops apiaster) 2 112.Sand Martin (Riparia riparia) + Total 89 22

In order to determine the degree of adverse impact in terms of quantity in the second phase the specified 22 species subject of conservation of the above table are considered in a taxonomic order as follows: 1. Dalmatian Pelican (Pelecanus crispus) – nesting, migratory, passing, wintering species listed in the Red Data Book of Bulgaria ; globally endangered species. It occupies natural and artificial inland water bodies, along the Danube river and the Black Sea Coast and the adjacent damp zones. On the territory of the protected area during the winter 33 (12-55) birds of summary assessment „А” have been registered. Not found on the location of the Investment Proposal but in case of low river levels it might be possible to use adjacent sandpits for repose and roosting during migration and wintering. Slight adverse impact is expected.

PA „Mechka Fish-ponds” DEGREE OF IMPACT Dalmatian Pelican (Pelecanus crispus) Propagation Migration Wintering (see item 11 for explanations Summary related to the table) Small In sites for In sites for In sites for assess- nests Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,9 0,9 1,8 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8 Total 0,9 0,9 3,4

2. Pygmy Cormorant (Phalacrocorax pygmeus) – nesting, migratory, passing, wintering species listed in the Red Data Book of Bulgaria , 2011 (endangered category). IItt occupies varied damp areas. On the territory of the protected area „Mechka Fish-ponds” 5 (1-9) nesting couples having a

33 summary assessment „С” have been registered. Not found in the location of the Investment Proposal but nests not far away from it in a mixed colony of great cormorants, Eurasian spoonbills and areas . At low river levels it might be possible to use the sandpits for repose and roosting during migration and wintering in the proximity to the reviewed site . Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Pygmy Cormorant Propagation Migration Wintering (Phalacrocorax pygmeus) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 0,6 0,6 2,4 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8 0,6 0,6 Total 0,6 0,6 4,0

3. Great Cormorant (Phalacrocorax carbo) – nesting, migratory, passing, wintering species listed in the Red Data Book of Bulgaria , 1985. IIt occupies varied damp areas. On the territory of the protected area „Mechka Fish-ponds” 0-30 nesting couples and 720 (40-1400) passing birds having a summary assessment „B” have been registered. Not found in the location of the Investment Proposal but nests not far away from it in a mixed colony of pygmy cormorants, herons and common spoonbills. At low river levels it might be possible to use the sandpits for repose ad roosti ng during migration and wintering in the proximity to the reviewed site . Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Great Cormorant Propagation Migration Wintering (Phalacrocorax carbo) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 0,6 0,6 2,4 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8 Total 0,6 0,6 0,6 0,6 4,0

34 4. Common Spoonbill (Platalea leucorodia) – nesting, migratory, passing, and by exception a wintering species. It occupies varied damp areas. On the territory of the protected area „Mechka Fish-ponds” 15 (10-20) birds in their reproductive period and 10 (1 -2o) passing birds having a summary assessment „A” have been registered. Not found in the location of the Investment Proposal but at low river levels it might be possible to use the sandpits for repose and roosting during migrations in the proximity to the reviewed site . Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Common Spoonbill Propagation Migration Wintering (Platalea leucorodia) Birds In sites for In sites for In sites for Summary (see item 11 for explanations Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 0,6 1,8 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 0,6 3,4

5. Black stork (Ciconia nigra) – migratory, nesting, passing species listed in the Red Data Book of Bulgaria, 1985. It occupies rocky areas, deciduous and coniferous woodland, varied damp areas . On the territory of the protected area „Mechka Fish-ponds” 15 (0-10) passing birds having a summary assessment „A” have been registered. Not found in the location of the Investment Proposal but at low river levels it might be possible to use the sandpits for repose and roosting during migrations in the proximity to the reviewed site . Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Black Stork Propagation Migration Wintering (Ciconia nigra) Birds In sites for In sites for In sites for Summary (see item 11 for explanations Asseessm Nests Nesting Feeding Feeding Roosting Feeding Roosting related to the table) ent Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,8

35 6. Greylag Goose (Anser anser) – migratory, nesting, passing and wintering spec ies listed in the Red Data Book of Bulgaria , 1985. IIt occupies vast damp areas with thick vegetation. On the territory of the protected area „Mechka Fish-ponds” 4 (0-9) passing birds and 17 (9-26) wintering birds having a summary assessment „B” have been registered. Not found in the location of the Investment Proposal but at low river levels it might be possible to use the sandpits for repose and roosting during migrations and wintering in the proximity to the reviewed site . Slight adverse impact is expected.

PA „Mechka Fish-ponds” DEGREE OF IMPACT Greylag Goose Propagation Migration Wintering (Anser anser) Birds In sites for In sites for In sites for Summary (see item 11 for explanations assess- Nests Nesting Feeding Feeding Roosting Feeding Roosting related to the table) ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

7. Mallard (Anas platyrhynchos) – nesting, migratory, passing, wintering species. IIt occupies varied damp areas. On the territory of the protected area „Mechka Fish-ponds” 7 (5-10) nesting couples, 318 (8-628) passing birds and 0-500 wintering birds having a summary assessment „D” have been registered. Not found in the location of the Investment Proposal but at low river levels it might be possible to use the sandpits for repose and roosting d uring migrations and wintering in the proximity to the reviewed site. Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Mallard (Anas Propagation Migration Wintering platyrhynchos) Birds In sites for In sites for In sites for Summary (see item 11 for explanations assess- Nests Nesting Feeding Feeding Roosting Feeding Roosting related to the table) ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)**

36 Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

8. Common Merganser (Mergus merganser) – passing and wintering species. It occupies varied wetlands along the Danuve river and the Black Sea Coast . On the territory of the protected area „Mechka Fish-ponds” 4 (0-8) wintering birds having a summary assessment „A” have been registered. Not found in the location of the Investment Proposal but at l ow river levels it might be possible to use the sandpits for repose and roosting during migrations and wintering in the proximity to the reviewed site. Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Common Merganser Propagation Migration Wintering (Mergus merganser) Birds In sites for In sites for In sites for Summary (see item 11 for explanations assess- Nests Nesting Feeding Feeding Roosting Feeding Roosting related to the table) mentа Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

9. Smew (Mergus albellus) – passing and wintering species. IItt occupies varied wetlands along the Danube river and the Black Sea Coast . On the territory of the protected area „Mechka Fish- ponds” 36 (2-71) wintering birds having a summary assessment „A” have been registered. Not found in the location of the Investment Proposal but at low river levels it might be possible to use the repose during migrations and wintering in the proximity to the reviewed site . Slight adverse impact is expected.

37 DEGREE OF IMPACT Propagation Migration Wintering Birds In sites for In sites for In sites for Summary Nests Assess- Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics

Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

10. Black Kite (Milvus migrans) – nesting, migratory, passing and partly wintering species listed in the Red Data Book of Bulgaria , 1985. It occupies varied woodland close to water bodies, open spaces. On the territory of the protected area „Mechka Fish-ponds” 2 birds during their reproductive period having a summary assessment „D” have been registered. Not found in the location of the Investment Proposal but it is possible to have separate couples nesting near it . Slight adverse impact is expected.

PA „Mechka Fish-ponds” DEGREE OF IMPACT Black Kite Propagation Migration Wintering (Milvus migrans) Birds In sites for In sites for In sites for Summary (see item 11 for explanations Assess- Nests Nesting Feeding Feeding Roosting Feeding Roosting related to the table) ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 2,8

38 11. White-tailed Eagle (Haliaeetus albicilla) – nesting, migratory, passing and wintering species listed in the Red Data Book of Bulgaria , 1985. It occupies varied woodland close to water bodies, open spaces. On the territory of the protected area „Mechka Fish-ponds” 1 nesting couple and 5 (2-7) wintering birds having a summary assessment „B” have been registered. Not found in the location of the Investment Proposal but at low river levels might be possible to use the водоеми during migrations and wintering in the proximity to the reviewed site . Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT White-tailed Eagle Propagation Migration Wintering (Haliaeetus albicilla) Birds In sites for In sites for In sites for Summary (see item 11 for explanations Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

12. Levant Sparrohawk (Accipiter brevipes) – nesting, migratory, passing species listed in the Red Data Book of Bulgaria, 1985. IIt occupies deciduous woodland, open spaces . On the territory of the protected area „Mechka Fish-ponds” 1 passing birds having a summary assessment „D” has been registered. Not found in the location of the Investment Proposal but it is possible to have separate couples nestng near it. Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Levant Sparrowhawk Propagation Migration Wintering (Accipiter brevipes) Birds In sites for In sites for In sites for Summary (see item 11 for explanations assess- Nests Nesting Feeding Feeding Roosting Feeding Roosting related to the table) ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 0,6 1,8 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 0,6 3,4

39 13. Lesser Spotted Eagle (Aquila pomarina) – nesting, migratory, passing and partly wintering species listed in the Red Data Book of Bulgaria , 1985. It occupies deciduous woodland, open spaces . On the territory of the protected area „Mechka Fish-ponds” 1 nesting couple and 10 passing birds having a summary assessment „B” have been registered. Not found in the location of the Investment Proposal but it is possible to use adjacent woodland for repose and roosting. Slight adverse impact is expected.

PA „Mechka Fish-ponds” DEGREE OF IMPACT Lesser Spotted Eagle (Aquila Propagation Migration Wintering pomarina) Summary (see item 11 for explanations Birds, In sites for In sites for In sites for nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 2,2

14. Osprey (Pandion haliaetus) – nesting, migratory, passing species listed in the Red Data Book of Bulgaria, 1985. It occupies varied wetlands. On the territory of the protected area „Mechka Fish- ponds” 2 (1-4) passing birds having a summary assessment „B” have been registered. Not found in the location of the Investment Proposal but it is possible to use adjacent woodland for repose and roosting during migrations. Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Osprey Propagation Migration Wintering (Pandion haliaetus) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 2,2

40 15. Little Ringed Plover (Charadrius dubius) – nesting, migratory, passing species listed in the Red Data Book of Bulgaria, 1985. It occupies deciduous woodland, open spaces, often near water bodies. On the territory of the protected area „Mechka Fish-ponds” 12 (10-15) passing birds having a summary assessment „B” have been registered. Not found in the location of the Investment Proposal but it is possible to have separate couples nesting on the near sandpits. Slight adverse impact is expected.

PA „Mechka Fish-ponds” DEGREE OF IMPACT Little Ringed Plover Propagation Migration Wintering (Charadrius dubius) Summary (see item 11 for explanations Birds, In sites for In sites for In sites for nests , assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

16. Eurasian Oystercatcher (Haematopus ostralegus) – nesting, migratory, passing and wintering species listed in the Red Data Book of Bulgaria , 1985. It occupies running and standing water bodies. On the territory of the protected area „Mechka Fish-ponds” separate passing birds having a summary assessment „D” have been registered. Not found in the location of the Investment Proposal but at low river levels it is possible to use the sandpits for re pose and roosting during migrations and wintering in the proximity of the reviewed site. Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Eurasian Oystercatcher Propagation Migration Wintering (Haematopus ostralegus) (see Summary item 11 for explanations Birds In sites for In sites for In sites for nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

41 17. Caspian Gull (Larus cachinnans) – nesting, migratory passing and wintering species . It occupies residential areas, water basins, cultivable areas. On the territory of the protected area „Mechka Fish-ponds” 22 passing and 100 wintering birds having a summary assessment „D” have been registered. Not found in the location of the Investment Proposal but at low river levels it is possible to use the sandpits for repose and roosting throughout the year in the proximity of the reviewed site. Slight adverse impact is expected .

PA„Mechka Fish-ponds” DEGREE OF IMPACT Caspian Gull (Larus Propagation Migration Wintering cachinnans) Birds, In sites for In sites for In sites for Summary (see item 11 for explanations nests, assessme related to the table) Nesting Feeding Feeding Roosting Feeding Roosting nt eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) Geograph. connection (0,8 t)

Total 0,3 0,3

18. Common Tern (Sterna hirundo) –nesting, migratory, passing species. It occupies running and standing water bodies. On the territory of the protected area „Mechka Fish-ponds” 9 (4-15) passing birds having a summary assessment „D” have been registered. Not found in the location of the Investment Proposal but it is possible to nest in colonies with little terns on sandpits for near it. Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Common Tern Propagation Migration Wintering (Sterna hirundo) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

42 19. Little Tern (Sterna albifrons) – nesting, migratory, passing species listed in the Red Data Book of Bulgaria, 1985. It occupies standing and running water bodies . On the territory of the protected area „Mechka Fish-ponds” 7 passing birds having a summary ass essment „D” have been registered. Not found in the location of the Investment Proposal but nesting is possible in colonies with little terns on sandpits near it. Slight adverse impact is expected .

PA „Mechka Fish-ponds” DEGREE OF IMPACT Little Tern (Sterna albifrons) Propagation Migration Wintering (see item 11 for explanations Summary related to the table) Birds In sites for In sites for In sites for Nests assess- Nesting Feeding Feeding Roosting Feeding Roosting ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 2,8

20. Caspian Tern (Sterna caspia) – passing species listed in the Red Data Book of Bulgaria , 1985. IIt occupies standing and running water bodies . On the territory of the protected area „Mechka Fish-ponds” 8 (7-10) passing birds having a summary assess ment „B” have been registered. Not found in the location of the Investment Proposal but at low river level might be possible to use sandpits for repose and roosting during migrations in the proximity of the reviewed site. Slight adverse impact is expected.

