Skopje Bypass Project The Complete Case
Transcription
Skopje Bypass Project The Complete Case
Civil Society Skopje, Macedonia Skopje Bypass Project The Complete Case By Ana Colovic, Eco-sense April, 2003 Ana Colovic, Eco-sense Contents: The Skopje Bypass Project- The Complete Case April 2003 Page No. 1. Introduction ............................................................................................................................ 2 2. Environmental Impact Assessment (EIA) Study ................................ 3 A. Summary of the EIA Study ............................................................................................ 3 a) b) c) d) e) f) g) h) i) Impact on Climate ............................................................................................................ 3 Air Pollutant Impacts ..................................................................................................... 3 Water Pollution Impacts ............................................................................................... 4 Noise Impacts ..................................................................................................................... 5 Impacts on Soils and Erosion .................................................................................. 5 Impacts on Flora & Fauna ........................................................................................... 6 Landscape Infringement .............................................................................................. 6 Socio-economics.............................................................................................................. 6 Cultural & Historic Heritage ....................................................................................... 7 B. Unaddressed issues........................................................................................................... 7 3. Problems ................................................................................................................................... 8 a) b) c) d) Danger to the water reservoir ................................................................................... 8 Disturbance of the church and destruction of the local graveyard... 8 Destruction of agricultural land .............................................................................. 8 Lack of public participation ....................................................................................... 8 4. Independent Review.....................................................................................................10 a) b) c) d) e) f) The case of the former route (1999) - Novo Selo route ...........................10 The case of the current route (2001) - Volkovo route ..............................10 Comparison between the former and the current routes ......................11 The Objector’s route (2002) ....................................................................................11 Findings and recommendations ...........................................................................12 Maps and sketches .......................................................................................................13 5. Environmental Management Plan ...................................................................14 6. Least-cost analyses .....................................................................................................14 7. Conclusions and suggestions to Government and EBRD .....15 8. Annexes ...................................................................................................................................16 This publication was made possible through financial support from the CEE Bankwatch Network 1 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 1. Introduction The Skopje Bypass is a planned 25-km highway ring around Skopje, the capital of Macedonia. The state-owned company, Fund for National and Regional Roads of Macedonia ('Project Sponsor'), has requested a EUR 25 million loan from the European Bank for Reconstruction and Development (EBRD) for the construction of the Section 2 of the Skopje Bypass. Two key pan-European transport corridors (Corridor VIII and Corridor X) cross the country of Macedonia and intersect at Skopje, forming part of the Trans-European Network. The Skopje Bypass is a part of Corridor VIII. The Skopje Bypass has been proposed for more than 30 years. It was first introduced during preparations of the Skopje Basic Urban Plan in 1965, and in 1985 the need for the bypass was confirmed by additional amendments to the Plan. The first proposed route for the bypass would have started at the “Hippodrome” loop. Here it was to branch off from the Veles-Skopje highway, continue north of Skopje mainly through flat terrain before reaching Suto Orizari, then descend southwards and pass near the village of Novo Selo before connecting with the Skopje-Tetovo highway near Saraj. (See ANNEX 1. Map of the alignments). The section from Hippodrome to Suto Orizari is named Section 1, and the Suto Orizari-Saraj section is Section 2. When they learned that a bypass road was to be built nearby, the villagers of Novo Selo protested and demanded a change in the alignment of Section 2. The section was altered and shifted northward. This new route now starts at Suto Orizari before leading westward, passing Konjski Rid, and crossing Stenkovec loop and the Lepenec River. Then it bends slightly northwards, runs through agricultural land, and passes the residential area of Volkovo. The road continues south through hilly landscape, finally reaching the Saraj point, where it connects to the Skopje-Tetovo highway (see ANNEX 1. Map of the alignments). At the moment, local residents are asking for a change of that part of the route that would negatively affect the lives of the people living in the villages of Volkovo and Orman. This part of the road will negatively affect the community's economic, social and environmental health. This publication has been prepared to illustrate the struggle of the villagers of Volkovo and Orman (both villages would be affected by the construction of the road) to change the currently proposed route so that it will not affect their lives, their environment, their villages' valuable sites and buildings, and the area's future in general. The publication includes related documents and illustrations in order to better present the past and present situation as well as to provide constructive development and suggestions for the case. This publication was made possible through financial