BCC calls for quick solution to the construction of Lot 3.2 of Struma Motorway

“Construction of a 15-km tunnel through the Kresna Gorge is unsuitable, unrealistic, ecologically and economically ungrounded and we insist on an alternative crossing through the gorge.” This is pointed out in a common declaration by the Bulgarian Academy of Sciences (BAS), University of Mining and Geology (UMG), University of Architecture, Civil Engineering and Geodesy (UACEG), Bulgarian Construction Chamber (BCC), Bulgarian Branch Association Road Safety (BBARS), Bulgarian Branch Chamber Roads (BBCR), Bulgarian Association of Consulting Companies in Railway Construction (BACCRC), Bulgarian Association of Intelligent Transportation Systems (BAITS) and Association Bulgarian Forum for Transport Infrastructure (BFTI). The document was signed by Deputy Chair of BAS Corr. Member Prof. D. Sc. Nikolai Miloshev, UACEG Rector Prof. Dr. Eng. Ivan Markov, UMG Rector Prof. Dr. Lyuben Totev and the chairmen of BCC, BBARS, BBRC, BACCRC, BAITS and BFTI. This happened at a roundtable entitled: “Review of the progress in preparation of an alternative crossing of Lot 3.2 of Struma Motorway. Possible risks to the project implementation”. The forum was attended by nearly 40 participants – representatives of branch organizations, universities, ministries and other departments. Among them was Eng. Assen Antov – Executive Director of National Company Strategic Infrastructure Projects, Eng. Lazar Lazarov – Chairman of the Board of Road Infrastructure Agency, Eng. Galina Vasileva – Deputy Head of the Managing Authority of OP Transport, Assoc. Prof. Dr. Anna Ganeva – Director of the Institute of Biodiversity and Ecosystem Research at BAS, Spyros Papagrigoriou – Executive Director of ENVECO S. A. BCC was represented by Executive Director Eng. Ivan Boykov, Eng. Simeon Peshov – Honorary Chairman, Eng. Valentin Zarev, Chairman of Section “Design and Construction Supervision” at the Chamber. “We call upon responsible authorities to speed up the decision on alternative for the construction of Lot 3.2 of Struma Motorway. Every day delay in the start of activities for realization of the project puts the successful implementation of one of the most important infrastructure projects in the new programming period at real risk, and the country - at the loss of millions of EU funds,” says the declaration. The document on the construction of Lot 3.2 Blagoevgrad – Sandanski of Struma Motorway in the section of the Kresna Gorge will be sent to Deputy Prime Minister for EU Funds and Economic Policies Tomislav Donchev, Minister of Regional Development and Public Works Lilyana Pavlova, Minister of Environment and Water Ivelina Vasileva, Minister of Transport, Information Technology and Communications Ivaylo Moskovski, to the Chairman of NCSIP Eng. Assen Antov, as well as to the European Commission and the European Parliament. Letters with the declaration will receive Walter Deffaa, DG Regional Policy EC, Daniel Calleja, DG Environment EC, Corina Cretu, European Commissioner for Regional Policy, Karmenu Vella, European Commissioner for Environment, Giovanni La Via, Chair of the Committee on the Environment to EP and Iskra Mihaylova, Chair of the Committee on Regional Development to EP. “I thank the Chamber, which in the last almost two years was very actively involved in the process of preparation for the project for Lot 3.2. In December last year we had to defend what we do to the Standing Committee of the Bern Convention. NGOs have asked the Convention to support the construction of a long tunnel. Project file however was not opened. The arguments of reason prevailed,” said Eng. Antov. “My belief is that even if we build a long tunnel, it will not last its operational years. In this region with its seismic and geology ill success will happen. Finally, it will turn out that after a certain period of its construction we have to go back to the old track, but in the current variant, and then we have to think how to expand it,” said during the discussion Corr. Member Prof. D.Sc.Nikolai Miloshev. BBA Road Safety was one of the initiators a few years ago to raise the topic of the long tunnel – this absurdity. The association unreservedly supports the declaration. We hope eventually to choose the alternative,” said Dr. Nikolay Ivanov. “I support the declaration, especially the part that refers to underground water. I want to draw attention to the fact that the tunnel is a large drainage, which will reduce the water levels in it. It will be reflected least in the higher parts and most – in the low parts, in the valleys where humidification is higher, the path of water from the surface to the tunnel is shorter and these areas are highly permeable and are connected with faults,” said Prof. Dr. Alexey Benderev. During the meeting Spyros Papagrigoriou, Executive Director of ENVECO S. A., presented the results of an environmental assessment of the proposed variants of Lot 3.2, the report on which is over 900 pages. “I want to express my satisfaction from what I heard. So much time spent in recent