PA „Mechka Fish-ponds” DEGREE OF IMPACT Caspian Tern (Sterna caspia) Propagation Migration Wintering (see item 11 for explanations Summary related to the table) Birds In sites for In sites for In sites for Nests assess- Nesting Feeding Feeding Roosting Feeding Roosting ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 2,8

43 21. Common Kingfisher (Alcedo atthis) – regular species. It occupies varied water bodies. On the territory of the protected area “Mechka Fish -ponds” 2 nesting couples having a summary assessment D have been registered. Not found in on the location of the Investment Proposal but can be used for hunting; nesting of separate couples on the adjacent steep banks is also possible . Slight adverse impact is expected.

PA „Mechka Fish-ponds” DEGREE OF IMPACT Common Kingfisher Propagation Migration Wintering (Alcedo atthis) Birds In sites for In sites for In sites for Summary (see item 11 for explanations Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,3 0,3 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 0,3 0,3 2,8 22. Sand Martin (Riparia riparia) – nesting, migratory, passing species. It occupies coasts of running and standing water bodies . On the territory of the protected area “Mechka Fish -ponds” 500 nesting couples having a summary assessment A have been registered. Not found in on the location of the Investment Proposal but nesting of separate couples on the adjacent steep banks is possible . Slight adverse impact is expected.

PA „Mechka Fish-ponds” DEGREE OF IMPACT Sand Martin (Riparia riparia) Propagation Migration Wintering (see item 11 for explanations Summary related to the table) Birds In sites for In sites for In sites for Nests assess- Nesting Feeding Feeding Roosting Feeding Roosting ment Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,3 0,3 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 0,3 0,3 2,8

44 The adverse impact on the species subject of conservation in the protected area has been summarized in the below Table 5.1.2-2: Table 5.1.2-2. Summarized data about the number of affected bird species subject of conservation in the protected area by various categories of adverse impacts as a result of the implementation of the Investment Proposal.

Number of species subject of conservation Category of Adverse Impact % оf the total number of species in Protected Area “Mechka Fish-ponds” No impact 91 80,5 Slight impact 22 19,5 Medium impact 0 0 Significant impact 0 0 Total 113 100

As it can be seen from the above table the prevailing part (80,5%) of the species subject of conservation, shall not be adver sely affected as a result of the implementation of the Investment Proposal. 22 bird species shall be slightly affected . Suitable mitigating measures are recommended for them.

5.1.3. Description and analysis of the impact of th e investment proposal on the integrity of the protected area in terms of its structure , functions and nature conservation objectives (loss of habitats, fragmentation, disturbance of species, violation of the species composition, hydrogeological and geological changes etc.) during implementation and use of the investment proposal.

At assessment of the adverse impacts on the structure, functions and the nature conservation objectives the guidelines of the Еuropean Union (2011), especially developed for combining the extraction activities in the various types of quarries with the requirements of Natura 2000 have been taken into consideration.. 5.1.3.1. Structure No significant adverse impacts on the structure of the reviewed protection area are expected . 5.1.3.2. Functions and nature conservation objectives No significant adverse impacts on the functions and the nature conservation objectives of t he reviewed protection area are expected .

45 5.1.3.3. Loss of habitats The activities related to the extraction of sand and gravel from the river bed shall take a relatively small part of the aquatory of the protected area so th ere shall be no significant loss of habitats. 5.1.3.4. Fragmentation The birds which while flying overcome a number of terrestrial obstacles, are not affected by fragmentation as some other animal groups. Therefore no signifi cant adverse impacts are expected on them as a result of possible fragmentation. 5.1.3.5. Disturbance of the species In the Lower Danube sand and gravel have been extracted from the river bed for decades. There are no scientific articles about proven significant adverse impacts on the various hydrophilous bird species as a result of this activity . Our long-years observations show that the hydrophilous birds quickly adapt to the noise of the dredges as well as with the ship and barges that are making much more noise. 5.1.3.6. Violation of the species composition Not expected. 5.1.3.7. Chemical changes Not expected. 5.1.3.8. Hydrogeological changes Not expected. 5.1.3.9. Geological changes Not expected. 5.1.3.10. Other changes Not expected.

5.2. Protected area ROSPA0108 Vedea Dunare 5.2.1. On types of natural habitats There are no types of natural habitats subject of conservation in the protected area . 5.2.2. On species subject of conservation These species are 18 in total (16 hydrophilous species and 2 species of rapacious birds). The assessment of the adverse impact on the m is made in two stages. The first stage presents the adverse impact only in qualitative terms (not expected - expected) – Table 5.2.2-1.

46 Table 5.2.2-1. Expected adverse impact on the bird species subject of conservation under items 3 and 4 (listed in a general taxonomic order) in the protected are as a result of the implementation of the Investment Proposal. Designation in the column „Not expected because....”: 1. The species throughout the year or during a certain season is not found in the habitats that are part of the terrain of the Investment Proposal or in its immediate proximity . 2. The species can be found in the habitats that are part of the terrain of the Investment Proposal or in its immediate proximity but on irregular, episodic, random base an d / or is listed in the Standard Data Form for the protected area with a summary assessment D . 3. The species overall the year or during a certain season can be found on regular basis in the habitats that are part of the terrain of the Investment Proposal but does not use them because they are close to asphalt covered roads, residential areas or due to some other reason. 4. The species regularly just flies over the terrain of the Investment Proposal during feeding or migration. The species is synanthropic o r unsusceptible to anthropogenic impact resulting from the implementation of the Investment Proposal.

Summary Adverse impact assessment № Species subject of conservation in PA „Vedea Dunare” of the Not expected Standard Expected because: Data Form 1. Great White Pelican (Pelecanus onocrotalus) C 2 2. Dalmatian Pelican (Pelecanus crispus) B + 3. Pygmy Cormorant (Phalacrocorax pygmeus) A + 4. Little Bittern (Ixobrychus minutus) B 2 5. Squacco Heron (Ardeola ralloides) B 2 + 6. Little Egret (Egretta garzetta) B + 7. Great Egret (Egretta alba) B + 8. Purple Heron (Ardea purpurea) B + 9. Black Stork (Ciconia nigra) B + 10. White Stork (Ciconia ciconia) B + 11. Glossy Ibis (Plegadis falcinellus) B + 12. Eurasian Spoonbill (Platalea leucorodia) B + 13. Western Marsh-harrier (Circus aeruginosus) B 2 14. Hen harrier (Circus cyaneus) B 2 15. Pied Avocet (Recurvirostra avosetta) B + 16. Black-winged Stilt (Himantopus himantopus) B + 17. Ferruginous Duck (Aythya nyroca) B 2 18. Common Kingfisher (Alcedo atthis) B + Total 18 6 13

47 In order to determine the degree in quantitative terms to which they can be affecte d adversely during the second stage the 13 species subject of conservation from the above table are described in a taxonomic order as follows: 1. Dalmatian Pelican (Pelecanus crispus) – nesting, migratory, passing, wintering species listed in the Red Data Book of Romana (category xxxx); globally endangered species. It occupies natural and artificial standing water bodies along the Lower Danube and the Black Sea Coast and the adjacent damp areas. On the territory of the protected area it is rarely registered during migrations having a summary assessment „B” . Not found on the terrain of the Investment Proposal but might be possible to use sandpits for repose and roosting during migrations . Slight adverse impact is expected. PA „Vedea Dunare” DEGREE OF IMPACT Dalmatian Pelican Pelecanus crispus Propagation Migration Wintering (see item 11 for explanations Summary related to the table) small In sites for In sites for In sites for assessme nests Nesting Feeding Feeding Roosting Feeding Roosting nt eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,9 0,9 1,8 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8 Total 0,9 0,9 3,4

2. Pygmy cormorant (Phalacrocorax pygmeus) – nesting, migratory, passing, wintering species listed in the Red Data Book of Romana (category vulnerable). It occupies varied wetlands. On the territory of the protected area “Vedea Dunare” more than 240 wintering and more than 1000 passing birds having a summary assessment „A” have been registered. Not found on the terrain of the Investment Proposal but the data from the Standard Data Form show an availability of a place of repose and roosting. Most probably it is located on a nameless island opposite the Mechka Fish - ponds which use the species for food. Slight adverse impact is expected .

48 PA „Vedea Dunare” DEGREE OF IMPACT Pygmy cormorant Propagation Migration Wintering (Phalacrocorax pygmeus) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 2,4 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 4,0

3. Squacco Heron (Ardeola ralloides) – nesting, migratory, passing, species listed in the Red Data Book of Romania (category vulnerable). It occupies varied wetlands. On the territory of the protected area “Vedea Dunare” 50-60 nesting couples having a summary assessment „B” have been registered. Not found on the terrain of the Investment Proposal but there is data about a mixed colony in the region of pygmy cormorants, areas and Eurasian spoonbills. Slight adverse impact is expected.

PA „Vedea Dunare” DEGREE OF IMPACT Squacco Heron (Ardeola Propagation Migration Wintering ralloides) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assessme related to the table) Nesting Feeding Feeding Roosting Feeding Roosting nt eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 0,6 0,6 2,4 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8 0,6 0,6 0,6 0,6 Total 4,0

4. Little Egret (Egretta garzetta) – nesting, migratory, passing species listed in the Red Data Book of Romania (category periclitata ). It occupies varied wetlands. On the territory of the protected area “Vedea Dunare” unknown number of passing birds having a summary assessment „B” has been

49 registered. Not found on the terrain of the Investment Proposal but in the region there is data about a mixed colony of pygmy cormorants, areas and Eurasian spoonbills. Slight adverse impact is expected.

PA „Vedea Dunare” DEGREE OF IMPACT Little Egret Propagation Migration Wintering (Egretta garzetta) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 2,8

5. Great Egret (Egretta alba) – nesting, migratory, passing and wintering species listed in the Red Data Book of Romania (category periclitata ). It occupies varied wetlands. On the territory o f the protected area “Vedea Dunare” more than 26 nesting couples having a summary assessment „B” have been registered. Not found on the terrain of the Investment Proposal but there is data that in the region about a mixed colony of pygmy cormorants, areas and Eurasian spoonbills. It is possible that it uses the terrain of the Investment Proposal for feeding. Slight adverse impact is expected .

PA „Vedea Dunare” DEGREE OF IMPACT Great Egret (Egretta alba) Propagation Migration Wintering (see item 11 for explanations Summary related to the table) Birds In sites for In sites for In sites for nests Assess- Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 06 0,6 0,6 1,8 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 0,6 3,4

50 6. Purple Heron (Ardea purpurea) – nesting, migratory, passing species listed in the Red Data Book of Romania (category periclitata ). It occupies varied wetlands. On the territory of the protected area “Vedea Dunare” a nesting couple having a summary assessment „B” has been registered. Not found on the terrain of the Investment Proposal but it is possible that it uses the terrain of the Investment Proposal for feeding. Slight adverse impact is expected .

PA „Vedea Dunare” DEGREE OF IMPACT Purple Heron Propagation Migration Wintering (Ardea purpurea) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 0,6 0,6 2,4 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 0,6 0,6 4,0

7. Black stork (Ciconia nigra) – nesting, migratory, passing species listed in the Red Data Book of Romania (category vulnerable ). It occupies rocky areas, deciduous and coniferous woodlands, varied wetlands. On the territory of the protected area “Vedea Dunare” 8-10 nesting couples and more than 48 passing birds having a summary assessment „B” have been registered. Not found on the terrain of the Investment Proposal but nesting of separate couples near it is possible. Slight adverse impact is expected.

PA „Vedea Dunare” DEGREE OF IMPACT Black stork Propagation Migration Wintering Summary (Ciconia nigra) Birds In sites for In sites for In sites for assess- (see item 11 for explanations ment related to the table) Nests Nesting Feeding Feeding Roosting Feeding Roosting eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,8

51 8. White Stork (Ciconia ciconia) – nesting migratory, pasing and wintering species listed in the Red Data Book of Romania (category vulnerable). It occupies vast wetlands with thick vegetation . On the territory of the protected area „Vedea Dunare” 12-24 nesting couples as well as passing and wintering birds having a summary assessment В have been registered. Not found on the terrain of the Investment Proposal. Slight adverse impact is expected.

PA „Vedea Dunare” DEGREE OF IMPACT White Stork Propagation Migration Wintering (Ciconia ciconia) Birds In sites for In sites for In sites for Summary (see item 11 for explanations Nests assess- related to the table) eggs Nesting Feeding Feeding Roosting Feeding Roosting ment Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 2,2

9. Eurasian Spoonbill (Platalea leucorodia) – nesting migratory, passing and by exceptio n wintering species from the Red Data Book of Romania (category periclitata). It occupies varied wetlands. On the territory of the protected area „Vedea Dunare” unknown number of passing birds having a summary assessment „В” has been registered. Not found in the terrain of the Investment Proposal but it is possible to use it for feeding. Slight adverse impact is expected.

PA „Vedea Dunare” DEGREE OF IMPACT Eurasian Spoonbill Propagation Migration Wintering (Platalea leucorodia) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 1,8 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 3,4

52 10. Glossy Ibis (Plegadis falcinellus) – nesting, migratory, passing speci es listed in the Red data Book of Romania (category vulnerable). It occupies varied wetlands. On the territory of the protected area „Vedea Dunare” passing birds having a summary assessment „B” have been registered. Not found in the location of the Investm ent Proposal but it is possible to use sandpits in the proximity for repose and roosting during migrations. Slight adverse impact is expected.

PA „Vedea Dunare” DEGREE OF IMPACT Glossy Ibis Propagation Migration Wintering (Plegadis falcinellus) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,6 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8 0,3 Total 0,3 0,3 2,2

11. Pied Avocet (Recurvirostra avosetta) – nesting, migratory, passing and partly wintering species from the Red Data Book of Romania (category vulnerable). It occupies standing and running water bodies. On the territory of the protected area „Vedea Dunare” only passing birds having a summary assessment „В” have been registered. Not found in the location of the Investment Proposal but it is possible to use the sandpits in the proximity for repose and roosting during migrations . Slight adverse impact is expected .

