Bulgaria: Experience with Aarhus

Use of the Aarhus Convention

Foundation for Environment and Agriculture

Together with Ecoglasnost and Greenpeace the Foundation for Environment and Agriculture (FEA) filed a court case against the EIA statement on NPP Belene. FEA sent a request to the Ministry of the Environment about the license of the reactors. They asked questions to the Ministry of Energy and Trade about the incidents at units 5 and 6 of the NPP Kozloduy.
FEA is preparing a question to the MEET and the Energy Committee in the Parliament about the EIA of the Research Reactor of the Bulgarian Academy of Science – FEA will organize protests if it the EIA is concluded without a public hearing.

Za Zemiata

Za Zemiata has used the rights provided by the Aarhus Convention to file questions

  • about the health status of the people living in the uranium mining zones
  • about data measuring the radioactivity of water and soil in the uranium mining zones
    The request showed, that the Ministry of Health does not have this data because there is no funding available to conduct such investigations. So the impacts on the health of the people in the surroundings are unknown.
  • try to receive a copy of the contract between Rosatom and the Bulgarian National electric company and all the documentation provided by Rosatom on the NPP Belene
  • try to receive information about the EIA – whether the authorities consider a new EIA necessary if the parameters of the reactors planned are changed

The information provided by the Bulgarian authorities was very little. The information concerning Belene NPP is usually rejected on basis of commercial confidentiality – or claiming that the “negotiations are not completed yet”. In some cases Za Zemiata continues with filing a court appeal.

Use of Aarhus 2010/2011: Foundation for Environment and Agriculture

Foundation for Environment and Agriculture

The Foundation for Environment and Agriculture will

  • Write a request for information from the MOEW about the license of the reactors of Belene / the license is valid for 2000 MW and the design is actually for 2120 MW.
  • Use the rights provided by the Aarhus Convention to gather information about Novi Han radioactive waste disposal case about the enlargement of the site and to fight against that the Government refused to provide information according to requirement from NGOs connected with Radioactive waste assessment

Za Zemiata

Za Zemiata has filed several requests for information concerning nuclear power in November 2010. The information requested was necessary for the anti-nuclear campaign.

1) Subject: Information on the NPP contract between NEC and Atomstrojexport
Sent: 4th Nov to Ministry of Economy and Energy
Answer: 18th Nov Ministry not responsible, forwarded request to NEC
Answer: 13th Nov NEC not responsible

Background: This request tried to find out about the contract between the Bulgarian National Electric Company and Atomstrojexport, the company selected to construct the NPP Belene. According to media reports, the contract between these two companies had expired on September 30th 2010 and was prolonged for another 6 months.
The Bulgarian NGO ZaZemiata requested information about the contract which was prolonged and the new price of Belene NPP.
Za Zemiata submitted the request to the Bulgarian Ministry of Economy and Energy, who forwarded it 2 weeks later to the National Electric Company (NEC). One month later Za Zemiata was informed by NEC, that National Electric Company is a commercial company and does not need to conform with the Aarhus Convention on Access to Information. However, NEC is 100% state-owned.

ZaZemiata consulted the case with the Access to Information Programme (http://www.aip-bg.org/index_eng.htm) and was advised to file a new request to the Ministry of economy and energy

2) Subject: Permits issued for NPP Belene
Sent: 2nd Dec 2010 ZZ sent the request to the Nuclear Regulator Agency (NRA)
Answer: 11th Dec 2010
The NRA made the access to information possible and ZZ received copies of all documentation requested.

Until 2010 NRA has issued 3 permissions in connection with Belene NPP. The permissions are issued to NEC
- permission for the choice of site for the NPP
- permission for the design of unit 1 of Belene NPP
- permission for the design of unit 2 of Belene NPP
So far (spring 2011) the permission for constructing and operation of Belene NPP is still not issued and it is in the stage of investigating the technical project.

3) Subject: EIA decision NPP Belene
Sent: 17.11.2010 To Ministry of the Environment
Answer: 1.12.2010 The Ministry provided a copy of the requested document on time.

4) Subject: Information on the capacity of NPP Belene
Sent: 17-11-2010 to Ministry of Economy and Energy
Answer: 2.12.2010 (the answer was somehow stuck in the post office)
The answer of the Ministry was that the requested information was available on the web-site of NEC and Belene NPP – www.nek.bg; www.belene-npp.com

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