Europe s Living Countryside Project. BULGARIAN REPORT Executive Summary

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1 Europe s Living Countryside Project BULGARIAN REPORT Executive Summary WWF DCP, Bulgaria September 2005

2 Europe s Living Countryside Project Bulgarian National Report Executive Summary Text 2005 WWF Danube-Carpathian Programme Prepared by: Yanka Kazakova, AgRD Coordinator, WWF Danube-Carpathian Programme e.mail: Kazakova@wwfdcp.bg; tel: With input from: Stanimir Stoychev Stoycheff Consult EOOD Dobromira Dimova Association of Parks in Bulgaria Svetla Nikolova Association Agrolink prof. Nadka Ignatova Forestry University in Sofia. 2

3 Preface The second pillar of the CAP has been developed to contribute towards sustainable rural development and to help rural areas to adapt to changes in Pillar 1 support and to rural restructuring, particularly in the agricultural sector. The EU-15 Member States and the candidate countries developed and implemented a first generation of rural development programmes following the 1999 Rural Development Regulation and SAPARD. In 2005, the European Agricultural Fund for Rural Development (EAFRD) package of measures was agreed. This provides the basis for the second generation of rural development programmes in the enlarged EU-25. EC strategic guidelines for rural development will be published and will place a stronger emphasis on the need to achieve sustainable development and on EU policy priorities, which include environmental priorities. Overall the new Regulation requires Member States to take a more strategic, focussed and participative approach to rural development as they develop their plans in for the new programmes to be implemented for the period. This study is part of Europe s Living Countryside, a pan-european research project sponsored by WWF Europe, the Land Use Policy Group (LUPG) of GB s conservation, countryside and environment agencies and Stichting Natuur en Milieu (SNM) in the Netherlands. National studies were undertaken in seven countries (Spain, Poland, the Netherlands, the UK, Germany, Hungary and Bulgaria see map below). The aim was to review progress with developing and implementing rural development programmes and to explore in detail how environmental priorities and objectives might better be identified and addressed in the new rural development programmes. Our research builds on Europe s Rural Futures, an earlier LUPG and WWF Europe pan- European project which analysed MSs initial progress with developing and implementing the plans. Areas highlighted where improvements could be made included the need for a more strategic, coherent and integrated approaches to addressing environmental issues. 3

4 The Europe s Living Countryside national research was carried out using an agreed common framework. This included analysing the evidence on environmental data and trends, using the results of mid-term evaluations and holding discussions and/or seminars with key stakeholders to help identify environmental priorities and to consider how the tools in the new regulation might be used to address environmental priorities and improve integration of environmental issues. Each national study includes at least one local case study to illustrate how this could be achieved. National experts from the LUPG, WWF and SNM partnership coordinated the in-depth national research, supported in some countries (Germany, the UK and Poland) by consultants commissioned to undertake the detailed work. For further information about the Europe s Living Countryside project please see or or contact: Rosie Simpson, Senior European Policy Adviser (Sustainable Land Management), Countryside Agency: Tel: rosie.simpson@countryside.gov.uk Elizabeth Guttenstein, Head of European Agriculture and Rural Development, WWF European Policy Office: Tel: Eguttenstein@wwfepo.org Arjan Berkhuysen, EU Nature and Agricultural Policies, Stichting Natuur en Milieu: Tel: a.berkhuysen@natuurenmilieu.nl 4

5 BULGARIA S EXPERIENCE IN RURAL DEVELOPMENT POLICY Bulgaria is scheduled to join the EU on 1 January 2007 and does not yet implement the full array of the European policies at national level. The current rural development policy was introduced in Bulgaria with the SAPARD programme in Bulgaria was among the first candidate countries to have its SAPARD national plan (NARDP) approved by the European Commission. BULGARIA S RURAL CONTEXT Bulgaria occupies about 11 million hectares of which 6.4 million hectares are classified as agricultural land and 3.8 million hectares are classified as forests. 4.7 million hectares are arable land and 1.4 million hectares are grassland and pastures. Protected areas cover approximately 5% of the country, predominantly forest areas. Bulgaria has good natural resources for agriculture, including some of the most productive farmland in Central and Eastern Europe with a wide variety of farming systems. About 20% of the agricultural land is mountainous or semi-mountainous. Rural areas cover 81.4% of the total area. The rural population amounts to over 3.6 million people, approximately 44% of the country s total population. The major forms of economic activity in rural areas are agriculture, forestry, tourism and traditional rural crafts. Historically, agriculture has been the backbone of the Bulgarian economy. The share of agriculture and forestry in the GDP has fluctuated widely reaching 27% of GDP in 1992 and falling back to about 12,5% in Bulgarian agriculture is currently characterised by market-orientated large-scale farms occupying 74% of the total utilized agricultural land and very small scale individual farms, occupying 26% of the total utilized agricultural land, with an average size of 1.2 ha. With the rise of subsistence farming, agriculture has become more labour intensive and agriculture has acted as an important social buffer to rising levels of unemployment during the transition period. 5

