Europe’s Living Countryside Project

BULGARIAN REPORTExecutive Summary

WWF DCP, BulgariaSeptember 2005

Europe’s Living Countryside Project

Bulgarian National Report – Executive Summary

© Text 2005 WWF Danube-Carpathian Programme

Prepared by:

Yanka Kazakova, AgRD Coordinator, WWF Danube-Carpathian Programmee.mail: Kazakova@wwfdcp.bg; tel: +359-2-964 05 45

With input from:

Stanimir Stoychev – Stoycheff Consult EOOD Dobromira Dimova – Association of Parks in Bulgaria Svetla Nikolova – Association Agrolink prof. Nadka Ignatova – Forestry University in Sofia.

2

PrefaceThe second pillar of the CAP has been developed to contribute towards sustainable ruraldevelopment and to help rural areas to adapt to changes in Pillar 1 support and to ruralrestructuring, particularly in the agricultural sector. The EU-15 Member States and thecandidate countries developed and implemented a first generation of rural developmentprogrammes following the 1999 Rural Development Regulation and SAPARD. In 2005, theEuropean Agricultural Fund for Rural Development (EAFRD) package of measures wasagreed. This provides the basis for the second generation of rural development programmes inthe enlarged EU-25. EC strategic guidelines for rural development will be published and willplace a stronger emphasis on the need to achieve sustainable development and on EU policypriorities, which include environmental priorities. Overall the new Regulation requiresMember States to take a more strategic, focussed and participative approach to ruraldevelopment as they develop their plans in 2005-6 for the new programmes to beimplemented for the 2007-13 period.

This study is part of Europe’s Living Countryside, a pan-European research project sponsoredby WWF Europe, the Land Use Policy Group (LUPG) of GB’s conservation, countryside andenvironment agencies and Stichting Natuur en Milieu (SNM) in the Netherlands. Nationalstudies were undertaken in seven countries (Spain, Poland, the Netherlands, the UK,Germany, Hungary and Bulgaria – see map below). The aim was to review progress withdeveloping and implementing rural development programmes and to explore in detail howenvironmental priorities and objectives might better be identified and addressed in the newrural development programmes.

Our research builds on Europe’s Rural Futures, an earlier LUPG and WWF Europe pan-European project which analysed MSs’ initial progress with developing and implementing the2000-6 plans. Areas highlighted where improvements could be made included the need for amore strategic, coherent and integrated approaches to addressing environmental issues.

3

The Europe’s Living Countryside national research was carried out using an agreed commonframework. This included analysing the evidence on environmental data and trends, using theresults of mid-term evaluations and holding discussions and/or seminars with keystakeholders to help identify environmental priorities and to consider how the tools in the newregulation might be used to address environmental priorities and improve integration ofenvironmental issues. Each national study includes at least one local case study to illustratehow this could be achieved.

National experts from the LUPG, WWF and SNM partnership coordinated the in-depthnational research, supported in some countries (Germany, the UK and Poland) by consultantscommissioned to undertake the detailed work.

For further information about the Europe’s Living Countryside project please seewww.lupg.org.uk or www.panda.org/epo/agriculture or contact:

Rosie Simpson, Senior European Policy Adviser (Sustainable Land Management),Countryside Agency: Tel: 00 44 1242 521381 rosie.simpson@countryside.gov.uk

Elizabeth Guttenstein, Head of European Agriculture and Rural Development,WWF European Policy Office: Tel: 00 322 740 0924Eguttenstein@wwfepo.org

Arjan Berkhuysen, EU Nature and Agricultural Policies, Stichting Natuur enMilieu: Tel: 00 31 30 234 8218 a.berkhuysen@natuurenmilieu.nl

4

BULGARIA’S EXPERIENCE IN RURAL DEVELOPMENT POLICYBulgaria is scheduled to join the EU on 1 January 2007 and does not yet implement the fullarray of the European policies at national level. The current rural development policy wasintroduced in Bulgaria with the SAPARD programme in 1999. Bulgaria was among the firstcandidate countries to have its SAPARD national plan (NARDP) approved by the EuropeanCommission.

BULGARIA’S RURAL CONTEXT

Bulgaria occupies about 11 million hectares of which 6.4 million hectares are classified asagricultural land and 3.8 millionhectares are classified as forests.4.7 million hectares are arableland and 1.4 million hectares aregrassland and pastures.Protected areas coverapproximately 5% of thecountry, predominantly forestareas. Bulgaria has good naturalresources for agriculture,including some of the mostproductive farmland in Centraland Eastern Europe with a widevariety of farming systems.About 20% of the agriculturalland is mountainous or semi-mountainous.