support from the CEE Bankwatch Network 2 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 2. Environmental Impact Assessment Study The Environmental Impact Assessment (EIA) Study was prepared for the Section 2 of the road and released on the January 25, 2002. The Fund for National and Regional Roads of Macedonia hired the foreign company Lahmeyer International to conduct the study. Regretfully, the experts from the Macedonian Ministry for Environment and Physical Planning were not included in the process of conducting the study. The primary environmental impacts associated with the construction of the highway were related to: y Air emissions, water pollution and traffic noise y Disposal of construction material y Erosion y Flora & Fauna y Landscape infringement A. Summary of the EIA Study The Summary of the EIA Study in this publication will be presented only by the Environmental Impact Assessment of primary environmental issues. This part of the Summary has been included here without change. The complete Summary can be found both in Macedonian and English language on the EBRD web page. At the end of this part of the Summary, we have presented a list of unaddressed issues by the EIA. a) Impact on Climate Effects of the new highway on climate can influence the local wind streams and microclimate by barriers and changes of surface characteristics. Given the design of the alignment, no significant barrier is planned which could affect the wind streams significantly. The installation of noise prevention walls, embankments, cuts and the highway itself will only have minor effects on the local climate. Another impact on climate is the emission of carbon dioxide (CO2) by the combustion of fuels. In general, fuel consumption by vehicles will be reduced in the future by improvement of vehicle technologies. The shift of traffic load from downtown Skopje to the highway, with its more advantageous flow of traffic, will reduce total CO2 emissions of this traffic by approximately 30 % (5,000 - 7,000 tons per year). b) Air Pollutant Impacts Vehicle traffic is a source of air pollutants which are emitted from the engines’ exhausts. Emissions and impact of relevant air pollutants (carbon monoxide, sulphur dioxide, nitrogen oxides, lead, soot, carbon hydroxides, and benzene) were calculated, taking into consideration type of vehicles, fuels and engines as well as road characteristics such as inclinations. Two scenarios were examined each considering the forecasted higher traffic This publication was made possible through financial support from the CEE Bankwatch Network 3 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 figures, but different levels of engine technology (Scenario A: low profile with leaded fuel; Scenario B: modern technology). According to the results, the amount of pollutants emitted will significantly decrease from Scenario A to Scenario B by at least 70 %. Based on an estimation of traffic related emissions, the pollutant concentration in the neighbourhood of the alignment was calculated considering average wind speed and the planned noise protection walls. The results show that the highest concentration will be found at the centre of the intersection Loop Stenkovec. Other high concentrations are expected within narrow bands alongside the inclining segments of the bypass. Concentration levels of the various pollutants decrease by at least 60 % from the road border to a distance of 200 m. The concentration of the pollutants generated by the bypass traffic was discussed with respect to air quality standards specified in Macedonian, European, and German legislation. All of the applicable standards will be met by the traffic generated impact concentrations. In addition to the traffic-related impact, background concentrations from other sources should be taken into consideration for evaluation of the future ambient air quality. It is assumed that, due to the rural character of the area, the background concentrations are most likely below 50 % of the air quality standards. The traffic related impact was, therefore, discussed with respect to a value of 50 % of the respective air quality standards. With the exception of NO2, even the maximum calculated concentration of the pollutants discussed is below the 50 % threshold level. For NO2, only a narrow band of 30 m maximum breadth exceeds this threshold at the segments with steep inclination and at the intersection Loop Stenkovec. No sensitive environmental factor is affected in these areas. In summary, no significantly adverse effect on the environment is to be expected from air pollutant emissions on the new alignment. c) Water Pollution Impacts During the construction phase, care must be taken to avoid any pollution by oils and lubricants of ground and surface waters. The release of these substances can have serious impacts on the water quality of both the surface and groundwater, and can severely effect aquatic fauna and flora. Driving in the river should be avoided. During construction no dams or similar facilities to provide access to the construction site should be erected. Conflicts during the operation phase could be caused by water pollution. Oil, tyre abrasion, solid particles and salt or other de-icing agents in winter can be discharged with the surface run-off into the river. Polluted surface run-off from the bridge should be prevented from discharging into the river. The danger of water pollution due to traffic accidents is high. Therefore a high safety standard must be applied. Additionally, extra robust crash barriers should be installed to avoid pollution of the river in case of accidents. The crossing of the river will result at least partly in a loss of riparian vegetation. The bridge is not expected to be a migration barrier. The impact on the banks will decrease the importance of the banks as a habitat. General impacts on the groundwater during the construction phase will be the lowering of the groundwater table if it is close to the surface. Based on the detailed design and the need for groundwater lowering, the impacts shall be assessed. The impacts will be limited in time and space. It is anticipated, that disturbances of the hydrological regime will be limited by extension and appear predominantly during the construction phase. In general, the impacts on surface water and groundwater by traffic-related substances are This publication was made possible through financial support from the CEE Bankwatch Network 4 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 considered minor. It is assumed that construction and operating will not have any significant effect on surface water and groundwater hydrology and quality, if proper management is applied. Nevertheless, if any temporary or permanent lowering of the groundwater table is needed or will occur, a specific assessment will be required. d) Noise Impacts The noise generated by vehicle traffic on the highway will affect the settlements located alongside the planned bypass. For evaluation of noise impact and determination of suitable noise abatement measures, calculations of noise levels were carried out. The calculated noise levels were evaluated with respect to noise standard regulations of Macedonia, the WHO and countries of the European Community. The applied noise standards for existing residential areas were 60 dB(A) at daytime and 50 dB(A) at nighttime. 