PA „Vedea Dunare” DEGREE OF IMPACT Pied Avocet Propagation Migration Wintering (Recurvirostra avosetta) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests assess- related to the table) Nesting Feeding Feeding Roosting Feeding Roosting ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 2,8

53 12. Black-winged Stilt (Himantopus himantopus) – nesting, migratory, passing species listed in the Red Data Book of Romania (category pericilata). It occupies standing water bodies . On the territory of the protected area „Vedea Dunare” 6-7 nesting couples having a summary assessment „В”. Not found in the location of the Investment Proposal but it is possible to use the sandpits in the proximity for repose and roosting during migrations . Slight adverse impact is expected .

PA „Vedea Dunare” DEGREE OF IMPACT Black-winged Stilt Propagation Migration Wintering (Himantopus himantopus) Summary (see item 11 for explanations Birds In sites for In sites for In sites for Nests Assessme related to the table) Nesting Feeding Feeding Roosting Feeding Roosting nt Eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,6 0,6 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,6 0,6 2,8

13. Common Kingfisher (Alcedo atthis) – regular species. It occupies veried water bodies. On the territory of the protected area „Vedea Dunare” more than 12 nesting couples having a summary assessment „С” have been registered. Not found in the location of the Investment Proposal but nesting of separate couples on the steep banks is possible. Slight adverse impact is expected.

PA „Vedea Dunare” DEGREE OF IMPACT Common Kingfisher (Alcedo Propagation Migration Wintering atthis) Birds In sites for In sites for In sites for Summary (see item 11 for explanations Assess- Nests Nesting Feeding Feeding Roosting Feeding Roosting related to the table) ment eggs Thermics Extinction (0,8 t) Damage(0,5 t)** Aggravation (0,3 t)** 0,3 0,3 0,3 0,3 1,2 Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) 0,8 Geograph. connection (0,8 t) 0,8

Total 0,3 0,3 0,3 0,3 2,8

54 The adverse impact on the species subject to conservatio n in the protected area is summarized in Table 5.2-2: Table 5.2-2. Summarized data about the number of affected bird species subject of conservation in the protected area by various categories of adverse impacts as a result of the implementation of the Investment Proposal.

Category of adverse impact Nuber of species subject of conservation in % of the total number of species PA “Vedea Dunare” No impact 6 33,3 Slight Impact 12 66,7 Medium impact 0 0 Significant impact 0 0 Total 18 100

As it can be seen from the above table 6 species or 33,3% of the species subject of conservation shall not be adversely affected by the implementation of the Investment proposal. 13 bird species shall be slightly affected. Suitable mitigating measures a re recommended for them.

5.2.3. Description and analysis of the impact of the investment proposal on the integrity of the protected area in terms of its structure, functions and nature conservation objectives (loss of habitats, fragmentation, disturbance of species, violation of the species composition, chemical, hydrogeological and geological changes etc. ) during the implementation and the use of the Investment Proposal

When assessing the adverse impacts on the structure, fun ctions and nature conservation objectives the guidelines of the Еuropean Union (2011) have been taken into consideration , that are developed in relation with combining of extraction activities in the various types of quarries with the requirements of Natura 2000. 5.2.3.1. Structure Significant adverse impacts on the structure of the reviewed protected area are not expected. 5.2.3.2. Functions and Nature Conservation Objectives No significant adverse impacts on the functions and the nature conservation objectives of the reviewed protection area are expected .

55 5.2.3.3. Loss of habitats The activities related to the extraction of sand and gravel from the river bed sha ll take a relatively small part of the aquatory of the protected area so there shall be no significant loss of habitats.

5.2.3.4. Fragmentation . The birds which while flying overcome a number of terrestrial obstacles, are n ot affected by fragmentation as some other animal groups. Therefore no significant adverse impacts are expected on them as a result of possible fragmentation.

5.2.3.5. Disturbance of the species In the Lower Danube sand and gravel have been extracted from the river bed for decades. There are no scientific articles about proven significant adverse impacts on the various hydrophilous bird species as a result of this activity . Our many years observations show that the hydrophi lous birds quickly adapt to the noise of the dredges as well as to the ship and barges that are making much more noise.

5.2.3.6. Violation of species composition Not expected. 5.2.3.7. Chemical changes Not expected. 5.2.3.8. Hydrogeological changes Not expected. 5.2.3.9. Geological changes Not expected. 5.2.3.10. Other changes Not expected. 5.3. Protected area ROSCI0088 Gura Vedei-Saica-Slobozia 5.3.1. Natural habitats type On the territory of the protected area only one habitat under Directive 92/43/ЕЕС has been established:

56  92А0 – riverside galleries of Salix alba and Populus alba. The following conclusions can be made about the habitats that can be found on the territory of the protected area: Habitat 92А0 Riverside galleries of Salix alba and Populus alba is not found on the territory of the Investment Proposal and there shall be no impact on its integrity and species diversity . 5.3.2. Species subject of conservation In the protected area no plant species of conservation importance and subjec t of conservation according to the Standard Data Form have been registered. Such species have not been established within the Investment Proposal and the adjacent regions . Therefore, we believe that the Investment Proposal shall not have a direct or indire ct adverse impact on the strength of its populations and the habitats. Presumptions for negative impacts on animal species subject of conservation in PA “Gura Vedei-Saica-Slobozia”, can be made for all fish species, amphibians and amphibian reptiles, as we ll as for the otter of the mammal species. In the description and analysis of the protected species (items 4.3.1 and 4.3.1.2), subject of conservation reflecting the elements of the Investment Proposal , an analytical comment was given regarding the possibl e impacts; the species that can not be found or do not refer to the implementation of the measure are excluded from the list. The analysis is limited to the fish species and particularly to the otter from the species of mammals. The fish species subject of conservation in the protected area can be divided into a couple of environmental groups depending on their requirements to the conditions of the environment. The Danube mackerel is a migratory species that can be found in the river in two bioecological f orms. One of them, the cryophilic one, usually spawns in the beginning of May by the end of June, while the smaller, more thermophicil one – from the middle of June to the end of July. This species moves in the thick river bed in unidimensional passages an d spawns when finding suitable places . The spawn is pelagic and floats in the upper water layers . After spawning the larvae are fed with rotatoria and algae floating passively upstream the river . The only impact on the spawn and the larvae is the muddling of the water in the stream sector located behind the dredging -machine. At sand extraction along with the running water small particles are also taken away that change the transparency of the water and its mechanical content until their sedimentation . Such an impact can be neglected due to two reasons: the scope of impact is quite small and insignificant , up to a few dozens of meters after the end of the facility and the availabilty of a muddying in the water brings to insignificant spacious changes and relocation of the generative passage to an adjacent section. No special research has been conducted for this impact on the generative behavior of the passage fish and their response but it can be firmly stated that so far irrespective of the random sand extrac tion in all parts of the river bed

57 along the entire Bulgarian sector, no drastic changes in the species stock have been observed. An assessment of the stocks is made according to the annual reports of the Executive Agency of Fishery and Aquacultures on the currents that vary between 20 and 25 tons on annual basis during the recent 10 years observing no abrupt changes . From the species subject of conservation the asp has similar ecological requirements to the environment. This numerous predatory species in the past became rare in many European countries . In the Danube river the species has a relative high and permanent density, which according to the specialists is due to the cleaning of the waters from surface light polluters and specific reproductive habitats – sections of stony bottom. Specialized and particular research on the species has not been conducted in Bulgaria but is known that its spawn is planctonik and floats among the stones of the lower water layers. In the past the pollution of the surface water with oil products from shipping was pointed out as the main reason for its reduction . This predator chases its victims – small fish in the upper water layers, most actively in the morning – at sunrise and in the evening – at sunset. Having in mind the biological and ecological requirements of the species , the only threat in case of implementation of the Investment Proposal is an occurrence of emergency situations with a spill of fuels and lubricants from the sand extraction facilities . Such incidents are inadmissible and the risk can be reduced if the applicable laws and regulations regarding the technical condition of the vessels are complied with. Very similar biology and ecology to that of the lamprey have the two target species of loaches (mudfish and spined loach) and the weatherfish (Misgurnis fossilis) . These small mudfish with snaky form dig the muddy and sandy river bottom at the coastal sectors where the current is relatively slow. Therefore we think that the Investment Proposal shall not ha ve an adverse impact on them. In terms of reproduction similarly to the lamprey they concentrate in reproductive passages and come together to the small rivers of the Danube basin . In addition we could say that the species Cobites taenia – known in as spotted weather loach has never been found in the Danube river and Bulgaria. This northern species is found in North Europe. According to Kottelat, M. & J. Freyhof (2007) for the Danube river the species Cobites taenia is wrongly reported an d is mistaken with the species Cobites elongatoides Bacescu & Maier, 1969, that can largely be found in the Danube basin. Out of the species subject of conservation in the area to the group of the deep-water fish we can add another four species – the two species of strebers (the small and the big one) and the two species of ruffes (striped ruffe and и Balon’s ruffe). These target fish occupy the parts of the river with high water column and large -gravel bottom. They are mostly active at night when they leav e their cavities and go to the shoals for finding food . They mainly eat various spineless organisms and

58 small fish. For these species the implementation of the Investment proposal might have an adverse impact though strongly limited. During sand extraction these species could not be able to habituate the area although it is a question of a few dozens of meters per day . Another threat during the reproduction period is the destruction of spawn. The biology and ecology of these fish is not well investigated but yet it is known that they reproduce in deep sections of the river with large -gravel bottom. The impact shall be limited to the area of the sand extraction and to a few dozens of meters away. This type of impact is valid for all dredging machines used in the Danube river which presently are more than 100; for most of the sectors for inert materials extraction no ecological procedures related to the assessment of the impact on the environment and Compatibility Assessment Report have been undertaken which hi nders the possibility to assess the cumulative effect and take adequate measures connected with seasonal or other prohibitions. The lack of any scientific and practical research about the influence and the impact on the hydrobiotic fauna at removal of inert materials and increase of water opaqueness does not allow us to make a thorough and in -depth analyses regarding the possible adverse effect resulting from such activities. It is a well -known fact that when the water opaqueness is reduced, as well as othe r physical and mechanical characteristics, fish stop reproducing and wait for the water parameters to stabilize . Another known fact is that increased content of organic impurities and precipitation on the bottom kill the spawn eggs adapted to grow on sandy bottom cover. According to the species lists this is one of the main reasons for the low survival rate of the spawn eggs with all fish species of similar egg growth . At dredging the muddy surface layer is removed from the river bed that can be considered as cleaning of the river bed and creation of suitable conditions for reproduction of mudfish species . Similar measures for cleaning of the river beds aiming at restoring the sturgeon species have been undertaken in North America. Further research in these sections confirm that the effect of the measures has been positive and the survival rate of the spawn has increased. Such an effect can be expected also from sand extraction in the particular Investment Proposal. The last target fish species for the prote cted area is the White-finned Gudgeon. This small fish lives at the bottom but avoids the deep parts of the river because of the strong resistance of the water at high water column. The preferred places are the shallow swift currents with stony and sandy bottoms where it lives and feeds just like the group of the “The Mediterranean Barbels”. These habitats are the places where this fish also reproduces, its spawn is psammophilic . The aquatory subject of discussion does not have such characteristics, therefo re we think that the species shall not be affected as a result of the implementation of the Investment Proposal. The otter is the only mammal subject of conservation in the Protected areas, which because of itsamphibiotic way of living might be affected a s a result of the implementation of the Investment

59 Proposal. The biological and ecological characteristics of this animal are connected with the hunting of hydrobionts mainly in the coastal part of the big rivers and in the whole bed of the small rivers . For the big rivers it is known that the two coasts are habituated by various specimen which is connected with the big river spaces and distances between the two banks as well as with the relatively strong water currents. Even for a good swimmer like the ot ter, the swimming of 1,5 – 2 km between the tow banks of a river is connected with a large energy consumption which is totally unnecessary. The research conducted in other parts of the Danube river shows that for this river the otters habituating the coast do not move even to islands hundres of meters away , which allows other specimen to live there without entering into an interspecific competition . This is connected not only with the big distances but also with the trophic provision of the big rivers. The section of the river where it is planned to extract ballast from the bottom is located close to the shipping route , where the current is very strong. Such sections are very unwanted and avoided by the otter . Only in case of movement it is possible to have occasional specimen within the area of the Investment Proposal , but even in such cases the ballast extraction activities are not dangerous for the animal. The animals avoid the close unknown noise that would move away the animal from the dredging buckets. The noise generated by the facilities shall not change the current situation having in mind the permanent generation of similar noise by the frequently passing ship . We think that the impacts on this species shall be insignificant and extremely small . 5.3.3.Description and analysis of the impact of the investment proposal on the integrity of the protected area in terms of its structure, functions and nature conservation objectives (loss of habitats, fragmentation, disturbance of species, violation of the species composition, chemical, hydrogeological and geological changes etc .) during the implementation and the use of the Investment Proposal 5.3.3.1. Structure The implementation of the Investmen t Proposal related to „extraction of sand and gravel from alluvial deposits in the bed of the Danube river , Kama section (km 510.5 – km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality”, shall not have a negative impact on the structure of area ROSCI0088 Gura Vedei-Saica-Slobozia under Directive on the habitats due to the following reasons: 1. The sections of extraction of inert materials in the reviewed Investment proposal are located in the bed of the Danube river, the extraction of inert materials shall be done under water, while the transportation – by water. Therefore it is unlikely to affect the natural habitats by direct or indirect impacts caused by the elements of the Investment Proposal.