Rural areas cover 81.4% of the total area. The rural population amounts to over 3.6 millionpeople, approximately 44% of the country’s total population. The major forms of economicactivity in rural areas are agriculture, forestry, tourism and traditional rural crafts.Historically, agriculture has been the backbone of the Bulgarian economy. The share ofagriculture and forestry in the GDP has fluctuated widely reaching 27% of GDP in 1992 andfalling back to about 12,5% in 2002. Bulgarian agriculture is currently characterised by market-orientated large-scale farmsoccupying 74% of the total utilized agricultural land and very small scale individual farms,occupying 26% of the total utilized agricultural land, with an average size of 1.2 ha. With therise of subsistence farming, agriculture has become more labour intensive and agriculture hasacted as an important social buffer to rising levels of unemployment during the transitionperiod.

5

OVERVIEW OF THE STATE OF THE RURAL ENVIRONMENT AND MAINISSUESConsultations suggest that the environmental problems associated with agriculture in Bulgariaare mainly related to soil and water pollution, soil degradation and erosion. This perceptiontreats the agriculture-environment relationship mainly in its negative aspects. The morepositive aspect of farming creating high nature value areas and maintaining important habitatsis not recognized. The ELCo project in Bulgaria focuses on the issues of water andbiodiversity/landscape which usually do not get sufficient attention as issues related toagriculture.

WATERBulgaria is a country with scarce water resources. The water flow is highly regulated.Riverbeds have been canalized and associated biodiversity lost, and dams have been built tostore water. The irrigation infrastructure in the country is significant. In 2002, the areas underirrigation were 22% of the utilized arable land for the period. However, according to theMinistry of Agriculture 40% of the national irrigation network is of low efficiency, and 80%of the secondary channel network is practically ruined. On the one hand, this situation has anegative influence on yields and on crop rotations structure, while on the other it reducessignificantly soil losses due to water erosion.

The quality of the surface water is improving and the nutrient load is declining, althoughagriculture continues to cause point and non-point water pollution. The high level of nitratesin ground water is most often due to agricultural practices. There is a lack of targetedprogrammes for awareness raising among farmers and other rural water users.

There is still a perception that dams are the best solution to water scarcity problems and newapproaches and technologies for water saving are required. The conventional engineeringapproach to water management continues to drive the destruction of the remaining water-related biodiversity (wetlands, riparian habitats).

The Environment Protection Act defines the protection and use of water to secure rationalmanagement at national and river-basin levels. The Water Act defines requirements for waterprotection and use. It only partially delivers the requirements of the Water FrameworkDirective.

The programme for implementation of the WFD in Bulgaria is still not developed. Staff in thedirectorates needs a lot of capacity building and training in order to be able to cope with theambitious tasks and responsibilities put on them. River-basin management planning lackssectoral stakeholder involvement.

Biological monitoring of lakes, reservoir and coastal waters is still implemented only at pilotlevel. The system of criteria and indicators for water classification in terms of biologicalelements is still not developed and adopted.

BIODIVERSITYBulgaria is among Europe's most biodiversity rich countries, with the presence of uniquenatural habitats, flora and fauna.

In compliance with international obligations Bulgaria has developed the National BiodiversityConservation Strategy (1998) and the National Plan for Biodiversity Conservation (2000).

6

However, there is incomplete compliance in respect of natural habitats and the developmentof management plans for species.

Protected areas in Bulgaria cover around 5% of the territory, mostly situated in forest areas:there are about 200,000 ha of virgin forests. Current proposals would increase the total area ofthe protected areas to more than 15% of the territory: the present network of protected areas isnot representative for the country. Parallel to the slow process of announcement of newprotected areas there is a tendency for taking out parts of already established ones due toongoing or planned construction.

The development of the Natura 2000 network in Bulgaria started at the end of 2002.According to expert evaluations Bulgaria has 250-300 potential sites that comply with therequirements of Natura 2000. They cover about 35% of the national territory, which is almosttwice the Government’s estimate of 12-15% of the total area of the country.

The identified threats in the National Plan for Biodiversity Conservation are: application ofinappropriate agricultural techniques and practices (including ploughing of meadows andabandoned agricultural lands), fires, soil degradation, uncontrolled gathering and destructionof plant and animal species, loss of genetic diversity and neglect of indigenous breeds andvarieties.

