E862 Volume 2 MINISTRY OF AGRICULTURE AND FORESTRY OF BULGARIA ENVIRONMENTAL ASSESSMENT OF THE FOREST DEVELOPMENT PROJECT, BULGARIA Final Report Helsinki January 28, 2004 , X ' TABLE OF CONTENTS ABBREVIATIONS AND ACRONYMS ....v..........................v EXECUTIVE SUMMARY .............................. vii 1. INTRODUCTION .1 1.1 Project Background .1 1.2 Objectives and Scope of the EA ..2 1.2.1 Objectives .2 1.2.2 Scope .2 1.3 Phases of Environmental Assessment .3 1.3.1 Activities Carried Out .3 1.3.2 Participation of Stakeholders .4 1.4 Contents of the Report ..4 2. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...5 2.1 Policy and Legislation .5 2.1.1 National Framework .5 2.1.2 International Commitments .7 2.1.3 Requirements of Financing Agencies .8 2.2 Institutional Framework ..9 2.2.1 Relevant Government Administration .9 3. DESCRIPTION OF THE FOREST DEVELOPMENT PROJECT ...10 3.1 Project Development Objectives and Key Indicators . .10 3.2 Project Components ..11 3.2.1 Component 1: Strengthen Public Forest Sector Management . .11 3.2.1.1 Building and Strengthening Nation-wide Forest Extension and Inspection Services .11 3.2.1.2 Building and Strengthening a Nation-wide Forest Fire Management System .11 3.2.1.3 Developing a Forest Information and Monitoring System, Including Updating of National Forest Database .12 3.2.1.4 Illegal Logging Surveillance and Monitoring .13 3.2.1.5 Finalization of Forest National Certification Standard .13 3.2.1.6 Support for Professional Technical Schools .13 3.2.2 Component 2: Strengthening of Capacities of Non-State Forest Owners .. 14 3.2.2.1 Fostering National Association of Private and Communal Forest Owners .14 3.2.2.2 Supporting Community-based and Communal Forest Owners Associations .14 3.2.2.3 SAPARD Realignment and Support .14 3.2.3 Component 3: Supporting State Forest Management Transition to Market Economy . .15 3.2.3.1 Implementation of Restructuring Plan for the National Forest Company .15 3.2.3.2 Upgrading of Forest Road Network .16 3.2.3.3 Thinning of Young and Fire Prone Stands .16 3.2.3.4 Reforestation and Rehabilitation of Destroyed and Devastated Forest Fire Sites .17 3.2.3.5 Implement Pilot Certification in Selected State Forests .17 3.2.4 Component 4: Promotion of Biodiversity Conservation in Forest Management ..17 3.2.4.1 Mainstreaming Biodiversity Conservation in Forest Management Planning .18 3.2.4.2 Integration of Biodiversity Conservation in Forest Management Operations .20 Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28. 2004. 3.2.4.3 Strengthening the System of Forest Nature Parks Managed by the National Forest Company ................................................... 22 3.2.4.4 Development of the Bulgaria Protected Areas Fund Endowment ........... 24 3.2.4.5 Forest Biodiversity Program Coordination and Management ................. 25 3.2.4.6 Joint Implementation Capacity Enhancement and Project Pipeline ........ 25 3.2.4.7 Additional Component Annexed to EA Assignment: Bulgaria Fuel Switch Pilot Project ................................................... 25 3.2.5 Component 5: Project Management and Monitoring . ............................. 25 3.2.5.1 Project Management ....................................... 26 3.2.5.2 Project Monitoring ....................................... 26 3.3 Institutional Arrangements for Project Implementation . ..................................................... 26 4. BASELINE DATA ............. 27 4.1 Forest Resources .................................. 27 4.2 Forest Management .................................. 27 4.3 Timber Harvesting .................................. 28 4.4 Non-wood Forest Production ................................. .. 29 4.4.1 Hunting and Fishing ................................. 29 4.4.2 Herbs, Mushrooms and Forest Fruits .. ............................... 30 4.4.3 Tourism and Recreation ................................. 30 4.5 Trends in Resource Use ................................. . 30 4.5.1 Forest Industries ................................. . 30 4.5.2 Harvesting Levels ................................. . 31 4.5.3 Illegal Harvesting ................................. . 32 4.5.4 Allowable Cut .................................. 33 4.6 Forest Ownership .................................. 33 4.7 Environmental Status ................................... 34 4.7.1 Biological Diversity ......................................... 34 4.7.1.1 Status ........................................ 34 4.7.1.2 Biodiversity Conservation and Management ........................................ 35 4.7.2 Water and Soil Protection ......................................... 35 4.7.3 Forest Health ........................................ . 36 4.7.4 Carbon Management ......................................... 36 4.8 Social Issues .......................................... . 37 4.9 Forest Administration .......................................... . 38 4.9.1 Structure and Functions ........................................... 38 4.9.2 Management of State-owned Production Forests . ................................ 38 4.9.3 Management of Protected Areas .......................................... 39 4.10 Other Forest-related Entities .................................... .. 39 4.10.1 Communal Forest Organizations .. .................................. 39 4.10.2 Non-govemmental Organizations .. .................................. 40 4.11 Public Participation ..................................... 40 5. ENVIRONMENTAL IMPACTS ..................................... . 41 5.1 Conduct of Assessment .................. 41 5.1.1 Approach .......................................... . 41 5.1.2 Methodology .......................................... . 43 5.1.2.1 Overview .......................................... 43 5.1.2.2 Impact Assessment .......................................... 43 5.1.2.3 Control of Significant Environmental Impacts ........................................ 46 5.1.2.4 Environmental Management Plan .......................................... 46 5.2 Component 1: Strengthen Public Forest Sector Management . ............................................ 46 5.2.1 Key Issues ...................................................... 46 5.2.2 Coverage and Impacts of the FDP Intervention . ..................................................... 47 5.2.3 Suggested Mitigation and Enhancement Measures . ............................................... 48 5.3 Component 2: Strengthening of Capacities of Non-State Forest Owners ... 49 5.3.1 Key Issues ...................................................... 49 5.3.2 Coverage and Impacts of the FDP Intervention . ..................................................... 50 Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. January 28, 2004. 5.3.3 Suggested Mitigation and Enhancement Measures . ............................................... 51 5.4 Component 3: Supporting State Forest Management Transition to Market Economy ..... 52 5.4.1 Key Issues ....................................................... 52 5.4.1.1 National Forest Company (NFC) ....................................................... 52 5.4.1.2 Upgrading of Forest Road Network ....................................................... 52 5.4.1.3 Thinning of Young and Fire Prone Stands .............................................. 55 5.4.1.4 Reforestation and Rehabilitation of Destroyed and Devastated Forest Fire Sites ....................................................... 56 5.4.1.5 Implement Pilot Certification in Selected State Forests .......................... 57 5.4.2 Coverage and Impacts of the FDP Intervention . ..................................................... 58 5.4.2.1 National Forest Company (NFC) & Pilot Certification ........................... 58 5.4.2.2 Upgrading of Forest Road Network ............................................... 58 5.4.2.3 Thinning of Young and Fire Prone Stands .............................................. 60 5.4.2.4 Reforestation and Rehabilitation of Destroyed and Devastated Forest Fire Sites ............................................... 61 5.4.3 Suggested Mitigation and Enhancement Measures . ............................................... 61 5.4.3.1 National Forest Company (NFC) ....................................................... 61 5.4.3.2 Upgrading of Forest Road Network ....................................................... 62 5.4.3.3 Thinning of Young and Fire Prone Stands & Rehabilitation of Destroyed and Devastated Forest Fires Sites .......................................... 63 5.5 Component 4: Promotion of Biodiversity Conservation in Forest Management ... 63 5.5.1 Key Issues .......................................... . 63 5.5.1.1 Biodiversity Conservation .......................................... 63 5.5.1.2 Carbon Sequestration .......................................... 65 5.5.1.3 Emission Reduction .......................................... 66 5.5.2 Coverage and Impacts of the FDP Intervention . ................................. 68 5.5.2.1 Biodiversity Conservation .......................................... 68 5.5.2.2 Carbon Sequestration and Emission Reduction ....................................... 69 5.5.3 Suggested Mitigation and Enhancement Measures . ............................... 71 5.5.3.1 Biodiversity Conservation .......................................... 71 5.5.3.2 Carbon Sequestration and Emission Reduction ....................................... 72 5.6 Overview of Significance Analysis and Cumulative Impacts . ............................................ 73 6. PROJECT ALTERNATIVES ..................... 75 6.1 The "FDP Alternative" ... ........................ 75 6.2 The "Without Project" Scenario ... ..................... 76 6.3 Restructuring Models of the NFB ... ..................... 77 6.3.1 Issues Related to Forest Environment .. ............................... 77 6.3.2 The "Without Restructuring" Scenario .. ............................... 78 6.3.3 Proposed Models ................................. . 79 6.3.3.1 Model I ................................. 79 6.3.3.2 Model II ................................. 79 6.3.3.3 Model III ................................. 80 6.3.4 Key Impacts .................................. 80 6.3.4.1 Activity Levels ................................. 80 6.3.4.2 Timber Harvesting ................................. 81 6.3.4.3 Road Construction ................................. 82 6.3.5 Institutional Arrangements .. ............................... 82 6.3.5.1 Incentive Structure ................................. 82 6.3.5.2 Regulatory Functions ................................. 84 6.3.5.3 Extension ................................. 84 6.3.6 Summary of Findings and Recommendations . ................................ 85 6.4 Rejected Sub-components of the FDP . . . ........................ 86 7. SAFEGUARD POLICIES ......................... . . 86 7.1 Safeguard Policies ........................ 86 7.2 Environmental Assessment ........................ 86 7.3 Natural Habitats ........................ 87 Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. 7.4 Forests ........................................ 87 7.5 Pest Management ........................................ 88 7.6 Cultural Property ........................................ 88 7.7 Involuntary Resettlement ........................................ 89 7.8 Operational Directive (OD) 4.20: Indigenous Peoples ........................................ 89 7.9 Operational Policy (OP) 4.37: Safety on Dams ........................................ 89 7.10 Operational Policy/Bank Procedure: Projects in International Waters (OP 7.50, BP 7.50, GP 7.50) ........................................ 90 7.11 Operational Policy (OP)/Bank Procedure (BP) 7.60: Projects in Disputed Areas ............... 90 8. ENVIRONMENTAL MANAGEMENT PLAN .................................................................. 91 8.1 Overview .................................................................. 91 8.2 Monitoring of Forest Investments .................................................................. 97 8.3 Environmental and Safety Training .................................................................. 97 REFERENCES ..99 List of Tables Table 3.1 Framework for Integrated Inter-Sectoral Training Program .21 Table 3.2 Management Effectiveness of the Nature Parks .23 Table 3.3 Nature Parks in Bulgaria .24 Table 4.1 Main Statistical Characteristics of the Forest Fund Regarding Forest Types in Year 2000 .27 Table 4.2 Production of Forest Industries in Bulgaria 1993-2001 .30 Table 5.1 Main Interventions of the PPU in the Rehabilitation and Construction of Forest Roads .59 Table 5.2 Significance Analysis of Environmental Impacts of the FDP Compared to the Current Practice .74 Table 6.1 Proposed Model I ....................................... 79 Table 6.2 Proposed Model II .80 Table 6.3 Proposed Model III .80 Table 7.1 Summary Table on Safeguard Policies .90 Table 8.1 Environmental Management Plan .92 List of Figures Figure 5.1 Impact Levels of the FDP Intervention .42 Figure 5.2 Phases of the Environmental Assessment .44 List of Boxes Box 2.1 Key Tendencies Outlined in the NFPS .6 Box 2.2 Environment-related Strategies and Plans .7 Box 5.1 Objects of Impact Assessment .43 Box 5.2 Categorization of the Environment with a View to Potential Impacts .45 List of Annexes Annex 1 Terms of Reference Annex 2 Field Trips Annex 3 Meetings with Stakeholders Annex 4 Feedback from Bulgarian BirdLife Protection Association Annex 5 Inception Workshop Annex 6 II Stakeholder Workshop Annex 7 III Stakeholder Workshop Annex 8 Forest Statistics Annex 9 Environmental Impacts of Current Practice Annex 10 Outline of Best Management Practice for Design and Construction of Forest Roads Annex 11 Minutes of a Meeting on the Safeguard Policy on Involuntary Resettlement Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR iV January 28, 2004. ABBREVIATIONS AND ACRONYMS % percent BAFO Bulgarian Association of Forest Owners BFC Bulgarian Forestry Chamber BGL Bulgarian lev BP Bank Procedure CEEC Central and Eastern European Countries CO2 carbon dioxide CRM Customer Management Relationship EA Environmental Assessment ECE Economic Commission for Europe. EEA Energy Efficiency Agenda EIA Environmental Impact Assessment EMP Environmental Management Plan EMS Environmental Management System ERP Enterprise resource planning EU European Union EUNIS European University Information Systems EUR euro EWS early warning system FA forest owners' association FAO United Nations Food and Agriculture Organization FBSC Forest Sector Business Center FDP Forest Development Project FDRS fire danger rating system FEC forest enterprise cooperative FIMS Forest Information and Monitoring System FMP Forest Management Plans FSC Forest Stewardship Council FSPP Fuel Switch Pilot Project GDP Gross Domestic Product GEF Global Environment Facility GIS Geographic Information Systems GOB Government of Bulgaria GTZ Deutsche Gesellschaft fuir Technische Zusammenarbeit (GTZ) GmbH ha hectare HCVF High Conservation Value Forest HRDP human resource development plan IBRD International Bank for Reconstruction and Development ICS Incident Control Systems IPM Integrated Pest Management ISO International Organization of Standardization IT Information Technology IUCN International Union for Conservation of Nature JI Joint Implementation km kilometer kW kilowatt LMRMP local mitigation and resource management plan LULUCF Land Use, Land-Use Change and Forestry Projects m meter m 3 cubic meter MAF Ministry of Agriculture and Forestry MEW Ministry of Environment and Water MOI Ministry of Interior Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. v January 28, 2004. MW Megawatt NEPF National Environment Protection Fund NFB National Forestry Board NFC National Forest Company NFPS National Forest Policy and Strategy NGO Non-governmental Organization NiMH National Institute of Meteorology and Hydrology NO° Nitrogen oxides NP Nature Park NTEF National Trust EcoFund NWFP Non-wood forest product NWG National Working Group OHS Occupational Health and Safety ONF Office National des Forets OP Operational Policy PAD Project Appraisal Document PAF Protected Areas Fund PCD Project Concept Document PDF Project Development Facility PEFC Programme for the Endorsement of Forest Certification Schemes PHARE Program of Community Aid to the Countries of Central and Eastern Europe PHRD Policy and Human Resources Development Fund PI Public involvement PIP Project Implementation Plan PMU Proj ect Management Unit POC Project Oversight Committee PPF Project Preparation Facility PPOC Project Preparation Oversight Committee PPT Project Preparation Team PPU Project Preparation Unit PRA Participatory Rural Assessment RES Renewable Energy Sources RIEW Regional Inspectorates of Environment and Water RS Restructuring Study SAPARD Special Accession Program Agriculture Rural Development SFA State Forest Administration SFA State Forest Administration SFM sustainable forest management SGP Small Grant Programs SME Small and Medium Enterprise SO, Sulphure oxides TOR Terms of Reference UNDP United Nations Development Program UNEP United Nations Environment Program USAID United States Agency for International Development USD United States Dollar WB World Bank WHO World Health Organization WWF World Wildlife Fund Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. Vi January 28, 2004. EXECUTIVE SUMMARY Sectoral Background The forests of Bulgaria, a rich environmental and natural resource base and increasingly important factor in the country's economic development, cover 3.91 million ha or about 34% of the national territory. Ownership is 86% state, 8% private individuals and 5% municipalities. Broad-leaved forests account for 67% of forest area, and 56% of standing volume. Average annual harvesting amounts to 4.4 million m3, of which 73% is for the forest industry and 27% for the local population's domestic use. Forestry plays an important role in rural Bulgaria as a provider of employment, recreation, tourism, water and public purpose activities. Bulgaria is a net exporter of wooden furniture. Extensive fires and illegal activities in the forests are major concerns, and the forestry sector's main performance indicators have a downward trend. Protected areas cover more than 556 000 ha, i.e. 5% of the country, including strict reserves, managed reserves, national parks, nature parks, nature monuments and protected territories. Mountain ridges, foothills, lowlands, and plains provide habitats from alpine forest belts, lowland grasslands and river plains to the dune communities along the Black Sea coast. The combination of habitat types and biogeography results in a level of biodiversity that ranks among the highest in Europe and comprises a wide range of relict and endemic plant and animal species, including big populations of large carnivores. Particularly important habitats include various types of dwarf pine, beech, chestnut and euxine oak forests. The National Forestry Board (NFB) in the Ministry of Agriculture and Forests (MAF) is responsible for the management of state forests and the control of all forests. Ministry of Environment and Waters (MEW) and its National Nature Protection Service through the National Park Directorates and Regional Inspectorates for Environment and Water administer strict reserves, managed reserves, and national parks. MAF through its Division for Protected Areas and Biodiversity manages nature parks, protected territories, and nature monuments. As a key sectoral issue, Bulgarian National Forest Policy and Strategy (NFPS) was developed in 2003. The NFPS sets out the broad development framework for the forestry including the role of the state and confirms the main issues facing the sustainable development of the sector. These are (i) reform of the (NFB) with the separation of ownership and supervisory functions, (ii) investment in silvicultural works - tending of young stands, reforestation, (iii) preserving the biodiversity value of forests, (iv) improving roading infrastructure, (v) increasing the level of harvesting while addressing illegal activities, (vi) ensuring the delivery of multi-function forestry, and (vii) enhancing the contribution to environment and rural development. There is a need to implement the NFPS to provide overall direction for reform of the forestry sector. Another key issue is the restructuring study, which identified a model for the future development of the state forest administration. This foresees the separation of management and supervisory functions through the establishment of a National Forest Company (NFC) with an essentially commercial mandate and a State Forest Administration (SFA) with a control and supervisory function. Illegal logging is a serious problem in the management of Bulgarian forests. Another major problem is the ongoing contestation on the ownership of state owned forests, several Environmental Assessment of the Forest Developnment Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUIFOR. vii January 28, 2004. municipalities claiming the restoration of up to 35 per cent of state-owned forest and blocking up to two million m3 from annual harvesting. The forestry sector has faced new challenges from the transition to market economy, restitution and EU Accession, and the sector is not able to finance management activities. New funding for the development of forest sector is provided through a combination of World Bank, EU SAPARD and several donors. The Project The Govemment has requested Bank assistance to prepare and to finance a Forest Development Project (FDP), which would assist in implementing the needs articulated in the strategic objectives of the NFPS and the restructuring study. The FDP aims to increase the contribution of forests to the national economy and to the benefit of rural populations through sustainable management of state, private and communal forests. It also aims to improve conservation of forest ecosystems through mainstreaming biodiversity into forest management, and through improved conservation of critical ecosystems. The FDP, which would be implemented over a six-year period through the auspices of Ministry of Agriculture and Forestry, has five main components: (1) strengthen public forest sector management; (2) strengthening of capacities of non-state forest owners; (3) supporting state forest management transition to market economy; (4) promotion of biodiversity conservation in forest management; and (5) project management and monitoring. The project would complement and interface with the EU PHARE Twinning program for strengthening the institutional capacity of the SFA and the management and business skills of the NFC. The project would also complement the Forestry Measure under the EU SAPARD program targeted at the private forestry sector and facilitate its realignment to identified needs The overall investment program related to the FDP includes (i) IBRD-financed activities targeted at sector reform and improved forest management, (ii) GEF-financed activities for forest biodiversity conservation, and (iii) Fuel Switch Pilot Project (FSPP) funded by the Government of Japan to explore the feasibility of switching fuel sources from fossil fuels to biomass. Indicative project costs are expected to total EUR 41.26 million. IBRD financing will total EUR 30 million. Key Findings of the Environmental Assessment The EA primarily addressed the expected project-specific impacts and then expanded upon the proposed overall and cumulative impacts of the FDP, which are likely at the sectoral level, to the extent that these could be evaluated. The overall impact of the FDP is evaluated to be positive. Since the internationally adopted principles of sustainable forest management underlie the FDP, the production, ecological and social functions of forests receive equal consideration and ensure long-term sustainable benefits from multifunctional forestry. Environmental issues have been recognized and addressed in the design of the project, and mitigation measures have been identified regarding significantly potential adverse impacts (e.g. through the outline for best practices in forest road construction). Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. viii January 28, 2004. Concerning the restructuring, the EA identified a risk that the NFC may not be economically viable and, consequently, sets low priority to non-revenue generating functions such as environmental management. This could happen if the courts satisfy the municipalities' claims to transfer a substantial portion of the current state forest area to municipal ownership. It is therefore recommended that the obligations related to environmental management of forests be incorporated into the statutes of the NFC. The "without project" alternative was analyzed and rejected in view of the urgent need to address the key issues of the sector. Failure to take action through a comprehensive project would result in unsustainable forest management practices, continued degradation of forests and loss of environmental values. Lack of biodiversity conservation, watershed protection and employment generation in rural areas would follow, and the forests would continue to suffer from high levels of illegal logging. It is unlikely that there would be any significantly positive environmental impacts of the 'without project' scenario, and the likelihood for occurrence of the present negative environmental impacts would remain high. The need for complementary mitigation and enhancement measures of environmental impacts is summarized in the Environmental Management Plan (EMP) together with responsibilities, schedules, cost estimates and monitoring indicators. Many of the suggested measures concern additional specifications of planned actions already included in the FDP and require no or only moderate additional funding. A review of likely critical environmental impacts and mitigating steps, which have been incorporated into the project follows. Review of Critical Environmental Impacts and Mitigation Measures Component 1: Strengthen Public Forest Sector Management The FDP Component 1 deals with the main environmental issues that fall within public administration in the Bulgarian forest sector. The obvious development needs regarding capacity building in forest administration (forest inspection and extension), improvement of information management, prevention of illegal activities and forest fires, are all well addressed in the documentation of the FDP. The resource constraints in key areas will also be relieved by the FDP enabling acquisition of adequate equipment and technology. The proposed activities are also in line with the priorities set by the NFPS. Key environment-related issues regarding public forest sector management include: (1) Law enforcement: There are insufficient resources and technical capacity of forest guards, low salaries and motivation, gaps and loopholes in existing legislation, ineffective system for execution of penal code, corruption in forest sector, industrial use of illegal wood, and dependence of local population on illegally harvested fuel-wood. (2) Forest extension: There is a limited capacity and material resources to provide support to private and municipal forest owners. (3) Forest education: Low level of education and further training of the personnel in the forest and forest industries sectors. (4) Occupational health and safety: Forest workers generally lack safety equipment, and forest workers have inadequate training and health control. (5) Forest health: There is insufficient technical and institutional capacity for forest protection and fire control. Plantation forests are degraded due to outbreaks of pests and fungi. Forests in vicinity of inhabited areas are pressured by grazing of goats and other domestic animals. (6) Forest informnation systems: There is inadequate capacity to assess the Environmental Assessment of the Forest Development Project. Bulgaria. Ministr of Agriculture and Forestry of Bulgaria. prepared by IN DU FOR. ix January 28. 2004. forest and non-wood resources and their use and, in general, lack of an integrated forest information system. The FDP implementation contributes to the law enforcement, and the establishment of forest information system provides a modem database for planning and monitoring of forest management activities and supports the combating of illegal logging. Finalization of the national standard for forest certification will provide an intemationally recognizable set of requirement for sustainable forest management. Updating of the draft standard is also in compliance with the NFPS objectives to certify minimum 30% of Bulgarian forests. The focus of the first component of the FDP is appropriate. Nonetheless, the following complementary measures are proposed, since they are closely related to planned activities, and their implementation requires only moderate resources: * In spite of the fact that the terms of reference for the study on illegal logging and corruption address the importance of inter-sectoral cooperation between various ministries, authorities and the private sector, the terms are recommended to be revised to have a clear focus on the following two issues: i) Lack of collaboration with the police force and the ineffectiveness of the judicial system in processing criminal charges would deserve a stronger stress in the analysis. In addition to the police force, improved collaboration is needed with e.g. Ministry of Economy, Ministry of Justice, Customs and Ministry of Finance; ii) Production capacity of wood processing industry and availability of wood is not in balance in certain regions of Bulgaria. The demand for industrial wood that exceeds the supply could be a major contributor to illegal logging, and the issue should be studied in detail. * In order to intensify the combat against illegalities in the forest sector, it is recommended to establish a high level inter-sectoral task force on illegal logging and corruption * The adverse social impacts of reduced use of illegally harvested fuel-wood are recognized by the FDP. While it is highly unlikely in the Bulgarian context that the restrictions on illegal acquisition of forest resources would force any households to relocate, the restrictions may have a negative impact on the livelihood of some population groups living in the vicinity of the forests. Therefore, the Govemment of Bulgaria should develop measures to ensure adequate and low cost supply of fuel-wood to local communities. These measures could include: i) An annual govemmental compensation payment to the NFC covering the difference between market prices for fuel-wood and actual sale price; ii) A reduced payment of dividends for the NFC for an agreed time period; iii) Allowing local people to harvest limited quantities of fuel-wood in state-owned forests needing thinnings. In addition, the Govemment should consider assisting the affected communities in relying on other sources of fuel as well as raising their awareness of the negative impact of uncontrolled logging on forest resources. * Updating of state regulations on logging and silvicultural activities with environmental requirements (e.g. maintenance of biodiversity and control of impacts on soil and water). * Independent logging companies should be included among the beneficiaries of technical assistance provided by the FDP. * The FDP should intensify the control of occupational health and safety in forest operations. The National Forest Company should require the logging and other forest management companies to respect the safety legislation of Bulgaria and guidelines of the World Bank. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUIFOR. x January 28, 2004. * The FDP has not sufficiently addressed the issues related to grazing and health conditions of plantation forests. It is recommended that both subjects are studied and careful consideration is given to the mitigation of negative impacts on animal husbandry. Component 2: Strengthening of Capacities of Non-State Forest Owners The FDP aims at strengthening of capacities of private and communal forest owners for sustainable forest management. More specifically, the FDP Component 2 will support establishment of a national interest organization and community based forest owners' associations and financing of private and communal forestry through the SAPARD Program. Other means to contribute to the private and communal forest management include extension and inspection services, information and monitoring systems and biodiversity component of the FDP. The FDP Component 2 focuses on institutional development in the non-state forest sector. In addition, the project will support the preparation of forest management / business plans for municipal and groupings of forest owners based on guidelines to be developed under the project. No specification, however, are given to the guidelines and therefore it is impossible to assess how biodiversity management and environmental control will be addressed in the forest management plans. Even though the documentation of the PPU does not specify the measures to control environmental impacts in the private and communal forests, the overall objective of the FDP strongly refers to their inclusion in the actual implementation of the project. The FDP will support (a) a need assessment of private owners and (b) a review and realignment of the SAPARD Forestry measure targeted at improving its relevance and accessibility to private owners and owner associations. In addition, the project will support, through local consultancy services, the preparation of the SAPARD applications under the Forestry Measure. The key environment-related issues regarding the non-state forestry include: (1) Sustainable forest management: Low quality of regeneration work, inadequate silvicultural measures, and weak environmental control of operations are problems. (2) Level of awareness: Legal requirements are poorly known, and expertise in forest management practices is not sufficient. (3) Financial instruments: National support instruments for environmental protection are lacking, and application procedure within the SAPARD is far too complicated for average non-state forest owners. (4) Other significant characteristics: Private holdings are typically small, willingness of private forest owners to join cooperatives and associations is not self- evident, non-existing forest estate market, and the restitution process of land property is not complete. Taking into account the financial restrictions of the FDP, it is not realistic to assume that the project is able to solve all the key problems of the non-state forest sector. The State Forest Administration, for instance, is tasked to control the success of forest regeneration, but there are no legal requirements to carry out silvicultural operations or regenerate mature forests. Furthermore, the establishment of forest owners' associations and joining them must be a voluntary action. Hence the environment-related suggestions are confined to the active interventions of the FDP: Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. xi January 28, 2004. * While supporting the establishment of forest owners' associations, the FDP needs to ensure that their statutes and functions recognize the importance of sustainable forest management. Consequently, the operational guidelines with focus on environmental control need to be prepared. * Environmental/occupational health and safety training must be given to the staff of associations. * When selling timber standing, the contract between the seller and the logging company must include provisions for the protection of environment and occupational health and safety. * The multi-objective forest management plans to be prepared for municipalities and groupings of forest owners must be in compliance with the requirements of sustainable forest management. * When the project supports the preparation of funding applications related to the SAPARD Program prior to the provision of assistance to municipalities, forest owners' association or private people, the FDP must ensure the environmental sustainability of the individual projects to be supported. It is necessary to develop clear environmental screening criteria to be applied by the local consultants assisting forest owners. In particular, road construction and establishment of fast growing plantations may have significantly negative environmental impacts, if the planning and implementation are not properly carried out (e.g. selection of sites and tree species in the establishment of new plantations). Component 3: Supporting State Forest Management Transition to Market Economy Component 3 will support implementation of restructuring plan for the NFC, upgrading of forest road network, thinning of young and fire prone stands, reforestation and rehabilitation of destroyed and devastated forest fire sites, and implementation of pilot certification in selected state forests. A key issue is the restructuring of national forest administration, which will be carried out in accordance with Restructuring Law that the Parliament of Bulgaria is expected to adopt by early 2004. The new law shall be consistent with International Best Practices provided by the World Bank. From the environmental point of view, the key requirements are related to the public good forest management functions, application of sustainable forest management practices and decision-making within the NFC. The forest road sub-component foresees the preparation of a national forest road master plan, which would direct future investments and ensure compliance with environmental values. The master plan includes also the development of a Code of Best Management Practices in relation to the design, construction, reconstruction and maintenance of forest roads, while maintaining ecological values. The FDP is tasked to develop methodology and criteria for prioritizing roading works by taking into account forest management plans, harvesting methods, economic and cost benefit analysis, non-timber forest products, protection status of forests, areas with high conservation values, fire management requirements and effects of illegal logging. It is concluded that the FDP has a great indirect influence on the environmental performance of state forestry through the forest road master plan. The direct impacts of road construction/rehabilitation funded by the WB are minor, because the FDP is financially able to build only 25-35 km of new roads and repair 125-150 km of existing roads. The location of the new roads will be determined only after the completion of the road master plan. It is known, however, that the areas where possible road construction will take place belong to the State or the municipal authorities. The outline of Best Management Practice also Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. xii January 28, 2004. states that the protection of forest habitats should be a priority when designing, constructing, rehabilitating and maintaining forest roads. Extraction of timber is typically cost intensive and causes damages to the remaining stands and to soil and water due to long skidding distances and inappropriate logging technologies applied. Furthermore, if the off-road transportation distance exceeds 400-500 m, the timber harvesting is not considered any more economically attractive. Thus the forest road network is essential for efficient utilization of timber resources. The relatively sparse forest road network (7.9 m/ha) has contributed to protection of biodiversity, landscape values and timber resources from over-exploitation and may have left substantial areas completely untouched. A negative environmental side effect of the inadequate road network, however, seems to be overexploitation of easily accessible forests. The key environment-related issues regarding the rehabilitation and construction of forest roads include: (1) Forest Resources and Products: Facilitation of efficient use of timber resources and non-wood products, reduced pressure on accessible forests, less damage to standing trees, prolonged lifecycles of transport equipment, improved forest fire control, and increased risks for illegal logging. (2) Flora and Fauna: Possibly opened access to untouched forests with high biodiversity values, potential fragmentation of forest resources. (3) Soil and Water: Possibility for landslides and other type of erosion, changes in water flows on slopes, decrease of erosion through rehabilitation of existing roads, less soil damage and siltation due to harvesting operations, silting of watercourses due to new roads, accidents with hazardous materials. (4) Occupational Health and Safety: Dust and noise, and accidents. (5) Social Issues: Job opportunities, improved transportation connections, possible negative effects on landscape and cultural values, expropriation of private lands. Thus, upgrading of forest road network is foreseen to have both positive and negative environmental impacts. Rehabilitation of existing roads is expected to have a predominantly positive impact since the use of guidelines and safeguards developed under the FDP will improve the environmental situation compared to present practice. The construction of new roads will have a number of positive environmental effects (e.g. reduced skidding distance and associated damage, reduced risk of overexploiting accessible areas), but the effects on biodiversity tend to be negative. However, these effects can be controlled and kept within reasonable limits using appropriate mitigation measures. The direct impact of the FDP will be of limited magnitude because the volume of road construction and rehabilitation is restricted. The forest road master plan will have a broader effect, but it can be evaluated only after a draft plan becomes available. However, if appropriate safeguards are implemented during its formulation and implementation, these impacts are likely to be similar to those of the roads rehabilitated and constructed under the FDP albeit on a larger scale. The FDP plans to carry out approximately 10 000 ha of thinnings in several regions of Bulgaria. Criteria for the selection of stands to be treated are developed and according to them, the priority shall be given to stands (a) specified for thinning in forest management plans, (b) with roading access, and (c) proximity to markets. The key environment-related issues regarding thinning of young and fire prone stands include: (1) Forest Resources and Products: improved growing condition for and quality of remaining trees, improved resistance to forest fire, fungi and pests, and damage to standing trees due to logging operations. (2) Flora and Fauna: Felling of coppice species may decrease biodiversity. (3) Soil and Water: Soil damages due to skidding in commercial thinnings. (4) Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. xiii January 28. 2004. Occupational Health and Safety: Noise and accidents with chain saws. (5) Social Issues: Job opportunities. The thinning activities will be targeted mainly to plantations that are not important from the biodiversity point of view. However, felling of coppice species may have adverse impacts on the biodiversity, if the guidelines do not suggest mixed stands as an objective. The FDP will fund reforestation of approximately 600 ha in the project years one and two. A combination of economic, ecological and social criteria were developed and agreed as the basis for site selection. The key environment-related issues regarding reforestation and rehabilitation of destroyed and devastated forest fire site include: (1) Forest Resources and Products: Aim is to achieve viable and commercially valuable growing stock as well as improved growing conditions for non-wood products. (2) Flora and Fauna will be diversified. (3) Soil and Water: Soil preparation causes mechanical disturbance with risks to erosion, forest cover results in improved capacity to absorb water, and silting may increase in watercourses. (4) Social Issues: Job opportunities, landscape values and stabilization of the environment will increase. The adverse impacts of rehabilitation on soil might be significant, if the operations are not well planned and implemented. Prior to planting, the soil usually needs to be prepared with mechanical or manual methods, and terraces may need to be constructed in slopes. The key environment-related issues regarding forest certification include: (1) Environmental Sustainability: Environmental impacts of forest management, maintenance of High Conservation Value Forests, compliance with laws and international agreements, management plans, and monitoring and assessment. (2) Economic Sustainability: Benefits from the forests and plantations, compliance with laws and international agreements, management plans, and monitoring and assessment. (3) Social Sustainability: Tenure and use rights, community relations and worker's rights, compliance with laws and international agreements, management plans, and monitoring and assessment. - Since the starting point for forest certification is sustainable forest management, all the environment-related issues of its application are considered to be significantly positive. The FDP will fund reforestation of approximately 600 ha in the project years one and two. A combination of economic, ecological and social criteria were developed and agreed as the basis for site selection. The following mitigation and enhancement measures are suggested: National Forest Company: The environmental concerns with a view to the NFC deal with the practical implementation of sustainable forest management and the management of nature parks. In order to ensure that the public good functions of the state forest fund are respected, it is recommended that the NFC shall operate under a charter approved by the Government and acceptable to the World Bank. The charter shall define, inter alia, the membership and functions of its boards, public participation in its meetings, use of revenues generated from the sale of forest goods and financing of the management of nature parks.. Regarding the decision-making within the NFC, it is recommended, for the reasons of transparency, that NGOs be represented in its board. In order to avoid speculations with state-owned land (e.g. at coast of Black Sea), the procedures for the control of land use rights should be prepared. In Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. xiv January 28, 2004. line with the draft Restructuring Law, the EA expected that the NFC will be entitled to manage the state-owned forests and not gain ownership to them. Upgrading of Forest Road Network: Well-designed environmental guidelines for road construction are available in draft form, and the projected increase in investment funds will create a favorable opportunity for their application. The terms of reference for the forest road master plan and outline of best management practice for design and construction of forest road will provide adequate tools for road construction. Attention should be paid to subjects listed below, even though they are partially addressed in the draft guidelines and other material of the FDP: * Until comprehensive information on Bulgarian High Conservation Value Forests (HCVF) is available for forest managers, construction of new roads suggested by the forest road master plan should focus on plantations and forest fire sites currently with no access. If new roads are proposed in natural forest areas, the WWF Toolkit for Identification of HCVF or available information of identified HCVF must to be utilized in the preparation of the forest road master plan. Furthermore, the master plan must make good use of material related to Corine biotopes and Natura 2000. Since the basic identification of Bulgarian HCVFs is still underway, it is recommended that the priority in the first years is given to areas with no disputes in terms of biodiversity values. * While planning roads, full access to databases on protected areas, HCVFs and other environment-related geographic information must be given to persons responsible for preparation of forest road master plan and construction of individual roads. * The siting of roads must include field surveys with respect to identification of small-sized key habitats, protection of watercourses (e.g. rivers and creeks), landscape values and cultural property. * The FDP must require that relevant national and international regulations related to occupational health and safety are applied to road construction work. In particular, all necessary safety measures shall be respected while carrying out blasting. * In the context of precautionary approach, it is recommended that a strategic environmental assessment process is applied to the preparation of forest road master plan and an environmental impact assessment process is applied to first 2-3 roads to be constructed. Thereafter, the FDP is considered to be fully competent to judge the need for continuation of such assessment process. The forest management plans and other data sources of the NFB seem to provide adequate information on forest sites that are in need of rehabilitation and thinnings. The forest fire and thinning sites currently included in the work plan are all appropriate objects for the FDP financing. However, the selection of tree species needs to be justified: * Pines are not recommended to low altitudes, where local broad-leaved species and mixed stands should be favored. At higher altitudes, mixed broad-leaved and coniferous stands are more acceptable. If monocultures need to be established, documented measures should be taken to prevent forest fires and diseases. * While carrying out thinnings, it is recommended that the FDP ensures that the operations aim at diversified tree species composition, and take protection of soil, water and biodiversity properly into account. * In addition, the FDP should require that forest workers, contractors or independent companies follow occupational health and safety regulations stipulated by the Bulgarian Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agricultue and Forestry of Bulgaria, prepared by INDUFOR. xv January 28, 2004. legislation and the World Bank. The local level staff of the NFC should control their implementation in the rehabilitation and thinning operations. Component 4: Promotion of Biodiversity Conservation in Forest Management The FDP GEF-funded component will strengthen conservation of the forest biodiversity in Bulgaria and ensure the sustainable management of biological resources in forested areas of the most significant conservation importance. With a view to production forests, the FDP is taking steps to mainstreaming biodiversity conservation in forest management planning and integrating biodiversity conservation in forest management. The project would, e.g., develop guidelines and tools for integrating biodiversity conservation into forest management. As a main intervention, the GEF component would strengthen the national system of protected areas and protection forests. Focus is given to the improvement of planning of nature parks and strengthening their capacity to preserve critical habitats, prevent fires, as well as undertake biodiversity monitoring and infrastructure development. This would include support to equipment for improving the effectiveness of the Nature Parks, assessment of the Nature Parks' management effectiveness, development of a biodiversity management information system within the NFC, park conservation programs, as well as priority investments. The proposed Protected Areas Fund would provide long-term revenue to complement direct budgetary support for protected areas. The FDP will also support "Joint implementation capacity enhancement and project pipeline", i.e., the implementation of the Fuel Switch Pilot Project (FSPP) to be financed through the Policy and Human Resources Development (PHRD) Trust Fund for Climate Change Initiatives. The assessment focused on three key issues, namely the biodiversity conservation with a view to its mainstreaming in forest management planning, its integration in forest management and strengthening of the systems of protected areas. The third key issue, strengthening of the system of protected areas under the National Forest Company, lends itself to a critical analysis of the new management structures proposed for the Nature Parks, and their influence on the sustainable forest management in the parks. The Company is likely to have little interest in such non-revenue generating functions as environmentally oriented forest management of Nature Parks. Such concern is valid especially with a view to a scenario in which the company would meet economical difficulties, e.g., during a possible economic recession period. Under the selected model, the company is expected to pay the environmental management cost from its own resources, and it may try to minimize the cost or reduce investments in activities vital for the sustainability of forest management in Nature Parks. On the other hand, if the company should be able to generate enough of operational surplus, it would be able to provide the resources needed for the management of environmental functions. In more detailed assessment, and as expected, the key environment-related issues of biodiversity conservation were found to include mainly positive elements: (1) Non-wood forest products and services: Increased exploitation and supply of NWFP through increased potential for hunting, fishing, and access to berries, fruits, mushrooms, etc. (2) Natural habitats: Increasing diversity at ecosystem, species/population and genetic levels; ecological corridors potentially provided through the networking of protected areas. (3) Soil: Steadily Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. xvi January 28, 2004. increasing stability, decrease of soil erosion, and improving nutrient balance. (4) Water: Local quality improvement. (5) Occupational health and safety: Injuries are possible due to inappropriate techniques or lack of safety equipment. (6) Social issues: Positive impacts to employment, local economy and living conditions through strengthened coordination and partnerships with regional and local stakeholders; increase in tourism; positive impacts to landscape through the preservation of critical habitats. (7) Other issues: Illegal logging, unauthorized grazing, and forest fires, hamper the integration of biodiversity conservation in forest management planning Although the FDP basically has a correct and appropriate focus in the GEF component, and the related environmental impacts are likely to be overwhelmingly positive, the EA identified the need for following complementary measures: * Mainstreaming of biodiversity conservation in forest management planning should be more highlighted and reflected as a crosscutting issue in all forest related activities. * The integration of biodiversity conservation in forest management should be ensured through its incorporation in those forest management plans that fall in the scope of FDP. Where production forestry is deemed compatible with biodiversity conservation, this should be clearly reflected in the forest management plans. * While general capacity building is addressed under the PHARE Twinning program in 2004 and the subsequent years, it should be reflected under biodiversity component as well. The FDP should, e.g., further build and strengthen the local level management's capacity for integrating biodiversity conservation in the management of production forests. * Restructuring of the NFB according to Model II implies that the Nature Parks report to the new National Forest Company. A main concern is that the company will not have enough interest in non-revenue generating functions such as management of Nature Parks, in particular during difficult economic situations. Model II suggests that the enterprise pays the environmental management cost from its own resources, and owing to its commercial orientation the enterprise may have an incentive to try to minimize the cost. A related concern is the nomination of the directorates for management and maintenance of nature parks. In order to mitigate the risk described above, the following combination of measures is proposed: (i) the mapping of High Conservation Value Forests; (ii) specific park management plans; (iii) specific contractual arrangements between the State Forest Administration and the National Forest Company stipulating financial compensations for activities going beyond the normal sustainable forest management; and (iv) appropriate legal provisions, including the environmentally oriented forest management obligations incorporated into the statutes of the state forest enterprise. The nomination of park directorates should also reflect this obligation. * In the cases where the Nature Parks' and Regional Forestry Boards' land areas overlap, the park management plan has the priority over the forest management plan. This regulation should be confirmed and even strengthened in the statutes of the new state forest enterprise. The FDP will also support "Joint implementation capacity enhancement and project pipeline", i.e., the implementation of the Fuel Switch Pilot Project (FSPP) to be financed through the Policy and Human Resources Development (PHRD) Trust Fund for Climate Change Initiatives. The project implementation has obvious positive environmental impacts, which are mainly related to emission reduction from energy production, upgraded silvicultural Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. xvii January 28, 2004. conditions of forests within the catchment areas for bio-fuels, new use forms for residues from woodworking industry and improved employment. While the project is likely to have mostly positive impacts, some negative implications may also emerge and have to be safeguarded against. The critical issues include the following: * Increased use of biomass for heating purposes may diminish availability of fuel-wood for local communities. Therefore, the influence of fuel switch installation on the wood supply to local communities must be carefully studied, and detailed plans have to be prepared to mitigate negative impacts. * Since energy plantations are often monocultures, the project should take potential attacks of pests and fungi and risks for fire into account, and prepare a Pest Management Plan for their management during project implementation, parallel to the identification of afforestation JI projects. Such plan should (i) consider various alternative designs of plantations to minimize the said risks, and (ii) propose relevant mitigation measures with a view to pest and fungi outbreaks. Furthermore, needs for using fertilizers should be evaluated to ensure high productive supply of biofuels. Overall, the FDP is recommended to actively utilize the forestry-related JI-measures in the project implementation. Bulgaria has plenty of other land areas, which are affected by erosion and watershed problems. These areas would greatly benefit from afforestation and simultaneously the project would create employment. Component 5: Project Management and Monitoring To provide project oversight and policy guidance during implementation, a Project Oversight Committee (POC) will be established at the level of the Ministry of Agriculture and Forestry in collaboration with the Ministry of Finance and the NFB. The project will finance the establishment of a Project Management Unit (PMU) within the MAF with overall responsibility for the implementation of the project, monitoring the progress of the project, and provision of quarterly implementation reports and activity plans to the Bank. While the PMU will make random field inspections, monitoring of forest investments will be contracted to a consortium with NGO representation. Investment in the POC is not expected to yield any negative environmental impacts and, hence, no mitigation measures are suggested. Environmental Management Plan The Environmental Management Plan (EMP) summarizes the key findings of the environmental assessment carried out, including suggested mitigation and enhancement measures with reference to significant environment-related issues, responsibilities, schedules, cost estimates and monitoring indicators. A great majority of the suggested measures concerns additional specifications of planned actions and safeguards already included in the FDP. The purpose is to ensure that the significant environmental and social issues will be duly considered while on implementation, even though their control measures might be elaborated in later phases of the project preparation or implementation. Most of the recommended mitigation or enhancement measures require no additional funding. Nevertheless, the realization of the EMP still contains two high cost-intensive actions at least partially beyond the budget of the FDP, namely the environmental and safety training of actors in the forest sector, and the financing of management of Nature Parks. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. xviii January 28, 2004. The World Bank's environmental and social safeguard policies, that aim to prevent and mitigate undue harm to people and their environment in the development process, were applied as appropriate. These policies are also meant to provide a platform for the participation of stakeholders in project design, and have been an important instrument for building ownership among local populations. According to the assessment made, six out of ten safeguard policies were triggered. Public Awareness and Participation Public participation and support, which is based on the awareness about the objectives of the FDP, will be critical for the success of the project. Numerous consultations had been carried out with forest sector stakeholders during the conception and preparation of the FDP, during the development of the NFPS and, again, during the EA preparation process. The objectives of stakeholder consultation were to improve the quality and relevance of the EA process, and to contribute to the openness, transparency and dialogue in the preparation of the FDP. A special effort was made to ensure that communication with the public be efficient and well balanced. The main stakeholder groups were identified during the inception phase of the assessment project, and additional groups were invited to participate in the assessment during the whole process. The first two stakeholder consultation workshops were held on October 13 and November 13, 2003, and these consultations gathered respectively 45 and 58 participants from the government, NGOs, academia, donors, and media. Outcomes of these workshops were taken into account by the project EA team, and the requests received from the individual stakeholders were also addressed. The Draft EA Report was made publicly available in Bulgarian and English on December 8, 2003. The stakeholder consultation workshop to discuss the Draft EA Report took place on December 17, 2003. Still an additional consultation meeting was held with six local environmental NGOs on December 16, 2003. Consultations reflected certain concerns on forest road constructions and consequences of the restructuring of the NFB in general, and the subsequent ways and means for the management of Nature Parks. The three stakeholder workshops were found both necessary and useful in order to provide the stakeholders concerned as well as the larger public with an opportunity to effectively influence the course of EA process, review the preliminary results, and comment on the Draft EA Report. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. xix January 28. 2004. 1. INTRODUCTION 1.1 Proiect Backaround The Bulgarian forests are one of the main natural resources in the country, but following the change of regime in the beginning of 1990s, the forest sector has been unable to fulfil its potential. As a result, forest production and industrial output have declined sharply and the financial difficulties experienced by the forest administration have reduced investments to the extent that the sustainability of forest management may be at risk. To reverse these trends the Government launched in July 2002 a process to formulate a National Forest Policy and Strategy (NFPS). Currently, a draft NFPS has been approved by the Cabinet of Ministers and its parliamentary approval is pending. NFPS sets out the broad development framework for the sector and identifies the following development strategies (i) reform of the National Forestry Board (NFB) with the separation of ownership and supervisory functions, (ii) investment in silvicultural works - tending of young stands, reforestation, (iii) preserving the biodiversity value of forests, (iv) improving roading infrastructure, (v) increasing the level of harvesting while addressing illegal activities, (vi) ensuring the delivery of multi-function forestry, and (vii) enhancing the contribution to environment and rural development. Parallel to preparation of the NFPS the Government requested Bank support in implementing the future development strategies. The Bank responded by assisting in the formulation of the Forest Development Project (FDP) providing support to the implementation of strategies in the priority areas of NFPS viz. institutional reform, private forestry, forest fires and incorporation of biodiversity conservation in forest management. The project would complement and interface with the EU PHARE Twinning program for strengthening the institutional capacity of the SFA and the management and business skills of the NFC. The project would also complement the Forestry Measure under the EU SAPARD program targeted at the private forestry sector and facilitate its realignment to identified needs. Over the past decade, the Bank has led similar undertakings in other countries in the region, including Poland, Slovakia, Croatia and Romania, and the experience gained is highly beneficial in developing a sustainable design. The Forest Development Project (FDP) would be implemented in 2004-2010 through the auspices of Ministry of Agriculture and Forestry. The FDP aims to enhance the sustainable management of Bulgarian private, communal and state forest resources and strengthen the conservation of globally significant biodiversity of Bulgaria. An increased contribution to the national economy and the conservation of environment is envisaged through the investment. The overall investment program related to the FDP includes (i) IBRD-financed activities targeted at sector reform and improved forest management, (ii) GEF-financed activities for forest biodiversity conservation, and (iii) Fuel Switch Pilot Project (FSPP) funded by the Government of Japan to explore the feasibility of switching fuel sources from fossil fuels to biomass. A new National Forest Policy and Strategy (NFPS) and a study on the restructuring of the National Forestry Board have established strategic approaches for the sector reform and substantiated project activities. In principle, the activities of the FDP are consistent with strategic actions of the NFPS. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DUFOR January 28, 2004. The FDP, which is to be implemented by the MAF over a six-year period, has five main components: (1) strengthen public forest sector management; (2) strengthening of capacities of non-state forest owners; (3) supporting state forest management transition to market economy; (4) promotion of biodiversity conservation in forest management; and (5) project management and monitoring. 1.2 Obiectives and Scope of the EA 1.2.1 Objectives This Environmental Assessment aims to assess the environmental impacts of the activities proposed under the Forest Development Project, as well as to make recommendations to mitigate any potential negative effects and enhance any positive outcomes. The main objective of the assignment is to undertake a full Environmental Impact Assessment of the FDP, including the Fuel Switch Pilot Project, and provide environmental analysis for the NFB Restructuring Study proposals (see Terms of Reference in Annex 10). The EA will (i) evaluate the project's potential environmental risks and impacts in its area of influence; (ii) examine project alternatives; (iii) identify ways of improving project selection, site, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and (iv) include the process of mitigating and managing adverse environmental impacts throughout project implementation. 1.2.2 Scope The scope of the EA covers first of all an assessment of the whole range of activities proposed by the FDP preparation team. A vital prerequisite for a successful outcome of the FDP implementation is, first, that the National Forest Policy and Strategy be developed and adopted and, second, that the restructuring options of the national forest administration are developed and the restructuring model decided upon. NFPS was to be a key policy document underlying the EA, while the restructuring process itself was an object of the assessment. The analysis of restructuring models of the NFB were to be carried out in close collaboration with the consultants responsible for overall project preparation, and through a process that included consultation with major stakeholders and which provided for comments and input from interested parties. Bulgarian environmental legislation and the relevant World Bank policies laid the foundation for the EA process and assisted in specifying the content of the EA Report. Under the supervision of the Project Preparation Unit (PPU) and MAF, in close collaboration with consultants engaged to undertake the overall preparation of the FDP, and through a process that includes consultation with major stakeholders and which provides for comment and input from interested parties, the EA consultant team carried out the following tasks: (1) Familiarized themselves with the status, trends and institutional capacity for forest management in Bulgaria, as well as the technical, institutional and policy issues related to the preparation of the FDP; (2) Undertook an Environmental Impact Assessment of the FDP, including the Fuel Switch Pilot Project; Environmental Assessment of the Forest Development Project, Bulgaria Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. (3) Developed the Project Environmental Assessment Report; and (4) Consulted the involved governmental agencies, concerned local and regional authorities, project-affected groups and local NGOs about the project's environmental aspects, took their views into account, and publicly disclosed the results and other information about the project. The Social Assessment was carried out as a separate assignment in parallel to the EA. Although the SA will be completed after the EA, preliminary information made available by the SA team was taken advantage of when preparing the EA report. 1.3 Phases of Environmental Assessment 1.3.1 Activities Carried Out As the main approach to meet the objectives of the study, and closely following the Terms of Reference, the assessment team carried out the following activities: - Inception phase, which included an initial stakeholder consultation workshop on 13 October 2003 (45 participants/95 invited) and resulted in the Inception Report. The report comprised a detailed work plan and a stakeholder consultation plan; - Identification of environmental impacts and risks through an analysis of the FDP proposals by components, the restructuring models of the NFB, and the fuel switch project pilot areas; - Analysis of the significance of environmental impacts and risks by screening them through the various criteria adopted for the purpose; - Control of significant environmental impacts and risks against the national legislation and the procedures defined by the FDP, followed by a gap analysis with a view to the need for additional control procedures; - Field trips to Blagoevgrad Region on 30-31 October 2003; Municipality of Apriltzi, Project "PHARE Program Biodist" on 19 November 2003; Municipality of Teteven 19 November 2003 and to Lovetch Region on 25-26 November 2003 (Annex 2) - Stakeholder consultation on 13 November 2003, where the first findings of the EA were presented to and discussed with 58 participants (130 invited); - Drafting and compilation of the EA report, including an Environmental Management Plan, by 5 December 2003; - Distribution to identified stakeholders for comments (about 150 addresses) and public disclosure of the draft EA report on 5 December 2003; - NGO consultation on 16 December 2003 with representatives of six national and international NGOs (Annexes 3-4); - Stakeholder consultation on 17 December 2003 to publicly review the results of the EA, as per the draft report, and to discuss them with interested stakeholders in order to collect comments for the final version of the EA report (26 participants / 150 invited); - Compilation and delivery to the MAF/PPU of the final EA report on 31 December 2003. The approach and methodology for the impact assessment are described in more detail in Chapter 5.1. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 3 January 28, 2004. 1.3.2 Participation of Stakeholders Active involvement of stakeholders is a precondition for the success of any EA process. The objectives of stakeholder consultation are to improve the quality and relevance of the assessment process, and to contribute to the openness, transparency and dialogue in the preparation of the FDP. A special effort was made to ensure that communication with the public is efficient and well balanced. The main stakeholder groups were identified during the inception phase of the assessment project, and additional groups were invited to participate in the assessment during the whole process (Annexes 5-7). Individual meetings were held with 36 stakeholders (Annex 3). The three stakeholder workshops were found both necessary and useful in order to provide the stakeholders concerned as well as the larger public with an opportunity to effectively influence the course of EA process, review the preliminary results, and comment on the Draft EA Report. 1.4 Contents of the Report This report presents the findings of the tasks outlined in Sections 1.3-1.4 above. The structure of this EA report follows the requirements and guidance given in the WB OP 4.01, Annex B. Restructuring of the NFB was given a particular emphasis as a scene-setter for the Bulgarian case. Environmental Management Plan concludes the assessment and provides a structure for the monitoring of implementation of the FDP from the environment protection point of view. The various chapters of the report are presented under the following titles (Chapter 5 largely follows the structure of the FDP): - Chapter 2 presents the Policy, Legal and Administrative Framework for forest sector management and development in Bulgaria, as well as for this EA. - Chapter 3 gives a summary description of the FDP, by components and sub-components - Chapter 4 presents a review of Baseline Data in forestry sector, relevant for the EA. - Chapter 5 describes first the conduct, and then the key findings and results of the Environmental Assessment (key issues, coverage and impacts of the FDP, and suggested mitigation and enhancement measures). - Chapter 6 describes a few most logical alternatives to the FDP and briefly discusses their suggested outcomes in order to provide material for comparisons of various relative merits of FDP and its alternatives. - Chapter 7 presents an Environmental Management Plan and includes the measures to be undertaken to prevent the realization of any potential negative impacts of the FDP. The plan comprises mitigation measures, responsibilities, schedule, costs and monitoring indicators for each key impact issue. - Chapter 8 discusses the World Bank Safeguard Policies and the related policy and process frameworks. - Annexes contain records of consultation meetings and public disclosure, statistical data, and other information related to the EA. Ens ironmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR 4 January 28. 