60 2. No protected natural habitats have been regi stered on the territory of the Investment Proposal. 3. It is not expected to reduce the area of any protected habitat in the area . The habitats located in the proximity having codes 3130 and 91Е0* are not expected to be affected. 4. On the territory of the regions adjacent to the Investment Proposal no target plant species or their habitats have been established . The possible implementation of the Investment Proposal would not influence the stru cture of the Protected Area in regards of animal species subject of conservation due to the following reasons : 1. The extraction of inert materials from the river bed is an old practice and is usually belittled, for most of them no permits are required from t he competent authorities of the Ministry of Environment and Water. So far there has been no evidence of negative role of such activities on the biological diversity of the hydrofauna as well as on the protected species listed in the annexes of the Biological Diversity Act. 2. The extraction areas are insignificantly small compared to the total area of the river and are close to the channel line where the strong current and the high water column does not allow the normal existence of most of the species. 3. It is unlikely to meet protected species in the aquatory of the Investment Proposal with the exception of sturgeon during its reproductive period but they are not a subject of conservation in the particular area. 4. The structure of the benthos hydrocenoses is adve rsely impacted to a great extent by the invasive mollusca species – mussels and the implementation of the Investment proposal may have a positive effect on the cleaning up to the bottom in this sector from the accumulated organic matter and invasive species of high density. 5.3.3.2. Functions and nature conservation objectives The functional implementation of the Investment Proposal shall not impact area ROSCI0088 Gura Vedei-Saica-Slobozia under the Directive on Habitats due t o the following reasons: 1. The Investment Proposal does not plan destruction of a protected habitat under the meaning of the Biological Diversity Act . 2. The Investment Proposal does not plan any impact on the populations of the species subject of conservation that may have negative influence on their density, strength and functional structure. 3. The possible implementation of the Investment proposal may have a positive effect on the functions of the Protected area in view of creating a habitat suitable for reprod uction of mudfish species as a result of its cleaning up from organic deposits and invasive species .

61 4. For the animal species the nature conservation objectives would improve as a result of the recovery of habitat that the hydrobionts may use as an environme nt to habituate, reproduce and normal development of the benthos hydrocenoses. 5.3.3.3. Loss of habitats The Contracting authority has coordinated the investment proposals with the Executive Agency For Exploration and Maintenance of the Danube River in relation with the performance of extraction works. The Investment Proposal stipulates compliance with the required distance of the working platforms from the Bulgarian coast in order to avoid erosion as a result of the extractio n works. Taking this into consideration, the implementation of the Investment Proposal is not expected to lead directly or indirectly to loss of habitats in the protected area. For the animal species loss of habitats is not planned taking into consideratio n the present status of the average current where the ship passes. So far it has not been scientifically proven that these measures have a restrictive role for the hydrobionats. The activities may lead to recovery mainly for the deep water rheophilic fish space for feeding and reproduction. 5.3.3.4. Fragmentation The location and size of the sectors do not presume fragmentation of the Protected area for any of the components subject of conservation in the area. 5.3.3.5. Disturbance of species No disturbance of species is expected because of the specifics and the location of the Investment Proposal. This factor influences the birds and mammals . From the species of mammals subject of conservation none is connected with aquatic environment excepting the otter. There are many cases of night visits of this species in anchored piers and barges which completely excludes the factor of disturbance of this species. 5.3.3.6. Violation of species composition Such an impact is not expected on any of the target species subject of conservation in the Protected area. Not expected for the animal species excepting the invasive mussels . It is probable that protected mollusca fall into the dredging buckets but they are not subject of conservation in this area. 5.3.3.7. Chemical changes Not expected. 5.3.3.8. Hydrogeological changes Not expected.

62 5.3.3.9. Geological changes Not expected. 5.3.3.10. Other Changes It is expected to increase the depth in the area of the Investment Proposal which may have a positive effect due to two reasons : cleaning of the organic deposit , disastrous for the spawn of mudfish and improvement of the suitable conditions for reproduction of all rare mudfish . 6. Mitigation measures 6.1. Protected area BGSPA000002024 Mechka Fish -ponds 6.1.1. During the design stage It is required to strictly observe the distances from the coasts of the Kama island and the river itself. This will ensure the conservation of the riverbank and keep the fauna that inhabits it undisturbed. Under no circumstances should it be provided for the withdrawal of island and c oastal areas that are already permanently situated and are overgrown with dense vegetation in various stages of development. 6.1.2. During the construction stage Before the commencement of the construction activities the workers and the employees of the contractor should be instructed on the objectives, the subject of conservation and the prohibitions in the protected area. It is not allowed for the workers and the employees of the contractor company to carry and use hunting weapons onboard the navigation v essels and the machinery for extraction of inert materials. For the transportation of people and freights between the navigation vessels and the machinery and the shore, the same route approved by the competent authorities should be used . 6.1.3. During the operating period Periodical monitoring of the condition of the Bulgarian coastline should be performed and in case of possible activation of the natural erosion activity, immediate action should be taken. If necessary, the dredging volumes should be reduc ed or the operations should be discontinued. Expected impact: Preventing even a minimal chance of coastal erosion in the area of the work site. Harmless effect on areas of habitat 91EO. Annually in early spring, research on the benthic fauna should be made , and if necessary, the workers should be acquainted with the endangered species of molluscs. Funds for these activities should be provided by the investor. In establishing nesting colonies of birds near the area of the IP , prompt and timely action should be taken to ensure the birds’ calm and their offspring’s survival. For this purpose an inspection

63 should be performed by an expert ornithologist who can recommend specific measures in accordance with the established facts. Since during the dredging it is l ikely that demersal fish species and those that move near the bottom would be affected, during the breeding period of the sturgeons the dredging works should be carried out at the lower part of the section ( in relation to the flow) of the operating layers. 6.2. Protected area ROSPA0108 Vedea Dunare • Before commencement of the activities on the area of the IP the workers and the employees of the contractor should be instructed on the requirements for work adjacent to areas protected under the Natura 2000 a nd the environmental protection, in order to prevent harm to the flora and fauna in the region; • It is required to ensure the optimal operation of the machines, in order to keep the air pollution with harmful emissions and dust to a minimum. • The disposal of household and food waste that could lead to contamination or poisoning of the water and representatives of the flora and the fauna should not be allowed. The waste should be collected in the respective containers and transported to a landfill designated by the municipality; • Spills of fuels and lubricants from machinery should not be allowed. • The fire safety rules should be observed; • The workers and the employees of the contractor should not be allowed to carry and use hunting weapons onboard the navigation vessels and the machinery for extraction of inert materials. • For the transportation of people and freights between the navigation vessels and the machinery and the shore, the same route approved by the competent authorities should be used; • In cases of establishing nesting colonies of birds near the area of the IP , prompt and timely action should be taken to ensure the birds’ calm and their offspring’s survival. For this purpose an inspection should be performed by an expert ornithologist who can recommend specific measures in accordance with the established facts; • Since during the dredging it is likely that demersal fish species and those that move near the bottom would be affected, during the breeding period of the sturgeons the dredging works should be carried out at the lower part of the section ( in relation to the flow) of the operating layers;

64 6.3. Protected area ROSCI0088 Gura Vedei -Saica-Slobozia • Before commencement of the activities on the area of the IP the workers and the employees of the contractor should be instructed on the requirements for work adjacent to areas protected under the Natura 2000 and the environmental protection, in order to prevent harm to the flora and fauna in the region; • It is required to ensure the optimal operation of the machines, in order to keep the air pollution with harmful emissions and dust to a minimum. • The disposal of household and food waste that could lead to contamination or poisoning of the water and representatives of the flora and the faun a should not be allowed. The waste should be collected in the respective containers and transported to a landfill designated by the municipality; • Spills of fuels and lubricants from machinery should not be allowed. • The fire safety rules should be obser ved; • The workers and the employees of the contractor should not be allowed to carry and use hunting weapons onboard the navigation vessels and the machinery for extraction of inert materials. • For the transportation of people and freights between the na vigation vessels and the machinery and the shore, the same route approved by the competent authorities should be used; • In cases of establishing nesting colonies of birds near the area of the IP , prompt and timely action should be taken to ensure the bird s’ calm and their offspring’s survival. For this purpose an inspection should be performed by an expert ornithologist who can recommend specific measures in accordance with the established facts;  • Since during the dredging it is likely that demersal fish species and those that move near the bottom would be affected, during the breeding period of the sturgeons the dredging works should be carried out at the lower part of the section ( in relation to the flow) of the operating layers. 7. Alternative solutions and evaluation of their impact Zero Alternative The Zero Alternative is discussed in detail in Section 3.3 of the Environmental Impact Assessment Report of the Investment Proposal. Here we would like to add that this alternative would not have a positive impact on the target fauna, given the strong degradation processes that have occurred as a result of the accumulation of

65 organic matter and siltation of the bottom. Self -purification is not expected, therefore poor environmental conditions will continue f or the hydrobionts. In implementing of the IP it is likely to improve the environmental conditions and the right conditions for the propagation of the demersal fish species to arise, and the hydrocenoses to normalize.

Alternative locations We have examined several sites for extraction of aggregates/inert materials in the region, which have subsequently been declined for various reasons. This leaves only the following alternative: Extraction of sand and gravel from alluvial deposits in the bed of the Danube River, Kama section (km 510.5 - km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria. If necessary, adjustments should be made in order to observe strictly the distances from the coasts of the islands and the river, and from t he protected areas ROSPA0108 Vedea Dunare and ROSCI0088 Gura Vedei-Saica-Slobozia.

66 8. Map material

Fig. 8-1. Satellite image with the location of the IP in relation to the sites in Romania and Bulgaria protected under Natura 2000 (the boundaries of ROSP A0108 Vedea Dunare are in green, the boundaries of ROSCI0088 Gura Vedei -Saica-Slobozia are in red and the boundaries of BGSPA0002024 Mechka Fish-ponds are in yellow) 9. Conclusions about the nature and degree of impact on both protected areas 9.1. Characteristics of the Investment Proposal The Investment Proposal/Project envisages extraction of inert materials from the river bed of the Danube River between km 510.5 and km 508.0 in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria.

67 The storage site is common and it is located in an urbanized area of the town of Ruse. The hauling of the inert materials will be executed by barges from the place of extraction to the place of unloading and processing. The area of the IP is bordered on the north by two protected areas under Natura 2000 (ROSPA0108 Vedea Dunare, ROSCI0088 Gura Vedei -Saica-Slobozia), and the protected area BGSPA0002024 Mechka Fish-ponds is located about 4 km west of it . 9.2. Characteristics of other plans, programs and projects/inve stment proposals, existing and/or in the stage of development or approval, which in combination with the evaluated Investment Proposal may have an adverse impact on the protected areas concerned In the area of the IP there are no similar IP that would have a negative cumulative effect. The cumulative effect of the impacts in the Danube is difficult to assess, given their divergence and largely unknown character. Many IP are not registered by the competent authorities, which eliminates them as participants i n the assessment of possible irritants or impacts. Others have not passed any procedures under the Bulgarian legislation for the EC, EIA and compatibility assessment report. Such are most of the quarries for extraction of sand from the bed of the Danube . 9.3. Characteristics of the protected areas Protected area BGSPA0002024 Mechka Fish-ponds declared by Order No. РД -561, dated 5th September 2008, published in the State Gazette issue No. 84, dated 26 th September, 2008. According to the order its total area is 2582.34 ha. The subject of protection in it are 113 species of waterfowl mainly. The wetlands along the Bul garian coast are the most important for their conservation. In the past there were large marshes, now converted into fishponds, many of which are abandoned. The water area of the Danube where the extraction of aggregates/inert materials is envisaged to be executed is of secondary importance for the birds that are under conservation. Protected area ROSPA0108 Vedea Dunare is situated on the left bank of the Danube between river km 494 and 541, as well as part of a large river from the mouth to the vicinity of the village of Cervenia. It includes a strip about 5 km wide from the floodplain of the Danube. The marshes that were numerous in the past are now drained as a result of the construction of a large embankment. They now occupy only 3% of its area, up to 22 ,874.4 ha. The subject of protection there are 18 species of waterfowl mainly. Protected area ROSCI0088 Gura Vedei -Saica-Slobozia is situated on the left bank of the Danube and it partly overlaps with the protected area ROSPA0108 Vedea Dunare (see Section 8). It was declared under Directive 92/43/EEC with code ROSCI0088 in the State Gazette, Part 1, No 98

68 dated 7th February, 2008 (Monitorul oficial al României, Partea I, Nr. 98th bis/7.II.2008) and covers an area of 5813,00 ha. 9.4. Area of impact 9.4.1. Protected area BGSPA0002024 Mechka Fish -ponds As stated above, this protected area is located about 4 km west of the area of the IP. Therefore 9.4.2. Protected area ROSPA0108 Vedea Dunare The area of impact of the IP on the birds will spread very close to the equipment for raking of the inert materials and it will cover water area with a radius of about 150 m. It is expected that six species or 33.3% of the species subject to conservation will not be negatively affected by the possible implementation of the IP. To a small extent 13 species of birds will be affected. Appropriate mitigation measures are recommended for them . 9.4.3. Protected area ROSCI0088 Gura Vedei -Saica-Slobozia It is not expected the types of habitats that are subject of conservation in th e protected area to be negatively affected. Depletion and extraction of the aggregates/inert materials is envisaged, which will lead to a positive effect due to the removal of the organic sediment, and also due to the destruction of the invasive molluscs. The creating of a deep area near the island shore may have a positive effect on the propagation of the deep-water species, including the sturgeons, and some objectives of conservation in the area. The probability of a specimen, from a species that is subje ct to conservation, to be affected is insignificant and negligible . 9.5. Degree of impact on natural habitat types 9.5.1. Protected area BGSPA0002024 Mechka Fish -ponds It is not expected as no habitat types that are subject to conservation are listed in t he standard data form of this protected area. 9.5.2. Protected area ROSPA0108 Vedea Dunare It is not expected as no habitat types that are subject to conservation are listed in the standard data form of this protected area. 9.5.3. Protected area ROSCI0088 Gura Vedei-Saica-Slobozia It is not expected, as in this protected area there is only one habitat type that is subject to conservation and it will not be negatively affected .