With regards to the costal ecosystems the threats are water pollution, gathering of rare andendangered species and introduction of foreign species. In the case of wetlands the majorproblems are drainage, changes in the water regime, engineering works on river banks and therelated destruction of plant and animal species and the loss of entire natural habitats.

The problems of the forest ecosystems are related to the poor integration of biodiversityconservation in the legislation. In the last two years new framework documents containingbetter information and priorities regarding conservation of forest habitats have beendeveloped.

Biodiversity conservation outside protected areas, including on HNV farmlands will requirenew measures and habitat degradation as a result of human impact requires restorativemeasures. Local/indigenous valuable agricultural species, local plant varieties and animalbreeds, and the wild relatives of crops and breeds need preservation.

Bulgarian flora and fauna includes a substantial number of endemic species and subspecieswith extinctions over the past few decades. Access to such data is very difficult and oftenconsidered non-existent. More structured data at regional level is available for the fewprotected areas which already have management plans. There is almost no information onbiodiversity outside the protected areas.

Monitoring of biodiversity is still not done in Bulgaria. There are actions taken at the momentto design a biodiversity monitoring programme: monitoring and research is required on theinfluence of different agricultural practices on biodiversity.

Farmers (especially in the less developed rural areas) need encouragement and incentives touse environmentally friendly practices and the Ministries of Agriculture and Environmentrequire strengthening to undertake their environmental roles.

7

LANDSCAPEBulgaria has recently ratified the European Landscape Convention but it is still not transposedin the national legislation. The National Biodiversity Conservation Strategy specifies 12 typesof ecosystems and landscapes as unique and representative for the Bulgarian biologicaldiversity. The major part of the important landscapes is included in the large protectedterritories. Such landscapes are included also in the three national parks and the ten naturalparks.

Data on landscapes is not collected at the moment at all, so it is difficult to evaluate landscapechanges. The changes in landscape resulting from human impact in the form of infrastructurechanges are a substantial problem. Introduction of large infrastructure projects, observedmostly in the high mountains and on the Black sea coast, has led to negative changes in thelandscape diversity of the country. The abandonment of arable land and pastures as well as theploughing up of meadows and the clear-cutting of small woodlands in arable fields also bringsignificant landscape changes.

In recent years there is a tendency for subtracting lands from designated agricultural land andincluding them in the construction boundaries of settlements. This process is observed mostlyaround the big cities and the Black sea coast. Often the subtracted lands are meadows, someof which are species-rich. The construction that follows leads to substantial changes inlandscape and loss of species and habitats.

The efforts of various institutions (regional development, agricultural, environmental andnature conservation, scientific, land and resource users) need better integration to achievesuccessful results in the management of the landscapes.

HIGH NATURE VALUE FARMING AREASThere are several mountain ranges in Bulgaria where the habitats and species are of pan-European importance. Their conservation depends on the maintenance of the existingextensive agricultural practices. The preservation of the local breeds, which are oftenconnected with different mountainous zones, contributes to the maintenance of rich geneticdiversity. According to the National Biodiversity Conservation Strategy grasslands andwetlands are the most vulnerable and threatened habitats in the country. Much of thebiodiversity and ecosystems are on, or in the immediate vicinity of farmland, and are directlyor indirectly influenced by agriculture.

Important natural resources on farms include vast territories of unaltered semi-natural regions,such as meadows, pastures, protected animals and plants, which are not to be found in naturereserves or other protected areas and are the main resource for agri-environmental protectioninitiatives. High Nature Value farmland contributes significantly to environmental assets.

As yet, the concept of HNV farmlands is not applied in Bulgaria. A large share of Bulgaria’sfarmland can be defined as HNV although there is a lack of inventory and mapping. Overallthere is almost no information on HNV farmlands’ status and distribution in the country.There is no government strategy or action plan for the maintenance and conservation of HighNature Value farmlands.Grasslands cover approximately 30% of the total agricultural land and are mostly semi-natural, divided into pastures, covering approximately 70%, and the remaining 30% used forhaymaking. Traditional practices such as haymaking, application of wood ashes, manuringand sowing of additional grass mixes have declined.

8

With the significant decrease of livestock numbers in Bulgaria the importance of grasslands asa fodder resource has decreased as well. As a result, many hay meadows are being ploughedup and pastures especially in remote areas are abandoned. These two factors threaten as manyas 40% of the existing grasslands in the country.

Improvements are required in the political framework for the maintenance and conservation ofthe HNV farmlands in Bulgaria, with better joint and coordinated actions between theMinistry of Agriculture and the Ministry of Environment, and involvement of keystakeholders (e.g. farmers, nature conservationists).There are no measures to support the conservation of HNV habitats and the related productionsystems. Rural development measures for the management of HNV farmland are neededbearing in mind the traditional importance of these systems for rural people.

