Construction of the Kaliakra wind farm parks (Bulgaria) Eagle (Aquila clanga), Imperial Eagle...

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T-PVS/Files (2004) xx CONVENTION ON THE CONSERVATION OF EUROPEAN WILDLIFE AND NATURAL HABITATS Standing Committee 25 th Meeting Strasbourg, 28 November - 2 December 2004 Possible new file Construction of the Kaliakra wind farm parks (Bulgaria) Report by the NGOs Document prepared by BirdLife International: Bulgarian Society for the Protection of Birds (BSPB, BirdLife in Bulgaria) and the Royal Society for the Protection of Birds (RSPB, BirdLife in the UK) And supported by: Bulgarian Academy of Sciences - National Natural History Museum The Bulgarian NGOs: Balkani Wildlife Society Bulgarian Herpetological Society Nature Protection Society - Varna

Transcript of Construction of the Kaliakra wind farm parks (Bulgaria) Eagle (Aquila clanga), Imperial Eagle...

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CONVENTION ON THE CONSERVATION OF EUROPEAN WILDLIFE AND NATURAL HABITATS

Standing Committee

25th Meeting

Strasbourg, 28 November - 2 December 2004

Possible new file

Construction of the Kaliakra wind farm parks (Bulgaria)

Report by the NGOs

Document prepared by BirdLife International: Bulgarian Society for the Protection of Birds (BSPB, BirdLife in Bulgaria)

and the Royal Society for the Protection of Birds (RSPB, BirdLife in the UK) And supported by:

Bulgarian Academy of Sciences - National Natural History Museum The Bulgarian NGOs:

Balkani Wildlife Society Bulgarian Herpetological Society Nature Protection Society - Varna

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I SUMMARY The Kaliakra wind farm projects in Bulgaria, if implemented, will:

1. pose a threat to the many tens of thousands of soaring and other birds using the Via Pontica bird migration route, which has a bottleneck through Cape Kaliakra. These include many species of unfavourable conservation status in Europe and listed in Annex II of the Convention, such as the globally threatened Dalmatian Pelican (Pelecanus crispus), Greater Spotted Eagle (Aquila clanga), Imperial Eagle (Aquila heliaca) and Lesser Kestrel (Falco naumanni), near-threatened Pygmy Cormorant (Phalacrocorax pygmeus), White-tailed Eagle (Haliaaetus albicilla), Pallid Harrier (Circus macrourus) and in addition White Stork (Ciconia ciconia), Black Stork (Ciconia nigra), White Pelican (Pelecanus onocrotalus) and other soaring birds.

2. cause mortality to the globally threatened Red-breasted Goose (Branta ruficollis), more than 70% of the world population of which winters locally.

3. Cause mortality of the near threatened Corncrake (Crex crex) that concentrates on autumn migration in the region of Kaliakra.

This would be in contravention of Articles 2, 3, 4, 6 (a & c), 7 and 10 of the Convention. The Bulgarian Government through the Regional Inspectorate of Environment Varna has aproved an Environmental Impact Assessment (EIA) report with a completely inadequate assessment of risks to biodiversity of the Kaliakra wind farms. From elsewhere there is robust evidence of the inappropriately chosen location for the wind farm. All information and up-to-date results of field surveys provided by BSPB and other NGOs and scientific isnstitutions of the Bulgarian Academy of Sciences have been ignored by the state authorities. Since the EIA has already been endorsed, if no strong international pressure is exerted on the Bulgarian Government to reconsider and revoke its decision, the project will be implemented with the full power of the foreseen consequences. The case should be paid special attention, as it becomes practice of the Regional Inspectorate of Environment Varna and the Ministry of Environment and Water (MoEW) to allow dangerous and detrimental windfarm projects along the migration route Via Pontica. Currently the Regional Inspectorate of Environment and Water – Varna has issued permissions for over 120 wind turbines located at bottleneck sites. Most of these were allowed without prior EIA1 and thus ignoring the cumulative effects of such projects. The Bern Convention has already been alerted about a similar case in our complaint T-PVS / Files (2004) 6. The Balchik windfarm is situated to the west of cape Kaliakra indicated on Figure 3 in the document. In a very similar manner the Regional Inspectorate of Environment and Water (RIEW) - Varna has ignored data collected in filed study of the autumn migration by BSPB/BirdLife Bulgaria and has approved windfarm projects for 70 turbines of 2MW each on a bottleneck site and proposed NATURA200/Emerald site “Kaliakra”. No prior investigation on autumn migration or breeding birds on the windfarm plots has been carried out before the EIA report has been implemented. Along with the Balchik windfarm project and these ones the RIEW-Varna with the approval of the MoEW creat a systematic procedure of ignoring conservation considerations and international obligations of conservation of migratory species and in the specific case ignoring the scientific opinion of thre institutes of the Academy of Sciences and two Departments of the Faculty of Biology of the Sofia University. If allowed these projects they will undermine the whole migrating birds conservation along the Bulgarian section of the Via Pontica and will create an unprecedented case of ignoring the 1 According to Bulgaria’s Environmental Protection Act, wind farms of capacity not exceeding 5MW are not a subject of obligatory EIA. Such project can be approved directly by the Director of the respective Regional Environmental Inspectorate.