6 OVERVIEW OF THE STATE OF THE RURAL ENVIRONMENT AND MAIN ISSUES Consultations suggest that the environmental problems associated with agriculture in Bulgaria are mainly related to soil and water pollution, soil degradation and erosion. This perception treats the agriculture-environment relationship mainly in its negative aspects. The more positive aspect of farming creating high nature value areas and maintaining important habitats is not recognized. The ELCo project in Bulgaria focuses on the issues of water and biodiversity/landscape which usually do not get sufficient attention as issues related to agriculture. WATER Bulgaria is a country with scarce water resources. The water flow is highly regulated. Riverbeds have been canalized and associated biodiversity lost, and dams have been built to store water. The irrigation infrastructure in the country is significant. In 2002, the areas under irrigation were 22% of the utilized arable land for the period. However, according to the Ministry of Agriculture 40% of the national irrigation network is of low efficiency, and 80% of the secondary channel network is practically ruined. On the one hand, this situation has a negative influence on yields and on crop rotations structure, while on the other it reduces significantly soil losses due to water erosion. The quality of the surface water is improving and the nutrient load is declining, although agriculture continues to cause point and non-point water pollution. The high level of nitrates in ground water is most often due to agricultural practices. There is a lack of targeted programmes for awareness raising among farmers and other rural water users. There is still a perception that dams are the best solution to water scarcity problems and new approaches and technologies for water saving are required. The conventional engineering approach to water management continues to drive the destruction of the remaining waterrelated biodiversity (wetlands, riparian habitats). The Environment Protection Act defines the protection and use of water to secure rational management at national and river-basin levels. The Water Act defines requirements for water protection and use. It only partially delivers the requirements of the Water Framework Directive. The programme for implementation of the WFD in Bulgaria is still not developed. Staff in the directorates needs a lot of capacity building and training in order to be able to cope with the ambitious tasks and responsibilities put on them. River-basin management planning lacks sectoral stakeholder involvement. Biological monitoring of lakes, reservoir and coastal waters is still implemented only at pilot level. The system of criteria and indicators for water classification in terms of biological elements is still not developed and adopted. BIODIVERSITY Bulgaria is among Europe's most biodiversity rich countries, with the presence of unique natural habitats, flora and fauna. In compliance with international obligations Bulgaria has developed the National Biodiversity Conservation Strategy (1998) and the National Plan for Biodiversity Conservation (2000). 6