THREATS POSED TO THE ENVIRONMENT IN RURAL AREAS

Traditionally agricultural and forest practices contributed to the creation and diversity of highnature conservation value areas. Many of them are still preserved in the mountainous andremote areas in Bulgaria. However, the more intensive agricultural and forest practices of thelast decades led to significant changes and degradation of environment and nature. The nextbox summarizes the main threats posed by intensive and/or unregulated agricultural and forestactivities. The public support coming from the national rural development programme shouldprevent degradation and whenever possible introduce targeted measures to improve the statusof the environment.

9

Box 1: Main threats posed by farming and forestry

FARMING

• Scrub encroachment in high mountainpastures due to lack of grazing animals.

• Degradation processes and loss of plantand animal species due to ploughing ofmeadows.

• Water pollution caused by eitherexcessive use of chemicals or improperpractices.

• The reversal of monoculture agricultureon large areas (eg. in Dobridja andTrakiiska nizina).

• Burning of stubble.

• Degradation processes andoverexploitation of grasslands nearsettlements due to overgrazing bylivestock.

• Logging of natural lowland forests andconverting them into arable lands.

• Expansion of goat breeding, especiallyin the forest regions

• Loss of native breeds and crops.

• Reduction of the rice fields, which leadsto reduction of the wetlands that areimportant for the birds.

• Semi-wild grazing by stock pigs (eg. inStrandja).

FORESTRY

• Substantial changes in the biological andlandscape diversity as a consequence offrequent forest fires.

• Illegal logging.

• Change of the natural communities as aresult of improperly planned orconducted renovation measures.

• Erosion resulting from the methods usedin the economic exploitation of forests.

• Water regime disorder as a result ofdrainage, construction of dams and otherirrigation facilities, and redistribution ofbig quantities of water for industrialpurposes.

• Substitution of habitats with intensiveforest crops and foreign and exoticspecies.

• Decrease in the area of forest habitats asa consequence of infrastructureconstruction, private home construction,industrial construction, and change offorestlands into arable lands

• Increased pressure from tourism.

• Low level of farmers and foresters’ awareness (especially in the less developed ruralregions) with regards to the problems of biodiversity conservation and the existingprogrammes and funds in this respect.

• Lack of tools for stimulating the farmers and forest owners to conserve biodiversity andimplement environmentally-friendly practices.

• Lack of monitoring and research on the influence of different agricultural and forestpractices on biodiversity.

10

KEY ENVIRONMENTAL ISSUES RELATED TO FARMING AND/OR FORESTRYThe selection of environmental issues presented is not exclusive and does not mean that theyare the only ones of importance for the country. However, we consider that biodiversity getslittle priority in developing agriculture and forest programmes and water is only mentionedwhen water pollution problems are concerned. Therefore, we selected issues that are presentthroughout the whole country with the aim to initiate integrated and coordinated actions totackle them. We also hope to demonstrate that farming activities, farm viability and natureconservation are not competing processes and can be complementary and mutually supportive.For the chosen themes of water and biodiversity, the issues related to farming, forestry and/orrural development can be summarized as follows:

WATER1. Continuous loss of riparian habitats due to infrastructure development through

• Dam construction for securing water resources for irrigation• Riverbank vegetation clearance • Excessive water consumption for irrigation

2. Reduced water quality due to pollution from settlements, farmlands and non pointsources through

• Improper manure management facilities due to lack of knowledge and funding• Water pollution due to improper agricultural practices• Lack of sewage systems in many rural settlements

BIODIVERSITY3. Loss of biodiversity and landscape diversity due to land abandonment through

• Loss of mosaic landscapes especially in mountainous areas• Abandonment of extensive pastures (HNV areas) due to decreased numbers of farm

animals

4. Loss of traditional farming systems and the related biodiversity due to intensificationthrough

• Ploughing of wet meadows for conversion• Loss of local breeds of animals• Loss of shelter belts, terraces and other landscape features • Decline of valuable animal and plant species due to uncontrolled gathering by local

people

5. Conflict between farmers and wild fauna through• Conflict between farmers and large carnivores• Declining number of waterfowl due to poaching and hunting.

11

PROPOSED OBJECTIVES AND TARGETS FOR THE SELECTEDENVIRONMENTAL ISSUESFor each of the issues and sub-issues listed above a set of objectives and examples ofquantified targets are proposed in the report which are relevant to the rural developmentprogrammes and measures.