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precautionary approach and the need of preliminary stud of the bird migration in sites where proposed windfarm development might have a significant negative impact on species and population level. Along the Bulgarian Black Sea coast passes the ancient bird migration fly way Via Pontica. Birds breeding and inhabiting the European continent from Germany to wets to Western Russia use this migration route. The studies on the migration of the soaring birds alone (Storks, Raptors, Pelicans etc.) proved that from August to September along the Bulgarian Black Sea coast fly over up to 300 000 White Storks (Ciconia ciconia) or over 50% of the European breeding population, up to 37 228 White Pelicans (Pelecanus onocrotalus) or almost the whole European population of the species, up to 4 570 Black Storks (C. nirga), some 30 660 Common Buzzards (Buteo buteo), over 23 000 Heoney Buzzards (Pernis apivorous) and up to 25 769 Lesser Spotted Eagles (Aquila pomarina). Beside the considerable numbers of theabove mentioned species along this migration route pass on annual base numerous globally threatened species and other SPEC categories - Dalmatian Pelican, Spotted Eagle, Imperial Eagle, Pallid Harrier, Red-footed Falcon, Lesser Kestrel, considerable portion of the Corncrake population etc. In addition to the soaring migrants there are hundreds of thousands of other actively flying migrating birds from all systematic groups. It is evaluated that at least 5 000 000 migrating birds pass along the Bulgarian Black Sea coast every autumn of them some 500 000 birds are the soaring migrants. The Standing Committee is invited: (i) to open a file on this case and (ii) to adopt the recommendation annexed to this report specifying steps which the Government of the Republic of Bulgaria should take to comply with its obligations under the Bern Convention. II The site of the planned wind farm: Important Bird Area (IBA) and Emerald Network/Natura 2000 site The site is located on the edge of the Dobrudja Plateau overhanging the vertical cliffs to the Black Sea, where the orientation of the coastline changes from east-west to north-south. The vegetation cover comprises mainly dry grassland, which is the last uncultivated habitat of remnat steppes. The plot of the wind turbines projects are istuated in the immediate vicinity of the Cape Kaliakra strict nature reserve. The wind farm and its supportive infrastructure will be built on some of the best preserved examples of Pontic steppe habitats. The Cape has been identified as Important Bird Area with total of 12 888 ha. The windfarm projects are planned in remnants of the Pontic steppe habitats along the coastline between the town of Kavarna and the village of Balgarevo and between Balgarevo village to buffer zone of Kaliakra reserve.

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Figure 1: General location of Cape Kaliakra Figure 2: Location of Cape Kaliakra reserve (red) and

proposed sites of wind farms (yellow)

The Via Pontica bird migration route lies along the Black Sea coast and the site in question is situated on this busy flyway. An intensive survey of the autumn migration carried out by BSPB/BirdLife Bulgaria in 2004 through a project directed for identifying migration bottleneck sites along the Black Sea coast for the needs of EMERALD/NATURA 2000, funded by BirdLife International, Dutch Ministry of Agriculture, Nature and Food Quality, European Commission and the Royal Society for the Protection of Birds. Daily counts of migrating soaring birds were carried out from 4 observation points near the villages of Balgarevo, Rogatchevo, Goritchane and Balchik from 10th August to 21st October 2004. At Balgarevo (the closest observation ponit to the proposed wind farms) more than 31 400 storks and raptors were recorded. This number of migrating birds covers the BirdLife IBA criterion (Heath & Evans 2000), thus qualifying as an IBA of Global Importance as a “bottle-neck” site. The site with an area of 12 888 ha is proposed for inclusion in the list of European IBAs and Special Protected Areas under the EU Birds Directive.

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Figure 3: Map of the migration flyway and location of Balgarevo, Goritchane, Rogatchevo and Balchik observation points.

Goritchane

Rogachevo

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The site meets the criteria for an Emerald Network site and for designation as a Special Protected Area (SPA) under the EU Birds Directive when Bulgaria accedes to the EU (foreseen year 2007). Currently the Natura 2000 Network in Bulgaria is under construction and the Bulgarian Ministry of Environment and Water has delegated identification of candidate SPAs to BSPB through a Memorandum of Understanding signed in June 2004. In terms of species concerned the 2004 study carried out by BSPB showed that altogether 8 globally threatened or near-threatened species (BirdLife International 2004) use the site or pass over it: the globally threatened Dalmatian Pelican (Pelecanus crispus), Red-breasted Goose (Branta ruficollis), Greater Spotted Eagle (Aquila clanga), Imperial Eagle (Aquila heliaca) and Lesser Kestrel (Falco naumanni); and the near-threatened Pygmy Cormorant (Phalacrocorax pygmeus), White-tailed Eagle (Haliaaetus albicilla) and Pallid Harrier (Circus macrourus). Of the 131 species recorded at Klaiakra, 97 are listed on Annex II of the Convention and 45 are priority species for conservation in Europe (SPEC1-3). Among the most numerous of these breeding at the site are Calandra Lark (Melanocorypha calandra), Tawny Pipit (Anthus campestris), Whinchat (Saxicola rubetra), Common Wheatear (Oenanthe oenanthe), Pied Wheatear (Oenanthe pleschanka), Red-backed Shrike (Lanius collurio), Stone Curlew (Burhinus oedicnemus) and Linnet (Carduelis cannabina). Eagle Owl (Bubo bubo), Greater Short-toed Lark (Calandrella brachydactyla) and Leser Short-toed Lark (Callandrella rufescens) also breed in the area. III The Kaliakra wind farm projects Up to now three projects of different Bulgarian private companies have been approved: Universum Energy Ltd. – 32 turbines between town of Kavarna and Balgarevo village, 35 turbines by INOS-1 Ltd. between the village Balgarevo and the buffer zone of Cape Kaliakra nature reserve and “Vertical-Petkov” 5 turbines to the north west of INOS-1 wind turbine park. EIA reports were elaborated and endorsed by the Regional Inspectorates of Environment and Waters in Varna for the three projects. None of the investors has made adequate effort for preliminary study on the migrating and breeding birds. The INOS-1 had funded a partial study of the spring migration and breeding birds that was finalized after the report on the EIA. None of the investors took into account the data on migrating birds presented by BSPB/BirdLife Bulgaria during the public hearing of the proposed projects carried out as part of the EIA consultation process. Beside the 72 turbines described above additional at least 20 more are planned for to north west of Cape Kaliakra reserve but still within the boundaries of the Kaliakra IBA. Additional environmental permissions to 20 to 30 individual turbines within the area of the NATURA 2000 site have been granted by the Regional Inspectorate of Environment and Water – Varna. Thus the total cumulative number of wind turbines up to now is minimum of 112. According to the information presented by the investors at the public hearing the INOS-1 Ltd project is funded by Mitsubishi Heavy Industries Ltd. At a public event prior to the public consultations representatives of Mitsubishi Heavy Industries has made an announcement that the company will provide 25 000 Euro “donation” in the form of free electricity to Balgarevo village. The Universum Energy Ltd project (although this information is not confirmed) is funded by a music broker company that regularly organizes concerts in the nearby town of Kavarna.