2004. 2. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK 2.1 Policy and Legislation 2.1.1 National Framework The environmental policies in the Bulgarian forest sector derive from the country's constitution requiring environmentally sustainable use of natural resources and the international agreements the country is signatory to. The key legislative acts in the forest sector are the Law for Restoration of Forest and Woodland Ownership (1997) and the Forestry Act (1997), whose adoption led to significant reforms in the forestry sector. Currently, the pivotal development process is the preparation of I National Forestry Policy and Strategy (NFPS). The basic objectives of NFPS are: - Sustainable development of forest sector through multifunctional forest management. - Compliance with international standards and commitments relevant to the forest sector - Ensuring access to adequate financial resources from national and international sources The Council of Ministers has given its approval to NFPS and it has also been reviewed and approved by the Forest and Agriculture Committee at the Parliament. As a next step the document will be submitted to the Parliament for approval. If approved and fully implemented, the NFPS will make a major contribution to the development of environmental management in the forest sector. The FDP is the main vehicle for implementing NFPS, its contribution to the implementation of NFPS will be examined in parallel with the overall environmental assessment. The key strategies of NFPS are outlined in Box 2.1. The National Fire Management Strategy was approved by the Collegium of the Ministry of Agriculture and Forestry in December 2003. Its implementation will be supervised by an Intersectoral Consultative Council comprising representatives from the different Ministries (to be established). In related fields one the most important legislative acts with bearing on forest environment is the Environmental Protection Act (SG 91/2002), Hunting and Game Protection Act (SG 78/2000), the Protected Areas Act (SN 133/1998), the Medicinal Herbs' Act (SN 21/2000), Waters Act (SG 67 / 1999, Biodiversity Act (SN 72/2002). National environment-related strategies of relevance to forestry include the National Action Plan on Climate Change (2000), the National Strategy and Action Plan on Biodiversity Conservation (1999), and the National Strategy for the Environment and the Action Plan for 2000-2006 (2001) (Box 2.2). The "forestry measures" of the EU Special Accession Program for Agricultural and Rural Development (SAPARD) officially commenced on September 2, 2003. The program represents a major cash injection to non-state forestry providing a total funding of approximately EUR 60 million, and it potentially has major environmental impacts. The program is targeted at private beneficiaries and the municipalities. Activities eligible for support under the program include, inter alia, establishment of plantations of fast growing species, non-commercial thinnings, planting of fruit trees or valuable tree species, Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 5 January 28, 2004. reconstruction of coppice stands into high-stem forests and afforestation of marginal agricultural lands. Box 2.1 Key Tendencies Outlined in the NFPS * Forest management - Application of forestry systems in conformity with nature - Rehabilitation of forests on deforested territories, increasing their sustainability and satisfaction of demand for forest products - Encouraging forest certification * Forest conservation - improving the health status of forests including adaptation to climate changes * Forest protection - improvement of protection of forest resources from illegal activities. * Use of timber - optimum use of timber potential (up to 8 cubic million meters per year during 2010 - 2013) . Non-timber forest resources (herbs, mushrooms, forest fruits) - regulation of use and creation of conditions for economically effective processing * Hunting and fisheries - biodiversity conservation and game stock rehabilitation . Biodiversity and Protected Areas - Integration of biodiversity conservation into forestry practices - Development of adequate system for biodiversity conservation "in situ" and "ex situ" * Forest protective functions - multifunctional forests management that assures the implementation of their protective functions * Tourism and recreation - tourism integration into traditional forest management activities . Forest industry: . - Development of effective state forest industry that could process the extracted wood available in the country - 10% annual growth in production and export of forest products . State administration - Establishment of optimum management structures that assure implementation of public functions - Effective management of state forest property - Updating of relevant forest legislation - Improvement of forest sector funding model . Human resources, education, science: - Improvement of education system - Improvement of forest workers social status improvement - Increasing the contribution of academy . Forest ownership - guarantee of equal rights and responsibilities for all forest owners . Information management - system development that provides detailed information about forest status, forest resources and their management * European integration and international cooperation: - Incorporation of EU legislation into national forest legislation - Initiating active international cooperation - Fulfillment of country's commitments to signed international agreements . Regional development - enhancement of the forest sector contribution to sustainable development in rural and mountain regions . Public and NGOs - mechanisms for creating opportunities for public participation in the forest sector decision making processes Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 6 January 28, 2004. Box 2.2 Environment-related Strategies and Plans National Environmental Strategy and Action Plan (2000 - 2006) The National Environmental Strategy and Action Plan were approved by the Council of Ministers in 2001. They are oriented towards actions and measures improving the implementation of existing legislation with the purpose of enhancing the effectiveness of nature conservation and other environmental measures. Some of the main objectives include: - Conservation, strengthening and rehabilitation of key ecosystems, habitats, species and genetic resources - Development of conditions for sustainable use of biological resources - Improvement of forest status - Application of preventive measures to avoid damage on environment (EA and permit regimes) With regard to improvement of forests status the following measures were identified: - Formulation of National Forest Program (NFP) - Organization of NFP implementation - Implementation of priority measures for preventing forest fires National Action Plan for Climate Change The National Action Plan for Climate Change was formulated to fulfill the obligations of the Bulgarian Govemment following from ratification of the United Nations Framework Convention on Climate Change (ratified SG 28/1995) and the Kyoto Protocol (ratified SG 72/2002). This Plan coordinates the actions of various govemment institutions to reduce greenhouse gas emissions. The Plan proposes substantial use of renewable energy resources. Forest vegetation is identified as the main carbon sink. The priority actions with respect to forest management are: - Expanding afforested area (creating forest shelter belts and afforesting abandoned agricultural lands) - Adapting forest vegetation to climate change especially in areas situated up to 800 meters above sea level (by switching afforestation species, creation of unevenaged forests, improving biodiversity conservation, converting coppice forests into seed stands) National Strategy for Biodiversity Conservation and National Plan for Biodiversity Conservation The National Strategy for Biodiversity Conservation and The National Plan for Biodiversity Conservation were approved by Bulgarian Govemment in 1999 and 2000, respectively. They are focused on biodiversity conservation in situ and promotion of sustainable nature resources use. Strategic actions include: - Development of legislation and appropriate regulations - Institutional strengthening and improvement of inter-sectoral coordination - Development of the Protected Areas System; establishment and maintenance of National Ecology Network - Rehabilitation and maintenance of priority sites - Environmental education - Promotion of sustainable use of natural resources use and eco-tourism 2.1.2 International Commitments Bulgaria has signed a number of environment-related agreements, adopted at international forums, which have relevance for the forest sector. These include (i) the Declaration on Environment and Development (Rio, 1992); (ii) the Kyoto Protocol to the UN Framework Convention on Climate Change; and (iii) the resolutions of the ministers' conferences on Protection of Forests in Europe (Strasbourg, Helsinki, Lisbon, Vienna). Regarding biodiversity Bulgaria is a Party to key intemational conventions, including (i) Convention on Biological Diversity (1992), (ii) Convention on the Conservation of the Wild European Flora and Fauna and Natural Habitats (1979), (iii) Convention on International Trade in Endangered Species of Wild Fauna and Flora (1973), (iv) Convention on Wetlands of International Importance as Waterfowl Habitats (1971), and (v) Convention on the Protection of the World's Cultural and Natural Heritage (1972) as well as to a number of regional conservation agreements. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 7 January 28, 2004. Achieving full compliance with these agreements is a major effort, and will require significant changes in the current forestry practices, as well as substantial capacity building in environmental forest management. Another impetus for developing environmental policies comes from the pre-accession negotiations with the European Union. Forestry is included in the Agriculture Chapter. The legislative work in the forestry sector has made significant progress. Full compliance with EU regulations concerning forest fire has been achieved, and the alignment with EU regulations on the marketing of reproductive material is expected to be complete by the end of January 2004. Preparatory work to establish Natura 2000 network with a view to complying with the EU "Habitats" and "Bird" Directives has started. 2.1.3 Requirements of Financing Agencies The World Bank's environmental and social safeguard policies aim to prevent and mitigate undue harm to people and their environment in the development process. These policies are also meant to provide a platform for the participation of stakeholders in project design, and have been an important instrument for building ownership among local populations. Environmental Assessment is one of the ten safeguard policies, and it is used to identify, avoid, and mitigate the potential negative environmental impacts associated with Bank lending operations. The purpose of Environmental Assessment is to improve decision making, to ensure that project options under consideration are sound and sustainable, and that potentially affected people have been properly consulted. The World Bank's environmental assessment policy and recommended processing are described in Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental Assessment. The World Bank screened FDP for its potential environmental impacts in 2002. With a view to the possibility that some of the project activities may have negative environmental impacts, and the public interest associated with the proposed program, the World Bank assigned the project an environmental category "A" which requires a full environmental assessment, including public disclosure and consultation. Consequently, an Environmental Impact Assessment (EA) was decided upon, consistent with the GOB environmental assessment requirements, relevant environmental legislation, and the requirements of the World Bank as outlined in its Operational Policy 4.01 "Environmental Assessment", Operational Policies on Forests (4.36), Natural Habitats (OP 4.04), Pest Management OP(4.09), and Cultural Property (OP 4.11), Involuntary Resettlement (4.12); as well as the World Bank Environmental Assessment Sourcebook. The project will address GEF Operational Program No. 3 - Forest Ecosystems. It corresponds to Program's objectives to (i) promote conservation and protection of primary and old growth and ecologically mature secondary forest ecosystems in areas at risk, and (ii) ensure the sustainable use of biodiversity by combining production, socio-economic and biodiversity goals. The selected project activities would also be relevant under the Operational Program No. 4 - Mountain Ecosystems. As required by GEF, Bulgaria has ratified the Convention on Biological Diversity on April 17, 1996. The project directly supports the implementation of the National Biodiversity Conservation Strategy and Action Plan (1999). As indicated above, the GEF grant would finance costs of activities required to achieve global conservation benefits, which would be Environmental Assessment of the Forest Developnient Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 8 January 28. 2004. incremental to the baseline national forest sector development program undertaken by the Government with support from the World Bank and the other donors. The EU policy concerning forestry is based on the Communication to the Council of Ministers and the European Parliament: "Forests and Development: The EC Approach" (COM(1999)554) adopted by the European Commission, on the 4 November 1999. The main message is to maintain the multifunctional role of forests and reconcile the various and sometimes conflicting demands on forests and forest assets. The EC recognizes issues and dilemmas attached to the sector and the difficulties in decision-making. The importance of national forest programs is highlighted and will be the framework of future assistance. The document also emphasizes the need for good governance as a prerequisite to ensure sustainable management of forests. Given the number of stakeholder groups with an interest in forests, a participatory approach is of special importance. The project will be implemented in collaboration with a number of directly related and supporting projects. The EU PHARE Twinning will support institutional and capacity building of middle and lower management in the SFA and NFC during 2004. The project aims to increase the effectiveness and draw down of EU SAPARD funding under the forestry measure, working closely with the SAPARD agency and the SFA. The WWF will support the finalization and endorsement of the national standard through public awareness and funding of participatory processes, while UNDP will support the pilot certification of state forests through training and awareness-raising. The German agency GTZ will continue to target private owners and will support the establishment of the national representative body and regional based associations through the provision of technical assistance. 2.2 Institutional Framework 2.2.1 Relevant Government Administration The Ministry of Environment and Water (MEW) takes the lead in the development and implementation of the national biodiversity conservation policy. MEW coordinates the activities of other Ministries, government agencies, municipalities, etc. pertinent to biodiversity conservation. MEW is also the focal point for climate change. The Ministry of Agriculture and Forestry (MAF) works towards mainstreaming that policy in the management of nation's forest and agricultural resources, and manages and controls the maintenance, use, restoration, and protection of forests. Administrative responsibility for forests resides within the Ministry of Agriculture and Forestry through the National Forestry Board, which is responsible for forest policy implementation. The NFB has sub-units for specific functions, such as forest protection and management of the nature parks. Ministry of Environment and Waters exercises public and commercial functions in the National Parks and the Reserves established in forest areas. The responsibilities of the respective institutions concerning the management, safeguarding, protection and rehabilitation of the nature parks are stipulated mainly by the Protected Areas Act and the Forest Act (State Gazette 125/1997) as well as the organizational regulation of the NFB on the functioning of the park administrations. A National Biodiversity Council is to be established as an advisory body under the Minister of the Environment. As a main coordinating body in the biodiversity area, it shall comprise Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 9 January 28, 2004. representatives of relevant Ministries and government agencies, scientific research and academic institutions, environmental NGOs. As a sectoral program, the FDP biodiversity component directly supports the implementation of the National Biodiversity Strategy and Action Plan. As of November 2003, the National Biodiversity Council has not been established. The international commitments, the NFPS, the legislation in force, and the regulatory procedures recognize many of the significant environmental impacts. However, the legislative and regulatory coverage does not seem to be adequate. The NFPS, e.g., highlights as main issues and challenges: (i) the lack of adequate legislation regulating the requirements for protection and management of landscapes, and (ii) the incompleteness of the biological diversity legislation. Furthermore, the legal requirements are not satisfactorily implemented and monitored. The EIA procedures have been defined in the Environmental Protection Act (2002). Plans, programs and development proposals for construction, activities and technologies or modifications thereof, the implementation of which is likely to have significant effects on the environment are subject to compulsory EIA. Regarding selected activities such as forestry the law will not take effect until 1 July 2004. The administrative responsibility for overseeing the EIA process and making related decisions rests with the Minister of Environment and Water (MEW) and the Directors of the Regional Inspectorates of Environment and Water (RIEW). 3. DESCRIPTION OF THE FOREST DEVELOPMENT PROJECT The EA assessment report is based on PAD made available in December 2003. However, following reviewers comments the PAD was revised in early January to (i) integrate GEF activities beneficial for sustainable forest management within the forest main components, leaving the GEF component exclusively dealing with Protected Areas and (ii) plan for cost- sharing across the loan and the grant to cover incremental costs for global biodiversity conservation. The activities supported by the project are basically unchanged but biodiversity conservation is fully mainstreamed across the project and shown as an integral part of relevant project activities. The new presentation of the project could not anymore be incorporated in the EA report, but since the change is not significant for the substance of the project, the conclusions of the EA remain valid. 3.1 Proiect Development Objectives and Key Indicators The project Development Objective is to increase the contribution of forests to the national economy and to the benefit of rural populations through sustainable management of state, private and communal forests. The Global Development Objective is to improve conservation of forest ecosystems through mainstreaming biodiversity into forest management, and through improved conservation of critical ecosystems. Project performance indicators include (a) increased contribution of forests and forest industries to GDP, (b) reduction in forest fires and fire response times, (c) increased area of non-state forests covered by adapted forest management plans, (d) transparent, results-based management systems in place for SFA and NFC, (e) reduction in illegal forest related activities, (f) area of high conservation value forests and functionally related habitats in productive landscape for which actual boundaries Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestty of Bulgaria, prepared by INDUFOR. 10 January 28, 2004. have been identified and status has been assessed and (g) management effectiveness of forest nature parks improved to a level of at least 70% using IUCN criteria. 3.2 Proiect Components 3.2.1 Component 1: Strengthen Public Forest Sector Management This is based on the results of the NFPS and the findings and recommendations of the Restructuring Study (RS). There are six sub-components. 3.2.1.1 Building and Strengthening Nation-wide Forest Extension and Inspection Services The project will support the institutional split of functions between the proposed State Forest Administration (SFA) - a purely regulatory and supervisory body - and the proposed new Forest Company (NFC) - a self-financing organization responsible for management of State owned forests. The project will support recruitment of a chief executive and senior management team by external consultants thus signaling a change in management style and promotion by merit. The human resource development plan (HRDP) developed under the RS outlines the scope and scale of capacity building necessary for the new organization. A phased and prioritized approach is adopted under the project. Initially the project will focus on capacity building of the senior management team followed by forest administration at headquarters and regional levels in policy and legislation, management of change, financial management and training skills. The training skills will facilitate delivery of in-house training throughout the organization and is essentially a train the trainers type program. Capacity building at district and lower levels is addressed under the PHARE Twinning program and covers enforcement of forestry regulations and laws, control of forest reproductive material, harmonization of laws, extension services to private and municipal forest owners, EU accession, policy and support services. The Twinning program also includes study tours to member states. Support for training peaks in year two and is reduced in the following years reflecting enhanced in-house capacity. To assist the restructuring, the project will support specific strategic actions in the RS Action Plan including development of standard operating procedures, development of training and extension materials for private and communal forest owners, human resource development, initial assessment centers for staff appraisal and appointment and good governance. The assets of the NFB will transfer to the NFC leaving the SFA without sufficient offices or equipment to operate. The project will not fund office procurement or rental. It will however finance office furniture and equipment, training equipment and logistical support including vehicles to enable the new organization fulfil its mandate and engage effectively with private forest owners. This support is limited to a scaled down version of the existing structure thus avoiding funding of equipment that will become surplus as the organization is rationalized over the next three years. 3.2.1.2 Building and Strengthening a Nation-wide Forest Fire Management System Bulgarian forests have suffered extensive fires damage over the last 11 years. Less than 2% of fires are due to natural causes. Fires have mainly affected relatively young coniferous plantations that are most susceptible to fire, but also mature stands including some broad- leaved species. Significant benefits emerge from exposure to different management structures, Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. operating systems and cultures. The project will support development of a study exchange program within the Mediterranean region, with key objectives to investigate the establishment and management of community based volunteer groups, the design and application of fire danger rating systems, risk assessment processes and community education and awareness programs. All support under the project is in line with the National Fire Strategy and complementary to the FAO fire prevention project activities. A significant contribution to forest damage stems from fires caused deliberately or accidentally by people. The most likely source of fires is from within rural communities and the activities of local residents. Provision is made for expenditure of up to EO.52 million for education and awareness campaign. This campaign would extend for three years and serve as a catalyst to integrate and coordinate all fire awareness campaigns currently exercised within Bulgaria. It is neither timely nor financially attractive to develop a forest fire danger rating system (FDRS) and early warning system (EWS) from basics; consequently the project will fund the adaptation of an existing system from within the Balkan region with proven results and applicability. An important output from an FDRS is an understanding of potential fire behavior on the following day/s. Interaction between the fire services and the National Institute of Meteorology and Hydrology (NiMH) will also be critical in this process. The NiMH has indicated that additional remote automatic weather stations will be required to improve Bulgaria's fire weather forecasting capability. The project makes provision for procurement and installation of up to four remote stations. Site selection and placement should be determined jointly by NiMH and fire agencies. Bulgaria has almost no fire trucks that are suited to forest fire suppression. Likewise, the availability of hand tools, with which much of the practical suppression is achieved, is very limited. The project provides for the purchase of (a) fire tankers to be located in high-risk districts, (b) protective outfits, and (c) sprayers and assorted hand tools. Other investments include (a) erection of six fire watchtowers, (b) communication equipment and (c) trail bikes. Training will include (a) Incident Control Systems (ICS), (b) Advanced fire fighter training, (c) Basic fire fighting and (d) Train-the-trainer exercises. Activities will be coordinated with the FAO Strengthening capacity for forest fire prevention project to ensure complementarity and synergy. 3.2.1.3 Developing a ForestInformation and Monitoring System, Including Updating of National Forest Database The new SFA will require a sound basis for decision-making, for monitoring and control and facilitating the development of the sector, especially private forest owners. A modern database and information system is required. The project would support system design, database build, data conversion, purchase of hardware and software, software development, IT training, communications and installation roll out to regional and district offices. A number of strategic applications are necessary to provide the end-user functionality required by the new SFA. These range from a data collection sub-system through forest inventory to cadastre and basic GIS. It is unlikely that off-the-shelf products alone will be able to provide the specific functionality required in each application area. However, off-the-shelf products will provide the foundations on which almost all the strategic applications will be built. For example, the specific GIS functionality would be built around an off-the-shelf GIS product. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 12 January 28, 2004. The definition of detailed functional requirements for the strategic applications will begin with a detailed analysis of existing Forestry IT systems within the MAF and NFB. Detailed analysis and design work will be undertaken in year one and provide a detailed Systems Requirements Specification and tender documents for the Forest Information and Monitoring System (FIMS). The implementation of an appropriate Customer Management Relationship (CRM) solution will be the focal point of the new FIMS. This would provide staff with details of all the entities with which that have any contact in relation to the monitoring and control of communal, state and private forest resources. The FIMS would have monitoring, control, policing, inventory and reporting modules. Subsequent to the initial database build and data integration work, data collection and integration will be an ongoing task for the SFA. Therefore one of the first modules that will be developed is the Data Collection (Reporting) Module. This will allow the SFA to integrate data (graphical and alphanumeric) collected from other organizations into their central database. 3.2.1.4 Illegal Logging Surveillance and Monitoring There is relatively little known about the real extent of illegal logging and corruption in Bulgaria's forests. The failure to capture revenues as a result of corruption and illegal harvesting increases the overall cost of forest management, and supports local rates of forest harvesting inconsistent with sustainable forest management. The project will support (a) a pilot surveillance project, (b) a detailed study on the extent of illegal logging and corruption including forest surveillance, (c) implementation of measures to reduce illegal activities based on study recommendations and (d) implementing an adequate participatory process (a Process Framework), involving representatives of the local population, to identify the social impact of the reduced access to forest resources and formulate possible mitigation measures and eligibility criteria.. The findings from the study and the process described under point (d) will form the basis for future realistic prevention and detection measures and developing additional measures for mitigating potential social impact caused by the reduced access to forest resources by the poor and socially excluded sections of the population. 3.2.1.5 Finalization of Forest National Certification Standard A draft national standard prepared by a National Working Group (NWG) failed to gain Forest Stewardship Council (FSC) endorsement. The process has since stagnated due to lack of funds. Certification will be made significantly easier if a national standard is first adopted and then endorsed by one of the internationally recognized schemes (e.g. FSC or PEFC). This is especially true to achieve the target set by the NFPS. The project would fund finalization of the national forest certification standard. 3.2.1.6 Supportfor Professional Technical Schools There are 15 Professional Technical Schools for forestry. The project will support the refurbishment of 15 classrooms, teacher training and the purchase of technical publications. Environmental Assessment of the Forest Developnment Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. 13 January 28, 2004. 3.2.2 Component 2: Strengthening of Capacities of Non-State Forest Owners 3.2.2.1 Fostering NationalAssociation of Private and Communal Forest Owners There are some 32 forest owner associations and enterprise co-operatives representing circa 4 000 members and less than 25 000 ha. There is no national representative or lobby for private and communal forest owners. There is a lack of any synergy or cohesion between the various forest owner associations. The Pamporovo workshop (June 2003) organized during project preparation represented the first initiative in terms of getting a common perspective amongst the forest owner associations. All of the forest owners and associations consulted are in favor of the creation of a national representative body provided it is established in a transparent and open manner and is truly representative of the various forest owner associations. A previous attempt to form a national lobby organization of owner associations failed due to a lack of transparency and representation. The project will support the establishment of the Bulgarian Association of Forest Owners (BAFO), a national level umbrella organization legally established and representing all categories of private forest owners in Bulgaria. It will be governed by an Executive Council comprising elected members from forest owner entities who will approve staff appointments and the annual business plan. The FDP will support running of BAFO for a four-year period commencing in Year 2 of the project. Support will include the cost for registration, salaries, office equipment, workshops, training materials, transport and annual running costs. Support will be provided on a sliding scale according to the following schedule Year 2 and Year 3 - 100%, Year 4 - 75% and Year 5 - 50%. GTZ will assist in the establishment and running of BAFO. Initially this will take the form of supply of part of the start-up equipment. 3.2.2.2 Supporting Community-based and Communal Forest Owners Associations There are approximately 30 forest owner enterprises and cooperations but some are largely inactive. The majority of co-operatives and associations are located in the Smolian Region. The municipalities, with the exception of Haskovo, have not established entities (internally) or associations to manage and coordinate their forests. The project will support the establishment of up to 23 cooperatives or associations in regions or Oblasts where forest owners are not represented currently through a capital grant for office equipment and registration. BAFO will organize the inaugural forum for the establishment of these new regionally based owner associations. It is expected that the SAPARD Program following its re alignment will address the needs of existing associations. The project will support the preparation of forest management/business plans for municipal and groupings of forest owners based on guidelines to be developed under the project. These management plans will facilitate the sustainable development of the private sector and reinforce collaboration among owners. 3.2.2.3 SAPARD Realignment and Support The Special Accession Program for Agriculture and Rural Development (SAPARD) is the single largest grant based initiative in Bulgaria for Agriculture and Rural Development including forestry. Measure 1.4. Forestry is expected to contribute to the thinning of 43 350 ha, construction of 1 500 km of new roads, upgrading of 5 100 km of roads, fast growing species -24 500 ha, plantations tended 3 850, productive forests established on Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. 14 January 28, 2004. marginal or eroded forest lands - 9 300 ha, planted low density forests - 2 900 ha and coppice stands converted to high forest - 1 500 and plantation of forest fruit species/high value timber forests established - 6 600 ha and forest nurseries upgraded - 150 ha. The SAPARD program will close at the end of 2006. Based on the current situation, it is unlikely that the targets will be met unless the barriers to implementation (100% up front funding by applicants, unrealistic eligibility criteria, documentation requirements, bureaucratic approval procedures, etc.) are resolved and the Measure conditionalities revised. The project will support (a) a needs assessment of private owners, and (b) a review and realignment of the SAPARD Forestry measure targeted at improving its relevance and accessibility to private owners and owner associations. In addition, the project will support, through local consultancy services and the extension service of the SFA, the preparation of SAPARD applications under the Forestry Measure. This will facilitate draw down of funds to private owners and owner associations as well as wood industry SMEs. 3.2.3 Component 3: Supporting State Forest Management Transition to Market Economy This component will provide the necessary support to assist the development of the National Forest Company (NFC). 3.2.3.1 Implementation of Restructuring Plan for the National Forest Company The project will support the incremental cost of an international Co-chief executive for the first three years to lessen opportunities for political interference. The project will support recruitment of a chief executive and senior management team by external consultants thus signaling a change in management style and promotion by merit. The human resource development plan (HRDP) developed under the RS outlines the scope and sale of capacity building necessary for the new organization. A phased and prioritized approach is adopted under the project. Initially the project will focus on capacity building of the senior management team followed by specialist training at headquarters and regional levels in marketing, financial management and control, management of change and training and facilitation skills. The training skills will facilitate delivery of in-house training throughout the organization and is essentially a train the trainers type program. Capacity building at profit center and lower levels in the organization is initially addressed under the PHARE Twinning program and covers business and financial management, marketing and trade of forest products, human resource development, customer services, negotiations and alternative revenue generation. The Twinning program also includes study tours to member states. Support for training peaks in year two and is reduced in the following years reflecting enhanced in-house capacity. The project will support specific strategic actions identified in the RS action plan including business planning, business process re-engineering, human resource development, interim budgeting and information systems and a review prior to second stage restructuring. The project will provide for technical assistance in supply chain logistics necessary to improve net revenues and competitiveness. The new company will require business and planning information systems if it is to deliver on its mandate. These are currently lacking and the project would also finance the design and implementation of a GIS based information management, planning and monitoring system. Enterprise resource planning (ERP) software package/solution will be used to operate the Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 15 January 28, 2004. business and will include an advanced accounting module for tracking costs and benefits of core and public purpose activities, and improvement in marketing, pricing and trading capacity. 3.2.3.2 Upgrading of Forest Road Network The average forest roading density is approximately 7.9 m/ha. This compares unfavorably with other European countries e.g. Austria - 36 m/ha, France - 26 m/ha, Germany - 45 m/ha, and Switzerland - 40 m/ha. The poor roading infrastructure, with its associated long average extraction distance, impacts on environmental damage with frequently used skid trails having excessively deep rutting, predisposing the site to erosion, seepage to and sedimentation of water courses. During the last ten years, almost no new roads have been constructed and little maintenance or reconstruction has been undertaken due to financial constraints. This lack of investment has resulted in an increasing proportion of the existing network becoming either unusable or with access limited to specific time periods or technology. Furthermore, traditional road building practices have not kept pace with advances in other countries, particularly practices to mitigate potential environmental impacts of forest road design and or construction. Dozers, with spoil being shoved down slope, are still the norm as opposed to using excavators. The NFPS identifies investment in roading infrastructure as a priority. Bringing the current infrastructure up to the accepted minimum of 12 m/ha will require the construction of circa 14 000 km and reconstruction of nearly 50% of existing roads. To ensure that any investment in roading is effective and environmentally sustainable, the project will first support the development of a forest road master plan for all of Bulgaria. This will (a) provide information on the current status and condition of existing roads; (b) identify future roading requirements; (c) detail a prioritized investment schedule for new road construction and upgrading of existing roads for the period 2005-2014; and (d) outline a Code of Best Management Practice in relation to the design, construction, reconstruction and maintenance of forest roads, while maintaining ecological values. As an added safeguard, the criteria for identifying investment will be developed using a participatory approach. A draft Code of Best Management Practice was prepared during project preparation ensuring the inclusion of environmental values during finalization. Following the adoption of the roads Master Plan, the project will support pilot new road and road reconstruction in priority areas agreed with the NFB during project preparation - Pazardjik, Smoylan, Burgas, Kardjali and Plovdiv. The emphasis will be on reconstruction (70%) rather than new roads. The precise extent of investment will depend on the priorities from the Master plan but the project foresees funding circa 122 km of reconstruction and approximately 21 km of new road. The project will also support environmental assessment for new road construction funded under the project. 3.2.3.3 Thinning of Young and Fire Prone Stands Less than 30% of first and second phase thinnings specified in the forest management plans have been undertaken in recent years due to a combination of (a) budget constraints (early thinnings incur a net cost), (b) lack of roads, and (c) availability and proximity to markets for small roundwood. This lack of silvicultural intervention is putting at risk the significant state investments in these plantations. Five priority areas were agreed with the NFB - Kardjali, Blagoevgrad, Bourgas, Schumen, Stara Zagora, Lovech and Kustendil. The project will Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 16 January 28, 2004. support the thinning of some 10 000 ha in these areas based on a standard subvention cost per unit treated area. Criteria for the selection of stands were agreed at a thinning workshop held for stakeholders and exclude areas in protected or high conservation value areas. Priority will be given to stands (a) specified for thinning in forest management pans, (b) with roading access, and (c) proximity to markets. In addition to increasing the future value of these forests, thinning will generate significant local employment opportunities. 3.2.3.4 Reforestation and Rehabilitation of Destroyed and Devastated Forest Fire Sites Recent forest fires have destroyed large areas of Bulgarian forests, particularly in the South East of the country. Due to budgetary constraints, there is a backlog of replanting of these fire-damaged areas. Failure to replant can result in increasing environmental damages through erosion, damage to watershed etc. Three priority regions were agreed with the NFB - Sliven, Bourgas and Kardjali. The project will fund reforestation (site preparation, planting and cleanings in years one and two) of circa 600 ha in the regions. The new plantings will include a greater diversity of species and specific fire resistant species thus avoiding the mistakes of the past. A combination of economic, ecological and social criteria were developed and agreed as the basis for site selection. This activity is expected to provide significant local employment opportunities. 3.2.3. 5 Implement Pilot Certification in Selected State Forests No Bulgarian forests are certified by either the Programme for the Endorsement of Forest Certification Schemes (PEFC) scheme or by the FSC. Bulgaria needs to start preparing now for the export of increased timber products based on volume targets outlined in the NFPS and to retain export markets that are increasingly demanding certified forest products. The project would fund (a) scoping study in a pilot forest area to identify corrective action requirements, (b) technical assistance to implement corrective actions, (c) assessment of pilot area for certification, and (d) training of local assessors. 3.2.4 Component 4: Promotion of Biodiversity Conservation in Forest Management Bulgaria is located on the crossroads of three broad bio-climatic regions - the mid-European continental, Eurasian steppe, and Mediterranean -which create a diverse range of transitional climatic conditions. The complex topography of mountain ridges, foothills, lowlands, and plains provides a high degree of variation in habitats from alpine forest belts, lowland grasslands and river plains to the dune communities along the Black Sea coast. Forests cover slightly more than a third of the country. The combination of habitat types and biogeography results in a level of biodiversity that ranks among the highest in Europe, and includes a wide range of relict and endemic plant and animal species (especially in the high mountain forest zone) dating back to the Tertiary and Quatemary periods. Particularly important habitats include various types of dwarf pine forests, beech forests, chestnut forests and the euxine oak forests of the Strandja Mountains. These forest host large populations of large carnivores such as bears and wolves. However, destruction and fragmentation of habitats from clearance, degradation and overexploitation of forest resources, combined with the direct loss of species from illegal Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDULFOR. 17 January 28, 2004. logging and poaching, have caused and continue to cause losses of forest biodiversity in Bulgaria. Today, the Bulgarian forests support 17 species of threatened mammals, 25 species of threatened birds and 14 species of threatened reptiles and amphibians. The Government of Bulgaria has requested the World Bank's assistance in financing a Forest Development Project (FDP), to be implemented in 2004-2010 through the Ministry of Agriculture and Forestry (MAF). The project aims to increase the contribution to the national economy and environment from rehabilitation and sustainable management of Bulgarian private, communal and state forest resources. The FDP will also strengthen the conservation of the globally significant biodiversity of Bulgaria through mainstreaming biodiversity conservation practices in forest management policy and operations. This latter aspect will be financed by a grant from the Global Environment Facility (GEF). Global Objective The GEF-funded component of the FDP will strengthen conservation of biodiversity in the natural forests of Bulgaria and ensure the sustainable development of biological resources in forested areas of the most significant conservation importance. 3.2.4.1 Mainstreaming Biodiversity Conservation in Forest Management Planning Component objective. To ensure that biodiversity conservation is fully incorporated into the forest management strategy planning process by identifying areas with high conservation value forests. Expected results. The project would provide the technical basis for government authorities to mainstream biodiversity conservation in regular forest management and undertake targeted conservation programs. Activity 4.1. 1 Identify critical ecosystems in production forests A preliminary analysis of the presence and distribution of the natural forest vegetation types of Bulgaria was conducted by national experts during the project design phase. The following steps were undertaken: 1. Designation of "forest" area in accordance with the FAO definition; 2. Identification of forest ecosystem types according to the EUNIS classification, incorporating NATURA 2000 as far as applicable; 3. Mapping of forest ecosystem type distributions 4. Conservation value assessment of forest ecosystem types using the WWF methodology for identifying high conservation value forests according to biodiversity value, extent, ecological functions and cultural values. As a result, 48 high conservation value forest ecosystem types were recognized, distributed within five major blocks of forest estate, namely: * Rila-Pirin region - 220 000 ha, of which forests comprise 150 000 ha * Central Balkan - 150 000 ha, of which forests comprise 100 000 ha Environnental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 18 January 28, 2004. * Western Rhodopes - 140 000 ha, of which forests comprise 105 000 ha * Strandja - 110 000 ha, of which forests comprise 90 000 ha * Western Balkan - 80 000 ha, of which forests comprise 55 000 ha In addition, 31 forest areas were located with critical concentrations of endemic and threatened species and 21 forest areas containing representative threatened and rare forest ecosystems. However, the actual boundaries of most of the sites have still to be determined from field surveys, and their current conservation status assessed. This activity will refine, test and establish the WWF methodology for identifying high conservation value forests in Bulgaria, and extend it to habitats that are adjacent and functionally related to, but not included within, the forest areas (such as screes, pastures, meadows and wetlands) as potential corridors between forest patches. Where appropriate, areas needing protection because of their critically important characteristics will be identified for designation. Activity 4.1.2 Initial action program preparedfor protection and management of selected endangered forests Following on from Activity 4.1. 1, the project will prepare an initial costed action program for all high conservation value forests and, as far as possible, associated functional habitats requiring protection and restoration. The key species (particularly those threatened and/or of commercial value) requiring protection and restoration will also be addressed. The program will take account of the priorities set out in the National Forest Policy and Strategy and draw on best international practice in accordance with EU legislation and policies (especially the establishment of the Natura 2000 network), and where appropriate guidelines issued by IUCN (e.g. with respect to species restoration, management and sustainable use in Game Breeding Stations). Activity 4.1.3 Identify priority measures to strengthen the regulatory framework and develop guidelines and tools to improve forest management practices Forest management planning practice in Bulgaria is currently directed mainly towards production management of timber resources. It is carried out on the level of individual stands, management classes, and ownership categories. The main parameters characteristic for biodiversity conservation, such as forest type, area, situation and connection of the habitats are not yet taken into consideration. At a larger scale, Bulgaria's accession to the European Landscape Convention means that forestry practice must increasingly take account of landscape impacts. However, the lack of specific regulations for biodiversity and landscape conservation and management in the forest legislation hampers developments in these matters. Meanwhile, the EU aims to adopt a Forest Charter during 2004. This will make forests in the expanded EU multifunctional, with funding for forest owners and users to implement sustainable, yet profitable, management practices. Accordingly, in preparation for Bulgaria's accession to the EU, the opportunity exists to undertake a number of key activities in order to maximize revenues from the EU budget, namely: Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUJFOR. 1 9 January 28, 2004. 1. Ensure that all high conservation value forests are included in the Natura 2000 system; 2. Introduce and apply international guidelines for the sustainable management of all forests, especially those outside of designated protected areas; 3. Strengthen the scientific and technical capacities of forest management authorities by reviewing skills and devising training activities; 4. Prepare for funding opportunities such as those to be available for data management (under the European Forestry Information System) and for afforestation, forest management and infrastructure (under the Rural Development Regulation). This activity will promote biodiversity (and to some degree landscape) conservation in mainstream forestry by developing tools and guidelines that promote forest management practices that resemble natural processes, especially in the ecologically valuable areas identified in Activity 1.1. The practices will focus on reducing negative effects on the long- term biodiversity value of the forests from, among other impacts, re-afforestation using non- native species, large scale water abstraction, creation of extensive single-aged forest stands, removal of all dead wood/brashings, lack of preventative fires, habitat fragmentation, illegal logging and illegal road access, unauthorized grazing, and uncontrolled tourism. The tools and guidelines will be disseminated throughout the forestry sector, and a series of seminars convened to discuss their implications. Where appropriate, amendments will be recommended to the forest management legislation and State Forest Enterprise statutes that would take account of biodiversity and landscape conservation requirements. Management plans will be prepared for critical Protected sites and the four Nature Parks (Vrachanski Balkan, Zlatni Pyassatsi Bulgarka, and Shumensko Plateau) currently lacking them 3.2.4.2 Integration of Biodiversity Conservation in Forest Management Operations Compontent objective. To enable the managers of forests (especially in the private sector) and relevant stakeholders, including the general public, to undertake and promote long-term sustainable conservation and wise use of forest lands. Expected results. The project would strengthen the participation, knowledge and capacity of those involved in the forest management sector at the national, regional, and local levels to undertake conservation activities and integrate them in regular forest management operations. Activity 4.2.1 Establishment of forest extension service to encourage priority biodiversity conservation activities int privately ownedforests An assessment of the restoration needs in damaged and degraded high conservation forest habitats was undertaken during the design phase with a view to conservation restoration priorities. It was found that the most frequent impacts are inflicted by intense forest fires, illegal logging, over-grazing and afforestation with non-native species. A specific guide to the rehabilitation of areas will be produced (see Activity 4.1.3), accompanied by training demonstrations on tasks such as planting methods, species composition, and stocking rates (see Activity 4.2.2). This activity will complement the extension work in the private sector of the wider FDP by providing top-up capital grants (seed capital) for specific actions aimed at sustainable habitat restoration and biodiversity conservation. Supported activities include integration of biodiversity conservation in non-State forest Management Plans; introduction of sustainable Environmental Assessinent of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 20 January 28. 2004. patterns for the use of non-timber forest resources; promotion of sustainable eco-tourism development; planting with native species using local seed sources and introduction long-term coppice rotations for fuelwood. A contractor will be engaged to administer the scheme, in accordance with a standard operating manual prepared for the purpose. Activity 4.2.2 Public awareness and information program and integrated inter-sectoral training program. As the project progresses, a wide range of outputs will be generated that should be published and disseminated in a variety of media to appropriate stakeholders and not least the general public. The PMU Biodiversity Officer (see Activity 4.5) will develop and coordinate a program for information provision, in collaboration with the MAF, National Forest Company, Nature Parks and relevant NGOs. The second aspect of this activity is to implement an Integrated Inter-Sectoral Training Program to broaden and deepen the capacity of forest managers in the public and private sector. The training program should be accredited and award certificates to the trainees. The program framework is set out in Table 3.1. Table 3.1 Framework for Integrated Inter-Sectoral Training Program Course Period No. Personnel Annually (weeks) MAF MAF NP Staff Others National Regional (private owners, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~~~~NG O s) Graduate-level studies in biodiversity conservation 52 1 1 and protected area management (scholarship and sabbaticals), to be designed jointly with an institution from other country In-service training on biodiversity conservation and 2 1 2 5 2 protected area management for Nature Park Directors, plus participation in Eurosite/EuroParcs seminars and training programs Study tour program based on visits to members of 3 2 5 5 Eurosite and EuroParcs In-service training on biodiversity conservation and 4 1 0 5 forest management: for (a) senior management; (b) forest district managers; (c) forest guards In-service training on management skills 3 5 5 In-service training on ecologically sustainable 3 2 2 5 5 tourism management In-service training on computer skills 3 10 In-service training on foreign languages 26 5 Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 21 January 28, 2004. Activity 4.2.3 Small grant program to strengthen public participation in forest biodiversity conservation Small Grant Programs (SGP) have been shown to be useful tools to initiate local involvement in sustainable management and benefit sharing. All successful SGPs are stakeholder-based with direct association with local municipalities, local populations and protected area managers. Indispensable is the development and use of a system of procurement as well as a scheme for project evaluation and monitoring. Alongside the privatization of forest areas and the increase in the potential of non-forest uses, the SGP will encourage a sustainable use regime at the local level. This activity comprises a design phase, followed by devolving the implementation of the SGP itself to the Nature Park directorates. In the design phase of this activity, the following aspects would be addressed: 1. Establish requirements for co-financing and in-kind contributions; 2. Prepare a Grants Application Manual, providing guidance on the application procedures, selection criteria and monitoring and evaluation system; 3. Training provision for the potential applicants (see Activity 4.2.2). 3.2.4.3 Strengthening the System of Forest Nature Parks Managed by the National Forest Company Component objective. To ensure that each Nature Park in the forest protection system achieves an overall management effectiveness on IUCN criteria of at least 70% by year 5 of the project. Expected results. The project would (i) improve planning, monitoring, and coordination for Nature Parks by the National Forest Company; (ii) strengthen the capacity of individual nature parks to preserve critical habitats and undertake biodiversity monitoring; and (iii) put in place critical infrastructure needed for sustainable management. Activity 4.3. 1 Improved planning, monitoring, and coordination for Nature Parks During the design phase of the project, guidelines issued by IUCN were used to evaluate the management effectiveness of the Nature Parks. The study established an average score of only 49%, as shown in Table 3.2. Thus, none of the Nature Parks achieved a high degree of management effectiveness, though planning efficiency and legal status were relatively good, while financial and human resources, and relations with local communities had the poorest scores. Many of the human capacity deficiencies in the Nature Parks will be addressed by the integrated inter-sectoral training program (Activity 4.2.2), while management plans will prepared for Protected sites and Nature Parks (Activity 4.1.3). Environmental Assessment of the Forest Developnment Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 22 January 28. 2004. Table 3.2 Management Effectiveness of the Nature Parks Indicator Shou- Ziatni Rous- Vitosha Vrach- Strandjs Sinite Rila Bulgarks Persinm Overal category mensko Pyassats senski anski Kaman Monastel * Plateau Lom Balkan Planning 44 44 56 67 44 67 67 67 11 11 57 efficiency Legal status 50 50 50 67 50 50 50 50 50 50 52 Partnership 50 50 67 50 67 50 50 33 33 17 52 Natural 47 60 47 47 47 56 47 47 33 20 50 resources management Financial and 40 53 47 40 40 33 40 40 40 40 42 human resources Relationship 44 44 44 33 44 44 33 33 33 II 40 with local communities Overall 51 51 50 48 48 48 47 45 33 25 49 This component will address the lack of office and field equipment which hamper the effectiveness of Nature Parks. An independent annual assessment of the Nature Parks' management effectiveness as a whole will be undertaken to determine whether improvements are being achieved above the baseline and to determine where weaknesses need further attention. Activity 4.3.2 Management information system for biodiversity data managed by the National Forest Company There is at present a total lack of any standardized biodiversity data collection, transfer, storage, or analysis in the state forest sector. In accordance with a study carried out during the project design phase, this activity will provide the necessary hardware, software, design and training required to establish a biodiversity information system at the level of the National Forest Company, main NFC regions with high conservation value forests and in each of the Nature Parks. This system will be a specialized extension of, and integrated with, the overall forest management information system to be installed by the FDP. Activity 4.3.3. Priority investnents to improve biodiversity conservation, sustainable management and long-term income generation in Nature Parks This activity is designed to provide funding for critical investments for targeted species conservation programs (management and monitoring) and key infrastructure (such as visitor centers, trails, field equipment and office equipment) in order to strengthen individual Nature Parks (Table 3.3) and enable them to undertake their functions adequately. The priority needs for each Nature Park were identified during the design phase of the project and will arise from new management plans. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 23 January 28, 2004. Table 3.3 Nature Parks in Bulgaria Nature Park Area (ha) Main Ecosystem Features Shoumensko Plateau 3 292 High canopy beech and hornbeam forest with some plantations of pines and false acacia Zlatni Pyassatsi 1 320 Mixed humid deciduous forest, with lianas in coastal stands and sub- Mediterranean shrub species on the dry slopes Roussenski Lom 3 259 Mid-European deciduous forest (oriental hornbeam), with shrub and steppe formations Vitosha 26 606 Mixed deciduous and conifer forest belts leading up to alpine pastures with lakes and bogs Vrachanski Balkan 30 129 Mixed deciduous and conifer forest belts with karstic cliffs and screes Strandja 116 136 Highly diverse mixed deciduous forests with sub-Mediterranean features ranging from coasts to hills, with some wetlands, rivers and pastures Sinite Kamani 11 380 Mixed deciduous (mainly beech) forests with secondary steppe and dry calciphilic herbaceous communities; siliceous rocky outcrops Rila Monastry 27 370 High alpine meadows, mixed conifer and deciduous forests; particularly rich in fungi species (162) Bulgarka 21 772 Beech and mixed deciduous forest, with highland pastures and meadows Persina 21 762 Danubian wetlands, flood meadows and riverine forests and river islands 3.2.4.4 Development of the Bulgaria Protected Areas Fund Endowment Component objectives. To provide counterpart funding for an endowment element in a Protected Areas Fund that would provide long-term revenue to complement direct budgetary support for protected areas, including Forest Nature Parks. Expected results. The project would assist the establishment of the PAF thus stimulating its expansion and revenues with additional resources coming from (i) domestic and international USD 6 million), and (iii) international multi- and bilateral donors. Activity 4.4.1 Establishment of Protected Areas Fund endowment The PAF will be set up under the auspices of the National Trust EcoFund (NTEF), an independent foundation previously established by special statute to disburse a Swiss debt-for- nature swap program. The objective of the Protected Areas Fund (PAF) is to support the protection of the landscapes, natural habitats, and biodiversity of Bulgaria's protected areas as envisioned in the National Strategy for the Conservation of Biological Diversity, through sustained funding that complements recurrent government expenditures and co-financing from donor projects for protected areas. The NTEF will be a Project Management Unit (PMU) for the PAF sub-component of the GEF grant, and will carry out the activity in line with a detailed project description prepared during the design phase of the project. Additional funding support for PAF start-up will be provided by USAID, and co-funding for the PAF endowment will be provided by the Governments of Bulgaria and Switzerland. It is expected that the capitalization of the Fund will reach USD 8 mill. equivalent by the end of the third year of implementation and USD 12 mill. equivalent - by the project completion. Financing of the endowment capital of the PAF with GEF resources will be conditional upon the availability of counterpart contributions from GOB, private sector and other donors, which should together exceed GEF input at least by a factor of three. Environmental Assessnient of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 24 January 28, 2004. 3.2.4.5 Forest Biodiversity Program Coordination and Management Component objective. To ensure the efficient and effective implementation of the GEF biodiversity component of the FDP. Expected results. The GEF component would be executed to the satisfaction of the stakeholders. The sub-component would finance incremental costs for the implementation of the GEF-funded program and would ensure coordination of the biodiversity conservation activities under the project with the other governmental and donor-funded conservation initiatives in the country. In particular, the grant would finance critical technical, procurement, financial management and other expertise and resources to complement activities under the Component 5 - Project Management and Monitoring. Thus, a Biodiversity Officer would be recruited to the PMU with the following main tasks: 1. Coordination of the activities of GEF component of the FDP relating to the protection and sustainable management of biological diversity in forests and functionally related habitats; 2. Provision of support and advice to the Project Management Unit, MAF, National Forest Company, Ministry of Environment and Waters, and key national and regional stakeholders on conservation of biological diversity in the forest sector; 3. Development of specifications and procurement packages for activities included in the Project Implementation Plan relating to protection and sustainable management of biological diversity in forests and functionally related habitats where appropriate. 3.2.4.6 Joint Implementation Capacity Enhancement and Project Pipeline There is an opportunity to build on previous World Bank studies and pilot projects relating to forest carbon. The fuel switch project will result in a number of pilot installations using forest biomass for heat and or heat and power. There is a lack of capacity in JI understanding and in identifying future potential forestry JI projects. Carbon targeted afforestation and other eligible JI forestry activities could enable the thinning and tending of young stands, the reforestation of degraded or burned areas etc for many years to come. This would be of benefit to both state and non-state private owners. The project will support the Bulgarian forest administration in building up a JI project pipeline for forestry and wood energy. 3.2.4.7 Additional Component Annexed to EA Assignment: Bulgaria Fuel Switch Pilot Project The objective of the grant is to define the actual costs and benefits of switching fuel from fossil fuels to wood in medium-sized municipal building heating systems. 3.2.5 Component 5: Project Management and Monitoring To provide project oversight and policy guidance during implementation, a Project Oversight Committee (POC) will be established at the level of the Ministry of Agriculture and Forestry in collaboration with the Ministry of Finance and the National Forestry Board or its descendents. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 25 January 2S, 2004. 3.2.5.1 Project Management The project will finance the establishment of a Project Management Unit (PMU) within the MAF with overall responsibility for the implementation of the project including procurement, disbursement, maintenance of project accounts and coordination. Permanent staffing would include a project director, a monitoring and evaluation financial management expert, two procurement specialists reducing to one after the third year, a forestry specialist with procurement skills, a GEF specialist, a financial manager a secretary/translator and a driver/assistant. The PMU would be supported by consultant services for IT procurement, training in financial management and Bank procurement, public relations and financial audit. In line with Bank policy to streamline PMU staffing and structures, the project would facilitate the development of synergistic approaches to procurement and financial management if and when the Rural Development project becomes operational. 3.2.5.2 Project Monitoring The PMU will be responsible for monitoring the progress of the project based on a comprehensive system of indicators developed during project preparation, and provide quarterly implementation reports and activity plans in a format acceptable to the Bank. While the PMU will make random field inspections, monitoring of forest investments will be contracted to a consortium with NGO representation. 3.3 Institutional Arrangements for Proiect Implementation FDP is being prepared by a Project Preparation Team (PPT) and coordinated and supervised by the MAF. The following institutional arrangements are envisaged for project implementation. A Project Oversight Committee (POC) will be responsible for providing oversight and assistance in resolving issues associated with project implementation. The Deputy Minister for Forestry in MAF will chair the committee. The POC will establish close links with relevant stakeholders and invite their input on a regular basis. The MAF will have overall responsibility for the project, including procurement, disbursement, maintenance of project accounts and coordination of implementation. A Project Management Unit (PMU), to be located within the offices of the MAF and separate from the National Forestry Board or its descendents, will manage implementation of the project on behalf of MAF. Through the PMU, the SFA within MAF and the NFC will be responsible for carrying out project activities at the national level. Given its inter-sectoral character, the project will be implemented in close collaboration with the Ministry of the Interior (National Service for Fire and Emergency Safety), the Ministry of Energy and Energy Resources (Executive Agency for Energy Efficiency), the Ministry of the Environment (Directorate for Protected Areas) and other national institutions as required. The current project preparation unit (PPU) will transfer to the PMU. Two assessments of PPU capacity have been incorporated into the training and support measures for the future PMU but are reliant on current staff transferring. Through the PMU, the SFA and the NFC will be responsible for carrying out all project activities at the county level. The NFC will continue to have extensive local coverage for silvicultural activities and retain its high level of forestry technical knowledge necessary for Environmental Assessment of the Forest Developnient Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUIFOR. 26 January 28, 2004. implementation of forest investments. The weakness in relation to IT implementation will be addressed through the development of a system user requirements specification and technical assistance to the NFC, SFA and PMU. The project will establish close collaboration and coordination with the forestry and biodiversity donor community. The project will work closely with UNDP in the field of biodiversity conservation. 4. BASELINE DATA 4.1 Forest Resources Some 600-700 years ago, nearly the entire land area of Bulgaria was covered by forests. Intensive anthropogenic activity gradually reduced the forest cover to about 30% of the country territory. Most of the remaining forests are located in the mountainous and semi- mountainous areas. However, in recent decades the forest area in Bulgaria has been steadily expanding. In the past 35 years, the forest cover increased from 3.1 million ha to 3.4 million ha. The forest fund (total forest area in administrative terms including non-forested areas) is even larger, 3.9 million ha accounting for 34% of the territory in Bulgaria. The expansion of the forest area has taken place mainly at the expense of lands not suited for agricultural use. The indicators on the forest stock show that Bulgarian forests are maturing; during 1965-2000, the growing stock more than doubled from 252 million m3 to 526 million m3. In 2000, the total annual increment reached 12 million m3. Broadleaved forests account for 67% of forest area, and 56% of stand volume (Table 4.1). Coniferous forests occupy only 33% of the area, but as they have high stocking level, their share of growing stock is 44. Table 4.1 Main Statistical Characteristics of the Forest Fund Regarding Forest Types in Year 2000 Forest type Forested area, ha Total growing stock, Mean Mean Mean Mean ha m3 age, incre- stock stand years ment per ha density per ha Conifers 1 114674 33.0 231 822686 44 42 6,735 221 0,75 High stem broadleaved 704 374 20.8 148 293 645 28 67 3,574 193 0,74 forests Forests for 535 438 15.8 23 790 301 5 48 1,022 44 0,60 reconstruction Coppice forests for 900 309 26.6 115 304 775 22 48 2,971 130 0,76 conversion Coppice forests 1 23 349 3.65 6 851 720 1 20 4,051 55 0,80 Total 3 375 117 100.0 526 063 127 100 49 4,00 156 0,73 Source: NFB 4.2 Forest Management The Bulgarian forest fund is arranged into three groups based on the main functions. In 2000, the area of commercial forests with environmental functions was 65.9% of the total forest fund area; the protective forests and forests for recreation covered 26.6%, and forests and forest land in protected areas accounted for 7.5%. