Bulgaria

I. Introduction/Recent Political Context

After an initial spurt of rapid change, the pace of reform in Bulgaria has moderated. The early developments were due in large part to the prominence of the Ecoglasnost movement, a former environmental non-governmental organization that has developed into a political force. Prior to the transformations in 1989-90, Ecoglasnost was one of the very few organizations that one could join in opposition to the regime. Consequently, environmental issues were a rallying point for voices otherwise excluded under the system. Ecoglasnost, unlike other similar organizations in the region, took a remarkable step and involved itself directly into the political transformations, forming a political movement and electing members of parliament. Since those early days, it has been part of the governing coalition and also a strong part of the opposition. This involvement in politics has had several effects on Ecoglasnost. It has forced it to broaden its agenda to a vast array of social and political issues, and it has involved its members, formerly prominent environmentalists primarily, into various societal roles. The environment has had to move over for other priorities.

Along with the evolution of Ecoglasnost there has been a related evolution of the whole of Bulgarian society. Whereas the populace had developed a high awareness about the environment prior to the initial phase of transition, since those early days issues of privatization, restitution, commercialization, trade, basic freedoms and government institutions have been discussed in turn. Although environmental awareness remains high, these other issues get a great deal of attention as well. Bulgaria continues, nevertheless, to work on revising and adopting environmental legislation at a steady pace and continues to enjoy one of the highest levels of environmental awareness and concern of any country in the region.

The major constraint identified by persons interested in public participation in Bulgaria is the lack of a definite procedure to obtain information pursuant to the constitution and the environmental law. A second key issue is the lack of responsibility on the side of authorities, due in part to the fact that currently as much as 90% of the regulated community is state-owned. Thus the economic and regulating interests are in conflict. Other problems identified include the lack of expertise and resources to identify technical environmental problems and the low level of initiative of citizens to participate.

II. Legal Structure and Legislative Process

A. Constitution

1) Basic Rights and Obligations

a. Right to Healthy Environment
The Constitution adopted in July 1991 sets forth general principles regarding the environment and provides a general guarantee of access to information by the public. Article 55 states:
Citizens shall have the right to a healthy and favourable environment corresponding to the established standards and norms. They shall protect the environment.

b. Right of Expression
Article 39 guarantees this right, and Article 40 guarantees freedom of the press and the media.

c. Right to Information

Article 41 (2) provides:
Citizens shall be entitled to obtain information from state bodies and agencies on any matter of legitimate interest to them which is not a state or official secret and does not affect the rights of others.

State secrets are those which appear on a list published in 1990 (D.V. 31/1990). The phrase, "[secrets that] affect the rights of others," is ill-defined; Bulgarian legal experts contend that the law currently contains no guidance as to the meaning of this phrase.

d. Right of Free Assembly
Article 43 guarantees the right to peaceful and unarmed assembly for meetings and "manifestations."

e. Right of Association

Art. 44 (1) states simply that "Citizens shall be free to associate." The remainder of that article limits this right in conventional ways (e.g., banning clandestine or paramilitary organizations). Paragraph (3) provides:
The law shall establish which organizations shall be subject to registration, the procedure for their termination, and their relationships with the state.

This paragraph could be read to justify state control over citizen associations. No such rules have been established up to the end of 1993.

Art. 12 (1) provides:
The associations of citizens shall serve to meet and safeguard their interests.

f. Right to Petition
Article 45 gives to citizens the right to lodge complaints, proposals and petitions with the state authorities.

g. Government's Relationship to the Citizens

Art. 1 (2) states:
The entire power of the state shall derive from the people. The people shall exercise this power directly and through the bodies established by this Constitution.

2) Right to Petition Constitutional Court for Review

Under the Constitution, ordinary citizens are not granted a right to petition the Constitutional Court. Rather, the main functions of the court contemplated in that document are resolutions of disputes among the branches of the state power.

The Law on Constitutional Court, No. 67, 16 Aug 91 pp 1-3 Durzhaven Vestnik, contemplates the notification of interested parties in a specific case (Art. 18 (2)), although these interested parties clearly do not have a right to participate in the case (Art. 21 (1)). The Court has discretion to allow participation by interested parties.