Issues Objectives Targets

Continuous loss ofriparian habitatsdue to irrigationinfrastructuredevelopment

• Develop a strategy for the restorationand management of riparian habitatsin line with the WFD;

• Ensure that the measures have directlinks to Natura 2000, river basin andexisting protected areas managementplans;

• New hydro-infrastructure projectsmust not lead to any further loss ofriparian habitats throughout thecountry;

• In each of the four riverbasins riparian habitats andfloodplain restorationmeasures are implementedby 2013

• X m/km/ of riverbankvegetation (tree belt) isrestored by 2013.

• 40% of the areas underirrigation have water savingtechnologies by 2013.

• The loss of water because ofoutdated irrigation systemsis reduced by X%.

Reduced waterquality due topollution fromsettlements,farmlands and nonpoint sources

• RD measures in place that willcontribute to achieving goodecological status of the rivers by2015;

• Develop an action plan for dealingwith the water pollution fromagriculture, not only for Nitratevulnerable zones;

• Ensure an integrated planning of therural infrastructure development (newsewage systems, etc) between theagriculture, regional development andenvironmental authorities.

• 80% of the farms haveproper manure managementfacilities by 2013.

• X settlements have newsewage systems;

• The size of the nitratevulnerable zones is reducedby X ha by 2013.

12

Loss ofbiodiversity andlandscape diversitydue to landabandonment

• RD measures are in place that willcontribute to achieving favourableconservation status for the N2000areas within 10 years;

• Define appropriate land use patternsand farming systems for the areasmost threatened by land abandonment(Strandja, Rodophi, etc.) togetherwith the nature conservationauthorities, in partnership withfarmers and NGOs;

• Ensure that all policies (agriculture,RD, regional, etc.) in the region worktowards achieving them;

• 90 % of all HNV areasreceive support forenvironmental farming by2013;

• at least 5 initiatives aredeveloped and implementedto demonstrate the positivelink between the farmingpractices and biodiversityand landscape diversity;

Loss of traditionalfarming systemsand the relatedbiodiversity due tointensification

• RD measures contribute tomaintaining traditional farmingsystems and the related biodiversityin the long-term;

• Define appropriate patterns of landuse and farming systems that willcontribute to the conservation ofhabitats and species of national andEuropean interest.

• Ensure that Pillar 1 and Pillar 2payments work in an integrated wayto promote these objectives.

• Ensure that measures have directlinks to Natura 2000 and river basinmanagement plans.

• Measures are in place andtaken up for 80% of allexisting wet meadows by2013;

• Undertake re-conversionactivities towards wetmeadows in at least 5regions by 2013. the numberof animals of 4 local breedsis doubled by 2013.

• X m of wild belts / terracesare maintained and restoredby 2013;

Conflict betweenfarmers andanimals

• Develop measures jointly betweenagriculture and nature conservationauthorities, in partnership withfarmers and NGOs to reduce thisconflict;

• Ensure that these measures havedirect links to Natura 2000 andprotected areas management plans;

• Support the traditional farmingsystems, dealing with the conflict;

• The number of animalskilled by farmers because ofthis conflict is reduced by75% by 2013.

13

STRUCTURE AND CONTENT OF THE SAPARD PROGRAMME IN BULGARIA

Bulgaria has one national plan for the period 2000-2006 which sets the framework for theimplementation of the SAPARD programme in the rural areas. This National Agriculture and Rural Development Plan is developed by the RuralDevelopment Directorate of the Ministry of Agriculture and Forestry. The practicalimplementation of the measures in the country is a responsibility of the SAPARD Agency,which combines the functions of implementing and paying bodies.

The Bulgarian national plan for agriculture and rural development has two main objectives:1. Development of efficient and sustainable agricultural production and competitivefood processing sector through improved market and technological infrastructure andstrategic investment policies, ultimately aimed at reaching EU standards.

2. Sustainable rural development, consistent with the best international environmentalpractices by providing alternative employment opportunities, economic diversification,development and rehabilitation of infrastructure. The national plan envisages theirachievement via the implementation of 11 measures.

Top priority (78% of the budget) is given to the actions to cover strategically importantactions related to the improvement of production and processing in the agricultural sector incompliance with the EU acquis. There are six measures in which the beneficiaries are mainlyprivate agricultural and forestry holdings and food processors. The second priority area (18% of the budget) covers the implementation of integrated ruraldevelopment plans in selected Bulgarian rural regions. The importance of this priority area isexpected to grow over time. For the achievement of the second objective - integrated andsustainable rural development - 3 measures are defined, i.e. diversification of activities of theprivate agricultural holdings, renovation of villages and protection of heritage anddevelopment of public infrastructure.