69 9.6. Degree of impact on habitats and populations of the species subject of conservation 9.6.1. Protected area BGSPA0002024 Mechka Fish -ponds Due to the relatively large distance of this protected area from the area of the IP the majority (80.5%) of the species that are subject of conservation will not be negatively affected by the pos sible implementation of the IP. To a small extent 22 species of birds may be affected. Appropriate mitigation measures are recommended for them . 9.6.2. Protected area ROSPA0108 Vedea Dunare It is expected that six species or 33.3% of the species subject of conservation will not be negatively affected by the possible implementation of the IP. To a small extent 13 species of birds will be affected. Appropriate mitigation measures are recommended for them . 9.6.3. Protected area ROSCI0088 Gura Vedei -Saica-Slobozia Direct or indirect negative impact on the natural habitat subject of conservation in the protected area is not expected. 9.7. Impacts on the conservation objectives and the integrity of the protected areas Not expected or if such occur, they will be n egligible and insignificant. 9.8. Possible mitigation and/or remedial measures 9.8.1. Protected area BGSPA0002024 Mechka Fish -ponds Before the commencement of the construction activities the workers and the employees of the contractor should be instructed on the location, the objectives, the subject of conservation and the prohibitions in the protected area . 9.8.2. Protected area ROSPA0108 Vedea Dunare • Before the commencement of the construction activities the workers and the employees of the contractor should be instructed on the objectives, the subject of conservation and the prohibitions in the protected area. • The disposal of household and food waste that could lead to contamination of the water of the Danube river should not be allowed. • Spills of fuels and lubricants from the construction machinery should not be allowed. • The workers and the employees of the contractor should not be allowed to carry and use hunting weapons onboard the navigation vessels for extraction of inert materials.  • For the transportation of people and freights between the navigation vessels and the shore, the same route approved by the competent authorities should be used .

70 9.8.3. Protected area ROSCI0088 Gura Vedei -Saica-Slobozia  Before the commencement of the construction activities the workers and the employees of the contractor should be instructed on the objectives, the subject of conservation and the prohibitions in the protected area ;  The disposal of household and food waste that could lead to contamination of the wate r of the Danube river should not be allowed ;  Spills of fuels and lubricants from the construction machinery should not be allowed.  The workers and the employees of the contractor should not be allowed to carry and use hunting weapons onboard the navigation vessels for extraction of inert materials.  For the transportation of people and freights between the navigation vessels and the shore, the same route approved by the competent authorities should be used . 9.9. Availability of alternative solutions We have surveyed several areas along the Danube river flow facing the Bulgarian coast. For one reason or another we have declined all but one, the area in the region of the village of Pirgovo, Ruse District. Due to the above the only alternative left is Extraction of sand and gravel from alluvial deposits in the bed of the Danube River, Kama section (km 510.5 - km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria . 9.10. Existence of reasons of primary public interest for the realization of the Investment Proposal or human health concerns, the public safety or beneficial environmental impacts. None. 9.11. Proposed compensatory measures Not necessary 9.12. General conclusion 9.12.1. Protected area BGSPA0002024 Mechka Fish -ponds In compliance with the mitigation measures the Investment Proposal “Extraction of sand and gravel from alluvial deposits in the bed of the Danube River, Kama section” (km 510.5 - km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria can be implemented, and it is estimated that it will have no significant impacts on the habitats and species that are subject of conservation in the Protected Area BGSPA0002024 Mechka Fish -ponds. The implementation of the IP is compatible with the subject and objectives of this Protected Area and can

71 have a positive effect on the restoration of a degraded habitat and turn it into a place with natural indicators of the benthic hydrobionts that is devoid of organic materials. Increasing the depth can create conditions for the propagation of the protected target fish species and sturgeon fish in the Danube. 9.12.2. Protected area ROSPA0108 Vedea Dunare The Investment Proposal “Extraction of sand and gravel from alluvial deposits in the bed of the Danube River, Kama section" (km 510.5 - km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria is compatible with the objectives and the subject of conservation in the Protected Area ROSPA0108 Vedea Dunare in accordance with the Birds Directive. In adherence to the mitigation measures it can be implemented and, as estimated, it will have no significant impacts on the habitats and the species that are subject to conservation in PA Vedea Dunare ”. 9.12.3. Protected area ROSCI0088 Gura Vedei -Saica-Slobozia The Investment Proposal “Extraction of sand and gravel from alluvial deposits in the bed of the Danube River, Kama section" (km 510.5 - km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality is compatible with the objectives and the subject of conservation in the Protected Area ROSCI0088 Gura Vedei-Saica-Slobozia under the Habitats Directive. In adherence to the mitigation measures it can be implemented and, as estimated, it will have no significant impacts on the habitats and the species that are subject to conservation in the Protected Area ROSCI0088 Gura Vedei-Saica-Slobozia 10. Information on the research methods, prediction and assessment methods of the impacts and sources of information used Flora and vegetation Research Methods The characteristics of the flora and the vegetation is performed based on field studies and existing information from scientific research and publications. The floristic surveys have been conducted using the botanical routes method, including a survey of t he area on foot by following the direction of the greatest variation of flora and fauna, from the lowest to the highest point, or vice versa; from the wettest to the driest sections; in the presence of large leveled areas, the survey is performed in a zig-zag manner. If it is necessary to identify and specify the taxa, herbarium materials are taken as well. The floristic characteristic made is compared with the information in the Manual for Determination of Habitats of European Importance in Bulgaria (Kavra kova etc., 2005) The Vegetation of Bulgaria (Bondev 1991,1997).

72 In order to assess the conservation and preservation importance existing regulations, scientific publications, standard data forms for PA, Flora of Bulgaria, the Internet and other sources wer e used. Prognosis and impact assessment The assessment of the degree of impact and the prognosis of future changes is made based on comparative analysis between the nature of the Investment Proposal and the possible impacts of its implementation, and by using information from literary sources as well . Fauna and animal populations Research methods used The studies are carried out based on the regulations of the Bulgarian environmental legislation adapted to the European legislation, the Environmental Protec tion Act, the Biological Diversity Act and the Protected Areas Act and the ensuing statutory documents and regulations - rules, ordinances and rates of compensation for irremediable damages. The field study of the target fauna was conducted at the end of O ctober 2010. The primary method used was the transect method but with an overall survey of the border areas as well. The registration of the species identification was performed visually and by the specific sound marks of the songbirds. In the transect met hod we performed a full survey of the area that is the subject of the Investment Plan and adjacent grounds. Thus by the transects, a polygon that covers the entire area and its close vicinity is closed. As a basis for comparison and analysis of the target fauna we have used the information from the standard data form of PA, as well as scientific data. We made a consultation with a former and a current biodiversity expert at RIEW - Ruse, as people who have known the area for a longer period. The data from th e standard form were conformed to their knowledge of the target species in the region, and by the extrapolation of data of areas with similar environmental conditions. Prognosis and impact assessment methods The prognosis and the impact assessments were ma de based on many years of practical experience in the study of natural habitats, the monitoring of wetlands, the protected areas, of rare, endangered and protected animal species in the entire country. The prognosis assessment is subjective and it is based on the information on the degree of impairment as a percentage of the habitats in the surveyed area. 11. Methods of quantitative assessment of the negative impact on the bird species that are subject of conservation For the quantitative assessment of the degree of negative impact on the individual bird species, subject of the conservation in the Protected Area our original table was used:

73 Sample Table for assessment of the negative impact on a given species that is subject of the conservation in the Protected Area.

DEGREE OF IMPACT White storck Ciconia ciconia Propagation Migration Wintering (see item 11 for explanations Summary related to the table) Birds In sites for In sites for In sites for assess- Nests Nesting Feeding Feeding Roosting Feeding Roosting ment Eggs Thermics Extinction (0,8 t)* Damage (0,5 t)** Aggravation (0,3 t)** Disturbance (0,1 t)** Fragmentation (0,1 t) Pollution (0,2 t) Bio corridors (0,8 t) Geograph. connection (0,8 t) Total

Notes: * In the case of species from the Red Data Book, the points are doubled, and for a species of global importance the points are tripled. ** When there is damage, aggravation and disturbance to a degree between 10% and 70% of the population of the species in the respective Protected Area, the points are doubled, and over 70 % the points are tripled. In the left-most column of the table the categories (the types) of negative impact on the species are listed. The characteristics of each of these categories are examined in turn: Extinction - negative impact causing zero nest success; causing complete destruction in various ways of nests, eggs, in nesting sites, migration and wintering, 38% of the overall impact severity. Damage - negative impact, causing significant (over 50%) reduction in nest success, driving away of the majority of the couples that have taken the nesting area or have made nests, of young birds prior to flying off etc.; significantly reducing the possibilities for ne sting, feeding and roosting; 23% of the overall impact severity. Aggravation - negative impact, causing reduction (less than 50%) of nest success; driving away of a small proportion of the couples that have taken the nesting area or have made nests, of you ng birds prior to flying off etc.; slightly reducing the possibilities for nesting, feeding and roosting; significant disruption of the normal uninterrupted activity of the birds; 14% of the overall impact severity. Disturbance - a negative impact not significantly affecting nest success, but disrupts the normal uninterrupted activity of the birds; 5% of the overall impact severity.

74 Fragmentation - negative impact, causing tearing, shredding, cutting of the places for nesting, migration and wintering; 5% of the overall impact severity. Pollution - negative impact of several types: Pollution by solid waste; Pollution by industrial waste; Oil pollution; Contamination with chemical fertilizers, pest control and other similar agents; Noise pollution; Light pollution. Only the degree of pollution should be entered in the table, and the nature of the pollution is specified in the text relating to the type; 9% of the overall impact severity. These include also staining, oil-coating of individual birds. The impact categories called Bio corridors and Geographical connection are included in the table only as a general assessment. In the next column the three phases of the annual cycle of the birds are included: Propagation – divided into: Birds, nests and eggs – taken into account both adult birds in the breeding phase, newly built nests and nests with eggs at different stages of development, young birds (pullus) at different stages of development; Nest sites – the natural substrata where the nests are located - trees, bushes, holes in the ground and earth, loess slopes, cliffs and rock formations, reedbeds, grasslands, pastures, meadows, sandspits (these do not include power poles, chimneys, roofs and church domes, monuments etc.). Feeding sites - all kinds of natural food biotopes. Migration - divided into: Thermal sites - areas over which rising air flows are formed and which the soaring birds use to fly higher during migration. Without their help this group of migrants cannot reach the wintering areas in Africa. Roosting sites - the majority of the waterfowl use natural and artificial ponds with large water surface for roosting, where they are safe. The migrating flocks of ordinary storks and cranes use open spaces away from roads and settlements – stubble-fields, fallow lands, meadows and pastures. The migrating raptors roost in large forest complexes. To the roosting sites we should add also those areas that ducks and geese use as shelters during moulting (when they lose their ability to fly and become vulnerable). The migratory songbirds use forests and reedbeds, as well as scrubs for roosting.

75 Wintering - divided into: Feeding sites - fields with winter cereals, alfalfa, lakes and marshes, fish -ponds and fish-farms, dams and small dams, the Black Sea shelf. Roosting sites - unfrozen lakes and marsh-lands, dams and small dams, fish-ponds and fish-farms, the Black Sea shelf; floodplain forests along the Danube, Tundzha, and Maritsa rivers and dense forests by the Black Sea, sandspits along the Danube and Maritsa river, e tc. In the right-most column the summary degree of impact of the respective category should be indicated, which is the sum of the individual scores. At the bottom of this column the total of the degrees of impact of all categories should be indicated. This is the final assessment of the degree of impact on a given species. from 0 to 1 - no impact from 1 to 5 - low degree of impact that can be avoided without taking special measures, only compliance with the best practices for construction and operation is n eeded; from 5 to 10 - moderate degree of impact that should be reduced or eliminated by implementation of mitigation measures; from 10 to 15 - a high degree of impact that should be reduced or eliminated by choosing alternatives or implementation of compen satory measures. 12. Sources Flora and protected areas Bondev, Iv., 1991. The Vegetation of Bulgaria. Map in scale 1:600 000 with explanatory text, Univ. publishing house St. Kliment Ohridski, Sofia, 183 p. Bondev, I., 1997. Geobotanical Zoning. B: Geogra phy of Bulgaria. 1997. Acad. publishing house Prof. M. Drinov. Golemanski, V. (ch. edit.). 2011. The Red Data Book of Bulgaria. Volume 2. Animals. IBER – BAS and MOEW, Sofia, 383 p. Gruev, B., B. Kuzmanov, 1994. General Biogeography, Univ. publishing hou se St. Kliment Ohridski, Sofia, 498 p. Directive 92/43/EEC of the Council of the European Communities on the Conservation of Natural Habitats and of Wild Fauna and Flora. Biological Diversity Act, SG, issue No. 77/06.08.2002 Protected Areas Act, SG, issue No. 133/11.11.1998, last amend. in SG, issue No. 103 dated 2009 Kavrakova, V., D. Dimova, M. Dimitrov, R. Tsonev, T. Belev, K. Rakovska (ed. team), 2009,

