Targeted Water Dotted by hunters' bullets, this sign in the Rila Mountain reads: “Strictly guarded drinking water zone – access restricted”. Photo: Aleksandra Dzhermova

Targeted Water

A controversial small hydropower plant (HPP) construction near the Rila National Park has been put on hold, following opposition and criticism by activists for the protection of nature. Happy with the outcome for now, environmentalists point at ineffective procedures and legal loopholes that render legal protection of Bulgaria’s rivers meaningless.

The project, called Energy Govedartsi, was of one many micro HPPs which mushroomed along Bulgaria’s rivers after the country passed laws that guaranteed preferential high prices for alternative energy back in 2007. Part of Bulgaria’s commitment to pan-EU renewable energy targets, the move led to a “Gold rush” phenomenon that practically dotted the country with alternative energy projects aiming for quick easy returns.

Energy Govedartsi intended three water catchments on the picturesque Cherni Iskar river and its tributaries: Preka and Levi Iskar, near the village of Govedartsi. The area falls in the municipality of Samokov, some 50 km away from Bulgaria’s capital Sofia, at the edge of the Rila Mountain – one of the country’s three national parks.

Dimiter Koumanov doesn’t like being called “green”: “I am just a guy who fights for his natural right to enjoy his hobby – fishing”, he explained. Photo: Personal Archive

Resistance to the proposed project mobilised  some of the most active organisations dealing with river protection: the Balkanka Association, aimed at protecting indigenous local trout; WWF Bulgaria; and the nation-wide For the Nature Coalition of civil society organisations. Dimiter Koumanov, a member of Balkanka, led the campaign. Two more prominent environmentalists also joined: Lubcho Lyukov, an engineer and local activist who had already campaigned against the construction of another hydropower plan on Levi Iskar river nearby, and Lyubomir Kostadinov, a lawyer at WWF Bulgaria.

A building engineer by profession, Koumanov’s real passion is fishing, and he speaks about rivers in an affectionate manner, calling them “the blood vessels of Earth”.  His love for rivers fuelled his desire to travel around the country exploring them and would later spark his mission to protect them. Today he has become a invaluable expert and voluntary  environmental watchdog for the protection of rivers throughout Bulgaria, maintaining a monitoring site for Bulgaria’s rivers at in collaboration with WWF Bulgaria.

The initial project for a micro-hydro plant above Govedartsi came from a company named Rila Eko Energy. The Commercial Register shows that the co-owners include Slaveyko Gerginov and Slavka Kyumdzhieva, individuals active in the construction of many hydropower plant projects in the Samokov region and investors in countless renewable energy projects around the country. Later on, the ownership changed, and the project was taken over by Agroinjinering 90, a company owned completely by yet another firm called Agrohold, which is owned by Vasil Zlatev. Zlatev’s son, Valentin, is a powerful businessman and representative in Bulgaria of Russian oil giant Lukoil.

“There is apparently a very high economic interest when building hydropower plants, because the state buys their energy at better prices. And this just creates the inability of institutions to do their job because the investor in this case is Valentin Zlatev, one of the most economically powerful people in this country”,  Lubomir Kostadinov commented in a media statement for BGNES.

Money against nature

According to the environmentalists, the rivers around Govedartsi are inhabited by critically endangered European bullhead fish and crayfish, both listed in the Red book of Bulgaria. A brief search in the online version of the Red Book shows that they are listed as threatened species due to the “degradation of habitats on the account of horizontal barriers on the river bed as a result of hydrological  activity”. The prescribed cure: to “stop the construction of new HPPs around the places they inhabit and establish protected areas”.

It becomes even more interesting as apparently the location of the future plants happens to be within the limits of a zone, named Rila-Bufer, which was proposed for inclusion in the EU’s Natura 2000 network of protected areas but has been postponed for years. “They are postponing Rila-Bufer on purpose so that they can accept such projects”, says Koumanov with disappointment.