The objective of the development of human resources (third priority area) has one measure –improvement of vocational training. The fourth priority area – technical assistance - is designed to assist in the implementation andmonitoring of SAPARD Programme.

Initially there were three approved measures:• investments in agricultural holdings, • improving the marketing and processing of agricultural and fishery products, and • development and diversification of economic activities, provision of multiple activities

and alternative income.

Six more measures were approved in August 2003: • forestry, afforestation of agricultural areas,• investment in forest holdings, processing and marketing of forestry products, • setting up producer groups, • renovation and development of villages, • protection and conservation of rural heritage and cultural traditions,

14

• development and improvement of rural infrastructure, • improvement in vocational training and technical assistance.

The remaining two measures • “Management of Water Resources” and • “Development of Environmentally Friendly Agricultural Practices and Activities”

are not yet approved.

ENVIRONMENTAL DESCRIPTION AND OBJECTIVES INCLUDED IN SAPARDEach of the measures has its own operational objectives. Environmental protection is reflectedin most of them. In most cases the Plan requires that the project/holding of the beneficiaryshould comply with the current national standards regarding the environment at the time whenthe decision to grant is taken. In the cases where the activity of the applicant is subject tomandatory Environmental Impact Assessment, according to the Environmental ProtectionAct, the decision should be included in the application package.However, there are no environmental indicators for progress towards objectives.

WATERIn general the environmental description covers all the main environmental issues includingwater quality and quantity (mainly water protection from pollution by fertilizers, pesticide andheavy metals). Nevertheless several specific issues in relation with water protection are notcovered sufficiently in the programme. The programme does not provide enough quantified data on the state of water quality in therural areas. The agri-environmental measure provides more information on water quality inthe rivers Struma, Arda, Rusensky Lom, Veleka which are the pilot areas of the Anti-erosionaction. The interrelations between farming activities and water-related biodiversity (wetlands,floodplains, riparian habitats, etc.) are not discussed in the environmental description at all.

BIODIVERSITY/LANDSCAPE

The environmental section of the SAPARD programme in Bulgaria describes mainlyproblems related to the environmental components and less on issues concerning theconservation and restoration of biodiversity.

There is no information on the landscape diversity in the environmental context section. Thisdiversity is mentioned only in the description and categorization of the protected areas.Conservation of landscape and historical heritage in the less developed rural regions is notpointed out. The place of the high nature value farming areas is not pointed out in thedefinition of the future national ecological network (Natura 2000).

HIGH NATURE VALUE FARMLANDS

The existence of high nature value farming areas is not specified in the present NationalAgriculture and Rural Development Plan. Inclusion of HNV farming areas will play a positiverole in the conservation of biological diversity of species and habitats. It is recommended toassess the potential sites in the country, which are suitable for application of this system.

15

OFFICIAL EVALUATIONS OF THE SAPARD PROGRAMME IN BULGARIA

a. Ex-ante evaluation (2000)In terms of impact on environmentally important areas, the SAPARD measures were notexpected to have any negative effects. A rapid assessment for the measures’ influence on theimplementation of the Habitats and Birds Directives was recommended, as well as todesignate areas before the implementation of the SAPARD in Bulgaria. This has not happenedyet.

Sufficient information on protected flora and fauna species was not available and therefore itwas not possible to comment on potential impact that SAPARD might have on theirpopulations. The evaluators concluded that at least five of the measures could have a positiveimpact on the environment in agriculture and forest land.

However, it was noted that the environmental impact depends a lot on the eligibility andselection criteria that are used and the incorporation of certain environmental policy andstructural tools in the procedure. Specific recommendations were made and particularemphasis was given on the monitoring and evaluation procedures of projects so as to includeenvironmental parameters. The results of the Mid-Term Evaluation and the related lack ofenvironmental performance information revealed that these were not followed.

Overall, the evaluators state that the Bulgarian SAPARD Plan is drafted towards the supportof economic development in agricultural and rural areas, through concerted agrarian andalternative economic activities.