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Figure 4: Soaring White Pelicans (Pelecanus onocrotalus) over IBA Kaliakra. Almost 100% of the European population of the species migrates over Via Pontica flyway.

IV Potential impacts on wildlife

Figure 5: Steppe areas with powerlines blocking the route of night migratnts and causing hundreds of deadly collisions of migrating birds like Quail and Corncrake. In the vicinity is planned the wind turbine park of INOS-1 Ltd. Photo: P.Iankov/BSPB .

Impacts that can be expected following the construction of the Kaliakra wind farm parks, inter alia, include: • creation of a major barrier to migration of soaring birds, posing a very high risk of

collision and mortality, thus having transboundary effects on population level. The site has a crucial location on the Via Pontica bird migration route and large flocks of migratory birds depend on the air movements in the area. Hot air rising from the ground (thermals) is additionally pushed by the sea brееze. This specific feature is used by the

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soaring birds for their energy-saving flight during the long migration to and from Africa and their European breeding grounds. A BSPB survey during autumn migration found that more than 30% of the almost 32 000 storks, pelicans and birds of prey fly through the site allocated for the wind farm at altitude from 0-250 m, i.e. at the height of the proposed wind turbine blades or within the area of the turbine effect.

• possible risk to night migrants passing through the area. The site is located in an area of

high density of nocturnal bird migration. In a study of adjacent area at Balchik a heavy night migration with 900 birds/hour/linear kilometer was registered in 2003. Between 30% and 55% of nocturnal migrants were recorded to fly at altitudes below 200 m. (Zehtindjiev in press). The area is known for its international concentrations of Corncrake (Crex crex) also known for being poor fliers and night migrants. Annually in the area thousands of Quails (Coturnix coturnix) and Corncrakes die due to collisions with powerlines that are completely invisible during the night. The wind turbines will put even haeavier burden to the already existing obstacles for birds in the area.

. Figure 6: A dead Black Bird (Turdus merula) that have collided with a wind-speed measuring antenna of one of the investors in the area of KaliakraIBA – Photo: P.Iankov/BSPB

. Figure 7: A dead Quail (Coturnix coturnix) collided with a wind-speed measuring antenna of one of the investors in the area of KaliakraIBA – Photo: P.Iankov/BSPB

• possible risk to the wintering globally threatened Red-breasted Geese. This potential

impact is of particular concern. The region of south-east Dobrudja is known for harbouring more than 70% of the world population of this species. Often, in hard winters, large mixed flocks of White-fronted Geese (Anser albifrons) and Red-breasted Geese roost in the sea close to the area and during morning take-off, pass at low altitude over the site (Kostadinova & Dereliev 2001).

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• Destruction of priority habitat for conservation – the steppe habitat of wetstern Pontic type

with Peonia tenuifolia. The last remnants of this habitat type is found in the area and this its preservation is one of the conservation objectives of the Cape Kaliakra reserve. Hwever the reserve only protects small part of the habitat while some of the best examples are better represented outside the reserve and its destruction will affect the populations and communities status. For example the endemic for Bulgaria plant association Paeonio tenuifoliae-Koelerietum brevis, the most representative part of it is found between Balgarevo and Kamen bryag villages. Some of the species found here are the Balkan and Bulgarian endemics Avena erintha, Chamaecytisus jankae, Scandix australis, Bellevalia sarmatica, Ruta graveolens, Artemisia pedemontana etc.

Figure 8: The last remnants of the steppe habitats of western Pontic type within the Kaliakra IBA –Photo: P.Iankov/BSPB .

Figure 9: Typical plant communities in the steppe habitats that will be destroyed by the wind turbine park development – Photo: S. Spasov/BSPB .