55 dB(A) at daytime and 45 dB(A) at nighttime should be kept in future residential areas. Sensitive buildings, such as schoolhouses, were discussed separately. The results of the calculations, without any noise prevention measures reveal high impacts with outdoor levels exceeding 65 dB(A) at night time for few buildings located close to the highway Northeast of Vucidol. Residential areas in Vucidol, Kondovo and Dorce Petrov are affected by noise levels exceeding 45 dB(A) at nighttime. This reveals the need for implementation of noise abatement measures. Effects of various mitigation measure alternatives were calculated. Installation of noise prevention walls, i.e. 4 m height was found to be the most efficient mitigation measures. The total size of residential area impacted by noise levels exceeding the limit of 50 dB(A), can be reduced by the recommended noise prevention walls by approximately 65 %; for the 45 dB(A) limit the area size reduction will be 45 %. By shifting the traffic from the city of Skopje to the bypass, an advantageous reduction of traffic noise in the city can be expected. Noise reduction was estimated to be up to 2 dB(A). During the construction phase noise reduction should be considered and noise intensive works should be executed only during daytime. e) Impacts on Soils and Erosion In general, soils are mainly affected through cut and fill operations. The construction will result in a sealing of natural soils of about 0.25 km2. Operation of the Bypass will not have significant impacts on soils if proper protection measures will be applied. Special care must be taken to avoid soil and groundwater contamination by spill of hazardous substances, especially for those areas with a high water table and absence of protective layers. Inadequate protection of cut and fill areas may result in soil erosion. The Technical Design already considers appropriate protection measures for slope stability. Further supporting measures such as retention walls or sheet piling for sensitive sections of the road alignment should be considered. Special care should be taken for construction of drainages at those cut sections where permanent water seepage appears after construction. It is proposed to re-use the topsoil as far as possible based on the best available technology. Prior to construction, the fertile topsoil layer should be carefully removed. Soils adjacent to the construction sites must be protected against compaction by construction machines. After finalisation of construction works the fertile soil should be placed on the slopes. After replacement of the soils, protection measures against soil erosion are needed. This publication was made possible through financial support from the CEE Bankwatch Network 5 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 f) Impacts on Flora & Fauna Eutrophication and altering of plant communities by air pollution is a mainly problem within a 10-metre buffer along the road. Soil pollution with heavy metals or organic pollutants is normally limited to the direct vicinity of the road. No nature reserves or other protected areas are occurring in the investigation corridor. An impact during the construction phase is the nuisance of breeding birds by the construction machines due to exhaust fumes, noise and visual irritations. Noise, air pollution and visual irritation caused by the traffic can decrease the value of bird habitats in a radius of several 100 metres. The consequence will be a significantly decreased density of breeding birds. The birds are also endangered by traffic, especially in sections with hedges close to the road. The four-lane bypass will affect the migration of animals (e.g. birds, amphibians, reptiles and flying insects) significantly. The planned high wire fences are protecting animals against car collisions on the one side; on the other side are also increasing the barrier effect. The barrier effect of the fences will be relatively high in areas without underpassing (animal culverts) or overpassing (greenbridge) possibilities (in the eastern area of investigation and partly in the western area). The planned illumination of the alignment has an adverse impact on night active insects because they are strongly attracted to the light. It is therefore highly recommended not to implement illumination. The migration possibilities for animals will be secured by the construction of culverts under the road body. An improvement of the living conditions of animals and plants can be achieved by the development of further habitat structures like dry pastures, hedges, subMediterranean forests and wetland biotopes. To avoid unnecessary additional loss of biotopes the construction site should be limited to the minimum area needed for the road works. The dumping of material should be handled only within the construction site. The removed biotope structures at the construction site should be restored after finalisation of the road works. The removal of shrubs and trees should be done outside the bird’s breeding period. g) Landscape Infringement During construction and due to the infrastructure itself, the landscape will be changed. Additional areas will be required for implementing the construction sites and for temporary dumping of excavated material, what declines the scenery’s value. During the construction phase significant impacts on the recreation function of the landscape may occur due to noise emission and general disturbance, e.g. the presence of construction vehicles. The alignment through hilly terrain with its land-cuts, bridges and embankments leads to a significant change of the scenery. The slope- and deep land-cuts increase the exploitation of area. Additional areas for dumping sites of excess soil and debris masses are needed. The visual impact of the construction