76 Manual for Determination of Habitats of European Importance in Bulgaria. Second, revised and supplemented edition. World Wildlife Fund, the Danube -Carpathian Program and the Green Balkans Federation, Sofia, 132 p. Kozhuharov, S. (ed.), 1992. Guide to the Vascular Plants in Bulgaria, publishing house Nauka & Izkustvo (Science and Art), Sofia, 788. MOEW. 2006. Management Plan for PA Kalimok - Brashlen, 2006-2016, Ministry of Environment and Water, with the financial support of the European Union, 225 p. (unpubl. report). Ordinance on the Conditions and Order for the Performance of Environmental Impact Assessment – SG, issue No. 25/2003, amended and suppl. in SG, issue No. 29 dated 16.04.2010 NATURA 2000 Standard data form for Protected Area Kalimok - Brashlen (BG0000377), Ministry of Environment and Water, 19 p. NATURA 2000 Standard data form for Protecte d Area Vedea Dunare (BG0002030), Ministry of Environment and Water, 15 p. NATURA 2000 Standard data form for Protected Area Mechka Fish-ponds (BG0002024), Ministry of Environment and Water, 13 p. Register of Protected Areas and Protected Zones in Bulgaria. Savev, A., M. Dimitrov. 2005. Flora of the Protected Area Kalimok Brashlen. – PA Kalimok Brushlen, 38 p. (unpubl. report). Flora of the NR of Bulgaria, Vol. I -X, 1963-1995. Published by BAS, Sofia. Devillers-Terschuren, J., P. Devillers, 2001. Application and development of the Palaearctic habitat classification in the course of the setting up of the Emerald Project, Strasbourg, 70 pp. http://eunis.eea.europa.eu/ (access on 10th June, 2011). http://eunis.eea.europa.eu/sites/349842 (access on 10th June, 2011). http://www.kalimok.eu/index.php?lang=bg (access on 10th June, 2011). Fauna and animal population Botev, B., Ts. Peshev (ed.). 1985. The Red Data Book of Bulgaria. Volume 2: Animals. Sofia. BAS. Golemanski and others (ed.). 2011. The Red Data Book of Bulgaria. Volume 2. Animals. IBER - BAS & MOEW, Sofia, 383 p. Directive 92/43/EEC of the Council of EEC dated 21st May, 1992 for the Conservation of Natural Habitats and of Wild Fauna and Flora.

77 Environmental Protection Act, SG, issue No. 91/25.09.2002 last amend. in SG, issue No. 103 dated 2009 Biological Diversity Act, SG, issue No. 77/06.08.2002 Protected Areas Act, SG, issue No. 133/11.11.1998, last amend in SG, issue No. 103 dated 2009 Instruction for Assessment of Protected Areas under Art. 7, Paragraph 3 in conjunction with Art. 6, Paragraph 1, items 3 and 4 of the Biological Diversity Act, incl uding habitats of bird species. Kostadinova, I. (comp.) 1997. Important Bird Areas in Bulgaria. BSPB, Conservation series. Book 1, BSPB, Sofia, 176 p. Kostadinova, I. 2005. Application of Criteria C for Determination of Bird Areas of Importance for the European Union in Bulgaria. Preliminary Application and Gap Analysis. B: Modern Condition of the Biological Condition in Bulgaria - Problems and Prospects. Bulgarian Bioplatform, Sofia, pp. 533 -548. Kostadinova, I, M. Mihailov (comp.) 2002. Guide for NATURA 2 000 in Bulgaria. BSPB, Conservation series. Book 5. BSPB, Sofia, 80 p. Kostadinova, I, M. Gramatikov (ch. edit.). 2007. Important Bird Areas in Bulgaria and Natura 2000. BSPB, 11, Sofia, 639 p. (in Bulgarian and English). MOEW. 2000. National Biodiversity Conservation Plan. 2000. MOEW. Ordinance of MOEW for Environmental Impact Assessment (SG, No. 3/2006). Ordinance on the Conditions and Order for the Performance of Compatibility Assessment of plans, programs, projects and investment proposals with the subj ects and objectives of conservation of the protected areas (SG, No. 73/2007). Guide for Natura 2000 in Bulgaria. 2,002. Conservation series - Vol 5. BSPB. Yankov, P. 2002. (ed.). Globally Threatened Birds in Bulgaria. National Action Plans for Their Conservation. Part 1. BSPB - MOEW Conservation series, Book 4, Sofia: 204 -219. BirdLife International. 2000. Endangered birds of the world. Barcelona and Cambridge, UK: Lynx Edicions and BirdLife International, 695 pp. Birdlife International. 2004. Birds in Euro pe: Population estimates, trends and conservation status. Cambridge, UK: Birdlife International (Birdlife Conservation Series No. 12), 373 pp. European Union. 2011. EC guidance on: Undertaking non -energy extractive activities in accordance with Natura 2000 requirements. Luxemburg, EU, ISBN 978-92-79-18646-2, 143 pp. Botnaruc, N., V. Tatole. 2005. Cartea rosie a vertebratilor ein Romania. Academia Romana, Buciersti, 260 pp.

78 BSPB. 2005. Observation of autumn migration of soaring birds in Bulgaria in 2004 in terms of identification of bottleneck IBAs to be included in the European Ecological Network NATURA 2000; BSPB, Sofia, 14 pp. Grimmet, R. F. A., R. T. A. Jones. 1989. Important Bird Areas in Europe. Cambridge, U.K.: ICBP (ICBP Technical Publication No 9). Heath, M.F. and Evans, M.I. (Eds). 2000. Important Bird Areas in Europe: Priority sites for conservation, vol. 2 Southern Europe. Cambridge, UK: BirdLife International (BirdLife Conservation Series No. 8). Michev, T., L. Profirov. 2003. Midwinter Numbers of Waterbirds in Bulgaria (1977-2001). Results from 25 years of mid-winter count carried out at the most important Bulgarian Wetlands. Publ. House Pensoft, Sofia, 160 pp. Michev, T., M. Stoyneva (eds). 2007. Inventory of Bulgarian Wetlands and their Biodiv ersity. Publ. House Elsi-M, Sofia, 362 pp. Munteanu, D. 2005. Cartea rosie a vertebratelor din Romania. Muzeul national de istorie naturala “G. Antipa”, Bucresti, 260 pp, ISBN 973 -0-03943-7. Osieck, E. 2000 Filling in the requirements of the EU Birds Dire ctive: Lessons from the ‘Dutch Case’“. In: European IBA Workshop. 29 March - 2 April 2000, Brussels, Belgium. Proceedings. BirdLife International, 86 -99. Waliczky, Z. 2000. “Important Bird Areas of European Union Importance: explanation of the EU Criteria applied in IBA 2000“ In: European IBA Workshop. 29 March - 2 April 2000, Brussels, Belgium. Proceedings. BirdLife International, 12 -16.

79 13. Appendices

13.1. Layout of Kama Island with location of the IP osits of the of osits signed/ - 194/23 February 2011 of the Executive of 2011 February 194/23 - 1 - g. G.Georgiev g. LAYOUT for water afacility using section for of a dep alluvial of Extraction River. Danube V No. Letter of the Maintenance and Exploration For Agency River. Danube 1:25000 Scale For Agency Executive of the Director Executive River Danube the of Maintenance and Exploration /En of Transport, Ministry of the seal Round Communications and Technology Information

80 13.2. INFORMATION ON PPP/IP ON THE DANUBE RIVER, provided by RIEW Ruse, with decision № 343/1.08.2012 (in beige background are the projects that are located near the area of the IP in question ) INFORMATION ON PPP/IP ON THE DANUBE RIVER, provided by RIEW Ruse, with decision № 343/1.08.2012 Name of Precise location Implement Outgo- the plan, (river Area Emplo Incoming No. ation Decision ing the project, km/geographical (in da) yer number stage number IP coordinates) Extraction in the canal of the No data Implement- РУ-126- Milko АО 3445/08. of inert Batin island from ed, but the ПР/2006 Stilyan 5384/24.0 09.2006 materials km 525,100 to km permits are ov 8.2006 from the 523,500 not Danube renewed 1 riverbed with over- ground means from km 525.100

Extraction from km 521,000 No data Implement- РУ-65- ET АО 623/13.0 of inert to km 519,000 at ed, but the ПР/2007 Poli- 532/01.02 2.2007 materials a minimum permits are Kamen .2007 from the distance from the not Chaka- Danube Bulgarian coast- renewed lov riverbed 350 m and a 2 with a maximum capacity of distance at the 50,000 t / upper end - 550 year m, at the lower end - 500 m in the Danube riverbed Extraction from km 503,500 No data Implement- РУ-04- ET АО 3995/31. of inert to km 502,700 at ed, but the ПР/2008 Poli- 4364/22.0 08.2007 materials a minimum permits are Kamen 8.2007 from the distance of 50 m not Chaka- Danube and a maximum renewed lov 3 riverbed distance of 150 m with vessel from the coast of anchoring the Lyuliyaka means and a island, town of capacity of Ruse 180,000 t/yr Extraction from km 512,000 Not РУ-68- Gravel АО 2891/25. of sand and to km 508,000 in implement- ПР/2008 and 3144/08.0 06.2007 4 gravel from the region of the ed Sand 6.2007 alluvial village of Pits deposits in Pirgovo, Ivanovo Bulgar

81 INFORMATION ON PPP/IP ON THE DANUBE RIVER, provided by RIEW Ruse, with decision № 343/1.08.2012 the Danube Municipality ia riverbed EAD

Extraction from km 437,000 700,000 Not РУ-77- Skalni of inert to km 435,000 implement- ПР/2008 Materi materials near the Radetski ed ali JSC 5 from the island, Tutrakan Danube Municipality riverbed Extraction from km 478,000 300,000 Not РУ-78- Skalni of inert to km 476,500 implement- ПР/2008 Materi materials near the Aleko ed ali JSC 6 from the island, village of Danube Sandrovo, Ruse riverbed Municipality Extraction Mishka Section 59,700 Not РУ- Gravel АО 2891/25. of sand and from km 462,000 implement- 105/ПР/20 and 3144/08.0 06.2007 gravel from to km 459,400 in ed 08 Sand 6.2007 alluvial the region of the Pits 7 deposits in village of Babovo, Bulgar the Danube Slovo pole ia riverbed Municipality EAD

Extraction from km 501,400 40,000 Implement- РУ-45- ET АО 959/01.0 of inert to km 502,000 in ed ПР/2010 Milen 1547/25.0 4.2010 materials the Ruse region Veliko 3.2010 8 from the v Danube riverbed Construction km 499 on the 119,263 Not РУ-62- Prista АО 2409/02. of a loading Danube river, implement- ПР/2010 Oil 3558/26.0 08.2010 and property ed Holdin 7.2010 discharging 63427.3.195 acc. g EAD port at km to the cadastral 9 499 for the map of the town Danube of Ruse river vessels of less than 1,350 gross tons Extraction from km 501,400 70,465 Not РУ-31- ET АО 1006/30. of inert to km 501,000 in implement- ПР/2011 Milen 1403/15.0 03.2011 materials the canal of the ed Veliko 3.2011 from the Lyuliyaka island, v 10 Danube Ruse region riverbed from km 501.400 to

82 INFORMATION ON PPP/IP ON THE DANUBE RIVER, provided by RIEW Ruse, with decision № 343/1.08.2012 km 501.000 with sailing and anchored means, 15000 m3/yr Removal of from km 468,000 75,2647 Implement- РУ-59- "Duna АО 1825/03. alluvial to km 464,000 ed ПР/2011 vski 2767/27.0 06.2011 deposits Dragaj 4.2011 from the -en 11 Danube Flot" riverbed AD – from km Ruse 468.000 to km 464.000 Removal of from km 404.600 227,615 Not РУ-95- DULU АО 1338/20. alluvial to km 403.000 implement- ПР/2011 F 1866/25.0 04.2011 deposits facing the harbour ed OOD 3.2011 from the of the village of Danube Popina, Sitovo riverbed Municipality with anchor vessels means in the 12 section from km 404.600 to km 403.000 near the village of Popina, Sitovo Municipality Extraction from km 502.300 22,000 Not РУ-5- "Drago АО АО5373 of inert to km 502.100 in implement- ПР/2012 -zovi 5373/01.1 /22.11.2 materials the canal of the ed 2" 1.2011 011 from the Lyuliyaka island OOD Danube riverbed in 13 section from km 502.3 to km 502.1 in the canal of the Lyuliyaka island

83 INFORMATION ON PPP/IP ON THE DANUBE RIVER, provided by RIEW Ruse, with decision № 343/1.08.2012 Removal of from km 396 to 177,501 Procedure Polaris АО АО alluvial km 395 for -8 1163/06.0 1163/12. deposits estimation OOD 3.2012 04.2012 14 from the of the Danube necessity of river EIA Removal of from km 385.800 81,844 Procedure Polaris АО АО alluvial to km. 385 for -8 1164/06.0 1164/12. deposits estimation OOD 3.2012 04.2012 15 from the of the Danube necessity of river EIA

84 13.3. Documents of Prof. Maya Stoyneva, PhD All documents of the experts, who have prepared this assessment, are already deposited with the Ministry of Environment and Water . We enclose hereto only the document s of Prof. Maya Stoyneva, PhD, in order to comply with the requirement of the MEW (Decision No.18-ПР/2010) for inclusion of an expert-hydrobiologist in the team.

