How will BGN 201 million be spent on the reclamation of lands damaged by coal mines?
There is an urgent need to synchronize the regulations affecting the territorial plans for a just transition and, in particular, the texts regarding the reclamation activities of the damaged lands. The lack of transparency in the financial framework, as well as the insufficient funds, especially those that concern the funds of the operators and mainly "Mini Maritsa East", are also among the negatives reported during a discussion of the non-governmental organization "For the Earth". It is a matter of complete ambiguity and how and who exactly will spend the 201 million BGN money earmarked for reclamation. A quality project for complete reclamation is needed, is one of the conclusions.
The view of the current Department of Energy team is that the energy transition is not only underway, but happening faster than expected, and the future is low-carbon energy sources plus the construction of batteries for energy storage. In parallel with this, the decommissioning of the operating coal mines must also proceed. Given the economic challenges arising from the decommissioning of coal mines, it is necessary to synchronize their activities with the work schedule of the companies for the production of the necessary quantities of coal, plus reclamation activities, explained Deputy Minister Krasimir Nenov, who attended the discussion. According to him, at the same time, mechanisms are being sought to finance these activities, which cannot be provided by the activities of modern operators, so as to prepare the grounds for future economic activities to develop on these grounds. As he later explained to journalists, this is necessary because the price of coal is tied to the funds allocated by the concessionaire for reclamation. As it becomes clear, with the current shutdown of TPP "Maritsa East 2" and the absence of quite long years of indexation of the price of coal mined by "Mini Maritsa East", the reclamation activities of the damaged areas are indeed insufficient.
Where is the discrepancy
There is still very little information on the subject of the upcoming reclamation of the coal mine damaged terrains contained in the Territorial Just Transition Plans. This was stated in her presentation by Radostina Slavkova from "For the Earth", who compared the various official documents. Funding for the amount of BGN 2.9 billion is planned under the Just Transition Fund. The planned funds for the reclamation of disturbed areas are 10% of the total amount, that is BGN 201,232,000 for the three regions. Of these, BGN 175,884,407 for the region of Stara Zagora and over BGN 25 million for the regions of Pernik and Kyustendil.
For all three regions, a priority under the territorial plans for a just transition is the restoration of disturbed areas in compliance with the "polluter pays" principle, with European funds also provided for.
In terms of targeted reclamation activities under the Just Transition Fund, it is a matter of tens of thousands of acres of land that could be used for green areas or housing in the future. At the same time, there is talk of a photovoltaic park and storage batteries for Stara Zagora, Slavkova pointed out, commenting on the violations in the regulations and inconsistencies in the non-paper. First, the concessionaire would have to restore the disturbed land surface to its original state. In the territorial plans it is said that these reclaimed lands cannot be used for agricultural activities, that the obligations are only for the restoration of the embankments, i.e. the question is how far the concessionaire's obligations extend
However, Slavkova's claims about the restored grounds turned out to be inaccurate. According to the data of representatives of "Mini Maritsa Iztok", who were present at the discussion, at the moment the company has carried out reclamation of a field of 48 thousand decares.
"For the Earth", for their part, drew attention to the fact that the question is how the 21 million BGN will be spent for pre-project studies and eco-activities, for the development of a general plan for the EPA. We are curious how the institutions will present it. Who and how will fulfill it, said Slavkova. She also raised a question about the term "initial recovery activities".
Among the important conclusions of the non-governmental organization is that the financial support is not enough for the more seriously affected lands. In addition, reclamation plans are difficult to access, and generally there is no unified view of what reclamation is and what rehabilitation is. There is also a lack of vision of which document is the most important to lead. In general, it is not clear from the territorial plans how the reclamation will be carried out and BGN 201 million will be spent, concluded Radostina Slavkova.
The lawyer Alexander Kodjabashev, for his part, commented that the reclamation activities are hidden and non-transparent and actions are necessary according to the regulations, so that they become transparent and clear. He motivated his claim with the conclusion, based on real data, that poorly done reclamation can cause disease, pollution of water bodies, damage to property, both private and public. According to him, in all three aspects - financial, legal and technical - the main responsibility lies with the operator, and with the concessionaire - with regard to the respective tailings storage facility. What is evident at first sight is that the actions start from the Minister of Energy. However, there is a lack of clarity in all three aspects (financial, legal and technical) - amount of obligations for financial provision, how the Minister of Energy carries out the activities, he said. According to him, there are no legal grounds and administrative reasons for the lack of transparency regarding the reclamation actions.
"Mini Maritsa East" have so far recultivated 48 thousand decares
Representatives of "Mini Maritsa East", who also attended the discussion, specified that the land recultivated so far by the company is 48 thousand decares and also pointed out that there is a need to change the national framework. There is talk of turning the land into agricultural and forestry land (Regulation 26), and now there is already talk of industrial land. In the meantime, it became clear that the company has submitted a proposal for a new concession contract, on which future reclamation activities depend.
The amounts for reclamation must be in line with the price of coal. That is, all these socially oriented price determinations affect the possibility of reclamation. If the revenues are limited, it is difficult to allocate funds for reclamation, said the representative of the company Stainov. As he explained, the process is very complex and is not only about the concept of "reclamation". It is a "process of long-term sustainability of the boards", toast before the reclamation there is a long period of recovery of the terrain itself. The company is also about to launch activities to return the Ovcharitsa River to its original bed.
There is no lack of control, the representatives of "Mini Maritsa East" were also categorical. According to them, strict control is exercised over the reclamation activities carried out. After the completion of all activities, a special commission arrives to inspect the terrain, and the reclaimed land is transferred to the State Land Fund.
The "concessions" department at the Ministry of Energy also explained that there is a control mechanism. It is provided for in every concession contract, which is accompanied by contributions to a guarantee fund.
Krasimir Nenov admitted that the activities to restore the disturbed areas repeatedly exceed the sum of BGN 200 million, but that is why the concessionaire also has obligations. "The mines have been carrying out reclamation activities until now. Now a mechanism must be found that is socially acceptable. If coal production is sufficient, they will be able to set aside funds,” he said. According to him, "in the current economic situation, the goal is for the mines to maintain their viability so that reclamation and land preparation for new economic activities continue."
A quality project is needed for complete reclamation, is the definitive conclusion.