The current implementation results show that the recommendations of the ex-ante evaluatorswere not followed, especially regarding the integration of environmental parameters in themonitoring and evaluation procedures of projects. Therefore the achievement of the statedSAPARD environmental objectives is questionable.

b. Mid-Term Review of the SAPARD programme in Bulgaria (2003)The Mid-Term Evaluation (MTE) of the SAPARD programme in Bulgaria1 covered theperiod of implementation from June 2001 to May 2003. The data available for the evaluation are also considered limited by the evaluators whoorganized additional interviews and focus groups to collect more information. The MTE concludes that the SAPARD programme has had a positive contribution to theimplementation of the acquis communautaire concerning the CAP. Protection ofenvironment, compliance with product hygiene and food safety standards were integrated inthe eligibility criteria for projects’ selection. However some important indicators includingwaste generation, manure and slurry storage methods, pollution discharge and impact onlandscape and biodiversity, were omitted.

By the time of evaluation no projects targeted exclusively at environmental improvementshave been implemented. In almost all the supported investments, beneficiaries stated thatinvestments respect the EU standards for protection of environment and the productionprocesses meet the requirements of the environmental protection legislation. However, there isno structured procedure to verify this. On the contrary, a report by the European Court ofAuditors reveals that such checks on the compliance of the investments with environmentalstandards are not carried out. 1 The evaluation was done by Agriconsulting Europe S.A.

16

The SAPARD Programme has been adding significant investment funds to the Bulgarianagriculture and processing industry. Supported investments in agricultural holdings in the first3 quarters of 2003 are equal to 88% of the gross investments in the Bulgarian agriculture in2001, and the SAPARD supported investments in the processing industry are about 50% ofthe investments in all food industry sectors in 2001. The underdeveloped agricultural credit market and the complexity of SAPARDimplementation arrangements have skewed the distribution of funds towards largeragricultural holdings and food processing companies and to projects with a shorter investmentcycle.

Further conclusions of the MTE are that the SAPARD application form and business plans arerather complex. In addition, the list of supporting documents both in the application stage andin re-payment stage was regarded as being too long and that their collection requiredsignificant financial and physical resources on the behalf of the applicant.

c. EU Court of Auditors Special Report “Has SAPARD Been Well Managed”Bulgaria was one of the accession countries visited by the auditors of the European Court ofAuditors to evaluate the SAPARD programme implementation2. On the environmentalperformance of the SAPARD Programme in Bulgaria the results of the audit confirm that thecountry granted higher priority to other measures than agri-environment, forestry, etc. At thesame time the management and control systems of all measures foresaw insufficient checks inrisk areas such as compliance with minimum standards for environment, hygiene and animalwelfare. Another conclusion of the auditors’ report is that the SAPARD money has generally beenspent on projects that increase the quantity of agricultural production, and not on projectswhich improve the quality of agricultural production (meeting quality and health standardsand protection of the environment). On the application process the report of the auditors conclude that the number and difficultyof obtaining the supporting documents is too high and their relevance is not always clear.However, the report states that the cumbersome administrative procedures are common for allSAPARD countries and are stricter than those required by the Commission.

Overall, assessing the two official SAPARD evaluations – Ex-ante and Mid-term, andthe situation on the ground in the country, we can conclude that the major objective andguiding principle of the SAPARD programme in Bulgaria is to improve thecompetitiveness of the agricultural sector (mainly medium and large scale holdings andenterprises) with the social and environmental objectives being a “wish list” of thingsthat might happen but without a real mechanism to pursue them.

2 EU Court of Auditors, Has SAPARD been well managed? Special Report No.2/2004, OJ C295, p.1-22,30.11.2004

17

RECOMMENDATIONS FOR ADDRESSING THE ENVIRONMENTAL ISSUES

Recommendations on WATER

• Nationwide awareness-raising programme is needed to overcome the old-fashionedthinking that dams are the best solution to water scarcity problems;

• Sectoral stakeholders (farmers and foresters, their associations, agricultural advisors, etc.)should be actively involved from the very beginning in the river-basin managementplanning;

• Rural development measures (eg. axis 1 – investments in agricultural holdings, axis 3 –rural infrastructure, etc.) should support new water management approaches and watersaving technologies (eg. on farm drip irrigation systems);

• Further destruction of the remaining water-related biodiversity (wetlands, riparianhabitats) should be prevented by requesting environmental plans from all projectssupported under the rural development plan;

• The training and advisory measures should support targeted programmes for farmers andother rural water users on the issues of water pollution prevention, water-savingtechnologies and practices, etc.

Recommendations on BIODIVERSITY

• Introduce rural development measures (agri-environment, forest-environment, less-favoured areas payments) aiming to support biodiversity conservation both inside andoutside protected areas, including on high nature value farmlands

• Introduce targeted agri-environment and forest-environment measures to restore habitatsthat have degraded as a result of human impact – meadows, pastures, wetlands, forests,wood and shrub strips dividing arable lands.