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V Background of the case In 2003 BSPB started an ongoing programme of indentification of sites with narrow front of migration of soaring birds along the whole Black Sea coast, known as bottleneck sites. In relation to a proposed windfarm near Balchik (Report to Bern Convention … in 2003) in 2004 BSPB carried out intensive monitoring of autumn migration in the area of Cape Kaliakra at four observation points – Bulgarevo, Gorichane, Rogachevo and Balchik In early 2005 INOS-1 Ltd and Universum Energy Ltd asked BSPB/BirdLife Bulgaria for recommendations for the coverage and direction for the EIA for their investment projects. BSPB based on unprocessed data from the autumn migration recommended at least one to two field seasons of research on the migration of birds and breeding birds but indicated that our preliminary data suggest that the area is a bottleneck site and dangerous for windfarm development. BSPB also notified that the area has been identified as covering criteria for IBA and NATURA 2000 site and that accoring to Article 6 of the Habitat Directive should be followed and the Bern (T-PVS/Inf(2002)30 report) and Bonn Conventions recommendations regarding windfarm projects must be taken into account. In May 2005 we learned that public hearings of the EIA reports on the INOS-1 Ltd and Universum Energy projects will be held in the town of Kavarna. The public hearing of the report on the EIA for Universum Energy Ltd was summoned almost secretly, without the legally required wide announcement. Just two days before the public hearing a representative of the Regional Inspectorate of Environment and Water – Varna denied in front of a BSPB representative that there was a date assigned for the public hearing. On the public hearing of the EIA report on Universum Energy Ltd held in Kavarna municipality building on 30th May 2005 it became obvious that there has been no preliminary study of the migration of birds and breeding bird survey on the plot of the investment project situated between Kavarna town and Balgarevo village. BSPB submitted official statement against the project based on the poor quality of the EIA. In addition BSPB submitted official written negative statements on the EIA and the project made by Balkani Wildlife Society, Bulgarian Herpetological Society and the National Natural History Museum. On the next day (31.05.2005) was the public hearing of the INOS-1 Ltd project. In the EIA there has been no preliminary research on the autumn migration, which in both cases is the major concern expressed by us. The investors of INOS-1 Ltd have commissioned a research on the breeding birds and spring migration, which was not completed prior to the EIA so the EIA has not considered this study which highlights the formality of it. The investor INOS-1 Ltd has regarded a general information provided by a researcher from the Institute of Zoology as an official statement on the migration. The information provided by the research technician Nikolai Karaivanov (MSc) was not officially approved by the research management of the Institute and was based on general information about birds in the Kavarna municipality. It concerns a much larger area and was not based on specific study on the plot of the windfarm investors. A BSPB representative presented a specific study on the plot of the investors containing species list, numbers, altitude and direction of flights. However, it was denounced by the EIA experts team as “claims”. Moreover, BSPB objected that there was no professional ornithologist included in the EIA team and therefore the EIA does not provide adequate assessment of the the potential threat for collisions of migratory birds with the wind tourbines,

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due to lack of adequate baseline data of migratory birds. In fact, the fauna expert of the EIA team was a botanist in training. During the whole EIA procedure experts from the investor’s side were systematically manipulating public and officials’ opinion claiming that no significant mortality caused by wind farms to birds has been detected anywhere in the world. All known international reports were quoted partially deliberately avoiding any proofs of significant bird mortality and thus distorting the genuine existing problem. They claimed that there is contradictions and not a unified opinion on the effect of windfarms on birds and stated that different experts state different positions. In addition the investors proposed that they would purchase when the windfarm starts operation a Doppler’s radar to locate flocks of birds that can potentially collide with the windfarm park and there will be operator to stop the wind turbines when collision risk is inevitable. This could not be performed into reality as the 35 turbines of 2 MW each are too big part of the electric system and the National Electricity Company will never connect the wind turbine knowing they will be switched off regularly. As the data of BSPB suggests the windfarm should be closed permanently from August till end of October as flocks of migrating birds throughout the period flying at a height and direction that will cause inevitable collision. If they are not shut down permanently it will be up to a person to decide which birds can collide or which should not. The term used to define the actions was “the turbines will be shut down when there is threat to bigger flocks” while even the killing of a single or two Imperial Eagles could have significant population impact as they have slower process of recovery but they do not fly in “big” flock so they would not obviously be treated similarly because they are “small insignificant flock”. However even the proposal of having such radar which is a kind of mitigation measure is a token of the recognition of the potential great threat of this windfarm. It is even more striking that the state officials ignored all results provided by BSPB supporting the warnings about high risk for collision and mortality of birds. Instead, they cited superficial research technician statement that they adopted as official statement of the Institute of Zoology, though the management authorities of the Institute did not endorse it. Even this information on the migration on the territory of the municipality was inconclusive. In its initial recommendation for the EIA report by the BSPB as a possible measure to mitigate the effect on birds to relocate the wind farm inland (without specifying how much and where exactly). However, no discussion on any alternative locations was accepted. The EIA also treats the question of possible alternatives, but with regard to the siting of the wind farm they reject any other alternative, because the investor owns the land plot. After the public hearing on the EIAs of the two major windfarm park projects within the IBA Kaliakra, BSPB has asked the Institutes of the Academy of Sciences and the Departments of the Faculty of Biology of Sofia University for official statements on the importance of the migration route Via Pontica and the bottleneck sites and the suitability of the Kaliakra area for windfarm construction. None of the scientific institutes approved the idea of having wind turbines on the Cape Kaliakra and stipulated the need of preliminary studies. Statements were sent by Institute of Botany, Central Laboratory of General Ecology, National Natural History Museum, Department of Zoology and Department of Ecology and Nature Protection of Sofia University. The expert council of the Regional Inspectorate of Environment-Varna (RIEW) did approve the EIAs on all investment proposals and overruled the objections of the NGOs and the National Natural History Museum.

