Why are Radan Kanev and Yes, Bulgaria defending the monopoly of Bansko?

On Friday, a media storm erupted around a document signed by the acting Minister of Ecology (and around the Bansko resort), according to which the new Pirin Park management plan does not need an eco-assessment – just as no park management plan in Bulgaria has had one so far. An eco-assessment is done on a specific site, not on a plan. The right-wing New Republic party and the Greens in Yes, Bulgaria immediately declared themselves against this decision, demanding a precedent eco-assessment and even a revision of the entire plan. Their motives are to ensure the preservation of Pirin Park from new construction and commercial logging in 60% of the park's territory. And the real effect of their actions is simply to cement Bansko's regional monopoly on tourism in the Pirin region.

What and why do we need a management plan?

Management plans provide the regimes, norms and zones according to which natural and national parks are to be managed for a certain period of time. Their idea is to provide predictable goal-setting in park management and control over activities within it. Unfortunately, the procedures for adopting new plans are so onerous that we currently have de facto chaos in all parks – the old plans have expired, but continue to operate until the new ones can enter into force.

The most drastic situation is in Rila and Strandzha with a delay of 7 and 14 years. The old plans, for understandable reasons, are no longer adequate to the new state of the environment (for example, in Pirin, grasslands are treated, which are now forests), and the new plans prepared many years ago are outdated even before they are adopted. Ultimately, we are observing the classic failure of the command-administrative approach to management.

What is the current state of tourism in Pirin Park?

The old Pirin Park Management Plan limits tourism in the national park to two small areas – the Bansko ski area and the Dobrinishte ski area. In practice, the old plan equates tourism in the park with winter tourism – i.e. no other type of tourism is envisaged as possible. The tourist flows themselves are envisaged during the winter season – the old plan excludes the possibility of having a tourist in Pirin in the summer who simply wants to walk in the park.

It is quite logical that when only Bansko and Dobrinishte have the opportunity to organize legal tourist activity, the entire load over the last 13 years is dumped there and instead of the hotel base being far more loosely and evenly distributed throughout the region, it is "dumped" in one place. All this is well described in the motivations of the new plan, which correctly criticizes the old one for not respecting the "basic planning principle of zoning, for the dispersion of the tourist load and equality of municipalities in the development of tourist activities."

In short, the old plan gives Bansko a monopoly on tourism in the entire region. And the fact that this monopoly was signed by representatives of environmental organizations raises eyebrows.

Are the accusations against the new Pirin Park management plan true?

The accusations of Radan Kanev and the Greens are that the new management plan allowed commercial logging on 60% of the park and a development area 12 times larger than the previous one.

1. Economic logging: Economic logging in protected areas is prohibited by the Law on the Protection of Territories in Article 21, which prohibits production activities and allows maintenance activities that are necessary for the protection of the forest. On the verge of the law and reflecting the concerns of “ecologists”, the foresters developing the new plan have banned maintenance logging even on diseased trees over 200 years old. It is important to mention that each maintenance logging is carried out with a separate project and is approved separately. Also, even if the management plan boldly prohibits all logging in the park, this will have no effect, since the plan is a subordinate regulatory act and cannot contradict the PPA.
2. The “development” zone: This refers to the expanded tourist zone from about 2% to about 12%, which is in line with good practice worldwide. The new plan expands the tourist zones and breaks Bansko’s monopoly, taking into account (for better or worse) the demands of “ecologists” and explicitly prohibits the construction of ski infrastructure outside the current borders of the Bansko ski area and the Dobrinishte ski area. That is, the idea is to give the other municipalities in the region some opportunity for alternative tourism through which to compete with Bansko – walking, hiking, trekking, etc. There are also explicit prohibitions on horseback tourism, cycling, rock climbing, hang gliding, bivouacs, movement of vehicles and ATVs, movement of snowmobiles, except in strictly defined places in the management plan. The ban on ski tourism is in three places – section 4.7, section 3 point 2 and section 2, sub-point 16.13. In the expanded tourism activity, the other municipalities do have the opportunity to try placing some object (for example, a handrail for hiking along a ravine), but this object undergoes an eco-assessment, EIA, etc. And this object cannot be connected to ski tourism and many other types of tourism. That is, the new plan gives a very weak, but still some opportunity for Bansko's monopoly on tourism to be broken.
3. If everyone is a mafia: in personal conversations I also come across the argument that if everyone is a mafia, the new plan would allow for new "constructions" that are prohibited by it. And what prevents everyone from being a mafia and forbidden things from being built under the old plan? And why should we think that the other Pirin municipalities are bigger "mafiosi" than Banska Bystrica, so we should screw them over? In fact, the only indisputably established illegal constructions in our country are in Pamporovo and the reason is simple - resorts without a clear concession zone are riskier than resorts with one.