• A combination of axis 1 (investment, training, advisory) and axis 2 (Agri-environment andLFAs payments) measures is needed to preserve local/indigenous valuable plant varietiesand animal breeds, and the wild relatives of crops and breeds.

• The development of biodiversity management plans on agricultural and forest landsshould be supported under the rural development programme (including mapping ofhabitats and land uses, and monitoring on the influence of different agricultural and forestpractices on biodiversity).

Recommendations on LANDSCAPE

• The ex-ante evaluation of the national rural development plan should assess the impact ofthe measures proposed from all axes on the landscapes in the country and whether thereare sufficient precautionary measures for tourism and other rural infrastructuredevelopment.

• Axis 2 measures should effectively contribute to the maintenance of the designatedvaluable landscapes via the agri- and forest-environment, LFAs and Natura 2000payments measures.

18

• Afforestation measure should not change valuable landscapes by planting trees on species-rich grasslands.

• The local development strategies supported under the axis 3 and Leader should considerthe surrounding landscapes and introduce actions to enhance them.

Recommendations on HIGH NATURE VALUE FARMLANDS

• The Bulgarian government should develop a strategy and an action plan for themaintenance and conservation of High Nature Value farmlands

• Inventory and mapping of High Nature Value farmlands could be supported under therural development plan;

• Measures from all axes supporting both directly the conservation of HNV habitats (axis 2)and indirectly by supporting the related production systems (axis 1) and the relatedinfrastructure (axis 3) should be introduced.

Recommendations on PUBLIC PARTICIPATION MECHANISMS The SAPARD programme is providing experience and knowledge in public participation inBulgaria’s rural development policy. There are actions that need to be taken in order to buildon this mainly positive experience and to improve it for the next programming period:

• The formalisation of the procedures for involving stakeholders – social, economic andenvironmental in the design, implementation, monitoring and evaluation of programmesand measures at local, regional and national levels;

• Capacity building measures and funding for local and regional stakeholders’ participationshould be introduced to make them an active and equal partner for rural development.

• The model of the transparent nomination process established by environmental NGOsshould be used as a democratic model by other economic, agricultural and social partners;

• Stakeholders groups need to elaborate criteria and process for nominating and selectingrepresentative. The participation of these representatives should also be subject tomonitoring and evaluation.

• The stakeholders outside the inter-ministerial working group should be involved in thevery beginning of the process of programme’s design and measures;

Recommendations on DELIVERY MECHANISMS Overall, greater promotion and targeted delivery of the programme to encourage participationfrom all potential beneficiaries is recommended:

• Up-dated quality information on the funding possibilities should be available at the lowestpossible administrative level (village or municipality).

• Delivery should be adapted according to the target group characteristics – more effortsshould be focused on small and medium-size applicants.

• All applicants (not just registered agricultural producers) should have access to various

19

expertise/advices to beneficiaries – technical, economic, environmental, etc.

• Allow other organizations than the National Agricultural Advisory Service to provideconsultancies and get paid for it.

• Provide regular and specialized training to the advisors - improve their knowledge andskills, do not rely only on their old background.

• Prepare and make available more easily understandable and user-friendly guidelines forapplicants.

Recommendations on MONITORING, EVALUATION AND INDICATORSThe SAPARD programme was the first to introduce monitoring and evaluation mechanisms inBulgaria and to allow for public participation in it. The experience shows that it is probablyone of the most difficult tasks for all involved parties.

• Quantitative and qualitative indicators, including environmental should be developed atthe very beginning of the programmeming process. They should be subject to approvalwith the whole package of programme’s objectives, priorities, measures, etc.;

• Baseline information on the proposed indicators should be collected in due time;

• Access to project data should be provided at least for the members of the monitoringcommittee, its working groups and programme’s evaluators;

• Systemized information on the status of achievement of the objectives of programmeandmeasures should be provided on a regular basis (annually)

• Ensure transparency of all aspects of programme implementation

• Identify the “good practices” and promote them among beneficiaries and applicants

• Introduce corrective measures/actions in due time

• Strengthening the role of the stakeholders in programme implementation. Theeffectiveness of their inputs could be improved if further training is provided.

• The Monitoring Committee should develop a mechanism and procedures for feed back onthe implementation of decisions taken and reasons for not doing so.

• Create possibilities for involving independent experts (NGOs, etc.) in the whole cycle ofmonitoring, evaluation and control of the programme.

20