7 However, there is incomplete compliance in respect of natural habitats and the development of management plans for species. Protected areas in Bulgaria cover around 5% of the territory, mostly situated in forest areas: there are about 200,000 ha of virgin forests. Current proposals would increase the total area of the protected areas to more than 15% of the territory: the present network of protected areas is not representative for the country. Parallel to the slow process of announcement of new protected areas there is a tendency for taking out parts of already established ones due to ongoing or planned construction. The development of the Natura 2000 network in Bulgaria started at the end of According to expert evaluations Bulgaria has potential sites that comply with the requirements of Natura They cover about 35% of the national territory, which is almost twice the Government s estimate of 12-15% of the total area of the country. The identified threats in the National Plan for Biodiversity Conservation are: application of inappropriate agricultural techniques and practices (including ploughing of meadows and abandoned agricultural lands), fires, soil degradation, uncontrolled gathering and destruction of plant and animal species, loss of genetic diversity and neglect of indigenous breeds and varieties. With regards to the costal ecosystems the threats are water pollution, gathering of rare and endangered species and introduction of foreign species. In the case of wetlands the major problems are drainage, changes in the water regime, engineering works on river banks and the related destruction of plant and animal species and the loss of entire natural habitats. The problems of the forest ecosystems are related to the poor integration of biodiversity conservation in the legislation. In the last two years new framework documents containing better information and priorities regarding conservation of forest habitats have been developed. Biodiversity conservation outside protected areas, including on HNV farmlands will require new measures and habitat degradation as a result of human impact requires restorative measures. Local/indigenous valuable agricultural species, local plant varieties and animal breeds, and the wild relatives of crops and breeds need preservation. Bulgarian flora and fauna includes a substantial number of endemic species and subspecies with extinctions over the past few decades. Access to such data is very difficult and often considered non-existent. More structured data at regional level is available for the few protected areas which already have management plans. There is almost no information on biodiversity outside the protected areas. Monitoring of biodiversity is still not done in Bulgaria. There are actions taken at the moment to design a biodiversity monitoring programme: monitoring and research is required on the influence of different agricultural practices on biodiversity. Farmers (especially in the less developed rural areas) need encouragement and incentives to use environmentally friendly practices and the Ministries of Agriculture and Environment require strengthening to undertake their environmental roles. 7

8 LANDSCAPE Bulgaria has recently ratified the European Landscape Convention but it is still not transposed in the national legislation. The National Biodiversity Conservation Strategy specifies 12 types of ecosystems and landscapes as unique and representative for the Bulgarian biological diversity. The major part of the important landscapes is included in the large protected territories. Such landscapes are included also in the three national parks and the ten natural parks. Data on landscapes is not collected at the moment at all, so it is difficult to evaluate landscape changes. The changes in landscape resulting from human impact in the form of infrastructure changes are a substantial problem. Introduction of large infrastructure projects, observed mostly in the high mountains and on the Black sea coast, has led to negative changes in the landscape diversity of the country. The abandonment of arable land and pastures as well as the ploughing up of meadows and the clear-cutting of small woodlands in arable fields also bring significant landscape changes. In recent years there is a tendency for subtracting lands from designated agricultural land and including them in the construction boundaries of settlements. This process is observed mostly around the big cities and the Black sea coast. Often the subtracted lands are meadows, some of which are species-rich. The construction that follows leads to substantial changes in landscape and loss of species and habitats. The efforts of various institutions (regional development, agricultural, environmental and nature conservation, scientific, land and resource users) need better integration to achieve successful results in the management of the landscapes. HIGH NATURE VALUE FARMING AREAS There are several mountain ranges in Bulgaria where the habitats and species are of pan- European importance. Their conservation depends on the maintenance of the existing extensive agricultural practices. The preservation of the local breeds, which are often connected with different mountainous zones, contributes to the maintenance of rich genetic diversity. According to the National Biodiversity Conservation Strategy grasslands and wetlands are the most vulnerable and threatened habitats in the country. Much of the biodiversity and ecosystems are on, or in the immediate vicinity of farmland, and are directly or indirectly influenced by agriculture. Important natural resources on farms include vast territories of unaltered semi-natural regions, such as meadows, pastures, protected animals and plants, which are not to be found in nature reserves or other protected areas and are the main resource for agri-environmental protection initiatives. High Nature Value farmland contributes significantly to environmental assets. As yet, the concept of HNV farmlands is not applied in Bulgaria. A large share of Bulgaria s farmland can be defined as HNV although there is a lack of inventory and mapping. Overall there is almost no information on HNV farmlands status and distribution in the country. There is no government strategy or action plan for the maintenance and conservation of High Nature Value farmlands. Grasslands cover approximately 30% of the total agricultural land and are mostly seminatural, divided into pastures, covering approximately 70%, and the remaining 30% used for haymaking. Traditional practices such as haymaking, application of wood ashes, manuring and sowing of additional grass mixes have declined. 8