Under the Regulation on Organization, Activity of Constitutional Court, No. 106, 20 Dec 91 pp 3-6 Durzhaven Vestnik, these provisions are further elaborated. Parties outside the government may be entered into a case, but only upon petition of the party initiating the action. Those parties who may initiate a case are one fifth of the national representatives, the president, the Council of Ministers, the Supreme Court, the Supreme Administrative Court, the prosecutor general, and certain parties arguing special jurisdictional issues. Article 18 (2) requires the petition to include:
The name and location (address) of interested institutions and individuals who, based on the petitioner's request, should be parties to the case.

Such interested parties are notified by the Court under Article 21 in accordance with the rules of civil procedure. However, the interested parties do not have an absolute right to participate in the case as stated in Article 27, though they may be present in person or through their representatives at proceedings which the Court resolves to be held in open session.

3) Other remedies

Article 7 of the Constitution provides that the state shall be liable for any damages caused by illegitimate rulings or acts of its agencies and officials.

Article 15 of the Constitution places an obligation on the Republic of Bulgaria to ensure the protection and reproduction of the environment, the conservation of living Nature in all its variety, and the sensible utilization of the country's natural and other resources.

B. Legislation and Rule-Making

1) Constitutional Provisions

The Constitution does not provide for its own amendment upon initiative of the people, nor does it expressly grant a constitutional right of initiative or referendum. It may implicitly grant a right of referendum (see below).

2) Right of Initiative

There is no right of initiative under Bulgarian law on the national level.

3) Right of Referendum

The Constitution contemplates referendum but does not expressly provide for a procedure. See Art. 42. A law on referendum is in the draft stage and is pending adoption. Also, Art. 84 (5) enumerates as a power of the National Assembly passing a resolution to hold a national referendum.

Bulgarian legal experts interviewed indicated that some attempts have been made to use referendum rights for environmental purposes under the Law for Polling the People, but they have not been successful due to the vagueness of the law.

4) PP Provisions in Laws

No laws give rights or guarantees to the public to participate in the legislative deliberations of the Parliament or the Government.

5) PP in Parliamentary Practice

The public does not generally participate in the parliamentary procedure. Occasionally committees will hold public hearings on specific issues but generally those invited to make presentations are strictly limited.

6) PP in Governmental Practice

The public is occasionally invited to take part in the drafting of laws on the Ministry level. The case of the draft waste law is discussed under "Case Studies" below.

One example of formalizing the practice can be seen by the establishment of the Council of Social Partnership. Consisting of representatives from government, trade unions and employers organizations, it is a body whose purpose is to facilitate negotiations concerning labor questions. An issue which has been considered is worker safety and the workplace environment.

7) PP on Local/ Regional Government Level

The Constitution, in Article 136 (1), states:
Citizens shall participate in the government of the municipality both through their elected bodies of local self-government and directly, through a referendum or a general meeting of the populace.

The 1991 Law on the Management and Administration of Municipalities provides for direct public participation in matters of local importance. This participation may take the form of public meetings, referenda of proposed or issued ordinances to the electorate, or involvement through the elected representatives. Meetings of municipal councils are advertised and open to the public. The law obliges local authorities to notify the public about their decisions. Local representatives are required to inform their individual constituencies about council decisions. An earlier law, not followed, requires "adequate time-limits" for introduction of every project to the public.

Article 22 of the Local Administration Law appears to give authority to local governments to impose stricter environmental standards on facilities that are entirely within their jurisdiction. Some local governments are investigating the possibility, at the urging of the public, of using contracts as the basis of negotiating environmental controls. As part of the contract negotiation process, public hearings would be held.

By way of example, in one municipality local environmental matters are considered and the laws enforced by the Supreme Ecological Council together with the Mayor. A sub-department on the "ecological program" prepares plans and programs for the ecological development of the municipality, which is established through discussions within the councils that are advertised and open to the public.

On the local level, some municipalities are revising their local laws and ordinances to reflect changes in the national law. For example, one municipality is drafting new ordinances to "reflect the democratic changes" and to reflect the requirements of the Environmental Protection Law. The new ordinances will specifically allow the public and NGOs to participate in local government proceedings, and will provide for the creation of public "green patrols."