years as expertise, commitment to different institutions, I am sure that such an important issue will be successfully resolved and we will reach an intelligent, sensible and workable solution for this facility. In this sense, the Institute of Biodiversity will assist within its competence with any questions about the project,” said Assoc. Prof. Dr. Anna Ganeva. After the roundtable the position of the scientific and expert community was introduced to the media at a press conference in BTA. Spyros Papagrigoriou, Executive Director of ENVECO S. A.: My opinion as an expert is that the alternative is the right environmentally friendly choice Mr. Papagrigoriou, what are the advantages of the option of passing Struma Motorway through the Kresna Gorge with short tunnels and viaducts? In the alternative we will avoid unsafety of the tunnel. It refers to seismicity of the region, hydrology, radioactivity and the need to be disposed of 8 million cubic meters of rock while the decision of short tunnels and viaducts uses largely the existing infrastructure. This from an environmental perspective is a serious advantage or in the alternative we can minimize unsafety. A very important advantage is the time for construction. Construction of a long tunnel can take twice as long for implementation as the alternative. This is the needed period for construction of a long tunnel without considering all risks that can increase the time to build the facility. When we started work, the studies on the tunnel were not enough to fully calculate what will be the effect of it. For example, it was not identified what would be the impact of all emergency exits and the roads that will be needed during construction. So we made a very detailed analysis and gave a number of suggestions. My opinion as an expert is that the alternative is the right choice, provided that the recommendations of our report are taken. What should be the next steps concerning the choice of a project for Lot 3.2? The first important step is to complete the assessment of environmental impact and that of compatibility with European directives. Then they should be presented to all interested parties – government, society, environmental organizations and scientific institutions. We are ready to participate in this process, if we are asked for help. DECLARATION by Bulgarian Academy of Sciences, University of Mining and Geology, University of Architecture, Civil Engineering and Geodesy, Construction Chamber in Bulgaria Bulgarian Branch Association “Road Safety” Bulgarian Branch Chamber “Roads” Association of Road Engineers and Consultants Bulgarian Association Intelligent Transport Systems Association “Bulgarian Forum for Transport Infrastructure” At the initiative of the Bulgarian Branch Association “Road Safety” (BBAPB), the Bulgarian Branch Chamber “Roads” (BBKP), the Association of Road Еngineers and Consultants (SPIK), the Bulgarian Association Intelligent Transport Systems (BAITS), the Construction Chamber in Bulgaria (BCC), and Department “Roads” at the Faculty of Transportation Engineering at the University of Architecture, Civil Engineering and Geodesy, on 03.02.2016 a discussion forum entitled “Review of the Progress of the Preparation of an Alternative for the Passing of Lot 3.2 of “Struma” Motorway. Possible Risks to the Realization of the Project” was held. At the forum all participants categorically confirmed the position expressed back in March 2014 that the decision taken to pass through the gorge with a “Long tunnel” is inadequately studied, considered and analyzed. We consider that the construction of a 15 km long tunnel through the Kresna Gorge is impractical, unrealistic, environmentally and economically unjustified and we insist on an alternative variant for passing in the section through the gorge. We remind that for the purpose of better expert awareness of state institutions on the issue of the implementation of “Struma” motorway in the area of Kresna Gorge, BCC has organized various events, meetings and forums. We have invited prominent international and Bulgarian scientists and experts for a thorough and detailed study of the proposed options, in all aspects. We have held international scientific conferences, which clearly outline the inadequately researched and considered engineering and geological, tectonic, seismic and environmental conditions in the construction of the “Long tunnel” option. Additional geological, hydrological, seismic, tectonic studies, analysis and evaluation of natural radioactive elements in the region of Kresna Gorge have been performed by renowned scientists. We have conducted an expert council, discussion forums and other events with the participation of representatives of the Bulgarian Academy of Sciences, the University of Architecture, Civil Engineering and Geodesy, the University of Mining and Geology, BBKP, BBAPB, SPIK, proven experts and scientists from Bulgaria and abroad. The participants have concluded unanimously that the Environmental Impact Assessment (EIA) adopted in 2008 on the basis of which a decision for choosing