9 With the significant decrease of livestock numbers in Bulgaria the importance of grasslands as a fodder resource has decreased as well. As a result, many hay meadows are being ploughed up and pastures especially in remote areas are abandoned. These two factors threaten as many as 40% of the existing grasslands in the country. Improvements are required in the political framework for the maintenance and conservation of the HNV farmlands in Bulgaria, with better joint and coordinated actions between the Ministry of Agriculture and the Ministry of Environment, and involvement of key stakeholders (e.g. farmers, nature conservationists). There are no measures to support the conservation of HNV habitats and the related production systems. Rural development measures for the management of HNV farmland are needed bearing in mind the traditional importance of these systems for rural people. THREATS POSED TO THE ENVIRONMENT IN RURAL AREAS Traditionally agricultural and forest practices contributed to the creation and diversity of high nature conservation value areas. Many of them are still preserved in the mountainous and remote areas in Bulgaria. However, the more intensive agricultural and forest practices of the last decades led to significant changes and degradation of environment and nature. The next box summarizes the main threats posed by intensive and/or unregulated agricultural and forest activities. The public support coming from the national rural development programme should prevent degradation and whenever possible introduce targeted measures to improve the status of the environment. 9

10 Box 1: Main threats posed by farming and forestry FARMING Scrub encroachment in high mountain pastures due to lack of grazing animals. Degradation processes and loss of plant and animal species due to ploughing of meadows. Water pollution caused by either excessive use of chemicals or improper practices. The reversal of monoculture agriculture on large areas (eg. in Dobridja and Trakiiska nizina). Burning of stubble. Degradation processes and overexploitation of grasslands near settlements due to overgrazing by livestock. Logging of natural lowland forests and converting them into arable lands. Expansion of goat breeding, especially in the forest regions Loss of native breeds and crops. Reduction of the rice fields, which leads to reduction of the wetlands that are important for the birds. Semi-wild grazing by stock pigs (eg. in Strandja). FORESTRY Substantial changes in the biological and landscape diversity as a consequence of frequent forest fires. Illegal logging. Change of the natural communities as a result of improperly planned or conducted renovation measures. Erosion resulting from the methods used in the economic exploitation of forests. Water regime disorder as a result of drainage, construction of dams and other irrigation facilities, and redistribution of big quantities of water for industrial purposes. Substitution of habitats with intensive forest crops and foreign and exotic species. Decrease in the area of forest habitats as a consequence of infrastructure construction, private home construction, industrial construction, and change of forestlands into arable lands Increased pressure from tourism. Low level of farmers and foresters awareness (especially in the less developed rural regions) with regards to the problems of biodiversity conservation and the existing programmes and funds in this respect. Lack of tools for stimulating the farmers and forest owners to conserve biodiversity and implement environmentally-friendly practices. Lack of monitoring and research on the influence of different agricultural and forest practices on biodiversity. 10

11 KEY ENVIRONMENTAL ISSUES RELATED TO FARMING AND/OR FORESTRY The selection of environmental issues presented is not exclusive and does not mean that they are the only ones of importance for the country. However, we consider that biodiversity gets little priority in developing agriculture and forest programmes and water is only mentioned when water pollution problems are concerned. Therefore, we selected issues that are present throughout the whole country with the aim to initiate integrated and coordinated actions to tackle them. We also hope to demonstrate that farming activities, farm viability and nature conservation are not competing processes and can be complementary and mutually supportive. For the chosen themes of water and biodiversity, the issues related to farming, forestry and/or rural development can be summarized as follows: WATER 1. Continuous loss of riparian habitats due to infrastructure development through Dam construction for securing water resources for irrigation Riverbank vegetation clearance Excessive water consumption for irrigation 2. Reduced water quality due to pollution from settlements, farmlands and non point sources through Improper manure management facilities due to lack of knowledge and funding Water pollution due to improper agricultural practices Lack of sewage systems in many rural settlements BIODIVERSITY 3. Loss of biodiversity and landscape diversity due to land abandonment through Loss of mosaic landscapes especially in mountainous areas Abandonment of extensive pastures (HNV areas) due to decreased numbers of farm animals 4. Loss of traditional farming systems and the related biodiversity due to intensification through Ploughing of wet meadows for conversion Loss of local breeds of animals Loss of shelter belts, terraces and other landscape features Decline of valuable animal and plant species due to uncontrolled gathering by local people 5. Conflict between farmers and wild fauna through Conflict between farmers and large carnivores Declining number of waterfowl due to poaching and hunting. 11