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The BSPB/BirdLife Bulgaria along with Balkani Wildlife Society and Society for the Protection of Nature -Varna ledged and appeal to the Minister of Environment and Water (at this time in resignation after the June parliamentary elections) Mrs. Dolores Arsenova. We did submit the new statements from the scientific and university institutions but all these were ignored by the Minister and the decision of the RIEW. This is a repetition case alike the Balchik case about which the Bern Convention was notified previously in our complaint T-PVS / Files (2004) 6 and a strong example of how all further wind farms in Bulgaria are being approved, unless international intervention is exerted: first investors negotiate with municipalities to choose a location and then provide “evidences” that this is a non-conflict area without any serious threats to birds and wildlife, while avoiding, by any means, involvement of NGOs or other independent experts in the process. In the recent development of the process it is evident that the rude ignoring of the conservation objectives and the need of preliminary study are becoming even more alarmingly a custom in the work of the RIEW-Varna and being approved by the MoEW. Another aspect of our concerns is that investors might use more intensively in future the “single turbine” approach to establish wind farms without EIA as the practice indicates that environmental licenses are granted to such projects easily, overruling their cumulative effects. We consider that there is systematic violation of the general principles of precautionary protection of migrating species and file should be opened against Bulgarian government for failing to provide adequate protection of migrating birds and ignoring conservation precautionary principle regarding the migration flyway Via Pontica. VI Action recommended

1. The Bulgarian Government and the Minister of Environment and Water must take full account of the results from the BSPB 2004 autumn migration survey in North East Bulgaria and accordingly revoke the decision on endorsement of the EIAs.

2. The Bulgarian Government should invite the investors to consider alternative locations

for the wind farm, while first thoroughly exploring possible conflicts with requirements of biodiversity law, nationally, at European level and globally.

3. The Ministry of Environment and Waters should request a thorough EIA procedure for

any further wind turbine construction proposal in Bulgaria.

4. The Bulgarian Government, must carry out as soon as possible a detailed and profound Strategic Environmental Assessment of all suitable locations in the country for wind farm construction, and expert NGOs must have a substantial role in this process and consultation should be considered with flyway countries whose breeding populations of migrating birds are likely to be affected by windturbines along Via Pontica – Romania, Russia, Hungary, Baltic states, Germany Slovakia and Czech Republic. This assessment should endeavour to foresee objectively, inter alia, any possible conflicts and threats to wildlife.

5. No EIA should be endorsed if based on a wildlife survey of less than 12 months

intensive fieldwork, with adequate methodology, detailed analyzes and well-justified prognoses and conclusions.

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6. Wherever wind farm developments take place in potentially sensitive areas, proper

independent monitoring schemes on the environmental impact should be undertaken, and expert NGOs should have prominent role in this activity.

7. All areas that qualify as sites in the Emerald/Natura 2000 network should be

adequately protected within the pre-accession period, as well as afterwards, according to the requirements of the Birds and Habitat Directives to avoid any deterioration and to protect their natural values.

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APPENDIX I

TECHNICAL REPORT OF THE BULGARIAN SOCIETY FOR THE PROTECTION OF BIRDS

Observation of autumn migration of soaring birds in Bulgaria in 2004 in terms of identification of bottleneck IBAs to be

included in the European Ecological Network NATURA 2000

Financied by

BirdLife International

Ministry of Agriculture, Nature and Food Quality, the Netherlands

European Commission

Royal Society for the Protection of Birds, BirdLife United Kingdom

Environmental Partnership Foundation, Bulgaria

January 2005

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Purpose of the study Bulgaria is expected to join to the European Union in 2007. By the date of accession the country has to identify Special Protection Areas. The latest IBA inventory (Kostadinova, 2000) list 50 IBAs for Bulgaria, however, they were selected only by using criteria A and B. This leaves a number of Annex I species without IBA coverage. In addition the existing IBAs in Bulgaria has no clear boundaries shown on a map and the new proposed IBAs will face the same problem, because of the proper map background is not available. During the first and the second phase of the project “Application of C criteria for identification of Important Bird Areas in Bulgaria” significant results where achieved – basic maps for defining of IBA boundaries were ensured, national populations of breeding birds were estimated and preliminary application of C criteria and gap analysis were elaborated in order to plan the further steps for application of C criteria. These analysis showed that boundaries of the proposed IBAs have to be digitised and additional information have to be collected for specific bird species in number of sites and regions. Because of scattered and poor data on migratory populations, the network includes only the sites along the Black Sea Coast, which according to the available data show clear potential to be migratory bottleneck sites. Other sites, included in the network because of other criteria have also potential to be migratory bottlenecks, but it had to be additionally studied. In other hand the big interest to develop wind power generators parks along the Black Sea Coast become the biggest threat for migratory birds, which use the second big migratory route in Europe – Via Pontica The purpose of the study was the identification of bottleneck sites for migratory birds along the Black Sea Coast, where preliminary data show that the potential importance exist, but it have to be supported be good quality data. Materials and methods The study of soaring migratory birds was carried out through direct observation during the whole light part of the day for the period 9 August - 21 October 2004. The observation was carried out using optics – telescopes and binoculars. For each species data were collected on the number, hour of observation, high of the flight, direction of the flight and the type of the flight. Every day the weather condition, including temperature, wind etc. were recorded. For the purpose of the study 9 observation points were selected in Eastern Bulgaria: Gorichane, Bulgarevo, Balchik, Rogachevo, Madara, Panitzovo, Banya, Ravadinovo and Malko Turnovo. Gorichane The observation point is situated west of the village Gorichane, 8 km west of the town of Shabla, and about 14 km west of the coastline. There were 50 observation days at this point for the period 15 September – 31 October. Bulgarevo The observation point is situated at Northern Black Sea Coast, south of the village Bulgarevo, 0.6 km north of the coastline, about 5 km northwest of the cape Kaliakra and about 6 km southeast of the town of Kavarna. There were 73 observation days at this point for the period 10 August – 21 October. Balchik, The observation point is situated at Northern Black Sea Coast, about 5 km southwest of the town of Balchik and 1.3 km NW of the coastline. There were 74 observation days at this point for the period 10 August – 21 October.