3-132

PEOPLE’S REPUBLIC OF BULGARIA

KLIMEMENT OHRIDSKI UNIVERSITY OF SOFIA

DIPLOMA OF HIGHER EDUCATION

NO. 101321

THE HOLDER OF THIS DIPLOMA

MAYA PETROVA PETROVA,

BORN ON 12TH OF MAY 1962 IN THE CITY OF SOFIA, WAS ENROLLED IN 1980 AND GRADUATED IN 1985 THE FULL-TIME COURSE OF STUDY OF THE FACULTY OF BIOLOGY IN THE MAJOR BIOLOGY WITH A GRADE POINT AVERAGE AT THE EXAMI NATIONS DURING THE COURSE OF STUDY EXCELLENT /5,83/ AND A GRADE POINT AVERAG E EXCELLENT /6,00/ AT THE STATE FINAL EXAMINATION.

BY VIRTUE OF DECISION OF THE STATE BOARD OF EXAMINERS OF JULY 1985 THE HOLDER IS ACKNOWLEDGED THE QUAL IFICATION BIOLOGIST with specialiation - botany.

DEAN: /SIGNED/ RECTOR: /SIGNED/

85 SOFIA, 9TH OF OCTOBER 1985

ROUND SEAL OF KLIMENT OHRIDSKI UNIVERSITY OF SOFIA, CITY OF SOFIA, PEOPLE’S REPUBLIC OF BULGARIA.

/HOLDER’S PHOTO AND SIGNATURE SEALED BY KLIMENT OHRIDSKI UNIVERSITY OF SOFIA, CITY OF SOFIA, PEOPLE’S REPUBLIC OF BULGARIA/

86 Declaration

Under Art. 9, Para 1, It. 4, It. 5, It. 6 and It. 7 of the Regulation on the Terms and Procedure for Implementation of Compatability Assessment of Plans, Programmes, Projects and Investment Proposals with the Object and Purpose of Conservation of Protected Areas, Adopted by Government Decree No. 201/31.08.2007 and Ordinance No. 227 dated 7.10.2010 of the Council of Ministers for amendement and supplement. The undersigned Maya Petrova Stoyneva, DO HEREBY DECLARE, that:  I am not a Client of the investment proposal „Extraction of sand and gravel from alluvial deposits in the bed of the Danube river, Kama section (km 512.0 – km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria”;  I am not an owner or a member of the management or supervisory body of the natural person – Contracting Authority and I am not personally interested in the realization of this investment proposal ;  I am not a related party under §1 of the Additional Provisions of the Commercial Law, neither am I in employment, civil or official relations with the Contracting Authority of the investment proposal;  I am not in employment, civil or official relations with the competen t authorities under Art. 10 of the Environment Protection Act ;  I am aware of the current Bulgarian and Europen legislation in the field of environmental protection and I have referred to and complied with these requirements and the present methodological documents while working on the assessment under Art. 7, It. 4 of the Regulation.

8th August 2012 Signature......

(Prof. M. Stoyneva, PhD)

87 SAINT KLIMENT OHRIDSKI UNIVERSITY OF SOFIA

COMPANY/INSTITUTION

ADDITIONAL AGREEMENT NO. РД22-196 / 22ND OF FEBRUARY 2012

TO EMPLOYMENT CONTRA CT NO. 3269 / 27TH OF JUNE 1988

THIS 31ST DAY OF JANUARY 2012 IN THE CITY OF SOFIA ON THE GROUNDS OF ART. 119 OF THE LABOUR CODE,

REPORT WITH REF. NO. 70.08.62/10TH FEBRUARY 2012 OF ASSOC. PROF. BOZHIDAR GALUTSOV – DEAN OF THE FACULTY OF BIOLOGY AND DECISION OF THE FACULTY BOARD OF THE FACULTY OF BIOLOGY FOR ACADEMIC POSITION PROFESSOR

THE PARTIES UNDER EMPLOYMENT CONTRACT NO. 3269 / 27TH OF JUNE 1988

PROF. IVAN ILCHEV, PHD – RECTOR OF ST. KLIMENT OHRIDSKI UNIVERSITY OF SOFIA – SOFIA

ADDRESS: 15 TSAR OSVOBODITEL BLVD., BULSTAT 000670680, TAX NO. 1220022435 – HEREINAFTER REFERRED TO AS EMPLOYER

AND MAYA PETROVA STOYNEVA, HEREINAFTER REFERRED TO AS EMPLOYEE

/FULL NAME OF THE PERSON AS INDICATED IN IDENTITY DOCUMENT/

PERMANENT ADDRESS: CITY OF SOFIA, 1632, OVCHA KUPEL HOUSING ESTATE, BLDG. 421, ENTR. A, FL. 9, APT. 33

CURRENT RESIDENCE: CITY OF SOFIA, 1632, OVCHA KUPEL HOUSING ESTATE, BLDG. 421, ENTR. A, FL. 9, APT. 33

PERSONAL ID. NO. 6205126279, HOLDER OF IDENTITY CARD NO. 626587454 ISSUED ON 16 FEBRUARY 2010 BY THE MINISTRY OF INTERIOR - SOFIA

EDUCATION: HIGHER, DEGREE – MASTER, MAJOR – BIOLOGY

HOLDER OF DIPLOMA NO. 101321 DATED 9 TH OF OCTOBER 1985, ISSUED BY KLIMENT OHRIDSKI UNIVERSITY OF SOFIA – FACULTY OF BIOLOGY

AND OTHER MAJOR /MINOR/:

88 DECISION OF THE FACULTY BOARD OF THE FACULTY OF BIOLOGY – RECORD NO. 01 / 31ST JANUARY 2012 FOR ACADEMIC POSITION PROFESSOR

DIPLOMA NO. 21888 / 21ST JANUARY 1992 OF THE HIGHER ATTESTATION COMMISSION, RECORD 03, NO. 10 DATED 21ST NOVEMBER 1991 FOR ACADEMIC DEGREE CANDIDATE OF BIOLOGICAL SCIENCES

THE PERSON HAS NOT WITH WORK EXPERIENCE: 26 YEARS/0 MONTHS/0 RETIRED DAYS

INCL. IN THE MAJOR:

Now, therefore, the parties hereto AGREE ON THE FOLLOWING AGREEMENT TO THE EMPLOYMENT CONTRACT:

1. WORKING PLACE: KLIMENT OHRIDSKI UNIVERSITY OF SOFIA

FACULTY OF BIOLOGY

DEPARTMENT OF BOTANY

2. THE EMPLOYER ENTRUSTS AND THE EMPLOYEE/WORKER UNDERTAKES:

FROM POSITION: ASSOCIATE PROFESSOR, HEAD OF DEPARTMENT OF BOTANY

TO HOLD THE POSITION OF: PROFESSOR, HEAD OF DEPARTMENT OF BOTANY

WITH NATIONAL OCCUPATIONAL CLASSIFICATION CODE: 1345 9012, STAFF CATEGORY: MANAGERIAL EMPLOYEES

WHICH SHALL ALSO INCLUDE THE DUTIES AND OBLIGATIONS ENLISTED IN THE ENCLOSED JOB DESCRIPTION, WHICH THE EMPLOYEE /WORKER/ HAS PRELIMINARY READ AND HAS RECEIVED A COPY OF IT.

3. THE POSITION SHALL BE OFFICIALLY HELD AS FROM: 31 JANUARY 2012

4. DURATION OF EMPLOYMENT RELATIONS – INDEFINITE PERIOD OF TIME

5. DAYS OF BASIC, EXTENDED AND ADDITIONALLY PAID ANNUAL LEAVES: 48 DAYS

6. THE NOTIFICATION TERM FOR TERMINATION OF THIS EMPLOYMENT CONTRACT BY EITHER PARTY IS DETERMINED UNDER ART. 326, PARA 2 OF THE LABOUR CODE AND IT IS 30 DAYS.

89 7. BASIC MONTHLY REMUNERATION: NINE HUNDRED AND NINETEEN BGN 919.00 BULGARIAN LEVS

/ACC. TO THE CLASSIFIER DATED 1 NOVEMBER 2008/

ADDITIONAL REMUNERATION FOR:

A) ACQUIRED LENGTH OF SERVICE AND PROFESSIONAL BGN 286.73 EXPERIENCE BY 1.2% FOR EACH YEAR OF SERVICE – 31.2% FOR 26 YEARS OF SERVICE

B) DOCTOR /PHD/ BGN 189.00

PRINTOUT DATE: 15TH FEBRUARY 2012 PAGE 1 OF 2

90 Research Papers of Prof. Maya Stoyneva, PhD, in Hydrobiology and the Danube River STOYNEVA, М. P., 1991. Algal flora of the Danube River (Bulgarian sector) and adjoined water basins. – Thesis for Candidate’s Degree., Sofia, Sof. Univ., 372. Draganov, St. J., M. P. S TOYNEVA, [1985] 19882. Algal flora of River Danube (Bulgarian sector) and adjacent water basins. I. Composition and distribution of the phytoplankton of River Danube. - Ann. Sof. Univ., Book 2 – Botany, 79: 38-63. Draganov, St. J., M. P. S TOYNEVA, [1986]1990a. Algal flora of the River Danube (Bulgarian sector) and the adjoined water basins. II. Composition and distribution of the phytobenthos of the River Danube. - Ann. Sof. Univ., Book 2 – Botany, 80: 11-24. Draganov, St., M. Stoyneva, 1992. Algal fl ora of the Danube river (Bulgarian sector) and adjoined water basins. III. Algae from some adjoined water basins. - Ann. Univ. Sof., Book 2 – Botany, 82: 63-78. Драганов, С., М. СТОЙНЕВА, Б. Георгиев, 1987. Альгофлора болгарского сектора Дуная и примыкающих бассейнов. - В: Сб. докл. Междунар. симп. "Роля на влажните зони за опазване на генетичния фонд", Сребырна, 8 - 12. 10. 1984, София, БАН, 42-51. Draganov, St. J., M. P. STOYNEVA, 1990. Saprobiologische Beurteilung des Donauwassers im Bulgarischen Abschnitt des Stromes im Jahre 1982 wahrend der vier Jahreszeiten 1987/1988 aufgrund des Phytoplanktons. - In: Limnologische Berichte der 28 Tagung der IAD, Varna, 23 - 28 September, 1990, Sofia, Verlag BAW, 349 - 354. STOYNEVA, M. P., St. J. Draganov, 1991. Green algae in the phytoplankton of the Danube (Bulgarian sector) - species composition, cell numbers and biomass. - Arch. Protistenkd., 139, 243-260 (IF=O.481)л STOYNEVA, M. P., 1994b. Shallows of the lower Danube as additional sources of potamoplankton. - In: Descy, J.-P., C. S. Reynolds, J. Padisak (eds), Phytoplankton in Turbid Environments: Rivers and Shallow Lakes. Hydrobiologia, 289: 171-178. (IF=0.592). STOYNEVA, M. P., St. J. Draganov, 1994b. Chlorococcal algae in the spring (1990) Danube phytoplankton: species composition, distribution, cell numbers and biomass. - Biologia, Bratislava, 49/4: 563-568. (IF=0.043). Kristiansen, J., M. STOYNEVA, 1998. Silica-scaled chrysophytes in Bulgaria. - Cryptogamie, Algologie, 19, 1-2, 19-28. (IF=0.273). STOYNEVA, M. P., 1998c. Development of the phytoplankton of the shallow Srebarna Lake (North -Eastern Bulgaria) across the trophic gradient. - In: Alvarez-Cobelas, M., C. S., Reynolds, P. Sanchez -Castillo, J. Kristiansen (eds), Phytoplankton and Trophic Gradients, Hydrobiologia, 369/370, 259-367. (IF=0.576)л STOYNEVA, M. P., 1998. On the distribution of Pseudokirchneriella danubiana (Hind.) Hind. and Pseudokirchneriella roselata (Hind.) Hind. in Bulgaria. - Biologia, Bratislava, 53/4, 433- 435. (IF=0.194) STOYNEVA, M. P., 1998. Spring-Phytoplankton of the River Danube in the year 1990. - Large rivers, 11, 2, Arch. Hydrobiol. 115/2, 167-194. (IF=1.367)

91 REPUBLIC OF BULGARIA

DIPLOMA OF HIGHER EDUCATION

D I P L O M A OF HIGHER EDUCATION

AWARDED TO DIMCHO ZAHARIEV IVANOV

PERSONAL ID. NO. 7406198842, BORN ON 19TH JUNE 1974

IN THE TOWN OF SHUMEN, VARNA COUNTY,

REPUBLIC OF BULGARIA,

COMPLETED A FIVE-YEAR COURSE OF STUDY

MAJORING IN: BIOLOGY AND CHEMISTR Y – FULL-TIME

WITH A GRADE POINT AVERAGE: EXCELLENT /5.67/

AND GPA OF THE STATE FINAL EXAMINATIONS: EXCELLENT /5.67/.

BY VIRTUE OF DECISION OF THE STATE BOARD OF EXAMI NERS

(RECORD NO. 198 DATED 11TH OCTOBER 1997)

THE STUDENT IS ACKNO WLEDGED HIGHER EDUCATION AND HE IS AWARDED THE QUALIFIC ATION OF

92 BIOLOGIST, BIOLOGY AND CHEMISTRY TEACHER .

DEAN: /SIGNED/ RECTOR: /SIGNED/

REGISTRATION NO. 17446 10TH MARCH 1998

ROUND SEAL OF EPISKOP KONSTANTIN PRESLAVSKY UNIVERSITY OF SHUMEN, TOWN OF SHUMEN,

REPUBLIC OF BULGARIA

93 REPUBLIC OF BULGARIA

COUNCIL OF MINISTERS

HIGHER attestation commission

D I P L O M A

OF acquired EDUCATIONAL AND ACADEMIC DEGREE

PHD

NO. 30792 DATE: 21ST AUGUST 2006

The HIGHER ATTESTATION commission

hereby CONFERS UPON

DIMCHO ZAHARIEV IVANOV

94 BORN ON 19TH JUNE 1974 IN THE TOWN OF SHUMEN,

the educational and academic degree PHD

IN THE SCIENTIFIC MAJOR 01.06.03 BOTANY

ON THE GROUNDS OF THESIS DEFENDED WITH SUBJECT MATTER:

“ECOBIOLOGICAL RESEARCH OF MEDICINAL SPECIES OF

GENUS STACHYS L. IN BULGARIA”

COMMISSION NO. 03, RECORD NO. 11 DATED 6TH JUNE 2006

SCIENTIFIC Secretary: /SIGNED/ chairperson: /SIGNED/

SEALED BY THE HIGHER ATTESTATION COMMISS ION AT THE COUNCIL O F MINISTERS OF THE REPUBLIC OF BU LGARIA.