12 PROPOSED OBJECTIVES AND TARGETS FOR THE SELECTED ENVIRONMENTAL ISSUES For each of the issues and sub-issues listed above a set of objectives and examples of quantified targets are proposed in the report which are relevant to the rural development programmes and measures. Issues Objectives Targets Continuous loss of riparian habitats due to irrigation infrastructure development Reduced water quality due to pollution from settlements, farmlands and non point sources Develop a strategy for the restoration and management of riparian habitats in line with the WFD; Ensure that the measures have direct links to Natura 2000, river basin and existing protected areas management plans; New hydro-infrastructure projects must not lead to any further loss of riparian habitats throughout the country; RD measures in place that will contribute to achieving good ecological status of the rivers by 2015; Develop an action plan for dealing with the water pollution from agriculture, not only for Nitrate vulnerable zones; Ensure an integrated planning of the rural infrastructure development (new sewage systems, etc) between the agriculture, regional development and environmental authorities. In each of the four river basins riparian habitats and floodplain restoration measures are implemented by 2013 X m/km/ of riverbank vegetation (tree belt) is restored by % of the areas under irrigation have water saving technologies by The loss of water because of outdated irrigation systems is reduced by X%. 80% of the farms have proper manure management facilities by X settlements have new sewage systems; The size of the nitrate vulnerable zones is reduced by X ha by

13 Loss of biodiversity and landscape diversity due to land abandonment Loss of traditional farming systems and the related biodiversity due to intensification Conflict between farmers and animals RD measures are in place that will contribute to achieving favourable conservation status for the N2000 areas within 10 years; Define appropriate land use patterns and farming systems for the areas most threatened by land abandonment (Strandja, Rodophi, etc.) together with the nature conservation authorities, in partnership with farmers and NGOs; Ensure that all policies (agriculture, RD, regional, etc.) in the region work towards achieving them; RD measures contribute to maintaining traditional farming systems and the related biodiversity in the long-term; Define appropriate patterns of land use and farming systems that will contribute to the conservation of habitats and species of national and European interest. Ensure that Pillar 1 and Pillar 2 payments work in an integrated way to promote these objectives. Ensure that measures have direct links to Natura 2000 and river basin management plans. Develop measures jointly between agriculture and nature conservation authorities, in partnership with farmers and NGOs to reduce this conflict; Ensure that these measures have direct links to Natura 2000 and protected areas management plans; Support the traditional farming systems, dealing with the conflict; 90 % of all HNV areas receive support for environmental farming by 2013; at least 5 initiatives are developed and implemented to demonstrate the positive link between the farming practices and biodiversity and landscape diversity; Measures are in place and taken up for 80% of all existing wet meadows by 2013; Undertake re-conversion activities towards wet meadows in at least 5 regions by the number of animals of 4 local breeds is doubled by X m of wild belts / terraces are maintained and restored by 2013; The number of animals killed by farmers because of this conflict is reduced by 75% by

14 STRUCTURE AND CONTENT OF THE SAPARD PROGRAMME IN BULGARIA Bulgaria has one national plan for the period which sets the framework for the implementation of the SAPARD programme in the rural areas. This National Agriculture and Rural Development Plan is developed by the Rural Development Directorate of the Ministry of Agriculture and Forestry. The practical implementation of the measures in the country is a responsibility of the SAPARD Agency, which combines the functions of implementing and paying bodies. The Bulgarian national plan for agriculture and rural development has two main objectives: 1. Development of efficient and sustainable agricultural production and competitive food processing sector through improved market and technological infrastructure and strategic investment policies, ultimately aimed at reaching EU standards. 2. Sustainable rural development, consistent with the best international environmental practices by providing alternative employment opportunities, economic diversification, development and rehabilitation of infrastructure. The national plan envisages their achievement via the implementation of 11 measures. Top priority (78% of the budget) is given to the actions to cover strategically important actions related to the improvement of production and processing in the agricultural sector in compliance with the EU acquis. There are six measures in which the beneficiaries are mainly private agricultural and forestry holdings and food processors. The second priority area (18% of the budget) covers the implementation of integrated rural development plans in selected Bulgarian rural regions. The importance of this priority area is expected to grow over time. For the achievement of the second objective - integrated and sustainable rural development - 3 measures are defined, i.e. diversification of activities of the private agricultural holdings, renovation of villages and protection of heritage and development of public infrastructure. The objective of the development of human resources (third priority area) has one measure improvement of vocational training. The fourth priority area technical assistance - is designed to assist in the implementation and monitoring of SAPARD Programme. Initially there were three approved measures: investments in agricultural holdings, improving the marketing and processing of agricultural and fishery products, and development and diversification of economic activities, provision of multiple activities and alternative income. Six more measures were approved in August 2003: forestry, afforestation of agricultural areas, investment in forest holdings, processing and marketing of forestry products, setting up producer groups, renovation and development of villages, protection and conservation of rural heritage and cultural traditions, 14