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Rogachevo The observation point is situated at Northern Black Sea Coast, in Rogachevo village, about 5,2 km west of the Albena Resort and the coastline, and about 6 km west-southwest of the Balchik observation point. There were 74 observation days at this point for the period 10 August – 21 October. Madara This is the most west observation point, used during the study. It is situated about 80 km west of the coastline and the town of Varna, at the western border of the Provadijsko-Roaksko Plato IBA. There were 26 observation days at this point for the period 10 August – 21 October. Panitzovo The observation point is situated at the northern part of Dyulino Pass of the Eastern Stara Planina Mountain, north of Panitzovo village, about 17,5 km west of the coastline. There were 75 observation days at this point for the period 9 August – 21 October. Banya The observation point is situated at the northern part of Obzor Pass of the Eastern Stara Planina Mountain, south of Banya village, about 7 km west of the coastline, and about 14,5 km southeast of the Panitzovo observation point. There were 58 observation days at this point for the period 26 August – 21 October. Ravadinovo The observation pint is situated at South Black Sea coast, north of the Ravadinovo Village, about 3 km southwest of the town of Sozopol. The coastline goes 2,6 km north of the observation point, and also 3,6 km east of it. There were 62 observation days at this point for the period 26 August – 21 October. Malko Turnovo The observation point is situated in Strandja Mountain (Strandja IBA), northeast of the town of Malko Turnovo and about 40 km west of the coastline. There were 40 observation days at this point for the period 8 September – 21 October. In total 60 experts and volunteers of BSPB took part in the observation of migration. At Gorichane and Malko Turnovo no white stork migration was followed, because of the late start of the observation at these two points. Results Gorichane In total in the area 1884 raptors, 1212 storks, 730 pelicans and 4 cranes were recorded (table 1). As the observation point was open on 15 September no representative data on White Stork migration and Honey Buzzard were collected. Following the directions of flight of migratory birds in the nearest observation point (Bulgarevo) it could be expected that more than 5800 white storks have passed in the area of Gorichane during the autumn migration 2004. Bulgarevo In the area of Bulgarevo point (between the town of Kavarna and Kaliakra cape) in total 31498 soaring birds were recorded during the autumn migration, mainly storks and pelicans (table 1).

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At this point was recorded also the biggest number of migratory Black Kites – 151. The globally threatened species recorded here were Imperial eagle and Pallid Harrier. Due to the specific geography of the coastline (direction east – west) and the predominant NW wind migratory birds stay in the area longer than usual migrants, trying to avoid sea and to go back again above the mainland. About 46% of birds fly to Southwest, but also significant number of them fly to the West (25%), even to Northwest (2%), following the coastline. More than 5% of the recorded white storks overnight North and Northwest of the village Bulgarevo and used the thermals in the area to soar. 40% of the migratory birds fly through the area up to 150 m high. When the wind is very strong storks and raptors (mainly harriers) land on the fields between Kavarna and Cape Kaliakra. 51% of the birds fly between 160 and 500 m high. Only 9% of the birds pass the area flying higher than 500 m. Balchik In the area of Balchik point in total 100 027 soaring birds were recorded during the autumn migration, mainly storks and raptors (table 1). At this point was recorded also the biggest number of the following migratory birds – Red Kite, Griffon Vulture, Marsh Harrier, Montagu`s Harrier, Pallid Harrier, Goshawk, Sparrowhawk, Levant Sparrowhawk, Common Buzzard, Osprey, Kestrel, Red-footed Falcon, Sacker and Peregrine Falcon. 23% of the migratory birds fly not higher than 150 m above land, and 39% of the migratory birds fly between 160 and 500 m. 5292 pelicans and 13716 storks passed the Balchik point were also recorded at Rogachevo point. Rogachevo In the area of Rogachevo point in total 149 083 soaring birds were recorded during the autumn migration, mainly storks and pelicans (table 1). This is the biggest number of soaring migratory birds observed at one point along the Black Sea Coast during the autumn migration 2004 counts covered by the project. At this point was recorded also the biggest number of migratory white pelicans and cranes. 11% of the migratory birds fly not higher than 150 m above land, and 35% of the migratory birds fly between 160 and 500 m. 5292 pelicans and 13716 storks passed the Rogachevo point were also recorded at Balchik point. Madara In the area of Madara point in total 4 119 soaring birds were recorded during the autumn migration, mainly raptors (table 1). Due to the fact that the migration was not followed every day during migration period the figures of the raptors are not representative and it is expected that they be underestimated. Migration of white stork in the western part of Provadijsko Royaksko Plateau IBA (at Madara observation point) is not so intensive, as in the Eastern part of the plateau. The area of Madara observation point seems to be the most western part of the main (most intensive and concentrated) Via Pontica migration route. Panitzovo In the area of Panitzovo point in total 131 088 soaring birds were recorded during the autumn migration (table 1). At this point was recorded also the biggest number of migratory Honey Buzzards and significant number of pelicans and lesser-spotted eagles. About 10% of migratory birds fly up to 150 above the observation point, including some birds, which fly lower than the observation point as they use the valley of Dvoinitza River. 82% of the migratory birds, which pass the mountain through the Dyulino Pass flying between 160 and 500 m above the observation point altitude. Raptors overnight in the forests of Kamchijska Planina IBA, which is situated north of the observation point. Pelicans were observed to overnight in the valley of Dvoinitza river.