should be minimised. This can be done best by means of planting. h) Socio-economics The bypass will cut off existing interconnections between the South and the North. Crossing of the highway for local traffic, pedestrians and bike riders will be possible using several overpasses and underpasses which will reduce the separating effect of the road. The construction of the new highway will not affect any known material assets in the investigation area. This publication was made possible through financial support from the CEE Bankwatch Network 6 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 i) Cultural & Historic Heritage An archaeological reconnaissance survey of the terrain should be carried out according to the request of the Institute for Protection of the Cultural Monuments of the City of Skopje (IPCM). However, no cultural heritage sites or features are so far known to be present in the area of the alignment. The execution of the excavation works should be carried out carefully and under the constant supervision of an archaeologist. B. Unaddressed issues The Environmental Impact Assessment failed to conduct a proper assessment and to propose mitigation measures for the following issues: • Water reservoir in Volkovo • Churches of St. Atanasij and St Paraskeva in Volkovo • Graveyard in Volkovo • Expropriation of the private agricultural land The Study also showed that one particular region near the proposed road is a special aquifer zone, rich in biodiversity and fertile soils (see ANNEX 2 Flora and fauna in the region of Volkovo). This region is inhabited by farmers settled in two villages (Volkovo and Orman). As a result of the lack of assessment of the above mentioned issues, the preparation and planning of the Skopje Bypass Project created significant problems for the local communities. This publication was made possible through financial support from the CEE Bankwatch Network 7 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 3. Problems with the Skopje Bypass project a) Danger to the water reservoir This reservoir (containing 6000 m3 of water) is of high importance for the local population as it holds the drinking water for over 15 000 people. The proposed route of the bypass is located less than 20 meters from the reservoir. There is a high risk of pollution or damage to the reservoir during construction or operation of the road. This reservoir was constructed with the donations of local people from the Volkovo and Orman village and is the private property of the community. b) Disturbance of the church and destruction of the local graveyard The Orthodox Church of St. Atanasij and its cemetery are located less than 10 meters from the proposed route of the bypass (see ANNEX 3 Location of church and graveyard). The church is regularly visited by the local people and is the only church in the area performing all of the community's religious services. Nearby is the Church of St. Paraskeva. Both churches were built on holy ground, on the top of the remains of more ancient churches. If the Bypass is built next to these houses of worship, their value to the community would be threatened by the substantial noise and pollution that would surely occur. The proposed route would also cross a part of the local graveyard, located next to the Church of St. Atanasij. This land is the only one used for burials and its location is such that any future expansion would have to be in the direction of the road. Constructing an overpass over the graveyard (as planned) is completely unacceptable for the local people. c) Destruction of agricultural land The planned route will destroy first class agricultural land used by local farmers for the production of different food products. The farmers financially support themselves and their families by supplying the citizens of Skopje with healthy and high-quality food products. If their land is taken in order to building the bypass, the farmers would lose any chance to grow and expand their production, and the city of Skopje would be denied significant products. From the total amount of land that would be used for the construction of the road, 40% consists of first class land and 28% of other agricultural land (see ANNEX 4 Land use). d) Lack of public participation Macedonian environmental legislation does not yet contain any regulations devoted to the preparation of environmental impact assessments, or accessibility to and public participation in their preparation. For this reason, any EBRD involvement should depend on the adherence to EBRD Environmental Procedures during the project's preparatory stage. Locally affected people were not invited to the scoping process meeting held on December 8, 2000, nor were they consulted during on-site measuring and research. Residents received no written response from the Project Sponsor regarding their written request for a route change (April, 2001, see ANNEX 5 Letter to the Road Fund). The Project Sponsor did not make the EIA report available in the communities of Volkovo or Orman. This publication was made possible through financial support from the CEE Bankwatch Network 8 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 Local NGOs asked the Project Sponsor to make sure public hearings would be well advertised in the local and national media (TV, radio and newspapers) in order to ensure good public participation. The NGOs requested a meeting between the Project Sponsor and interested groups prior to the public hearing in order to inform the NGOs about the process of the public hearing, which was taking place for the first time in Macedonia. The NGOs also requested an independent facilitator. However, the Project Sponsor failed to meet any of these demands (see ANNEX 6 Letter from NGO). The public hearing itself was held on a working day during working hours in spite of a request to change the time of the meeting. Many people could not participate because of their working duties. During the consultations, the representatives of the Fund for National and Regional Roads of Macedonia showed complete disrespect towards the proposals made by local communities and NGOs. This publication was made possible through financial support from the CEE Bankwatch Network 9 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 4. Independent Review After the local residents contacted the EBRD and explained the problems that they were facing, in July 2002 the Bank decided to hire an independent consultant, Chris Holland, to review the route and propose solutions to the above-mentioned problems. The results of his research are summarised