C. Right-to-Know and Freedom of Information

1) Constitutional Provisions

Article 41 (2) of the Constitution provides:
Citizens shall be entitled to obtain information from state bodies and agencies on any matter of legitimate interest to them which is not a state or official secret and does not affect the rights of others.

2) Laws

A freedom of information law has been in the draft stage since early 1992 at the latest. There has been no political progress with respect to this law in recent months, and the general opinion of Bulgarian legal and political experts interviewed is that this law has little chance of adoption in the foreseeable future. The current draft contains general statements giving the right of free access to information which is the subject of a person's legitimate interest. The law would place an obligation on government to disseminate any information it has that is of public interest.

Under articles 8 and 9 of the Environmental Protection Law, No. 86, 18 Oct 91, all persons have the right of access to information about the state of the environment, which includes:
data about the result of actions, causing or likely to cause pollution or damage to the environment, or to its components; ... [and] data about activities and actions, undertaken with the purpose of protection and restoration of the environment.

The law further requires the government to gather and requires producers of goods and services to provide such environmental information. Apart from the more specific EIA requirement discussed below, environmental impact information about projects is also available upon request prior to issuing final operating permits. The right to disseminate such information may be limited by other provisions of law, such as those relating to trade secrets. For example, the EIA decree discussed below specifically excludes state, official or other protected secrets, including those protected by the Act on Protection of Competition, from disclosure to the public in the EIA report.

3) Procedures

Procedures for access to information are lacking at present.

4) Reporting Requirements

Producers of goods and services are required to provide to the government and the public the information required to be disclosed under Articles 8 and 9.

Further information disclosure requirements relate to the occurrence of accidental releases and the hazardousness of products entering commerce:
[Authorities, as well as producers of goods and services] shall inform the population without delay when pollution or damage of the environment occur, including natural disasters, industrial accidents and fires, and shall provide information about the changes in the environment that have taken place, the measures for their restriction and elimination and the requirements for the conduct of the citizens with a view to ensure their health and safety...

Arts. 12 (1), 13. Under the environmental impact assessment decree, discussed below, detailed information about the local environment and possible impacts must be provided in the preliminary reports for public discussion.

5) Remedies

Article 15 goes on to state:
An authority or a person who considers that his request for information is unjustifiably rejected or unlawfully restricted, or that the obtained information is unreliable, shall have the right to request protection of his rights through administrative channels or through the court.

A claim may be brought under the Law on Administrative and Legal Services (DV 61/ 1985) under certain circumstances. However, the sanction for failure to provide the information is low (approximately $ 10 US) and there is no remedy for damages and no possibility of injunction.

III. Legal Process

A. Administrative Law and Procedure

1) Administrative Actions by the Public

The Administrative Code provides for ordinary appeal of administrative actions through the administrative process and the possibility of secondary appeal to the judiciary. "Interested parties" have the right to participate in administrative proceedings. As stated in Article 7 (2) of the Administrative Code:
The interested citizens and organizations are informed about the beginning of the administrative procedure.

Following the administrative procedure:
The administrative decision or the refusal to edict a decision is announced in a three-days period after the ediction to all interested citizens and organizations, including those that have not taken part in the procedure.

Art. 17 (1) of the Administrative Code. If an interested party participates in the administrative procedure, it has the right, under Article 11 (2) to respond to the statements of other parties, to provide evidence and to ask the administrative authority to collect evidence. There is no requirement that the decision include any discussion of the contentions of any particular party; that is, the decision-maker does not need to give reasons for failing to accept certain comments. Article 21 (1) provides conventional rights of appeal from administrative decisions for interested parties.

Unfortunately the law and practice in Bulgaria give no guidance about the notion of "legal interest" when applied to associations. According to Bulgarian legal experts, however, there are no special restrictions to limit the ability of associations to intervene, for example on account of certification or registration with authorities or duration of existence. Given the broad purposes of the environmental protection regime, a vast number of persons could potentially have standing as interested parties. See, e.g., supplementary dispositions of the environmental protection law, 1 (5). Under the administrative law, moreover, it would seem that even those parties which meet the broad interest requirements but did not participate in the administrative proceeding, may appeal the final decision.