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 27 January 28, 2004. The national normative regulations for forest management require control of environmental impacts of afforestation, reforestation and thinnings. However, increasingly severe resource constraints make full compliance with the regulations difficult, especially where substantial investments are required. There are three sub-categories of protective forests including (i) those managed for soil and water conservation or erosion control, (ii) small-scale areas established to protect specific objects, and (iii) recreational areas (for details see Annex 8). In most protective forests such as water reservoir zones, forest shelterbelts, forests against erosion, recreational forests, forest seed bases and genetic banks only ameliorative forest management activities (e.g. sanitary and selection fellings) are allowed. Protected areas are divided into six categories according to degree of restrictions on their management (Annex 8). Strictly protected forest area, where no management intervention is allowed, represents 4.5% of the forest fund. The foundation for the operational activities of the NFB are the five-year implementation plans formulated at the regional level, based on which the NFB draws up its annual operational plans. However, in recent years these plans have not been fulfilled because of restricted resources for implementation and lacking demand for a number of assortments. Forest management plans are elaborated by compartments for a ten-year period based on detailed regulations in the Forest Act and other legislation. Forest management plans are obligatory and cover 100 per cent of the state-owned forests. The management plans for private woodlots have usually been extracted from NFB management plan. Since these plans were prepared for a much larger area, they often have limited relevance for the individual holding. To enable operational control of forest activities, so-called technological plans are prepared. They focus on wood production, technologies and methods to be applied. In private and communal forests, the NFB marks trees for cutting. Planning of forest management and operations is based on a long tradition and experience, but due to financial and technical reasons it is concentrated almost exclusively on timber production and the timber resource. The forest management plans provide information on non-wood forest products and environmental protection, but it is not included in the compartment level data (data sheets and maps). The principles of multifunctional forest management have not yet been incorporated in the planning concept. 4.3 Timber Harvesting Timber harvesting is carried out through regeneration fellings, sanitary fellings and thinnings. New stands are established mainly through natural regeneration. Clearfellings are carried out to a very limited extent. They are applied in stand reconstruction and in tending of stands with species requiring intensive management; the maximum size of clearcutting areas is limited to 5 ha. Harvesting technology is rather outdated reflecting both limited investment capacity in the sector as well as the low labor cost, which keeps manual methods competitive. Nearly all fellings are carried out by chainsaws. Skidding is mainly carried out using tractors, but Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 28 January 28, 2004. animals, horses and oxen, are also frequently used; formerly used cable systems have largely been abandoned because of difficulties in maintenance. For transportation, old trucks with a load capacity of 8-12 tons are utilized. The average transportation distance is about 150-200 km. The forest road density is on average 7.9 m/ha, which is a low figure compared to other European countries with broadly similar topographic conditions (e.g. in Austria 36 m/ha, Switzerland 40 m/ha, France 26 m/ha, Germany 45 m/ha). Skidding distances can be up to 2 km. According to the NFPS, approximately 477 000 m3 of the present annual allowable cut is inaccessible due the lack of forest roads. Accessible mature wood resources are intensively utilized in Bulgaria owing to the high demand for saw logs and other large dimension wood assortments. Locally, over-exploitation of easily accessible resources may occur. Field visit October 30-31, 2003: In the Regional Forestry Board of Blagoevgrad, the inaccessible mature forests make up 21% of the total forest area. If young and middle-aged stands with thinning needs are taken into account, the share of inaccessible forests exceeds 30%. The regulations for timber harvesting include environmental safeguards, but the required environmental standards are not necessarily met. The existing normative regulations for the forest roads are technical instructions for the design and construction. The control of environmental impacts is not separately addressed, but certain norms clearly contribute to the protection of soil and water resources. The limited capacity of the NFB to supervise the private sector constructors has often led to violations of existing regulations. Felling is often carried out carelessly causing damage to remaining stand. Inappropriate skidding damages tree roots, and causes soil compaction. Uncontrolled movement of people and animals in the cutting area is often hindering regeneration. The forest workers do not generally wear appropriate safety equipment. There are also shortcomings in the training and health control of forest workers. 4.4 Non-wood Forest Production 4.4.1 Hunting and Fishing About 85% of the country's territory is assigned for hunting, and hunting and fishing are of growing interest to the public. Game management was carried out systematically and rather effectively until the beginning of the 1990s. However, since then game stocks have decreased drastically. The analysis of the data from game inventory during the last 12 years showed a continuous decrease in the number of the main game species (red deer, row deer, fallow deer, small game) (Stoyev 2003). Hunting management plans are effective tools to protect and use game population. The quality of hunting management, however, has suffered from lack of resources, and the capacity to enforce regulations has been reduced leading to increased poaching. Environtinental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 29 January 28, 2004. 4.4.2 Herbs, Mushrooms and Forest Fruits Medicinal and aromatic plants are used as raw material for producing a broad range of goods. Typical of Bulgaria is the extensive use of plants as alternative medicine, traditional utilization of wild species of herbs, as well as export of large quantities of plants. It is reported that some 15 500 tons of herbs are being exported annually, generating an average income of some USD 35.5 million (Forest Sector Analysis 2003). The management of non-wood resources is generally inadequate. The key problem is poor surveillance of harvesting. Harvested wild species of herbs can be legally collected for "personal use" without any registration, but there is limited control over this practice. The harvested amounts considerably exceed what is needed for personal consumption; the documented harvest of herbs is about five times lower than the exported quantity. No assessments on the availability of the non-wood resources are carried out and estimates on the sustainability of current use cannot be established. Harvesting technology is often ill suited for the purpose, and lack of local processing capacity prevents generation of added value. 4.4.3 Tourism and Recreation Bulgarian forests have high potential for development of tourism and recreation. The main forms of forest-based tourism, which have gained popularity are (i) hunting and fishing; (ii) landscape tourism; (iii) ornithology tourism. Overall, the development potential of forest- based tourism is largely unutilized, and the co-ordination between the NFB and private sector tourism developers is underdeveloped. 4.5 Trends in Resource Use 4.5.1 Forest Industries The production of forest industries plummeted after the collapse of communism (Table 4.2). In 2000, the output value from forest industries was only 36% of the level reached in 1990. However, after the initial shock, the declined gradually slowed down and turned into an upward trend toward the end of the decade. Production has expanded especially in mechanical forest industries, whereas the decline of pulp and paper production still continues. Table 4.2 Production of Forest Industries in Bulgaria 1993-2001 Units Product x1000 1993 1994 1995 1996 1997 1998 1999 2000 2001 Sawnwood Cum 253 253 253 253 253 253 325 312 312 Wood-based panels Cum 233 233 233 233 233 233 216 470 530 Wood pulp Mt 97 97 97 97 97 97 78 85 85 Other fiber pulp Mt 10 10 10 10 10 10 10 10 10 Recovered paper Mt 128 128 128 128 128 80 80 80 80 Paper and paperboard Mt 139 148 150 150 150 153 126 136 136 Source: FAQ 2003 Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 30 January 28, 2004. Secondary processing, especially firniture making, is a major activity in the Bulgarian forest sector. The production value of furniture making is about equal to the combined production value of wood-based panels and sawnwood, the two largest branches in primary processing (Forest Sector Analysis 2003). Over the 1998-2002 period, the production of firniture continuously increased. The strengths of the Bulgarian forest industries include low labor cost, availability of well- qualified specialists and reasonable access to raw material, including large tracts of species in high demand such as beech, elm and other deciduous trees. The main disadvantages are outdated equipment and machinery, lack of quality control, weak management and marketing. To improve the technological level, a substantial increase in investment would be badly needed. 4.5.2 Harvesting Levels In recent years harvesting volumes have been much below the biological potential. The average harvesting volume envisaged in the forest management plan for 1996-2000 was 5.2 million m3/a. The planned amount is substantially below the increment (see above) because a substantial portion of the theoretically available volume consists of small- dimensioned timber, which for the time being does not have a market. The official estimate on average harvesting volume during this period is 4.4 million m3/a, which is 85% of the planned volume. Harvesting levels have decreased steadily. In 1996, the official harvesting volume was recorded at 4.9 million mi3, but in 2001 it dropped to 2.9 million m3, which represents merely 24% of the annual increment. However, it is possible that the official volume is an underestimate. A survey on fuelwood use among rural population suggests that total fuelwood consumption could reach up to 6 million m 3 annually. This is a considerably higher figure than the official estimate of 1.5-2 million m3/a (Mediana 2001). There is also a substantial amount of unrecorded, illegal logging. The reasons for the low level of harvesting include, inter alia, the following (status in 2002) (Forest Sector Analysis 2003): * Owing to inadequate road network (average density 7.9 m/ha) 477 300 m3 of the allowable cut could not be accessed, as it is situated in "temporarily inaccessible areas". * Private and municipal owners are challenging in court several decisions, whereby a forest area claimed by them was not restituted. Harvesting activities on these properties, which hold 1 869 000 m3 of the allowable cut, are blocked pending court rulings. * There is a lack of markets for technological timber. Regarding future development, it is assumed that most of the complaints regarding ownership status have already been filed, and that the area under dispute will not significantly expand. It is therefore expected that from now on the area available for harvesting will gradually increase, as the legal proceedings reach completion. If the plans to expand road construction will be implemented, it will also - in a few years time - expand the area available for harvesting. However, the direct impact of the FDP will be modest in this regard owing to the limited amount of new roads - 25 km - to be constructed under the project. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 31 January 28, 2004. From environmental point of view it is significant that especially thinnings have not been implemented as planned. In fact, thinning volumes have plummeted in the last three years. Their area was modest to begin with - 50% of the planned area in 1996 - but in 2000 it sunk to 37% and in 2001 only 28% of the plan was fulfilled. The backlog in thinnings is the most serious concern regarding the future development of growing stock and increment, because delayed thinnings impact negatively on growth and health of the forest resource. In particular, there is a risk that the large investment made in coniferous plantations will be lost, because lack of thinning reduces their productivity and makes them more vulnerable to wind, fires, and pest attacks. 4.5.3 Illegal Harvesting In the last years the number and the extent of illegal activities in the forests have increased. Violations in the use of forest, game and fish resources fall into three basic categories according to involved actors and their objectives (NFPS 2003). The violations are undertaken by * local inhabitants to meet their needs for wood, meat and other products. These violations are seasonal, unorganized and cause smaller single damage. * organized criminal groups to realize significant financial profit. Usually this sort of violation is organized with the participation of civil servants, especially staff in forestry administration. * wood-consuming companies. This takes the form of transporting of unaccounted and . unpaid wood sometimes with the assistance of staff in forestry administration. There are many negative environmental impacts associated with illegal logging. As they usually target the most accessible sites near forest roads, these sites become easily overexploited. Harvesting is carried out without any consideration for environmental issues. As a result, there is often physical damage on the remaining stand and roads. Clogged ditches have reduced draining capacity. In younger forests the remaining trees are of inferior quality as the best ones have been harvested. The estimates on the volume of illegal logging are at best rough approximations. Recorded volume of illegally harvested wood was 41 600 m3 in 2001, three quarters of it firewood. Unofficial estimates provide higher figures, up to several million m3 per year. It is estimated that 5 to 15 per cent of the timber on the commercial market has been illegally logged. Locally, the volume of illegal logging has temporarily equaled the annual allowable cut and led to restrictions in the authorized logging operations: Field visit October 30-31, 2003: The Regional Forestry Board of Blagoevgrad has estimated by measuring stumps in the field that approximately 70 000 m3 of timber were cut illegally in Razlog Game Breeding Station in 2002-2003. The current AAC of Razlog Game Breeding Station is computed at 36 000 m3. Approximately 200 people have been involved in the illegal activities. With active control measures initiated by the Regional Forestry Board, the volume of illegal timber is believed to drop by 95%. There is evidence of a lack of discipline and lack of responsibility among the employees in the forest system. The violations in the forests are considered the main cause of corruption in the sector. There are municipalities where violations in the forests have reached a scale Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR 32 January 28. 2004. threatening not only the ecological balance, but also their perspective for economic development. The effectiveness of applying the penal laws of forest legislation is considered very low (NFPS 2003). 4.5.4 Allowable Cut Shortcomings in data and lack of relevant research prevent detailed projections on the future development of the forest stock. However, taking into consideration restrictions on forest management in protected and protective forests, it has been estimated - as an expert judgement -that in 2010, the maximum sustainable harvesting volume could reach 8 million m3 (4.5 million m3 from thinnings and 3.5 m3 from regeneration fellings), and in 2020 - 10 million m3 (5 million m3 from thinnings and 5 million m3 from regeneration fellings (NFPS 2003). The relationship of this estimate with the current forest use is difficult to estimate mainly to uncertainties related to the extent of illegal use and fuelwood cuttings. In addition, a large portion of this consists of small-size timber, which can be harvested only if new processing capacity is established. 4.6 Forest Ownership The restitution process is underway transferring state forest to ownership of non-state entities. A temporary status in October 2002 indicated that about 86% of the forest area was still in state ownership. The largest non-state owners include municipalities with 6% of forest area as well as individuals, who have 8%. The woodlots in individual ownership are very small, most of them around 1 ha in size. Municipal forests usually cover several hundreds of hectares. About 140 000 ha of forest in protected areas is in non-state ownership. Of this, approximately 40% is in individual ownership, the rest is held mainly by municipalities. The basis for the restitution process is the status of forest ownership in the year 1947. At that time the largest portion, more than half of the forests were managed by municipalities, often based on lease agreements from the state. Several municipalities have launched a legal procedure to establish their property rights to forest areas that they used to managed but which are currently in state ownership. The outcome is uncertain, but it is estimated that the upper limit for the area that the municipalities could gain ownership to is 35 per cent of the forest area (Stoyev, pers. comm.). The environmental concerns of the private and communal forestry are related to lack of forest management skills, unawareness of legal requirements, undeveloped support structures and unrealistic expectations of benefits from forests. Since both individual owners and municipalities are often located in the most deprived regions of the countries, it is probable that they will give high priority for obtaining cash income from their property. Most private forest holdings are not large enough to provide the owners with reasonable income unless most of the available resource is immediately exploited, which is a potential risk for the sustainability of forest management both in terms of timber production and environment. Regarding the latter, there is particular concern over the fact that many restituted forests are located on critical watershed protection sites close to villages. In addition, inadequate and inappropriate silvicultural treatments may lead to deterioration of forest resources. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDULFOR. 33 January 28. 2004. 4.7 Environmental Status The main focus of environmental management of forests has so far been on soil and water conservation as well as on maintaining forest health; issues related to biodiversity have received less attention. Lack of resources has been a persistent constraint to implementation of environmental protection measures. In addition, inappropriate organizational arrangements have reduced the efficiency of using existing resources. 4.7.1 Biological Diversity 4.7.1.1 Status The Bulgarian forest resource contains environmental values, which are unique in European and even global terms. According to Temperate and Boreal Forest Resource Assessment (TBFRA) the area of virgin forests in Bulgaria is 257 000 ha, which in absolute terms is the third largest area in the whole of Europe excepting Sweden and Finland. On a national level, the management of Bulgarian forests is a key factor for the conservation of the biological and landscape diversity. The lands and the forests of Bulgaria contain (NFPS 2003): * Over 80% of the protected plants; * Over 60% of the animals threatened with extinction; * Over 60% of the priorities for protection habitats; * Eight of the twelve unique landscape complexes, determined in the National Strategy for Protection of the Biological Diversity as unique and representative for the Bulgarian biological diversity; * The populations of 43 world threatened species. As part of preparing the FDP an analysis of natural forest vegetation types has been conducted. A total of 48 high conservation value forest ecosystem types were recognized. Five major forest blocks comprising large natural forest ecosystems were identified, namely: Rila-Pirin region, Central Balkan, Western Rhodopes, Strandzha and Western Balkan. Their total area is 700 000 ha, of which forests cover 500 000 ha. The project also listed 31 forest areas with critical concentrations of endemic and threatened species (vascular plants, invertebrates and vertebrates) as well as 21 sites of areas containing representative threatened and rare forest ecosystems. The increased human activity in the forests in the last 100 years and the national economic development have led to: * Increased use of forest areas, and extraction of forest products; * Fragmentation of forest ecosystems; * Homogenization of the tree composition and the age of the forest stands; * Significant changes in the biological and landscape diversity as a result of the forest fires. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and FoIestry of Bulgaria, prepared by INDUFOR. 34 January 28, 2004. 4.7.1.2 Biodiversity Conservation and Management In recent years increased attention has been paid to conservation of forest biodiversity. The efforts made by the Government have been supported and complemented by a large number of donor assisted projects. However, despite substantial allocation of resources for biodiversity conservation, the various interventions tend to remain isolated and suffer from poor co-ordination. There is also a lack of qualified staff in NFB and Regional Forestry Boards, and biodiversity conservation is not emphasized as a field of expertise. The priority strategy for biodiversity conservation in Bulgaria is the preservation of species in situ. Accordingly, the main implementation tool is the establishment of a National Ecological Network of protected areas and protected zones. In the forest sector, the FDP is introducing a strategy to mainstream biodiversity conservation into the management of productive forest areas. The existing protected areas have a favorable structure in that several individual sites are large enough to accommodate many highly demanding species (Kun 2002). On the other hand, the current protected area network may not be fully representative. A large part of the areas are located in high mountain areas excluding forest ecosystems typical of plain areas. Development efforts are, however, underway. Two, new nature parks, Rilski Manastir (the Rila Monastery) and Persina, were established in 2000. There is also a significant number of initiatives to expand the protected areas network further (IUCN category V) including those focusing on West and East Rhodopes, Western Balkan Range, Studenetz, Belasitza etc. The National Forestry Board supports these initiatives promoting the idea of establishing a trans- border protected areas network - the so-called Balkan Green Belt. Biodiversity conservation has not yet been able to make its way into the mainstream of forest management. The main intervention is to steer the tree species composition towards "optimum" in the thinnings of natural forests. This optimum reflects the composition of tree species in a naturally developed stand. Otherwise, the maintenance of biodiversity at the level of species and key habitats is not clearly addressed in the present forest management operations. For instance, the amount of decaying wood in the production forests is too low to provide habitats for species dependent on this type of resource. 4.7.2 Water and Soil Protection Water and soil protection have high significance in Bulgaria. More than half of the land area is sloped 20% or more, and about 60% of the country territory is subject to erosion. There are 2000 water streams with torrential regime. Bulgarian forests also provide about 85% of the water flow in the country or nearly 3.6 billion m of clear drinkable water. Some 14% of Bulgarian forests have as a primary goal the protection of the soil against erosion and water balance maintenance. To-date, about 660 000 ha of erosion-prone areas have been afforested including more than 20 000 ha of protective belts. However, the last 10 years show a sharp decrease in afforestation activities against erosion and construction of protective equipment. There are also about 900 000 ha of land outside the forest fund, which are severely affected by erosion but do not benefit from significant protection programs. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 35 January 28, 2004. The risk for large-scale erosion is well recognized in the guidelines for forest management operations (e.g. ban on clear fellings, special attention to operations on southern and western slopes). Small-scale damages, however, are caused by road construction and off-road transportation of timber. In addition, unauthorized activities and forest fires have contributed to landslides and other type of erosion. The adverse impacts on water bodies are mainly related to uncontrolled erosion, performance of cutting operations, and construction and maintenance of forest roads. The Bulgarian legislation does not require environmental impact assessment on construction of forest roads. 4.7.3 Forest Health A pan-European survey (UJN-ECE and European Commission 2002) indicates that defoliation peaked in 1998, when 60.2% of the trees in Bulgaria were moderately or seriously affected (defoliation classes 2-4). Since then the situation has gradually improved, and in 2001 the proportion of damaged trees was recorded at 33.8%. Most causes of defoliation are outside the forest sector. Within the sector, periodic outbreaks of fungi and pests like Lymantria dispar, Thaumetopoea pityocampa, leaf-rollers and caterpillars, have caused massive defoliation in plantation forests. Long-distance transportation of timber is a minor source of air pollution and ambient noise. The area of forest fires has increased dramatically since 1990s; compared to the previous decade the increase is more than 20-fold. Over the last 11 years, 133 000 ha corresponding to 3.5% of the total forest area have been affected. Several possible reasons have been identified: social and economic changes towards market economy, inadequate coordination between authorities responsible for fire control, lack of fire-fighting equipment, organizational changes in the forest sector, planting of unsuitable tree species etc. A typical feature is that the forest fires are almost exclusively caused by human activities outside the forest (most commonly fire escapes from agricultural burning); natural fires (e.g. lighting) are reported to account only for 1-2% of the incidences. However, unknown causes dominate in the fire statistics. A National Strategy for Forest Fire Management has been developed to (i) set up normative arrangements including authorities and responsibilities of state institutions and NGOs, (ii) establish information systems for early warning and detection, fire danger rating and registration of fires, (iii) combat forest fires including equipment and training, (iv) rehabilitate burnt forest sites and carry out preventive measures in fire prone forest, and (v) participate local communities in the fire control. The Collegium of the Ministry of Agriculture and Forestry endorsed the proposed strategy in December 2003. Illegal grazing and the great number of goats also contribute to degradation of forests. 4.7.4 Carbon Management Bulgarian forests play a significant role for decreasing the emissions of greenhouse gases in the atmosphere accumulating the carbon in the biomass and actually absorb CO2. The total absorbing capacity is estimated to nearly 142 millions of tones of carbon, which is about 516 millions of tons CO2 - equivalent (NFPS 2003). Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 36 January 28, 2004. The Bulgarian govemment intends to enhance its contribution to carbon balance by development of bioenergy, afforestation and adaptation of management regimes to climate changes. Roundwood from thinnings, logging residues (e.g. branches and tree tops), industrial by-products (e.g. bark, edgings, chips, sawdust) and recycling materials (e.g. construction timber and recovered paper) are the most important renewable sources for energy production in Bulgaria. With respect to afforestation, a great potential is available in the bumed forest areas and abandoned agricultural lands. Adaptation of management applies above all to regimes applied to forest vegetation situated under 800 meters above sea level. The national energy production currently relies on fossil fuels and nuclear power. As a result of highly subsidized energy supply system in Bulgaria, the efficiency in the utilization of energy for heating purposes has been low. In particular, public buildings have been constructed with little concem for energy efficiency. Liberalization of energy prices has resulted in dramatically increased heating expenses that can constitute a significant portion of the local govemment budgets. The energy sector is globally the number one contributor to greenhouse gas emissions. In line with the Kyoto Protocol, the national objective is to achieve 8% reduction in greenhouse gas emissions by 2008-2012 from 1990 level. In addition, a target of the European Commission is to increase the share of Renewable Energy Sources (RES) to 12% by 2010. The EU member countries aim to achieve the target by preparing and implementing national polices and promotion programs. Construction of energy generation facilities is strictly regulated by the national legislation (in particular, Energy Act and the new Environmental Protection Act). If the output capacity of a heat plant is designed to be 50 MW or more, an Environmental Impact Assessment (EIA) is an obligatory requirement for the investment. With regard to boilers with lower capacities, Regional Environmental Inspectorates make the decision on the need for the EIA based on the provided technical description and prevailing conditions on the proposed site and its surroundings. The EIA can always be imposed based on the Environmental Protection Act. The normative regulations do not require operational licenses (e.g. in terms of monitoring stack emissions) for boilers with a capacity of 5 MW or less. Nevertheless, the construction of heat facilities of small and medium size is still under strict govemmental control, since the authorities have to evaluate the designed boilers and other equipment. The Bulgarian State Standards set also requirements for the technology to be applied in the heating plants. 4.8 Social Issues The most important social contributions of the forest sector are provision of employment and allocation of subsidized fuelwood. In 2000, the number of people employed in forestry sector was estimated at 14 500, which represented about 0.5% of the total workforce in the country. However, it should be noted that forestry sector has higher significance in deprived rural areas, where employment opportunities are highly limited. The wages paid in forestry are around national average for all sectors, whereas in wood processing they reach only two thirds of it. Reduced purchasing power of the Bulgarian population has resulted in a sharp increase of use of timber for cooking and heating. Within the last two years the number of households using wood as source of energy has doubled and reaches now about 40 percent. With further Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 37 January 28, 2004. increases in electricity prices in the coming years, wood energy will continue to play a key role, especially in rural areas, leading to greater risks of illegal logging, overexploitation, and erosion of accessible areas around settlements (World Bank 2002). The Government has a strong social orientation in its policy on timber use. Between 1996-2001 nearly 30% of harvested timber - roughly 1.1 million m3 per year - was designated for use by local households, mainly to supply fuelwood. The price for the allocated timber is set below those paid in the free market. There are allegations that the procedure for distribution may occasionally be subject to favoritism and corruption. Despite being a social support, the subsidized allocations are sometimes provided to people who intend to re-sell them for profit. Apart from being socially unjust, the practice is also distorting the commercial fuelwood market (Forest Sector Analysis 2003). Non-wood products are an important supplement to people's diets in rural areas and individuals have the right to collect herbs, mushrooms and berries for personal use. However, people often circumvent the regulations and collect them for sale on the commercial market. Forests also serve as grazing areas for goats. Near densely populated areas the herds are often so large that they damage the tree stands. 4.9 Forest Administration 4.9.1 Structure and Functions The overall administrative responsibility for forestry-related matters is assigned to the Ministry of Agriculture and Forestry (MAF), which - among other tasks - is responsible for formulation and implementation of forest policy. MAF is also charged with implementing the restitution of agricultural and forest lands. Another relevant body is the Ministry of Economy responsible for the administration of the wood processing industries through the formulation of policies and strategies and monitoring the activities of the industries for compliance with laws and regulations. The responsibility for management of protected areas is divided between National Forestry Board (NFB) and Ministry of Environment and Water (MEW). The latter is the lead body in implementing biodiversity-related policies in the country. The main operative body of state forest administration is the National Board of Forestry (NFB) under MAF. The NFB has functions as a public authority (formulation of legislation, forest protection, law enforcement, research and development etc.) as well as responsibility for state forest management. However, as the NFB structure and its relationship with MAF will soon undergo a major overhaul with the support of the FDP, the present structure will not be analyzed further. Instead, the potential environmental impacts of the various development options will be examined in more detail in Chapter 6.3. 4.9.2 Management of State-owned Production Forests The National Forestry Board (NFB) is in charge of forest management through Regional Forestry Boards (RFB) and local subordinates. The RFBs, 16 in number, have two types of local units for state-owned production forests: (i) State Forestries (144 units), and (ii) Game Breeding Stations (37 units). The State Forestries are the basic organizational structure. The Game Breeding Stations are responsible for forest operations in districts, where game management plays a significant role. The production forests under the control of Game Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 38 January 28, 2004. Breeding Stations are split up into two groups according to their management objective: (i) intensive game management, and (ii) regular forest management. The areas managed by the Game Breeding Stations are mainly ordinary production forests. 4.9.3 Management of Protected Areas Based on the 1998 Protected Areas Act the responsibility for managing protected areas was split between the Ministry of Environment and Water (MEW) and National Forestry Board. MEW is charged with the overall supervision and control over all protected areas as well as for the practical management of National Parks, reserves and strict nature reserves. To this end, MEW has established three National Park Directorates, and no changes in the administrative structure are envisaged. NFB is entrusted with the management of other protected areas including Nature Parks, Protected Landscapes and Natural Landmarks, and the current plan is to hand them over to the new state forest company. Protected Areas Act defines the concept of Nature Park. All 1 1 Nature Parks are categorized as high conservation value forest areas (HCVA). MEW manages, maintains and safeguards the protected areas that are exclusive state property (three national parks, 55 reserves and 35 support reserves). The management and safeguard of territories that are not exclusive state property (1 1 nature parks, 146 protected landscapes, and 473 natural landmarks) is implemented by their owners. According to the law, the NFB nominates specialized directorates for management and maintenance of nature parks. Comprehensive data on expenditure in protected areas is lacking. However, it appears that in the three National Parks under MEW, the planned expenditure for 2002 of the same order of magnitude as in the other EU accession countries. The Nature Parks managed by NFB, on the other hand, had much more limited resources (Forest Sector Analysis 2003). In the past, some additional funds have become available through two separate Funds - the National Environment Protection Fund (NEPF) and the National Trust Eco Fund (NCEF). In 2003, the Government initiated the establishment of Protected Areas Fund to provide supplementary funding for protected areas. The fuind will operate within the existing NCEF and will focus on the themes of biodiversity conservation, infrastructure, management plan development, sustainable economic use of protected areas, communication and education, and institutional strengthening. The Government is making a strong commitment to this fund and to the nation's protected areas. It will match international grants to the fund, up to BGL 12.5 million. In addition, it will continue to support the annual budget of the protected areas system at a cost of BGL 1.5 million in 2003, and increasing by 20 percent per year over the next four years. 4.10 Other Forest-related Entities 4.10.1 Communal Forest Organizations Municipal forest organizations will be a significant player in the Bulgarian forest sector. Municipalities with major forest ownership are expected to establish specialized forestry units. Their statutes, functions and responsibilities shall be defined by the municipal councils or forest directorates within the municipal administrations. So far, only one municipal forestry Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR, 39 January 28, 2004. center has been established in the municipality of Haskovo. About half a dozen municipalities have established a forestry unit with a few staff (Forest Sector Analysis 2003). 4.10.2 Non-governmental Organizations Non-governmental organizations active in Bulgaria's forest sector are still rather weak. Private forest owners' organizations are emerging, although they still have limited membership. The forest owners' associations (FA) and forest enterprise co-operatives (FEC) currently cover a total area of 17 571 ha and have 4 151 members. The total number of FAs and FECs is 32, most of them established in the Smolyan region. There are also a few co- operatives as well as associations uniting the private owners in northern Bulgaria (PPU 2003). There are about 100-300 environmental NGOs active either at the national or local levels, and most of them have an interest in forestry. The environmental NGOs typically engage in activities such as promotion of afforestation, control of forest management, biodiversity conservation, environmental advocacy and education etc. Their activities are hindered by lack of funding and administrative capacity. On the other hand, many of them enjoy strong links with international environmental networks and have developed an impressive level of competence in regard to many issues facing the country's environment. A limited number of Bulgaria's ecological NGOs has members with forest-related education; this fact poses an opportunity for their further involvement and policy dialogue on the national forest strategy and the FDP (Forest Sector Analysis 2003). 4.11 Public Participation The policy of the Ministry of Agriculture and Forestry and the National Forestry Board has provisions for public involvement in connection with important legislative and governmental decisions. Prior to their introduction to the Council of Ministers, all draft legislation goes through a consultative procedure within governmental institutions, and in certain cases with non-governmental organizations. Regarding the latter, their full potential may be underutilized by MAF. Among the various bodies established by MAF, the environmental NGOs are represented only in the Council for Forest Protection. In contrast, the MEW regularly includes the environmental NGOs as members in official expert groups. The formulation of a National Forest Policy and Strategy (NFPS) is the first example of a major process in the forestry sector, where all stakeholders including the non-governmental and private sector organizations have an opportunity to provide inputs at various stages of the process. The preparation of FDP was also a highly participatory process. The current procedure for formulating regional forest management plans lacks opportunities for participation, and may seem non-transparent to the public. In contrast, the methodology for preparing forest management plans has provisions for public participation irrespective of their ownership or status as commercial, protective or protected forest. Environmental Assessment of the Forest Developnment Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. 40 January 28, 2004. 5. ENVIRONMENTAL IMPACTS 5.1 Conduct of Assessment 5.1.1 Approach The terms of reference for the environmental assessment of the FDP require a review of environmental impacts and risks associated with physical investments in the forest sector development, and the proposed administrative, legal and institutional changes. The direct physical investments of the FDP are carried out in five main areas: (i) rehabilitation and construction of forest roads, (ii) rehabilitation and regeneration of forest fire sites, (iii) thinnings of young and fire prone stands, (iv) construction of key infrastructure in nature parks and (v) implementation of the Fuel Switch Pilot Project. The direct administrative, legal and institutional changes are related to (a) restructuring of the National Forestry Board (NFB), (b) support to the establishment of national and local level interest organizations for private and communal forest owners, and (c) assistance in setting up a series of network clusters for SMEs. In particular, the restructuring of the NFB is expected to result in major administrative changes in the Bulgarian forest sector and the foundation of two new organizations: the National Forest Company (NFC) to manage state-owned forests and State Forest Administration (SFA) to carry out extension and inspection service. The components of the FDP were thoroughly examined during the inception phase of the EA process. For analytical purposes the intervention of the FDP was divided into three groups according to its impact areas, which have distinguished interaction with the environment (Figure 5.1). The main principle is that field operations have direct environmental impacts, while institutional structures, operational models and guidelines are means to control activities and their impacts. Thus the institutional level and the level of operational control indirectly affect the environmental performance. The assessment of components related to administrative, legal and institutional changes was rather broad addressing issues on several different levels. (Box 5.1): - Component 1: Strengthen Public Forest Sector Management - Component 2: Strengthening of Capabilities of Non-State Forest Owners - Sub-component 3.1: Implementation of Restructuring Plan for the National Forest Company The other components and sub-components were assessed exclusively against pre-selected impact areas described in Box 5. 1: - Component 3: Supporting State Forest Management Transition to Market Economy (excluding Sub-component 3. 1) - Component 4: Promotion of Biodiversity Conservation in Forest Management In accordance with the terms of reference, the restructuring models of the NFB are also separately analyzed to provide elements for the decision-making in the reform of the Bulgarian forest sector. The analysis focuses on the comparison of the alternative models, and their influences on timber harvesting, construction of forest roads and institutional arrangements (Chapter 6.3). Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 41 January 28. 2004. Figure 5.1 Impact Levels of the FDP Intervention LEVEL OF NORMATIVE REGULATIONS International Commitments F National Legislation Policies and Strategies F Others INSTITUTIONAL LEVEL Ministries of Bulgaria National Forestry Board Forest owners' associations Others LEVEL OF OPERATIONAL CONTROL Governmental Norms Guidelines Codes of Best Practice Others OPERATIONAL LEVEL Rehabilitation Thinnings l Road Construction Others ENVIRONMENTAL IMPACTS Forest Resources & Products Biodiversity Soil & Water Others Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 42 January 28. 2004. Box 5.1 Objects of Impact Assessment 1. Strengthen Public Forest Sector Management 2. Strengthening of Capacities of Non-State Forest - Building and Strengthening Nationwide Forest Owners Extension and Inspection Services - Fostering National Association of Private and - Building and Strengthening a Nationwide Forest Communal Forest Owners Fire Management System - Supporting Community Based and Communal - Developing a Forest Information and Monitoring Forest Owners Associations System, Including Updating of National Forest - Realignment of SAPARD and Support Database - Illegal Logging Surveillance and Monitoring - Finalization of National Forest Certification Standard - Support for Professional Technical Schools 3. Supporting State Forest Management Transition 4. Promotion of Biodiversity Conservation in to Market Economy Forest Management - Implementation of Restructuring Plan for State - Mainstreaming Biodiversity Conservation in Forest Administration Forest Management Planning - Upgrading of Forest Road Network - Integration of Biodiversity Conservation in - Thinning of Young and Fire Prone Stands Forest Management Operations - Reforestation and Rehabilitation of Destroyed and - Strengthening the System of Forest Nature Parks Devastated Forest Fire Sites Managed by the National Forest Company - Implement Pilot Certification in Selected State - Development of the Bulgaria Protected Areas Forests Fund Endowment - Forest Biodiversity Program Coordination and Management - Joint Implementation Capacity Enhancement and Project Pipeline - Bulgaria Fuel Switch Pilot Project 5. Project Management and Monitoring - Project Management - Project Monitoring 5.1.2 Methodology 5.1.2.1 Overview The methodology developed in the inception phase of the EA process was employed as such for the conduct of assessment. The assessment process consists of six main phases presented in Figure 5.2. 5.1.2.2 Impact Assessment The impact assessment contains (i) identification of environmental impacts and (ii) their significance analysis within the frame provided by the regrouping of the FDP components. The impacts on the environment are split up into seven categories, of which five deal with forest and nature and two with occupational health and safety, and social issues (Box 5.2). Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 43 January 28, 2004. Figure 5.2 Phases of the Environmental Assessment Inception Phase Identification of Environmental Impacts and Risks Components of FDP (incl. Restructuring of NFB (incl. the project alternatives) three alternative models) Fuel Switch Project (incl. options for pilot areas) Significance Analysis of Environmental Impacts and Risks All Identified Environmental Impacts and Risks Screening through the criteria Legal requirements - Stakeholder views International requirements - Other criteria Significant Environmental Impacts and Risks Control of Significant Environmental Impacts and Risks Provisions of Bulgarian legislation Procedures defined by the FDP Gap Analysis Need for Additional Control Procedures Stakeholder Consultation Environmental Management Plan Mitigation Methods Monitoring Capacity Building Implementation Plan Reporting & Public Consultation Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUIFOR. 44 January 28, 2004. Box 5.2 Categorization of the Environment with a View to Potential Impacts 1. Forest Resources and Products 2. Flora & Fauna (Biodiversity) - Wood - Habitats - Non-wood forest products - Species - Forest health (e.g. pest management) - Others - Others 3. Soil 4. Water - Nutrient balance - Water abstraction - Water (e.g. groundwater) - Soil particles - Hazardous substances (contamination) - Hazardous substances (chemicals) - Mechanical disturbance - Others - Others 5. Air 6. Occupational Health and Safety (OHS) - Hazardous compounds (pollutants) - Hazardous compounds - Global warming - Air quality (e.g. particulate matters, hazardous - Ambient noise compounds) - Others - Workplace noise - Others 7. Social Issues 8. Other issues considered - Employment / Income - Illegal logging and other unauthorized use of forest - Local economy products - Cultural property - Grazing - Involuntary resettlement - Forest fires - Others - Others While identifying environmental impacts of forest management and other activities, a difference was made between normal operational conditions and abnormal conditions. The normal operational conditions refer to forest management practices or other activities, which are carried out according to the current regulations and control systems. The abnormal operational conditions refer to situations, where operations deviate from the defined practice. The likelihood of occurrence of such situations was taken into account with the help of e.g. statistical data, information provided by the stakeholders and field observations. Forest fires, illegal logging and other unauthorized activities are included in the abnormal conditions. The current management practices and institutions are adopted as the baseline while evaluating the environmental impacts and risks. The impact of the FDP and the restructuring of the NFB were compared to the baseline situation. The significance of the environmental impacts and risks is determined on the basis of a set of criteria. The main criteria include: - National legislation - Intemational requirements (e.g. the guidelines of World Bank/International Finance Corporation, the international agreements and treaties) - Stakeholder views - Other unspecified criteria Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 45 January 28, 2004, 5.1.2.3 Control of Significant Environmental Impacts The existing control procedures for the significant environmental impacts and risks were studied in detail. The following documents establish the main sources of information: - National legislation and other normative regulations - Systems, guidelines and norms of the NFB - Planning and control procedures of the FDP and the FSPP (Terms of Reference for project sub-components, Project Appraisal Documents etc.) The EA team assessed the adequacy of control procedures developed for the identified, significant environmental impacts and risks. Based on the findings of the assessment, recommendations were made to further elaborate the control procedures or to develop new ones to mitigate significant adverse environmental impacts. 5.1.2.4 Environmental Management Plan The Environmental Management Plan (EMP) summarizes the significant environmental impacts and risks and proposes measures for their mitigation. The following components are included in the EMP: (1) Mitigation measures for the significant adverse environmental impacts (separately for normal and abnormal conditions such as accidents and emergency situations) (2) Monitoring measures (3) Needs for capacity development and training (4) Implementation schedule and costs estimates (5) Integration of the EMP to the FDP 5.2 Component 1: Strengthen Public Forest Sector Management 5.2.1 Key Issues Environment-related issues regarding public forest sector management include: (1) Law enforcement * Insufficient resources and technical capacity of forest guards, low salaries and motivation * Gaps and loopholes in existing legislation * Ineffective system for execution of penal code (For instance, the NFPS identified the ineffectiveness of the current penal system as a major problem for law enforcement) * Corruption in forest sector * Industrial use of illegal wood * Dependence of local population on illegally harvested fuelwood (2) Forest extension Limited capacity and material resources to provide support to private and municipal forest owners Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 46 January 28, 2004. (3) Forest education Low level of education and further training of the personnel in the forest and forest industries sectors (4) Occupational health and safety * Forest workers generally lack safety equipment * Inadequate training and health control of forest workers (5) Forest health * Insufficient technical and institutional capacity for forest protection and fire control * Plantation forests are degraded due to outbreaks of pests and fungi (in principle, the pest and fungi diseases are results of physiological exhaustion of trees. Humidity, nutrient balance, temperature, stand structure and biological characteristics of species are examples of factors to affect the health of trees) * Forests in vicinity of inhabited areas are pressured by grazing of goats and other domestic animals (6) Forest information systems * Inadequate capacity to assess the forest and non-wood resources and their use * Lack of an integrated forest information system 5.2.2 Coverage and Impacts of the FDP Intervention The FDP Component 1 deals with the main environmental issues that fall within public administration in the Bulgarian forest sector. The obvious development needs regarding capacity building in forest administration (forest inspection and extension), improvement of information management, prevention of illegal activities and forest fires, are all well addressed in the documentation of the FDP. The resource constraints in key areas will also be relieved by the FDP enabling acquisition of adequate equipment and technology. The proposed activities also are in line with the priorities set by the NFPS. The FDP implementation contributes to law enforcement through differentiated inspection of forest management and unauthorized activities in the state-owned, private and communal lands and through intensified extension services targeted to non-state forest owners. The establishment of a forest information system supports the law enforcement objectives including the combat against illegal logging and provides a modem database for planning and monitoring of forest management activities. The primary goal of the study on illegal logging and corruption is to get a reliable picture on illegal logging and to use this information for the design and strengthening of monitoring and enforcement capabilities in Bulgaria' forestry sector. The study has three specific objectives namely: (i) to clarify the extent of the illegal logging problem and (ii) to provide recommendations for improving the current monitoring system; and (iii) to clarify the inter- sectoral dimension of illegal logging to provide data and information on the subject. The expected results of this assessment will not only provide the Bulgarian authorities with a clearer picture of the problem, but will further constitute the basis for strengthening the present logging monitoring system and for finding effective solutions to illegal logging Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 47 January 28, 2004. problems, both commercially motivated and poverty-driven ones. The impact cannot be estimated at this stage, but this is undoubtedly a key area to be addressed. The PPU has prepared a fire technical report, which includes an analysis of forest fires and control systems applied in Bulgaria as well as recommended investments and specifications for implementation. The report recommends ten projects for implementation, which are all included in the FDP: fire study tour, community education and awareness, provision of fire trucks, communications, equipment supply, fire danger/rating risk assessment, training, fire lookouts, legislation and coordination and fire reporting information system. The strategy appears appropriate and it is estimated that the environmental impact will be positive. Finalization of the national standard for forest certification will provide an internationally recognizable set of requirement for sustainable forest management. Updating of the draft standard is also in compliance with the NFPS objectives to certify a minimum of 30% of Bulgarian forests. The environmental impact of expanded certification is decidedly positive. 5.2.3 Suggested Mitigation and Enhancement Measures The focus of this component of the FDP is by and large appropriate, since distribution of resources too thinly over a large number of activities carries the risk that their effectiveness is seriously reduced. Nonetheless, the following complementary measures are proposed, since they are closely related to planned activities, and their implementation requires moderate resources: * In spite of the fact that the terms of reference for the study on illegal logging and corruption address the importance of inter-sectoral cooperation between various ministries, authorities and the private sector, the terms are recommended to be revised to have a clear focus on the following two issues: 1. Lack of collaboration with the police force and the ineffectiveness of the judicial system in processing criminal charges and enforcing penalties have often proved to be serious bottlenecks. This aspect would deserve a stronger stress in the analysis. In addition to the police force, improved collaboration is needed with e.g. Ministry of Economy, Ministry of Justice, Customs and Ministry of Finance. 2. Production capacity of wood processing industry and availability of wood is not in balance in certain regions of Bulgaria. The demand for industrial wood that exceeds the supply could be a major contributor to illegal logging, and the issue should be studied in detail. * In order to intensify the combat against illegalities in the forest sector, it is recommended to establish a high level inter-sectoral task force on illegal logging and corruption * The adverse social impacts of reduced use of illegally harvested fuelwood are recognized by the FDP (e.g. terms of reference for the study on illegal logging and corruption). Therefore, the Government of Bulgaria should develop measures to ensure adequate and low cost supply of fuelwood to local communities. These measures could include: 1. An annual governmental compensation payment to the NFC covering the difference between market prices for fuelwood and actual sale price 2. A reduced payment of dividends for the NFC for an agreed time period 3. Allowing local people to harvest fuelwood in state-owned forests needing thinnings Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 48 January 28, 2004. * Updating of state regulations on logging and silvicultural activities with environmental requirements (e.g. maintenance of biodiversity and control of impacts on soil and water) * Independent logging companies should be included among the beneficiaries of technical assistance provided by the FDP, since independent logging companies are envisaged to carry out 90% of the harvesting operations in the state-owned production forests. In the non-state forests, the logging companies may account for almost 100% of the harvesting volumes. * The FDP should intensify the control of occupational health and safety in forest operations. The National Forest Company should require the logging and other forest management companies to respect the safety legislation of Bulgaria and guidelines of the World Bank. The implementation of safety regulations could be subject to regular monitoring by the State Forest Administration as well as the internal control system of the National Forest Company. * The FDP has not sufficiently addressed the issues related to grazing and health conditions of plantation forests, which both are included in the strategic actions of the NFPS. It is recommended that both subjects are studied and careful consideration is given to the mitigation of negative impacts on animal husbandry. * When developing the national forest database special attention should be paid to enabling data exchange with other databases including relevant environmental-related data. Typically, all forest-related environmental data cannot be included in one database, because it is often collected and used by institutions outside the forest sector. It should therefore be ensured that data formats are compatible and that access to pertinent information is not restricted due to technological or administrative barriers. * The institutional arrangements for law enforcement and monitoring could benefit from resources available outside the state sector. Currently, only state entities are involved, but private forest owners could have an interest to participate in surveillance activities at a low cost. The NFPS also gave a high priority to developing arrangements that would enable the NGOs to contribute to the monitoring system. * While finalizing the national standard for forest certification, it is recommended to pay attention to its applicability to small-scale forestry and group certification. Otherwise, there is a risk that only large forest management units will be certified according the national standard. 5.3 Component 2: Strengthening of Capacities of Non-State Forest Owners 5.3.1 Key Issues The re-established private sector of Bulgaria is not yet well organized and especially the private forest owners are often unsure how to manage their land properties. The restitution process has resulted in fragmentation of forest resources and small-sized holdings, which are not large enough to provide the owners with reasonable income on the basis of sustainable forest management. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 49 January 28, 2004. The key environment-related issues regarding the non-state forestry include: (1) Sustainable forest management * Low quality of regeneration work * Inadequate silvicultural measures * Environmental control of operations in general is weak (2) Level of awareness * Legal requirements are poorly known * Expertise in forest management practices is not sufficient (3) Financial instruments * National support instruments for environmental protection are lacking * Application procedure within SAPARD is far too complicated for average non-state forest owners (4) Other significant characteristics * Private holdings are typically small covering less than 1 ha (If less than 1 ha, a FMP is not obligatory) * Willingness of private forest owners to join cooperatives and associations is not self-evident * Non-existing forest estate market * Restitution process is not complete. In particular, municipal ownership may become significant 5.3.2 Coverage and Impacts of the FDP Intervention The FDP aims at strengthening of capacities of private and communal forest owners for sustainable forest management. More specifically, the FDP Component 2 will support establishment of a national interest organization and community based forest owners' associations and financing of private and communal forestry through the SAPARD Program. Other means to contribute to the private and communal forest management include extension and inspection services, information and monitoring systems and biodiversity component of the FDP. The FDP Component 2 focuses on institutional development in the non-state forest sector. In addition, the project will support the preparation of forest management/business plans for municipal and groupings of forest owners based on guidelines to be developed under the project. The FDP is tasked to provide specific support to include biodiversity conservation issues in the forest management plans with GEF incremental funding. Therefore it is assumed that biodiversity management will be taken adequately in account in the implementation of the project. The Special Accession Program for Rural Development (SAPARD) of the EU represents the single largest grant based initiative in Bulgaria for Agriculture and Rural Development including forestry. Within the program, the Measure 1.4 for Forestry, Afforestation of Agricultural Areas, Investment in Forest Holdings, Processing and Marketing of Forestry Products has an overall budget of EUR 59.69 million. The FDP will support (a) a need Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 50 January 28, 2004. assessment of private owners and (b) a review and realignment of the SAPARD Forestry measure targeted at improving its relevance and accessibility to private owners and owner associations. In addition, the project will support, through local consultancy services and extension service of the State Forest Administration, the preparation of SAPARD applications under the Forestry Measure. The FDP will assist the non-state forest owners in accessing the SAPARD funds through providing a proposition for the realignment of the SAPARD Forestry Measure and support in preparation of funding applications, but will not be involved in the actual investment activities in the private forests. If the FDP support to the private forestry sector will be successful and lead to an efficient utilization of the SAPARD financing instrument, a significant amount of forest improvement activities will be carried out on privately owned lands. If properly implemented, these activities (see Chapter 3.2.2.3) will generally have positive environmental impacts. However, with inappropriate implementation the risk of causing adverse impacts is significant. 5.3.3 Suggested Mitigation and Enhancement Measures Taking into account the mandate and financial restrictions of the FDP, it is not realistic to assume that the project is able to solve all the key issues of the non-state forest sector. The Inspection and Extension Service, for instance, is tasked to control the success of forest regeneration, but there are no legal requirements to carry out silvicultural operations or regenerate mature forests. Furthermore, the establishment of forest owners' associations and joining them must be a voluntary action. Hence the environment-related suggestions are confined to the active interventions of the FDP: * While supporting the establishment of forest owners' associations, the FDP needs to ensure that their statutes and functions recognize the importance of sustainable forest management. Consequently, the operational guidelines with focus on environmental control need to be prepared. The association can also adopt guidelines to be prepared by the FDP. * Environmental/occupational health and safety training must be given to the staff of associations. The quality of the training needs to be high enough to make the trained persons capable to disseminate the information to the logging companies and their workers as well as to the actual forest owners. * When selling timber standing, the contract between the seller and the logging company must include provisions for the protection of environment and occupational health and safety. * The forest management plans to be prepared for municipalities and groupings of forest owners must be multi-objective, in compliance with the requirements of sustainable forest management and prepared according standards and methods approved by the World Bank. * When the project supports the preparation of funding applications related to the SAPARD Program, prior to the provision of assistance to municipalities, forest owners' association or private people, the FDP must ensure the environmental sustainability of the individual projects to be supported. It is necessary to develop clear environmental screening criteria to be applied by the local consultants assisting forest owners. In particular, road construction and establishment of fast growing plantations may have significantly negative environmental impacts, if the planning and implementation are not properly carried out (e.g. selection of sites and tree species in the establishment of new plantations). Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 51 January 28, 2004. 5.4 Component 3: Supportin2 State Forest Mana2ement Transition to Market Economy 5.4.1 Key Issues 5.4.1.1 National Forest Company (NFC) The restructuring of the State Forest Administration will be carried out in accordance with Restructuring Law that the Parliament of Bulgaria is expected to adopt by early 2004. The new law shall be consistent with Intemational Best Practices provided by the World Bank. The Bank requirements include, among others, a management board that is independent from political structures, selection of the Director General on the basis of competition, adoption of intemational accounting standards and clear rules for the allocation of profits and potential losses. From the environmental point of view, the key requirements are related to the public good forest management functions, application of sustainable forest management practices and decision-making within the NFC. (1) Sustainable Forest Management * Re-investment of timber sales revenues in regeneration, silviculture and other necessary forest operations * Biodiversity management in production forests, including High Conservation Value Forests * Protection of soil and water * Social services (2) Management of Nature Parks * Administrative position of the nature parks (A part of the stakeholder groups is concemed about the future of nature parks under control of the NFC) * Risks that the NFC favors commercial uses of the forest fund over the public good functions * Biodiversity conservation * Recreational services * Other social services (3) Decision-making within the NFC * Stakeholder participation * Transfer of land use rights or selling of state-owned lands (e.g. at Black Sea Coast) 5.4.1.2 Upgrading of Forest Road Network The key environment-related issues regarding rehabilitation and construction of forest roads include: (1) Forest Resources and Products * Facilitation of efficient use of timber resources and non-wood products, including savings in timber harvesting costs * Improved forest road network decreases pressure on accessible forests * Less damages to standing trees Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 52 January 28, 2004. * Intact roads prolong lifecycles of transport equipment * Improved forest fire control (e.g. due to improved access) * Risks for illegal logging and other unauthorized activities increase (2) Flora and Fauna * New roads may open access to untouched forests with high biodiversity values * Potential temporary or constant fragmentation of forest resources due to new roads (edge effect increases, decreased intact forest blocks) (3) Soil and Water * Construction of new roads may result in landslides and other type of erosion * New roads may changes water flows on slopes (e.g. drying of soil may lead to decreased soil productivity, as indicated by Bulgarian research work) * Rehabilitation of existing roads decreases erosion, siltation, landslides and stagnant water * Less soil damage and siltation due to harvesting operation * New roads may cause silting of watercourses (e.g. deterioration of water biotopes and water abstraction) * Accidents with hazardous materials (contamination of soil and water) (4) Occupational Health and Safety * Dust and noise * Accidents, especially if explosives are used (5) Social Issues * Job opportunities * Improved transportation connections * New roads may affect negatively landscape and cultural values, if not planned properly From the timber production point of view, extraction of timber in Bulgaria is typically cost intensive and causes damages to the remaining stands due to long skidding distances and inappropriate logging technology applied. Additionally, if the road transportation distance exceeds 400-500 m the timber harvesting is not considered any more economically attractive. Thus, the forest road network is essential for an efficient utilization of timber resources. The side effects of enhanced forest road network consist of decreased forest resources, since new roads will occupy land from timber production (an issue raised by participants at the initial stakeholder workshop), and facilitation of illegal logging. The adverse impacts of the first mentioned issue may be limited (the standard profile of forest road is about 5.5-6.0 meter wide and the canopy usually closes at 60 years and beyond) and can be compensated by increased availability of timber resources and reduced harvesting costs. However, unauthorized activities may cause a serious threat to the sustainable use of timber resources. This is a real concern, if new roads will be constructed in remote areas with no permanent settlement or control personnel. The improved forest road network will lead to a drastic reduction of other skidding related environmental damages due long skidding distances i.e. adverse impacts on soil (erosion, compaction, landslides) and water (siltation). Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 53 January 28, 2004. The improved forest road network will also improve access in case of forest fires and reduce damage to transport equipment leading to increased lifecycle of equipment. With regard to the non-wood forest products, the improved road network will facilitate improved utilization opportunities (e.g. picking of mushrooms and herbs). On the other hand, if the utilization of non-wood products is not properly controlled, the new roads can contribute to their over-exploitation. On the one hand, the relatively sparse forest road network (7.9 m/ha) has contributed to protection of biodiversity, landscape values and timber resources from over-exploitation and may have left substantial areas completely untouched. On the other hand, a negative environmental side effect of the inadequate road network, however, seems to be overexploitation of easily accessible forests. The overall impact of new roads on the biodiversity conservation can be negative, if the planning and construction is managed inappropriately. Potential risks for forest biodiversity include disturbance or destruction of individual forest habitats such as "high value conservation forests" or "key biotopes". In particular, access roads (Category 1) are usually located between slopes (valleys) alongside mountainous rivers and creeks with habitats of specialized species. Thus the roads can occupy areas that may contain high biodiversity values. Secondary and strip roads (Category 2 and 3) are more often located on the slopes where the siting can be better designed to avoid environmentally sensitive locations. Road construction may result in increased edge effect and temporary or constant fragmentation of forest vegetation, which can shrink or eliminate large contiguous blocks of forest required by certain species. Regarding the species requiring such forest blocks, the impact on them will essentially depend on the capacity of the protected area network to meet their needs. Unfortunately, a systematic and comprehensive analysis on the capacity of the protected area network to provide for this is lacking. New roads may also directly or indirectly affect migration of certain species. The use of roads for timber procurement may indirectly lead to disappearance or damage of valuable habitats, if the forest operations such as logging or silvicultural treatments neglect biodiversity management. The unauthorized activities may also negatively affect the biodiversity, since the upgraded and new roads may facilitate access to environmentally valuable areas. In particular, the NGOs are concerned about opportunities the new roads bring about for authorized and unauthorized activities. The roads can e.g. facilitate logging of areas that are currently classified as production forests, but are identified to include significant biodiversity values or are in process to be incorporated into a protected area network (e.g. Natura 2000). The rehabilitation and construction of roads inevitably result in mechanical disturbance of soil and impacts on water resources, if they are located in the vicinity of roads. Especially during the construction work, the watercourses are typically silted with soil from embankment slopes and other roading area. Silted water changes the quality of water, may temporarily affect water abstraction of local communities and especially deteriorates living and reproduction conditions of river fish and other species. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 54 January 28, 2004. The basic guidelines related to the occupational health and safety are partly neglected while constructing forest roads. Key areas include safety procedures of blasting work, and use of personal safety equipment. The social impacts of the upgraded forest road network are predominantly positive (e.g. improved transport connection and employment opportunities for local population). Given the current forest ownership structure, the construction of forest access roads (a total of 25-35 km) does not envisage acquisition of land from private forest owners. 5.4.1.3 Thinning of Young and Fire Prone Stands Due to chronic budget shortage, the thinnings have been neglected putting the results of the earlier afforestation efforts at risk. For instance in 2002, approximately 43 500 ha was thinned nationwide. The area makes up only 37% of the thinning needs defined by the forest management plans. The key environment-related issues regarding thinning of young and fire prone stands include: (1) Forest Resources and Products * Improved growing condition for and quality of remaining trees (e.g. vitality of trees and resistance to fungi and pest diseases) * Improved resistance to forest fire, fungi and pests. However, logging residues left on the ground can be a fire load * Damage to standing trees possible due to logging operations (2) Flora and Fauna * Felling of coppice species may decrease biodiversity (3) Soil and Water * Soil damage due to skidding in commercial thinnings (4) Occupational Health and Safety * Noise * Accidents with chain saws (5) Social Issues * Job opportunities Wood production in terms of commercial volume and value is likely to benefit from the conduct of thinnings. Thinnings will also improve the vitality of the remaining growing stock and make it more resistant to diseases. The thinning operations may, however, cause damage to the remaining trees, if not properly carried out. The technology applied and skills of workers are key factors to minimize the logging damages. The thinning activities will be targeted mainly to single tree plantations, which at present hardly are valuable sources for non-wood products or important from the biodiversity point of Environmental Assessment of the Forest Development Project, Bulgaria Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. 55 January 28, 2004. view. However, felling of coppice species may have adverse impacts on the biodiversity, if the guidelines do not suggest mixed stands as an objective (including commercially non- valuable species). Furthermore, the skidding roads and tracks can be potential causes for landslides. It is also worth mentioning as a potential negative impact of pre-commercial thinnings that the logging residues including stemwood left on the ground can be a significant fire load in the forest. In addition, the thinning operations can deteriorate the quality of water, if logging residues are left on the rivers, creeks and other water bodies, as observed during field visits. Thinnings will provide local communities with job opportunities and sources for additional income. 5.4.1.4 Reforestation and Rehabilitation of Destroyed and Devastated Forest Fire Sites Recent forest fires have destroyed large areas of Bulgarian forests, particularly in the South East of the country. In ideal circumstances, natural regeneration of forest fire sites would lead to a tree species composition that is well adapted to the prevailing conditions. However, the natural development process is likely to be unsuccessful and usually takes more time than regeneration speeded up by planting and other silvicultural measures. Due to a relatively long time needed for the recovery of forest vegetation, erosion is likely to cause serious risks for the further development of burnt sites on slopes. In most cases, the forest fire sites would require active measures to ensure timely regeneration and avoid erosion. The economic value of replanted areas is also expected to be higher than that of naturally regenerated sites. The key environment-related issues regarding reforestation and rehabilitation of destroyed and devastated forest fire site include: (1) Forest Resources and Products * Aim is to achieve viable and commercially valuable growing stock * Ameliorated growing conditions for non-wood products (2) Flora and Fauna * Diversified Flora and Fauna (3) Soil and Water * Soil preparation causes mechanical disturbance of soil and risk for erosion * Expansion of forest cover enhances watershed functions * Possible silting of and nutrient increase in watercourse (4) Social Issues * Job opportunities * Stabilization of the environment * Improved landscape values Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 56 January 28, 2004. While planning the rehabilitation activities, it is important to make sure that the composition of tree species is suitable for the soil types and other prevailing conditions. Establishment of a growing stock resistant to pests and fire would require careful planning and utilization of available knowledge of plantation management. Regeneration with local species (suitable mixture of tree species) would improve the quality of these habitats and provide better conditions for species important in terms of non-wood forest products and enhancement of biodiversity. The adverse impacts of rehabilitation on soil might be significant, if the operations are not well planned and implemented. Prior to planting, the soil usually needs to be prepared with mechanical or manual methods. Terraces are constructed, if the regeneration area is located on steep slopes. The potential impacts on water are mainly related to undesirable movements of soil (e.g. landslides) that can cause silting of watercourses. Soil preparation can be a root cause for such incidents. The rehabilitation of burnt areas will diminish risks for erosion in long terms because of the improved vegetation cover. Regeneration/rehabilitation activities will provide local communities with job opportunities and sources for additional income. Increased forest cover will positively affect the living conditions of people through more stabilized environment. The beneficiaries could be e.g. private households, municipalities, agriculture and animal husbandry. 5.4.1.5 Implement Pilot Certification in Selected State Forests The Forest Stewardship Council (FSC) and Program for the Endorsement of Forest Certification schemes (PEFC) are named as potential certification systems to be applied. Prior to initiation of the actual certification process, the current planning, management and monitoring practices need to be modified to be compatible with the Principles and Criteria of the FSC or a national FSC standard. If the PEFC selected, a national PEFC standard have to be developed before the initiation of certification process. The key environment-related issues regarding forest certification include: (1) Environmental Sustainability * Environmental impacts of forest management * Maintenance of High Conservation Value Forests * Compliance with laws and international agreements * Management plans * Monitoring and assessment (2) Economic Sustainability * Benefits from the forests and plantations * Compliance with laws and international agreements * Management plans * Monitoring and assessment Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 57 January 28, 2004. (3) Social Sustainability * Tenure and use rights * Community relations and worker's rights * Compliance with laws and international agreements * Management plans * Monitoring and assessment As the starting point within the forest certification is sustainable forest management, all the environment-related impacts resulting from its application are considered to be significantly positive. 5.4.2 Coverage and Impacts of the FDP Intervention 5.4.2.1 National Forest Company (NFC) & Pilot Certification The FDP will support the institutional set up of the proposed National Forest Company (NFC) - a self-financing organization responsible for management of State owned forests. The project intervention includes recruitment of chief executive and senior management team, human resource development in several fields, and design and implementation of necessary information systems. These are also expected to provide adequate knowledge capacity and technical preparedness for the implementation of sustainable forest management. This sub-component, however, does not directly address the need to further develop operational guidelines for forest management activities. The new NFC will apply the existing regulations, but it is also presumed that the company will adopt e.g. the guidelines to be prepared based on the findings of biodiversity component of the FDP. In addition, the code of best management practice for design and construction of forest roads will supplement the NFC's directions. The pilot certification would also play an important role in the overall development of management practices in the state-owned forests. A full application of the FSC or PEFC scheme will lead to revision needs in the present planning and monitoring systems, and forest management practices. It is considered that the pilot certification will guide the state forestry towards economically, ecologically, socially and culturally sustainable forest management. In particular, forest certification is a tool to ensure the maintenance of biodiversity and other values of nature parks and HCVFs. 5.4.2.2 Upgrading of Forest Road Network The aim of the FDP is to improve the forest road network in order to minimize harvesting damage, reduce operational costs, minimize fire hazard, and relieve pressure from over- exploitation of accessible forests. Acknowledging the threats related to the repair and construction of forest roads, the PPU has developed tools to recognize environmental risks and instruments to control environmental impacts (Table 5.1). Environrental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 5 8 January 28, 2004 Table 5.1 Main Interventions of the PPU in the Rehabilitation and Construction of Forest Roads Intervention Main Impact Areas Remarks Terms of Reference for Forest Identification of road needs and Preparation of the master plan will be Roads Master Plan priority districts. Control of initiated in spring 2004 landscape level and cumulative environmental impacts Outline of Best Management Planning - Identification and control of Practice for Design and environmental risks Construction of Forest Roads Design - Quality of road (based on the anticipated traffic) Location - Minimization of risks to environmental values Construction - Minimization of soil disturbance to the site Drainage - Minimization of impacts on water quality Maintenance - Road surface and drainage works The forest road sub-component foresees the preparation of a national forest road master plan, which would direct future investments and ensure compliance with environmental values. The objective of the master plan is to (i) provide information on the current status and condition of existing roads, (ii) identify future road requirements, (iii) detail a prioritized investment schedule for new road construction and upgrading existing roads for the period 2005-2014, and (iv) prepare a Code of Best Management Practices in relation to the design, construction, reconstruction and maintenance of forest roads, while maintaining ecological values (Annex 10). Within the scope of forest road master plan, the FDP is tasked to develop methodology and criteria for prioritizing roading works by taking into account forest management plans, harvesting methods, economic and cost benefit analysis, non-timber forest products, protection status of forests, areas with high conservation values, fire management requirements and effects of illegal logging. Where necessary, the plan should exclude specific areas from road construction, if deemed necessary for environmental, social and/or economic reasons. It is concluded that the FDP has a great indirect influence on the environmental performance of state forestry through the forest road master plan. The direct impacts of road construction/rehabilitation funded by the WB are minor, because the FDP is financially able to build only 25-35 km of new roads on State or municipal land and repair 125-150 km of existing roads. The initial time schedule for the completion of tasks defined in the terms of reference for forest road master plan is between March/May 2004 and October 2004. Since the priority areas to benefit from the FDP investments in the transportation infrastructure are not yet selected and no regional or site-specific plans are available on the development of forest road network, the actual environmental impacts regarding rehabilitation and construction of forest roads could not be assessed at this stage, but it is expected that the environmental assessment of the forest road master plan, which will be undertaken during the project implementation (see paragraph 5.4.3.2), will ensure that any potential impact will be satisfactorily addressed. The outline of Best Management Practice states that the protection of forest habitats should be a priority when designing, constructing, rehabilitating and maintaining forest roads. The Environniental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 59 January 28, 2004. outline has a special environmental emphasis in the planning phase, when environmentally sensitive locations are identified, road siting in the landscape is determined and basic specifications to protect water quality and environmental values are drawn up. During the construction phase, operational control focuses on the protection of soil and water (onsite and downstream impacts). Even though detailed impact assessments cannot be made at this stage, it is observed that the terms of reference for the forest road master plan including the Code of Best Management Practice for Design and Construction of Forest Roads addresses the key environmental issues related to the upgrading of forest road network making it possible to efficiently control the adverse environmental impacts. In fact, the environmental considerations were one of the main reasons for the introduction of the forest road master plan to the FDP. Wider use of the Code of Best Management Practice will be a significant improvement compared to the present situation. 5.4.2.3 Thinning of Young and Fire Prone Stands The FDP plans to carry out thinning are targeted to young sites, where the trees to be felled have low commercial value. These stands are currently in a development stage, where the quality of growing stock needs to be steered through thinnings in order to ensure high technical quality of remaining trees. The thinning stands also include plantations of pines, which are proved to be highly prone to forest fires due to the prevailing site conditions (e.g. dry soil types, low altitudes and exposure to sun). If thinnings were not carried out, the risk for forest fires would also be greater. Compared to without project scenario (less thinnings), it can be concluded that the approximately 10 000 ha of thinnings planned to be financed by the FDP contributes favorably to overall economic, ecological and social development. The FDP funds will be used for salaries of workers and purchase of equipment needed in logging. Criteria for the selection of stands were agreed at a thinning workshop held for stakeholders and exclude areas in protected or high conservation value areas. Priority will be given to stands (a) specified for thinning in forest management plans, (b) with roading access, and (c) proximity to markets. So far, The FDP has technological plans to carry out thinnings in seven regions as follows: - Kardjali 360.0 ha - Blagoevgrad 457.9 ha - Bourgas 416.0 ha - Shumen 338.0 ha - Strara Zagora 362.0 ha - Lovech 176.0 ha - Kustendil 255.1 ha - Total 2 365.0 ha The stands to be treated vary according to the age (1-30 years), dominant tree species (beeches, oaks, pines etc.) and measure to be carried out (re-spacing, cleaning, thinning in groups, etc.). As the FDP has main focus on pre-commercial thinnings with no off-road skidding of timber, they are likely to cause less damage to the growing stock and soil than commercial thinnings. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 60 January 28, 2004. 5.4.2.4 Reforestation and Rehabilitation of Destroyed and Devastated Forest Fire Sites The FDP is tasked to support the investments needed in the implementation of the National Strategy for Forest Fire Management (ref. Chapter 4.7.3). The concrete operations in the forest fund deal with thinning of fire prone stands and regeneration and rehabilitation of forest fire sites. The FDP finances salaries of workers, cleaning of sites, soil preparation and purchase and planting of saplings. The FDP will fund reforestation of approximately 600 ha in the project years one and two. A combination of economic, ecological and social criteria were developed and agreed as the basis for site selection. The criteria contain, inter alia, following elements: - economic - high productivity sites, low establishment costs - environmental - erosion control, susceptibility to fire, soil improvement - social - creation of employment, landscape, recreation, non timber forest products A scoring system that is included in the evaluation system, however, was not applied, as it was not considered pragmatic (Mitchell, pers. comm.). At present, the FDP has detailed plans for reforestation and rehabilitation of 399 ha in three regions: - Bourgas 124.0 ha - Kardjali 124.3 ha - Sliven 150.7 ha A total number of 41 sites (sub-compartments) is included in the work program of project year one. Technological plans containing basic information and maps on the sites, proposed soil preparation methods and tree species to be used are available for the implementation of regeneration activities. The working methods to be applied are based on the existing Bulgarian systems, including control of environmental impacts. If the operational guidelines are followed, the outcome meets the basic environmental requirements except possible concerns related to the selection of tree species 5.4.3 Suggested Mitigation and Enhancement Measures 5.4.3.1 National Forest Company (NFC) The environmental concerns associated with the NFC relate to practice-level implementation of the principles on sustainable forest management and management of nature parks. In order to ensure that the public good functions of the state forest fund are respected, it is recommended that the NFC shall operate under a charter approved by the Government and acceptable to the World Bank. The charter shall define, inter alia, the membership and functions of its boards, public participation in its meetings, use of revenues generated from the sale of forest goods and financing of the management of nature parks. The mitigation measures related to the management of biodiversity and protection of soil and water are addressed in the Component 4: Promotion of Biodiversity Conservation in Forest Management. Regarding NFC's management structure, it is recommended that for improved transparency NGOs will also be given seats in its board. For instance in Estonia and Latvia, NGOs have been represented in the boards of similar state-owned forest companies. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 61 January 28, 2004. In order to avoid speculation with state-owned land (e.g. at coast of Black Sea), it is recommended that appropriate procedures are prepared to control acquisition and sales of forest assets to maintain integrity of forests, and transfer of land use rights in a manner that would not negatively affect environment. In line with the draft Restructuring Law, it is here expected that the NFC will be entitled to manage the state-owned forests but not get a full ownership to them. Consequently, the risk of speculation may relate to lease of land use rights rather than land sales. 5.4.3.2 Upgrading of Forest Road Network Well-designed environmental guidelines for road construction are available in draft form, and the projected increase in investment funds will create a favorable opportunity for their application. The terms of reference for the forest road master plan and outline of best management practice for design and construction of forest road will provide adequate tools for road construction experts. They cover a wide range of issues related to road construction technology and control of environmental and social implications. The ultimate impact, however, will depend on how well the guidelines are followed in practice. In general the proposed mitigation measures are considered adequate, even though some minor adjustments are proposed. More attention should be paid to few subjects listed below, even though they are partially addressed in the draft guidelines and other material of the FDP: * Until comprehensive information on Bulgarian High Conservation Value Forests (HCVF) is available for forest managers, construction of new roads suggested by the forest road master plan should focus on plantations and forest fire sites currently with no access. If new roads are proposed in natural forest areas, the WWF Toolkit for Identification of HCVF or available information of identified HCVF must to be utilized in the preparation of the forest road master plan. Furthermore, the master plan must make good use of material related to Corine biotopes and Natura 2000. Since the basic identification of Bulgarian HCVFs is still underway, it is recommended that the priority in the first years is given to areas with no disputes in terms of biodiversity values. * While planning roads, full access to databases on protected areas, HCVFs and other environment-related geographic information must be given to persons responsible for preparation of forest road master plan and construction of individual roads. * The siting of roads must include field surveys with respect to identification of small-sized key habitats, protection of watercourses (e.g. rivers and creeks), landscape values and cultural property. * The FDP must require that relevant national and international regulations related to occupational health and safety are applied to road construction work. In particular, all necessary safety measures shall be respected while carrying out blasting. * In the context of precautionary approach, it is recommended that a strategic environmental assessment process is applied to the preparation of forest road master plan and an environmental impact assessment process is applied to first 2-3 roads to be constructed. Thereafter, the FDP is considered to be fully competent to judge the need for continuation of such assessment process. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 62 January 28, 2004. 5.4.3.3 Thinning of Young and Fire Prone Stands & Rehabilitation of Destroyed and Devastated Forest Fires Sites The forest management plans and other data sources of the NFB seem to provide adequate information on forest sites that are in need of rehabilitation and thinnings. The forest fire and thinning sites currently included in the work plan are all appropriate objects for the FDP financing. However, the selection of tree species needs to be justified: * Pines (e.g. Pinus nigra) are not recommended to low altitudes (less than 400 m from the sea level), where local broad-leaved (e.g. Quercus spp.) species and mixed stands should be favored. At higher altitudes, mixed broad-leaved (e.g. Fagus spp.) and coniferous stands are more acceptable. If single tree species plantations of conifers or broad-leaved species need to be established, documented measures should be taken to prevent forest fires and diseases. * While carrying out thinnings, it is recommended that the FDP ensures that the operations aim at diversified tree species composition, and take protection of soil, water and biodiversity properly into account. * In addition, the FDP should require that forest workers, contractors or independent companies follow occupational health and safety regulations stipulated by the Bulgarian legislation and the World Bank. The local level staff of the NFC should control their implementation in the rehabilitation and thinning operations. 5.5 Component 4: Promotion of Biodiversity Conservation in Forest Management 5.5.1 Key Issues 5.5.1.1 Biodiversity Conservation Environment-related issues regarding the promotion of biodiversity conservation in forest management were reviewed in two stages; first on a general level and then through a more detailed Environmental Assessment. Furthermore, note was taken of the main concems brought up during the first two stakeholder consultations, namely: (i) the low efficiency of the nature park administration, (ii) the insufficient emphasis on the protection of high conservation value forests, and (iii) the lack of mechanism for the reservation of forested areas for a future national ecological network. The main message from those consultations was that the FDP should make greater efforts to address these concerns. The general level assessment of broad biodiversity conservation issues focused on two key aspects, namely the biodiversity conservation with a view to its mainstreaming in forest management planning, and its integration in forest management. The third key issue, strengthening of the system of protected areas under the National Forest Company, lends itself to a critical analysis of the new management structures proposed for the Nature Parks, and their influence on the sustainable forest management in the parks. The Company is likely to have little interest in such non-revenue generating functions as environmentally oriented forest management of Nature Parks. Such concern is valid especially with a view to a scenario in which the company would meet economical difficulties, e.g., during a possible economic recession period. Under the selected model, the company is expected to pay the environmental management cost from its own resources, and it may try to minimize the cost or reduce investments in activities vital for the sustainability of Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INIDUFOR. 63 January 28, 2004. forest management in Nature Parks. On the other hand, if the company should be able to generate enough of operational surplus, it would be able to provide the resources needed for the management of environmental functions. In a more detailed assessment, and as expected, the key environment-related issues of biodiversity conservation were found to include mainly positive elements: (1) Non-wood forest products (NWFP) and services * Increased exploitation of NWFP, depending on the access regulations. * Increased supply of NWFP; increased potential for hunting, fishing, and access to berries, fruits, mushrooms, etc. (2) Natural habitats * Increasing diversity at ecosystem, species/population and genetic levels. * Networking of protected areas potentially provides ecological corridors and stepping stones for migratory species. (3) Soil * Steadily increasing stability, decrease of soil erosion. * Steadily improving nutrient balance. (4) Water * Local quality improvement. (5) Occupational health and safety * Injuries are possible due to inappropriate techniques or safety equipment. (6) Social issues * Positive impacts to employment, local economy and living conditions through strengthened coordination and partnerships with regional and local stakeholders (land-owners, land-users, local communities). * Increase in tourism. * Decrease in the loss from natural disasters * Positive impacts to landscape through the preservation of critical habitats. (7) Other issues * Illegal logging, grazing and forest fires hamper the integration of biodiversity conservation in forest management planning. * In general, the monitoring of changes in forest resources suffers from inadequate information and monitoring system capacities. Consequently, the environmental aspects of such monitoring are weak. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 64 January 28, 2004. 5.5.1.2 Carbon Sequestration Carbon targeted afforestation in line with Joint Implementation Mechanism (JI), and related and emerging modalities such as Land Use, Land-Use Change and Forestry Projects (LULUCF) provides attractive opportunities to support sustainable forest management in Bulgaria. The afforestation (or reforestation) options include (i) reforestation of burned and degraded sites, (ii) energy-plantations on agricultural areas, (iii) conversion of coppice forest to high forest (iv) set-aside of marginal agricultural land for natural regeneration or afforestation, and (v) conservation of natural forests. The key environment-related issues regarding establishment of energy plantations, which is an option in the Fuel Switch Pilot Project, include: (1) Forest Resources and Products * Increased forest vegetation cover * Growing fuelwood supply * Risks for outbreak of pest and fungi diseases (2) Flora and Fauna * Establishment of plantations may destroy valuable habitats, if site selection fails * Energy plantations are typically mono-cultural formations (3) Soil and Water * Mechanical disturbance of soil due to soil preparation; new forest cover prevents erosion * Depletion of nutrients because of full tree harvesting * Improved watersheds (4) Air * Carbon sequestration (however, no permanent carbon sinks) (5) Occupational Health and Safety * Accidents possible (e.g. soil preparation, planting and harvesting) (6) Social Issues * Job opportunities (e.g. establishment of plantations, fuelwood supply) * May affect negatively landscape and cultural values Afforestation increases forest cover and plantations serve as a carbon sink contributing to abatement against global warming. The potential adverse impacts of plantation establishment are related to decreased biodiversity, especially if planting takes place in areas with valuable habitats. The fuel wood plantations as such represent low biodiversity, as they are typically composed of one tree species (e.g. Robinia and poplars). Outbreaks of pests and fungi have caused massive defoliation in the Bulgarian plantation forests. They are likely to be a risk in fuel wood plantations as well. Furthermore, short rotations and efficient utilization of biomass grown in the energy plantations will contribute to depletion of nutrients from the soil. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 65 January 28, 2004. 5.5.1.3 Emission Reduction Replacement of fossil fuels with biofuels provides emission reductions that can be subject to sales of carbon credits. The biofuels supply of possible fuel-switch installations considered within the FDP will be mainly based on thinnings, thinning residues and by-products from woodworking industry. With the present prices of energy, the use of biofuels would also result in savings in energy costs. The key environment-related issues regarding fuel switch projects (comparison of changes to be achieved through the switch of energy sources at heating plants and in fuelwood supply) include (1) Natural Resources and Products * Non-renewable fuel oils are replaced by renewable biofuels (however, fossils as auxiliary fuels may be needed) * Intensified thinnings improve the quality of growing stock * Risks for overexploitation or inappropriate use of forest resources and illegal logging, if the demand and supply of fuelwood are not in balance. (2) Soil and Water * Contamination of soil, which a typical problem at heat plants using fossil fuels, decreases due to fuel switch * Less leaks from oil containers, which decreases risks for pollution of soil and water resources * Soil and water damages in the forest are possible due to fuelwood harvesting * Removal of tree tops, branches and residues may deteriorate nutrient balance of soil (3) Air * Stack emissions (no additional greenhouse gases considered, if biofuels are used) * Cleaning of atmosphere (natural decomposition of thinning residues and wastes of woodworking industry is replaced by heat production based on fuel switch) (4) Waste Management * Disposal of hazardous wastes (e.g. ash, soot, waste oils) * Improved recycling of wood wastes at sawmills and other woodworking factories (5) Occupational Health and Safety * Workplace air quality and noise * Accidents possible (e.g. fires) (6) Social Issues * Job opportunities * Improved local economy * More reliable and cheaper energy supply * May affect negatively availability of fuelwood for local people * Accidents (e.g. fires) Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 66 January 28, 2004. The heating systems to be replaced are typically old-fashioned equipment with low energy efficiency and high frequency of shutdowns. With regard to the fuel consumption, the environmental advantages of new heating systems come from (i) use of RES, and (ii) improved efficiency in the heat production. The fuel consumption of an installation depends on quality of fuels (e.g. density and moisture) and output of boilers (MW). In order to avoid adverse environmental and social impacts, the design of heat plant has to be in balance with availability of biofuels. The significant impacts of existing and new heating facilities on soil and water are related to abnormal conditions (e.g. leaks, accidents and emergency situations). The normal production conditions do not significantly affect the quality of soil and water. However, it is worth mentioning that sites of central heating plants based on fossil fuels are often contaminated by oil and other hazardous substances. The stack emissions to air are the main environmental impact of energy generation in the normal production conditions. A boiler based on the RES also emits greenhouse gases, including e.g. CO2, NO,, SOx and particulate matters, but is not considered to increase their total amount in the atmosphere (without the use of auxiliary fuels). Heat plants generate hazardous wastes, of which ash, soot and other burning rejects and waste oils are the most significant ones. The waste management related to hazardous materials always needs special instructions and disposal practices. This is also important from the occupational health and safety point of view. Local communities are expected to benefit from a new heating facility through the use of local fuels and new income sources that are generated by the supply of biofuels. It is also expected that wood fuels would provide reduced heat costs. If savings in heat production will be achieved, this would allow the local government to reallocate its financial resources for other public purposes. However, new heating plants may decrease the availability of fuelwood currently used by local communities. Broadleaved species are preferred over conifers as domestic fuelwood because of their higher calorific values, but conifers, which are projected to be the main fuel of the planned heat plants due to the existing supply potential, are also used for heating purposes by private households. The heat plants are in any case able to pay more than private people for fuelwood of broadleaved or coniferous species, which is likely to affect fuelwood supply to local communities. A high demand for fuelwood may also contribute to unsustainable forest harvesting (e.g. illegal logging and exceeding of allowable cut). The scale of undesirable consequences depends on how large the gap between supply and demand of local fuelwood is. A modest increase in demand for fuelwood causes competition and possibly more illegal logging of stands of all ages. A significant increase may lead to a substantial exceeding of allowable cut and unsustainable harvesting on a large scale. Industrial residues are one option to complement the fuelwood supply to the planned heat plants. This argument is justified, since there is insufficient industrial demand for bark, sawdust, wood chips and other residual materials of the Bulgarian wood processing industry (e.g. sawmills, wood panel producers and furniture industry). Their supply for heat production would provide an opportunity to re-use this valuable raw material. However, the current consumers or beneficiaries of these industrial residues can experience reduced supply of raw materials or domestic fuelwood if wood flows are diverted to the heat plant. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 67 January 28, 2004. 5.5.2 Coverage and Impacts of the FDP Intervention 5.5.2.1 Biodiversity Conservation The GEF-funded component of the FDP will strengthen conservation of the forest biodiversity in Bulgaria and ensure the sustainable management of biological resources in forested areas of the most significant conservation importance. It comprises a sub-component, which will help enhance carbon benefits from the Bulgarian forests. Mainstreaming Biodiversity Conservation in Forest Management, and Integration of Biodiversity Conservation in Forest Management Operations With a view to the production forests, the FDP is taking steps to mainstream biodiversity conservation in forest management planning and integrate biodiversity conservation in forest management. Since biodiversity conservation is one of the key elements of multifunctional sustainable forest management, its mainstreaming in forest management lends itself as a crosscutting issue in all project components. The project would, e.g., identify boundaries of high conservation value forests, plan for the protection and restoration of these areas, develop guidelines and tools for integrating biodiversity conservation into forest management, recommend amendments to the forest management legislation and NFC statutes to take account of biodiversity and landscape conservation, and prepare Nature Park management plans. The project would also strengthen the participation, knowledge and capacity of those involved in the forest management at the national, regional, and local levels to undertake conservation activities and integrate them into regular forest management operations. Strengthening the System of Protected Areas under the National Forest Company As a main intervention, the GEF component would strengthen the national system of protected areas and protection forests. Focus is given to the improvement of planning of nature parks and strengthening their capacity to preserve critical habitats, prevent fires, as well as undertake biodiversity monitoring and infrastructure development. This would include support to equipment for improving the effectiveness of the Nature Parks, assessment of the Nature Parks' management effectiveness, development of a biodiversity management information system within the NFC, park conservation programs, as well as priority investments (visitors' centers, trails, equipment) to improve biodiversity conservation, sustainable management and long-term income generation in Nature Parks. The proposed Endowment Fund means counterpart funding for an endowment element in a Protected Areas Fund that would provide long-term revenue to complement direct budgetary support for protected areas, including Forest Nature Parks. Hence, the GEF component of the FDP has addressed essential needs for biodiversity conservation and forest protection, and the component is likely to achieve a range of positive environmental and social impacts. Measures have also been designed to enhance the positive outcomes and to include mitigation measures for possible adverse or negative impacts. The project will have overall positive environmental impacts through (i) the improved management of nature parks, (ii) the conservation of globally and nationally significant biodiversity in protection forests of the project area, (iii) the improved management of forests resulting in greater habitat diversity, and (iv) the reduction of existing pressures on forests. In the "no-project alternative", the pressures on forests would be expected to increase. The Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DUFOR. 68 January 28. 2004. primary major impacts have the potential to be cumulatively significant. With a view to actions proposed by the FDP, terms of reference were drawn up for two studies of particular relevance: (i) develop guidelines and tools for integrating biodiversity conservation in forest management planning, with a focus on production forests outside the protected areas, and (ii) support integration of biodiversity conservation in specific forest management planning activities, with a focus on non-wood forest products and eco-tourism. No significant environmental impacts are envisaged. There would be no major construction in or through critical ecosystems. As is normal with protected area management planning, an assessment of land use and vegetation would be carried out identifying critical ecosystems, and a management plan would be prepared (with local people) whose objective would be to ensure that critical ecosystems are protected while ensuring that peoples' livelihoods are also sustained. Construction, if any, would be limited to very minor civil works, requiring normal mitigation measures. There would be no conversion of critical natural habitats. The purpose of the management plan would be to preserve these and to permnit recovery of threatened ecosystems. 5.5.2.2 Carbon Sequestration and Emission Reduction The FDP will support the Bulgarian forest administration in building Joint Implementation (JI) Capacity and in project pipeline for forestry and wood energy, i.e., the implementation of the Fuel Switch Pilot Project (FSPP) to be financed through the Policy and Human Resources Development (PHRD) Trust Fund for Climate Change Initiatives. The FSPP includes feasibility studies for: - construction of two municipal pilot facilities (installation of heating systems including buildings and other facilities) to produce energy from RES, and organizing biofuels supply to the pilot facilities (e.g. from thinnings, energy plantations and residues from woodworking industry) - preparation of Baseline Study (to calculate the potential emission reductions and carbon sequestration under the fuel switch proposal, including "leakage") - preparation of Monitoring Plan (in compliance with the Baseline Study, a surveillance of the fuel switch project's performance with the help of indicators) - preparation of emission reduction and sequestration study - drafting carbon study concept note for Prototype Carbon Fund / BioCarbon Fund The FSPP preparation has reached a stage, in which the PPU has signed the contract with a consulting company to prepare the feasibility studies on the implementation of the fuel switch grant. Based on the findings of the FSPP, the FDP would finance three feasibility studies and the conversion of current fossil fuel burning boilers to biomass fired units in three pilot areas. The Feasibility studies analyze the availability of fuelwood for the optional locations of heat plants. It is expected that the existing forests (thinnings) and residues from woodworking industry are the priority sources for biofuels supply. Energy plantations with fast growing species will be established only where absolutely necessary. If new energy plantations are needed, the project is prepared to finance 60 ha for each pilot heating facility (total 120 ha). Criteria specified by the JI mechanism, and related and emerging modalities will be applied to the selection of sites for energy plantations. The PPU has also discussed that the fuels of Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 69 January 28, 2004. trucks, chippers and other equipment to be employed for the wood supply system must be unleaded to minimize the adverse impacts of exhaustive gases to air. In addition to the assessment of reductions in emissions and sequestration of carbon, the Baseline Studies and the Monitoring Plans shall provide information on environmental and social impacts of the fuel switch projects. The mitigation of adverse environmental and social impacts is required to be a built-in element of the FSPP and FDP provided that they are carried out according to requirements of JI Mechanism. The draft location identification report presents the following priority list for installation of boilers based on the technical parameters of the buildings, preliminary cost estimates and available funds: 1. Ardino, secondary school Vassil Levski, expected capacity of 600 kW and fuelwood consumption of 1 200 m3/year 2. Teteven, secondary school George Benkovsky, expected capacity of 300 kW and fuelwood consumption of 550 m3/year 3. Ardino, hospital and elementary school Hristo Botev, expected capacity 600 kW and fuelwood consumption of 1 200 m3/year The draft report states that the fuelwood needs can be supplied from thinnings in a sustainable manner both in Ardino and Teteven. In Ardino, the total cuttings currently account for about 13 000 m3, which is less than half of the allowable cut. The additional supply coming from thinnings is likely to be small dimension industrial timber for which there is currently no demand. Even though the additional amount needed is rather limited and its impact on the overall supply situation may therefore be restricted, it would be necessary to have a more elaborate analysis on two issues: (i)fuelwood price dynamics following the establishment of a heating plant; While small dimensioned timber from thinnings can be used as fuelwood, it may have a higher market price than the present supply (e.g. extraction costs could be higher, because it is likely that the present supply has come from the cheapest available sources). Competition could raise the overall price level and result in an increased energy cost for the local population or higher pressure for illegal logging. Also, a strengthening industrial demand for small dimensioned timber could have a similar effect by reducing the availability of fuelwood. It appears that even today small dimensioned industrial timber is used as fuelwood (the current production of fuelwood exceeds the fuelwood projections of forest management programs). Stronger demand is unlikely to develop in the short term but the situation can change in the medium term. (ii) physical availability of the resource; while the unused cutting potential may exist, it is unclear whether it is at present physically accessible, . In Teteven, the lack of a municipal forest management plan and forest inventory information makes it difficult to assess the future supply of fuelwood. Anyhow, the availability of wood processing residues in large quantities (about 6 000-7 000 m3) would provide an adequate fuelwood basis for the proposed heating facility. Currently, there is no alternative use for this resource and using it to supply the heating plant would probably leave the fuelwood market unaffected. In all likelihood, project implementation will have significant positive environmental impacts, which are mainly related to emission reduction from energy production, upgraded silvicultural conditions of forests within the catchment areas for biofuels, new use forms for residues from woodworking industry and improved employment. Negative impacts may occur, if increased Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 70 January 28, 2004. use of biomass for heating purposes diminishes availability of ffielwood for local communities. Energy plantations consisting of one tree species (e.g. Robinia pseudoacacia or poplars) are susceptible to pest and fuingi diseases and forest fires. 5.5.3 Suggested Mitigation and Enhancement Measures 5.5.3.1 Biodiversity Conservation The concept of sustainable forest management (SFM) underlies the FDP, giving equal value to the protection and production fuinctions of forests. Human use of protection forests is regulated, and varies from strict protection to low-impact forest operations. Production forests, while predominantly managed for economic production of wood and non-wood forest products and services, are also subject to ecological considerations and constraints. The focus is on long-term benefits and sustainability. An ecosystems approach is integral to SFM, and the conservation and sustainable use of biodiversity should be addressed at landscape/habitat, species/population and genetic levels. The SFM principles are also reflected in the concept of multifunctional forestry for which the EU has developed standards and guidelines, which Bulgaria is increasingly taking into account (NFPS, 2003). Although the FDP basically has a correct and appropriate focus in the GEF component, and the related environmental impacts are likely to be overwhelmingly positive, the EA has identified the need for following complementary measures and their suggested mitigation measures: * Mainstreaming of biodiversity conservation in forest management planning should be more highlighted and reflected as a crosscutting issue in all forest related activities. While accomplishing such mainstreaming, the FDP should, e.g., focus more on collaborative local partnerships, as well as substantive training and extension programs. * The integration of biodiversity conservation in forest management should be ensured through its incorporation in those forest management plans that fall in the scope of FDP. Where production forestry is deemed compatible with biodiversity conservation, this should be clearly reflected in the forest management plans. * While general capacity building is addressed under the PHARE Twinning program in 2004 and the subsequent years, it should be reflected under biodiversity component as well. The FDP should, e.g., further build and strengthen the local level management's capacity for integrating biodiversity conservation in the management of production forests. * Restructuring of the NFB according to Model II implies that the Nature Parks report to the new National Forest Company. A main concern is that the company will not have enough interest in non-revenue generating functions such as management of Nature Parks, in particular during difficult economic situations. Model II suggests that the enterprise pays the environmental management cost from its own resources, and owing to its commercial orientation the enterprise may have an incentive to try to minimize the cost. A related concern is the nomination of the directorates for management and maintenance of nature parks. In order to mitigate the risk described above, the following combination of measures is proposed: (i) the mapping of High Conservation Value Forests; (ii) specific park management plans; (iii) specific contractual arrangements between the State Forest Administration and the National Forest Company stipulating financial compensations for activities going beyond the normal sustainable forest management; and (iv) appropriate Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 71 January 28. 2004. legal provisions, including the environmentally oriented forest management obligations incorporated into the statutes of the state forest enterprise. The nomination of park directorates should also reflect this obligation. * In the cases where the Nature Parks' and Regional Forestry Boards' land areas overlap, the park management plan has the priority over the forest management plan. This regulation should be confirmed and even strengthened in the statutes of the new state forest enterprise. * The background study made on the GIS architecture for biodiversity data management in the forestry sector should be used as a basis for the strengthening of the monitoring of changes in forest resources in general and changes in the environmental parameters in particular. 5.5.3.2 Carbon Sequestration and Emission Reduction While the project is likely to have mostly positive impacts, some negative implications may also emerge and have to be safeguarded against. The critical issues include the following: * Increased use of biomass for heating purposes may diminish availability of fuelwood for local communities. Therefore, the influence of fuel switch installation on the wood supply to local communities must be carefully studied, and detailed plans have to be prepared to mitigate negative impacts. The feasibility studies on the implementation of the fuel switch grant must include fuelwood supply and demand analyses within the heat plants' catchment areas for fuels to ensure that the impact on local population can be identified and appropriate mitigation measures can be implemented as necessary. Since energy plantations are often monocultures, the project should take potential attacks of pests and fungi and risks for fire into account, and prepare a Pest Management Plan for their management during project implementation, parallel to the identification of afforestation JI projects. Such a plan should (i) consider various alternative designs of plantations to minimize the said risks, and (ii) propose relevant mitigation measures with a view to pest and fungi outbreaks. The criteria for pesticide selection and use based upon the World Health Organization's Recommended Classification of Pesticides by Hazard and Guidelines for Classification (Geneva: WHO, 1994-1995) are included in the World Bank's Operational Policy 4.09 on Pest Management. Furthermore, needs for using fertilizers should be evaluated to ensure high productive supply of biofuels. In all, the FDP is recommended to actively utilize the forestry-related JI-measures in the project implementation. Bulgaria has, outside the forest fund, an abundance of land affected by erosion and watershed problems. These areas would greatly benefit from afforestation and simultaneously the project would create employment. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 72 January 28, 2004. 5.6 Overview of Significance Analysis and Cumulative Impacts The overall cumulative environmental impact of the FDP is evaluated to be distinctly positive. Key environmental issues are well recognized and addressed in the preparatory phase of the project, and mitigation measures are already initiated regarding significantly adverse impacts (e.g. an outline for best practice in forest road construction). Furthermore, implementation of sustainable forest management is one of the main objectives underlying the planned administrative reform of the Bulgarian forest sector. Administrative and institutional development both in the public and private sector is emphasized in the FDP. This approach would create a sound basis for an improved control over the present adversities such as illegal logging, corruption, risks related to biodiversity conservation and inadequate silvicultural measures in the Bulgarian forestry. Consequently, direct physical investments of the FDP in the forest management are rather limited focusing on reforestation of forest fire sites, thinnings and upgrading of forest road network. However, they make an important contribution to sustainable forest management by demonstrating environmentally friendly approaches to forest investments both for the new NFC and non- state forest owners. Training of forest professionals, extension to private and communal forest owners, improvements in information systems, preparation of forest management guidelines and forest road master plan and intensified monitoring will also enhance the positive effects of the administrative and institutional changes that the FDP is tasked to support and implement. The main environmental concerns of the FDP relate to sustainable management of production forests and nature parks in charge of a profit-making company. The preparation of a nationwide forest road master plan and construction of new roads have also raised concerns, in particular among the NGOs community. The combination of a for-profit national forest company and the plan to expand the forest road network is considered to involve substantial environmental risks. Table 5.2 summarizes the environmental impacts of the FDP intervention compared to the present practice (without project scenario). The table includes significant environmental risks related to abnormal operational conditions (e.g. ignorance of regulations and operational guidelines, accident, uncontrolled activities such as illegal logging or forest fires). The significance of such risks is given in parenthesis in Table 5.2. Present impacts of relevant forest management activities including heat generation are assessed in Annex 9. The environmental impacts of institutional changes are of indirect nature so the assessment result may contain uncertainties. However, if the principles of sustainable development are respected, in most cases the outcome is likely to be positive in terms of environmental performance. With reference to the NFC, the environmental risks in Table 5.2 refer to possible over-exploitation of forest resources including the nature parks under economic pressures. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 73 January 28, 2004. Table 5.2 Significance Analysis of Environmental Impacts of the FDP Compared to the Current Practice Component of FDP Imacpat Area Forest Flora and Soil Water Air OHS Social issues Others resources / Fauna products l Component I - State Forest Administration + + + + + + ++ Forest Fire Management System ++ ++ + + + _ _ _++ - Information and Monitoring Systems + + + + + + + + -Surveillance oni Illegal Logging ++ ++ + + + + ++ -Certification Statndard + + + + + + + + - Support for Professional Techinical Schools 0 0 0 0 0 0 0 O Component 2 - BAFO o o ] o o o ] O -Support to Local Forest Ownters Associations + + + + + + + + - Realignment of SAPARD and Support + + + + + + + + Component 3 - National Forest Comnpany (NFC) + + + + + + + + - Upgradingforest Road Network ++ (--) - r +1 - +- ( ) + ( + (-- -( - Thinnings ++ +(-) +(-) +(-) + ( ++ - Reforestation and Rehabilitation of Forest Fire ++ + ++ (-) ++ (-) + (- Sites - Pilot Certification ++ ++ ++ ++ + ++ ++ ++ Component 4 - Mainstreanming ofBiodiversity Conservation ++ ++ + + + + + + - Strengthening of Biodiversity Conservation in + ++ + + + + + + (-) forest Management l l_l___l _ l__ - Strengthening of Nature Parks + ++ + + + + + + - Endowment Fund + + + + + + + + - Program Coordination and Management 0 0 0 0 0 0 0 0 - Joint Implementation Capacity Enhancement | +- I + ( | ++ + + + - Fuel Switch Pilot Project ++ + + ++ + + - + Component 5 Project Management 0 0 0 0 0 0 0 0 -Project Monitoring 0 0 0 0 0 0 0 0 + positive, ++ significantly positive, - negative, -- significantly negative, ()risks related to abnormal conditions, 0 no actual impacts Environmental Assessmient of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. 74 Upgrading of forest road network is foreseen to have both positive and negative environmental impacts. Rehabilitation of existing roads is expected to have a predominantly positive impact since the use of guidelines and safeguards developed under the FDP will improve the environmental situation compared to present practice. The construction of new roads will have a number of positive environmental effects (e.g. reduced skidding distance and associated damage, reduced risk of overexploiting accessible areas), but the effects on biodiversity tend to be negative. However, these effects can be controlled and kept within reasonable limits using appropriate mitigation measures. The direct impact of the FDP will be minor because only 125-150 km of existing roads will be rehabilitated and the construction of new roads will be limited to 25-30 km. The forest road master plan will have a broader effect, but it cannot be evaluated until a draft plan is available. However, if appropriate safeguards are implemented during its formulation and implementation, these impacts are likely to be similar to those of road rehabilitation and construction under the FDP albeit on a larger scale. As a commercially-oriented organization, the NFC will have an interest to expand the accessible forest area through expansion of forest road network. The NFC is a key player in the sector and will have the majority forest land under its management. This implies also that the way in which the Company manages its forests determines to a large extent the quality of environmental management in the Bulgarian forest sector. However, the proposed control measures are considered adequate to contain the potential risks. The NFC performance will be monitored through the regular monitoring and enforcement system established under forest administration. In addition, the proposal made by the EA team to have the NFC operated under a charter approved by the Government and acceptable to the Bank will enable strong guidance of its activities including environmental management. The National Forest Policy and Strategy (NFPS) has provided the strategic framework for the preparation of the FDP. There are also other activities implemented within the NFPS framework and as they are complementary to the FDP it is expected that substantial synergy benefits will be captured.. Among these activities, the SAPARD Program and EU PHARE Twinning have the most direct links with the FDP. There will also be a close co-operation with projects working on the identification of High Conservation Value Forests (HCVF) and establishment of Natura 2000 network. The concerns regarding environmental sustainability of the FDP are justified because with inappropriate implementation the risk of negative impacts would be substantial. However, the FDP includes a number of measures mitigate the negative effects, and if properly implemented, the harmful impacts can be avoided or at least kept within reasonable limits. Still, the complementary measures proposed by the EA team should be considered to ensure full environmental sustainability (see Chapters 5.2-5.5). 6. PROJECT ALTERNATIVES 6.1 The "FDP Alternative" The concept of the FDP was developed through a participatory process in Bulgaria. As a prerequisite for the FDP implementation, the National Forest Policy and Strategy was developed and adopted. Furthermore, the restructuring options of the national forest administration were developed and the restructuring model decided upon as first steps of the project preparation. The strategic choices of the development of the forest sector of Bulgaria Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 75 January 28. 2004. were made during the NFPS development. The FDP is based on those strategies, and its overall aim is to increase the contribution of forests to the national economy and maximize the opportunities and benefits to the rural population through reformulated and sustainable management of private, communal, and state forests of Bulgaria. Since the principles of sustainable forest management underlie the FDP, the protection and production functions of forests receive equal value. The management interventions of protection forests are regulated, and vary from strict protection to low-impact forest operations. Production forests, while predominantly managed for economic production of wood and non-wood forest products and services, are also subject to ecological considerations and constraints. The focus is in long-term benefits and sustainability. An ecosystems approach is integral to SFM, and the conservation and sustainable use of biodiversity has to be addressed at landscape, habitat, species and genetic levels. While adopting the goal of sustainable forest management, the "FDP alternative" incorporates an internationally adopted approach to environment protection in forest management, so as to ensure long-term sustainable benefits from multifunctional forestry. This can be seen as one of its major contributions and a main merit as compared to other altematives. 6.2 The "Without Proiect" Scenario Under the "without project" scenario, the Government would not receive the loan from the World Bank. As a consequence, the provisions of GEF grant and the bilateral development funds would probably be reconsidered or at least heavily revised. A realistic assumption therefore is that none of the project components would be implemented as planned. The state entity would continue to maintain some control over the uses of forests with the limited means in its disposal. The forests would continue to suffer from illegal cutting of fuel wood for local consumption and timber for commercial processing and exports. The local economy would benefit very little from the forest resources. The existing infrastructure of forests, such as recreation facilities, roads and buildings, would further deteriorate, probably leading to decrease of tourism. A major problem with the "without project" scenario is its environmental implication. Illegal logging would probably lead to overexploitation of the most easily accessible roadside sites, and reckless harvesting would damage the remaining stands making them vulnerable to pest and disease outbreaks. Illegal logging would also most likely lead to destruction of HCVFs and by selecting only the best trees from young stands illegal operators would also contribute to deterioration of genetic resources. Risk for erosion would increase along with the establishment of skidding trails without best practices and maintenance. Many of the instruments improving the sustainability of forest management would not be put in place. Deterioration of watershed areas near settlement would continue owing to illegal use by local population. The "without project" alternative would be socially and economically very limited, since the potential contributions of the forest sector to the development of the rural economy would remain minimal in terms of employment, revenues and supply of raw material for the wood processing industries. Environmnental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 76 January 28, 2004. In summary, the "without project" altemative, where the present policy would continue and the state entity responsible for forest management should keep on writing ever steeper deficits and eventually implode under shortened budgets would represent a thereat to the forest resources representing significant future revenues, which Bulgaria has achieved at substantial costs over the past 50 years. Consequently, the altemative of not addressing the current forest resource degradation trends and their impact on rural economy was rejected because of the high economic and social costs associated with the gradual degradation of Bulgaria's forest resource. Furthermore, the FDP project provides an opportunity to contribute to the national and global environmental objectives, to which Bulgaria is committed through signature of intemational agreements. 6.3 Restructuring Models of the NFB 6.3.1 Issues Related to Forest Environment As part of the ongoing formulation of a National Policy and Strategy (2004-2013) and a National Forestry Program (2004-2008) the Govemment of Bulgaria has commissioned a Restructuring Study of the State Forest Sector in Bulgaria. The study was launched in April 2003 and it is expected present its final conclusions in early 2004. The observations made in EIA are based mainly on the information available in the mid-term report published in mid- October 2003. The restructuring study is expected to cast light on the question whether the precarious financial situation of the NFB could be improved through changes in its structure and organization. Currently, the NFB is a budget-funded public entity responsible for timber sales and forest management as well as some regulatory functions such as inspection. The Govemment's tight budgetary policy and rising operation costs of the NFB have resulted in a continuously deteriorating financial status. Another key issue to investigate is the impact of structural changes on the independence and neutrality of public administration. Until now, the NFB has essentially exercised self-control, as the Ministry of Agriculture and Forestry, under which the NFB operates, has not had resources or staff to implement the supervisory function (Mid-term Report 2003). Both issues have an indirect but significant bearing on the forest environment. Lack of funds for the NFB was reflected in the sharply reduced allocation for forest management and a very low level of capital expenditure in 2001 (Forest Sector Analysis 2003). It is possible that the curbs in expenditure would target primarily non-productive activities such as environmental management. There is also a risk that environmental standards are followed less strictly, if this is seen to result in cost savings or larger revenue. Lack of supervision over the NFB on the part of MAF could increase this risk, especially owing to the large monetary values involved in the commercial activities of the NFB. A third, separate question of importance for the environmental management of state forests is the responsibility for managing the Nature Parks. It is currently the responsibility of the NFB, but budget constraints are hampering their efforts. The available funds have been very restricted; less than 1 BGL per hectare, which is a limited amount in absolute terms and less than one fifth of the funds available for management of National Parks (Forest Sector Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 77 January 28, 2004. Analysis 2003). In part, the problem is related to internal distribution of funds within the NFB, where protected areas appear to have a low priority. A fourth issue is the impact on illegal logging, which is a major source of environmental damage in Bulgarian forests. 6.3.2 The "Without Restructuring" Scenario In the present arrangement the NFB is responsible for nearly all public functions in the forestry sector such as inspection, extension, forest protection, research and development etc. as well as the management of state forests. The NFB has also a commercial function in the sense that it sells rights and short-term contracts for silvicultural work to private companies. The present structure was built up on a notion that a Government organization would be best positioned to accommodate the long production span in forestry and to take adequately into consideration the environmental and non-material values. Further, by concentrating all functions (except forest operations) under one single central management a close co- ordination between these functions could be ensured. While this reasoning has merits, the main drawback of the present system is that it is not conducive to efficiency, even though this would be highly necessary given the current financial difficulties of the NFB. Despite a series of budget cuts the NFP has posted an operational deficit since 1999, and it is highly unlikely that Govemment subsidies could in the long run match the increasing costs. Besides, the availability of subsidies has been erratic, which makes it difficult to use them as a basis for long-term planning. Hindrances to efficient operations in NFB include, inter alia, the following: - The large number of functions assigned to each administrative unit (comprising public functions and organization of state forest management) and lack of prioritization prevents them from focusing on key activities and using resources in a rational manner. Monitoring and evaluation of organizational performance is difficult without well-defined tasks and targets. - Development of commercial activities requires rapid and flexible implementation of structural changes and re-allocation of resources. However, the present budget system effectively prevents this. Further, it does not provide incentives for increasing efficiency. - NFB is unable to compete with the private sector for qualified staff, because of the rigidity of the Government salary scheme not allowing payment of competitive salaries. In addition, salary levels are based on formal position rather than achievement. With the current organizational and management structure, the financial situation of the NFB is likely to deteriorate further. This, in turn, will require further cuts in environment-related expenditure, and to increase pressure to reduce costs by ignoring environmental safeguards and standards. The conflict of interest between supervisory and commercial functions would also prevail (see discussion in Chapter 6.3.5) The present administrative structure is vulnerable to corruption; the staff have limited motive to prevent illegal practices and low salaries increase propensity to collude with illegal Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 78 January 28. 2004. operators. The limited resources available for surveillance (e.g. limited number of vehicles & low fuel rations) facilitate illegal operators' access to forest resources. Steps towards the restructuring of forest administration would probably be taken in a long run even without the FDP, but such development would probably lack holistic approach to SFM, be less comprehensive and take much longer time. 6.3.3 Proposed Models The restructuring study put forward three principal organizational models for the state forest sector to be analyzed further (Mid Term Report 2003). With regard to their organizational structure the main difference between them is how the key functions and responsibilities are administratively combined or separated. The Government has given a preliminary indication that further development of NFB will be based on Model II, but as required in the TOR and to provide a reference point for comparisons, this discussion will evaluate all three models. 