the “long tunnel” option was adopted is based on incomplete, inadequately studied conditions and the conclusions drawn are premature and incorrect. No geological, hydrological and seismological studies have been carried out. No analysis has been performed of natural radioactive elements of the massifs, despite that it is well known that in the vicinity of the gorge there is an uranium deposit and increased concentrations of radionuclides. A number of significant factors affecting the environment have not been taken into consideration, such as: building and maintaining in good operational condition of the temporary roads needed for the construction, which will become permanent after that, to serve as emergency road connections in the operation of the tunnel; the problem of the disposal and storage of huge amounts of rock masses with elevated radiation levels has not been studied; the problem related to the work of builders in areas with significantly increased radiation has not been analyzed; the draining and drying of large massifs, located above the route of the tunnel and many other factors have not been accounted for which are obvious omissions. With the propose of thorough examination of the proposed options, the preparation of an environmental assessment was assigned to a foreign, highly qualified, internationally recognized and independent company – “ENVECO” Greece. Its conclusions have proven completely categorically, in a scientific manner the disadvantages from an environmental perspective of the “long tunnel” option compared to other alternatives. In its report, the experts of “ENVECO”, considering all possible factors of environmental impact categorically state that when in the alternative option the necessary measures for the protection of the flora and the fauna in the region are implemented, this option achieves a better overall assessment for environmental friendliness, compared to the decision for the construction of a long tunnel. In summary, the main conclusions drawn regarding the construction of a “Long tunnel”, established by the completed additional research and studies are as follows: l The area of the Kresna Gorge is located in one of the most seismically active areas of this part of the Balkan Peninsula. The occurrence of some of the most powerful seismic events in Europe and the Balkans is related to it. On April 4th, 1904 two strong earthquakes were registered within an interval of 23 minutes with magnitudes 7.1 and 7.8, The most significant surface deformations and destructions were established in the Simitli graben and in Kresna Gorge. During the earthquake ruptures in the earth’s surface were formed with an amplitude of more than 3m. The tunnel projected for construction crosses the main active structures that have generated these earthquakes; l A complex and extremely diverse geological structure with very low levels of the RMR (rock mass rating - evaluation of rock masses) classification indicator which means that the main part of the route will have to be constructed under extremely difficult conditions for construction. The route of the tunnel will cross many fault zones, some of which are active. This indicates a high degree of anticipation of sudden detachment of unstable boulders during construction or operation of the facility. Under these conditions the time for the construction of long tunnel cannot be determined exactly. Normally, construction under such conditions is very time consuming, and in this case it can reach ten years or more; l Elevated radiation established in the specific activity of natural radio-nuclides, which are two to three times higher than the background ones. Excavation work in these rock massifs must be performed under strict measures for working in areas with increased radioactive backgrounds that will put at risk the health and lives of the builders; l The excavated rock, which in broken form has a volume of about 8 million cubic meters, will occupy huge spaces for its storage. Such landfills have not been defined. At the same time the presence of elevated radioactivity requires such materials to be stored and kept under special conditions - the territory is to be drained and the effluents are to be specially purified, the rock materials should be backfilled with additional clean land mass; l During the construction of the tunnel the rock formations will be drained and in this way large areas will be drained. They will create environmental problems with the deforestation of vast territories. l Drainage waters will have increased radioactivity and special cleaning facilities are to be provided for their runoff; l The long tunnel poses a great risk with regard to its security. Such a facility has a high risk of terrorist attacks. At the same time, in long tunnels a buildup of grease particles from the exhaust of motor vehicles occurs, which create a film on the asphalt and in combination with dust they abruptly deteriorate tyre grip with the road. Sliding occurs and this hampers the stopping and driving of motor vehicle travelling in it. (An especially