Changing Varna’s General Development Plan. How?

There is a need for changes in the General Development Plan of Varna. First of all, to make a new reading of the way the city is built and developed. Then to stop the uncontrolled overbuilding. This is what the newly elected mayor of Varna, Blagomir Kotsev, said at his first press conference as mayor. Kotsev himself is aware that this is not an easy process and will take at least one to two years at minimum. The aim of the changes is to create more green areas and reduce the intensity of construction in some parts of the city. It sounds more than promising, but still as part of an election campaign.

How can this practically happen?
Yes, overbuilding and the reduction of green areas are one of the biggest problems for the quality of the urban environment and the quality of life of the citizens of Varna. There must be a balance between construction and infrastructure, and green areas, the new mayor believes. However, the term ‘over-development’ does not appear in our legislation, which means that we do not have a precise definition of the problem. It is more of a feeling among citizens. But no one denies that it exists. And it can inevitably be regulated by the Master Plan, the original purpose of which is to ensure the sustainable development of the municipality of Varna. According to the mayor, one of his first meetings will be with the Varna Chamber of Architects to present their proposals for changes to the master plan. We asked the head of the Chamber of Architects, Marin Velchev, for his opinion. According to him, the ‘partial amendment’ of the General Development Plan
comes very late, because it was neglected by the previous city leadership.
In the 11 years since the plan was adopted, the mayor has not reported to the council on its implementation or proposed changes to the plan. It is rumoured that there have been proposals to amend and update the plan, but all discussions have been in the direction of increasing the building and density indicators. Perhaps the only deterrent to these changes has been the township’s significant breach of Regulation 7. According to an analysis commissioned by the local government, the city has only half of the legally required green space. The required public green space in large cities is 20 square metres per resident. With a population of more than 430,000, Varna needs more than 8,600,000 m2 of green space.
According to the provisions of the Varna Master Plan, this indicator for the urban area is currently 10.05 m2/inhabitant. In order to reach its minimum value, “green areas for various forms of recreation within the settlement area” are included, which do not cover the components of active use by the population, commented architect Marin Velchev. According to him, the actual area of parks and green spaces in the
city should be increased almost three times to reach the minimum indicator.
However, there are no such green areas in Varna, and there is a tendency for all the smaller parks and gardens to be gradually “absorbed”, which significantly reduces the quality of the urban environment.
This leads to negative economic, ecological, social and psychological trends, according to the expert.

Is it possible to halt the downward trend?
The main problem that Varna Municipality has somehow overlooked is the loss of municipal property through sale. These properties could have had public functions (schools, gardens, parks, markets, centres of integrated urban transport, parking lots for condominiums, etc.), says architect Marin Velchev. The leadership of the Varna Chamber of Architects made an official statement on this issue two years ago, but
the then chief architect of the city did not react.
The option currently being discussed by the city’s architectural community is the expropriation of land in the Saltanat area in order to increase the park area for public use. In the Integrated Development Plan of Varna Municipality (2021-2027), a project of the Chamber of Architects for the creation of a so-called “Green Fund” was adopted, which would gradually accumulate funds for the transformation of the urban environment into a more sustainable and greener one. At the moment, however, this remains a dream.
There are a number of contradictions and shortcomings in the current General Development Plan for Varna, which create loopholes for the implementation of construction projects. An illustrative example of this is the case of “Koja Tepe”, where over 4 hectares of pine forest were cut down two years ago for the implementation of a housing project. The area in which the forest is located and the areas under it are marked in the graphic part of the master plan as follows “the protective forest is marked as an area for preventive protection”; “for preventive protection of areas at geological risk”; “the area affected by ancient, old and modern active landslides”.
The Rules and Regulations for the Implementation of the Master Plan, which are an integral part of the Master Plan adopted in 2012, provide for the urbanisation of the area. On this basis, in September 2013, Mayor Ivan Portnih issued an order for the preparation of a development plan, a development plan, the RDP and the urbanisation of the forest area.
Even more striking is the discrepancy for the Sea Garden. According to the graphic part of the plan, the areas of Saltanat, Gorchivata cheshma and Trakata are a park with public use, while in the text they are described as a resort, which opens up possibilities for development.
The other questionable shortcoming of the current master plan is the creation of urban zones of one or 2 to 5 separate plots. Such zoning decisions have led to accusations against the municipality that the plan was designed for certain property owners who benefited from higher building parameters at the expense of their neighbours. “There should be no such preferential zoning for individual property owners. It could
also be considered a corrupt and illegal practice. It would be appropriate to group all zones together in the amendments to the master plan,” suggests Arch. Kalina Miteva/Pavlova.
The future contract for the “Partial amendment of the Varna Master Plan” will be commissioned by the municipality. In it, the parameters for changing certain shortcomings and errors should be set. However, the basic parameters for the development of the city will be maintained. In fact, there are areas with high building indicators and intensity, which makes one wonder how something like this can happen in such areas. The President of the Regional Chamber of Architects points out that there are also areas that cannot be developed due to low density and intensity indicators – industrial zones to the south of Varna Airport.
There is no obligation to change the General Development Plan of Varna.
There is no explicit legal obligation to periodically update the master plan, nor are the authorities obliged to make or request changes in all cases where there are grounds for doing so, according to lawyer Alexander Asenov. On the other hand, in order to anticipate investment proposals, including infrastructure, that are not reflected in the master plan, it must be amended, Asenov said. The same applies if the detailed development plans provide for changes that are not included in the master plan. In this case, the master plan must be amended first.
“A master plan, if it is prepared for the next 15 years, needs to be updated regularly because trends emerge that need to be addressed. If we see something going in a bad direction, we need to counteract it; if it goes in a positive direction, we need to support it,” says Arch. Ventsislava Nedyalkova of the VarnaSpaces association. In her words, “it is very important that the spatial plan is linked to the strategic plan PIRO, which is in force for Varna from 2021 to 2027″. The master plan is a dream, a story. If we want something to happen, we have to foresee the financial resources for its implementation,” says Arch. Nedyalkova.
According to her, the master plan urgently needs to be updated, but it also needs to be linked to the PIRO
strategic plan in order to set the right priorities.
The General Development Plan of Varna in court after protests.
The Varna Master Plan was adopted by the city council in 2012 after a series of protests against its provisions and against the possibility of developing the Sea Garden and forest areas. As the provisions of the Spatial Planning Law at the time did not allow for direct appeals against master plans, a group of NGOs, including the Public Centre for Environment and Sustainable Development, challenged the
environmental assessment of the plan. After repeated delays and more than 2 years, the case ended with the dismissal of the appeal. Subsequent attempts to appeal the court’s decision were also unsuccessful, as the civil society organisations were dismissed as interested parties. However, the case continues to be pursued by the landowners. Despite the apparent failure so far, the lawsuits have resulted in the
unconstitutionality of the provision that the Master Plan cannot be challenged.
The possibility of challenging the General Development Plan itself in court is being considered, but so far there is no clear strategy for doing so, said lawyer Alexander Asenov. The decision is likely to be made once the parameters of the update are clear and whether they are in the public interest.