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
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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.
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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
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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
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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.
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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.
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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.
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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.
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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.
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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:
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“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)
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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.
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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).
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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.
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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.
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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
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Ana Colovic, Eco-sense
The Skopje Bypass Project- The Complete Case
April 2003
ANNEX 1. Map of the alignments
(Independent review, August 2002)
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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:
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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
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Ana Colovic, Eco-sense
The Skopje Bypass Project- The Complete Case
April 2003
ANNEX 3. Location of church and graveyard
(Independent review, August 2002)
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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
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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
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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.
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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
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Ana Colovic, Eco-sense
The Skopje Bypass Project- The Complete Case
April 2003
ANNEX 7. Elementary school
(Independent review, August 2002)
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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.
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