6.3.3.1 Model I One central unit (a ministerial entity) has the responsibility for management as well as control and administrative functions. Management of Nature Parks is carried out by the Ministry. Model I represents a moderate development from the current structure and does not reflect the status quo (Table 6.1). Table 6.1 Proposed Model I Ministry Economic Management Functions Control and Administration Functions Forest operations Policy & strategy 10% own harvesting Legislation Sale of timber Regulation Sale of non-timber products Forest policing Hunting and fishing Support to private forest owners Forest protection (fires & pests) Forest protection (erosion control) National database Research (experimental stations) Seed control Nature park management 6.3.3.2 Model II A clear separation of functions. The management functions are operated by one market and customer oriented state owned independent legal organization. A strong separate state organization is responsible for the state control and administrative functions. National Forest Company charged with management of Nature Parks (Table 6.2). Environmnental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 79 January 28, 2004. Table 6.2 Proposed Model II National Forest Company Ministry Forest operations Policy & strategy 10% own harvesting Legislation Sale of timber Regulation Sale of non-timber products Forest policing Hunting and fishing Support to private forest owners Forest protection (fires & pests) Forest protection (erosion control) Nature park management National database New business development Seed control 6.3.3.3 Model III A clear separation of functions as in Model II. The management functions are divided among different private concession holders and one independent state owned organization. Control and administrative functions are held by one state organization. National Forest Company charged with management of Nature Parks (Table 6.3). Table 6.3 Proposed Model III National Forest Company Ministry Forest operations Policy & strategy 10% own harvesting Legislation Sale of timber Regulation Sale of non-timber products Forest policing Hunting and fishing Support to private forest owners Forest protection (fires & pests) Forest protection (erosion control) Nature park management National database New business development Seed control Private Company Concessions Forest & hunting operations Sale of timber products Sale of non-timber products Harvesting operations The three models could have a slightly different impact on the environment. Some of this variation is related to assumptions regarding the extent of investment in forest management, road construction, and timber harvesting under each model. There are also differences in how the models provide incentives for sustainable forest management. 6.3.4 Key Impacts 6.3.4.1 Activity Levels Regarding the assumptions on activity levels, the main difference is that Model I assumes that there is no increase in new roads and road repair over the 2003 levels, whereas Models II and III both assume an increased expenditure of BGL 22 million per year by 2008. Subsequently, the expansion of the road network will enable larger harvesting volumes. Under Model I Environmental Assessment of the Forest Development Project, Bulgaria. Ministty of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 80 January 28. 2004. timber sales are assumed to increase to 4 million m3 per year by 2008, while both Model II and Model III assume that during the same period timber sales reach the level of 5 million m3 per year. The difference in road investment is based on the projection that increased investment would be much less likely within a Ministry with funding and budgetary constraints than in a company that will have greater control of funds for investment into a roads network (Mid Term Report 2003). 6.3.4.2 Timber Harvesting The implication of increased harvesting volumes is that they increase the pressure on the forest environment and reduce the margin for preventive and mitigating action. If the constraints become very severe there is risk that environmental considerations are paid less attention to. The key objective is to ensure that the enterprise is able to operate profitably without exceeding sustainable harvesting levels. It has been estimated that in 2010 the maximum annual allowable cut would be 8 million m3, and in 2020 10 million m3 of standing timber (Forest Sector Analysis 2003). Estimates on the merchantable volume are unavailable, but experts have suggested that it could be as low as 75% of the standing volume mainly because small-dimensioned timber lacks markets (Yonov, pers. comm.). Accordingly, the total merchantable volume in 2010 would be 6 million m3. The portion available to the state forest enterprise will essentially depend on the development of forest ownership. Currently, state forests account for 86 percent of the total forest area, and the rest is in non-state ownership, mainly in the hands of private people or municipalities. If the allowable cut were distributed evenly over the forest area, the share of state forests would be about 5 million m3 per year, which is the same amount as the projection under Models II and III in year 2008. However, several municipalities are contesting the present ownership structure claiming that a much higher portion of the state forest area should be restored to them (up to 35-45% of total forest area). As a result, about 1.9 million m3 of the annual allowable cut' in state forests is currently blocked off from harvesting pending court rulings (Forest Sector Analysis 2003). If the municipalities' claims prove successful, the projected harvesting volumes in the remaining state forests could not be implemented without exceeding the annual allowable cut. Under Model I with lower harvesting levels, there would be less pressure to exceed the sustainable limits, but even in this case the situation would be very tight. While a reduced area would bring down the operating costs, the funding requirements for many of the non-revenue generating functions such as the management of Nature Parks would remain unchanged. This could be a problem especially under Models II and III, where the state forest enterprise is expected to fund all activities from its own resources. It should be noted, however, that the courts may satisfy none or only part of the municipalities' claims. Also, the maximum allowable cut is projected to continue its expansion until year 2020 and possibly beyond it. This will gradually ease the impact of these constraints, but the pressure on the forest environment could be high at the critical juncture following the organizational reform. Estimate based on standing volume; corresponds to some 1.4 million m3 of merchantable timber Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 81 January 28, 2004. So far, there is no indication what the court rulings will be and when they will become available. Because the NFB needs an urgent reform, it is recommended that the reform process be continued based on the present strategy. However, the outcome of the court processes should be monitored closely, and if a significant reduction of the state forest area appears likely, an appropriate revision of the strategy should be undertaken. It is emphasized that a reduced state forest area does not necessarily have a negative effect on the environment, but a diminished area would require a revision of the current scope of the FDP; attention should be shifted more towards municipal forests. There are also estimates suggesting that fuelwood consumption by the local population is substantially higher than the present official figures (6 million m3 vs. 1.5-2 million m3 annually) (Forest Sector Analysis 2003). Some estimates on the volume of illegal logging are also quite high, up to several million m3 annually. If these estimates were accurate, the scope for industrial timber harvesting could be substantially reduced. However, lacking more detailed information, it is difficult to assess the significance of these issue, as well as the possibilities to reduce fuel wood consumption or illegal logging. It is therefore recommended that the local experts review the available data and provide their judgement on their impact on the sustainability of industrial timber harvesting. 6.3.4.3 Road Construction The impact of the expansion of the forest road network and timber harvesting will depend on the way in which they are implemented. Potential risks to forest biodiversity include disturbance or destruction of individual forest habitats such as "high value conservation forests" or "key biotopes". New roads may also shrink or eliminate large contiguous blocks of forest required by some species. Poor implementation of road construction could also result in contamination of soil and water or erosion. The interests of tourism development may be in conflict with the expansion of timber harvesting in areas of exceptional natural beauty. However, while these are justified concerns, they do not constitute a major threat for the environmental sustainability of the FDP. A host of preventive and mitigating measures are available and if they are properly implemented no major harm on the environment is foreseen (for a more detailed discussion see Chapter 5.4). 6.3.5 Institutional Arrangements 6.3.5.1 Incentive Structure The three models differ in the way in which they motivate the various entities to carry out forest management, and this is also likely to have implications on how environmental management is dealt with. One of the main concerns with Models II and III is that the state forest enterprise with its orientation towards the market and customers will have limited interest in non-revenue generating functions such as environmental protection, management of Nature Parks and provision of public goods. This is a justified concern especially if there is a risk that the enterprise will end up in a precarious economic situation. Only financially healthy organizations are able to provide environmental and non-material services, and financial strength is also a precondition for investment in activities, which are necessary for the long-term sustainability of forest management. Under the existing models the enterprise is Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 82 January 28, 2004. expected to pay the environmental management cost from its own resources, and owing to its commercial orientation the enterprise may have an incentive to try to minimize the cost. However, the organizational set-up under Models II and III is likely to encourage economic efficiency, and the available projections show that the enterprise will be able to make substantial investments and generate a surplus after a transition period. Detailed estimates on the amount of funding needed for adequate environmental management are unavailable, but the burden on the enterprise is likely to be reasonable. For instance, the current number of staff in Nature Parks is 68, which is slightly more than 1 per cent of the projected number of employees in the whole enterprise in 2008. Provided that the enterprise will be able to generate a healthy operational surplus, it will have little difficulty to provide the necessary resources for the management of environmental functions. In other countries with similar organizational structure in state forestry (e.g. in Austria, the Czech Republic and Finland), the environmental functions are well resourced. With Model I, where all functions are combined, the economic objectives may be less explicit and less oriented towards economic gain, which could reduce pressure to achieve cost savings by limiting environment-related expenses. In financial terms, the forest administration is foreseen more or less to break even, but the projected investment volume is modest, which may jeopardize the long-term sustainability of forest management. Under this model the implementation of any activities is entirely dependent on budget funding, and the principal concern is that the Government's policy to restrain public expenditure will leave the forest administration without the necessary resources. Inadequate funding and low staff salaries would also increase the risk of corruption and illegal activities both in productive and protected forest. A significant advantage of Models II and III is that the entities charged with forest operations manage their own budgets. This gives them more control over the management process than the arrangement under Model I where funding for all activities comes from the govemment budget. Increased capacity for control is usually coupled with increased sense of responsibility for proper implementation of plans including those related to environmental management. Highly motivated staff is also likely to be able combat illegal logging more effectively. Another feature increasing the organizations' capacity for control is the switch from selling standing timber to delivery sales of assortments at the road side or mill gate. This approach is common to all models, and it is likely to contribute significantly to the combat against illegal logging and reduction of associated environmental damage. The main risk with all models is that changes in external conditions make forest management financially unviable and divert attention away from environmental issues. A detailed assessment of the financial calculations could not be carried out, but the based on the information made available the assumptions underpinning them appear realistic. For instance, timber prices are expected to remain at the current level, and the salary increases for the enterprise staff are estimated to be about 5% per year. One of the main potential threats is that a substantial part of the state forest area will be transferred to private and municipal ownership as a result of the on-going court processes (see above). Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 83 January 28, 2004. 6.3.5.2 Regulatory Functions Despite the importance of adequate funding it is emphasized that the financial health of the management organization does not automatically result in adequate environmental management. Especially under Models II and III, where an improved economic performance will be one of the main objectives for the state forest enterprise, there would be an incentive to minimize the environment-related costs. To ensure that the management is fully aware of their responsibilities, the obligations related to environmental functions and provision of public goods should be clearly spelled out in the enterprise statutes. Under Model I these should be included in the regulations governing the activities of the forestry administration. Further, the fulfillment of these obligations must be closely monitored. The advantage of Models II and III is that the split between functions enables the establishment of an independent control unit. This is likely to enhance the effectiveness of supervision over forest management in comparison with Model I where the functions are combined. It is stressed that for this approach to work properly, the control unit needs to have adequate resources and the legal framework and the judicial system have to be appropriate. The risk with Model I is that in a crisis situation, the neutrality of a control function that is subordinated to top management may easily be compromised. Regarding the impact of forest concessions envisaged under Model III, an independent control unit can exercise effective supervision over concession areas under the same assumptions as in Model II (see above). The main risk with concessions is that introduction of changes to the concession agreement may be a difficult and cumbersome procedure compared to the ease of adopting them in a state organization. These agreements are typically made for rather long periods with rather detailed stipulations in regard to environmental management. The concession holders may be reticent to introduce changes entailing increased costs or reduced income. Settlement of conflicts through financial compensations may prove expensive, and agreements leaving options open involve a substantial risk for the concession holder and easily lead to significantly reduced concession fees. 6.3.5.3 Extension Providing support to non-state forest owners is an important means of promoting sustainability of forest management. In terms of availability of resources or effectiveness, the models do not markedly differ. In all cases funding comes from Government budget and the management structure follows the patterns typical of state entities. The key difference is that in Model I it is part of the all-encompassing functions of the ministry; under Models II and III support to non-state forest owners is still a function of the ministry, but the management of state forests is assigned to a separate entity, the state forest enterprise. The significance of this arrangement is that under Model I the ministry would be an active player on the timber market. At the same time, the ministry would provide services to non-state forest owners who, in principle, are competing with it on the same market. The structure of Models II and III eliminates the conflict of interest and provides for a more neutral structure. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 84 January 28, 2004. 6.3.6 Summary of Findings and Recommendations Reform of the national forest administration is an important element in the transition process of the forest sector towards a market economy and Bulgaria's access to the EU. Without restructuring the administration, a lack of resources, corruption and illegal logging would continue to negatively influence the forest environment in a manner that would eventually put the overall sustainability of forest management in Bulgaria at risk. For the success of the reform, it is essential that the restructuring law and regulations, the statutes/charter of the National Forest Company and all regulatory provisions to reorganize the state control and administrative functions, provide adequate framework, incentives and safeguards for an accountable and transparent organization. To this end, available international best standards should be followed. Regarding the three models proposed for restructuration, there are significant differences in the way in which they provide incentives for environmental management. Model I appears least likely to instigate behavior, which has a direct negative impact on the forest environment. The main risks with this model are a lack of an independent control function as well as the projection that the (environmental) investments remain limited. The main constraint is the limitations of the Government budget. Unless sufficient funding can be provided the organization would also be vulnerable to corruption and illegal practices causing negative environmental impacts both in productive and protected forest. Models II and III put more emphasis on the economic functions of forest, which entails the danger that environmental functions are given low priority. On the other hand, the independence of the control function as well as the projection on expanding (environmental) investments could counter this threat. Increased responsibility for management decisions is also likely to enhance staff motivation and enhance their capacity to manage the forest resources sustainably and combat illegal practices. The main risk with Models II and III is that the enterprise will not be economically viable, and as a result sets low priority to non- revenue generating functions such as environmental management. This could happen if the courts satisfy the municipalities' claims to transfer a substantial portion of the current state forest area to municipal ownership. Such a change in ownership structure would not necessarily imply negative effects on the environment, but the scope of the FDP would have to be adjusted accordingly; providing support to municipal forests should become a more important activity. Adequate environmental management is possible under all models, but the actual impact will depend on the way in which the various measures are implemented. Model I involves substantial risks because of its dependence on budget funding and the Government's precarious financial situation. Recommendations (mainly related to Model II): - Monitor closely the court processes regarding claims to restore part of the state forests to municipal ownership; maintain preparedness to introduce changes to the strategy as necessary - Obtain a assessment from the local experts on the impact of fuel wood harvesting and illegal logging on harvesting of industrial timber in state forests Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 85 January 28. 2004. - Incorporate the obligations related to environmental management of forests into the statutes of the state forest enterprise - Ensure that the inspection function has adequate staff and other resources - Compensate the National Forest Company for public good forest management functions beyond sustainable forest management practices, which are executed on behalf of the forest administration and for services rendered to the society. Such functions include the management of protected areas, recreation services, support to private forest owners, etc. - Develop a strategy for mitigating the risk of failure of the National Forest Company, so as to describe what would be done if the company were to fold. General public interests - including environmental management of forests - should be preserved in such case. 6.4 Rejected Sub-components of the FDP The EA team took note that the sub-component "Carbon Targeted Afforestation" has been removed from the project description included in the PAD draft version 3, which means that it will not be implemented. Under this sub-component, the project was supposed to support limited afforestation in areas where the sum of environmental, financial and landscaping benefits would make such investments economically feasible. Planting of fast growing species was deemed to be questionable from an environmental point of view and contrary to the aims of the NFPS for more natural type forests. However, this slightly contradicts with the national afforestation targets and needs. The establishment of a Forest Sector Business Center (FBSC) was rejected due to the structure of the sector and the altemative approach adopted under Action 2005. Based on consultation with private forest owners, pilot certification was replaced by assistance to realign support provided under the EU SAPARD program. The support to SMEs was also erased from the scope the FDP. The deletion of the said sub-components is not likely to have any significant environmental impacts. 7. SAFEGUARD POLICIES 7.1 Safeguard Policies The World Bank's environmental and social safeguard policies aim to prevent and mitigate undue harm to people and their environment in the development process. These policies are also meant to provide a platform for the participation of stakeholders in project design, and have been an important instrument for building ownership among local populations. 7.2 Environmental Assessment Environmental Assessment is one of the ten Safeguard Policies, and it is used to identify, avoid, and mitigate the potential negative environmental impacts associated with Bank lending operations. The purpose of Environmental Assessment is to improve decision making, to ensure that project options under consideration are sound and sustainable, and that potentially affected people have been properly consulted. The World Bank's environmental assessment policy and recommended processing are described in Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental Assessment. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 86 January 28, 2004. The FDP was screened for its potential environmental impacts and assigned an environmental category A, which requires a full environmental assessment, including public disclosure and consultation. Hence, this safeguard policy is triggered. 7.3 Natural Habitats Operational Policy 4.04: Natural Habitats seeks to ensure that World Bank-supported infrastructure and other development projects take into account the conservation of biodiversity, as well as the numerous environmental services and products which natural habitats provide to human society. The policy strictly limits the circumstances under which any Bank-supported project can damage natural habitats (land and water areas where most of the native plant and animal species are still present). Specifically, the policy prohibits Bank support for projects which would lead to the significant loss or degradation of any critical natural habitats, whose definition includes those natural habitats which are either legally protected, officially proposed for protection, or unprotected but of known high conservation value. In non-critical natural habitats, Bank supported projects can cause significant loss or degradation only when there are no feasible alternatives to achieve the project's substantial overall net benefits; and acceptable mitigation measures, such as compensatory protected areas, are included within the project. The FDP components involving road construction, thinnings and afforestation trigger the Natural Habitats safeguard policy, and various measures are included in the project implementation plans to conserve biodiversity, limit damage to natural habitats and avoid degradation of natural habitats. 7.4 Forests The Bank's Operational Policy/Bank Procedure 4.36: Forests aims to reduce deforestation, enhance the environmental contribution of forested areas, promote afforestation, reduce poverty, and encourage economic development. The Bank recognizes that forests play an increasingly important role in poverty alleviation, economic development, and for providing local as well as global environmental services. Success in establishing sustainable forest conservation and management practices depends not only on changing the behavior of all critical stakeholders, but also on a wide range of partnerships to accomplish what no country, government agency, donor, or interest group can do alone. The strategies proposed by FDP entail major changes in Bulgarian forest management as well as substantial environmental impacts. The Bank's Operational Policy on Forests applies to (a) projects that have or may have impacts on the health and quality of forests; (b) projects that affect the rights and welfare of people and their level of dependence upon or interaction with forests; and (c) projects that aim to bring about changes in the management, protection, or utilization of natural forests or plantations, whether they are publicly, privately, or communally owned. Environmnental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 87 January 28, 2004. The overall objective of the FDP is to increase the contribution of forests to the national economy and to the benefit of rural populations through sustainable management of state, private and communal forests. The project includes physical investments in forests (e.g. thinnings, rehabilitation of burnt forest sites, road construction, energy production with fuelwood and possibly establishment of plantations) and administrative changes to facilitate efficient and sustainable use of forest resources. It also aims at improved conservation of forest ecosystems through mainstreaming biodiversity into forest management, and through improved conservation of critical ecosystems. All these activities have direct or indirect impacts so significant that they trigger the Forests Safeguard Policy. 7.5 Pest Management According to Operational Policy 4.09 on Pest Management and BP 4.01 Annex C - application of EA to projects involving pest management, the rural development projects have to avoid using harmful pesticides. Integrated Pest Management (IPM) techniques provide one solution, and their use should be encouraged in the sectors concerned. Should pesticides need to be used in crop protection or in the fight against vector-borne disease, the Bank-funded projects should include a Pest Management Plan, prepared by the borrower, either as a stand- alone document or as part of an Environmental Assessment. The FDP has proposed the establishment of energy plantations (yet only where absolutely necessary) and suggested use of fertilizers to ensure high productive supply of biofuels. The project should prepare a plan for pest and fungi management. Although this triggers the Pest Management safeguard policy, the pilot energy plantations will be financed only where absolutely necessary, with a maximum of 120 ha. Therefore, a full Pest Management Plan does not seem necessary before appraisal. Pest Management Plan could be prepared during project implementation, parallel to the identification of afforestation JI projects. Such plan should (i) consider various alternative designs of plantations to minimize the said risks and, and (ii) propose relevant mitigation measures with a view to pest and fungi outbreaks. The criteria for pesticide selection and use based upon the World Health Organization's Recommended Classification of Pesticides by Hazard and Guidelines for Classification (Geneva: WHO, 1994-1995) are included in OP 4.09. 7.6 Cultural Property Cultural resources are important as sources of valuable historical and scientific information, as assets for economic and social development, and as integral parts of a people's cultural identity and practices. The loss of such resources is irreversible, but fortunately, it is often avoidable. The objective of Operational Policy Note 11.03: Cultural Property is to avoid, or mitigate, adverse impacts on cultural resources from development projects that the World Bank finances. The project will support construction of access roads (a total of 25-30 km) in largely uninhabited forest areas. These are 3rd category and soft-surface roads whose location can easily be determined in a way that will not affect any cultural properties. The construction of these roads involves relatively shallow ground work with no large scale excavations or movements of earths that could lead to archeological discoveries and location of cultural properties whose existence is not known today. In line with the standard road construction Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUIFOR. 88 January 28, 2004. practices, the construction of the forest access roads supported under the project will be preceded by a feasibility study and physical reconnaissance of the terrain. Hence, the Cultural Property safeguard policy is not triggered. 7.7 Involuntary Resettlement The Bank's Operational Policy 4.12: Involuntary Resettlement is triggered in situations involving involuntary taking of land and involuntary restrictions of access to legally designated parks and protected areas. The policy aims to avoid involuntary resettlement to the extent feasible, or to minimize and mitigate its adverse social and economic impacts. It promotes participation of displaced people in resettlement planning and implementation, and its key economic objective is to assist displaced persons in their efforts to improve or at least restore their incomes and standards of living after displacement. The policy prescribes compensation and other resettlement measures to achieve its objectives and requires that borrowers prepare adequate resettlement planning instruments prior to Bank appraisal of proposed projects. The Involuntary Resettlement policy is triggered because of the potential impacts on people's livelihoods caused by proposed restrictions of access to forests (grazing, extension of protected area) and reducing illegal extraction of forest-related resources (para 3b of OP 4.12). This in turn requires the preparation of a Process Framework (currently under preparation by the Government). 7.8 Operational Directive (OD) 4.20: Indizenous Peoples The World Bank policy on indigenous peoples, Operational Directive (OD) 4.20: Indigenous Peoples, underscores the need for Borrowers and Bank staff to identify indigenous peoples, consult with them, ensure that they participate in and benefit from Bank-funded operations in a culturally appropriate way and that adverse impacts on them are avoided, or where not feasible, minimized or mitigated. The policy, issued in September 1991, is presently being revised into Operational Policy (OP) 4.10 and Bank Procedure (BP) 4. 10. The OD is not triggered as there no indigenous people in any of the potential project areas. 7.9 Operational Policy (OP) 4.37: Safety on Dams Dam safety is a matter of significant importance in many countries in the world today because of the presence of a large number of dams, existing, under construction or planned. The safe operation of dams has significant social, economic, and environmental relevance. When the World Bank finances new dams, Operational Policy (OP) 4.37: Safety on Dams requires that experienced and competent professionals design and supervise construction, and that the borrower adopts and implements dam safety measures through the project cycle. The policy also applies to existing dams where they influence the performance of a project. In this case, a dam safety assessment should be carried out and necessary additional dam safety measures implemented. OP 4.37 recommends, where appropriate, that Bank staff discuss with the borrowers any measures necessary to strengthen the institutional, legislative, and regulatory frameworks for dam safety programs in those countries. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 89 January 28. 2004. The OP is not triggered because the project does not include dam-related activities 7.10 Operational Policy/Bank Procedure: Projects in International Waters (OP 7.50, BP 7.50, GP 7.50) Operational Policy (OP)/Bank Procedure (BP) 7.50: Projects in International Waters may affect the relations between the World Bank and its borrowers, and between riparian states. Therefore, the Bank attaches great importance to the riparians making appropriate agreements or arrangements for the entire waterway, or parts thereof, and stands ready to assist in this regard. In the absence of such agreements or arrangements, the Bank requires, as a general rule, that the prospective borrower notifies the other riparians of the project. The Policy lays down detailed procedures for the notification requirement, including the role of the Bank in affecting the notification, period of reply and the procedures in case there is an objection by one of the riparians to the project. The EA team considers that the OP is not triggered. Project activities may potentially affect some watersheds supplying water to river "Danube" which is a border river between Bulgaria and Romania. However, because watershed protection has not been a major problem in the past and the FDP is expected to continue sustainable practices, the risk of negative impacts is considered small. 7.11 Operational Policy (OP)/Bank Procedure (BP) 7.60: Proiects in Disputed Areas Operational Policy (OP)/Bank Procedure (BP) 7.60: Projects in Disputed Areas may affect the relations between the Bank and its borrowers, and between the claimants to the disputed area. Therefore, the Bank will only finance projects in disputed areas when either there is no objection from the other claimant to the disputed area, or when the special circumstances of the case support Bank financing, notwithstanding the objection. The policy details those special circumstances. In such cases, the project documents should include a statement emphasizing that by supporting the project, the Bank does not intend to make any judgment on the legal or other status of the territories concerned or to prejudice the final determination of the parties' claims. The OP is not triggered since there are no area disputes between Bulgaria and the neighboring countries. Table 7.1 Summary Table on Safeguard Policies Policy Triggered Environmental Assessment (OP 4.01, BP 4.01, GP 4.01) Yes Natural Habitats (OP .04, BP 4.04, GP 4.04) Yes Forestry (OP 4.36, GP 4.36) Yes Pest Management (OP 4.09) Yes Cultural Property (OPN 11.03) No Involuntary Resettlement (OP/BP 4.12) Yes Indigenous Peoples (OD 4.20) No Safety of Dams (OP 4.37, BP 4.37) No Projects in International Waters (OP 7.50, BP 7.50, GP 7.50) No Projects in Disputed Areas (OP 7.60, BP 7.60, GP 7.60) No Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DUFOR. 90 January 28. 2004. 8. ENVIRONMENTAL MANAGEMENT PLAN 8.1 Overview The Environmental Management Plan (EMP) summarizes the key findings of the environmental assessment carried out, including suggested mitigation and enhancement measures with reference to significant environment-related issues, responsibilities, schedules, cost estimates and monitoring indicators (Table 8.1). The EMP does not repeat those measures defined by the baseline control procedures of Bulgaria, or incorporated into the activities of the FDP, if they are deemed as such adequate for environmental control. However, identified development needs in the baseline control procedures and the FDP intervention are addressed in the EMP. A great majority of the suggested measures concerns additional specifications of planned actions and safeguards already included in the FDP. The purpose is to ensure that the significant environmental and social issues will be duly considered while on implementation, even though their control measures might be elaborated in later phases of the project preparation or implementation (e.g. based on the outcomes of numerous feasibility studies and surveys to be carried out). Most of the recommended mitigation or enhancement measures require no or only moderate additional funding. Nevertheless, the realization of the EMP still contains two high cost- intensive actions at least partially beyond the budget of the FDP: - Environmental and safety training of actors in the forest sector - Financing of management of Nature Parks The FDP will support general capacity building of the State Forest Administration (SFA) and the National Forest Company (NFC) at headquarters and regional levels by aid of the Phare Twinning program in 2004. The capacity building of the SFA is allocated to law enforcement and extension services to private and municipal forest owners, and that of NFC mainly to business planning, marketing and financial management. It would be of great importance that the FDP also had a clear focus on environmental training over institutional boundaries. The plan for environmental and safety training of actors in the forest sector is discussed separately in Chapter 8.3 and referred in Table 8.1. The financing of nature park management is beyond the scope of the FDP. However, the compensation for their management should be addressed in the implementation of the restructuring plan for the National Forest Company (the FDP Sub-component 3.1). It is estimated that approximately EUR 4/ha is needed to annually invest in the nature parks to enhance and maintain their biodiversity, recreational and other public good values and services. No additional costs are allocated for the monitoring in the EMP, since the FDP Component 5: Project Management and Monitoring includes provisions for such activities. It is also stated in the FDP documentation that while the PMU will make random field inspections, monitoring of forest investments will be contracted to a consortium with NGO representation. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 91 January 28, 2004. Table 8.1 Environmental Management Plan Activity / Investment Significant environmental Complementary mitigation / Responsibility Schedule Cost estimate, EUR Monitoring impacts and risks Enhancement measure Component 1: Strengthen Public Forest Sector Management Restructuring forest * Reduction in unauthorized Borrower shall prepare a study on private MAF, SFA, FDP 2005 10 000 While preparing /reviewing administration / activities sector's possibilities to contribute to control and - TOR State Forest * Reduced damages from monitoring of forest management - draft report Administration grazing - final report - capacity building Borrower shall ensure that state regulations on MAF, SFA, FDP 2005 10 000 Quality checking of - restructuring action plan logging and silvicultural activities are updated - draft version - equipment to include environmental requirements - final regulations acceptable to the World Bank Borrower shall ensure that logging companies MAF, FDP See Chapter 7.3 are provided with training on - environmental issues - occupational health and safety Borrower shall prepare a study on the health of MAF, FDP, 2005 10 000 While preparing /reviewing plantation forests and grazing including National - TOR measures to Consultants - draft report - prevent diseases in plantations - final report - minimize adverse impacts of grazing - mitigate impacts of above actions on animal husbandry Forest fire management * Improved protection of No additional measures suggested system forest resources and - education campaigns products - fire rating system * Improved protection of flora - early waming system and fauna/ biodiversity - weather stations * Fewer forest fires - equipment - training Information and Borrower shall assure compatibility in data MAF, SFA, FDP 2004 No need for Checking prior to purchase of Monitoring System exchange additional funding software - software & hardware - training Surveillance on illegal * Use of forest resources and With regard to industrial use of illegal wood, GOB, NFC, FDP, 2005 No need for While preparing /reviewing logging products is better controlled Borrower shall expand the scope of Illegal Consultant additional funding - TOR - conduct ofa study * Less damages to flora and Logging and Corruption Study to cover: - draft report - initiate measures to fauna / biodiversity - collaboration with police force and other - final report reduce illegal actvities * Reduction in unauthorized relevant authorities and forest activities - analysis on supply and demand of wood With regard to domestic use of illegal wood, GOB, NFC, FDP, 2005 No need for While preparing /reviewing Borrower shall ensure that Illegal Logging and Consultant additional funding - TOR Corruption Study proposes means to supply - draft report fuelwood at low cost through, e.g. - final report - govemmental compensation to the NFC for fuelwood supply - reduced payment of dividends for the NFC - free fuelwood harvesting by local people Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. 92 Activity / Investment Significant environmental Complementary mitigation/ Responsibility Schedule Cost estimate, EUIR Monitoring impacts and risks Enhancement measure Borrower shall establish a high level inter- GOB 2004 Funding from Establishment of task force sectoral task force on illegal logging and govemmental budget Plans, activities and results corruption achieved Borrower shall prepare a separate study MAF, FDP, 2005 10 000 While preparing /reviewing including measures to National - TOR - prevent diseases in plantations Consultants - draft report - minimize adverse impacts of grazing - final report - mitigate impacts of above actions on animal husbandry Borrower shall follow the Process Framework See Annex 12 for mitigating potential adverse likelihood impacts Forest Certification Borrower shall develop indicators for small National Working 2004 No need for While preparing /reviewing Standard holdings and group certification Group, Consultant, additional funding - 2' draft standard FDP - prior to finalization of _ standard Support for professional No additional measures suggested Technical Schools Component 2: Strengthening of Capacities of Non-State Forest Owners BAFO No additional measures suggested Support to local forest Borrower shall integrate sustainable forest Associations, FDP 2004-2005 No need for Sustainable forest management owners' associations management in the activities carried out by additional funding should be prerequisite for FDP - establishment of local forest owners' associations through support associations - appropriately formulated statutes - development of - operational guidelines guidelines / business Borrower shall ensure that the staffof MAF, FDP See Chapter 7.3 plans associations is given training on - environmental issues - occupational health and safety With regard to standing sales of timber, Associations, SFA, 2004 No need for Checking based on sampling Borrower shall ensure the preparation of FDP additional funding - by associations standard contracts form including provisions for - by contracts - environmental issues - occupational health and safety With regard to forest management plans, FDP, associations 2004 No need for Checking prior to purchase of Borrower shall ensure that the plans are multi- additional funding software objective and software to be applied allows site- specific data on - key habitats - non-wood product - cultural values - etc. C Realignment of SAPARD Borrower shall ensure environmental screening FDP 2004- 5 000-10 000 Continuously and support of projects directly supported by the FDP under - need assessment TOR as well as EA screening protocols - review and realignment acceptable to the World Bank - consultancy support - definition of assessment criteria - assessment of individual projects Envirnosiental Assessnient of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. 93 Activity / Investment Significant environmental Complementary mitigation/ Responsibility Schedule Cost estimate, EUR| Monitoring impacts and risks Enhancement measure Component 3: Supporting State Forest Management Transition to Market Economy National Forest Company Risks related to Borrower shall ensure that the NFC operates NFC, GOB, FDP 2004 No need for Checking the charter prior to the - training and TA * unsustainable use of forest under a charter approved by the Government additional funding Governmental approval - information systems resources and products (e.g. and acceptable to the World Bank defining, - hardware and software nature parks) inter alia, * damage to flora and fauna / - membership and functions of its boards biodiversity, soil and water - public participation in the meetings * nadequate OHS - use of revenues - mechanisms for financing the management of nature parks Borrower shall ensure that the staff of the NFC NFC, FDP See Chapter 7.3 are given training on - environmental issues - occupational health and safety Borrower shall ensure that the NFC board GOB, NFC 2004 No need for NGO participation is checked includes a range of national interest groups, additional funding from including environmental and social NGOs - statutes of the NFC - members of the board Borrower shall prepare procedures to control GOB, NFC 2004 No need for Existence of such procedures acquiring and selling land as well as transfer of additional funding Checking of individual cases land use rights Updating forest road * Improved possibilities to Borrower shall undertake the following, all NFC, FDP * Checking key issues are network use forest resources and acceptable to the World Bank: included in forest road master - forest road master plan products - ensure that environmental issues are plan and Code of Best - code of best practice for * Enhanced transport incorporated into the forest road master plan Practice design, construction and connections - make use of available results from the WWF * Checking conduct of field maintenance of forest Risks related to exercise on HCVF and material related to surveys by road projects roads * unsustainable use of forest Corine biotopes and Natura 2000 * See Chapter 7.2 - upgrading (circa 122 resources and products (inl. conduct field surveys to identify key habitats km) and construction nature parks) and to protect nature in general (e.g. use (21 km) of new roads in * damaging of Flora and WWF toolkit for identification of HCVF) pilot areas Fauna/biodiversity, soil and - fully apply Best Management Practice to water road construction and rehabilitation * inadequate OHS Borrower shall conduct Strategic EIA on the NFC, FDP 2004 30 000 No roading work prior to the * facilitation of illegal logging forest road master plan conduct of Strategic oA Borrower shall conduct EIA on first 2-3 roads NEC, FDP 2005-2006 10000-15 000 Number of EtA carried out for precautionary reasons Thinnings * Improvements in quality of Borrower shall ensure that tree marking will be NFC, FDP 2004 No need for Field checks pnor to and afler - 10000 ha of young forest resources and carried out taking into consideration desirable additional funding cuttings (see Chapter 7.2) stands products tree species composition after thinnings * Provision ofjob Borrower shall complement technological plans NFC, FDP 2004 No need for * Checking the content of all opportunities to include guidelines for protection of soil and additional funding technological plans Risks related to water * Field checks (see Chapter * damaging of flora and 7.2) fauna! biodiversity, soil and water * inadequate OHS Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. 94 Activity / Investment Significant environmental Complementary mitigation/ Responsibility Schedule Cost estimate, EUB Monitoring impacts and risks Enhancement measure Reforestation and * Improvements in forest Borrower shall check and, if necessary, revise NFC, FDP 2004 No need for * Checking the quality of all rehabilitation of forest fire resources and products technological plans not to include proposals for additional funding technological plans prior to sites * Less erosion mono-culture planting initiation of upgrading work - cleaning, site * Provision ofjob * Field checks (see Chapter preparation and planting opportunities 7.2) of 600 ha Risks related to Borrower shall ensure that planting of pine at NFC, FDP 2004 No need for * Checking the quality of all * damaging of soil and water low altitudes is avoided additional funding technological plans prior to * inadequate OHS initiation of upgrading work * Field checks (see Chapter 7.2) Borrower shall prepare and implement plans to NFC, FDP 2004 No need for * Checking necessary plans prevent forest fires and diseases additional funding prior to initiation of upgrading work * Field checks (see Chapter 7.2) Pilot certification Improvements related to No additional measures suggested - scoping study management of - technical assistance * Forest resources and - preassessment products - training of assessors * Flora and fauna / biodiversity * Soil * Water * OHS * Social issues l Component 4: Promotion of Biodiversity Conservation in Forest Management Mainstreaming of * Improved quality of forest Borrower shall train key technical staff at all NFC, SFA, FDP See Chapter 7.3 biodiversity conservation resources and increased levels in forest management supply of non-wood forest planning products - identification of * Improved conservation of endangered habitats flora and fauna / - guidelines and tools biodiversity - integration of * Reduced damage from biodiversity mgmt Illegal logging and grazing - use of NWFP - eco-tourism Biodiversity conservation * Improved conservation of Borrower shall revise guidelines for the NFC, SFA, FDP 2004-2005 15 000 Existence of new guidelines in forest management flora and fauna/biodiversity development of Forest Management Plans - capacity building * Reduced damage from (green plans) - awareness campaigns illegal logging and grazing Borrower shall train relevant staff in applying NFC, SFA, FDP 2005 18 000 Number of stafftrained - training of stakeholders the FMP guidelines in practice Number of green FMP prepared - site specific conservation activities Environiiental Assessment of ihe Forest Developnient Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. January 28, 2004. 95 Activity / Investment Significant environmental Complementary mitigation / Responsibility Schedule Cost estimate, EUR Monitoring impacts and risks Enhancement measure Strengthening of nature * Improved conservation of In case of conflict of interest between FMPs and NFC, NFC, FDP 2004 No need for Number of conflicts reduced to parks floma and fauna / Nature park plans, Borrower shall strengthen additional funding zero - planning, monitoring biodiversity the regulation to secure the priority of Nature and coordination Park Plan over the FMP capacity strengthening investments Endowment Fund No additional measures suggested Program coordination and No additional measures suggested management Joint Implementation * Increased quality of forest Borrower shall secure that the feasibility studies FSPP, FDP 2004 No need for While preparing /reviewing capacity enhancement/ resources and products / analyze and initiate means to ensure adequate additional funding - TOR FSPP potential increase of forest availability of domestic fuelwood - draft feasibility study - feasibility studies cover - final feasibility study - equipment * Reduced GHG emissions / Borrower shall prepare and implement plans to FSPP, FDP 2004 No need for While preparing /reviewing carbon sequestration prevent forest diseases and fires, if energy additional funding - TOR Risks related to plantations are proposed to be established - draft feasibility study * conservation of flora and - final feasibility study fauna/biodiversity (See Chapter 7.2) * properties of soil Borrower shall carry out soil studies to FSPP, FDP 2004 1 000 While preparing /reviewing * quality of water determine needs for use of fertilizers, if energy - TOR * inadequate OHS plantations are proposed to be established - draft feasibility study * supply of domestic - final feasibility study fuelwood (See Chapter 7.2) Component 5: Project Management and Monitoring Monitoring and No additional measures suggested management Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. 96 8.2 Monitoring of Forest Investments It is recommended that the FDP conducts, in collaboration with interested NGO representatives, field inspections regarding: - rehabilitation and construction of forest roads - thinning of young and fire prone stands - rehabilitation and regeneration of forest fire sites - establishment of energy plantations, where appropriate Rehabilitation and construction offorest roads: The FDP monitoring team should review all plans for upgrading forest road network against normative regulations, the forest roads master plan and other guidelines, and initiate corrective action, where necessary, and approve them prior to the actual rehabilitation and construction work. Each new forest road should also be inspected in the field while on construction. The proposed monitoring indicators consist of the factors stipulated in the Code of Best Practice for Design and Construction of Forest Roads. The team should identify non-conformities and immediately initiate corrective actions. Thinning of young and fire prone stands / Rehabilitation and regeneration offorest fire sites: Prior to the operations, the technological plans should be reviewed and revised, if shortcomings are identified in terms of e.g. biological diversity (in particular, tree species composition), protection of soil and water, and fire prevention. The FDP is proposed to field check the forest operations based on sampling. The field objects to be inspected should contain (i) ongoing operations, (ii) completed sites, and (iii) cover all regions to where the FDP funds allocated. As in the case of forest roads, the monitoring team should identify non- conformities and immediately initiate corrective actions. Establishment of energy plantations: It is recommended that the FDP double-checks the selected sites are in accordance with the requirements under Kyoto Protocol (the land is not under forest cover as defined in the Marrakesh Accords and it will become forested as a result of the project). Furthermore, the FDP should evaluate the proposed safeguards for prevention of forest fires, pest and fungi diseases, and needs for use of fertilizers. Review of plans and field inspections, including observed non-conformities should be recorded. The implementation of corrective actions should be followed, and checked in the field, if deemed necessary. 8.3 Environmental and Safety Training Sustainable forest management practices, including occupational safety, are at present inadequately applied to the practice. Main reasons include shortage of high quality guidelines appropriate to the Bulgarian conditions and lack of training. Training needs are found in both public and private forest sectors. Enhancement of environmental and safety-related knowledge among the main actors in forest sector is a major effort, but necessary for the implementation of sustainable forest management and improvement of occupational health and safety conditions of forest workers. Therefore, it is recommended that a national environmental and safety training program is prepared and realized. The program is split up into three phases: (i) preparation of forest Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 97 January 28, 2004. management guidelines, which is partially included in the FDP, (ii) training of national trainers, and (iii) organizing local level training courses. It is estimated that 15 national trainers would be a sufficient number to organize approximately 150 local training sessions, to which representatives of SFA, NFC, forest owners' associations, municipals with a significant forest ownership and logging companies are invited. A training course would include lessons and presentations in classroom, group work as well as field exercises and demonstrations. The preparation of guidelines, training of trainers and organizing the training courses are estimated to require a year and a budget of EUR 350 000, of which 90% is allocated for the local training courses. The remaining 10% would be used for the education of trainers and preparation of course materials. International consultants would be hired for the training of trainers. The environmental and safety training could be arranged in the line organizations of SFA and NFC, but this approach poorly reaches unorganized logging companies, municipal forest owners and forest owners' associations. A training model involving these groups would decrease misinterpretations and deviations in the practical applications of sustainable forest management, since the trainers would be given coherent education. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 98 January 28, 2004. REFERENCES Forest Sector Analysis. 2003. Report on Forest Sector Analysis - Bulgaria. Project for the Development of the National Forest Policy and Strategy in Bulgaria. Sofia, January 24, 2003. Kun, Zoltan (ed.). 2002. Potential Pan Parks In Europe. A Quickscan of European Protected Areas Against Selected Pan Parks Indicators. Pan Parks Foundation. PPU. 2003. Private Forest Owners Study for Bulgarian Forest Development Project Preparation. Project Preparation Unit. Project Preparation Unit (PPU). 2003. Private Forest Owners Study for Bulgarian Forest Development Project Preparation. World Bank. 2002. Bulgaria Forest Development Project. Project Concept Document. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUIFOR. 99 January 28, 2004. t I I A NNEXES I -~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ANNEX I Terms of Reference Annex 1 BULGARIA Forest Development Project (PE-P033964) Terms of Reference for Project Environmental Assessment l. Introduction The Government of Bulgaria (GOB) has requested the World Bank's assistance in financing a Forest Development Project (FDP), to be implemented in 2004 - 2010 through the national Ministry of Agriculture and Forestry (MoAF). The objective of the project is to increase the contribution to the national economy and environment from rehabilitation and sustainable management of Bulgarian private, communal and state forest resources. The FDP would also strengthen the conservation of globally significant biodiversity of Bulgaria through mainstreaming of biodiversity conservation in forest management. The total project cost is estimated at US$ 44.3 million equivalent and will be financed by the World Bank (US$ 30 mln), GEF (US$ 7 mln), GOB and bilateral donors (US$ 7.3 mln). The project was screened for its potential environmental impacts, and because of the possibility that some of the project activities may have negative environmental impacts, and the public interest associated with the proposed program, the World Bank assigned the FDP an environmental category "A," which requires a full environmental assessment, including public disclosure and consultation. Therefore, GOB seeks the services of internationally qualified consultants to prepare a Project Environmental Impact Assessment (EA), which would be consistent with the GOB environmental assessment requirements and the requirements of the World Bank as outlined in its Operational Policy 4.01 "Environmental Assessment". II. Background Information Proiect timetable and scope. The FDP is expected to be appraised by the World Bank in November 2003 and submitted for World Bank's Board approval in May, 2004. The overall investment program related to the FDP includes (i) IBRD-financed activities targeted at sector reform and improved forest management, (ii) GEF-financed activities for forest biodiversity conservation, and (iii) fuel switch pilot program funded by the Government of Japan to explore the feasibility of switching fuel sources from fossil fuels to bio-mass. A new National Forest Policy and Strategy (NFPS) process and a study on the restructuring of the National Forestry Board will establish strategic approaches for the sector reform and substantiate project activities. The Project will incorporate the following inter-related activities, which are all subject to the Environmental Impact Assessment: 1. Strengthening public forest sector management, through (i) reform and strategic development of forest administration; (ii) building and strengthening nationwide forest extension and inspection services; (iii) building and strengthening a nationwide forest fire management system; (iv) developing a GIS-based forest information and monitoring system, including updating of national forest database; and (v) establishing a central capacity for marketing information and promotion of Bulgarian forestry products. 2. Strengthening capacities of private and communal forest owners for sustainable forest management, through (i) fostering emergence of a representative association of private and communal forest owners at the national level; (ii) supporting the establishment of community based and communal forest owners associations; (iii) supporting participation of forest owner associations in SAPARD program; and (iv) pilot certification of forests under management of new forest management associations. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agricutture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. Annex 1 3. Adapting state forest management to market economy and to new realities arising from forest restitution, through (i) establishing and developing a new state forest enterprise; (ii) rehabilitating and optimizing forest road network to minimize harvesting damage, reducing operation costs and minimizing fire hazards, as well as relieving pressure from over-exploitation; (iii) thinning of young and fire prone stands; (iv) reforestation and rehabilitation of destroyed and devastated forest fire sites; and (v) pilot certification in selected state forests. 4. Promotion of biodiversity conservation in forest management (GEF-financed), to include (i) mainstreaming of biodiversity conservation in forest management planning; (ii) integration of biodiversity conservation in regular forest management operations; (iii) strengthening the system of protected areas under the jurisdiction of the Ministry of Agriculture and Forestry; (iv) development of the Bulgaria protected areas endowment fund. 5. Enhanced carbon benefits from Bulgarian forests, through (i) improved forest structure by promoting the use of biomass; and (ii) carbon targeted afforestation. 6. Project Management and Monitoring. 7. Fuel Switch Pilot Project (PHRD-financed) Detailed description of the proposed project components is provided in Attachment 1. GEF-funded activities would be interconnected and mainstreamed into the activities carried out by various components under the IBRD forestry loan. In addition to the direct global benefits, resulting from the increased protection of the internationally significant forest habitats, the project will establish strategic partnerships with local land owners, land users, and communities, which would greatly contribute to the long-term sustainability of the conservation effort. The PHRD-funded Fuel Switch Pilot Project aims to define the actual costs and benefits of switching from fossil fuels to wood in medium-sized municipal building heating systems in rural Bulgaria. The project will make the fuel switch in two sites by rehabilitating building structures, replacing heating systems, and arranging for the provision of wood fuel. The project design will be built on the outcomes of the Restructuring Study for the National Forestry Board. The overall objective of the Restructuring Study is to provide the MoAF and the Government of Bulgaria with a clearly identified and quantified proposal for the restructuring, reorganization and financial management of the National Forestry Board (NFB) and the Bulgarian Forest Administration. NFB should be enabled to develop into an effective forest management authority, operating in harmony with the environment and tending the forests in accordance with the principles of sustainable forest management (SFM). The proposal should analyze the financial, commercial, social, and environmental advantages and disadvantages of various options and demonstrate the appropriateness of the preferred option. The restructuring proposal will aim at improving the organizational and operational efficiency and financial performance of NFB while at the same time ensuring the continued increase in the long term value of the forests and enhancing their social and environmental roles for the benefit of the people of Bulgaria. Arrangements for the project preparation. The Ministry of Agriculture and Forestry of Bulgaria is the implementing agency for the FDP. A Project Management Unit (PMU) under MoAF, headed by the Project Coordinator, is administering the project preparation and contracting consultants to perform individual preparation studies. In particular, they include (i) general FDP preparation study and the development of the Project Document; (ii) project environmental and social assessments; and (iii) a set of component-specific studies. Preparatory work is mostly funded from the (i) PHRD grant for the preparation of the FDP; (ii) GEF PDF Block B grant for the preparation of the program for GEF financing; and (iii) governmental sources. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. Annex 1 Project Preparation Facility (PPF) The GoB has requested a PPF with expected effectiveness date of January 2004. The packages requested for PPF financing include: * support to the new state forest management company and the state forest administration in terms of technical assistance and training of staff; * preparation of forest roads masterplan; * preparation of timber supply chain process analysis; * assistance in the area of forest fires prevention. The project preparation would also take benefit of the specific studies funded by international donors, such as (i) the study for the National Forest Sector Strategy and Policy - NFPS (FAO and governments of Switzerland and Germany); (ii) study on the development of the National Standards for Sustainable Forest Management; (iii) assessments on the potential for the reduced consumption of fossil fuel (PHRD grant to design climate change mitigation measures); (iv) forest fire prevention and management studies supported by the government of Switzerland; and (v) analysis underlying communal forestry initiatives financed by the GTZ. III. Scope of Work Objective The objective of the assignment is to undertake a full (Category "A") Environmental Impact Assessment of the FDP (including the Fuel Switch Pilot Project), and provide environmental analysis for the NFB Restructuring Study proposals. The EA would: (i) evaluate the project's potential environmental risks and impacts in its area of influence; (ii) examine project alternatives; (iii) identify ways of improving project selection, site, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and (iv) include the process of mitigating and managing adverse environmental impacts throughout project implementation. Environmental Assessment Requirements The EA should be carried out in close collaboration with the consultants responsible for overall project preparation, and through a process that includes consultation with major stakeholders and which provides for comment and input from interested parties. The following regulations and guidelines should guide the EA process and assist in specifying the content of the EA Report: Relevant Bulgarian environmental legislation; World Bank Operational Policy (OP) 4.01: Environmental Assessment; World Bank Operational Policies on Forests (4.36), Natural Habitats (OP 4.04), Pest Management (OP 4.09), and Cultural Property (OP 4.11); World Bank Environmental Assessment Sourcebook (1991) and the October 1993 Environmental Assessment Sourcebook Updates; Tasks Under the supervision of the PMU and MoAF, and in close collaboration with consultants engaged to undertake overall preparation of the FDP, the EA consultant team will: A. Familiarize themselves with the status, trends and institutional capacity for forest management in Bulgaria, as well as the technical, institutional and policy issues related to the preparation of the FDP. In particular, this will entail: Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. 3 January 28, 2004 Annex 1 * Reviewing background documentation, including: - Bulgaria Forest Development Project documentation: Project Concept Document and the associated documents, including the initial Project Integrated Safeguards Data Sheet, the GEF Project Concept Note for the Component on Promotion of Biodiversity Conservation in Forest Management, and the PHRD grant proposal for the Fuel Switch Pilot Project (Annex 1); - the Bulgaria National Biodiversity Conservation Strategy (1998) and the Bulgaria National Biodiversity Conservation Action Plan (2000); - the 1999 MWFEP/World Bank Forestry Sector Note; - the 1994 World Bank/FAO Forestry Sector Review; - the 1995 World Bank Forestry Sector Review; - relevant existing and draft legislation and regulations, including the recent forest legislation, together with progress in adapting by Bulgaria forest related provisions for compliance under the EU Acquis Communautaire; - EU documentation with significance for the development of the Bulgaria forestry sector, including PHARE, SAPARD and ISPA programs; - the EU Forest Strategy; - the World Bank guidelines for the preparation of investment projects, including guidelines for the preparation of Project Appraisal Documents, Project Implementation Plans, and Project Information Documents (Annex 2); - the World Bank Operational Policy 4.01: Environmental Assessment (Annex 3); and the other World Bank safeguard policies - OP 4.04; 4.09; 4.11; 4.36; etc.; as relevant. - FAO guidelines for the development of National Forest Programs. * Reviewing background information on the relevant abiotic and biotic characteristics of the area. This will include review of soils, topography, and hydrology to frame the context for concerns about soil erosion and impacts on aquatic resources. Background information on forests, sensitive forest ecosystems, and threatened and endangered species would help frame the context for forest biodiversity issues. * Reviewing the relevant findings of the NFPS and the study on the restructuring of the Bulgaria National Forestry Board (NFB). * Consulting counterparts and key forestry sector stakeholders, including MoAF, NFB, private and state forest industries, the academic and environmental communities, NGOs, private and communal forest land owner associations, municipalities and local communities (both at the project sites and the potentially affected neighboring areas). * Reviewing technical and strategic development processes and solutions adopted by other countries facing similar forestry sector reform issues. This will include, inter-alia, consultations with the World Bank consultants undertaking the regional review of the experience of forest land restitution. * Reviewing available experience of environmental impact assessments for similar forest sector development operations. This will include, inter-alia, consultations with consultants developing EA update for the Romania Forest Development Project. B. Undertake an Environmental Impact Assessment of the FDP (including the Fuel Switch Pilot Project). Support the development and selection of proposals under the NFB Restructuring Study. In particular, consultants will: (i) Evaluate FDP potential environmental risks and impacts in its area of influence. Both positive and negative, primary and secondary impacts, and their magnitude should be evaluated for all project activities. The assessment should review environmental impacts and risks associated with the construction of forest roads, harvesting, afforestation and reforestation, and other physical investments in the forest sector development, and the proposed administrative, legal and institutional changes. It should also examine the risks to project performance associated with illegal harvesting and problems of governance. Thus, for example, potential negative impacts associated with the construction of forest roads may include: (a) habitat loss and fragmentation; (b) degradation and loss of biodiversity, including species internationally or nationally recognised as threatened or endangered; (c) alteration of drainage and natural hydrologic regime; (d) stream erosion; (e) soil erosion and downstream sedimentation; (f) slope instability and landslides; (g) resultant secondary impacts, such as the additional pressure on Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 4 January 28. 