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ACCC/C/2018/161 Bulgaria

Case status: Pending.
Topics: Clear, transparent and consistent framework; Protection of environmental defenders; Access to justice.
Articles alleged: 3 (1), 3 (8); 8; 9 (1)–(5).
Articles considered by the Committee:
Articles, if any, found in non-compliance:
Summary: The communication was submitted to the Compliance Committee on 1 October 2018 by Za Zemiata, a Bulgarian NGO. The communication alleged non-compliance with articles 3 (1) and (8), 8 and 9 (1)–(5), of the Convention with respect to certain legislative amendments, court practice denying standing to challenge air quality plans and allegedly derogatory public statements made by high officials with regard to environmental NGOs.

Documents                                                                                    Status Date received or
posted by the secretariat


From the communicant 01.10.2018
Comments on preliminary admissibility From the Party concerned 05.11.2018
Letters to the Party concerned and the communicant enclosing Committee's determination of preliminary admissibility and forwarding the communication for the Party concerned's response From the secretariat 18.01.2019
Response to the communication
Annex 1: Administrative Procedure Code
From the Party concerned 17.06.2019
Additional information
Annex 1: Attachments 1-10
Annex 2: Attachments 11-15
Annex 3: Attachments 16-20
From the communicant 20.02.2020
Letters inviting Party concerned and communicant to hearing at the Committee's 81st meeting From the secretariat 31.10.2023
Email enclosing update From the Party concerned 20.11.2023
Reply to Committee’s questions of 31.10.2023
Annex 1: Extracts of legislation
Annex 2: Chronology of events of adoption of Amendment to EPA
Annex 3: Judgment no. 552 of Supreme Administrative Court, dated 24.01.2022
Annex 5: Written consents (redacted version of annex 4)
Annex 6: List of activities as environmental defender: Toma Belev
Annex 7: List of activities as environmental defender: Andrey Kovachev
Annex 8: Publication of 14.01.2018 in the online media of the Bulgarian National Television BULG and ENG
From the communicant 28.11.2023
Annex 9: Publication of 01.02.2018 in the online media of the Bulgarian National Radio BULG and ENG
Annex 10: Excerpts from judgment no. 10238, 27.07.2018
Annex 11: English translation of annex 18 to additional information dated 20.02.2020
Statements at hearing From the communicant 13.12.2023
Additional information and opening statement at hearing From the Party concerned 13.12.2023