WWF Bulgaria’s Kostadinov shares his opinion. In a media statement he explained that two of the EU’s directives are being overlooked in the case: the Habitats and the Water Framework Directive, that had set a 2015 deadline for all waters to be in a good ecological state. And waters are far from such as state in Bulgaria, the expert warned. Micro HPP installations like the one Govedartsi was building exist in large numbers along rivers across the country and frequently keep water conditions under critical levels. “And without proper water, there is just no ecological state. There is no life!”, WWF warned.

The clear waters of Cherni Iskar before the drinking water catchment. Photo: Aleksandra Dzhermova/

Sofia’s water under threat

Balkanka and WWF also pointed out that the main building of the future plant would be located 160m away from the drinking water catchment of the city of Sofia, situated around the Cherni Iskar river. In a detailed 19-page long objection to the Surface Water Exploitation Permit, the authors state that the building would fall into a Sanitary Protection Zone (SPZ), required by law around the water catchment area to ensure it’s safety. A SPZ features three rings, each within a different distance from the water source and with different restrictions. Energy Govedartsi’s building would be located within ring 1, bearing the highest restrictions imposed by law, where construction is strictly forbidden and access is allowed only for the support teams only.

So if the project was carried out, regulations would be violated and people’s health would be at risk, conservationists argued.

poison from the decaying biomass would be consumed by the people in Sofia

Moreover, all rivers from the body of water Cherni Iskar, Malyovishka, Preki rivers, Pravi Iskar, Levi Iskar and others are located in a protected zone for drinking waters, Lukov stated in a letter to Sofia’s mayor, Yordanka Fundakova, and Sofia’s environmental inspectorate. He went on explaining that “the poison from the decaying biomass in the water would be consumed by three million people in Sofia”.

A field trip and brief walk around the area show close proximity between the future construction site and the two water catchments – on Cherni Iskar and on Preka. Both are used by Sofiyska Voda – Sofia’s water supply corporation – and have signs saying: “Strictly guarded drinking water zone – access restricted!”

Cherni Iskar river after the water catchment with significantly reduced running water in the river bed. Photo: Aleksandra Dzhermova

“We already have problems with water! Especially in winter. If they catch Preka river, some neighbourhoods of Sofia will be left without water”, complained a local elderly man, who spoke on condition of anonymity. In his opinion, people in Govedartsi have no other means of survival apart from growing potatoes and tourism. Because of the poverty in the region, the investors can convince people that such projects are good for their village, promising investments and new jobs. “But the lack of water will kill both agriculture and tourism”, the elderly citizen of Govedartsi concluded.

Officials breaking laws

The campaigners came across a peculiar detail: the sanitary protection zone, prescribed by law, had not been created around the drinking water catchment near Govedartsi. In clear violation of the law, the state body in charge did not act to establish a sanitary protection zone near Govedartsi. This body was the state’s Danube River Basin Directorate (DRBD) based in Pleven. Practically withdrawing from its duty to apply the law, the state authority left a water source that supplies the city of Sofia and the surrounding settlements without protection, the campaigners observed. Appalled by this apparent disregard of the law by the DRBD’s Director, they addressed a complaint to Bulgarian Prime Minister Boyko Borisov.

More was to come. Despite the campaigners’ claims that the project would threaten endangered species and drinkable water sources of Bulgaria’s capital city, the DRBD issued a Surface Water Exploitation permit for the project on 19.08.2016. The permit gave a green light  for Energy Govedartsi to move forward with construction. The permit also contained a three-page justification, which defended the project and completely dismissed the objections of conservationists and local people.

The sanitary protection zone around the drinking water catchment is an entirely separate procedure that has nothing to do with the permit, DRBD insisted.  With an official letter of coordination between Sofiyska Voda and DRBD, the drinking water catchment issue has been settled. There is no evidence to back up that the water will be poisoned, the institution continued. And as for the protected areas, it is not within DRBD’s competence to establish protected areas or assess if the impact on biodiversity will be significant. It places all trust in the last resolutions of Sofia’s Regional Inspection for Environment and Water (RIEW), which denies that the impact of the project will be considerable in any way.