95 Episkop Konstantin Preslavsky University of Shumen

Human resources department

9712 SHUMEN, 115 UNIVERSITETSKA ST., PHONE: +359 (0)54/ 830 773

REF. NO. ЛС-12-82 / 4TH MAY 2010

TO WHOM IT MAY CONCE RN

C e r t i f i c a t e

THIS CERTIFICATE IS ISSUED TO DIMCHO ZAHARIEV IVANOV, HOLDING THE POSITION OF CHIEF ASSISTANT, IN ORDER TO CERTIFY THAT THE AFOREMENTIONED PERSO N HAS BEEN EMPLOYED ON FULL-TIME EMPLOYMENT CONTRACT BASIS FOR INDEFINITE PERIOD OF TIME AT EPISKOP KONSTANTIN P RESLAVSKY UNIVERSITY OF SHUMEN, FACULTY OF NATURAL SCIENCES, DEPARTMENT OF AGRARIAN STUDIES AND PLANT PROTECTION.

FROM THE DATE OF HIS APPOINTMENT, 1ST OCTOBER 1998 TO 1ST MAY 2010, THE PERSON HAS TOTAL WORK EXPERIEN CE OF 11 YEARS AND 7 MONTHS, HOLDING THE FOLLOWING POSITIONS:

- SPECIALIST – BIOLOGIST /0.5 PAYROLL POSITION/;

96 - ACCREDITATION SPECI ALIST /0.5 PAYROLL POSITION/;

- ASSISTANT UNDER ART. 68, PARA 1, ITEM 1;

- JUNIOR SPECIALIST 2ND DEGREE /0.5 PAYROLL POSITION/, SENIOR SPECIALIST 1ST DEGREE

/0.5 PAYROLL POSITION/;

- ASSISTANT UNDER ART. 68, PARA 1, ITEM 4;

- ASSISTANT UNDER ART. 67, PARA 1, ITEM 1;

- SENIOR ASSISTANT;

- CHIEF ASSISTANT;

HEAD OF HUMAN RESOURCES DEPARTMENT:

/N. NAYDENOVA - SIGNED/

ROUND SEAL OF EPISKOP KONSTANTIN PRESLAVSKY UNIVERSITY OF SHUMEN, TOWN OF SHUMEN,

HUMAN RESOURCES DEPARTMENT, REPUBLIC OF BULGARIA

97 REPUBLIC OF BULGARIA

ST. KLIMENT OHRIDSKI

SOFIA UNIVERSITY

FACULTY OF BIOLOGY

SUPPLEMENT TO DIPLOM A NO. 123374

CERTIFICATE

OF ANNUAL EXAMINATIO N RESULTS

AWARDED TO NIKOLAY DYANKOV KO DZHABASHEV

DATE OF BIRTH 27TH JUNE 1968

PLACE OF BIRTH: TOWN OF SILISTRA

YEAR OF ENROLLMENT 1988/89

YEAR OF GRADUATION 1992/93

FACULTY NO. 5368

FACULTY OF BIOLOGY

98 THROUGHOUT THE COURS E OF STUDY, THE STUDENT STUDIED AND

PASSED EXAMINATIONS IN THE FOLLOWING SUB JECTS IN THE MAJOR

BIOLOGY

STATE FINAL EXAMINATION

AUGUST, 1993

master’s thesis Defence: eXCELLENT /6,00/

QUALIFICATION: BIOLOGIST

SPECIALIZATION: zoology of invertebrates - entomology

RECTOR: /SIGNED/

FACULTY DEAN: /SIGNED/

SEALED BY THE CHANCELLOR’S OFFICE OF ST. KLIMENT OHRIDSKI SOFIA UNIVERSITY.

99 MINISTRY OF EDUCATION AND CULTURE

DIPLOMA OF COMPLETED HIGHER EDUCATION

SERIES B NO. 14759 *

THE HOLDER OF THIS DIPLOMA

TANYU MANEV MICHEV,

BORN ON 17TH OF MARCH 1939 IN THE TOWN OF CHIRPAN, WAS ENROLLED IN 1956 AND GRADUATED IN 1961 THE FULL-TIME COURSE OF STUDY O F THE FACULTY OF BIOLOGY, GEOLOGY AND GEOG RAPHY AT SOFIA UNIVERSITY IN THE MAJOR BIOLOGY WITH A GRADE POINT AVERAGE AT THE EXAMINATIONS DURING THE COURSE OF STUDY VERY GOOD /4,95/ AND A GRADE POINT AVERAG E VERY GOOD /5,00/ OF THE STATE FINAL EXAMINATION.

BY VIRTUE OF DECISION OF THE STATE BOARD OF EXAMINERS OF JUNE 1961 THE HOLDER IS ACKNOWLEDGED THE QUAL IFICATION BIOLOGIST - zoologist – natural sciences, agriculture and chemistry teacher .

Chairperson of the state board of examiners : /SIGNED/

DEAN: /SIGNED/ RECTOR: /SIGNED/

100 SOFIA, 11TH OF JULY 1961

REGISTRATION NO. 48015

ROUND SEAL OF KLIMENT OHRIDSKI UNIVERSITY OF SOFIA, CITY OF SOFIA, PEOPLE’S REPUBLIC OF BULGARIA.

Ministry of PUBLIC Education

HEREBY VERIFIES THE AUTHENTICITY OF THE SIGNATURE

AND SEAL AFFIXED ON THE PRESENT DIPLOMA.

NO. ЛС-130/ 21ST APRIL 1971, CITY OF SOFIA

INSPECTOR: /SIGNED/

SEALED BY THE MINISTRY OF PUBLIC EDUCATION, REPUBLIC OF BULGARIA

101 Bulgarian academy of sciences

Central laboratory of general ecology

2 Y. GAGARIN ST. PHONE: 8736137

SOFIA 1113 FAX: 8705498

REF. NO. 252

10TH DECEMBER 2007

C e r t i f i c a t e

THIS CERTIFICATE IS ISSUED TO TANYU MANEV MICHEV IN ORDER TO CERTIFY THAT THE AFOREMENTIONED HAS B EEN EMPLOYED ON FULL-TIME EMPLOYMENT CONT RACT BASIS SINCE 1ST JANUARY 1996 AT THE CENTRAL LABORATORY OF GENERAL ECOLOGY AT THE BULGARIAN ACADEMY OF SCIE NCES, HOLDING THE POSITION OF SENIOR RESEARCH WORKER – 2ND DEGREE AND DIRECTOR OF THE SCIENTIFIC RESEARCH GROUP "BIODIVERSITY PROTEC TION" AT BIODIVERSIT Y SECTION.

THIS CERTIFICATE IS TO SERVE BEFORE THE MINISTRY OF ENVIRONMENT AND WATE R.

DIRECTOR:

/SEN. RES. WORKER N. CHIPEV, PHD - SIGNED/

ROUND SEAL OF THE BULGARIAN ACADEMY OF SCIENCES, REPUBLIC OF BULGARIA

102 University of forestry

Faculty of forestry

SOFIA 1756, 10 KLIMENT OHRIDSKI BLVD., EXCHANGE: 91-907/INT. 475, TEL./FAX 862-28-54

C e r t i f i c a t e

NO. 1923 / 13TH NOVEMBER 2007

THE DEAN’S OFFICE OF THE FACULTY OF FORESTRY (FF) AT THE UNIVERSITY OF FORESTRY, CITY OF SOFIA, HEREBY CERTIFIES THAT CHIEF ASSISTANT NIKOLAY DYANKOV KODZ HABASHEV IS A LECTURER IN THE FOLLOWING SUBJEC TS:

 ZOOLOGY – AT THE FACULTY OF FORESTRY – EDUCATIONAL AND QUALIFICATION DEGREE “BAC HELOR”, FACULTY OF E COLOGY AND LANDSCAPE ARCHITECTURE – BACHELOR’S DEGREE,

FACULTY OF VETERINARY MEDICINE – MASTER’S DEGREE;

 FAUNA PROTECTION – AT THE FACULTY OF E COLOGY AND LANDSCAPE ARCHITECTURE – BACHELOR’S DEGREE;

 BIOLOGICAL DIVERSITY PROTECTION AND DE VELOPMENT OF ECOLOGICAL NETWORK – AT THE FACULTY OF E COLOGY AND LANDSCAPE ARCHITECTURE – MASTER’S DEGREE.

THIS CERTIFICATE IS ISSUED TO SERVE BEFO RE THE MINISTRY OF ENVIRONMENT AND WATE R.

DEAN OF FACULTY OF FORESTRY:

/ASSOC. PROF. MILKO MILEV, PHD - SIGNED/

ROUND SEAL OF THE FACULTY OF FORESTRY AT THE UNIVERSITY OF FORESTRY, DEAN’S OFFICE

103 Declaration

Under Art. 9, Para 1, It. 4, It. 5, It. 6 and It. 7 of the Regulation on the Terms and Procedure for Implementation of Compatability Assessment of Plans, Programmes, Projects and Investment Proposals with the Object and Purpose of Conservation of Protected Areas, Adopted by Government Decree No. 201/31.08.2007 and Ordinance No. 227 dated 7.10.2010 of the Council of Ministers for amendement and supplement. The undersigned Dimcho Zahariev Ivanov , DO HEREBY DECLARE, that:  I am not a Client of the investment proposal „Extraction of sand and gravel from alluvial deposits in the bed of the Danube river, Kama section (km 512.0 – km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria”;  I am not an owner or a member of the management or supervisory body of the natural person - Contracting Authority and I am not personally interested in the realization of this inve stment proposal;  I am not a related party under §1 of the Additional Provisions of the Commercial Law, neither am I in employment, civil or official relations with the Contracting Authority of the investment proposal;  I am not in employment, civil or official relations with the competent authorities under Art. 10 of the Environment Protection Act ;  I am aware of the current Bulgarian and Europen legislation in the field of environmental protection and I have referred to and complied with these requirements a nd the present methodological documents while working on the assessment under Art. 7, It. 4 of the Regulation.

8th August 2012 Signature......

(Ch. Ass. D. Zahariev, PhD)

104 Declaration

Under Art. 9, Para 1, It. 4, It. 5, It. 6 and It. 7 of the Regulation on the Terms and Procedure for Implementation of Compatability Assessment of Plans, Programmes, Projects and Investment Proposals with the Object and Purpose of Conservation of Protected Areas, Adopted by Government Decree No. 201/31.08.2007 and Ordinance No. 227 dated 7.10.2010 of the Council of Ministers for amendement and supplement. The undersigned Nikolay Dyankov Kodzhabashev , DO HEREBY DECLARE, that:  I am not a Client of the investment proposal „Extraction of sand and gravel from alluvial deposits in the bed of the Danube river, Kama section (km 512.0 – km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria”;  I am not an owner or a member of the management or supervisory body of the natura l person - Contracting Authority and I am not personally interested in the realization of this investment proposal;  I am not a related party under §1 of the Additional Provisions of the Commercial Law, neither am I in employment, civil or official relations with the Contracting Authority of the investment proposal;  I am not in employment, civil or official relations with the competent authorities under Art. 10 of the Environment Protection Act ;  I am aware of the current Bulgarian and Europen legislation in the field of environmental protection and I have referred to and complied with these requirements and the present methodological documents while working on the assessment under Art. 7, It. 4 of the Regulation.

8th August 2012 Signature......

(Ch. Ass. N. Kodzhabashev)

105 Declaration

Under Art. 9, Para 1, It. 4, It. 5, It. 6 and It. 7 of the Regulation on the Terms and Procedure for Implementation of Compatability Assessment of Plans, Programmes, Projects and Investment Proposals with the Object and Purpose of Conservation of Protected Areas, Adopted by Government Decree No. 201/31.08.2007 and Ordinance No. 227 dated 7.10.2010 of the Council of Ministers for amendement and supplement. The undersigned Tanyu Manev Michev , DO HEREBY DECLARE, that:  I am not a Client of the investment proposal „Extraction of sand and gravel from alluvial deposits in the bed of the Danube river, Kama section (km 512.0 – km 508.0) in the region of the village of Pirgovo, Ivanovo Municipality, Bulgaria”;  I am not an owner or a member of the management or supervisory body of the natural person - Contracting Authority and I am not personally interested in the realization of this investment proposal ;  I am not a related party under §1 of the Additional Provisions of the Commercial Law, neither am I in employment, civil or official relations with the Contracting Authority of the investment proposal;  I am not in employment, civil or official relations with the competent authorities under Art. 10 of the Environment Protection Act;  I am aware of the current Bulgarian and Europen legislation in the field of environmental protection and I have referred to and complied with these requirements and the present methodological documents while working on the assess ment under Art. 7, It. 4 of the Regulation.

8th August 2012 Signature......

(Assoc. Prof. T. Michev)

106