below. a) The case of the former route (1999) - Novo Selo route The consultant reviewed the bypass' former proposed route, which was to pass nearer to the city of Skopje, through the village of Novo Selo. He studied the route and objections to it and found little documentation supporting the drastic change in route that occurred. b) The case of the current route (2001) - Volkovo route The consultant describes the development of the new route, its details and the reasons for the local residents' objections. A history of the route is included too. Concerning the objections for the current route, the consultant considers the various objections raised by the local population from Volkovo and Orman village: A. Reservoir The consultant agrees with the environmental consultants and engineers that the bypass poses no potential threat to the reservoir, and believes that there is no reason to expect the reservoir to be contaminated or in any way affected by the road. However, he proposes that more detailed plans be shown to the local community to ensure a better understanding of the distance between the road and the reservoir. Also, he recommends that the Road Fund offer written reassurances to the community that it would undertake monitoring of the reservoir during construction and for two years afterwards, and that it would fully rectify any damage that may occur during that period. B. Churches and burial ground Here the consultant gives details on the location and situation of the two churches in Volkovo and the cemetery they share. He found that the churches were not include on the engineering sketches and maps and that therefore the road was designed crossing over church property. The consultant believes that construction of the road on this location would have a highly negative impact on the area. He proposes that further investigation be carried out concerning the relocation of the road westward. He suggests that the designer work up an alignment according to his sketches and proposals: shifting the road farther away from the church, the reservoir and the far northern houses of the village, and placing the road into short tunnels, etc (see ANNEX 3 Location of church and graveyard). Even though the independent reviewer agrees that the impact on the churches would be great, he does not consider them to be important enough to reject the road altogether: This publication was made possible through financial support from the CEE Bankwatch Network 10 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 “Should the further work not lead to a design which is considered both more acceptable and within affordable limits, there could prove to be a choice between accepting the impact at the churches and not having a Bypass. In that case, my opinion is that the adverse impact, although major, is not so great to tip the scales against the bypass being built and operated. ” C. Agriculture Here, the consultant explains that there are not enough documents, policies or maps identifying category one lands. He believes that the effect on crops from pollution would be minimal and there is no cause for concern. He also states that there is no risk for workers in the fields. In general, he believes that the loss of land for the purpose of the bypass should not be a reason for changing the route, but is rather a compensation issue. D. The elementary school Concerning a school located 170 meters from the projected route, the consultant is quite satisfied with the road’s minimal impact on the school's operation (see ANNEX 7 Elementary school). He also believes that the road will not affect the children’s health nor expose the children to other risks. The concentration of the emissions is in accordance with EC 1999 guidelines for human health. E. Stopanski Dvor Stopanski Dvor is a small settlement near Volkovo and was identified by the consultant as a potential cause of concern. He believes that the settlement’s character would be affected by the proposed high sound walls, which are completely alien to the area. He classifies the impact on Stopanski Dvor as major, and one which should be reduced. He recommends further investigation to help develop a more reasonable solution. c) Comparison between the former and current routes The consultant does not rate any of impacts of the current route as severe, nor do the number of lesser impacts add up to an equivalently severe impact. He concludes that the impacts are not enough to reject the route on environmental grounds. “It certainly does not mean that the route should be accepted in this present form. More work needs to be done on possible changes. “ The former route is more expensive but more effective as a bypass. Two advantages of the current route are its cost and the fact that it no longer impacts the village of Novo Selo. In other respects, the current route is the less ideal route. In the consultant’s opinion, the greater cost of the former route would be justified by the benefits. d) The Objector’s route (2002) In general, the consultant considers the Objector’s route to be not as effective as expected because of the following reasons: - it would be significantly longer (12,9 km long, an increase of 2,4 km over the current route) This publication was made possible through financial support from the CEE Bankwatch Network 11 Ana Colovic, Eco-sense - The Skopje Bypass Project- The Complete Case April 2003 it would cost more it would have less impact on human settlements but it more impact on the natural environment it will attract less traffic and have less traffic benefits overall, it would not have sufficient environmental gains to justify the greater costs and the loss of effectiveness as a bypass. He recommends that an outline appraisal of the route be prepared and compared with the current one. e) Findings and recommendations The consultant made the following important action-demanding findings, which are listed in the report: - Seismic risks were not explicitly reported. - Data on property and impact, with reference to the houses affected and type of land taken, were not reported. - Compensation to persons whose property is expropriated will be negotiated; but no compensation will be paid to persons whose property is adversely affected by proximity to the highway. - Possibilities for ameliorating the impact on human settlements were not sufficiently investigated. - The current route has less impact on human settlements than the former route but more impact on the environment. - The former route has severe impact on human settlements at Novo Selo - It may be possible to ameliorate