“We want rivers and nature, enough of hydropower plants” reads a slogan by the Govedartsi river protection campaign in front of the Ministry of Environment and Waters. Photo: Bulphoto

Left without any options, the green organisations’ members stood in protest in front of the Ministry of Environment and Waters in Sofia a few days later. The DRBD director’s approval of this project would have made it impossible to announce a sanitary protection zone in the future, the campaigners claimed. This would eventually lead to polluted water or the shutting down of the source altogether.

“We assure you that the people of Govedartsi will not be happy to hear that, as they already have problems with water”, Balkanka pointed.

The protesters were eventually let in and briefed then Deputy Minister Atanaska Nikolova. “The Permit is not final, and if there are any mistakes, the Minister of Environment and Waters, as a supreme body, can abolish or return it for additional discussions”, she assured them. Nikolova then promised that the institution would undertake massive check-ups of hydropower facilities around the country and closely look into the Govedartsi case. But ecologists weren’t satisfied and kept insisting on what they believed to be the only solution to the problem: a temporary moratorium on construction.

This spelled doom for the rivers above Govedartsi

Eventually, by the beginning of 2017 MEW cancelled the water usage permit issued by the DRBD back in 2016. But this did not prevent the municipality in Samokov from issuing a construction permit for the project, using an existing legal loophole. This spelled doom for the rivers above Govedartsi, and the campaigners were bracing for defeat.

But the unbelievable happened: the investor changed his mind and the project was put on hold. He must have “lost enthusiasm” to invest in an environmentally controversial project due to our resistance and all the legal complications, Dimitar Koumanov speculated. But there is another possible reason, voiced by energy market experts: the subsidised prices for the so called “green” energy were cancelled, and the state’s attitude to its producers hardened. No commentary or response was given by Energy Govedartsi.

A history of administrative mess and shady connections

After nearly 15 years of development, the Energy Govedartsi project has left a lot of questions and a very evident smell of an administrative mess. Contradictions to the institutional resolutions, a lot of variables in the investment proposal and continuously changing ownership are just some of the intriguing uncertainties.

For example, in 2011, RIEW Sofia issued two resolutions. One from January 14, indicating that an appropriate assessment is necessary because the area in question was within the protected zone of Rila – North (part of Rila-Bufer), clearly indicating there was a chance that the hydropower plants would have significant consequences on the surrounding nature. And the other, issued directly after the first, stated that there was no need of an AA because there was no danger of significant impact.

The reason for the contradiction: the first one had a technical mistake since, in reality, the protected zones are not yet recognised officially.

Contradictions continue with the attempt to clarify the ever-changing parameters of the project. As it is listed in Balkanka’s complaint, and also confirmed via a search on the online register, the Surface Water Catchment Permit has been changed or re-issued three times in 2007, 2008 and 2010 since first being issued in 2005 for Rila Eko Energy. In 2013, the parameters of the permit changed to allow for two buildings on one property.  In 2014, a new permit was approved yet again for two facilities with two buildings on one piece of land. Somewhere amongst this mess, the project owner changed as well, and a new license in the name of Agroinjinering 90 OOD was published. The most recent permit from 19 August, 2016 finally settled for one MHPP, with one building but three water catchments.

Amidst this whole licensing saga, it was also discovered that back in October 2008, a director of DRBD, Toshko Todorov, had in fact abolished the 2008 permit for the project altogether. This action led to his dismissal soon after, the fishermen from Balkanka believe. “What is worse, is that after Todorov was fired, this was a clear sign to those who came after him of what will happen if they don’t follow “orders“, the campaign commented. Clearly, Todorov’s successors fell in line, but, fortunately, local environmentalists owed no such allegiance and continued to stand up for the nature and well-being of their communities.

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