What does the protest against the new plan achieve?

1. It cements Bansko's monopoly for at least another 5 years: as absurd as it may sound, Radan Kanev and Yes, Bulgaria want to continue the old management plan, which grants Bansko a monopoly on tourism in Pirin Park. Yes, certain confusing texts in the old plan significantly complicate the replacement of old lifts with new ones and the placement of new ones within the existing ski area, but this is more of a side headache for the operator of the Bansko ski area than a real problem - with the naked eye it is clear that the ski area is bursting at the seams, even without the launch of Tsarna Mogila or the invention of a second gondola lift. And without competition from surrounding municipalities, the operator is free to significantly raise its prices and revenues.
2. It throws all planning procedures into total legal chaos: we must not forget that in addition to the procedure for Pirin Park, planning procedures are underway for almost all other parks. Since it is not required by law, this eco-assessment has not been done for any park. If for some reason the Ministry of Environment and Water returns the Pirin plan for eco-assessment, this will not be fatal for it - it will be ready in 2-3 months. But it will allow all other plans to be appealed and returned to a later stage. In a word - chaos.
3. It deals another blow to the reputation of all mountain municipalities in Bulgaria– even with all their flaws, the ski areas of Borovets, Bansko and Pamporovo are doing well. But the same cannot be said for the ambitions of many other small mountain municipalities to develop their own tourist areas, which are blocked by delayed management plans (for example, all municipalities in Rila) or repelled investors who are watching the Punic battles in the three resorts and have no incentive to enter into such a battle on bare ground anywhere. For example, the small and well-established ski area of Osogovo has been unsuccessfully looking for an investor for a decade now. Not to mention how sub-zero the interest is in small areas in the Stara Planina, which should be made entirely on greenfield land.

Why are Radan Kanev and Yes, Bulgaria defending the monopoly of Bansko?

At first glance, their actions are inexplicable. From a business perspective, the Bansko municipality and the ski area operator have a maximum interest in the old plan continuing to operate for as long as possible - although with certain obstacles in replacing old lifts with new ones, it guarantees them a monopoly in the region.

On the other hand, Nova Republika and Da, Bulgaria find themselves in the unenviable position of being small parties without financial resources with access to only 3-4 well-intentioned websites. And any such opportunity for a media bombshell and appearing on television is hard to miss, even if the path to this opportunity is littered with lies and defending the monopoly of one municipality to the detriment of dozens of others.

Another example that politicians have an incentive to only do things that will get them ratings and votes. If they don't have an electorate in the mountain municipalities, it makes sense for them to easily sacrifice them, just to get 5 minutes of television fame.

How do entrepreneurs who have invested savings and loans in investments in other municipalities feel, awaiting the adoption of the new plan, eliminating Bansko's dominant position, or simply investor interest in other parts of Bulgaria? Better not ask.

Personally, I expect all the businessmen in Bansko to send a bottle of wine to all the protesters on Monday, helping them to cement their regional monopoly for about 5 more years. And what do the protesters think they are achieving – it's all the same. The important thing is that we are alive and well.

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