The Ministry of Environment and Water (MoEW) is the body responsible for formulating, implementing and monitoring the environmental protection policy in the Republic of Bulgaria. It is hardly surprising, therefore, that in many cases this Ministry turns out to be an opponent of the rest of the state institutions and authorities in its pursuance of an environmental protection policy ensuring a healthier environment for Bulgarians and ultimately leading to the so-called state of "sustainable development", a term which is a bit vague. I do not think the objectives of the other institutions in the country essentially differ from the ones of this Ministry but these institutions are simply not conscious of them or ignore them in preference to other, often much more prosaic, interests and aspirations.

What does the MoEW do to ensure the achievement of its objectives despite the unfavourable economic environment it has to work in? (By "unfavourable economic environment" I mean not only the current situation in former Yugoslavia but also, more generally speaking, the never-ending "reforms", as well as the fact that the majority of our society have not fully recognised the essential nature of the objectives defined and are not ready to actively participate in their practical achievement). How does the Ministry identify its priorities so as to be as efficient as possible when resources are limited, trained staff are inadequate and there is no support on the part of other institutions? What sort of relations does it have with the environmental protection NGOs which in many cases assist it in its activities and whose actions can sometimes turn the scales in the decision-making process?

The answers to all these questions are very important because they can offer guidance as to how actions could be improved on and how to attain better efficiency of the Ministry itself, as well as its partners, the NGOs, sometimes referred to in a prejudicial way as "enemies" and "saboteurs".

Attention needs to be drawn to the fact that under the current management team a few very ambitious steps have been taken which, if implemented successfully, could lead both to improving the state of the environment in Bulgaria and giving ground for taking technologically advanced actions, which in turn ensure certain advantages on the international and domestic markets. Amongst there attempts the Programme for Introduction of Lead-free Petrol and Changing the Automobile Profile in Bulgaria, the Air Pollution Act, the willingness to develop a Waste Management Strategy and the general tendency to solve problems strategically and not by rule of thumb, rank high. In many cases the Ministry reacts positively to signals from the NGOs, as long as they are well substantiated. Attempts have also been made to involve other institutions whose competencies and capacities in some cases surpass those of the Ministry as regards decision-making in relation to certain problems. Far from suggesting that all merits can be listed here, I believe this is anyway unnecessary in view of the self-promotion the Ministry achieves through its actions.

It is far more important to focus on the bottlenecks in the MoEW activities which blot the overall positive picture of environmental protection efforts.

1. The first and foremost point to stress is the glaring contradiction in respect of the so-called "Strategic Environmental Impact Assessment" (SEIA). In essence, the SEIA issue is provided for in Art. 20, Par. 1. Item 2 of the Environmental Protection Act (EPA) but not terminologically speaking. On the other hand, Art. 2 of the Environmental Impact Assessment (EIA) Instructions is an attempt to repeal Art. 20, Par. 1. Item 2 of the EPA. De facto, this creates confusion and some institutions (such as the Greater Sofia Municipality with regard to the Hilton Hotel issue) choose to take advantage of the situation and interpret the act as suits them best. The lack of enforcement practice in respect of SEIA leads to the fact that the National Assembly passed somewhat hastily the so-called "Strategy for Development of the Energy Production Sector until 2010" which is a slightly changed version of a similar document drafted under Zhan Videnov's government for the purpose of strengthening the extensive development of the sector, hence of the country, at the expense of privatizing of revenues from the nuclear lobby on an international and domestic scale. A similar problem is likely to arise with regard to the above mentioned Waste Management Strategy which contains some definitely anti-environmental proposals, such as construction of incinerators, the latter being one of the main sources of dioxins and furans enjoying notoriety in connection with recent bombings in former Yugoslavia. This example goes to show the lack of coordination between the individual pieces of primary and secondary legislation and consequential loopholes in the legislation. Thus, even though relevant instruments might exist, these cannot be put to use as intended. Projects not requiring mandatory EIA, where there is no control over permits issued by mayors, provide a similar example.

2. The way the National Eco Fund is approached an interesting case too. With its expected BGL 70 billions it proves to be a major instrument for support of environmental policies. However, one wonders at the lack of information as regards its activities (except for reactive, fragmentary and very very generalised one). To put it mildly, it is not proper for the MoEW to both invest in and oversee a certain activity.

3. Another contradiction is related to the fact that part of the MoWE staff are members of boards and businesses whose activity could hardly be described as "environmentally-friendly". Thus, the businesses in question enjoy special protection when they ought to be penalised for their environmentally unfriendly activities.

4. Giving way to pressures from above is a problem too and the MoEW hardly tries to cope with this and pursue the public interest. This holds true also for the closing down of the dangerous blocks 1-4 at the Kozlodui nuclear power station, the Pirdop Copper-extracting Works Environment Regeneration Project, the Luda riverbed correction and the Gorna Arda cascade. Similar reasons prevent the overseeing of permit issuing as regards sites not requiring mandatory EIA. To top it all, Environment Minister Maneva claimed at the annual meeting of NGOs in Plovdiv that it was not the right time for ratifying the Aarhus Convention (concerning access to environment-related information and the right to enforce environmental legislation) because it was better to wait for the Information Act (drafted under Mario Tagarinski) to be passed and also because some issues require complex solution. The complexity of the whole thing comes from the fact that the Convention favours citizens and imposes obligations on the administration - a situation not quite to the taste of those in power in Bulgaria since the days of the Third Bulgarian Kingdom. These and many other examples go to show that the MoEW does not take a stance true to principle but uses double standards. Thus, of its own accord, it puts itself in the position of partial isolation from its potential partners, the public and the NGOs, who are justify disappointed at the fact that "somebody at the top has yet again taken things in hand".

5. The refusal to give some preferences to businesses offering environmentally friendly products, services, and know-how on the alleged grounds that "We are in a Currency Board" is another example of double standard. If the board is the root of all evil then why not dispense with it? Apparently this is not the problem because the Board requires financial discipline but does not limit the budget. The budget and state expenditure is supposed to be determined by our perception of necessity and priority. In this case, however, necessity is limited to simple "if things don't change they stay the way they are" actions. Because if the country needs administrative reform, there is no logic to it that all bureaucrats should permanently stick to their positions with no severe cuts to anyway padded staffing levels. If this is changed then there will be more opportunities to give preferences. In actual fact, it is much better not to introduce preferences but to go for the opposite strategy - impose heavy taxes (up to or over 100 %) on those who pollute the environment and dissipate resources and energy. This will almost certainly lead to their self-destruction.

All these and many other examples demonstrate a sort of inconsistency which is detrimental mostly to environmental protection and this is being done with the unqualified or tacit approval of the MoEW. Only if we are true to principle, if we finally see that only consistent efforts along the lines of environmental protection and health care, as well as utilising opportunities provided for in legislation, can lead to lasting positive results and much more benefits for Bulgaria as compared to what we have now with the current allegedly balanced approach, can we achieve the objectives as defined in programmes and strategies. The current approach, after years of implementation, will ultimately lead us to a state very different from the one in member states in the prosperous European Union which we hope to join.