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Banya In the area of Banya point in total 106 707 soaring birds were recorded during the autumn migration (table 1). At this point was recorded also the biggest number of migratory Spotted Eagles, Dalmatian Pelicans and Black Storks. About 42% of migratory birds fly up to 150 above the observation point, and 55% of the migratory birds, which pass the mountain through the Obzor Pass flying between 160 and 500 m above the observation point altitude. Raptors overnight in the forests of Kamchijska Planina IBA, which is situated north of the observation point. As the observation point was open after the pick numbers of white storks (figure 2), it is expected that the flyway population over the area is much bigger than recorded. Ravadinovo In the area of Ravadinovo point in total 127 781 soaring birds were recorded during the autumn migration, mainly storks (table 1). The area is situated south of the Burgas Bay and it has key role for the white storks, which pass the bay. At this observation point was recorded both the biggest number of migratory white storks for the period of migration (123 125) and the biggest number of white storks passed the area in one day (about 73 000). The biggest number of imperial eagle was recorded also at this point. 4% of the migratory birds fly not higher than 150 m above land, and 61% of the migratory birds fly between 160 and 500 m. Malko Turnovo In the area of Malko Turnovo point in total 13 686 soaring birds were recorded during the autumn migration, mainly raptors (table 1). As the observation point was open on 8 September no representative data on White Stork migration and Honey Buzzard were collected. At this point was recorded the biggest number of migratory Lesser spotted Eagles, Booted Eagles and Short-toed Eagles. 43% of the migratory birds fly not higher than 150 m above land, and 29% of the migratory birds fly between 160 and 500 m.

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Table 1 Migratory bird counts at 9 observation points along the Black Sea coast in 2004.

species GorichaneBalgarevo Balchik RogachevoMadaraPanitzovo Banya Ravadinovo Malko Turnovo

P. apivorus 25 643 1201 1415 1263 3121 1596 1353 685Milvus migrans 8 151 110 38 2 30 7 5 2Milvus milvus 4 14 3 2 3 1 1Haliaeetus albicilla 1 N. percnopterus 1 1Gyps fulvus 4 6 2 2 2Circaetus gallicus 2 15 75 55 13 84 56 39 175Circus aeruginosus 62 196 1189 506 33 289 267 94 47Circus cyaneus 37 15 34 14 14 19 71 6 9Circus macrourus 3 26 36 10 1 14 9 2Circus pygargus 5 68 241 173 16 50 49 184 2Circus pyg. /macr. 5 34 4 9 3 17 1 2Circus spp. 11 52 48 100 33 155 29 22 16Accipites gentilis 32 7 314 70 8 12 18 151 11Accipiter nisus 171 59 480 242 64 81 478 121 205Accipiter brevipes 1 65 105 60 1 23 11 18 13Accipiter nis./brev. 1 5 7 33 3 27 57 5 39Buteo buteo 1020 632 13053 6659 248 6339 9222 1224 2278Buteo rufinus 13 24 94 21 33 10 30 16 2Buteo lagopus 2 2 1 1 3Aquila pomarina 29 21 1359 2357 296 5412 2740 141 6472Aquila clanga 1 1 3 2Aquila clan. /pom. 1 1 3Aquila heliaca 3 2 1 1 3 4 2Aquila hel. /rap. 12 1Aquila chrysaetos 1 1 3 2 3 4 7 4Hieraaetus pennatus 1 17 30 34 9 30 8 4 44Pandion haliaetus 2 2 28 15 4 6 5 6 3Falco naumanni 1 1 Falco tinnunculus 61 89 151 41 18 26 22 14 12Falco tinn. /naum. 2 1 Falco vespertinus 107 141 235 65 3 3 15 22 1Falco columbarius 6 1 1 2 5 1 2Falco subbuteo 90 43 215 78 15 26 115 51 62Falco vesp. /subb. 7 2 3 4 1 2Falco eleonorae 2 3 3 Falco cherrug 1 7 2 2 Falco peregrinus 5 3 10 8 4 5 2 7Falco spp. 44 47 139 136 9 52 47 141 29Non identifyed raptors 121 174 368 1949 100 850 206 205 639Total raptors 1884 2549 19556 14114 2202 16708 16638 3878 11335Ciconia ciconia 1125 26309 67229 117619 1836 101601 86641 123125 333Ciconia nigra 87 146 1526 966 66 1029 2492 483 1286Ciconia spp. 1 77 Grus grus 4 57 41 67 15 27 14 19 5P. onocrotalus 708 2338 11415 16305 11599 895 276 76Pelecanus crispus 22 7 17 1 1 27 P. onocr./crisp 109 1 28 651Total storks pelicans and cranes 1946 28949 80471 134969 1917 114380 90069 123903 2351

Total soaring birds 3830 31498 100027 149083 4119 131088 106707 127781 13686

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For the first time in Bulgaria an estimation of the White Stork flyway population is made on the basis of observations at the points mentioned above. Total of about 414 000 White Storks were recorded to pass along the Black Sea coast (overlapping counts were identified and excluded from the total) over the observation points, which make about 40% of total European population. On a base of these figures it is expected about 70 up to 80% of the European population of White Stork to fly along the Via Pontica migration route. Conclusions On the basis of the results of the autumn migration study in 2004 the following conclusions can be made:

1. All the studied areas showed considerable importance for the migratory soaring birds and can be qualified as bottleneck sites.