15 development and improvement of rural infrastructure, improvement in vocational training and technical assistance. The remaining two measures Management of Water Resources and Development of Environmentally Friendly Agricultural Practices and Activities are not yet approved. ENVIRONMENTAL DESCRIPTION AND OBJECTIVES INCLUDED IN SAPARD Each of the measures has its own operational objectives. Environmental protection is reflected in most of them. In most cases the Plan requires that the project/holding of the beneficiary should comply with the current national standards regarding the environment at the time when the decision to grant is taken. In the cases where the activity of the applicant is subject to mandatory Environmental Impact Assessment, according to the Environmental Protection Act, the decision should be included in the application package. However, there are no environmental indicators for progress towards objectives. WATER In general the environmental description covers all the main environmental issues including water quality and quantity (mainly water protection from pollution by fertilizers, pesticide and heavy metals). Nevertheless several specific issues in relation with water protection are not covered sufficiently in the programme. The programme does not provide enough quantified data on the state of water quality in the rural areas. The agri-environmental measure provides more information on water quality in the rivers Struma, Arda, Rusensky Lom, Veleka which are the pilot areas of the Anti-erosion action. The interrelations between farming activities and water-related biodiversity (wetlands, floodplains, riparian habitats, etc.) are not discussed in the environmental description at all. BIODIVERSITY/LANDSCAPE The environmental section of the SAPARD programme in Bulgaria describes mainly problems related to the environmental components and less on issues concerning the conservation and restoration of biodiversity. There is no information on the landscape diversity in the environmental context section. This diversity is mentioned only in the description and categorization of the protected areas. Conservation of landscape and historical heritage in the less developed rural regions is not pointed out. The place of the high nature value farming areas is not pointed out in the definition of the future national ecological network (Natura 2000). HIGH NATURE VALUE FARMLANDS The existence of high nature value farming areas is not specified in the present National Agriculture and Rural Development Plan. Inclusion of HNV farming areas will play a positive role in the conservation of biological diversity of species and habitats. It is recommended to assess the potential sites in the country, which are suitable for application of this system. 15

16 OFFICIAL EVALUATIONS OF THE SAPARD PROGRAMME IN BULGARIA a. Ex-ante evaluation (2000) In terms of impact on environmentally important areas, the SAPARD measures were not expected to have any negative effects. A rapid assessment for the measures influence on the implementation of the Habitats and Birds Directives was recommended, as well as to designate areas before the implementation of the SAPARD in Bulgaria. This has not happened yet. Sufficient information on protected flora and fauna species was not available and therefore it was not possible to comment on potential impact that SAPARD might have on their populations. The evaluators concluded that at least five of the measures could have a positive impact on the environment in agriculture and forest land. However, it was noted that the environmental impact depends a lot on the eligibility and selection criteria that are used and the incorporation of certain environmental policy and structural tools in the procedure. Specific recommendations were made and particular emphasis was given on the monitoring and evaluation procedures of projects so as to include environmental parameters. The results of the Mid-Term Evaluation and the related lack of environmental performance information revealed that these were not followed. Overall, the evaluators state that the Bulgarian SAPARD Plan is drafted towards the support of economic development in agricultural and rural areas, through concerted agrarian and alternative economic activities. The current implementation results show that the recommendations of the ex-ante evaluators were not followed, especially regarding the integration of environmental parameters in the monitoring and evaluation procedures of projects. Therefore the achievement of the stated SAPARD environmental objectives is questionable. b. Mid-Term Review of the SAPARD programme in Bulgaria (2003) The Mid-Term Evaluation (MTE) of the SAPARD programme in Bulgaria 1 covered the period of implementation from June 2001 to May The data available for the evaluation are also considered limited by the evaluators who organized additional interviews and focus groups to collect more information. The MTE concludes that the SAPARD programme has had a positive contribution to the implementation of the acquis communautaire concerning the CAP. Protection of environment, compliance with product hygiene and food safety standards were integrated in the eligibility criteria for projects selection. However some important indicators including waste generation, manure and slurry storage methods, pollution discharge and impact on landscape and biodiversity, were omitted. By the time of evaluation no projects targeted exclusively at environmental improvements have been implemented. In almost all the supported investments, beneficiaries stated that investments respect the EU standards for protection of environment and the production processes meet the requirements of the environmental protection legislation. However, there is no structured procedure to verify this. On the contrary, a report by the European Court of Auditors reveals that such checks on the compliance of the investments with environmental standards are not carried out. 1 The evaluation was done by Agriconsulting Europe S.A. 16