2) Intervening in an Ongoing Case

Interested parties have the right to enter into an ongoing administrative action. Bulgarian legal experts interviewed knew of no case where this has been used for environmental protection. There is reportedly no body of jurisprudence concerning what is an "interested party." The Civil Code requires "legal injury" for standing in a civil action, however. This could possibly restrict appeal by interested parties who cannot show injury to a single instance before higher administrative authorities.

The administrative law does not provide a means for the public to intervene in the permitting process.

3) Challenging Official Inaction

In addition to the general Constitutional right to make complaints against the government, the law on responsibility of the state for damages to citizens confers the right to citizens to get redress for misdeeds of the government administration and the judiciary. This possibility of recovering damages applies to those injured by official inaction as well. There appears to be no provision under which someone may petition a court to order an official to take action on a matter he has neglected and under which he has a duty to act, however. The law mentioned above applies only to remedies for past misdeeds, and requires injury -- it cannot be used to compel action to avoid possible future harm.

B. Public Participation in Environmental Protection Laws

1) Environmental Impact Assessment

Article 19 of the Environmental Protection Law provides that all activities may be subject to an EIA requirement. EIAs are obligatory for national and regional development programs; territory-structuring and urban-development plans and their amendments, and projects for reconstruction and enlargement of existing enterprises included therein; and specific types of projects enumerated and registered pursuant to an appendix to the law. Furthermore, in certain instances, local government bodies have discretion to order an EIA. Article 20 was amended in late 1992. The changes included granting a right to interested physical or legal entities to propose to competent authorities that an EIA be ordered. Also, certain facilities with large environmental impacts must perform an EIA every five years.

Articles 21-23b spell out the obligations of the investor or proposer of the activity in undertaking the EIA process. Article 23a requires the competent authority to organize the discussion of the results of the EIA. The discussion shall include
(1) the organs of the local administration, representatives of NGOs, the public and interested physical and legal entities.
(2) The persons under 1 must be informed by the competent authority or initiator of the activity by means of the mass media or other suitable way not later than one month before the discussion.

Under Article 23b the competent authority must adopt its decision within 3 months after the holding of the hearing. The competent body shall make conclusions based on the EIA, taking into account the views of the persons participating in the procedure. Within 14 days after adopting its decision, the decision must be published in the same manner as above. Interested parties may appeal the decision to a court under normal laws of administrative procedure within 14 days of the publication of the decision, in matters of local importance, or within 30 days of publication, in matters of national importance. An appeal from the decision of a regional environmental inspectorate shall be taken to the regional court, and an appeal from the decision of the Ministry shall be taken to the Supreme Court.

The Minister of Health may review a negative EIA finding, and may require an assessment of the state of health of affected persons as well.

A decree on EIA was issued 28 December 1992 by the Ministry of Environment, the Ministry of Building, Architecture & Public Works (the "Ministry of Building"), the Ministry of Health, and the Ministry of Agricultural Development, Land use & Restoration of Landed Property. Technically it is both a law for assessment of impacts of proposed projects and a law for audits of operating facilities which, in the opinion of the Minister of Environment and local governments have a significant effect on the environment in the course of their operation, restructuring, privatization or restitution (may result in audits every 5 years for ongoing operations).

Under Section 4 of the decree, "discussion" of a wide range of proposals with potential environmental impacts is required. The specific requirements for the discussion phase are set out in Chapter IV (Sections 8 and 9). This process must be organized by the relevant body which will make the final decision on the EIA. Public organizations and the general public have the right to take part in the discussion (Section 8 (2)). The discussion may not take place until one month after notice has been sent to interested parties and the general public via the national and local mass media. The relevant materials (plans, drawings, tables, models, etc.) must be available for examination at places determined by the local authority. It is the duty of the investor or initiator of the activity to collect and record the written opinions, comments and objections of participants. The competent authority may order additional discussion and consultations with experts if there are controversial issues. Section 8 (3). Official and trade secrets shall be protected from disclosure under Section 9. For regional and town planning schemes, this EIA process shall be a part of the procedure for discussion of the preliminary and final draft of the scheme, in accordance with the laws pertaining to regional and town planning.

Final administrative decisions under the law may be attacked in the courts. For programs, schemes, projects and activities of local significance, the appeal must be taken within 14 days and should be lodged with the local district court. Appeals from decisions concerning programs, schemes, projects and activities with national and international significance must be taken within 30 days to the Supreme Court. Section 10 (8).