the impacts at Novo Selo by alignment changes not previously considered. - The objector’s route is likely to have its own adverse impacts, to be significantly more costly and to be significantly less functional as a traffic bypass. He also made a large number of recommendations for improving the further design of the road or lessening its impact on settlements: - Not all avenues for reducing environmental impact have been fully explored. More work should be done before settling on a route. The Road Fund should make a contractual agreement to protect the water reservoir. An adaptation of the alignment should be investigated near the Volkovo churches. The Road Fund should provide fencing and landscaping around the elementary school. All construction should be monitored to prevent impacts by temporary works. Improvements in detailed design should be investigated at Przini (east of Volkovo) and the possibility of moving the alignment north should be also be investigated. This publication was made possible through financial support from the CEE Bankwatch Network 12 Ana Colovic, Eco-sense - - The Skopje Bypass Project- The Complete Case April 2003 A junction with the existing M3 should be investigated as an alternative to the proposed full motorway junction. The Novo Selo route should be re-appraised (a) if the work on improving the current route is unfruitful and (b) if, as a result, there is consensus in central and local government that the difficulties with the current route cannot be sufficiently ameliorated. The consultant engineer should prepare a note showing how the costs of rock tunnelling and rock cutting are estimated. Data on land expropriation should be compiled by type of land. A statement on seismic risks for structures and earthworks should be prepared. f) Maps and sketches This report includes annexes containing maps and sketches. These include sketches showing the current route compared to the former route and objector’s route (see ANNEX 1 Map of the alternatives); a sketch of possible changes in alignment near the churches (see ANNEX 3 Location of church and graveyard); a sketch of the elementary school and the projected road (see ANNEX 7 Elementary school); and a map showing the objector’s route (see ANNEX 1 Map of the alternatives). This publication was made possible through financial support from the CEE Bankwatch Network 13 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 5. Environmental Management Plan The Environmental Mitigation Plan was prepared in March 2003 by Lahmeyer International, after the Government’s decision (February 20, 2003) to continue with the project with the last proposed route (the “Volkovo route”). The Environment Management Plan is based on the Mitigation and Compensation Measures proposed in the Environmental Impact Assessment Study (see 2. Environmental Impact Assessment Study). Compliance with the Environmental Management Plan is to be supervised by an Environmental Monitor who will be assigned by the EBRD. An Environmental Monitoring and Advisory Group will be established, to be chaired by the Environmental Monitor and composed of representatives of the Ministry of Transport and Communications, the Ministry of Environment and Physical Planning, the Fund for National and Regional Roads, NGOs and the communities of Volkovo and Orman. The Plan proposes a number of mitigation measures. It also includes some new measures that were prepared after the independent review: a new footpath to replace the severed Volkovo-Nikistane track; additional landscaping measures around the churches and graveyard at Volkovo; attractive fencing around the school; protection and supervision of the construction in Volkovo. The mitigation measure for the water reservoir in Volkovo is however, inadequate. The independent consultant proposed that “the Road Fund offers written reassurance to the community that it would undertake monitoring of the reservoir during construction and two years afterwards and that it would fully rectify any damage that may occur during that period”. However, the Plan proposes that the agreement cover only the construction phase of the project. If the villagers do not receive a guarantee that the reservoir will be protected for at least the first two years of the operation of the highway, they will continue to see the road as a threat to the water reservoir. Also, landscaping measures around the churches and graveyard would not mitigate the negative impacts of the road. 6. Least-cost analyses Document disclosure? In April 2003, the environmental organisation Eco-sense from Skopje asked the Fund for National and Regional Roads to disclose its “Least-Cost Study” (see ANNEX 8 Least-Cost Study). This was prepared by the Balkan Consulting Company and shows an estimate of the costs of the current route as well as the objector’s route (proposed by the villagers of Volkovo and Orman). The Study would have provided us with information about the estimated costs of the objectors’ route and we would have been able to propose new solutions for decreasing the costs of the route. However, the Fund replied that this study is not publicly available. When asked to put this answer in writing, no response was received. We assume that by refusing to admit officially that the Study is not publicly available, the Fund actually does not admit that it does not want to disclose the particular document. The reasons for this are so far unknown to us. This publication was made possible through financial support from the CEE Bankwatch Network 14 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 7. Conclusions and suggestions to Government and EBRD The Macedonian Government has already decided that the route of the bypass should not be changed. But receiving a loan from the EBRD to cover construction expenses is not only the Government's decision. It is also every citizen’s obligation. If Macedonia asks for this loan for the construction of this road (EUR 25 million) and the EBRD approves it, then all citizens of Macedonia will have to pay back the loan through various taxes. The citizens of Skopje therefore have a right to request an appropriate route which would minimise harm done to their lives and their environment. People have a right to visit places of worship and to peacefully pay respect to the dead. If a road threatens to put an end to this tradition and impedes their right to religion, then they have every right to demand a change. For these reasons, the Government of Macedonia should reconsider its decision. The Fund for National and Regional Roads should change the