Series of Toma Belev and Borislav Sandov buried BGN 4.2 million in counting birds, fish, and butterflies (DOCUMENT) PART TWO


A new investigation by into financial schemes at the Ministry of Environment and Water (MoEW) has come across a horrific scheme to drain the budget through the „green terrorists'“ favorite counting of birds, fish, butterflies, and establishing the habitats of… mosses. The documents we have in our editorial office show how BGN 4.2 million were swept up because of Agreement D-33-19 of 8 July 2022 between the Ministry of Environment and Water and the National Museum of Natural History (NMNH).

The ultimate objective of the document is to delegate to the museum an atypical activity – consulting and assisting in the collection, analysis, and interpretation of data on natural habitat types and species for the National Biodiversity Status Monitoring System (NBSMS) and Value of Biodiversity Conservation Policy.

Behind the loud name lies the monitoring and collection of information on the distribution of brown bear (Ursus arctos), European ground squirrel (Spermophillus citellus), Eurasian lynx (Lynx lynx), wild cat (Felis silvestris), stone crayfish, Cydalima perspectalis, orchids/ salep orchid plant and other species throughout the country.

BGN 4.2 million has also sunk away on collecting new data on the distribution of the tiger moth (Euplagia quadripunctaria) under the agreement with the BAS, which is under the umbrella of the Ministry of Education…

The principle of the mechanism for scientific consultation by BAS is that, when specific expertise is needed, the executive authorities send a request to the Minister of Education and Science, who in turn commissions the scientific consultation based on the request approved by the Contracting Entity (Borislav Sandov’s and Toma Belev’s MoEW) and BAS.

Under Article 2 of Ministerial Decree No. 3 of January 10, 2020, BAS shall provide scientific advice on nationally assigned activities by the executive authorities CONCERNING A SPECIFIC POLICY ISSUE OR SECTOR WHERE ADDITIONAL SCIENTIFIC EXPERTISE OR SCIENTIFIC ASSESSMENT IS NEEDED, ESSENTIAL OR REQUIRED.

Scientific advice may be provided in the form of opinion, expert report, recommendation, and evaluation. However, the question arises as to how it is determined that the subject matter of this agreement is scientific advice.

Another very important point is that a large part of the activities under the agreement concern the completion of data in the National Biodiversity Monitoring System (NBSMS), which is organised and managed by the Minister of Environment and Water under Article 147 of the Environmental Protection Act. 

I.e., it is not a specific issue or complementary scientific expertise on the part of BAS, but an overall operation, the implementation of which is entirely the responsibility of the Minister of the Environment, in this case – Borislav Sandov.

It is a curious fact, which should have already aroused the interest of the Prosecutor’s Office, that the Executive Environmental Agency, as a structure directly subordinate to the Ministry of Environment, was a beneficiary of a European project that has a direct bearing on the collection of field data in 2022, for which Borislav Sandov and Toma Belev generously buried a new BGN 4.2 million.

Stay tuned to for the third part of the series on the outrage in the Ministry of Environment to learn how BGN 310,000 were spent without a public tender for the purchase of a car, boat, multimedia, etc. for the bird, fish and butterfly censusers.

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