2. The area between the town of Kavarna and Kaliakra Cape has to be designated as IBA because of its specific geographic conditions and vulnerability of the migratory birds when they pass this area. The lands where big flocks of white storks overnight regularly also must be included within the IBA.

3. The Balchik area confirm its importance for migratory birds and as more than 3% of birds fly less than 500 m high it could be considered as bottleneck site and designated as IBA

4. A new IBA will be proposed – “Batova”, which includes both the valley of the river Batova and Frangensko Plateau where big flyway populations of storks, pelicans and raptors concentrate. Almost all the migratory birds, which passed the area were recorded both in Rogachevo and Balchik points, and only the birds flying along the Batova valley (mainly raptors) were not recorded, but pass the area.

5. The IBA Emine will be significantly enlarged to the west and to the south to cover the Obzor pass and Dyulino Pass on Stara Planina Mountain, as well as the plain and the sea next to the south slopes of the mountain.

6. The importance of Kamchijska Planina IBA as a stopover site for raptors during migration is confirmed.

7. A new IBA will be proposed in the area of Ravadinovo – named Bakurluka, which cover the studied area which includes significant part of sea, as well as the Bakurluka Hill, which is used mostly by raptors as a stop-over site during migration.

8. Data on migratory birds at two existing IBAs – Provadijsko-Royaksko Plateau and Strandja were improved.

9. The study gives valuable ornithological argumentation for the significance of coastal and inland territories of East Bulgaria for migratory birds and improve considerably the knowledge on the Via Pontica migration route. It clearly shows the need migratory routes in Dobridja to be additionally studied in order to ensure the key areas gain proper legal protection

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Dynamics of soaring birds along the Black Sea Coast - autumn 2004

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Dynamics of raptors migration along the Black Sea Coast - autumn 2004

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Dynamics of White Stork (Ciconia ciconia) migration along the Black Sea Coast - autumn 2004

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Dynamics of White Pelican (Pelecanus onocrotalus) migraton along the Black Sea Coast - autumn 2004

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Appendix II Convention on the Conservation of European Wildlife and Natural Habitats Draft Recommendation No xx (2004) of the Standing Committee examined on xx November 2004 on the proposed construction of the Kaliakra wind farm parks in Bulgaria, threatening a large proportion of the European populations of certain bird species during their migration along the Via Pontica migration route, at a site qualifying as an Important Bird Area and Emerald/Natura 2000 site The Standing Committee of the Convention on the Conservation of European Wildlife and Natural Habitats, acting under the terms of Article 14 of the Convention; Having regard to the aims of the Convention to conserve wild flora and fauna and their natural habitats; Recalling that under Article 4 of the Convention each Contracting Parties shall take appropriate and necessary legislative and administrative measures to ensure the conservation of the habitats of the wild flora and fauna species, especially those specified in Appendix I and II, and the conservation of endangered natural habitats; Recalling that Article 4 of the Convention stipulates that the Contracting Parties in their planning and development policies shall have regard to the conservation requirements of the areas protected under the preceding paragraph, so as to avoid or minimize as far as possible any deterioration of such areas; Considering that the Kaliakra region lies on the migration route and in the winter range of globally threatened and other rare species of European importance that Bulgaria has undertaken to protect under its national legislation; Considering that the site between Kavarna town and cape Kaliakra is a major component in the implementation of the Emerald/Natura 2000 network; Aware of the foreseeable adverse impact of the proposed wind farm on the European populations of migratory bird species; Pointing at the Recommendation adopted by the Standing Committee of the Convention at its 22nd Meeting (4-5 December 2002) including guidance on criteria for environmental assessment and precautions for site selection of wind farms; Mindful of the need to reconcile the economic and ecological issues raised by this project and convinced of the necessity of identifying an alternative location for the wind farm compatible with the natural and human environment; Recommends that the Government of the Republic of Bulgaria:

1. takes full account of the additional information provided through the bird survey carried out at the site by the BSPB/BirdLife in Bulgaria from 10th August to 21st October 2004 and revokes the decision on the EIA of the Director of the Regional Inspectorate of Environment and Waters in Varna and the Minister of Environment and Water Mrs Dolores Arsenova;

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2. invites the investor to consider an alternative location for the wind farm which

avoids conflicts with the requirements of biodiversity conservation;

3. requests EIA procedures on all future wind turbine construction proposals;

4. does not endorse any further EIA on any wind farm project if it is based on wildlife surveys of less than 12 months thorough, adequate and intensive field work with in-depth analyzes and well-justified prognoses and conclusions. Takes full account of any additional information, as it emerges.

5. takes account, in the assessment of any future wind farm projects, of the

imperatives of conserving fauna, flora and habitats as well as the concerns of the local communities in the municipalities concerned;

6. undertakes as a matter of priority and urgency, a detailed and profound Strategic

Environmental Assessment of all suitable locations in the country for wind farm construction, allowing expert NGOs a substantial role in this process. This assessment should endeavour to foresee objectively, inter alia, any possible conflicts and threats to wildlife;

7. ensures that where wind farm development takes place that may have a significant

negative impact on wildlife, proper independent monitoring schemes on the environmental impact are established, making full use of input from experts including NGOs;

8. ensures that all areas that qualify as sites in the Emerald/Natura 2000 network

receive full legal protection within the pre-accession period, as well as afterwards, and that any deterioration is avoided while their natural values are protected.