17 The SAPARD Programme has been adding significant investment funds to the Bulgarian agriculture and processing industry. Supported investments in agricultural holdings in the first 3 quarters of 2003 are equal to 88% of the gross investments in the Bulgarian agriculture in 2001, and the SAPARD supported investments in the processing industry are about 50% of the investments in all food industry sectors in The underdeveloped agricultural credit market and the complexity of SAPARD implementation arrangements have skewed the distribution of funds towards larger agricultural holdings and food processing companies and to projects with a shorter investment cycle. Further conclusions of the MTE are that the SAPARD application form and business plans are rather complex. In addition, the list of supporting documents both in the application stage and in re-payment stage was regarded as being too long and that their collection required significant financial and physical resources on the behalf of the applicant. c. EU Court of Auditors Special Report Has SAPARD Been Well Managed Bulgaria was one of the accession countries visited by the auditors of the European Court of Auditors to evaluate the SAPARD programme implementation 2. On the environmental performance of the SAPARD Programme in Bulgaria the results of the audit confirm that the country granted higher priority to other measures than agri-environment, forestry, etc. At the same time the management and control systems of all measures foresaw insufficient checks in risk areas such as compliance with minimum standards for environment, hygiene and animal welfare. Another conclusion of the auditors report is that the SAPARD money has generally been spent on projects that increase the quantity of agricultural production, and not on projects which improve the quality of agricultural production (meeting quality and health standards and protection of the environment). On the application process the report of the auditors conclude that the number and difficulty of obtaining the supporting documents is too high and their relevance is not always clear. However, the report states that the cumbersome administrative procedures are common for all SAPARD countries and are stricter than those required by the Commission. Overall, assessing the two official SAPARD evaluations Ex-ante and Mid-term, and the situation on the ground in the country, we can conclude that the major objective and guiding principle of the SAPARD programme in Bulgaria is to improve the competitiveness of the agricultural sector (mainly medium and large scale holdings and enterprises) with the social and environmental objectives being a wish list of things that might happen but without a real mechanism to pursue them. 2 EU Court of Auditors, Has SAPARD been well managed? Special Report No.2/2004, OJ C295, p.1-22,

18 RECOMMENDATIONS FOR ADDRESSING THE ENVIRONMENTAL ISSUES Recommendations on WATER Nationwide awareness-raising programme is needed to overcome the old-fashioned thinking that dams are the best solution to water scarcity problems; Sectoral stakeholders (farmers and foresters, their associations, agricultural advisors, etc.) should be actively involved from the very beginning in the river-basin management planning; Rural development measures (eg. axis 1 investments in agricultural holdings, axis 3 rural infrastructure, etc.) should support new water management approaches and water saving technologies (eg. on farm drip irrigation systems); Further destruction of the remaining water-related biodiversity (wetlands, riparian habitats) should be prevented by requesting environmental plans from all projects supported under the rural development plan; The training and advisory measures should support targeted programmes for farmers and other rural water users on the issues of water pollution prevention, water-saving technologies and practices, etc. Recommendations on BIODIVERSITY Introduce rural development measures (agri-environment, forest-environment, lessfavoured areas payments) aiming to support biodiversity conservation both inside and outside protected areas, including on high nature value farmlands Introduce targeted agri-environment and forest-environment measures to restore habitats that have degraded as a result of human impact meadows, pastures, wetlands, forests, wood and shrub strips dividing arable lands. A combination of axis 1 (investment, training, advisory) and axis 2 (Agri-environment and LFAs payments) measures is needed to preserve local/indigenous valuable plant varieties and animal breeds, and the wild relatives of crops and breeds. The development of biodiversity management plans on agricultural and forest lands should be supported under the rural development programme (including mapping of habitats and land uses, and monitoring on the influence of different agricultural and forest practices on biodiversity). Recommendations on LANDSCAPE The ex-ante evaluation of the national rural development plan should assess the impact of the measures proposed from all axes on the landscapes in the country and whether there are sufficient precautionary measures for tourism and other rural infrastructure development. Axis 2 measures should effectively contribute to the maintenance of the designated valuable landscapes via the agri- and forest-environment, LFAs and Natura 2000 payments measures. 18