2004. Annex 1 biological resources due to the increased access to formerly remote areas, increased resources extraction and resulting impacts on biodiversity and physical environment, impact of the increased temporary and permanent employment, and etc.; and others. Risks associated with the industrial development of the forestry sector include: (a) increased pollution of air and water and the associated health impacts; (b) risks of soil and groundwater contamination from inappropriate use and/or storage of toxic materials; (c) increased water abstraction and associated conflicts with other water users; (d) increased traffic with associated noise, air pollution and accidents; (e) risk of inadequate measures to protect employee's safety at work; (f) inappropriate waste disposal; (g) land use conflicts between users; and etc. The area of influence of the project activities targeted at strengthening political, institutional and administrative framework for forest management spreads countrywide. The area of influence for site- specific physical investments will be determined in the course of the project preparation. It is expected that the most of physical investments will take place in the Southern part of Bulgaria (regions adjacent to Greece and Turkey), however, it is likely that some other regions of the country will be covered as well. Proposed work plan should take into account the preparation of packages to be financed by a PPF and the need to consider those activities with priority. (ii) Examine project alternatives. Project alternatives considered and the reasons for their rejection should be described in sufficient detail (particularly in the context of the NFPS). The EA will examine positive and negative environmental impacts of two or three alternative project designs. (iii) Identify ways of improving project selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or cotnpensating for adverse environmental impacts and enhancing positive impacts. EA consultants will work closely with the team undertaking the overall preparation of the FDP to strengthen the project's technical design. When needed, they will suggest modifications to the proposed activities to ensure the project's compliance with the safeguard policies of the World Bank (OPs 4.01; 4.04; 4.09; 4.11; 4.36). In that regard, preventive measures should be favored over mitigatory or compensatory measures, whenever feasible. (iv) Design arrangements under the project to mitigate and manage adverse environmental impacts throughout implementation. This would include developing a set of mitigation and monitoring measures, as well as binding recommendations for roads construction/ rehabilitation and for the other environmentally sensitive operations, to be incorporated in the Environmental Management Plan. The program of physical investments under the project will be phased in time throughout implementation. Therefore, it is essential that the EA would (i) provide a thorough framework analysis for such program, (ii) provide analysis for the specific investments defined at project preparation, and (iii) establish procedures and accountability arrangements - through the Environmental Management Plan for the project - to ensure that the adequate environmental safeguards are in place for those investments, which will be defined later in the course of the project implementation. In performing the assignment, EA consultants will cooperate and coordinate with consulting teams engaged under separate TORs to undertake overall preparation of the FDP or carry out specific project-related studies (NFB Restructuring Study, Social and Institutional Assessment, etc.). Working closely with MoAF, PMU and the engaged consultants, the project EA team will collaboratively review the environmental, social, economic and technical analysis undertaken to provide the rationale for activities that would be funded under the FDP. As appropriate, their input will be reflected in the Project Document and the associated project documentation. As needed, the project EA team will work with the MoAF, Ministry of Environment and Water (MoEW), and the other governmental agencies concerned to ensure compliance of the assessment procedures with the national EA requirements. The social analysis for the project will be carried out as part of the Social and Institutional Assessment under separate TOR. However, the results of that analysis should be fully accounted for during the EA and, when appropriate, incorporated in to the Project EA Report. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. 5 January 28, 2004 Annex 1 The FDP would support the identification in Bulgaria of "high conservation value forests (HCVFs)", which is an innovative conservation tool employed under the World Bank - WWF Alliance to promote forest biodiversity conservation. However, the identification and mapping of the HCVFs will be tested and carried in using existing GEF PDF B grant funds and also at implementation and is not part of the present EA assignment. The EA consulting team will undertake the project EA in a fully transparent manner and ensure adequate participation of project stakeholders, both national and in the regions, govemmental and non- govemmental, in the assessment process. The project EA should meet all requirements for public consultation and disclosure for Category "A" projects (see paragraphs 12-16 below). The project is likely to enhance conservation of natural habitats. The EA should review project activities to determine the applicability of the World Bank OP 4.04 (Natural Habitats), identify any potential significant or irreversible impacts the project will have on natural habitats, and propose mitigating measures for those impacts, including a Pest Management Plan. The EA will determine the applicability of the World Bank OP 4.09 (Pest Management) and identify any potential significant or irreversible impacts the project will have on the environment as a result of forest pest management, and propose mitigating measures for those impacts. The EA will also identify any cumulative impacts (when the area is subject to multiple impacts or when more than one World Bank safeguard policy is triggered). Based on their analysis, EA consultants will prepare a draft and final EA Report, which will include an Environmental Management Plan (EMP) - (see below). C. Develop the Project Environmental Assessment Report. The EA Report should focus on the significant environmental issues of the project. The Report's scope and level of detail should be commensurate with the project's potential impacts. The Report should be structured as follows: (a) Executive summary. Concisely discusses in non-technical language significant findings and recommended actions. (b) Policy, legal, and administrative framework. Discusses the policy, legal, and administrative framework within which the EA is carried out. Explains the environmental requirements of any co- financiers. Identifies relevant intemational environmental agreements to which the country is a party. (c) Project description. Concisely describes the proposed project activities and their geographic, ecological, social, and temporal context, including any offsite investments that may be required (e.g., raw material and product storage facilities, access roads, etc.). Indicates the need for any resettlement plan or indigenous peoples development plan. Includes relevant maps showing the project sites and the project's area of influence. (d) Baseline data. Assesses the dimensions of the study area and describes relevant physical, biological, and socioeconomic conditions, including any changes anticipated before the project commences. Also takes into account current and proposed development activities within the project area but not directly connected to the project. Data should be relevant to decisions about project location, design, operation, or mitigatory measures. The section indicates the accuracy, reliability, and sources of the data. (e) Environmental impacts. Predicts and assesses the project's likely positive and negative impacts, in quantitative terms to the extent possible. Identifies mitigation measures and any residual negative impacts that cannot be mitigated. Explores opportunities for environmental enhancement. Identifies and estimates the extent and quality of available data, key data gaps, and uncertainties associated with predictions, and specifies topics that do not require further attention. (f) Analysis of alternatives. Systematically compares feasible altematives to proposed project sites, technology, design, and operation - including the without project situation - in terms of their potential environmental impacts; the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under local conditions; and their institutional, training, and monitoring requirements. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR 6 January 28, 2004. Annex 1 For each of the alternatives, quantifies the environmental impacts to the extent possible, and attaches economic values where feasible. States the basis for selecting the particular project design proposed and justifies recommended emission levels and approaches to pollution prevention and abatement, as needed. (g) Environmental management plan (EMP). The EMP will describe a set of mitigation, monitoring, and institutional measures to be taken during implementation and operation to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. The plan will also include the actions needed to implement these measures. The EA team will (a) identify the set of responses to potentially adverse impacts; (b) determine requirements for ensuring that those responses are made effectively and in a timely manner; and (c) describe the means for meeting those requirements. More specifically, the EMP includes the following components: (i) mitigation, (ii) monitoring, (iii) capacity development and training, (iv) integration of EMP with project and (v) implementation schedule and cost estimates. In more detail, requirements for the EMP are provided in Attachment 2. (h) Appendixes (i) List of EA Report preparers - individuals and organizations. (ii) References - written materials both published and unpublished, used in study preparation. (iii) Record of interagency and consultation meetings, including consultations for obtaining the informed views of the affected people and non-governmental organizations (NGOs). The record also specifies any means other than consultations (e.g., surveys) that were used to obtain the views of affected groups and NGOs. (iv) Tables presenting the relevant data referred to or summarized in the main text. (v) List of associated reports (e.g., resettlement plan or indigenous peoples development plan). (vi) Other Appendixes needed to guide in implementing the Environmental Management Plan. The EA Report should be concise and limited to significant environmental issues. It should focus on findings, conclusions and recommended actions, supported by summaries of the data collected and citations for any references used in interpreting those data. Detailed or uninterpreted data should be presented in appendixes or as a separate volume. The use of tables, graphs, photographs, maps (with coordinates) and other visual aids is essential. Unpublished documents used in the EA, which may not be readily available, should be assembled in an appendix. All information in the Report has to be well referenced. The Report should be submitted in hard-copy and an acceptable electronic format. Public consultation and disclosure In performing the assessment, the EA team consults project-affected groups and local NGOs about the project's environmental aspects and takes their views into account. Project stakeholder groups and concemed NGOs should be consulted (i) at the initial consultation in the beginning of the assignment - to review TOR and identify any outstanding issues that need consideration in the EA; (ii) as needed in the course of the assessment, and (iii) once the Draft EA Report is prepared. Relevant materials should be provided to counterparts in a timely manner prior to consultations. These materials should be presented in the Bulgarian language and in a form understandable to the groups being consulted. Thus, for the initial consultation, the EA team will distribute a summary of the proposed project objectives, description, and potential impacts. When the Draft EA Report is prepared, the EA team will provide for consultation a summary of the EA conclusions. Prior to such consultation, the Draft EA Report should also be made available at a public place accessible to project-affected groups and local NGOs. With the guidance from the PMU, the EA team will also coordinate and consult on the EA-related matters with the involved governmental agencies, and the concerned local and regional authorities. Throughout the assignment, the EA team should record and describe in detail all steps taken to consult with key stakeholders and publicly disclose information about the project. A summary on that work (minutes of stakeholder workshops, records of meetings, substance of communication and comments, and etc.) should be included in the EA Report as an Appendix. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUJFOR. 7 January 28, 2004. Annex 1 EA consultants will finance the required stakeholder and public consultations. IV. Consulting Team Requirements The consultant team should have a proper mix of skills for carrying out the assignment according to the present terms of reference. The EA team should have expertise in the following fields: * Environmental impact assessment, * Detailed knowledge of the environmental issues in Bulgaria and particularly in the Bulgarian forest sector and in biodiversity conservation; * Capacity in assessing environmental impacts of institutional, legal and policy reforms, as well as of illegal logging; * Experience with carbon sequestration projects, * Natural resource management * Experience with participatory approaches, stakeholder consultation and work with NGOs, * Natural resources and environmental legislation, and * High standards in writing reports and networking capacities with other project related consulting teams. Experience in environmental impact assessment of forest operations: harvesting, road development, afforestation / reforestation and good knowledge of the Bulgarian forestry, conservation, and natural resources management issues is essential. Most of the background work and analysis for the EA is expected to be completed by the national experts. National staff assistants for interpretation/translation and other support services shall also be engaged. Suggested team composition: * Team leader - at least 10 years of professional experience, including Environmental Assessment of institutional, legal and policy reform; environmental impacts of illegal logging. * EIA Expert - at least 10 years of professional experience, including Environmental assessment of forestry operations: forest road design/construction, forest harvesting/ transport, afforestation/reforestation, forest fire management; * Senior local expert with at least 10 years of experience, including Environmental Assessment and forestry * Additional experts with the mix of skills described in pt. 18. V. Schedule of Outputs and Payments 21 Consultants are expected to carry out the EA over a period of 5 months (from August 01, 2003 to December, 31 2003) according to the following timetable: * 2 weeks: consultants (i) review background documents, (ii) conduct initial stakeholder consultation to review EA TOR, and (iii) identify any outstanding issues that need consideration in the EA; * 2 weeks: consultants develop an inception report and a work plan for the EA based on their review and stakeholder consultations; * 11 weeks: detailed review of the existing documentation and gathering the required additional data in Bulgaria; local expert workshops to close information gaps; public consultations and stakeholder workshops as needed; development of the Draft EA Report. When prepared, the Draft EA Report will be submitted to the PMU/MoAF for its initial review and comments. Following the PMU/MoAF acceptance of the Draft EA Report, a 4 week period will be required for disclosure and public consultation, in order to ensure that these are credible and effective Enviromnental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 8 January 28, 2004. Annex 1 in disseminating the EA information and gathering additional feedback from stakeholders. In the suggested timeframe consultants will disclose the Draft EA Report, carry out public consultations, and then finalize the Report. The Final EA Report, satisfactory to PMU/MoAF, should be submitted no later than December 19, 2003. The Draft EA Report, and the Final EA Report should be submitted to the PMU/MoAF both in English and in Bulgarian, in hard-copy and electronic formats. Payments under the assignment will be made as follows: 15% - on signing of the contract; * 20% - on the PMU/MoAF approval of the inception report and the work plan; * 40% - on the PMU/MoAF acceptance of the satisfactory Draft EA Report. * 25% - on the PMU/MoAF acceptance of the satisfactory Final EA Report. VI. Other Information In performing the assignment, the EA team will report to the Project Coordinator, Project Management Unit. At all times, as appropriate, EA consultants will seek feedback from the Project Coordinator on their recommendations and proposed activities. The PMU will provide guidance to the EA consultants in coordinating with the concemed govemmental authorities and the line authorities of the MoAF/NFB in the regions. The PMU will also facilitate cooperation between the EA team and the other consultants engaged for the preparation of the FDP. For the purposes of supporting the timely and efficient accomplishment of the preparation work, the govemment would provide the consultants with access to all available relevant data and documentation required to undertake the assignment; access to officials for fact finding interviews; and all permits necessary for the consultants to do the assignment. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaeia, prepared by INDUIFOR. 9 January 28, 2004. Annex 1 Attachment 1 Activities of the Bulgaria Forest Development Project (extract from the World Bank Project Concept Document) The project would support the following activities: 1. Strengthening Public Forest Sector Management 1.1 Reform and Strategic Development of Forest Administration. Picking up from the national Forest Sector Strategy and Policy, the project would finance reforms of the forest administration which will require a full study on NFB restructuring. This would include (i) analysis of present situation, including costs and revenues, forest products marketing and pricing mechanisms, human resources and personnel; (ii) preparation of alternative models for restructuring NFB for discussion by stakeholders; (iii) selection of preferred model by Government and stakeholders according to defined rules; and (iv) development of a phased plan with financial details for reforming and strengthening NFB institutional capacities, and for improving operational and commercial efficiency while simultaneously safeguarding public interest and ecological services. 1.2 Building and Strengthening Nationwide Forest Extension and Inspection Services. Based on the results and decisions regarding the restructuring of the forest administration, the project will support the capacity of the forest administration at headquarters, regional offices, and district level to provide enforcement of forestry use regulations and laws, as well as to provide extension services to private and municipal forest owners. The project would fund (i) training ; and (ii) equipment (vehicles, office furniture and equipment, communication equipment, and demonstration equipment to improve reach out to forest owners). 1.3 Building and Strengthening a Nationwide Forest Fire Management System. In coordination with ongoing efforts a strategy for fire management is presently being developed and is expected to be finalized soon. The project would support investments to make such a strategy operational. Concrete investments would deal with (i) fire prevention (fire awareness campaigns); (ii) fire pre-suppression including measures spelled out by the forest management plans (firebreaks, and firefighting roads), and the building of a modem GIS based fire forecast system; (iii) fire suppression including improved detection (watchtowers) and communication (TA to design the system, and equipment), training of national, regional and local forest fire organizations, fire fighting equipment. 1.4 Developing a GIS based Forest Information and Monitoring System, Including Updating of National Forest Database. The project would support designing the system, possible data conversion, basic office furniture and equipment, including computers, software, printers, fax machines etc., for headquarters, regional and local offices. 1.5 Establishing a Central Capacity for Marketing Information and Promotion of Bulgarian Forestry Products. The project would support investment in a Forest Sector Business Center (FBSC) which should be an independent business development and advisory body to develop the linkage between forest owners and the forest products market in general. The project would support design of a business plan, concentrating on the development of a self-financing mechanism, including funding of partial operational costs for the duration of the project. Funds would further be provided for developing office space, web based information, and related equipment. 2. Strengthening of Capacities of Private and Communal Forest Owners for Sustainable Forest Management 2.1 Fostering Emergence of a Representative Association of Private and Communal Forest Owners at the National Level. The new private and municipal forest owners will need coordination and a lobbying voice to ensure their participation in future forestry policy at the national level. Such an organization would further provide technical and legal assistance to help forest owners settle Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 10 January 28, 2004. Annex 1 difference with the state administration but also amongst themselves. The project would support investments in analyzing the long-term financial sustainability of the association and assist the association with drafting of a 5 year business plan. Investments would also be made in headquarters and regional representative offices including offices furniture and equipment, as well as computers, software, printers, fax machines. Funding would further be provided for core staff salaries and training in managing a successful and representative member organization, and cover partial operational costs for the duration of the project. Investments would be decided in consultation with other donors active in the forestry sector in Bulgaria. 2.2 Supporting the Establishment of Community Based and Communal Forest Owners Associations. To take advantage of economies of scale, particularly for small forest owners, the project foresees the formation of forest owners associations. The project would finance a matching grant scheme to foster the establishment of new associations, including support for preparing statutes and registration. The funds provided would go towards the development of a business plan and basic training for members of the new associations and support the preparation of forest management plans. The grant would further finance office furniture and equipment, including computers, internet access, software and printers as well as provide basic field equipment not covered by SAPARD funding. 2.3 Supporting Participation of Forest Owner Associations in SAPARD Program. Recent articles in local news papers point to the fact that the large majority of small landholders, including forest owners in Bulgaria will be unable to complete the application forms to access SAPARD funds. The project will support preparation of SAPARD applications, including the preparation of business plans, investment calculations. To facilitate the process further, the Project, in conjunction with the Rural Investment Project currently being identified, will provide a matching grants/credits scheme to help small holders in financing their own share in SAPARD measures. 2.4 Pilot Certification of Forests Under Management of New Forest Management Associations. To maximize the value of any wood extraction, and in line with completed management plans, the project will support the certification of privately held forest tracts. Direct grants would be provided to new forest owners to cover the costs to undertake the certification process. 3. Adapting State Forest Management to Market Economy and to New Realities Arising from Forest Restitution 3.1 Establishing and Developing a New State Forest Enterprise. This component will provide the necessary support to assist the Bulgarian govemment in splitting the current commercial function in the forestry sector from the policy making and regulatory activities. Concretely this means the implementation of the NFB restructuring plan as selected under sub-component 1.1, including logistical support in terms of vehicles, and equipment and development of human resources required to sustainably manage state forest and allocated non-core functions. The project would also finance installation of a GIS based information management, planning and monitoring system which is linked to all levels of the forest administration and provides interactive access to decentralized structures. Further the project would support the development of an advanced accounting system for tracking and recording costs and benefits of core and public good functions; and improvement of marketing, pricing, trading capacities for maximizing revenue generation from selling of forest products. Lastly, support would be provided for the development of Human Resources and the design of social packages for mitigating consequences of change process available. 3.2 Rehabilitating and Optimizing Forest Road Network to Minimize Harvesting Damage and, Reducing Operation Costs and Minimizing Fire Hazards as well as Relieving Pressure from Over- Exploitation. Extraction of wood from many Bulgarian forests is very costly and causes great damage to remaining stands due to very poorly maintained or inexistent forest roads. The project would therefore finance the development of an infrastructure master plan and identify priority intervention areas and fund rehabilitation and optimization of the road infrastructure in these areas. Simultaneously, these roads will provide fire barriers, cut extraction costs and improve access for forest inspection agents. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. January 28, 2004. Annex 1 3.3 Thinning of Young and Fire Prone Stands. Due to chronic budget shortages, the thinning of large tracts of fairly young stands of mostly pine trees has been neglected putting at risk earlier heavy investments in afforestation. The project, therefore will support financing of the thinning these forest stands. Concretely investments will include, salaries for laborers, as well as chain saws, axes, hand saws and other forestry tools, as well as trucks and equipment to transport the extracted wood and residues from the forests. Simultaneously, this activity is expected to generate significant employment for local communities from where a majority of the labor for these tasks will come. 3.4 Reforestation and Rehabilitation of Destroyed and Devastated Forest Fire Sites. Recent forest fires have destroyed large areas of Bulgarian forests, particularly in the South East of the country. The project would fund reforestation of some of these areas with high environmental significance to help Bulgaria in maintaining its forestry coverage. Investments will include identification of areas with highest benefits, salaries for workers, purchasing of saplings, preparation of the soil, and planting of the saplings in the designated areas, including subsequent early thinnings. This activity will provide significant employment in the areas were the largest and most recent fires have taken place. 3.5 Implement Pilot Certification in Selected State Forests. Similarly and for the same reasons as in the case of forests in private or municipal hands, tracts of state forest would be identified and brought under a certification regime. The project would fund consulting services for the identification, application and certification of the designated forest areas. 4. Promotion of Biodiversity Conservation in Forest Management 1 4.1 Mainstreaming Biodiversity Conservation in Forest Management Planning. There is a need to (i) identify critically endangered forest habitats for priority conservation, (ii) develop a strategy and action plan for the protection of these habitats, (iii) develop guidelines and tools for integrating biodiversity conservation in forest management planning, and (iv) support integration of biodiversity conservation in specific forest management planning activities. The GEF Grant would finance: (i) technical and policy advice to the MoAF, (ii) seminars to ensure participation and coordination of stakeholders (MoAF, Ministry of Environment and Water-MoEW, regional forest administrations, forest management enterprises, nature park administrations, environmental NGOs, research organizations, when appropriate - concemed national park administrations and regional Directorates of MoEW, and municipalities), (iii) cost of the office equipment, (iv) training activities, and (v) publications. 4.2 Integration of Biodiversity Conservation in Forest Management. Sub-component would support (i) building capacity of forest extension and inspection services, (ii) awareness campaigns and training of stakeholders, and (iii) restoration of critical habitats in bumed and degraded forested areas. In particular, financing would be provided for (i) technical advice to MoAF for the assessment of the region-specific capacity building needs, (ii) procurement of the field and office equipment, (iii) establishment of the related infrastructure facilities, (iv) training for the personnel of the MoAF and the local field inspection teams, and (v) costs of targeted fire prevention, management and enforcement operations and habitat restoration activities. Small grants would also be made available to NGOs, municipalities, private forest owners and their associations, and nature parks to locally undertake public awareness and stakeholder coordination initiatives, as well as targeted conservation interventions. 4.3 Strengthening the System of Protected Areas under the Jurisdiction of the Ministry of Agriculture and Forestry. Project activities would target at (i) improving planning, monitoring, and coordination for nature parks at the national level, and (ii) strengthening the capacity of individual nature parks to preserve critical habitats, including capacities to undertake biodiversity monitoring, forest fire prevention and management, and infrastructure development. Grant financing would cover (i) policy and technical advice to MoAF, (ii) procurement of the field and office equipment, (iii) staff training, (iv) small civil works, and (v) costs of the targeted conservation programs. ' The Component would be funded by a grant from the Global Environment Facility. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 12 January 28, 2004. Annex 1 4.4 Development of the Bulgaria Protected Areas Endowment Fund. The objective of the Protected Areas Endowment Fund is to secure stable and adequate long-term financing for the development and successful operation of the Bulgaria's protected area system. The Fund would complement direct budgetary support to protected areas and finance infrastructure and other capital investments, park management and tourism development projects, and other development programs for protected areas. This Fund would be build on the already existing National Trust Eco Fund (NTEF) set up in 1996 and for which the established management structures exist. The Fund would support protected areas in four forms: (i) grants to park directorates; (ii) payments to private contractors for goods and services provided for protected areas; (iii) loans to the private sector where operations are directly related to beneficial practices in protected areas; (iv) matching grants to villages, associations, municipalities, NGOs, which invest in activities that benefit protected areas. The Fund is expected to be an independent trust managed by the NTEF - a financial mechanism prescribed within the national environmental legislation. The fund-raising objective of the Fund would be to achieve a sufficient size to guarantee that the capital costs and development needs of national protected areas are met on a sustainable basis. The Fund would also be replenished with resources coming from (i) domestic and international private sector organizations, (ii) government of Bulgaria, and (iii) international multi- and bilateral donors. The focus of the activities and priority projects to be funded under the Fund will be determined further during project preparation. 5. Enhancing Carbon Benefits from Bulgarian Forests 5.1 Improved Forest Structure by Promoting Use of Biomass. For the time being, thinnings extracted from forests have been left to rot on piles within the forest. Examples elsewhere have shown that with proper technology, such residues can provide valuable fuel for use in boilers, in public buildings and municipal heating systems who presently rely on fossil fuel. The project would finance feasibility studies and implementation for the conversion of technology from current fossil fuel burning boilers to bio-mass fired units. Investment would include chipping equipment and the building of storage facilities, boilers and other equipment needed for this fuel-switch. 5.2 Carbon Targeted Afforestation. As indicated above, afforestation with fast-growing species may be attractive when it combines environmental benefits on certain sites. The project would support limited afforestation in areas where the sum of environmental, financial, and landscaping benefits would make such investments economically feasible. 6. Project Management and Monitoring To provide project oversight and policy guidance during implementation, a Project Oversight Committee (POC) would be established at the level of the Ministry of Agriculture and Forestry in collaboration with the Ministry of Finance, the National Forestry Board, and the Ministry of Environment and Water. 6.1 Project Management. The project will finance operation of a Project Management Unit (PMU) within the MoAF with overall responsibility for the implementation of the project including procurement, disbursement, maintenance of project accounts and coordination of implementation. Permanent staffing would include a project manager/coordinator, a procurement specialist and a financial manager supported by an administrative assistant. These staff would be complemented by technical specialists for issues relating to forest management, communications and information technology, training and public relations and other issues that may arise during implementation on a contractual basis at market competitive rates. The PMU would be responsible to ensure the proper implementation at the regional and district level by working closely with the National Forestry Board. The PMU has been established and will administer FDP preparation activities. 6.2 Project Monitoring. The PMU will be responsible for monitoring the progress of the project based on a comprehensive system of indicators to be developed during project preparation, and provide quarterly implementation reports and activity plans in a format acceptable to the World Bank. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 13 January 28, 2004. Annex 1 Bulgaria Fuel Switch Pilot Project (Extract from the PHRD grant proposal) Grant Amount (US$) 891,660 Development Objectives The objective of the grant is to define the actual costs and benefits of switching fuel from fossil fuels to wood in medium-sized municipal building heating systems. While wood was the prevalent fuel source for heating buildings prior to WWII, high subsidies for fossil fuel introduced under the centrally- planned economy caused many wood-burning systems to be replaced by highly-polluting and low- efficiency heavy oil and coal heating systems. Grant Beneficiaries & Scope Grant beneficiaries would be rural municipalities which have an abundance of young forest resources or are located in densely forested areas and import much of their heating fuel at very high cost. Most of these towns suffer from disproportionately high unemployment after the collapse of much of the local industry and agriculture and suffer under the burden of high energy costs for heating of municipal and other public buildings ever since energy prices were liberated. Other beneficiaries would be municipal, state, and private forest owners who lack market opportunities for low quality thinning products and carry high financial burdens for maintaining quality of young forests. With the move to a market economy, prices gradually adjusted and imported fossil fuels have become unaffordable. The technology from modem, efficient wood-burning systems has the potential to offer a solution to this dilemma. The cost of good forest management is also defrayed by creating a market for wood residues from thinning operations. While increasing adoption by municipalities in western Europe, the link between forest management and wood use as a renewable energy source is a new concept in Bulgaria. This source could solve the problem of how municipalities will finance their heating bills as they are faced with reduced energy subsidies. Activities under this pilot are crucial to answering the questions of financing the current cost of heating for municipalities as the central government gradually withdraws its funding. The designing and construction of these two pilot facilities, and the subsequent monitoring of their operations and costs will serve as model for replication under the Forestry Development Project. It is for this reason that significant resources are being spent on design, installation, and the close monitoring of operations for a couple of years under varied situations (i.e.: different wood types, various transport distances for wood chips, various storage systems, etc.). With the data on operations and costs obtained under these pilots and lessons into the additional fuel switches to be undertaken under the Forestry Development Project, the private sector should become interested in financing further fuel switches beyond the Bank-funded project. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 14 January 28, 2004. Annex I Description Of Grant Components Component A Design and Feasibility Studies for Fuel Switch Options Estimated Cost (US$) 44,550 Studies will include an initial site identification activity using a participative method and a set of criteria such as forest dependency of the local population, land availability for forest plantations, technical, economic, social, and environmental suitability, suitability of public buildings. From five preselected sites, the two most suitable will be selected for implementation of the proposed activities. Once the sites have been chosen, detailed feasibility studies including economic, financial, social and environmental impacts will be undertaken. The calculations will include the details of the economics of fuel switching and using wood thinnings and plantations of fast growing tree species, in a rotational pattern, to supply the necessary fuel for the operation of the heating systems. This analysis is particularly important and will be applied to answering the question of financing the current costs of heating for municipalities as the central government withdraws its funding. Deliverables/Outputs 1. Location identification studies. 2. Manual on operations of boiler/heating facilities. 3. Detailed Feasibility Studies for two sites. 4. Environmental Impact Study. Component B Heating System Switches - 2 sites Estimated Cost (US$) 325,000 The Grant would fund the conversion of heating systems of public buildings from consuming fossil fuel to a modem, fuel efficient/low pollution wood chip burning installation in two selected sites. Investments in goods would include a new burner and boiler system with necessary controls, facilities, and peripherals; a storage space or silo; and an automated conveyor mechanism from the silo to the burner/boiler, including maintenance and incremental operating costs for a period of three years. The grant would also finance a report evaluating the energy efficiency evaluation of the buildings to be equipped with boilers under the pilot, including concrete proposals for maximizing energy efficiency gains with minimal investments, provide financing for works to implement the energy saving repairs/ rehabilitation. As the proposal seeks to introduce this new technology to Bulgaria, there is not yet a willingness to borrow for it technology. Therefore, the demonstration and dissemination workshops in Component E are critical for the sustainability of the investments under this component. Deliverables/Outputs 1. Acquisition of two fully functional heating systems, (including burners and boilers, controls, peripherals and facilities, including storage or silo) fully tested with all documentation and plans 2. Complete energy efficiency review report of the buildings freshly equipped, with detailed list of investments and estimated efficiency gains achieved. 3. Completed works on the refit/rehabilitation of buildings. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 1 5 January 28, 2004. Annex 1 Component C Securing the Fuel Supply Chain Estimated Cost (US$) 303,000 This component will finance the afforestation or reforestation of certain areas with fast growing species such as Rubinia in a rotating pattern which will eventually provide the supply of energy to the municipal heating system. The areas to be planted will be approximately 60 ha for each site. A second element to be financed under this component would be the removal of thinning residues extracted from forests under the standard forestry management plan to be chipped on site for transport to silo in proximity of the boiler unit. Some small thinning equipment will be purchased with the grant such as chain saws, axes and hand saws, cables and forestry chains and other small tools and equipment to get the thinned wood to the mobile chipper. To supply the wood chips, two mobile chipping machines including their operation and maintenance costs for the same period would also be covered. The grant would also finance loading and transport costs of chips from thinning sites to the storage silo. A third sub-component covers forest fire protection and would be split between demonstration works and equipment. A significant demonstration works activity in which basic fire prevention measures will be undertaken and demonstrated, including cleaning of fire strips, forest roads and removal of excess underbrush, establishing fire breaks, and precautionary burning. Equipment needed for this activity include personal fire protection gear and a basic water pump system. Deliverables/Outputs 1. Selected forest areas thinned in line with forest management plan using new more efficient thinning techniques and chipping of materials 2. Procurement of two wood chippers, chain saws, cables and other basic logging materials. 3. Identification and planting of specific areas with fast growing species in 12 year rotating pattern. 4. Procurement of basic fire equipment, and the clearing of fire strips Component D Harnessing the Carbon Market Estimated Cost (US$) 38,650 The positive impacts of the fuel switch will be enhanced through potential sales of carbon credits. To make an application to the Prototype Carbon Fund (PCF) possible, the grant will make available financing a detailed baseline study which accurately calculate the potential carbon credits made available under the fuel switching proposal but also what the potentials are for such a switch country wide. Lastly, a monitoring plan would be drafted which would design and propose precise monitoring indicators which will help quantify the ultimate carbon credits and overall benefits of the project. Deliverables/Outputs 1. Carbon baseline study 2. Development of a set of detailed monitoring indicators Component E Dissemination/Public Awareness Initiative Estimated Cost (US$) 56,900 This component will finance the compiling of lessons learned under the pilot project and develop guidelines for the development of similar switches across the country. Similarly, this component will finance a public awareness campaign including the printing of leaflets, a mass-media campaign on radio or television, as well as the design of a web-page providing detailed account on the process of fuel switching in the two pilot sites. Dissemination at the government level, especially for interested municipal governments, will be made through 5 workshops of 2 days each and consisting of 50 participants representing the full spectrum of stakeholders with on site visits of the rotating plantations and boiler installations, and refurbished buildings with technical details and costs. These workshops are the most vital part of the proposal as they are the means of information dissemination and project sustainability as this is a pilot activity. It is envisioned that two workshops would be held at each site throughout the three-year project period and one workshop would be held in the capital with the government as the main audience. Deliverables/Outputs 1. A set of operational guidelines for replication 2. A mass media campaign 3. Presentation of 5 workshops with 50 stakeholders each 4. Development of a public information web page Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 16 January 28. 2004. Annex 1 Component F Grant Management Estimated Cost (US$) 42,500 This component will establish a management unit capable of managing the grant, trained with staff who can undertake the necessary analysis expected to be generated from the pilot project. Resources would pay for the incremental costs of the consultant services of a project manager, procurement officer, and an accountant on a part-time basis; purchase an effective work station with the minimum essential equipment (a computer, copier, fax machine); cover the transportation expenses from Sofia to the two selected sites, including subsistence; and other administrative expenditures. Lastly, the grant would fund detailed auditing of the project accounts. Deliverables/Outputs 1. Implementation Schedules 2. An operational plan 3. A procurement plan 4. Project progress reports 5. Annual audit reports 6. Procurement of basic office equipment Component G Other studies Estimated Cost (US$) 81,060 Deliverables/Outputs Studies and analytical material for achieving the objectives of the grant Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 17 January 28, 2004. Annex 1 Attachment 2 ENVIRONMENTAL MANAGEMENT PLAN A project's environmental management plan (EMP) consists of the set of mitigation, monitoring, and institutional measures to be taken during implementation and operation to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. The plan also includes the actions needed to implement these measures. Management plans are essential elements of EA reports for Category A projects. To prepare a management plan, the EA design team (a) identify the set of responses to potentially adverse impacts; (b) determine requirements for ensuring that those responses are made effectively and in a timely manner; and (c) describe the means for meeting those requirements. More specifically, the EMP includes the following components. Mitigation The EMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels. The plan includes compensatory measures if mitigation measures are not feasible, cost-effective, or sufficient. Specifically, the EMP (a) identifies and summarizes all anticipated significant adverse environmental impacts (including those involving indigenous people or involuntary resettlement); (b) describes-with technical details-each mitigation measure, including the type of impact to which it relates and the conditions under which it is required (e.g., continuously or in the event of contingencies), together with designs, equipment descriptions, and operating procedures, as appropriate; (c) estimates any potential environmental impacts of these measures; and (d) provides linkage with any other mitigation plans (e.g., for involuntary resettlement, indigenous peoples, or cultural property) required for the project. Monitoring Environmental monitoring during project implementation provides information about key environmental aspects of the project, particularly the environmental impacts of the project and the effectiveness of mitigation measures. Such information enables the borrower and the Bank to evaluate the success of mitigation as part of project supervision, and allows corrective action to be taken when needed. Therefore, the EMP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts assessed in the EA report and the mitigation measures described in the EMP. Specifically, the monitoring section of the EMP provides (a) a specific description, and technical details, of monitoring measures, including the parameters to be measured, methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and definition of thresholds that will signal the need for corrective actions; and (b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures, and (ii) fumish information on the progress and results of mitigation. Capacity Development and Training To support timely and effective implementation of environmental project components and mitigation measures, the EMP draws on the EA's assessment of the existence, role, and capability of environmental units on site or at the agency and ministry level. If necessary, the EMP recommends the establishment or expansion of such units, and the training of staff, to allow implementation of EA recommendations. Specifically, the EMP provides a specific description of institutional arrangements-who is responsible for carrying out the mitigatory and monitoring measures (e.g., for operation, supervision, enforcement, monitoring of implementation, remedial action, financing, reporting, and staff training). To strengthen environmental management capability in the agencies responsible for implementation, most EMPs cover one or more of the following additional topics: (a) Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 18 January 28, 2004. Annex 1 technical assistance programs, (b) procurement of equipment and supplies, and (c) organizational changes. Implementation Schedule and Cost Estimates For all three aspects (mitigation, monitoring, and capacity development), the EMP provides (a) an implementation schedule for measures that must be carried out as part of the project, showing phasing and coordination with overall project implementation plans; and (b) the capital and recurrent cost estimates and sources of funds for implementing the EMP. These figures are also integrated into the total project cost tables. Integration of EMP with Project The borrower's decision to proceed with a project, and the Bank's decision to support it, are predicated in part on the expectation that the EMP will be executed effectively. Consequently, the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities, and it must be integrated into the project's overall planning, design, budget, and implementation. Such integration is achieved by establishing the EMP within the project so that the plan will receive funding and supervision along with the other components. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. 19 January 28, 2004. Annex 1 Attachment 3 LIST OF ANNEXES TO THE TOR Annex 1. Bulgaria Forest Development Project documentation: Project Concept Document and the associated documents, including the initial Project Integrated Safeguards Data Sheet, the GEF Project Concept Note for the Component on Promotion of Biodiversity Conservation in Forest Management, and the PHRD grant proposal for the Fuel Switch Pilot Project. Annex 2. The World Bank guidelines for the preparation of investment projects, including guidelines for the preparation of Project Appraisal Documents, Project Implementation Plans, and Project Information Documents. Annex 3. The World Bank Operational Policy 4.01: Environmental Assessment. OP 4.36: Forestry, OP 4.04: Natural Habitats, OP4.09: Pest Management, OP 4.11: Cultural Property. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 20 January 28, 2004. ANNEX 2 Field Trips Annex 2 FIELD TRIP ON 30-31 OCTOBER, 2003 - BLAGOEVGRAD REGION Jussi Lounasvuori, Dimitar Stoev, Grud Popov, Spas Todorov, Neli Doncheva lst day 10.00 Visiting the office of "Rila" National Park 10.00 - 12.30 Meeting with the Director of Blagoevgrad RFB - Mr. Svetoslav Michailov 12.30 - 14.00 traveling + lunch (at Simitli SF/ "Predela" place) Host: Chief accountant of Simitli SF 14.00 - 16.30 1) Field visits ("Betoloto" place - area of severe illegal logging activities and subsequently devastated by forest fire) 2) Meeting with a local NGO "150 women" (from Razlog town; speaker - Maria Tumbeva) and guard from "Pirin" National Park 16.30- 18.00 traveling 18.00- 19.30 Meeting the Vice-director of "Dikchan" State Game Breeding Station - Mr. Plamen Kalojanov Dinner and overnight DOLEN Village - Architectural Reserve 2nd Day 9.00 - 13.00 Field visits: - forest roads under construction - thinning 13.00 - 15.30 Traveling 15. 30- 17.30 Meeting the Staff (biodiversity expert, chief accountant, PR expert and forest expert) of "Rila Monastery"Nature Park at the administrative building of the Directorate; Field visits of the Nature Park - "Partizanska Poliana" place and Rila Monastery Return Journey to Sofia Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by [NDUIFOR. January 28, 2004. Annex 2 FIELD TRIP ON FUEL SWITCH INSTALLATIONS, 19 NOVEMBER 2003 1. Visit to the Municipality of Apriltzi, Project "PHARE Program Biodist" * Owner of the installation: Municipality of Apriltzi (Mayor: Mr. Ivan Pirov) * Address: 5641 Apriltzi, district Lovetch, tel. +359 6958 2222 * Use of energy produced: Heating of a school, a hospital, the municipality building, etc. The installation replaces about 40 ovens used before, saving about 50 % of the former heating cost. * Licences/authorizations (e.g. emissions in the air): Not needed for installations with capacity less than 5 mW. * Fuel quality and amount used per year: Dry wood chips, which is waste wood originating from local mechanical wood industries. * Consumption: 150kg per hour, no annual figures were available, because the installation is new. Note: The municipality is planning to complete the fuel acquisition with waste wood from local wood slashing and timber cutting operations (fresh wood). * Storage of fuel: Large storage room for chips at ground level. No soil pollution was observed. * Liquid fuel tanks: N.A. * System for refilling the tanks, security system, leaks: Wood chips dumped by truckloads. * Disposal of unbumed waste: Ash distributed to pastures as fertilizers (only small amounts produced, they said). * Boiler: Polytech (Made in Austria) * Maintenance of boiler: Cleaning of the pipes done every 300 hours, when conifer chips are used (less often with hardwood chips). * Preparedness for accidents: The installation is automatic/semi-automatic, and it is equipped with a control system manufactured by Siemens (Germany). Should a technical problem occur, an alarm is triggered and the process is automatically interrupted. Only one person is employed for surveillance and control functions. Feeding of chips goes automatically (spiral feeder). * Note: this installation means rationalization and has a "negative" impact on local employment, as compared with the situation before. Many people were employed with heating before the boiler came. 2. Visit to Municipality of Teteven Hosts: Mr. Todor Ivanov Todorov, Secretary General; Mr. Sergei Simeonov, Forest Officer. Also present: Mr. Angel Ivanov, General Manager, Vitales JSC (local forest industry company), and Mr. Christo Christov, Director, Energy Institute JS Co., Sofia. Focus of the visit was in the discussions concerning the prerequisites, opportunities and consequences of the fuel switch process being planned by the Fuel Switch Project. Teteven has a large amount of restituted private forests. Their proportion is one of the highest in Bulgaria. Population of the city is 12500, and additional 12500 people are living in the rural areas of the municipality. The municipality owns 18600 ha of forests, which is 57 % of the local forest fund. Main tree species are: Beech 80 %, Conifers 13 % and Oak 7 %. Annual growth is about 100 000 cu.m. These forests are managed by the Regional Forestry Board and Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. Annex 2 the municipality. Forestry operations are performed by contracted enterprises under the control of the RBF. Forestry and forest industries are important elements of the local economy. All wood processing industries are in private hands. Unemployment rate is 19 %. There is plenty of waste wood for chip-making available, and the prices are: 22 BGL per cu.m. for wood-chips (non-delivered), and about 30 BGL delivered. Spare-wood, i.e. potential for additional fuel for the switch was estimated as follows: a) from municipal forests: waste wood is now left in forest, e.g. waste wood from thinnings is about 40 000 cu.m. per year (up to 60 000 according to cutting plans); b) from forest industries: "about 10 ton per day" (around 3000 ton per year) In Teteven, the Fuel Switch Project plans to change four central heating systems, switching from oil to wood chips boilers, (350 kW each) Currently the four boilers are more than 20 years old, still in good condition, and used for the heating of a Technical College, a Gymnasium, the College of Forestry and the Town Hall. Each of them is now heated with fossil oil burners. Oil consumption is 182 500 litre per year, and the corresponding cost is 137 000 BGL per year. Envisaged savings after the switch is 80 000 BGL per year. Envisaged amount of C02 replaced: 471 ton per year. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 3 January 28, 2004. Annex 2 FIELD TRIP IN THE REGION OF LOVECH RFB Sipi Jaakkola, Jussi Lounasvuori, Nellie Doncheva lst Day (Tuesday, 25.11. 2003) 1) Monastery of Troyan 2) Meeting/discussion in the Exhibition hall of the Museum of Natural History, Oreshaka village (Appendix 1) 3) Lunch 4) Field visits - cable logging operations, forest roads 5) Dinner 2nd Day (Wednesday, 26.11.2003) 1) Visit in "Lesoplast" Factory -Troyan town 2) Visit in Borima SF (Meeting the Director - Sasho Vasilkov and the Vice-Director - Mariana Ivanova) 3) Visit in Teteven SF (Meeting the Director - Ilia Mitov and the Vice Director, forest guards etc.) - Illegal logging - Quercus rubra plantation - Temporary nursery in Quercus cerris stand - Reforestation (Quercus cerris+Quercusfrainetto+Tilia sp.) 4) Teteven town: boilers in the Municipal building and in a Hotel. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by [NDUFOR. 4 January 28, 2004. Annex 2 LIST OF THE PARTICIPANTS 1) Pavli Bogdanski - Director of Lovech RFB 2) Petko Kanakov - NGO "Friends of Central Balkan National Park" 3) Dimitar Shishkov - Director of Trojan SF 4) Diljana Pironkova - Vice Director of Trojan SF 5) Tzvetomir Simeonov - representative of the Teteven Municipal Forestry 6) Ljubomir Marinov - "Lesprom - Trojan" State Logging Company 7) Ivan Popov - private and cooperative forests association 8) Iordan Antonov - secretary of the Monastery of Trojan / church forests 9) Ivan Nedjalkov - private forest owner 10) Tzvetomir Vasilev - representative of the School for Mountain Guides - "Vasil Levski" & private forest owner 1 1) Georgi Georgiev - Director of Chemi Osam SF Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 5 January 28, 2004. ANNEX 3 Meetings with Stakeholders Annex 3 List of Persons Met during the EA Process Name and Organization Subject Bardarov, Alexander, NFPS Team NFPS Development Bele, Toma, Director, Vitosha Nature Park Nature Park Management Issues Bojinov, Hristo, Director, National Nature Protected Areas Management, Nature Parks, and Protection Service, MEW Biodiversity Conservation Christov, Christo, Director, Energy Institute JSC, Fuel Switch Component of the FDP Sofia Duerr, Christoph, Bulgarian-Swiss Forestry Swiss Contribution to FDP Programme Germer, Carsten, GEF Rhodope Project Linkages between FDP and Rhodope projects Gilliland, John, Restructuring Team Restructuring Issues Goriup, Paul, Consultant, Naturebureau, U.K. GEF Component of the FDP Grigorova, Vania, Director, Department of EIA, EIA legislation, Linkages between the EA and MEW National EIA regulations and procedures Ivanov, Angel, Vitales JSC, Teteven Fuel Switch Component of the FDP Karpowicz, Zbigniew, Consultant, FFI GEF Component of the FDP Kapp, Gerald, Consultant, GFA Fuel Switch Component of the FDP Kormushev, Ivan, Board Member Restructuring Issues Kostadinova, Snejana, Team Leader, Social Safeguards related to Involuntary Resettlement Assessment Team Marinkova, Maria, Karlaka 2001, Ltd., Batak SME logging and forestation operations Mihailov, Mihail, Senior Specialist, MEW Nature Parks and Biodiversity Conservation Mihova, Boriana, Consultant GEF Component of the FDP Mitchell, Andrew (and his team), Team Leader of FDP the FDP Naidenov, Iantcho, Director, Forest Protection Comments on the EA Station (NBF), Sofia Pirov, Ivan, Mayor of Apriltzi Fuel Switch Component of the FDP Plugchieva, Meglena, Vice-minister, MAF EA Implementation Issues Serafimov, Georgiu, Game Breeding Station Current Road Planning Practices "Beglinka", Batak Simeonov, Sergei, Forest Manager, Municipality Forest Management Issues Related to Fuel Switch of Teteven Spiridonov, Geko, Biodiversity Consultant Nature Parks and Biodiversity Issues Stephanov, Antonyi, President, Bulprofor Comments on the EA Sutter, Michael, Consultant, OBF Restructuring as an EA Issue Todorov, Spas, PPU Management of the EA Todorov, Todor, Secretary General, Municipality Fuel Switch Component of the FDP of Teteven Trifonov, Borislav, MAF Restructuring Issues Yonov, Nikolai, National Coordinator, FDP-PPU Day-to-day Management of the EA Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. January 28, 2004. Annex 3 NGO MEETING DECEMBER 16, 2003 Location: FDP office, room 207, Sofia Date: Tuesday, December 16, 2003 Time: 14.00 - 17.30 Hours Attendants: Anelia Stefanova - "For the earth", Andrei Kovatchev - "Balkani" Association, Teodor Todorov - Foundation "Time", Zhivko Bogdanov -representative of WWF - Bulgaria, Veronika Ferdinandova- Bulgarian Society for Bird Protection, Petko Kovatchev - Informational and Training Center in Ecology, Grud Popov, Dimitar Stoev, Jussi Lounasvuori, Neli Doncheva Subject: Discussion of the EIA draft report on FDP 1. Presentation on the findings of the draft EIA Report by Mr. Jussi Lounasvuori 2. Discussion of the draft EIA Report. The following concerns were shared by the different NGO representatives: Anelia Stefanova: A detailed study on the illegal logging is a must. It should not address only the demand and supply of timber at national level but also the issues related to corruption (note that this is already included in the TOR), illegal logging in an international context, imports and exports of timber between the neighboring countries etc. Illegal logging should also be considered when selecting the restructuring model of the National Forestry Board (NFB). Petko Kovatchev: The "Green Balkans" NGO has developed a list of recommendations that have to be considered in the construction of forest roads. This also applies to the Fuel Switch Component. The so-called Golden Standard developed by the WWF, which addresses the climate issues, should be utilized in the Fuel Switch Component. When establishing "energy plantations", local tree species should be used. Andrei Kovatchev: The organizational position of the Nature Parks (NP) should be very well studied and chosen. Whether the NPs are under the planned National State Forest Company (SFC) or not, one has to ensure that their functions are effective and stable. (Comment by Petko Kovatchev: There are conflicts between the environmental protection and biodiversity conservation goals of the NPs and the commercial objectives of the SFC. In addition, the training of the forestry staff in environmental protection and biodiversity conservation needs a special attention. Petko Kovatchev, Andrei Kovatchev, Anelia Stefanova: In order to ensure safeguards regarding forest roads construction, a Strategic Environmental Impact Assessment of the Forest Roads Master Plan (FRMP) is needed. It is required that the FRMP has to be detailed and address issues such as territorial planning, density of the road network, links with protected areas (prevention of the fragmentation), cooperation with stakeholders and others. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. Annex 3 Veronika Ferdinandova: How will the FRMP consider the key habitats and species since the inventory on the critical areas is not carried out?! There is a lack of data. The available information from Corine Biotopes, Natura 2000 and others is not sufficient and adequate for the road planning purposes. The WWF Toolkit for Identification of High Conservation Value Forests and Corine outputs need to be used. Petko Kovatchev: The FRMP will be prepared before the identification of the critical areas, which is wrong. First the critical habitats should be identified and the FRMP should be based on this information. Andrei Kovatchev suggests when identifying critical habitats, unified criteria to be used. Anelia Stefanova: The forest roads should be constructed and concentrated to areas where thinnings and rehabilitation of burned areas are envisaged. Zhivko Bogdanov: The developed Toolkit for Identification of HCVF should be used in the "debated" areas covered by the FDP. Teodor Todorov: Control is the key action that should be ensured. There is a big difference between the intentions, the promises and the real situation. Andrei Kovatchev: Regarding the thinnings, there is a positive impact. The same applies for the reforestations, but the local tree species should be used. Petko Kovatchev: The Fuel Switch Component has not been discussed in the preparation phase of the FDP. The open areas, which might be critical habitats for certain species should not be planted. Zhivko Bogdanov: The certification envisaged in the FDP is not sufficient. We need more certified areas. The National Standard for Forest Certification is not that important. Veronika Ferdinandova: Authorization and legalization of the monitoring activity of the NGOs (for example: monitoring performed by the NGOs on the illegal activities in the forests). Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 3 January 28, 2004. ANNEX 4 Feedback from Bulgarian BirdLife Protection Association t jBBLPA BULGARIAN BIRDLIFE PROTECTION ASSOCIATION P.O. Box 50, Yavorov qt, 71 bl, 4 entr, I apt, 1111 Sofia, Bulgaria Phone (+359 2) 870 75 79, fax (+359 2) 72 26 40 E mail: bspb hq(Cabspb.org Annex 4 143/1000/294-006/23-12-2003 Attn: Indufor Oy Toolonkatu 1 1-A FIN-00100 Helsinki Finland Copy: FDP PPU, NFB Regarding: A standpoint of the Bulgarian BirdLife Protection Association/ BirdLife Bulgaria on the First Draft of EIA Report of the Project "Bulgaria - Forest sector development" Dear colleagues, Thank you for the given opportunity to comment the Final Draft EIA Report of "Bulgaria - FDP". We truly believe that the current cooperation established between the PPU and the NGOs will strenghten more in the future and will be a good premise for a successful restructuring of the Bulgarian forest sector. We enclose our comments in Appendix 1. We are at the disposal of any additional discussions of our proposals. Respectfully, Veronika Ferdinandova BBIPA/Bulgarian BirdLife Protection Association/ Bulgarian Forest work group leader BirdLife Bulgaria and a member of European Forest Task Force/ BirdLife Intemational Sergei Dereliev Nature protection director /BirdLife Bulgaria BBLPA is the partner of BirdLife International in Bulgaria B INTFRNATIONAI. Annex 4 Appendix 1 A Standpoint of the BBLPA/BirdLife Bulgaria on the First EIA Draft Report of Bulgaria FDP / Project "Bulgaria - forest sector development"/ General comments Regretfully, to comment the envoronmental assessment of the project we have to be familiar with the project itself. We did not receive copy of it, since it was in a process of development. Unclear remains the question whether the experts themselves, who have eloborated the environmental assessment, have had access to the project or have assessed its general guidelines. That, as well as the extreemly short term of access of the EA document, could be evaluated as a seriuos breach of the procedures, which leads to non-execution of EA formulated goal. We consider unacceptable elaboration of environmental assessment of pendant draft report. That's the reason for keeping the right for additional comments in receiving the present complete copy of FDP. Specific recommendations 1. Concerning the " Illegal logging supervision and monitoring " and "Strenghtening the state forest sector management" We consider that the esimated rate for illegal logging of 5 % to 15 % is substantially reduced. The data of the NFPS studies shows, that the illegal logging of wood fuel several times exceed the official harvesting. There is no such estimation for the illegal logging of other assortments, but taking into account the illegal logging of construction wood, it could be suggested that this quantity is considerable. For this reason we could recommend to change the appraisal of about 5% to 15% illegal logging to more realisitc figures. A more realistic estimation of this problem would faciliatate its solution. 2. On item 4.5.2 Levels of harvesting. We would recommend to use the definfition "official" or "harvesting under review". That's due to the fact that only the figures for the officialy registered harvesting are known and in practice the complete forest harvesting could be some times larger as a result of poach logging. 3. On item 5.3 With a view to strenghtening the combat with poaching, noted in the ToR about illegal logging study, we would recommend: * Shcemes for change the ways of sale and trace of the sold wood; Suggestions for change the way of sale with a view to economic, not administrative pressure under the illegal logging We would recommend, with a view to strenghtening the combat with poaching, noted in the ToR about illegal logging study: Certification system FSC is the only one worldly imposed system for certification. So we suggest to add certificaton according to system FSC wherever is said about certificaion . BBLPA, as well as the other environmental NGOs in Bulgaria do not accept PEFC certification system. Our categorical opinion is that it's a discredited system which couldn't be imposed with funds from international loans. Taking into consideration that Indufor Oy is well acquainted with PEFC; I think that this standpoint doesn't need more profound argumentation. 4. On item 5.5 We emphatically do not agree with the opinion that the suggested Law on the State Forest Company meets the World Bank requirements for politically independent Management Committee of the enterprise. It makes a very centralized commercial company which in practice is out of the social control. The Management Committee is with full majority of experts, appointed by the Ministry of Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. Annex 4 Agriculture and Forests. There are no Advisory Committees proposed to discuss the business plan of the enterprise. There are no representatives from public and scientific organizatons involved (even with advisory functions). This enterprise would be very accessible to political influences and taking into account its importance to the undeveloped regions of Bulgaria, it could become means in the pre- election compaigns. We propose increase of the number of the company Management Commeittee to 15 members, including two ecological NGOs representatives, as well as academical institutions representartives. We consider that amalgamation of Nature Park boards into the Enterprise would comprise this nature preserving structures. It couldn't be possible one structure to incorporate control and commercial functions. There have already been precedents how aiming trade activities development some Nature Parks boards suggest roads constructon, which would destroy bird's nests of some European endangered species. We propose Nature Park boards to be incorporated into the department of forest administration. We would activilely lobby in the Bulgarian Parliement. We think that unsufficient attention is paid to the risks of afforestation with inappropriate species in regeneration of territories devastated by forest fire. At present to the state forest boards is given the right to decide what will be the selection of spices for afforestation. Unfortunately, that led to mass regeneration with cedars. They are cheap for production and afforrestation, but their negative impact on biodiversity is not taken into consideration at all. We propose to elaborate a Code of the best afforestion practices and address adequately this problem in it. Once again we suggest clarification on the matter of certification and that it will be made according to FSC system. We strongly desagree with any kind of support by the project to impose the PEFC system in Bulgaria. 5. On item 5.6 We will reapeat again that in our point of view the combination between commercial and control functions is unacceptable. We emphpatically consider that the Nature Parks should remain in subjection of the Forest administration and out of the jurisdiction of the Company. In case the Nature Parks are incorporated into the National Forest Company, then the complete GEF component should be reviwed. 6. On item 6.3.1 We consider that the financial restrictions have hindered the Nature Parks Management. The lack of funds of the Nature Park Boards is not in consequence of budget restrictions but the low level of priority of this directon in the NFB management. In comparison with this item could be analized expenditures invested in forest and hunting houses which are extreemly unprofitable. In this case the problem is not that much about the cash, but about its allocation inside the department. Therefore, we think that with the eventual Park incorporation into the Company this problem would not be solved but intesified. 7. On item 7 We suggest the recommendations and additions given by us on items 3, 4, 5 and 6 to be included in the Environment Management Plan, as well as the necessary funds to be provided. We rely on that The BBLA /BirdLife Bulgaria point of view will be taken into account. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 3 January 28, 2004. ANNEX 5 Inception Workshop Annex 5 INITIAL STAKEHOLDER WORKSHOP ON ENVIRONMENTAL ASSESSMENT OF THE FOREST DEVELOPMENT PROJECT Park Hotel Moskva Monday, October 13, 2003 13.00- 17.00 Hours AGENDA until 13.00 Registration 13.00 - 14.00 Opening Session - Chairman: Mr. SipiJaakkola 13.00- 13.10 Opening - Mr. Nikolai Yonov 13.10- 14.00 Presentations on: * Status of the Forest Development Project (FDP) - Mr. Andrew Mitchell * EIA Team - Mr. Grud Popov * Environmental Impact Assessment (EIA) of the FDP - Mr. Sipi Jaakkola * Terms of Reference, Schedule and Work Plan of the EIA - Mr. Jussi Lounasvuori 14.00- 14.30 Coffee break 14.30 - 15.30 Group Work focusing on the stakeholders' expectations on the EIA (main concerns, fears, ways to contribute, etc) Working Group 1: Institutional Reform - Restructuring of the NFB Speaker: Mr. Borislav Trifonov, Facilitator: Mr. Alex Bardarov Working GrouD 2: Forest Management Practices Speaker: Mr. Spas Todorov, Facilitator: Mr. Grud Popov Working Group 3: Biodiversity Conservation in state owned and private forests Speaker: Mr. Toma Belev, Facilitators: Mr. Dimitar Stoev and Mr. Geko Spiridonov Working Group 4: Fuel Switch Project Speaker: Ms. Yeni Katsarska, Facilitator: Ms. Miroslava Dikova 15.30 - 16.30 Presentation of the outcomes from the work in each Working Group Chairman : Mr. Nikolai Yonov 16.30- 17.00 Concluding Session - Chairman: Mr. Nikolai Yonov Stakeholders are informed about the follow-up and reporting of the EIA, and invited to monitor the FDP Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. January 28, 2004. Annex 5 List of participants invited to the Inception Workshop held in the Park Hotel "Moskva" on 13 October 2003 3N9 Name Organization / institution Stakeholder group Dr. Meglena Plougchieva National Forestry Board (NFB) Institutional/administrative I Mr. Ilia Simeonov NFB Institutional/administrative 2 Mr. Nikolay Yonov NFB Institutional/administrative 3 Mr. Georgi Tinchev NFB Institutional/administrative 4 Mrs. Ana Petrakieva NFB Institutional/administrative 5 Mr. Petko Vrachovski NFB Institutional/administrative 6 Kliment Mavrov NFB Institutional/administrative 7 Stoicho Bjalkov NFB Institutional/administrative 8 Ivan Kormushev NFB Institutional/administrative 9 Borislav Trifonov NFB Institutional/administrative 10 Vesna Kimova NFB Institutional/administrative 11 Rosen Popsavov NFB Institutional/administrative 12 Boriska Stoimenova Ministry of Finance Institutional/administrative 13 D. Todorova Ministry of Energy Institutional/administrative 14 Zhaklin Metodieva Ministry of Environment and Waters (MOEW) Institutional/administrative 15 Vanja Grigorova MOEW Institutional/administrative 16 Hristo Bojinov MOEW Institutional/administrative 17 Mihail Mihailov MOEW Institutional/administrative 18 Kalojan Anev MOEW Institutional/administrative 19 Petar Dobrev MOEW Institutional/administrative 20 Mrs. Emilia Stoyanova MOEW Institutional/administrative 21 Gergana Blagieva Regional Environmental Inspection - Sofia Institutional/administrative 22 Ganya Hristova Ministry of Finance Institutional/administrative 23 Elitza Dancheva Ministry of Economy Institutional/administrative 26 Dessislava Mihalkova Ministry of Economy Institutional/administrative 24 Barzilov National Fire Protection Service Institutional/administrative 25 Nikolai Istatkov Ministry of Economy Institutional/administrative 27 Mihail Mihailov Rila Monastery Nature Park Institutional/administrative 28 Toma Belev Vitosha NP Institutional/administrative 29 Georgi Grancharov Pirin National Park Institutional/administrative 30 Vasil Ptrov Rila National Park Institutional/administrative 31 Nela Rachvitz Central Balkan National Park Institutional/administrative 32 Hristoskov State forestry - Sofia Institutional/administrative 33 Juri Minkov State Game Breeding Station - Vitinja Institutional/administrative 34 Milcho Hristov Regional forestry Board - Sofia Institutional/administrative 35 Danail Zhekin Forest Seed Control Station - Plovdiv Research 36 Svilena Bojinova Forest Seed Control Station - Sofia Research 37 Jancho Naidenov Forest Protection Service Research 38 Borislav Bojov Union of the foresters in Bulgaria NGO 39 Rumen Raikov AGROLESPROJECT NGO 40 Kiro Kirov AGROLESPROJECT NGO 41 Hristo Mihailov Bulgarian Union of Hunters and Fisherman NGO 42 Svetla Bratanova Central Laboratory in General Ecology Research 43 National Association of the Municipalities in Grigor Gogov Bulgaria Social sector 44 National Association of the Municipalities in Teodosi Dimitrov Bulgaria Social sector 45 Konstantin Panov Bulgarian Tourist Association NGO - tourism 46 Ventzislav Udev Bulgarian Tourist Union NGO - tourism 47 Peter Petrov Bourgas Regional Tourism Association NGO - tourism 48 Mr. Pavel lliev Pirin Tourist Forum NGO - tourism 49 Association for alternative tourism NGO - tourism 50 Silvia Hinkova Central Balkan - Kalofer Ecotourism Association NGO - tourism Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 2 January 28. 2004. Annex 5 NE Name Organization / institution Stakeholder group 51 George Pamporov National Trust EcoFund Project 52 Dimitar Nenkov National Trust EcoFund Project Biodiversity Conservation and Economic Growth 53 Steve Dennison (BCEG) Project Project 54 Kamelia Georgieva BCEG Project Project 55 Alexander Bardarov National Forest Policy and Strategy Project 56 Simeon Marin NATURA 2000 Project 57 Jus Bach NATURA 2000 Project 58 Kalina Todorova NATURA 2000 Project 59 Ogniana Glavosanova UNDP International organization 60 Carsten Germer UNDP/GEF International organization 61 Gerasim Gerassimov Swiss Development Cooperation Program International organization BSBCP - Bulgarian Swiss Biodiversity 62 Rossen Vassilev Conservation Project Project 63 Martin Borissov German Bulgarian Forestry Project Project 64 Vasil Stiptzov Bulgarian Swiss Forestry Project Project 65 Cnristoff Duerr Bulgarian Swiss Forestry Project Project 66 Hristo Nikolov Green Balkans Environmental NGO 67 Jivko Bogdanov WWF BULGARIA Environmental NGO 68 Zheko Spiridonov Wilderness Fund Association Environmental NGO 69 Simeon Nedyalkov Association of BG Ecologists Environmental NGO 70 Veleslava Abadjieva Time - Ecoprojects Foundation Environmental NGO 71 Elena Tzingarska Balkani Association Environmental NGO 72 Andrei Kovachev Balkani Association Environmental NGO 73 Latinka Topalova Student Club for Environmental Piotection Environmental NGO 74 Petar Jankov Bulgarian association for Bird Protection Environmental NGO 75 Anelia Stefanova Ecological association FOR THE EARTH Environmental NGO Bulgarian Association of producers of herbs and 76 Desislav Dionisiev mushrooms Economic function Bulgarian Chamber on Wood-processing and 77 Kalin Simeonov Furniture Industry Forest industry 78 Antonii Steanov BULPROFOR NGO 79 Svetoslav Avramov Union of forest trade companies in Bulgaria Forest industry 80 Anelia Pochekanska Cooperative "GORA" Non-state forest owners Federation of the trade-union organisations from 81 Petar Abrashev the forestry and wood-processing industry Social function 82 Nikolo Parlikov Bulgarian Forestry Chamber Non-state forest owners 83 Ivanka Dushkova Union for Development Social function 84 Katia Pavlova University of Forestry Education & research 85 Dilianka Bezlova University of Forestry Education & research 86 Georgi Zhekov University of Forestry Education & research 87 Kiril Bogdanov University of Forestry Education & research 88 Milko Milev University of Forestry Education & research 89 Georgi Kostov University of Forestry Education & research 90 Georgi Rafailov University of Forestry Education & research 91 Puhalev University of Forestry Education & research 92 Alexander Alexandrov Forestry Institute Education & research 93 Ivan Raev Forestry Institute Education & research 94 Bulgarian Church NGO 95 Bluelink Network - about 400 NGOs are informed NGO Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 3 January 28, 2004. Annex 5 List of the participants in the Inception Workshop held in Park Hotel "Moskva" on 13 October 2003 NE Name of the participant Organization / institution Stakeholder group 1 Rosen Popsavov National Forestry Board Institutional/administrative 2 Emil Rakadjiev National Forestry Board Institutional/administrative 3 Elitza Dancheva Ministry of Economy Institutional/administrative 4 Boriana Hristova Ministry of Environment and Waters Institutional/administrative 5 Hristo Bojinov Ministry of Environment and Waters Institutional/administrative 6 Lilia Bogdanova Ministry of Environment and Waters Institutional/administrative 7 Valentina Nikolova Ministry of Environment and Waters Institutional/administrative 8 Rumiana Getovska State Game Breeding Station "Vitinja" Institutional/administrative 9 Toshko Petkov State Game Breeding Station "Vitinja" Institutional/administrative 10 Mihail Mihailov "Rilski Manastir" Nature Park Institutional/administrative 11 Tzvetomir Simeonov National Association of the Municipalities Social sector 12 Prof. Alexander Alexandrov Forestry Institute/ Bulgarian Academy of Education & research Sciences 13 Prof. Georgi Puhalev University of Forestry Education & research 14 Dobromir Borislavov student at the University of Forestry Education & research 15 Georgi Zhekov University of Forestry Education & research 16 Prof. Georgi Rafailov University of Forestry Education & research 17 Assoc. Prof. Katinka Mihova University of Forestry Education & research 18 Svilena Bojinova Forest Seed Control Station - Sofia Research 19 Jancho Naidenov Forest Protection Service Research 20 Svetla Bratanova Central Laboratory in General Research Ecology/Bulgarian Academy of Sciences 21 Jens Bach Project Natura 2000 Project 22 Simeon Marin Project Natura 2000 Project 23 Alexander Bardarov National Forest Policy and Strategy Project 26 Kristoph Duerr Bulgarian Swiss Forestry Project Project 24 Ognjana Glavushanova UNDP Intemational Organization 25 Carsten Germer GEF Rhodope/UNDP International Organization 27 Vladimir Milushev Student Club for Environmental Protection Environmental NGO 28 Latinka Topalova Bulgarian Association for Bird Protection Environmental NGO 29 Martin Kurtev Bulgarian Association for Bird Protection Environmental NGO 30 Stefan Avramov Bulgarian Foundation BIODIVERSITY Environmental NGO 31 Zheko Spiridonov Nature Fund Environmental NGO 32 Nikolai Pipkov National Hunting and Fishing Association Environmental NGO 33 Borislav Bojov Union of the foresters in Bulgaria NGO 34 Rumen Raikov Agrolesproject NGO 35 Antoni Stefanov BULPROFOR NGO 36 Ljuben Ljubenov MUDI International Company 37 Maria Radmilova "Sega" Daily Newspaper Media 38 Radostina Biljarska National Radio - Horizont Media 39 Kremena Krusteva EVROPA TV Media 40 Svetlana Todorova "Banker" Newspaper Media 41 Kamelia Tzvetanova Bulgarian Telegraph Agency Media 42 Ekaterina Toteva Bulgarian Telegraph Agency Media 43 Tihomir Tonchev "24 chasa" daily newspaper Media 44 Petar Hadjiev ZEMIA Newspaper Media 45 Vladislava Peeva "Standart" Daily Newspaper Media Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDU FOR 4 January 28, 2004. Annex 5 REPUBLIC OF BULGARIA MINISTRY OF AGRICULTURE AND FORESTS Initial Stakeholder Workshop: Reports of the Wortking Groups (provided by the Agency Profile, Ltd.) INITIAL STAKEHOLDER WORKSHOP ON ENVIRONMENTAL ASSESSMENT OF THE FOREST DEVELOPMENT PROJECT Park Hotel Moskva, October 13, 2003 (NOTE: THE TEXT IS PROVIDED BY "AGENCY PROFILE" HIRED BY THE PPU) On Monday, October 13, 2003 in Park Hotel "Moskva" the initial stakeholder workshop WAS HELD on Environmental Assessment on Forest Development Project. It was organized by THE Ministry of Agriculture and Forestry - National Forestry Board (NFB) and Preparation Project Unit of the Forest Development Project (FDP), supported by World Bank. The participants of the Workshop worked in four groups: 1-st Group -"Institutional reform - Restructuring of the National Forestry Board (NFB)"; 2-nd Group- "Forest management practices"; 3-rd Group-"Biodiversity Conservation in state owned and private forests" and 4-th Group-"Fuel Switch Project". In the final plenary the leaders of the Groups presented their first expert outcomes for the Environmental Assessment of the project. They defined objectives to environmental impact assessment and laid out the criteria, which will guide the activities of the project and the measures for improving the present condition. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 5 January 28, 2004. Annex 5 CONCLUDING SESSION Sipi Jaakkola, Team leader, Environmental Assessment of the Forest Development Project: It's time to start our final plenary, chaired by Dr. lonov. Nikolai lonov, National coordinator of the Forest Development Project. Speaker of the 1-st Group-"lnstitutional reform - Restructuring of the National Forestry Board (NFB) ": This task, which I'm going to take up now preoccupies me a little, because I have to switch from what I was doing until present. But as envisaged, we have to exchange our findings with each of the groups, which means that the respective speakers should indeed very briefly and concisely present their findings. I will give the summery of our group. Our group discussed the impact on the Environment of the up coming restructuring of the NFB. We had quite a lively exchange of opinions and we divided issue into three components. The first is the model as it is now and the other was developed by the restructuring team with the World Bank, and the third one was an alternative option proposed by some of the branch organizations. I will try to pull the things together. The model as it is now: we reached the conclusion that even if it is theoretically well designed, in practice it does not work. We are observing an abdication of the State from its responsibilities towards the forests. That means we found very little positive things although they exist in theory. Mainly because this activity is not well supported because structurally and financially, this model now is not functioning. And exactly because this model does not function properly and it does not exclude the opportunities for shadow economy, we concluded it is not to be recommended as a good model from environmental protection point of view. I have to make a conditional remark in advance, since we are expecting the decision of the Cabinet for the possible restructuring. After the Cabinet approves the proposal, we will have to expect very detailed and will developed proposal for how the administration would look like. As of now we do not have any clear idea of how exactly our restructuring will look like. At the same time we have to make an assessment of positive and negative impacts on and risks for environmental protection. Team of restructuring administration, believes that creation of a) National Forestry Company would have a positive impact on the environment in general, provided however at the structures, aims and objectives of the individual bodies were very clearly defined. We spoke specifically of Natural Parks and their place in the model, and we spoke also of other structural bodies which will exercise economic and control functions. We believed, the main advantage and positive impact would be, that funds would be accumulated and used for reinvestment into forestry, which will allow by the National Company or by other companies to do economic activities in the forestry. However an additional guarantee is needed: the Minister is the one selecting the executive board of the Company. We need to have a control mechanism or re-corrective mechanism, which would assist the Minister or prevent a situation when one and the same person nominates both control and economic functions. We did not reach consensus in this issue, however because on one hand many colleagues believe that sufficient legal guarantees exist, but on the other hand the situation is slightly different in practice. One of the risks identified is a structuring, which is not clear enough. Clarity is needed in terms of forestry projects of forest management projects, and the tasks and objectives of structural units, which need to be better defined. The discussion did not reach a conclusion whether the "official", or the alternative model is better. But I need to mention the concerns the representatives of the alternative model. The alternative proposal contains the forestry Council as a control structure. We believe these models are based on a long term approach in planning and implementation. At the same time, in the opinion of some of us, the other model has the same qualities. The main concerns or risks are that the decision making based on competence may be replaced by decision - making by judgment, when the National Forestry Company is established. This is a potential risk related to the so called second model. This is the summary of the main points of our discussion. Clearly, the conclusion is that Environment Impact Assessment is absolutely necessary with a view to Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 6 January 28, 2004. Annex 5 restructuring. Once we have more clarity regarding the models of restructuring, we will know which is the most applicable one. Majority of the participants in the discussion at our table supported the officially proposed model. That's enough. Spas Todorov, technical project coordinator, PPU. Speaker of the 2-nd Group "Forest Management Practices": Looking at the watch I believe Mr. lonov will give me six or seven minutes, to tell you what we achieved during one hour. What was our task? In Forest Management Practices we have four components - forest roads, forest fires, thinnings and afforestation. For each of these activities we have attempted to define positive and negative impact, to explain the criteria, which we believe can be used in this activity and finally to propose appropriate measures. This may not the best approach but I believe it contains important elements. Forest roads are one of the important components of FDP. The positive impacts of roads relate to forest management, implementation of forestry operations including Natural parks, advantages for development of tourism, and also for communication of inhabitants of the pilot areas, protection of forests, and management of protected areas, regardless whether they're under the jurisdiction of the Ministry of Environment and Waters or the Ministry of Agriculture and Forestry. The negative impacts of poorly constructed forest roads: 1) As engineering facilities they have a negative impact on the ecosystem in general; 2) They lead to degradation processes; 3) pollution from dangerous emissions and substances is also due to such roads; and 4) Areas which could be used for production of timber are lost. The criteria for evaluation of the impact of forest roads on the environment: 1) acceptance of a strategy for the development of forest road network as an element of the National Plan for the Forestry Road Network; 2) Validation of control practices;3) One of the most important set of criteria is contained in Environment Impact Assessment. Our colleague from the Ministry of Transport made important proposals and mentioned a report, which contains the most important requirements of the European Union; I will analyze this information as soon as possible. The measures we are proposing: first the harmonization of the documents, regulating the technical feasibility studies and construction of forest roads according to the requirements of the European Union; second, the compliance with voluntary practices of the European Union, and third, the greater participation of NGO's in the discussion of forest road projects. And now the forest fires. We did not find any positive impact. Among the many negative impacts are the loss of timber, biodiversity, soil fertility, losses of investments and others. Control criteria included in the ordinance on fire and accident safety result from implementation of forest management plans, the sections of fire safety. They also result from the status of the fire protection equipment. The measures, which we are proposing: 1) completion and adoption of a National Strategy to control forest fires; 2) establishment of an efficient organization of the different institutions responsible for controlling forest fires and 3) acquiring or ensuring the equipment required for fire fighting purposes. We do not have the sufficient time to speak about main thinnings. The conclusion we have reached is that the thinnings must be made in time, because if they are not made, it is a loss for the whole society, not only for the forest. The criteria are listed in the applicable legislative documents and also in the contest of special development projects. The negative impact for missing or delayed thinnings leads to poor a sanitary situation of the forest and risk of fire. They should be made in time and we would believe in introduction of new forestry practices. Appropriate financial mechanisms need to be introduced for the conducts of thinnings of plantations. One of the measures that we propose under the FDP is the demonstration of good practices. More importantly, we have to change the regulatory framework, which would lead to achievement of the other two objectives - constraints on new practices, and financial mechanisms for stimulating an activity, which is not financially attractive. This has a horizontal link to the Fuel Switch Project and I believe it will be mentioned shortly. The final component is afforestation. Because of lack of time, I will not speak of the obvious positive and negative impacts. I will go directly to the criteria for measuring them, Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 7 January 28, 2004. Annex 5 which are: 1) ecological, economical and social criteria and also related to the selection of plant species, which need to be of suitable origin. 2) The second criteria and priority is afforestation of clear-cut areas, burnt areas and erosion-affected areas. The measures we are proposing to achieve the criteria above are: the adoption and implementation of optimal afforestation schemes, the creation of favorable conditions for the participation of other stakeholders in afforestation activities, such as private and municipal forest owners, companies and others. Thanks to our colleagues for the effort. Geko Spiridonov, expert, Bulgarian team. Speaker of the 3-rd Group "Biodiversity Conservation in public and private forests": Our group had too little time and we have many participants. We did not have all the documentation we wanted to have, but I believe we can submit an interesting input on biodiversity. First the biodiversity from the view point of view of the first component - strengthening of the public forestry sector. We have one positive finding here. We have a slight concern in terms of fire prevention activities, which are envisaged. And, in particular, one related to the mineral strips and other limiting devices for the large forest areas. Finally, in the larger the coniferous forests, which in fact are artificial plantations we could not speak of any serious impact on biodiversity. May be the situation in our country is different from the large coniferous forest areas in Western Rhodope. The second component is the strengthening of municipal and private forest. Our participants did not have experience on this subject, We received an alarming message that in places which already have established units at local or municipal level the management continues to be central. At meetings, where representatives of the National Forestry Board participate at municipal level, secondary attention was the problems of municipalities. Our general view here was that the municipal and probably private structures will indeed receive knowledge they need. We felt that in municipal forests already biodiversity initiatives have been implemented, although they are not yet incorporated in regulatory documents. The third component is adapting state forest management to market economy. In our view there is a good balance between the needs of the country, the possibilities to meet them and the possibilities for imports if required. In this component, only the separate section regarding the forest roads raises some concerns. A positive assessment was made of the possibilities, due to the improvement of the forest road network in coniferous forests. In fact, all these roads would still continue to be in use if thinnings were properly conducted. But even if it would take time the network of forest roads needs to be reestablished. After the positive aspects we spoke about possible concerns, namely roads in areas, which have high conservation value. Such areas cover about 8% of the forests, which represent trees between 80 and 100 years old. The component regarding biodiversity conservation was analyzed using 4 indicators, presented to the group. With regard to endangered habitats and area, those having European or World significance should be conserved as a priority. Those habitats, whose exact distribution and area are not yet known, need to be defined. Such habitats, which may not represent interest from a landscape or forestry point of view, but where endangered species are found, must also be conserved. An opinion was expressed that such forests should also be preserved, which are picturesque from a landscaping point of view and are of interest for the development of tourism. Only three items were set down as a plan of action. The most important thing to mention is that the establishment of the national ecological network in particular NATURA 2000, is lagging behind. Regarding the 5 wetlands on the Danube River, which were clear cut areas, we had the largest number of proposals for the conservation of biodiversity and its integration into forest management. First of all, it has to be legally regulated, of course. Second the biodiversity conservation has to be simplified in order to be clear about the objectives. Regarding the assessment of biodiversity we have an example of how an assessment could go both ways. An inventory of 17 species, which are of high conservation value, was made in the 5 forestry districts of the Stranja Park. This example, which is dating 4 or 5 years back, should probably inspire other forest managers to integrate biodiversity to management. A Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDU FOR. 8 January 28. 2004. Annex 5 negative element is that in some areas, in some parks, their management continues as so called forests of economic significance, although in forestry legislation these forests have been defined as forest in protected area. The last criteria was the strengthening of the system of protected areas. Both the question and the answer are pointing in the same direction: was the protection done by state forestry boards in protective areas efficient. The clear answer was: "no". Thank you. Viadislava Peeva, editor, "Standard" Newspaper. Speaker of the 4-th Group "Fuel Switch Project": Our group, entirely composed of ladies, surprisingly quickly reached the conclusion that it does indeed make sense to change from traditional fossil and oil fuels to others. We clearly see a positive environmental effect, because harmful emissions and greenhouse effects will be reduced. Therefore, our country will gradually move towards fulfilling its obligations under the Kyoto Protocol. The additional afforestation, which the project envisages, will also contribute to this effect. We are leaving the economic effect of such a change on a second place. Municipalities will reduce their costs for the production of energy for heating and electricity. They will also be able to increase their revenues by selling such energy at preferential prices. They will also receive revenue from the sale of greenhouse emissions thus avoided or saved. We also see a social effect because new jobs will be created, although not many. However, the funds saved can be allocated to other programmes or social support or employment. The demonstration effect of such type of a project is important. It will demonstrate that it is an advantage to introduce energy saving technologies, which will help us to fulfill the obligation of 8% of green energy. Our concerns were related exclusively with 1) the construction of infrastructure and 2) whether the transportation and the cutting machines, which will be used for the production of material, would generate harmful emissions, which could offset the reduction of such emissions. We identified this as a recommendation to the consultants, who will perform the Environment Assessment. We also had some concerns regarding risks for biodiversity. But we believe there are ways to compensate for this by choosing the best options. As a whole, we should look for multiple environmental benefits for the project. Thank you! Nikolai lonov, National coordinator of Environmental Assessment on Forest Development Project: Let me give the floor to Mr. Jaakkola who will inform you about the next steps of the EA project, and then you are also invited to make remarks or ask questions. Sipi Jaakkola, Team Leader of the Environmental Assessment of Forest Development Project: Thank you very much for your valuable contribution to our work. This was our first consultation whit the stakeholders, but not the last. It is understandable that the concept of Environmental Assessment may be new at first site. Sometimes it was easier to discuss the changes the Forest Development Project will bring, than the environmental impacts and risks involved. I propose that we take this initial workshop as an introduction to the topic and issues, but we need to continue and make progress. I would like to ask for your continuing participation in this Environmental Assessment process. Please think about the Environmental Assessment issues and problems further, and discuss them with your colleagues, if possible. I invite you to contact us and provide us with your remarks, concerns and your proposals for ways to contribute to the assessment. The next step is our Inception Report. We'll analyze the results of this workshop. We'll make our final Work plan, we'll make a Stakeholders consultation plan, and we'll organize the next consultation in the middle of November. You will be invited. The Draft EA Report is due the 5-th of December. Of course you will have a chance to give your comments on the Draft EA report. We are located in the Project Preparation Unit. Dr. lonov will provide the address details of this unit. Thank you. Environmental Assessment of the Forest Developmnent Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 9 January 28, 2004. ANNEX 6 II Stakeholder Workshop Annex 6 STAKEHOLDER WORKSHOP ON ENVIRONMENTAL ASSESSMENT OF THE FOREST DEVELOPMENT PROJECT Park Hotel Moskva Monday, 13 November 2003 13.00- 17.00 Hours Co-organized by the Ministry of Agriculture and Forestry and Indufor Oy - AGENDA - until 13.00 Registration 13.00 - 14.00 Opening Session - Chairman: Mr. Sipi Jaakkola - Facilitator: Mr. Plamen Dimitrov Reports on the first results of the Environmental Assessment of the Forest Development Project presented by: * Mr. Jussi Lounasvuori * Mr. Grud Popov * Mr. Dimitar Stoev 14.00 - 14.30 Coffee break 14.30- 15.45 Group Work Session focusing on the stakeholders inputs contributing to the EA process - Introduction by: Mr. Jussi Lounasvuori, Mr. Plamen Dimitrov Working Group 1: Management of State-owned Production Forests, Private and Communal Forests and Protected Areas Speaker: Mr. Spas Todorov Working Group 2: Rehabilitation and Construction of Forest Roads Speaker: Mr. Dimitar Stoev Working Group 3: Rehabilitation of Forest Fire Sites, and Thinning of Young and Fire Prone Stands Speaker: Mr. Grud Popov Working Group 4: Fuel Switch Pilot Project Speaker: Ms. Yeni Katsarska 15.45 - 16.45 Presentation of the outcomes from the work in each Working Group Facilitator: Mr. Plamen Dimitrov 16.45 - 17.00 Concluding Session - Chairman: Mr. SipiJaakkola Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INNDU FOR. January 28, 2004. Annex 6 List of invited to participate in the Second Stakeholder Workshop on EIA of DP Park Hotel Moskva - 13 November 2003 _2 Name of the participant Organization / institution Stakeholder group I Institutional/administrative Meglena Plugchieva National Forestry Board (I/A) 2 Dimitar Batalov NFB (I/A) 3 Nikolai Yonov NFB (I/A) 4 Georgi Tinchev NFB (I/A) 5 Ana Petrakieva NFB (I/A) 6 Petko Vrachovski NFB (I/A) 7 Neli Michailova NFB (I/A) 8 Stoicho Bialkov NFB (I/A) 9 Ivan Kormushev NFB (I/A) 10 Ljubcho Trichkov NFB (I/A) 11 Nikolaj Pironkov NFB (I/A) 12 Biser Dachev NFB (I/A) 13 Rosen Popsavov NFB (I/A) 14 Boriska Stoimenova Ministry of Finance (I/A) 15 D. Todorova Ministry of Energy (I/A) 16 Ministry of Environment and Water Jaklin Metodieva (MEW) (I/A) 17 Vanja Grigorova MEW (I/A) 18 Hristo Bojinov MEW (I/A) 19 Velichko Velichkov MEW (I/A) 20 Michail Michailov MEW (I/A) 21 Kalojan Anev MEW (I/A) 22 Lilija Bogdanova MEW (I/A) 23 Borijana Hristova MEW (I/A) 24 Julija Nikolova MEW (I/A) 25 Ganja Hristova Ministry of Finance (I/A) 26 Environmental Agency Emilija Stoineva (I/A) 27 Geno Genov Ministry of Regional Development (I/A) 28 Konstantin Gegov Ministry of Regional Development (I/A) 29 Regional Inspection in Environment and Gergana Blagieva Water (RIEW) - Sofia (I/A) 30 RIEW - Blagoevgrad (I/A) 31 RIEW - Pazardjik (I/A) 32 Elitza Dancheva Ministry of Economy (I/A) 33 Desislava Michalkova Ministry of Economy (I/A) 34 Nikolaj Istatkov Ministry of Economy (I/A) 35 Barzilov National Fire Management Service (I/A) 36 Michail Michailov Rilski Manastir Nature Park (NP) (I/A) 37 Toma Belev Vitosha NP (I/A) 38 Darina Nikolaeva Shumensko Plato NP (I/A) 39 lOniHs TyM6aKoBa Zlatni Piasatzi NP (I/A) 40 CTeJaH 3naTapoB Strandja NP (I/A) 41 Nikolaj Nenchev Vrachanski Balkan (I/A) 42 Ivan lvanov Sinite Kamani NP (I/A) 43 Milko Belberov Rusenski Lom NP (I/A) 44 Misho Mihailov Rilski manastir NP (I/A) 45 Ani Peizanova Persina NP (I/A) 46 Maja Radeva Balgarka NP (I/A) 47 Georgi Grancharov Pirin National Park (I/A) 48 Vasil Petrov Rila National Park (I/A) 49 Nela Rachevitz Central Balkan National Park (I/A) Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. Annex 6 Name of the participant Organization / institution Stakeholder group 50 Regional Forestry Board (RFB) Sofia (I/A) 51 RFB Smolian (I/A) 52 RFB Kardjali (I/A) 53 RFB Kjustendil (I/A) 54 RFB Varna (I/A) 55 RFB Burgas (I/A) 56 RFB Berkovitza (I/A) 57 RFB Plovdiv (I/A) 58 RFB Pazardjik (I/A) 59 RFB Veliko Tarnovo (I/A) 60 RFB Sliven (I/A) 61 RFB Shumen (I/A) 62 State Forestry (SF) Sofia (I/A) 63 SF Ihtiman (I/A) 64 SF Ardino (I/A) 65 SF Vratza (I/A) 66 Izvora State Game Breeding Station (SGBS) (I/A) 67 Vitoshko SGBS (I/A) 68 Juri Mikov Vitinja SGBS (I/A) 69 Danail Zhekin Plovdiv Seed Control Station Science/research 70 Svilena Bojinova Sofia Seed Control Station Science/research 71 Jancho Najdenov Forest Protection Service - Sofia Science/research 72 Borislav Bojov Union of the foresters in Bulgaria NGO 73 Rumen Rajkov Agrolesproject NGO 74 Kiro Kirov ArponecProject NGO 75 Hristo Michailov Union of hunters and fishermen NGO 76 Svetla Bratanova Central Laboratory in Ecology Science/research 77 National Association of the Municipalities Grigor Gogov in Bulgaria Social 78 National Association of the Municipalities Teodosi Dimitrov in Bulgaria Social 79 Konstantin Panov Bulgarian Tourist Association NGO (Tourism) 80 Ventsislav Udev Bulgarian Tourist Association NGO (Tourism) 81 Petar Petrov Bourgas Regional Tourist Association NGO (Tourism) 82 Pavel Iliev Tourist Forum - Pirin NGO (Tourism) 83 Association for Alternative Tourism NGO (Tourism) Central Balkan - Kalofer - Tourist 84 Silvia Nikolaeva Association NGO (tourism) National Protected Areas Endowment 85 FeoprH HaMnopoB Ecofund Project National Protected Areas Endowment 86 Dimitar Nenkov Ecofund Project "Biodiversity Conservation and Economic 87 Steve Denison Growth" Project Project "Biodiversity Conservation and Economic 88 Kamelia Georgieva Growth" Project " Project 89 Aleksander Bardarov National Forest Policy and Strategy Project 90 Simeon Marin NATURA 2000 Project 91 Kalina Todorova NATURA 2000 Project 92 Ognjana Glavousanova UNDP International Organization 93 Karsten Germer UNDP/GEF International Organization Embassy of Switzerland, Cooperation 94 Gerasim Gerasimov Office International Organization Bulgarian-Swiss Biodiversity 95 Rosen Vasilev Conservation Programme Project 96 Martin Borisov German Bulgarian Forestry Project Project Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 3 January 28, 2004. Annex 6 N° Name of the participant Organization / institution Stakeholder group 97 Vasil Stiptzov Bulgarian-Swiss Forestry Project Project 98 Kristof Duerr Bulgarian-Swiss Forestry Project Project 99 Hristo Nikolov Green Balkans Ecological NGO 100 Zhivko Bogdanov WWF Bulgaria Ecological NGO 101 Zheko Spiridonov "Wild Nature" Association Ecological NGO 102 Simeon Nedjalkov Association of the Ecologists in Bulgaria Ecological NGO 103 Veleslava Abadjieva Time - Ecoprojects Ecological NGO 104 Elena Tzingarska "Balkani" Association Ecological NGO 105 Andrei Kovatchev "Balkani" Association Ecological NGO 106 Latinka Topalova Student Club for Environmental Protection Ecological NGO 107 Maria Tumbeva "Women Club" - Raziog NGO Union of the Specialists in Parks and 108 Maria Samardjieva Landscape NGO 109 Petar Jankov Bulgarian Association for Bird Protection Ecological NGO 110 Anelia Stefanova Ecoassociation for the Earth" Ecological NGO Bulgarian Association of the Producers of 111 Desislav Dionisiev Mushrooms and Herbs Business Branch Chamber in Woodprocessing and 112 Kalin Simeonov Furniture Industry Forest Industry 113 Antonii Stefanov Bulprofor NGO 114 Svetoslav Avramov Union of the forest-trade companies Forest Industry 115 Maria Marinkova Forest Federation Forest Industry 116 Anelia Pochekanska Forest Cooperative "GORA" Private forest owners 117 Milka Mladenova Burgas Private forest owners 118 Petar Abrashev Federation of forest workers Social 119 Nikolo Parlikov Bulgarian Forestry Chamber Non-state forest owners 120 Ivanka Dushkova Union for development Social 121 Georgi Zhekov University of Forestry Education and science 122 Kiril Bogdanov University of Forestry Education and science 123 Milko Milev University of Forestry Education and science 124 Georgi Rafailov University of Forestry Education and science 125 Georgi Puhalev University of Forestry Education and science 126 Katinka Mihova University of Forestry Education and science Students University of Forestry Education and science Forestry Institute - Bulgarian Academy of 128 Aleksandatr Aleksandrov Science Education and science Forestry Institute - Bulgarian Academy of 129 Ivan Raev Science Education and science 130 Bulgarian Church NGO Bluelink network - about 400 NGOs are I___ ______ ______ ______ _____ inform ed NGO Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 4 January 28. 2004. Annex 6 List of the participants in the Second Stakeholder Workshop on EA of the FDP held in Park Hotel "Moskva" on 13 November 2003 N° Name of the participant Organization / institution I Radostina Portaleva State Forestry - Sofia 2 Vasil Stiptzov BSFP 3 Spas Todorov PPU/FDP 4 Emanuil Kilorev Regional Forestry Board - Varna 5 Emilia Stoineva Executive Environmental Agency 6 Stefan Avramov Bulgarian Association of Bird Protection 7 Gerald Kapp GFA Terra System 8 Svetla Bratanova Central Laboratory in Ecological Investigations - BAS 9 Veronika Ferdinandova Forestry Institute - BAS 10 Hristo Vachovski Retired forester 11 Andrei Kovachev "Balkani" Ecological Association 12 Carsten Germer GEF Rodope Project/ UNDP 13 Julia Nikolova MEW 14 Boriana Hristova MEW 15 Angel Georgiev Regional Environmental Inspection - Blagoevgrad 16 Antonija Chilikova Eco-organisation RODOPI 17 Krastio Sadiiski Forestry cooperative ELA 2001 18 Volknar Schaeer Eta Energy 19 Andrew Mitchell DP 20 Boriana Borisova Ministry o Regional Development 21 Emil Rakadjiev NFB 22 Dragomir Zahariev SCEP 23 Tzvetelina Naidenova SCEP 26 Petko Tzvetkov BSBP 24 Maria Radmilova SEGA Daily Newspaper 25 Petar Zhekov DUMA Daily Newspaper 27 Elitza Dancheva ME 28 Nikolai Tzekov DW 29 Snejana Kostadinova ACG - social assessment 30 Krasen Daskalov ACG - social assessment 31 Stoicho Gluhov Forestry cooperative - Borika 32 Cristoph Duerr BSFP 33 Anton Balibanov RFB - Plovdiv 34 Velichko Velichkov MEW 35 Pavli Bogdanski RFB - Lovech 36 Aleksandar Dunchev SCEP - UF 37 Boriana Paskaleva SCEP - UF 38 Maria Radeva SCEP - UF 39 Zheko Spiridonov Nature fund 40 Prodan Prodanov RFB - Pazardzhik 41 Radi Radev ECOFORUM Association 42 Elmira Dokova ECOFORUM Association 43 Angel Andreevski Zdravno Delo Newspaper 44 Damian Dohchev Sinite Kamani NPD 45 Rumjana Ficheva Central Balkan National Park 46 Anelia Pochekanska Gorovladeletz Association 47 Ivan Vasev Poplar Station - Pazardjik 48 Maria Tumbeva Women Club - Razlog 49 Slavka Davidova Forestry Cooperative - Chepelare 50 Blagoi Koichev SCEP - UF 51 Toma Belev Vitosha NP 52 Peter Zhelev University of Forestry 53 Vladimir Konstantinov NFB 54 Jancho Najdenov Forest Protection Service - Sofia 55 Georgi Tinchev NFB 56 Nikolaj Jonov NFB 57 Miroslava Dikova FDP 58 Jeni Katzarska FDP Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 5 January 28. 2004. Annex 6 Workshop on FDP Environment Impact Assessment Park Hotel Moskva Thursday, 13 November 2003 13.00- 17.00 q* PREPARATION FOR WORK IN GROUPS Jussi Lounasvuori, international expert, Indufor Oy: It's time to start work in-groups. Our goal is to gather feedback information from you and to incorporate it in the outputs of environmental assessment. Your contribution is extremely important to us. There are three tasks or issues, which we have prepared and put in the folders for each of you. First, we would like to understand whether in your opinion the EA identifications, made by us, are adequate and sufficient, and if you are pleased by the determined significant environmental impacts. The second task is to understand if you find appropriate, the defined systems for control of the significant environmental impacts. And the next issue is what is your appraisal for the impacts to ecological control of the project. While you are working please use the provided aids. More comprehensive introduction in the work for each group will be given by the relevant facilitator /leader/. Have a fruitful work session! Plamen Dimitov, facilitator: We have one hour for work in groups on the issues introduced by Jussi Lounasvuori. After that the work group speakers will introduce before all the participants in the workshop the outputs of the group work. Finally, we shall proceed with an open discussion on all the questions concerning the present reports and the group work. I will be at your disposal and will facilitate the working process. Now I would like to draw your attention to the people, who will present the outputs in the groups. Mr. Spas Todorov is in the group N 1. We shall expect from him to summarize and coordinate the work in the group. He will present the outputs of the subject "Management of state production forest, private and communal forests and protected areas". Second work group - Mr. Dimitar Stoev. He will coordinate the work group, which has topic for discussion - "Rehabilitation and construction of forest roads", and he will report the achievements, recommendations and standpoints. In the third group with theme "Rehabilitation of forest fire sites, thinning of young and fire prone stands" is Mr. Grud Popov. In the forth group " Fuel Switch Pilot Project" is Ms Yeni Katzarska. . Have a successful work! We shall be at your disposal for supplementary assistance to each issue, regarding the process and the matter of the work. There are materials for writing and other necessary outfits, so please, especially those who will express the whole group standpoint, use them actively, write down the main ideas, recommendations and comments. It is important to write at max participants' views in each group. Once again have a successful work! We have one hour! Working in Groups Plamen Dimitrov: We shall start the discussion first listening to the leaders of the groups. I am giving the floor to Mr. Spas Todorov, work group X2 1 "Management of state production, private and communal forests and protected areas". Welcome! According to the schedule you have 10 minutes. This time limitation is given to have time for questions. Spas Todorov: Good evening! I will try to tell you for ten minutes what we could not do for one hour. I suppose that there will be some questions so I will ask for help the colleagues from my work group The first recommendation to the EIA team, please take it as a recommendation not as a critics, is the following - the First group members consider that the material, arranged this way, doesn't give Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 6 January 28. 2004. Annex 6 enough opportunity to appraise the scope of the implemented activity. I mean the stipulations of the Forest Development Project and what represents the connection between the present practice, the main issues, systems for control, and the proposed activities of the Project in the future. We consider that if we had a Draft Final Report we should be more constructive and discuss the matter straight to the point. To the point - we review the state; communal and private forest management as a whole. We understand that for convenience they are divided in different groups - state - in the first group, private and communal in the other group, but the recommendation we shall give concern the state as well as the communal and private forests. We consider that the system for regulation of the main forest function is inadequate. The present forest categorization, if I could express in such a way, according to the Law on Forest, divides the forests in forest for wood production, protected forests and protected areas. Here should be taken in account that there are a lot of new issues. We recommend the EA team to abide by the classification and terminology in the actual Law on Forests. We regard as necessary to be made an accurate balance of the country needs of wood. And if it's necessary to explain why, I am willing to do it We consider that the low efficiency of park administration should be pointed out as a key concern. As the main means of control execution or as elements of the system for control we suggest incorporation of the forest certification. We do not say that FSC or any other should be included, because it is a subject to a different discussion, but only that the certification is pertinent. Other important instrument is the approach for determination of the forests with high conservation value. We think that important instrument will be the EIA of the forest management plans and the forest road construction during all the phases - design, implementation, and management. We consider that the EIA is pertinent, because the ineffective system for control, currently executed by NFB, MAF and MEW is a serious ecological problem. The present major ecological problems, which assist the private and communal forest management in addition to what has been already written: Our group considers that the private forests usage is unauthorized by forest management plans, especially in the regions with forest coverage lower than the average for the country. We also think that the private and communal forest owners do not have enough capacity and expertise to be efficient forest owners and their forests have to remain forest after a prolonged period of time. A very heated debate, concerning something that seems natural and is perceived by any person, is the suggestion for FDP support of volunteer association at a national level or establishment of so called Bulgarian forest owners association. In my opinion this is acceptable, but it is good that there are people who think in a different way. However, it means that we have to reconsider once again if it is a major problem. Regarding the third element - the protected areas. My colleagues suggest protected area expansion as one of the measures against forest over exploration and with aim to preserve the present valuable forests. Unfortunately, we didn't have time to complete this so important topic. The last, we suggested as a means, is acceptance of approach in assessing the HCV forest as a base for forest activity. In the part FDP scope of activity, it is possible to add the project suggestions for making four nature parks management plans, as well as small projects to support management of so called natural areas with special conservation value. I will be grateful to answer any of your questions Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 7 January 28, 2004. Annex 6 Questions and suggestions Stefan Avramov: A question, may be political one - On condition that all the European NGOs, including Bulgarian ones, acknowledge as the only system for regulation the FSC and reject the PFC, why that can't be noted down at the draft document? Thank you! Radi Radev: What are your recommendations for usage increase of the wood residues in harvesting? And how do you consider the pressure on the forests as an energy resource use can be decreased? Krassen Daskalov: You said that in the group there were "pros and cons " about owners' association, especially regarding the private owners. Would you please tell anything more about the negative opinion, as I understood yours is positive? Yancho Naidenov: My question is rather economical, but it concerns the optimization of the forest use. Do Mr. Todorov and the whole group considers that it is time to change the rate tax on root, which now is % of the market price with modified rate tax. This question enters the forest roads issue - there was told about the rate policy and the current wrong practice, which drives all the users to utilize the most easily accessible forests - the best forests / the most valuable forests/. Thank you! As far as I heard from Mr. Todorov, he suggests a text concerning the protected forests expansion to be recorded. And if I have understood clearly, I think that this formulation is not right. There are quite a number of forests announced by the Law for protected. In the worst case it for the area of protected territories should be recorded - " to be reassessed ", not emphatically "to be increased". Answers Spas Todorov: First, I would like to thank for your interest in what we've presented. Second - I do not answer political questions, because I am a forest expert. To Stefan 's Question - During the time of our discussion we were talking about FSC and other systems for certification. I would like to repeat what my colleagues' supported; I regret it differs from your opinion. We could suggest including of the forest certification in the system for control. I also have personal opinion and preference, but I think that to define which system to accept in Bulgaria is a very serious problem, which requires participation of more competent people or at least they have to be here. I mean that this is another subject. And if you accept let's not fix this now. It's will be a reason for another meeting. To Mr. Radev's question for the use of wood residues in the timber industry - I think that we could record it as a recommendation or issue, which could be overcome. Furthermore, after about 20-25 min. Ms Yeni Katzarska will introduce us to the four group, which discuss the issues of the FSPP. How will the pressure on the forests be lowered - this question could have several aspects - economical, political, social and ecological. I don't take responsibility to answer because our project - FDP, suggest some solutions to lower this pressure on the forest. The first one is regulative forest use. Here, among us, is Snegana who develops the Social impact project, including the illegal logging. The logging could be taken as a result of extreme poverty of our compatriots and caused by organized criminality. I am not ready to give answer to this question, but the project will do it quite soon - up to one or two months, when then EA is completed. To Mr. Daskalov question about association - This is an important question and I suppose that all of us understand it as a volunteer process. In our country there are more than 300 cooperatives and associations of private owners and in our opinion they should be assisted to amalgamate of their own free will. This means in my naive perception to provide means /financial resource/ to gather these Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 8 January 28. 2004. Annex 6 people, to organized and prepare without, in any rate, establishing an association or other type of pool. It is obligatory to support the process and the people. Explanation by...?: I can explain, because I declared that it's absolutely unnecessary, because the support to a similar association has nothing to do with the environmental assessment. It is about the issue that in Bulgaria for 6 years we have supported such a national organization to arrive at the court now between it and the main donor GTZ. And the government guarantees the grants. On second place - there is another source for volunteer association, which is SAPARD program. At present, there is a measure that supports the volunteer association, and it is not necessary to be duplicated with loan from the World Bank. In this case I would say - then why don't we support ecological organizations to amalgamate or the organizations of users of other forest resources? And not on the least place my absolute distrust that with public funds an NGO should be supported. Once again I repeat this is not an EA issue. Elucidation on the last question Andrew Mitchell: I have to elucidate some issues concerning our support to the private owners and especially regarding SAPARD. Our purpose is not to compete with SAPARD. The idea is to assist and stimulate the utilization of SAPARD funds. At that moment the process for application in SAPARD is extremely complicated and it takes two or three months. There are other projects which support the SAPARD funds for private forest owners. Our support with usage of resources from the loan is aiming the reach of funds that SAPARD offers. Thank you! Spas Todorov: The reason to suggest this component is the private owners' willingness, expressed on one of our meetings in the countryside. That's not anything, fabricated by us, which should be followed. To the last question of Mr. Yancho Naidenov - I think that the NFC and the government will give the best determination for the economical interest. The first side - in interest of the company and the forest, and the other side - hopefully in interest of the society. I do not know if this answer is satisfactory for you but that's what I could say. And there is another question about the percentage of the protected areas - On this issue some of my colleagues will assist. Please, Mr. Geko Spiridonov! Geko Spiridonov: Thank you! In Bulgaria the protected territories cover about 5% of the country territory. By this indicator Bulgaria is amongst the last 1/3 of the European countries. And by biodiversity is on 3-4 place. There is an absolute discrepancy between nature and conservation. Second - The NFB announced a very important initiative, and that is to say establishment of Green belt along the Bulgarian frontiers. These are large territories in The Western Balkans, Osogovo, and Rhodopes. So, that is the policy of the NFB itself. In the MEW plans and according to the biodiversity conservation strategy up to 2000 we would have to reach 7.5%, and up to 2006 - at least 10 -12%. But we are in the middle. This strategy is accepted by the Ministerial council and I think that we shouldn't argue about something, which has already been a state policy. Thank you! Plamen Dimitrov: I give the floor to Mr. Stoev , Group 2 - " Rehabilitation and construction of forest roads" Dimitar Stoev: I hope that in our group the things are more specified and I won't be so circumstantial. Fortunately, there were almost no notes concerning the EIA of forest road network. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 9 January 28. 2004. Annex 6 Special attention was paid to the mechanisms for control, which often excite apprehensions. One of the notes of the colleagues in the group was that still it would be better to have more information related to the project. Another substantial issue is that in Bulgaria there aren't elaborated clear ecological standards, by which to assess the impact on the relevant infrastructure, particularly on the biodiversity. As it was said we are reviewing the ToR of the Master plan for Forest road network development, where a desire to incorporate the environmental assessment in the normative base, bound to the forest roads is recommended to underlie eventually in the plan. The wish is for obligatory EA, something that should accompanies the forest road projects. It was maintained that the future Master plan should also have an EIA, independently of what is being carried out at the moment for the whole project. Conceming the issue that forest roads should be designed and realized to allow the access to the closed forest areas/basins/, a standpoint was expressed that the Master plan would develop alternatives. For example, about forest road network development in places where there is a necessity for more thinnings and as a counterpoint for road network construction to closed areas, most of which have high conservation value. One of the recommendations to the assessment implemented by us is that at this phase we should give recommendations to the scope of EIA of already prepared Plan for forest road development. An apprehension was expressed that the appraisal of the necessity for EIA implementation of forest roads is administratively closed and is not a subject of public control. I do not know how we could react in this case, as the Law on Environment covers this issue and possible recommendations for amendment in the legislation from the project side seem hardly feasible. In connection with the forest road network there is a fear that at present there is no mechanism to preserve the protected zones of the national ecological network from over exploration and more significant impacts. It's recommended establishing an official standard in the forest legislative framework for preservation of the protected habitations. This is also a wish related to amendment in laws. These were the notes and recommendation to the project. Ouestions and suggestions I won't ask questions to the colleague. I just would like to specify an issue on the Project. It should be " Rehabilitation, construction and maintenance of the forest roads", because at the moment most of the roads are real ruins. That's why we should note down in the project the necessary concems for the maintenance of these roads. A walk in our mountain will show that they are the beginning of landslides and active processes of erosion. Thank you! Answers Dimitar Stoev: Now we are examining the ToR of the Master plan implementation for Forest road network. An element of this plan is quality and quantity assessment of the current road network and outlining measurements for its rehabilitation, not only construction of new roads. So that's what is meant in the plan. Plamen Dimitrov: Mr. Popov I call on you to present the work of group 3 - " Rehabilitation of forest fire sites, thinnings of young and prone stands." Grud Popov: First of all, surprisingly the discussion tackled the benefits from the fires, since in the main summaries the damages were maintained as indisputable. Then the thesis that there are benefits was stated. I won't dwell on this discussion because it was too detailed - on the benefits of some species regeneration, on the woodland pastures, on biodiversity change, on some characteristics of ecosystems and their management and the changes in ecosystems. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 10 January 28. 2004. Annex 6 The common opinion that in Bulgaria controlled fires couldn't be realized or are in small amount outweighed. The endeavors in this respect are very emphatical. The stubbles buming showed how many forests have been devastated along with them. The main reason for this is namely the kind of controlled fire, which is stubble buming. The group work proceeded with three basic issues: economical benefits and damages from the rehabilitation of the forest fire sites; economical profits and the connection with the other components of the project - alternatively with fuel switch. Finally we end with recommendations. The benefits from the rehabilitation of the forest fire sites are in most cases matter of public knowledge, but still I will repeat them again briefly: erosion cessation, including the wind erosion, as the burning of the topsoil base, so called by the foresters "forest soil base", is a good opportunity for formation and emergence of the wind erosion, which sometimes could be more dangerous than the water erosion. The burnt residues, produced on the surface, are too light and most often during the commencing pouring rains instantly appears the topsoil erosion./soil base erosion. In this case the benefits are connected with the rehabilitation, in discontinuation of the ground water flow, increase of the underground water, improvement of the water regime of the springs and rivers, improvement of habitats and animal habitations - as well as the game and all the other animals, micro organisms, and accumulation of carbon. Economical benefits - Often they are bound to the ecological, but mostly we shall emphasize the wood production, and the carbon sequestration and the potential benefits, which will be obtained as a result of the quality improvement and the increase of drinkable water. Connection with the other projects - The attention was drawn to the matter that in rehabilitating of the forest fire sites into account should be taken whether this territory will be close to industrial enterprises and if it is feasible - afforestation with fast growing species. They will be the starting point for rehabilitation of the environment and subsequently will be used in the FSPP - as a fuel, other benefits. A question that has given rise to much controversy was the design and control. Principally, the design of the afforestation activities, and the selection of tree species were debated. The general impression is that the design and formation of so-called technological plans is at a good level. The execution itself gives rise to difficulties with objective and subjective nature. One of the questions is that by virtue of the law the forest fire site should be rehabilitated for a two-year period. In this case the technological plan couldn't be executed because of the lack of seed material. For example, the Quercues consertsa - a type of oak, which yields every other 7 - 8 years, most often every 10 years. The seedling provision for regeneration seed material is not possible during this period. Also attention was paid to the issue that the horizontal removal is not useful. I think there is an agreement on the vertical removal, but we pay rare attention to the horizontal one. For example, to take saplings from northern or eastern part Bulgaria and to afforest them in the Sakar region in a forest fire site. In the end, the recommendations were in the following aspect - establishment of fire breaks from deciduous species, i.g. not to be established extensive monocultures. Qualified workers should do the afforestation and the process should be effectively controlled, as I already said - with appropriate species and a wider variety. Also attention was called to a special concern, which is often neglected or forgotten - it's about the ecological knowledge rising of the people occupied in this process. A forester, who has given half of his life to the forests, who has given life /to vegetation/, hardly could destroy it. There was a wide discussion on the matter of administrative measures and opportunities for fire control and mastering. Questions and recommendations Andrei Kovachev, Association Wild Nature "The Balkans": I would suggest three points to be reviewed when talking about control mechanisms - three safety measures against the fires to be taken, which to be examined and included. First - complete prohibition of stubble burning and mechanisms for control of the relevant measures. Up to present there have been no mechanisms for control. Second - prohibition for burnt woodcutting. In the recent Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. Annex 6 times a large part of the forest fires were result of the desire to avoid the forest management plans. And the third measure is - no permission of coniferous species for regeneration of fired sites. Please, colleagues, speak very carefully about economical benefits of fire burning because it was found that there has been only about 10 % material yield. And to our colleague Kovachev - he said that the coniferous species should not be used for regeneration of the fired forests. I would ask about the dwarf pine zone/Pinus montana/, with what kind of species we would afforest, because ones of the biggest fires in Rila are in the dwarf pine zone? Answers Grud Popov: I would like to thank to the colleague for this question. Since I quite shortened the comments on the mechanisms for control, question arose. One of the points is - first, to eliminate the reasons. These are the commercial interests. There are many cases which aren't a small number and they are the basic cause. They are mainly in the low forest vegetation zone, in the accessible forests. Second, an immediate reaction is necessary when a fire starts, because when its starts to spread, its mastering becomes very hard. About the prohibition for stubble burning - there is such a prohibition. Another question is who can master and control it. Prohibition for cutting of burnt wood - it is dangerous, if such a prohibition exits. It is not possible to regenerate the forest fire site. The reaction should be - to forbid the export of fired wood so as to decrease the commercial interests. Prohibition for afforestation of coniferous species - The colleague Mr. Nidenov mentioned about the upper forest vegetation zone, but had something else in mind - afforestation in the low forest vegetation zone, which is out of coniferous species area. Yes, I agree with you, this definitely is being done, but there are such cases - with high erosion, greatly degraded sites where other species couldn't be afforested. That's why recommendation were - not to establish monocultures on a large scale, and if such cases exist - to afforest deciduous species where the soil is better and to keep a wide variety of broad leaf species and right after that to proceed with thinning activities. Plamen Dimitrov: Thank you! I would like quickly to invite Ms Katzarska, Group 4 - "Fuel Switch Pilot Project" Yeni Katzarska: I would like to say that our work started with a great misapprehension, because the information given in the presentation isn't in correspondence with the general framework of the FDP - Fuel Switch". The work group agreed on that in discussion the given presentation should not be taken into consideration ", but the summary which I will give as a coordinator of that project. Second, an abstract to clarify the project framework will be sent by e-mail to the participants. I will tell you for 2-3 minutes what is the fundamental framework of the project, trying to be concise, because the time is running: This is a project approved as "Joint implementation project" on Kyoto protocol. Some major tasks are provided for it, which will lead to greenhouse gas emission reduction. The activities are: switch of conventional fuel as oil residue, coal and naphtha, which emit a great amount of carbon, with wood residues which will be extracted as a result of the thinning in the existent forest massifs and also wood waste from wood processing and furniture industry. The second component is - to provide fuel chain supply for these heating systems, the project stipulates between 60 and 150 ha with fast growing species for the relevant appropriate areas, but it should be taken into account that the priority should be given to areas under erosion and abandoned areas. The third component is: If we achieve substantial decrease in greenhouse gas emission, this considerable amount to be transferred to a third party - consumer against payment. I would like one Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 12 January 28, 2004. Annex 6 more time to draw your attention to the question about the emissions, which will be reduced because of the project activities. In fact, this is the mechanism "joint implementation" which has nothing to do with the mechanism "emission trade", which in practice, is a trade with historically accomplished reduced amount of emissions. I believe that I haven't been too circumstantial. In the work group were pointed out the main benefits, which are respectively: Global warming effect reduction, state policy realization in the field of forest management by means of extraction and utilization of the residues from the thinnings. Also the priority areas for afforestation could be the areas under erosion or the abandoned areas. It is possible to omit some of the significant benefits. Some very serious remarks were made, as well as some recommendations. As an extremely important remark the group considered the issues about determination of the maximum which can be extracted from the forest without having negative impact on the existent forest ecosystems. Also one of the main recommendations was to apply the project observing the existent landscape. My colleague will present the rest of information. Yancho Naidenov: First, to the third remark - as for the accepted at present over exploration of the forest, I will remind that the ring road is the picture in Bulgaria that has been around the Iskar gorge in the mid 19th to the 20th century. As a result of that, active processes of erosion have aroused and about the 20s the Bulgarian government has been forced to move part of the population round the Iskar gorge and take active afforestation activities. My organization takes care of forest of 74 forestry board enterprises. In considerable part of them the transmitted plan for meeting the requirements of the vouchers for energy needs many times exceed the utilization. From the 9 thousand cubics according to the forest management project 19 should be harvested. Guess on account of what happens so. Not to speak that part of this wood should be with entirely different purpose and price. As for the forth recommendation - it is related with that still the energy plants, established for implementation of the program, should supplement the existent landscape. The matter is very wide and I will stop here, because I have to say two more notes. I am interested in something: This EIA of FDP is made in agreement with the Bulgarian government, right? If it's so I consider that in some issue it is not according to the relevant legislation. My second question is - Who will accept this assessment? The last thing I would like to say, and it will take no more than a minute - it's not a chance that I asked about the differentiated taxes for the forest resource use. Generally, they divide the forest in- groups, depending on their economical and ecological significance, accessibility and a set of indicators. The current system of payment, utilization as a percent of the selling price, stimulates exactly the destruction of the best forests. I am afraid that the forests with special purpose and the protected areas will be "attacked". Thank you! Questions and recommendation Andrei Kovachev, Association Wild Nature "The Balkans": This part of the project should not get into the riverside habitation and damp zones. These are the high conservation value areas. There is a question to the EA team: Is there any assessment of the prize tendencies? I am afraid that in 5 years in connection with the fuel prize rising there will be a mass return to electric power and the whole Project will turn out worthless. Radi Radev: I have the following suggestion: in such outlined framework of the Project, which we understood today and which is not compliant with the presented, as it was said, the connection of that Project with the entire project for the forest sector restructuring should be appraised very carefully. And second - if this framework is accepted, to my mind it covers only one element, which is hardly the most effective. This could be a subject of previous discussion. Envirotmiental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by IN DU FOR. 13 January 28, 2004. Annex 6 Spas Todorov: I will allow myself to express a different opinion. I respect the statement of the coordinator of the Fuel Switch Project, but I consider that the proposed scheme of the EIA team is correctly applied to the idea and the whole project. In respect to the framework, to the significant ecological problems, related to the heating systems and the present significant environmental issues, to my mind the requirements to comment the main issues are met. On the other hand, really they are not complete and at some points are partial. I associate to that opinion of yours. However I would not reject 100% with light hand, what is purposed, because there are rational elements. Thank you! Answers Yeni Katzarska: I will go back to that object of the economical expedience of the application of the fuel switch is the commencing preliminary study, which will start the next week. And this project is not a dogma - it is not said that if there is no advisability, despite everything "Kremikovci"/ that's a key metallurgic factory / will be established in the forests - I will pernit myself to make this reference. Part of this preliminary study is the economical and financial analysis of the realization of such projects. I hope that with this I answer your question and as for the question about the comparison of the cost with that of the electric power - I wouldn't rely as you on that the price of the electric power would be the lowest. At least my contacts with Ministry of energetics makes me think negatively and not to count on that. But I consider that we should not lead our discussion on the basis of presumptions and admissions. Question Velichko Velichkov, MEW: I have a question - in principal, all the installations for burning the mineral fuels; coals and naphtha are provided with fittings for purification. So the emission of hazardous substances in the atmosphere is controlled. Do you think that in the process of fuel wood burning are excreted hazardous emissions? That's my first question. At present, in Bulgaria are harvested about 2 - to 2 300 mill.. cubic meters of fir. You stipulate 100 ha afforestation, which in the optimum statements/ accounts/ will provide from 300 to 500 cubic meters wood. These things are just some kind of game. And I would like to add something else - don't you think that at present the fuel wood prize is very low and for that reason the Project could seem ineffective? But in the rich countries people allow themselves to use fir only in weekends. On the first place, in this respect, is Canada. Answer Yeni Katzartza: I will ask you to leave the examples for another time, because probably all the participants now which are the examples. If that was the question let me answer it. Going back to the question for purifying installations I would like to move back to the brief summary of the project, which I made at the beginning. First, this is a pilot project. The fittings will be smaller than the sulphur purifying installations. According to the requirements of the Law on Environment preservation by MWE, installations over 50 MW are liable to EIA. In wood burning there is no sulphur emissions, so the purifying installations of this kind are not necessary. The need for EIA is clarified by Regulation N2 2 for the procedure of EIA implementation and for each installation under 50 MW and a relevant EIA could be instructed by the Regional Environment Inspection. Also, I would like to add that yes, there will be hazardous emissions, mainly dust particles. In the process of pre-project study the most suitable type of boilers will be selected, and the use of "pirolysa" boilers is not excluded, whereas there is no emission of dust particles. That was for the first question. I do not want to go back to the question about the fuel prizes; we shall round in a close circle. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 14 January 28, 2004. Annex 6 I would like to draw your attention to what we specified that the residues of the thinning should be used. The question does not concern the fuel fir cutting. That's why I asked for attention to the summary I made at the beginning. Comment Spas Todorov: Just not to leave my friend Velichko Velichkov with the impression that we avoid his question - the hospital in Ardino spends 40 thousands lv during the winter period for heating with oil residue. So the chief doctor comes and says: " Make the things in such a way so we don't pay this money". If you make a simple calculation and the forests are used in this region - the thinnings that aren't skidded and the sawdust, which remain and when they are treated with catalyst it turns out that cold be implemented for about 8-10 thousand lv. So that's the first thing The second - for a resource and raw material it is not relied on these 100 ha, which will be afforested and which will grow after a certain period of time - after 20-30. This is just a side-element of the Project .The main resources should be available and by communal and private forests, not by state ones but I won't go into details. Thank you! Plamen Dimitrov: I would like to thank to the leaders of the work groups and their members for the fruitful work I would suggest applauding the presentations. Thank you! Closing words Sipi Jaakkola: Thank you! What I could say in respect to the discussion in the work groups and the results is that they were very intensive. Certainly, most of us would like to continue till 8 a clock, but unfortunately it is already time to leave this hall. Thank you once again for the strenuous. Do you have some general comments concerning the today's work? Thank you! Andrew Mitchel: If someone has any comments on the designed FDP environmental impacts please do not hesitate to contact with my colleagues or me! Sipi Jaakkola: Thank you! You will receive our address to contact us! The concluding notes: We have the written summaries of the work group outputs. This discussion was recorded on audiotapes, which will be carefully analyzed by our EIA team. The written conclusions, we shall draw, will be available for anyone. I would hesitate to go in details after that discussion, in which there wasn't consensus and agreement on many issues. You gave a really worthy contribution for the EIA of the Project, and we shall profit by it. The following steps: Our team will elaborate the whole work on EIA and the systems for control. After that - on 5th of December we shall present a Draft Report. Then there is a period for its review and presentation. This period is specially intended for your comments on the Draft Report. I shall urge you to take the opportunity to make your comments. Then we shall review them and incorporate them in development the EIA Final Report up to the end of December. Then follows the procedure on its review and the introduction/acquaintance with it. The Final Report will be publicly available in so called "info shop" during the period of 120 days. Briefly, this is the entire process. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 15 January 28, 2004. ANNEX 7 III Stakeholder Workshop Annex 7 STAKEHOLDER WORKSHOP ON ENVIRONMENTAL ASSESSMENT OF THE FOREST DEVELOPMENT PROJECT Ministry of Agriculture and Forestry Wednesday, 17 December 2003 13.00- 17.00 Hours Co-organized by the Ministry of Agriculture and Forestry, Project Preparation Unit of FDP and Indufor Oy - AGENDA - until 13.00 Registration 13.00 - 13.10 Opening by Mr. Nikolay Yonov Presentation of the Draft EA Report, including the Environmental Management 13.10 - 14.30 Plan - Mr. Jussi Lounasvuori 14.30 - 15.00 Coffee break 15.00 - 16.30 Discussion Session focusing on the stakeholders feedback on Draft EA Report Introduction by: Mr. Jussi Lounasvuori 16.30- 17.00 Concluding session: Mr. JussiLounasvuori Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by [NDUFOR. January 28, 2004. Annex 7 List of the participants in the Third Stakeholder Workshop on EA of the FDP held in the Ministry of Agriculture and Forestry, on 17 December 2003 N° NAME ORGANIZATION / INSTITUTION STAKEHOLDER GROUP I Ivan Ivanov Sinite Kamani NP Institutional/administrati ve (I/A) 2 Vasil Stiptzov BSFP Project 3 Spas Todorov PPU/FDP Project 4 Aleksander Forestry Institute - BAS Science/research Alexandrov 5 Emilia Stoineva Executive Environmental Agency (I/A) 6 Georgi Gogushev RFB Blagoevgrad (I/A) 7 Darina Veselinova Sofia SF (I/A) 8 Svetla Bratanova Central Laboratory in Ecological Science/research Investigations - BAS 9 Toshko Barzilov National Fire Management Service (I/A) 10 Ivanka Dushkova Union for Development Social 11 Andrei Kovachev "Balkani" Ecological Association Environmental NGO 12 Jancho Najdenov Forest Protection Service - Sofia Science/research 13 Julia Nikolova MEW (I/A) 14 Michaela Yordanova Eco-organisation - Rodopi Environmental NGO 15 Galina Manova Regional Environmental Inspection - (I/A) Blagoevgrad 16 Antonii Stefanov BULPROFOR NGO 17 Ilija Peichev Ministry of Economy (I/A) 18 Stanislav Lazarov GBFP Project 19 Andrew Mitchell PP/FDP Project 20 Boriana Borisova Ministry of Regional Development (I/A) 21 Emil Rakadjiev NFB (I/A) 22 Zhivko Bogdanov WWF - DCP Bulgaria Environmental NGO 23 Snejana Kostadinova ACG - social assessment of the FDP Project 24 Anton Bambalov RFB - Plovdiv (I/A) 25 Geko Spiridonov Nature fund Environmental NGO 26 Mihail Mihailov Rilski Manastir NP (I/A) Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 15, 2004. Annex 7 Minutes of Meeting Location: Ministry of Agriculture and Forestry, room 400, Sofia Date: Wednesday, December 17, 2003 Time: 13.00 - 16.30 Hours Subject: Discussion of the EIA draft report on FDP 1. Presentation on the findings of the draft EIA Report by Mr. Jussi Lounasvuori 2. Discussion of the draft EIA Report. Geko Spiridonov: I appreciate the EIA draft report. It is obvious that the EIA team cannot assess something, which is not yet developed. However, I still have some comments: a. HCVF and the impact of the forest road extension on these forests and areas. I suggest that in the indicators marking the success of the project might be mentioned that one of these indicators should be the extension of the protected territories. I also suggest that we should use the term "HCVF" instead of "valuable forests". In the project should be incorporated the data available on CORINE and Natura 2000 sites. b. According to the WB, this project is in category "A" and it should be subject to complete Environmental Assessment. Since the Forest Road Master Plan is not ready yet, detailed guidelines should be given by the EIA Team in advance. c. NPs under the State Forest Company (SFC). SFC is actually an enterprise, and that's why, I consider that the SFC will be oriented towards economical benefits and interested in making savings. Presently, the staff of the NPDs is not sufficient. When there is contradiction between the economical and the environmental interests, the problems will arise and affect the NPs. Is there any alternative to exclude the NPDs from the structure of the SFC? I suppose that this issue should be also commented by the Ministry of Environment and Water, but as far as I know they haven't made any comments yet. Jancho Naidenov: I am glad that one of my previous remarks has been taken into account. It was about the forest roads and namely that not only the design and the construction of forest roads are important, but also their maintenance. However, I have some additional remarks: 1) Forest health: the data about defoliation of Bulgarian forests used in the report is not correct. 2) Forest fires: fire management should start at the earliest time possible. 3) The expression "carbon sequestration" should be replaced by "restoration and optimization of carbon balance". 4) It is mentioned in the report that the artificial plantations are devastated, which is not the case. In many plantations succession processes, typical for the natural stands are going on. 5) I share the concern that the new forest roads may have negative impact if they provide access to not accessible forests, which are the most valuable and well-preserved forests. Env ironmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUIFOR_ 3 January 15, 2004. Annex 7 Jussi Lounasvuori: I am also concerned about the forest road network and the management of the NPs. The both comments from Mr. Spiridonov and Mr. Naidenov have touched these issues and placed similar questions. Regarding the forest roads, I have already mentioned that it is difficult to perform a detailed assessment on this stage. I rely very much on the development of the Forest Roads Master Plan (FRMP). It should carefully consider the HCVF. The NGOs have suggested that the FRMP should be subject of Strategic Environmental Impact Assessment. This will afford an opportunity to influence the decisions for the future development of the forest road network. About the Nature Parks: Many concerns that the NPs should not be under the control of the NFC have been raised. So, I would like to place again the question: NPs under the NFC or not? What do you think? Jancho Naidenov: I think that the NPs should stay under the Forest Institution. It is a good indication that the state has managed to preserve the NPs until now. This is not the case with the National Parks, for example the new ski slopes on the territory of Pirin National Park. Vasil Stiptzov: There are different positions regarding the management of the NPs. If the NPs are under the National Forest Company, after 5 - 6 years they will be either closed down, either excluded from the NFC. Many of the activities that are undertaken in the NPs require investments, and the NFC will expect the subsidies for the management of the NPs. This means that on one hand the NFC will expect financial means for implementation of the necessary activities in the NPs and on the other hand - compensations. As an enterprise, the NFC will be interested to generate incomes and to reinvest. I find that it is inadequate that there is no department dealing with economics in the new structure. Nothing is mentioned about the condition of the harvesting companies. They are supposed to undertake 80 % of the harvesting activities of the NFC, but do they have adequate resources?! Regarding the report of the Restructuring Study, I will say that the economical aspect is missing or is poorly developed. All this means that attention should be paid to the economical issues. About the Forest Certification: Why do we need a National Certification Standard since there are FSC and PEFC standards already developed?! The draft NCS has not been yet approved by the FSC or PEFC. Actually, I consider as a positive that the FDP is paying special attention to the forest certification. I would like to say that if we want to achieve sustainable forest management not only the forests should be certified but also the harvesting/logging companies. These companies should be certified according to ISO or other certification bodies for qualitative certification. Thus will be achieved a better control. Jussi Lounasvuori: Generally, the findings of the report correspond to the opinions and statements expressed today. The next task will be to incorporate your feedback in the final report. Thank you for being here today and thank you for the valuable comments. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 4 January 15, 2004. ANNEX 8 Forest Statistics Annex 8 FOREST STATISTICS Table 1 Main Statistical Characteristics of the Forest Fund Regarding the Forest Types in Year 2000 Forest type Forested area, ha Total growing stock, Mean Mean Mean Mean ha m3 age, incre- stock stand years ment per ha density ~~~~~~~~per ha Conifers 1 114 674 33.0 231 822 686 44 42 6,735 221 0,75 High stem broadleaved 704 374 20.8 148 293 645 28 67 3,574 193 0,74 forests Forests for 535 438 15.8 23 790 301 5 48 1,022 44 0,60 reconstruction Coppice forests for 900 309 26.6 115 304 775 22 48 2,971 130 0,76 conversion Coppice forests 1 23 349 3.65 6 851 720 1 20 4,051 55 0,80 Total 3 375 117 100.0 526 063 127 100 49 4,00 156 0,73 Source: NFB Table 2 Protective Forest Areas in Bulgaria Forest category Total area Forested area ha % ha % Protective 540 867 13.8 432 882 12.7 Water-preserving 245 452 6.3 221 237 6.5 Erosion-preventing and soil conservating 252 538 6.5 175 312 5.2 Ameliorative 42 877 1.1 36 333 1.1 Other protective 251 170 6.4 232 153 6.8 Nurseries 747 0.02 96 0.003 Cultural heritage monuments 1 584 0.04 1 463 0.04 Hunting management areas 174 426 4.5 160 312 4.7 Seed-producing stands and plantations 40 825 1.0 40 474 1.2 Tree gardens and geographic plantations 1 908 0.05 1 596 0.05 Botanical gardens and zoos 166 0.004 160 0.005 200m-area surrounding huts and monasteries 95 0.002 77 0.002 Buffer areas 7 953 0.2 7 135 0.2 Owned by other departments 23 466 0.6 20 840 0.6 Recreational 247 611 6.3 222 757 6.6 Woodland resorts 132 403 3.4 122 649 3.6 Green zones and systems 97 531 2.5 85 116 2.5 Country parks 17 677 0.5 14 992 0.4 Total 1 039 648 26.5 887 792 26.1 Source: NFB Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28. 2004. Annex 8 Table 3 Protected Areas in Bulgaria No Category Total number oi Total area of PA ii Area included in Percentage of PA in Bulgaria Bulgaria (ha) in the forest fund in PA within the in 2002 2002 2000 Forest fund I Reserves 55 76 979.0 58 177.00 75.58 2 Support Reserves 35 4 517.1 945.00 20.92 3 National Parks 3 150 362.3 119 226.00 79.29 4 Nature Parks I 1 247 604.0 179 338.09 72.43 5 Protected landscapes 146 39 000.2 21 878.00 56.10 6 Natural landmarks 473 23 318.3 10 007.00 42.91 Total 723 541780.9 389 571.09 71.91 Source: NFB Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. a ANNEX 9 Environmental Impacts of Current Practice Annex 9 ENVIRONMENTAL IMPACTS OF MANAGEMENT OF STATE-OWNED PRODUCTION AND PROTECTIVE FORESTS Environmental Impacts Timber Production Forests Protective Forests (Game, Watershed, Erosion) Current Deviation from Current Deviation from Practice Current Practice Current Practice Practice 1. Forest Products + + + - Wood products Low utilization of forests, over- Controlled utilization of forests, exploitation of accessible mature lack of silvicultural operations; forests, lack of silvicultural Illegal logging, fires, uncontrolled operations; Illegal logging, fires, grazing uncontrolled grazing - Non-wood products and services Over-exploitation possible; Game management adequately Poaching, controlled; Poaching 2. Flora and Fauna i - - Habitats and species Biodiversity is threatened by forest Biodiversity is threatened by forest management activities (e.g. removal management activities (e.g. removal of decaying wood) of decaying wood) 3. Soil I -_ - I- - Stability of soil, mechanical Damages to soil due to skidding and Damages to soil due to skidding and disturbance road construction road construction, special attention paid to erosion control - Nutrient balance Minor impacts Minor impacts - Water Minor impacts due to road Minor impacts due to road construction construction - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 4. Water I-- - I- - Water abstraction Temporal changes possible Temporal changes possible - Soil particles / nutrients Silting of water bodies due to road Silting of water bodies due to road construction and skidding construction and skidding, special attention paid to watershed management - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 5. Air I- - I- - Air pollution Minor impacts Minor impacts - Ambient noise Minor impacts Minor impacts 6. OHS I -_ I -_ - Hazardous compounds Minor impacts Minor impacts - Injuries Possible due to inappropriate Possible due to inappropriate techniques, safety equipment techniques, safety equipment - Air quality No actual impacts No actual impacts - Workplace noise Threshold of 85 dBA can be Threshold of 85 dBA can be exceeded exceeded 7. Social issues + + - + + - - Employment / income Positive impacts Positive impacts - Local economy Positive impacts Positive impacts - Living conditions Usually positive impacts Usually positive impacts - Landscape May have negative impacts May have negative impacts - Cultural values May have negative impacts May have negative impacts Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. Annex 9 ENVIRONMENTAL IMPACTS OF MANAGEMENT OF PRIVATE AND COMMUNAL FORESTS Environmental Impacts Private forests Communal forests Current Deviation from Current Deviation from Practice Current Practice Current Practice Practice 1. Forest Products - Wood Over-exploitation of mature forests, Over-exploitation of mature forests, lack of silvicultural operations; lack of silvicultural operations; Illegal logging, fires, uncontrolled illegal logging, fires, uncontrolled grazing grazing - Non-wood products Over-exploitation possible; Over-exploitation possible; Poaching, Poaching, 2. Flora and Fauna -T- - 1-- - Habitats and species Biodiversity is threatened by forest Biodiversity is threatened by forest management activities (e.g. removal management activities (e.g. removal of decaying wood) of decaying wood) 3. Soil I --I -_ - Stability of soil, mechanical Damages to soil due to skidding and Damages to soil due to skidding and disturbance road construction road construction - Nutrient balance Minor impacts Minor impacts - Water Minor impacts due to road Minor impacts due to road construction construction - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 4. Water I -_ I -_ - Water abstraction Temporal changes possible Temporal changes possible - Soil particles / nutrients Silting of water bodies due to road Silting of water bodies due to road construction and skidding construction and skidding - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 5. Air | - - Air pollution Minor impacts Minor impacts - Ambient noise Minor impacts Minor impacts 6. OHS* i - Hazardous compounds Minor impacts Minor impacts - Injuries Possible due to inappropriate Possible due to inappropriate techniques, safety equipment techniques, safety equipment - Air quality No actual changes No actual changes - Workplace noise Threshold of 85 dBA may be Threshold of 85 dBA may be exceeded exceeded 7. Social issues +++ - ++-- - - Employment / income Positive impacts Positive impacts - Local economy Positive impacts Positive impacts - Living conditions - Landscape May affect negatively May affect negatively - Cultural values May affect negatively May affect negatively Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 3 January 28, 2004. Annex 9 ENVIRONMENTAL IMPACTS OF REHABILITATION AND CONSTRUCTION OF FOREST ROADS Environmental Impacts Rehabilitation of Existing Roads Construction of New Roads Current Deviation from Current Deviation from Practice Current Practice Current Practice Practice 1. Forest Products + + + + - Wood Facilitation of efficient use of wood New areas available for logging resources; Risk for illegal logging operations, reduced operational increases, improved fire control costs, logging causes less damages to standing trees, improved fire control; Risk for illegal logging increases - Non-wood products Improved utilization opportunities; Improved utilization opportunities, Risk for unauthorized activities hauling of timber causes less increases damages to vegetation, improved fire control; Risk for unauthorized activities increases 2. Flora and Fauna - - - Habitats and species No new areas affected; Access to new areas with BD Unauthorized activities may affect values, fragmentation, improved habitats and species fire control; Unauthorized activities may affect BD 3. Soil I -_ - Stability of soil, mechanical Minor changes only May result in landslides and disturbance erosion etc.; less soil damages due to harvesting - Nutrient balance No actual changes Minor changes - Water No actual changes May result in drying of soil - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) - Procurement of soil materials for May result in erosion May result in erosion road construction 4. Water - - - Water abstraction Temporary deterioration Temporary deterioration - Soil particles / nutrients Silting of watercourse Silting of watercourses - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 5. Air - | - Air pollution Minor impacts Minor impacts - Ambient noise Minor impacts Minor impacts 6. OHS I. - Hazardous compounds Not in use Use of explosives - Air quality Dust may be a concern Dust may be a concern - Workplace noise Short noise peaks possible Short noise peaks possible 7. Social issues + + i + + - Employment / income Positive impacts Positive impacts - Local economy Positive impacts Positive impacts - Living conditions Improved transportation Improved transportation connections connections, resettlement and take over of private property - Landscape No actual impacts May affect negatively - Cultural values No actual impacts May affect negatively Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 4 January 28, 2004. Annex 9 ENVIRONMENTAL IMPACTS OF REHABILITATION OF FOREST FIRE SITES AND THINNING OF YOUNG AND FIRE PRONE STAND Environmental Impacts Regeneration and Rehabilitation Thinnings Current Deviation from Current Deviation from Practice Current Practice Current Practice Practice 1. Forest Products + + + + - Wood Aim is to achieve viable and Aim is to improve the quality of commercially valuable growing remaining trees, improved stock resistance to fire; Possible damages to standing trees - Non-wood products Improved growing conditions for Only low risk for damages caused non-wood products by thinnings 2. Flora and Fauna + + - - - - Habitats and species Rehabilitation and regeneration No major impacts in plantations, would lead to more diversified felling of coppice species decreases flora and fauna biodiversity 3. Soil I -_-I-_ - Stability of soil, mechanical Soil preparation causes mechanical Soil damages due to skidding are disturbance disturbance of soil possible - Nutrient balance Minor changes Negative impacts, if residues are removed - Water Forest cover leads to improved Minor changes only capacity to absorb water - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 4. Water I -_ I -_ - Water abstraction Impacts are negligible Impacts are negligible - Soil particles / nutrients Silting of watercourses, nutrient Silting of watercourses, nutrient increase increase - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 5. Air I - - - Air pollution Minor impacts from equipment Minor impacts from equipment - Ambient noise Minor impacts from equipment Minor impacts from equipment 6. OHS - Hazardous compounds Not in use Not in use - Air quality Minor impacts (e.g. dust) Minor impacts (e.g. dust) - Workplace noise Noise of mechanical site Noise of chain saws and timber preparation hauling vehicles 7. Social issues + + - + + - Employment / income Positive impacts Positive impacts - Local economy Positive impacts Positive impacts - Living conditions Stabilization of the environment Minor impacts - Landscape No actual impacts May affect negatively - Cultural values No actual impacts May affect negatively Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 5 January 28, 2004. Annex 9 ENVIRONMENTAL IMPACTS OF HEATING PLANTS Environmental Impacts Existing he ting systems New heati g systems Current Deviation from Current Deviation from Practice Current Practice Current Practice Practice 1. Use of natural resources + - - Fuels Non-renewable fuel oils and coal Renewable biofuels, fossils as auxiliary fuels - Others Electricity, office supplies etc. Construction materials, electricity, office supplies etc. 2. Soil I - - -_ - Hazardous substances Sites are typically contaminated Leaks of auxiliary fuels and with oil; Leaks and emergency emergency situations are possible situations are possible 3. Water I -_ -_ - Protection of watercourses Leaks from oil containers and Leaks of auxiliary fuels and emergency situations can affect emergency situations can affect - Water abstraction Leaks from oil containers and Leaks of auxiliary fuels and emergency situations can affect emergency situations can affect 4.Air I -_ ++ - - Air pollution Stack emissions; peaks due to start- Stack emissions; peaks due to start- ups, fires and other emergency ups, fires and other emergency situations situations - Ambient noise Minor impacts Minor impacts 5. Waste management - - - Hazardous wastes Disposal of burning rejects Disposal of burning rejects - Other hazardous wastes Disposal of waste oils etc Disposal of waste oils etc 6. OHS F - - Hazardous compounds Handling of oils etc. Handling of oils etc. - Air quality Minor impacts; accidents Minor impacts; accidents - Workplace noise Threshold of 85 dBA can be Threshold of 85 dBA can be exceeded exceeded 7. Social issues ++ - + + - - Employment / income Heat plants are employers Construction of plant and heat production give jobs - Local economy Financial resources are tied up with Positive impacts as heat production fuels that could replaced by local is based on local fuels ones - Living conditions Expensive heat supply; fires and More reliable and cheaper heat other emergency situations supply; fires and other emergency situations - Landscape No actual impacts No actual impacts - Cultural values No actual impacts No actual impacts Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 6 January 28, 2004. Annex 9 ENVIRONMENTAL IMPACTS OF FUEL SUPPLY SYSTEM Environmental Impacts Fuels from existing forests / Fuels from fast growing plantations and industry plantations Current Practice Deviation from Current Deviation from Current Practice Practice Current Practice 1. Forest Products + + + + - Wood Promotion of thinning, commercial Afforestation will increase forest value of fuel wood from thinning; cover and wood supply; risk for Possible damages to standing trees outbreak of pests and fungi - Non-wood products Only low risk for damages caused by No major impacts thinnings (plantations) 2. Flora and Fauna - I - Habitats and species No major impacts, if the starting point Establishment of plantation may is mono-culture, felling of coppice destroy valuable habitats (e.g. species decreases biodiversity coppice species), mono-culture 3. Soil I -_ I -_ - Stability of soil, mechanical Soil damages due to skidding are Soil preparation causes mechanical disturbance possible disturbance of soil - Nutrient balance Nutrient depletion, if branches and tree Nutrient depletion due to full tree tops are removed harvesting - Water Minor changes only Forest cover leads to improved capacity to absorb water - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 4. Water I --I - - Water abstraction Impacts are negligible Impacts are negligible - Soil particles / nutrients Silting of watercourses, nutrient Silting of watercourses, nutrient increase increase - Hazardous substances Accidents possible (leaks) Accidents possible (leaks) 5.Air ++ - I - - Air pollution Minor impacts from equipment, (e.g. Minor impacts from equipment chippers and trucks) (e.g. chippers and trucks) - Ambient noise Minor impacts from equipment Minor impacts from equipment - Cleaning of atmosphere New plantations are carbon sinks 6. OHS I -_ - Hazardous compounds Not in use Not in use - Air quality Minor impacts (e.g. dust) Minor impacts (e.g. dust) - Workplace noise Noise of chain saws and timber Noise of mechanical soil hauling vehicles preparation, noise of chain saws and timber hauling vehicles 7. Social issues + + + + - Employment / income Positive impacts Positive impacts - Local economy Positive impacts Positive impacts - Living conditions Minor impacts Stabilization of the environment - Landscape No actual impacts May affect negatively - Cultural values No actual impacts May affect negatively 8. Fuels from industrial sites + + - Wastes Improved recycling of wood-based wastes, decreased volumes available for local people Environrmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 7 January 28, 2004. ANNEX I0 Outline of Best Management Practice for Design and Construction of Forest Roads i b1) Annex 10 BULGARIA FORESTS DEVELOPMENT PROJECT PROJECT PREPARATION NUMBER PE-P033964 Outline of Best Management Practice for Design and Construction of Forest Roads Submitted by Project Management (Ireland) Ltd Final Draft - 16th October 2003 ~b1) JAnnex 10 TABLE OF CONTENTS SECTION I ENVIRONMENTAL CONSIDERATIONS 1 1.1 Introduction 1 1.2 Environmental Values 2 1.2.1 Soil 2 1.2.2 Water Quality 2 1.2.3 Landscape 2 1.2.4 Ecological and Scientific 2 1.2.5 Cultural and Archaeological 3 1.2.6 Biodiversity 3 1.2.7 Forest Protection and Health 3 1.3 Environmental Impact Assessment 3 1.3.1 Initial Environmental Evaluation 3 1.3.2 Screening Procedure 3 1.3.3 Mitigation Measures 4 2 SECTION 2 -FOREST ROADS 4 2.1 Road Planning 4 2.2 Forest Road Design 5 2.3 Road Location 5 2.4 Road Construction 5 2.5 Road Drainage 7 2.6 Embankment Slopes 7 2.7 Stream / River and Watercourse Crossings 8 2.8 Quarries, Pits and Fill Disposal Areas 8 2.9 Road Curves, Junctions, Passing and Turning Places 9 2.10 Road Maintenance 10 2.11 Suspension of Timber Transport 10 3 GLOSSARY 17 Appendix I Checklist for Initial Environmental Evaluation Appendix 2 Road Maintenance Inspection and Risk Rating Appendix 3 References Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agnculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. PM J Annex 10 Executive Summary Forest roads are necessary to provide access to the forest for general management, harvesting, fire protection, security and recreation. The purpose of these Best Management Practice guidelines is to ensure that all stages in the planning, design, construction and maintenance of forest roads are carried out in a manner that is compatible with environmental values and sustainable forest management. The most effective means of reducing impact levels is to ensure that full consideration is given to avoiding riparian areas in the planning of road location and alignment. Identifying and avoiding areas with the potential for negative environmental impact should be a key criteria in the initial planning and design process. Although an Environmental Impact Assessment (EIA) is not legally required for forest road construction in Bulgaria it will still be necessary to undertake an Initial Environmental Evaluation (IEE) at the road planning stage. An IEE consists of a screening procedure and mitigation measures. The IEE should include a description of the local environment and the proposed road development, together with the identification of environmental impacts that are anticipated. While all road construction to be funded under the Forest Development Project will be subject to EIA screening, the Consultants strongly recommend that all future forest roading projects be subject to the same procedure. Phase Best Practice Planning Potential environmental risks and construction difficulties are identified at road planning stage to ensure adequate design standards consistent with minimising environmental impacts. Design New and upgraded roads designed to a standard capable of carrying anticipated timber haulage traffic for a crop rotation to meet environmental requirements and with safety. Design should be done the year before construction, to allow adequate time for review. Location Roads located so as to minimise risks to environmental values and road construction to take account of environmental values during all stages of formation and completion. Construction Forest roads and access points to county roads constructed in planned engineering stages, to minimise disturbance to the site, and well in advance of timber harvesting and road haulage. Drainage Roads properly formed, consolidated, completed and drained to ensure that the impact of run-off on water quality is minimised. Maintenance Road surfaces and drainage works maintained to protect the road foundation, disperse water and minimise environmental impact. Each of the Best Management Practices are supported by a series of implementation guideline Environmental Assessment of the Forest Development Project, Bulgaria Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. jj January 28, 2004 1PI 12 Annex 10 SECTION 1 ENVIRONMENTAL CONSIDERATIONS 1.1 Introduction Forest roads are necessary to provide access to the forest for general management, harvesting, fire protection and recreation. Their construction represents one of the more visible forestry operations and can have a number of environmental impacts including landscape, water, soil, habitat and social / community. The purpose of these outline Best Management Practice guidelines is to ensure that all stages in the planning, design, construction and maintenance of forest roads are carried out in a manner that is compatible with environmental values and sustainable forest management. The protection of forest habitats should be a priority when designing, constructing, rehabilitating and maintaining forest roads. These guidelines are to be used in conjunction with existing Bulgarian norms and regulations and compliance with them will form part of the tender procedures for the roading component of the World Bank Forest Development Project. Road works can have a number of environmental impacts and these need to be considered during all phases of road work, from initial road alignment / route selection through design, construction and maintenance. The most effective means of reducing impact levels is to ensure that full consideration is given to avoiding riparian areas in the planning of road location and alignment. Identifying and avoiding areas with the potential for negative environmental impact should be a key criterion in the initial planning and design process. Phase Best Practice Planning Potential environmental risks and construction difficulties are identified at road planning stage to ensure adequate design standards consistent with minimising environmental impacts. Design New and upgraded roads designed to a standard capable of carrying anticipated timber haulage traffic for a crop rotation to meet environmental requirements and with safety. Location Roads located so as to minimise risks to environmental values and road construction to take account of environmental values during all stages of formation and completion. Construction Forest roads and access points to county roads constructed in planned engineering stages, to minimise disturbance to the site, and well in advance of timber harvesting and road haulage. Drainage Roads properly formed, consolidated, completed and drained to ensure that the impact of run-off on water quality is minimised. Maintenance Road surfaces and drainage works maintained to protect the road foundation, disperse water and minimise environmental impact. Table 1: Environmental Values for Various Road Phases Post construction monitoring and maintenance have been neglected in recent years. They are however critical to ensure that structures are operating as designed and installed, and that where problems are occurring or likely to occur, remedial measures are taken. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. January 28, 2004. i",It) Annex 10 1.2 Environmental Values In order to plan and manage forest operations (including road construction) in a sustainable manner, it is necessary to identify certain forest values which need to be safeguarded. These values can be broadly classified as environmental, economic and social, with associated constituent values. Environmental Values Economic Values Social Values Soil Sustained productivity Rural development Water quality Commercial viability Amenity and recreation Landscape Safety Ecological and scientific Other community values Cultural and archaeological Biodiversity Forest protection and health Table 2: Sustainable Values Necessary in Forest Operations 1.2.1 Soil Soil values relate to erosion, compaction, stability and displacement, and levels of soil fertility. Wet soils can become badly compacted by machine passage. Soil displacement and slippage can occur during road construction with consequent impact on water quality. Damage can be reduced by carefully planning and supervising forest road construction. 1.2.2 Water Quality Water values are concerned with protecting water quality, ecology and stability and controlling onsite and downstream impacts. Harvesting and road construction impact on the hydrology, chemistry and level of sedimentation in aquatic zones, through compaction by heavy machinery, soil displacement and slippage, increased run-off through drainage, and contamination with chemicals and fuel. 1.2.3 Landscape How a forest will look and its composition relative to the landscape must be determined at the initial stage of development, with planting areas, species selection, location of open spaces, firebreaks, road alignments etc. decided upon accordingly. 1.2.4 Ecological and Scientific Ecological and scientific values are concerned with conserving communities of rare or unusual fauna or flora, unique landforms and geology, and areas dedicated to research. Forestry practice and conservation are not mutually exclusive. While many forests are managed within commercial objectives, the balance between these and conservation will depend on structure and composition, and where the forests are located. Forest road construction needs to recognise this balance. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004. PA J Annex 10 1.2.5 Cultural and Archaeological Bulgaria has been inhabited for thousands of years. As a result, the country is rich in the physical heritage of former generations. Many of these sites occur on forest land. 1.2.6 Biodiversity Biodiversity describes the variability among living organisms and the ecosystems of which they are a part. Three conceptual levels of biodiversity are recognized - ecosystem, species and genetic. Forests are complex ecosystems and important sources of biodiversity. Sustainable forest management implies maintaining or increasing non-forest biodiversity such as additional flora through the retention of existing habitat and the treatment of open spaces and edges. Insect, bird, aquatic and mammal diversity can all be enhanced through appropriate management practice. 1.2.7 Forest Protection and Health Health risks to forests arise from pests and diseases. Other threats include fire, wind, snow-break and atmospheric pollution. Forest management practices can reduce the risk of snow-break through the correct timing of road construction and thinning. 1.3 Environmental Impact Assessment Environmental Impact Assessment (EIA) is a process for predicting the effects of a proposed development on the environment. Effects may be positive or negative. The mitigation of negative impacts may then be considered in the design process by the avoidance, elimination or the reduction of their sources together with the enhancement of positive effects. The process should highlight methods for enhancing the positive effects 1.3.1 Initial Environmental Evaluation Although forest road construction is not subject to EIA, it will still be necessary to undertake an Initial Environmental Evaluation (IEE) at the road planning stage. An IEE consists of two components:- * Screening Procedure; and * Mitigation Measures. The IEE should include a description of the local environment and the proposed road development, together with the identification of environmental impacts that are anticipated. 1.3.2 Screening Procedure The purpose of the screening is to ensure that no activity within the scope of the different phases of forest road construction has the potential to impact significantly on the environment. For the purposes of screening, account should be taken in particular of the direct and indirect effects of the planned road construction on the following factors: * Human beings, fauna and flora; * Soil, water, air, climate and the landscape; * Material assets and the cultural heritage; and Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 3 January 28, 2004. P & ) Annex 10 * The interaction between the factors mentioned in the previous three bullet points. Examples of simple screening checklists are given in Appendix 1. The screening should be undertaken by a competent person during road planning and prior to the commencement of any construction activity. 1.3.3 Mitigation Measures If in the opinion of the road designer or the person undertaking the IEE there is the potential or likelihood for any negative environmental impact, then mitigation measures should be proposed to minimize the potential impact. These mitigation measures should be additional to the normal compliance with environmental regulations and national standards. There are three established strategies for mitigation - avoidance, reduction and remedy. The efficacy of each is directly dependent on the stage in the design process at which environmental considerations are taken into account. Impact avoidance can only be considered at the earliest stage, while remedy may be the only option available to fully designed projects. Where mitigation measures are proposed, it will be necessary to ensure that these are complied with in the design and construction phases. 2. SECTION 2 - FOREST ROADS 2.1 Road Plannin2 Forest road planning is the first phase of forest road construction. At this stage, the need for a road has been identified. The objectives to be achieved by a forest road must be clear. The primary purpose of a forest road is that it must be capable of safely carrying timber haulage vehicles. It must also provide satisfactory access to the forest work areas and have minimal impact on its surrounding environment. Best Practice Potential environmental risks and construction difficulties are identified at road planning stage, to ensure adequate design standards consistent with minimising environmental impacts. Best Practice Guidelines (1) Road plans to be based on detailed surveys and environmental care principles that ensure that all environmentally sensitive locations are identified and appropriate design and construction techniques adopted; (2) Road plans to be prepared well in advance of harvesting and transport operations to enable the roads to be located on alignments and grades that provide the required standard of access without compromising water quality and environmental values; and (3) Roads to be kept to the minimum total length consistent with management objectives, located in the best landscape position possible, constructed under suitable weather conditions and well consolidated before use. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 4 January 28. 2004. RIAM ) Annex 10 2.2 Forest Road Design The purpose of road design is to provide the optimum road geometry to accommodate the planned vehicle sizes and traffic. Optimum road design should minimize the cost of construction, transportation, maintenance and impacts on other resources, and provide for user safety and a stable road with appropriate alignments and travel speeds. Best Practice New and upgraded roads designed to a standard capable of carrying anticipated traffic with safety and to meet environmental requirements. Best Practice Guidelines (1) New and upgraded roads to be designed to accommodate the anticipated frequency, type and speed of traffic, soil and sub-grade conditions, road drainage and water quality requirements and landscape and environmental values; and (2) Roads to be constructed on alignments with grades that do not exceed those specified for the road classification. 2.3 Road Location Best Practice Roads located so as to minimise risks to environmental values (including landscape) and road construction to take account of environmental values during all stages of formation and completion. Best Practice Guidelines Roads to be located so that they: (1) Avoid protected areas, scientific research areas, high conservation value and environmentally sensitive areas and designated archaeological and cultural sites; (2) Minimize the number of stream / river crossings and interference with natural drainage; (3) Keep earthworks to a minimum by matching wherever possible, road alignment with topography of the site; (4) Avoid steep and unstable slopes and areas prone to landslips; (5) Avoid disturbance to streams, buffer strips and riparian vegetation; (6) Permit surface run-off to be discharged away from streams or drainage channels as far as is practicable. 2.4 Road Construction Best Practice Forest roads and access points to national roads constructed in planned engineering stages, to minimise disturbance to the site, and well in advance of timber harvesting and transportation. Environmental Assessment of the Forest Development Project. Bulgana. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 5 January 28. 2004. AMJ) Annex 10 Best Practice Guidelines Methods of Construction (1) Methods for the construction of forest roads2 and associated special construction works including the specification of machinery and ancillary equipment to be selected to promote efficient construction and minimise environmental impact. Timing (1) Road construction to be undertaken when snow, rainfall and soil conditions minimize the risk of erosion and subsequent impact on off-site water quality, but recognizing the role of adequate soil moisture in achieving desirable compaction and stabilization of the sub-grade. Clearing Road Alignment (1) The road alignment to be cleared before commencing formation. Any stumps, logs and other forms of debris to be removed to ensure that they are not buried in the load bearing portion of the road. Where necessary, topsoil to be stockpiled in a manner suitable for rehabilitation works with organic and mineral soil stored separately; and (2) The area cleared to be kept to the minimum required for effective construction, and to allow sunlight and air movement onto the road surface for effective drying. Carriageway (1) The formation / carriageway to have a minimum width (m) in accordance with road classification, except along curves and junctions where it shall be extended in accordance with the design standard. Fills and Embankments (1) Fills and embankments to be consolidated and stabilized using currently accepted engineering practices; (2) The side-slope of embankments to be the natural angle of repose of the material; and (3) All faces and slopes requiring stabilization and drainage to be treated prior to the removal of machinery and equipment from the site. Culverts and Drains (1) All roadside drains, culvert drains and other drainage structures to be installed concurrently with the formation of the road. Sections of partially constructed road to be left over-winter or for other extended periods to be drained by out-sloping or cross drains. Partially Built Roads (1) All partially built roads (or those being left to settle) to be closed to traffic until they are completed; and (2) Where road construction is halted or suspended, adequate temporary stabilisation to be employed to deal with site earthworks drainage. Contamination (1) The refuelling and maintenance of machines not to take place close to sensitive sites to prevent spillage of fuel and oils from entering streams and watercourses. 2 Excavator in combination with dump trucks is preferred to the traditional use of bulldozers but this method is only effective where operators have undergone appropriate training. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 6 January 28, 2004. Annex 10 2.5 Road Drainagze Forest road drainage is an important aspect of forest road construction and maintenance. Without good drainage a road will lose considerable strength and as a result will not achieve its design life. A .wet road" may be as little as 25% as strong as a similar well drained road. Proper drainage will reduce a roads impact on the environment. Best Practice Roads properly formed, consolidated, completed and drained to ensure that the impact of run-off on water quality is minimised. Best Practice Guidelines (1) When the formation area is fully stripped, the sub-grade to be shaped to a cambered profile, the degree of camber depending on the nature of the sub-grade material but within the range 200 - 300 mm; (2) Roads to have a minimum gradient of 1:100 to facilitate drainage and water run-off; (3) Roadside drains to be provided to minimize the concentrations and velocity of run-off and ensure that water drains from the road surface; (4) Interceptor drains or culverts to be spaced according to the road grade and have sufficient capacity to convey the peak flow from a 1: 25 year storm event; (5) Silt traps to be provided where necessary to prevent direct discharge into streams and watercourses; and (6) Drainage from road sections outside buffer strips to be discharged before the road enters the buffer strip. 2.6 Embankment Slopes Best Practice Appropriate shaping and drainage of embankment slopes undertaken to assist better stability. Best Practice Guidelines Roadside embankment slopes (both cut and fill) to be constructed and stabilized by: (1) Appropriate sloping, to prevent slippage into roadside drains; (2) Stepping where suitable and where vertical slope is greater than 6.0 m .This is also known as benching or benched foundation - a foundation on a sloping bearing stratum, cut in steps to ensure that it will not slide when concreted and loaded; (3) Revegetating where the soil is highly erodible; (4) Forming interceptor drains above the embankment slope to minimize erosion as appropriate; and (5) Using retaining walls or other engineering structures, as necessary. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 7 January 28, 2004. Annex 10 2.7 Stream / River and Watercourse Crossings Best Practice Stream / river and watercourse crossings by bridge, culvert or ford designed to meet transport needs and minimise impacts on the site and have relevant approvals. Best Practice Guidelines The crossing used in any particular situation to be determined by the nature, size and period of flow and characteristics of the bed and banks of the stream / river and the road classification. Construction operations shall ensure that: (1) Disturbance to the stream bed and banks is kept to a minimum; (2) Fill is not pushed into streams or rivers nor into a position from which it can move into a stream or river; (3) Cement and raw concrete are not spilt into watercourses; and (4) Where practicable, stream / river crossings to be adequately elevated and low approaches maintained such that water drains away from the crossing point. Bridges (1) To be constructed for crossings of streams, rivers and watercourses where culverts or fords are not considered adequate. Bridge design should allow for a 1-25 year flood; and (2) Shall not constrict clearly defined channels and shall be designed and constructed so that the passage of flood water is not restricted. Fords (1) Fords to be as wide as the crossing will allow so that peak flows are well dispersed. The base of the ford to be constructed of erosion-resistant material such as rock or concrete and should conform to the natural level of the stream / river bed. Culverts (1) Culverts to be of a size adequate to carry expected peak flows (1 in 25 year storm) and installed to conform wherever possible to the natural slope and alignment of the stream, river or drainage line; and (2) Culverts to be spaced depending on road gradient and susceptibility of sub-grade to erosion. Excavations and Embankments (1) Excavations for bridges, placement of abutments or girders must, as far as practicable, be made above the high water mark; (2) Earth embankments constructed for bridge approaches must be protected from erosion by one or more of the following: revegetation with naturally-seeded vegetation or planted or sown grasses or ground cover, retaining walls, bulkheads or rock surfacing; and (3) Topsoil to be stockpiled in a manner suitable for re-distribution during site rehabilitation. 2.8 Ouarries. Pits and Fill Disposal Areas Best Practice All quarries, gravel and borrow pit, and fill disposal areas planned and designed to minimise soil erosion, mass soil movement, and water quality deterioration, and be visually unobtrusive. When no longer required they must be rehabilitated. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria. prepared by INDUFOR. 8 January 28, 2004. Annex 10 Best Practice Guidelines Location (1) All rock quarries, gravel pits and borrow pits to be located at such distances from streams, watercourses and riparian zones to minimize the potential damage to stream and riparian values; and (2) Fill disposal areas to be located where the risk of soil erosion, mass soil movement and water quality deterioration is minimal. Drainage (1) During construction and use of rock quarries, gravel pits or borrow pits, run-off water to be discharged into undisturbed vegetation. Where run-off is concentrated it must pass through one or more holding areas sufficient to prevent run-off being directly discharged into streams or drainage lines. Rehabilitation (1) All gravel pits and borrow pits to be used so as to enable progressive rehabilitation in accordance with the staged depletion of the material. When the gravel source is either exhausted or abandoned, such rehabilitation must be completed within two years. Rehabilitation should include removal of all rubbish or litter, grading slopes and ripping compacted areas, spreading previously stockpiled topsoil and revegetating with suitable species; and (2) Care to be taken in restoring a site to minimize danger from overhangs, loose rock and waste material heaps. 2.9 Road Curves, Junctions, Passing and Turning Places Best Practice Road curves, junctions, passing and turning places designed and constructed to facilitate safe and efficient use of the roading network. Best Practice Guidelines Curves (1) The minimum radius of curvature to comply with the norm for the road class; and (2) Formation and carriageway widths shall be widened at curves to allow for vehicle "track-in". Passing Places (1) Passing places to be provided by widening of the carriageway at intervals of approximately 300 - 400 m, with a clear line of sight. Turning Places (1) Turning places to be provided at or near the end of cul-de-sac roads. Road Junctions (1) All road junctions both within the forest and from the forest to the national road should wherever possible be of right-angled bell-mouth design and where not possible, the angle of the road must be at least 45°. (2) Local authorities should be contacted at the road planning stage whenever a junction from the forest to the national road is planned. Environmental Assessment of the Forest Development Project, Bulgaria Ministry of Agriculture and Forestry of Bulgarna, prepared by INDUFOR. 9 January 28, 2004. 1111> Annex 10 2.10 Road Maintenance Best Practice Road surfaces and drainage works maintained to protect the road foundation, disperse water and minimise environmental impact. Best Practice Guidelines (1) Roads to be inspected on a regular basis and assigned a priority risk rating regarding the need for maintenance and reduction of potential adverse environmental impact (Appendix 2). (2) Roads to be maintained as necessary to minimize erosion of the road surface. The surface of roads shall be cambered, and any windrows of soil on the outside of the road shall be regularly breached, except where they have been intentionally constructed for the protection of fills; (3) Vegetation beside roads shall, where necessary, be controlled to improve visibility for drivers and prevent vegetation invading the road surface or blocking roadside drains; and (4) Road drainage systems to be maintained to protect the road from erosion and to minimize discharge of turbid waters into streams. 2.11 Suspension of Timber Transport Best Practice Roads closed to timber traffic when weather or road surface moisture conditions threaten water quality or the integrity and long-term serviceability of the road itself. Best Practice Guidelines (1) Roads to be closed to timber transport in wet conditions when disturbance of the road surface poses a threat to stream water quality through detachment of road surfaces and/or damage to surface drainage of the road; (2) Roads to be closed to timber transport in wet conditions when excessive damage would occur to the road surface; and (3) Timber transport to be suspended in dry weather on roads where the surface materials have unravelled to a degree that poses a threat to stream or wetland water quality in subsequent wet weather. Environmental Assessment of the Forest Development Project Bulgaria. Ministry of Agnculture and Forestry of Buigara, prepared by INDUFOR. 1 0 January 28, 2004. F3II,> Annex 10 APPENDIX 1: EXAMPLE SCREENING CHECKLIST FOR INITIAL ENVIRONMENTAL EVALUATION Receptor Score * Nature of Impact Mitigation Measure People Flora I Fauna Soils Water Landscape Archaeology I Cultural Heritage Material Assets * Evaluate on a scale from -3 to +3, where -3 refers to major negative impacts, and +3 refers to major positive impacts Assessment Signature (prior to initial design): Assessment Date: Completion Signature (during and after construction): Completion Date: Mitigation Measure(s) Implemented: Signature: Date: Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. 11 PA-") Annex 10 Example Screening Checklist for Forest Road Initial Environmental Evaluation Impacts on Environment Impact on Built Environment Impacts on Human Beings Soils, Water Air Flora Lands Buildings Cultural Communi- Health, Quality of Economy Use of Activity Geolo and cape and Heritage cations Smells, life and and natural gy Fauna Structures Noise and recreation Employ- resources ________________________ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~Vibration ment Design Tree Clearance Construction Culverts and bridges Drainage Exploitation & Use Maintenance Improvement / Upgrading Note: Likely potential impacts are evaluated on a scale from -3 to +3, where -3 refers to major negative impacts, and +3 refers to major positive impacts Envirorunental Assessment of the Forest Development Project, Bulgaria Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. 12 Annex 10 APPENDIX 2: ROAD MAINTENANCE INSPECTION AND RISK RATING |Risk Rating Risk rating is a procedure that requires knowledge of two factors: the likelihood of a hazard occurring and the consequence (or severity of impact) should the hazard occur. In quantitative terms, this relationship can be shown as: Risk = Hazard x Consequence Hazard refers to the probability of erosion and stream sedimentation increasing from a given section of road. Consequence refers to the potential impacts on resource, social and economic values that are likely to occur in the immediate area of, or downslope or downstream of the road, if the erosion and sedimentation events occur. There are four levels of risk rating: very high, high, moderate and low. Each is determined according to a combination of ratings for hazard and consequence, as shown in Tables 1, 2 and 3. All roads should receive one documented road inspection per year. Roads having a high or very high risk rating should also be inspected after extreme weather events. Inspection reports, or checklists, must ensure that key road elements are covered and any deficiencies noted. Inspections after extreme weather should be undertaken as soon as possible after the event. Detail noted during the inspection would normally be limited to major maintenance problems. All staff and contractors who travel on forest roads should be encouraged to report any road maintenance problems that they encounter in the course of their work. All remedial work must be carried out within a time period that is commensurate with risk to the road, its users and the environment. The road is located on terrain with visible or suspected evidence of landslides or High mass wasting. It is not limited to any particular side slope, although the steeper the ground, the greater the potential for avalanches and debris torrents. Soils may also be highly erodable. The road is located on stable terrain. Minor problems may develop. Erosion is Moderate limited to small scale slumping and ravelling. Cut and fill slope erosion and surface erosion are generally shallow. The road is located on stable terrain. Normal road construction and harvesting Low practices will not significantly decrease terrain stability. Periodic drain maintenance will likely be required. Soils are generally well compacted. En, ironmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agnculture and Forestry of Bulgaria. prepared by INDUFOR. 1 3 January 28, 2004. Annex 10 Table 1: Hazard Rating On-site Forecast the consequence or severity of the damage or loss to a specific downslope / value, should erosion and sedimentation occur downstream values High Moderate Low Water supply Areas having very high Areas having very high Areas not rated as water values, which, if water values, but less Moderate or High damaged would have a sensitive than those with serious long-term effect high ratings on water quality. Fish habitat Areas having high to very Areas having moderate Areas having low fishery high fishery values fishery values values Wildlife Areas having critical Areas having high wildlife Areas not rated as habitat and importance to wildlife values but less sensitive Moderate or High migration than those with High ratings Forest site Areas having high Areas having moderate Areas not rated as productivity potential to grow potential to grow Moderate or High merchantable timber, merchantable timber which if damaged would have a serious long-term effect on regeneration Human life, Areas having rural N/A Areas that are private development, domestic uninhabited and property dwellings or industrial undeveloped development, highways and railways Utilities Areas having water N/A Areas with no utilities mains, electric transmission, gas and oil lines or fibre optic cable Landscape Areas having very high Areas having high values Areas having non-visible values for viewing and for viewing but less development or low landscape sensitivity sensitive than those with landscape sensitivity High ratings Recreational Areas having very high Areas having high value Areas without, or having value for recreation for recreation but less low, physical, biological, sensitive than those with cultural or historic High rating features Environmnental Assessment of the Forest Development Project, Bulgaria. Ministty of Agriculture and Forestry of Bulgana. prepared by INDUFOR. 14 January 28, 2004. Annex 10 Table 2: Consequence (or Severity) Ratings Hazard Rating Consequence Rating Risk Rating High X High = Very High High X Moderate - High Moderate X High High High X Low Moderate Moderate X Moderate - Moderate Low X High Moderate Moderate X Low = Low Low X Moderate = Low Low X Low - Low Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agniculture and Forestry of Bulgaria, prepared by INDUFOR. 15 January 28. 2004. q~~~~~~~~~~ Annex 10 APPENDIX 3: REFERENCES Cameron, W. 1990: Manual of Prescribed Culvert Installation Methods to Avoid Specific Types of Culvert Failure. University of New Brunswick Clinch B. Logan, B. 1991: Forestry BMPs (Best Management Practices). Forest Stewardship Guidelines for Water Quality. Montana State University. FAO 1989: Watershed Management Field Manual (Road design and construction in sensitive watersheds). Food and Agriculture Organisation of the United, Nations Conservation Guide 13/5 FAO. 1996a. Forest Codes of Practice: Contributing to Environmentally Sound Forest Operations. Forestry Paper 133. FAO, Rome. FAO. 1996b. FAO Model Code of Forest Harvesting Practice. FAO, Rome. FAO 1998: Proceedings of the seminar on environmentally sound forest roads and wood transport. Sinaia, Romania 17-22 June 1996. Food and Agriculture Organisation, Rome Forest Road Engineering Guidebook, September 1995 (Forest Practice Code of British Columbia). Garland, J 1983: Designing Woodland Roads. Oregon State University, Extension Service. Corvallis, Oregon. Lay, M. 1986: Handbook of Road Technology. Volume 1 Planning and Pavements. Gordon and Breach Science Publishers. LIRO 1999: Forest Roading Manual. Logging Industry Research Organisation, New Zealand. Local Government Training Board 1988: RAMM Road Assessment and Maintenance Management System. National Roads Board of New Zealand. Murphy, A. 1985: Forest Transportation Systems - Roads and Structures Manual. University of Maine. National Academy of Sciences. 1978: Geometric Design Standards for Low Volume Roads. Washington, D.C. OECD 1986: Economic Design of Low Traffic Roads. Paris Robinson, R. 1988: Trends in Axle Loading and Their Effect on Design of Road Pavements. Transport and Road Research Laboratory. Great Britain Ryan, T., Phillips, H., Ramsay, J. and Dempsey, J. 2003: Guidelines for the Design, Construction and Management of Forest Roads. COFORD, Dublin, Ireland Talbot, S. 1985: Building Standard Woodland Roads. Nova Scotia Department of Lands and Forests. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 16 January 28, 2004 PAM _>,) Annex 10 3. GLOSSARY BORROW PIT An excavation for obtaining fill material from outside the formation limits. BUFFER ZONES An area adjacent to an aquatic zone and managed for the protection of water quality and aquatic ecosystems. CAMBER (a) The degree of cross fall on a road from centre line to side. (b) The curved cross sectional profile given to the formation and to the carriageway to aid water runoff. CARRIAGEWAY That portion of the road devoted particularly to the use of vehicles, (Roadway) inclusive of shoulders and auxiliary lanes. CATCHMENT That area determined by topographical or equivalent features upon AREA any part of which rain falling will contribute to the discharge of the stream at the point under consideration. CROSS SECTION The profile of the ground more or less at right angles to a traverse or main directional line. CROSSFALL The slope at right angles to the main alignment direction. CULVERT One or more adjacent pipes or enclosed channels for conveying a watercourse or stream below formation level. DESIGN SPEED A speed fixed for the design and correlation of those geometric features of a carriageway that influence vehicle operation. DRAINAGE The provision of channels to remove excess water or to lower the water table to a level below the road and to prevent the ingress of water in the future. EARTHWORKS All operations involved in loosening, removing and depositing or compacting earth, soil, or rock: or the material when so placed. EMBANKMENT A raised mass of soil or rock used to carry a road over low areas. EXCLUSION ZONE Areas in which forest roadwork and its ancillary activities are not permitted. FORD A relatively shallow place in a stream or watercourse where the bed may be crossed by traffic. The ford can be natural gravel or concrete. FORMATION The final surface of the ground, excluding any side slopes after completion of the earthworks on which the pavement is founded. GRADIENT Expressed as the fall or rise of 1 vertical unit per number of horizontal (or GRADE) units of a pipe, road, etc. The slope can also be expressed as the number of degrees from the horizontal or as a percentage. PASSING BAY A widened length of carriageway at which vehicles can pass each other. PAVEMENT Constructed layers of a road surface which reduce / disperse loads to levels which are within the bearing capacity of the sub-grade. QUARRY An open-surface working from which stone is obtained. RAVELLING The loosening of stones or particles forming the surface course of a pavement. RIPARIAN ZONES The area directly adjacent to an aquatic zone, representing the intermediate between the aquatic and terrestrial environments. SEDIMENT Any material which settles in a liquid, hence specially the material which is carried and dropped by a river or drain, often called silt. SEDIMENT TRAP Structures used to monitor the sediment produced from an area during construction and / or reduce the quantity of sediment entering a waterway. SUBBASE The material in the pavement in unbound roads below the upper surfacing layer. SUBGRADE The parent in situ material immediately below the formation. SUPERELEVATION The transverse or inward slope of road surface on curves I corners. Environmental Assessment of the Forest Development Project. Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 17 January 28, 2004. ANNEX 11 Minutes of a Meeting on the Safeguard Policy on Involuntary Resettlement Annex II MINUTES OF A MEETING ON THE SAFEGUARD POLICY ON INVOLUNTARY RESETTLEMENT IN THE CONTEXT OF THE BULGARIA FOREST DEVELOPMENT PROJECT, HELD IN SOFIA, 3 DECEMBER 2003 Participants: Ms. Snejana Kostadinova, TL Social Assessment Ms. Miroslava Dikova, Procurement and Financial Management Officer, PPU Mr. Andrew Mitchell, TL FDP Mr. Sipi Jaakkola, TL EA/FDP (minutes) Documents distributed to participants on 2 December 2003: WB/OP4.12, incl. Annex A; Relevant case documents on Romania afforestation, Moldova soil conservation, China SFDP, Croatia Rijeka gateway and Croatia coastal cities pollution. Background: The FDP preparation had not yet arrived at final conclusion concerning the Involuntary Resettlement Safeguard Policy. The GEF project preparation team had concluded that "... the project will not result in resettlement or migrations of people". The WB pre-appraisal team had requested the EA team to make a closer analysis of the risk for involuntary resettlement. Issues: The meeting reviewed and evaluated the following issues as potential causes for resettlement: i) Restriction of access to land if, roads are constructed on private land or land traditionally used by local population; ii) Increased enforcement in Nature Parks and restriction of certain activities; iii) increased restrictions to land/assets due to extension of Parks; and iv) actions to reduce poaching and hunting of protected species, including for conflicting species such as bear, otter, wolf, etc. Roads: The meeting was reminded about the fact that no road plans were made, since by this time the FDP had only drawn up the terms of reference for Road Master Plan and the Best Practices for Road Construction. No roads were to be planned through villages, other settlements, private lands or land traditionally used by local population. During the project implementation, an EIA was envisaged for the first few road plans in order to ensure that the environmental and social safeguards were in place. Should the need arise, a clause could be added to the master plan saying that roads should not adversely influence the livelihoods of local population. Nature Parks: The restriction of activities, such as grazing, as well as the restrictions related to land-use due to the extension of Parks belong to the domain of the ongoing Social Assessment. After the first month of the SA, no resettlement issues had been identified, yet the SA will make detailed studies on economic activities by main sectors in villages. According to the SA team, the involuntary settlement could be triggered under the following preconditions: 1. Very high dependency on forest resources (for example 80 to 90 per cent of income earned from forests). 2. Complete (100 per cent) prohibition of all activities, which is not the case even in nature parks. 3. The whole forest area (100 per cent) of a private forest owner undergoing such restrictions. The SA team has made several different Social Assessments, e.g. in West Stara Planina and Rhodope mountains (UNDP-study). The team also made SAs for management plans of the Central Balkan National Park, Rila National Park and Rila Monastery Nature Park. Furthermore, the SA team has Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agrinculture and Forestry of Bulgaria, prepared by INDUFOR. January 28, 2004. Annex 11 conducted a SA for the Wetlands Project funded by the World Bank in 2001, where this topic also was one of the main issues. The SA team has never identified any significant dependency on forest resources. The highest dependency was identified in West Stara Planina, but even there it was less than 40 per cent. The meeting therefore concluded that this issue had not sufficient amplitude to trigger the involuntary resettlement safeguard. Should the ongoing SA, however, identify or foresee any involuntary resettlement in the context of FDP interventions, the SA would propose a clause in the PAD urging the GOB to prepare a resettlement plan. The meeting agreed that the current situation of the FDP is comparable to the above-mentioned Wetlands Project where a clause was put in the PAD saying that research during project preparation has not identified any reasons why the Resettlement Safeguard should be triggered, but that the Government of Bulgaria should prepare a Resettlement Plan if these conditions would arise during the project implementation. Actions to reduce poaching and hunting of protected species: According to Bulgarian legislation, the game in private forests is state property. The private forest owners are not allowed to hunt in their property, and they do not have access to such activities or uses. Concerning hunter groups, there are regulations stipulating what, when and where they can hunt each year. Illegal logging: As a consequence of new constraints on illegal logging, the livelihoods of some parts (groups) of population involved in illegal logging could shrink. At the moment, it is not clear how large those groups might be and how much they depend on those activities. The TOR of illegal logging study should include a clause saying that any such potential reduction should be subject to mitigation measures. The SA will study and analyse this problem and identify the possible needs and problems. The meeting also stressed in this context that the NFB should continue maintaining the fuel wood supply system, which it has put in place and which provides fuel wood at subsidized prices to people meeting certain criteria. Discussion on additional topics related to involuntary resettlement: Private forest lots in Nature Parks: (i) Since many of the private forest lots are too small for the purposes of any meaningful forest management (average size less than 1 ha), market ideas have been developed on the selling of private forestland to parks. These ideas have not yet materialized. (ii) If user rights are deprived or limited due to the fact that a private forest lot is in the Park and regulated by the park management plan, a compensation of deprived user rights has been discussed. This idea has not yet been materialized, either. Environmental Assessment of the Forest Development Project, Bulgaria. Ministry of Agriculture and Forestry of Bulgaria, prepared by INDUFOR. 2 January 28, 2004.