The public participation provisions of the EIA decree apply even to projects for which design work began prior to its coming into effect. Those projects are generally covered by Decree No. 1 of 1991 concerning the ecological requirements for regional planning and investment projects of the Ministry of Building and the Ministry of the Environment (D'rzhaven Vestnik No. 24, 1991), but an express exception is made for the public participation procedure, which is to follow the new decree even for such projects. See Transitional and Final Provisions, ¤ 3.

The public participation process in a given case may be cut off, however, by a decision of the Ministry or Regional Environmental Inspectorate that it is "clear" that there are no significant environmental impacts. Only normal administrative challenges (that is, to the next higher administrative authority) apply to this decision.

2) Environmental Permitting

Laws concerning approvals for water use, water discharge, change of use of land or other environmental approvals do not contain provisions requiring public participation.

Issuance of permits depends upon the type of project or facility. Construction projects are generally covered by the Law on Territorial and Administrative Planning. The Council of Ministers has established a committee to approve large projects. A smaller committee within the Ministry of Building approves smaller projects. A representative from the Ministry of the Environment sits on these committees, but according to one source he is generally ignored. Projects solely within a municipality are approved by the municipal councils, with a representative of the regional commission participating.

Typically, development project proposals must first be approved by the municipal Department of Urban Planning or other relevant department, and then by the municipal Department of the Environment. There are no specific public participation procedures applicable to these proceedings, although in many cases there are open hearings held and the press reports on them.

3) Citizen Enforcement, Monitoring and Inspection Rights

There are no specific legal provisions granting citizens extraordinary rights to enforce environmental laws. The Constitution places a general duty on citizens to protect the environment. Citizens have available the normal means of making complaints to competent authorities, but must rely upon the various channels of administration for the advancement of cases. There is no legal basis for direct citizen enforcement in the courts. Citizens may use the liability provisions of Article 30 of the Environmental Protection Act, however, to achieve a similar result. This provision states:
(1) The persons aggrieved under Article 29 [see text under "Liability" below] may lodge a claim and institute proceedings against offenders to stop the damage and to eliminate the consequences of the pollution.
(2) The claims to cease the disturbance and to eliminate its effects may be lodged by the municipal authorities, as well as by associations of citizens with an ideal purpose and by every citizen.

4) Liability

Article 29 of the Environmental Protection Law states:
Persons who are found to have by intent or neglect caused harm to others by pollution or damage to the environment shall be bound to remedy the damage. The compensation may not be less than the sum required to repair the damages caused.

Article 30 of the Environmental Protection Law further provides that associations, citizens or an injured party may request the court to order the dangerous activity to cease. According to authorities in Bulgaria, in the first two years of applicability of this provision, not one single case has been brought making a claim under this Article. Moreover, there is not a single case concerning any portion of the Environmental Protection Act in books on judicial practice published up to 1993.

C. Public Participation Through Other Laws

1) Land Use Laws

A 1988 decree on the public assessment of the programs, plans and projects for construction and urbanization provides a possible means of public participation. Although there is no requirement that the public be notified of specific permit applications, there is an opportunity for public participation in the overall development plan for the local government through the annual publication of the Urban Plan. A one-month comment period is provided after publishing the plan. Permit applications consistent with the plan need not be published, but permit applications that would effect a change in the plan must be advertised and the public has the right to be heard. The public has a right to challenge permits issued if they are not consistent with the Urban Plan.

2) Construction Permitting

Persons affected by an application for a construction permit are required to receive notice and have 7 days to submit comments. Urban Plan issues discussed above may be relevant during this review period.

The approving body depends upon the size and character of the investment. Certain projects involving foreign investors are discussed below. The Law on Territorial and Administrative Planning requires approval of projects by committees, on the level of the government for large projects, and within the Ministry of Building for smaller projects. Projects limited to the area of a single municipality are approved on the municipality level, with participation of the regional planning commission. Environmental authorities take part in the approval process on every level. There are no public participation provisions applicable to these proceedings, although open hearings are held in practice, often with press reportage.