19 Afforestation measure should not change valuable landscapes by planting trees on speciesrich grasslands. The local development strategies supported under the axis 3 and Leader should consider the surrounding landscapes and introduce actions to enhance them. Recommendations on HIGH NATURE VALUE FARMLANDS The Bulgarian government should develop a strategy and an action plan for the maintenance and conservation of High Nature Value farmlands Inventory and mapping of High Nature Value farmlands could be supported under the rural development plan; Measures from all axes supporting both directly the conservation of HNV habitats (axis 2) and indirectly by supporting the related production systems (axis 1) and the related infrastructure (axis 3) should be introduced. Recommendations on PUBLIC PARTICIPATION MECHANISMS The SAPARD programme is providing experience and knowledge in public participation in Bulgaria s rural development policy. There are actions that need to be taken in order to build on this mainly positive experience and to improve it for the next programming period: The formalisation of the procedures for involving stakeholders social, economic and environmental in the design, implementation, monitoring and evaluation of programmes and measures at local, regional and national levels; Capacity building measures and funding for local and regional stakeholders participation should be introduced to make them an active and equal partner for rural development. The model of the transparent nomination process established by environmental NGOs should be used as a democratic model by other economic, agricultural and social partners; Stakeholders groups need to elaborate criteria and process for nominating and selecting representative. The participation of these representatives should also be subject to monitoring and evaluation. The stakeholders outside the inter-ministerial working group should be involved in the very beginning of the process of programme s design and measures; Recommendations on DELIVERY MECHANISMS Overall, greater promotion and targeted delivery of the programme to encourage participation from all potential beneficiaries is recommended: Up-dated quality information on the funding possibilities should be available at the lowest possible administrative level (village or municipality). Delivery should be adapted according to the target group characteristics more efforts should be focused on small and medium-size applicants. All applicants (not just registered agricultural producers) should have access to various 19

20 expertise/advices to beneficiaries technical, economic, environmental, etc. Allow other organizations than the National Agricultural Advisory Service to provide consultancies and get paid for it. Provide regular and specialized training to the advisors - improve their knowledge and skills, do not rely only on their old background. Prepare and make available more easily understandable and user-friendly guidelines for applicants. Recommendations on MONITORING, EVALUATION AND INDICATORS The SAPARD programme was the first to introduce monitoring and evaluation mechanisms in Bulgaria and to allow for public participation in it. The experience shows that it is probably one of the most difficult tasks for all involved parties. Quantitative and qualitative indicators, including environmental should be developed at the very beginning of the programmeming process. They should be subject to approval with the whole package of programme s objectives, priorities, measures, etc.; Baseline information on the proposed indicators should be collected in due time; Access to project data should be provided at least for the members of the monitoring committee, its working groups and programme s evaluators; Systemized information on the status of achievement of the objectives of programmeand measures should be provided on a regular basis (annually) Ensure transparency of all aspects of programme implementation Identify the good practices and promote them among beneficiaries and applicants Introduce corrective measures/actions in due time Strengthening the role of the stakeholders in programme implementation. The effectiveness of their inputs could be improved if further training is provided. The Monitoring Committee should develop a mechanism and procedures for feed back on the implementation of decisions taken and reasons for not doing so. Create possibilities for involving independent experts (NGOs, etc.) in the whole cycle of monitoring, evaluation and control of the programme. 20