route according to the demands of the local community. The European Bank for Reconstruction and Development should support the changes of the road. The Bank should protect the villager’s right to live in a clean and prosperous environment and lead a normal, quiet life. Without these changes, the Government and EBRD should not consider the loan for the Bypass. This publication was made possible through financial support from the CEE Bankwatch Network 15 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 8. Annexes ANNEX 1. Map of the alternatives ANNEX 2. Flora and fauna in the region of Volkovo ANNEX 3. Location of church and graveyard ANNEX 4. Land use ANNEX 5. Letter to the Road Fund ANNEX 6. Letter from NGO ANNEX 7. Elementary school ANNEX 8. Least-Cost Study This publication was made possible through financial support from the CEE Bankwatch Network 16 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 ANNEX 1. Map of the alignments (Independent review, August 2002) This publication was made possible through financial support from the CEE Bankwatch Network 17 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 ANNEX 2. Flora and fauna in the region of Volkovo (Environmental Impact Assessment Study, January 2002) Picture 1. Fauna near Volkovo Legend: This publication was made possible through financial support from the CEE Bankwatch Network 18 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 Picture 2. Flora in the Volkovo region Legend: - Biotopes with regional importance - Biotopes with local importance This publication was made possible through financial support from the CEE Bankwatch Network 19 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 ANNEX 3. Location of church and graveyard (Independent review, August 2002) This publication was made possible through financial support from the CEE Bankwatch Network 20 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 ANNEX 4. Land use (Environmental Impact Assessment Study, January 2002) Legend: 1 2 3 4 5 6 7 8 9 10 11 12 Agricultural area- poor structural diversity (intensive agriculture) Agricultural area with high structural diversity Degraded pine afforestation on lake shores and rivers Vineyard Dry pastures Construction site River Riparian vegetation Gravelly fluvial plain Reed with dry pastures and succession of sub-mediterranean low forest Housing areas Pine afforestation This publication was made possible through financial support from the CEE Bankwatch Network 21 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 ANNEX 5. Letter to the Road Fund Letter to the Fund for National and Regional Roads and Ministry of Transport and Connections To: The Fund for National and Regional Roads, Ministry for Transport and Communications of Republic of Macedonia, Skopje On March 12, 2001, we had a meeting with you concerning the construction of the highway which is to pass close to our villages, Volkovo and Orman, and we regret to say that we did not find that you understood our concerns on this matter. We agreed to re-investigate the whole situation and let you know the results via letter. We are sorry for the delay in submitting our information, but we had problems accessing it because of the political situation in the country. The two communities (Volkovo and Orman) held a meeting on March 29, 2001with the intention of discussing the construction of the highway. At the meeting, citizens were informed about the planned route of the highway and about our meeting with you. From the discussion at the meeting, the citizens made a decision -- to stop the planned construction because of the following reasons: y Political /economic reasons: the political reason would be the division of the two communities (Volkovo from Orman) and the economic reason is that the route is planned to pass through fertile, first-class soil which represents the only source of existence for the majority of the people living in the region. y Social reasons: the route passes close to the one and only local cemetery and after construction of the highway, there will be very little land left for burial use. y The most important issue is that the route passes close to a water reservoir which contains drinking water (the construction of this reservoir was funded by citizens’ donations). There is a high risk of damage to this reservoir as a result of the construction of the highway and also a danger of pollution from exhaust fumes from the highway. We are therefore suggesting shifting the route to state-owned land in the following way: the route should cross over the village of Orman, the hill of Krastavec, Tupance, over the Church "Cetirieset Macenici," over the Church "Sveti Atanasie," in the direction of the Monastery of Mala Bogorodica and towards Svilare. If this is done, the endangered objects mentioned above would not be harmed because of the new location of the route. At the meeting of the two communities, an Initiative Board was elected, containing ten members (five from each community). Your further communication should be with the members of this Board. We are hereby demanding from you that after accepting this letter, you should not send any more of the geometry research crew to the sites. You can contact the following persons from the Board: Ljube Todorovski from Orman (306022) and Ljube Ristevski from Volkovo (305-775). Sincerely, Community of Volkovo, Skopje President Dragomir Panovski Signature Community of Orman, Skopje Ljube Todorovski Signature ANNEX 1 Minutes from the meeting (29.03.2001) Minutes of the meeting of the citizens of Volkovo and Orman, held on 29.03.2001 at 19:00 in the quarters of the community Volkovo This publication was made possible through financial support from the CEE Bankwatch Network 22 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 Present were: Mayor of the Municipality Gjorce Petrov, Mr. Ane Vasilevski, Experts from the Municipality, around 200 citizens from Volkovo and Orman. The following chair was proposed and accepted by consensus: − Dragomir Panovski, Chairman − Voislav Kaevski, member − Nikola Bogoevski, member − Rudica Boskoska, recording secretary The following agenda was proposed and accepted with a consensus: Information about the construction of the Skopje Bypass, which is to pass through the villages of Volkovo and Orman The Chairman, Mr. Panovski, briefly informed the citizens about the activities taken so far to influence the Ministry for Transport and Communications and the designers of the project in order to change the route of the Bypass. The need for modification of the route occurred because of the