The law on Economic Activity of Foreign Persons and on Protection of Foreign Investment requires that permits for certain foreign investments must be issued by a committee established by the Council of Ministers. A representative from the Ministry of Environment sits on this committee, but his role is limited. There are no specific provisions for public participation or consideration of environmental matters in this law, but the law generally provides that Bulgarian law shall apply to foreign investments unless otherwise specified. This would invoke public participation requirements under EIA laws, for example.

3) Other Laws

The 1980 Law on Suggestions, Grievances, Complaints and Requests requires governmental authorities to respond to complaints filed by aggrieved citizens. Bulgarian legal experts indicate that the law is hardly used. This law requires complaints against a particular governmental body to be referred to an "appropriate" disinterested body for decision. Art. 15. Where complaints are found to be ungrounded, the reasons for rejection must be stated. Art. 16. There is no express possibility for judicial review in the law.

Under Article 4 of this law, the state is prohibited from retaliating against an individual for making a complaint.

There are no laws in Bulgaria which would give a worker a remedy in the case where he is fired or otherwise punished for reporting a violation by his private employer of an environmental law. A draft of the proposed waste law contains an article that would guarantee that a person who reports a violation will not be put into an "offensive situation" because of his act.

In the case of the commission of a crime, the person reporting would be protected from retaliation.

A decree on environmental funds was issued in 1993. This decree establishes rules for administering such funds on the national and regional level and provides for receipts to contribute to the funds. The decree contains a general public participation provision concerned with decisions pertaining to disbursements, which is not clearly formulated.

IV. Anticipated Developments in the Law

As of September 1993 the Ministry of Environment was nearly ready to submit drafts on waste and protected areas to the Council of Ministers, and was drafting additional laws on marine environment, air, biodiversity, land protection, noise, and water. In parallel the Environment Committee of the National Assembly was drafting laws on forest protection and hunting. Bulgarian legal experts familiar with the drafts have indicated that the EIA law will be relied upon to determine public participation rights and obligations, and that the new laws will contain minimal public participation provisions.

A new non-profit corporation law in progress is expected to make it easier for non-governmental organizations to form and operate. They are currently governed by a 40-year-old law on individuals and families.

The relatively young local government law is in the process of a complete overhaul.

There is a proposal to enlarge the information required to be reported and disseminated under section 11 of the Environmental Law to include assessments of the current state of "components" of the environment, and data about protection and restoration activities.

V. Case Studies on Public Participation
(including Public Actions)

The Ministry of Environment has developed a National Environmental Strategy in cooperation with international assistance organizations. This strategy, although considered by some to be the environmental policy of the state (mandated to be prepared by the Minister of Environment under Article 24 of the Environmental Protection Act), has never been acted upon by the Council of Ministers nor presented to the National Assembly for ratification. Consequently it has not been published in the official state gazette. The development of the strategy included the involvement of NGOs and organizations such as Ecoglasnost.

Troyan Project -- a mayor has formed citizen committees on technical issues and policy. The policy committee has held public hearings and operates a "green phone" line. Working with the public, the project administrators determined three priority projects for water quality improvement.

A neighborhood organization called Clear Air in Region Izgrev formed to protest the presence in their neighborhood of a furniture plant. The authorities have found that, except for a few minor violations, the plant operates within legal limitations. The citizens complained that the controls were too lenient. The municipality has taken the side of the citizens, sending a letter simultaneously to the Council of Ministers and the Ministry of Environment and attaching the complaint of the NGO. Both the Ministry of Environment and Council of Ministers will write their opinions in response. At this point there is no court action. The citizens say that they lack the money for a court case and prefer to settle the matter administratively.

Protests against the construction of the Belene nuclear power station included a strike action in early 1990. After eight months of similar protests, the Council of Ministers suspended the project. Civil disobedience resulted in the suspension of lead smelting activities and the implementation of health protection schemes at a lead and zinc plant in 1990. A plan to divert the flow of the Rila River to Sofia (Rila-Mesta Hydro) and construction of the Cherni Ossam Dam were also suspended after protests, although reports indicate that the Ossam dam may be back on the agenda of the Construction Ministry. Other successful public actions mentioned were Dmitrovgrad and Kurjely.

On the other hand, the Ministry of Environment has published drafts of the waste law and has requested public comment, but has received no comments from non-governmental organizations. On a special panel convened to discuss the law, only scientists and lawyers participated and none of them represented NGOs, although the NGOs were invited.


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