illustrative example of this is the road accident which occurred recently in the Vitinya tunnel); l Extremely high operating costs required for its maintenance and for ensuring the safe passage of a large number of motor vehicles. The Bulgarian motor vehicle fleet is composed mainly of older vehicles, many of which are not in a very good condition and their breakdown in such a tunnel will lead to a large number of killed and injured people. The analyses have shown that:  The construction of a long tunnel is technically risky; it is inappropriate and unacceptable for realization due to engineering and geological, seismic, economic and environmental uncertainties;  The alternatives of a road on both sides of the gorge are inapplicable. They have been already considered and rejected, according to the ecological and multi-criteria analyses carried out. We appreciate positively the actions of the government and the National Company for Strategic Infrastructure Projects in developing a conceptual design for an alternative route. We find that the technical solution in the project is a modern, high-tech one, using different technical methods for compliance with the natural resources and preservation of the ecological ones. Two short tunnels and flyovers are projected for the passage on two levels in areas located in protected zones. All bridge facilities will step into the river only in the vicinity of the existing pillars of the old bridges, and even a bridge with openings exceeding 70 meters is projected. The necessary nature friendly bank consolidation of the river will be carried out in order to avoid flooding of areas and territories with special habitats. The escarpments endangered by collapsing will be stabilized with special high-strength wire netting. In this way the erosive processes of rocks will be stopped, without interfering with biodiversity. A number of measures are envisaged for the least possible interference in nature and conservation of biodiversity. A report on the assessment of environmental impacts (EIA) is in a process of preparation. In this way the efforts for finding an alternative to the tunnel option is carried out in strict compliance with all norms of European legislation for working in areas with particularly rich biological development. In view of the complexity of the route and the deadline for the implementation of the project - by 2020, according to the programming period 2014-2020, we address the responsible institutions: 1. We consider that the construction of a 15 km long tunnel through the Kresna Gorge is impractical, unrealistic, environmentally and economically unjustified and we do not support the further examination of this possibility of passage. 2. We appeal that the responsible institutions accelerate the adoption of a decision for an option for the construction of Lot 3.2 of “Struma” highway. Every day of delay in the start of activities for the realization of the site puts the successful implementation of one of the most important infrastructure projects in the new programming period, in front of a real risk, and our country in front of the loss of millions of euro of European funds. 3. We propose that the responsible institutions initiate, as early as in the month of February, a wide discussion on the issue which should include representatives of branch organizations, the non-government sector, and representatives of the scientific community. 4. We propose that the development of the report on EIA of the alternative route takes into consideration the environment protection recommendations, prepared by ENVEKO and the ones of the Institute of Biodiversity and Ecosystem Research of the Bulgarian Academy of Sciences. At the same time we do not accept the actions of some NGOs which, with the aim of passing lobbyist interests, seek all sorts of ways to sabotage the efforts to find the best solution for this transport corridor which is very important for Bulgaria and Europe. The tunnel will neither save any human lives, nor nature. It is necessary, with the inclusion of a greater scientific, technical and creative potential, to accept responsibly as soon as possible the alternative route according to the prepared new conceptual design. Bulgarian Academy of Sciences Corresponding member, Prof.Dr. Nikolay Miloshev, Vice President of BAS University of Mining and Geology Prof. Dr. Lyuben Totev, Rector of UMG University of Architecture, Civil Engineering and Geodesy Prof. Dr.Eng. Ivan Markov, Rector of UACG Construction Chamber in Bulgaria (CCB) Eng. Svetoslav Glosov, President of CCB Bulgarian Branch Assocation “Road Safety” (BBAPB) Dr. Nikolay Ivanov, President of BBAPB Bulgarian Branch Chamber “Roads” (BBKP) Eng. Pavel Dikovski, President of BBKP Association of Road Engineers and Consultants (SPIK) Eng. Todor Todorov, Executive Director of SPIK Bulgarian Association Intelligent Transport Systems Eng. Rumen Mihaylov, President of BAITS Association “Bulgarian Forum for Transport Infrastructure” (BFTI) Prof.Dr.Mitko Dimitrov – Vice President of the Managing Board of BFTI 03.02.2016 Sofia