following reasons: the suggested route is unacceptable for the citizens of the two villages because of its construction on fertile agricultural land, because of the danger of fracture of the water reservoir, and because of the pollution of the whole region by exhaust fumes from the transport vehicles using the Bypass. So far there has not been a positive understanding from the Ministry for Transport and Communications. At this meeting the citizens should clearly indicate an alternative location for the Bypass. During the discussion the Mayor of the Municipality Gjorce Petrov, Mr. Ane Vasilevski informed the citizens present that he had received a letter from the Project Sponsor asking for identification of key elements and objects in the route's region. The Mayor indicated that this might be an opportunity for the citizens to demand a different route. There were also other citizens actively participating in the discussion. They precisely pointed out an alternative route for the Bypass. After the discussion, the following conclusions were made: The Bypass should pass: separation (of sand) "Granit," over the village of Orman- the hill of Krastavec Tupance, over the Church "Cetirieset Macenici," over the Church "Sveti Atanasie," over the reservoir of water, over the Monastery of Mala Bogorodica. The designer of the project should indicate the exact route according to the above mentioned objects. A special request letter containing the minutes of this meeting as an annex should be sent to the Ministry for Transport and Communications. In case that this request is not taken into consideration, the citizens of both communities will organize demonstrations, to be covered by media. The Initiative Board will have the responsibility of following the activities taken to achieve the requests of the citizens from Volkovo and Orman concerning the modification of the route. The following members of the Initiative Board were proposed and accepted by consensus: Stefan Krstevski, Ljube Ristevski, Bogoljub Jankovski, Dragoljub Ristovski and Mirce Blazevski from Volkovo. Voislav Kaevski, Pero Kitanovski, Ljube Todorovski, Branko Ackovik and Dimce Cvetkovski from Orman. The meeting of the citizens finished at 21:00. Chairman Dragomir Panovski Signature Recording secretary Rudica Boskoska Signature Note: The Eighth Conference of the Municipality Council of Gjorce Petrov was held on April 25, 2001. The first issue on the agenda was information about the Skopje Bypass Corridor East-West. The Council accepted the information presented and made the following decisions: The Council respects the requests from the citizens and advises the communities to continue with following the development of the project. The Council proposes that the Mayor gathers a team of people who will closely monitor the situation and report to the Council and the citizens. This publication was made possible through financial support from the CEE Bankwatch Network 23 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 ANNEX 6. Letter from NGO To: Fund for National and Regional Roads of Macedonia Dear Mr. Spasovski, We are sending you our comments and suggestions regarding the process of the public hearings for the "Skopje Bypass" project that should be organized on the 16th of April 2002. 1. We would like to suggest the organisation of an informative meeting with NGOs at least one week before the public hearing. This would be to ensure that NGOs are well acquainted with the process and procedures of the public hearing. 2. In order to achieve a wide spread of information, we suggest the preparation and distribution of a poster which would contain important information about the public hearing. Also, we expect that the process will be announced via the media (TV and radio) soon, as you have already stated. 3. We propose that the meeting start at 16:00 and not at 10:00, as was previously announced. We are proposing this because the hearing will take place on a working day (Tuesday) and there is a possibility that the meeting would not be attended by people who are obligated by their job positions and requirements. 4. The meeting should be facilitated by an independent, qualified facilitator. We suggest Mr. Zarko Koneski from the Institute for Sustainable Communities, Skopje (contact phone at work: 114 855 and at home: 177 304) 5. We expect access to the meeting to be free from any limitations or unnecessary restrictions for all parties and media. 6. The answers to the questions or comments raised at the hearing should be posted within one month of the hearing. If more time is needed, the party who raised the question or comment should then be informed about the exact date when the answer will be given. We are sending you these comments in order to make the organising and conducting of the public hearing easier. If you have any questions or comments about our suggestions, please feel free to contact us. Looking forward to a productive meeting and as a result, an acceptable bypass for the whole city. Best wishes, Sincerely, Ana Colovic 11 April, 2002 This publication was made possible through financial support from the CEE Bankwatch Network 24 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 ANNEX 7. Elementary school (Independent review, August 2002) This publication was made possible through financial support from the CEE Bankwatch Network 25 Ana Colovic, Eco-sense The Skopje Bypass Project- The Complete Case April 2003 ANNEX 8. Least-Cost Study To: The Fund for National and Regional Roads of Macedonia To the General Director Dear Mr. Useini, We are writing to you in connection to the “Skopje Bypass” Project and related documents. Namely, we would like to ask for access to the following documents: - Technical analyses of possible alignments; - Technical engineer’s comments on tunnel costs through rocks and rock cuttings; - Analyses, estimation and comparison of costs among alignments. We hope that you would supply us with the mentioned documents and that we will be able to study them on Monday, 14th of April 2003. Thank you in advance, Ana Colovic Eco-sense Skopje, 11 April 2003 To: The Fund for National and Regional Roads of Macedonia To the General Director Dear Mr. Useini, We would like to ask you for a response in written concerning the availability of Skopje Bypass documents we have requested on 11th of April 2003. You can send your letter through fax: 02 370 779 or regular mail: Kozara, 68/3-9, Skopje. Regards, Ana Colovic Eco-sense Skopje, 17 April 2003. This publication was made possible through financial support from the CEE Bankwatch Network 26