“They put a note, on the 16th they will come to collect money. Whoever did not pay, their water would be cut off. People laugh. Which water will they stop? There is no water… When you open the faucet, the water meter spins, but nothing flows. There are people to whom the water does not reach at all, but they received bills of BGN 120 each”.

Velichka Gacheva is a saleswoman in the village store of Solnik village, Dolni chiflik municipality. You can learn everything from her. And the fact that… “They turn on water once every two days. And those who live up in the neighborhood have no water at all for a week or two. The water comes from the river Dvoinitsa. And the village of Dulino is fed from there, but they don’t have a problem there.”

This was supposed to be a report about the drought of three villages and the disaster of 1000 people in the Varna region in the 21st century. And it should have seen the light of day as early as last fall. But it turned into an investigation into illegal mining of aggregates, which is still ongoing.

For the prosecution, “the author of the crime under Art. 240a, para. 1 of the Criminal Code was not disclosed, which is why the criminal proceedings were stopped by a decree on 28.11.2023 and the case was sent to OD-MIA-Varna, to continue the investigation of the crime.”

What the law says

According to Art. 240a (1) who carries out extraction of underground resources without a granted concession or when the operation of the granted mining concession has been suspended in accordance with Art. 68 of the Law on Underground Resources or on the basis of the concluded contract, shall be punished by imprisonment for up to six years and a fine of one thousand to twenty thousand BGN.

And more: according to Art. 1, para. 3 of the Law on Subsoil Resources, mining of subsoil resources is prohibited in riverbeds, lands belonging to rivers and reservoirs, coastal floodplains of rivers.

The voice of the people

Despite the prohibition of the law and the formal absence of an offender, the people of the drought-affected villages think otherwise. “We claim that inert materials were mined from the bed of the Dvoinitsa river, as a result of which the same was expanded and deepened. This has led to a displacement of the natural flow of water, as a result of which the sources from which we obtain water cannot maintain the necessary quantities and satisfy our drinking water needs,” they wrote in a report to the Attorney General, the Minister of Regional development, the regional governor of Varna and a number of other institutions, the people of Solnik.

Formally, everything is legal

In response to an inquiry under the Law on Access to Public Information (PAI), the Black Sea Basin Directorate (CBDHR) provided us with a written report, which shows that in September 2007, the director of the institution issued a permit for the use of water body – Dvoinitsa river in the land of the village of Solnik. The same was extended five times with different decisions and is valid until December 2015. The holder of the permit is “ZSK DEVNYA” AD, and the purpose of use is “removal of alluvial sediments from a surface water body, in order to ensure the conductivity of the river bed”.

Although they do not have an obligation to provide us with an answer under the PDOI, “ZSK DEVNYA” confirmed that they had a permit for the use of a water body in order to seize alluvial materials from the bed of the Dvoinitsa River near the village of Solnik until the end of 2015. During the period not by his action, the company did not cede the right to seize sediment materials.

And defacto…

Only the law makes a distinction between “seizure of sediments” and “extraction of aggregates”. For the people of Solnik, including those who worked on the site, there is no difference.

According to Wikipedia, sediments are unconsolidated deposits on the earth’s surface – sand, gravel, gravel, clay, etc.

According to the Bulgarian Association of Aggregates Manufacturers,

aggregates include sand, gravel, crushed stone. They are used as the main ingredient in the production of concrete and other composite mixtures.

We spoke with former workers of “ZSK DEVNYA” who witnessed the clearing of silt from the river.

“The entire trough was being worked on. The excavator first digs, sees if there is ballast, i.e. sand and stones, and if any to what level. A mass of earth came out from below. After it, there was another baluster, but it was already 4-5 m deep. The company dug up to 2 m”, claims Atanas Nenov, who worked as an electrical mechanic from 2007 to 2014 for the company. During this period, the site had three crushers and about 10 belts that carried the stones from one crusher to the other, pumps and… a concrete junction. (Inert materials are used precisely for the production of concrete.) “The water that was used was from the river – Nenov continues his story. “It would pressurize the ballast with pumps, go through three clarifiers and go back into the river again.”

The control

The control was reduced to the amount of water used and its pollution. Something that sounds illogical with a permit for the purpose of cleaning river sediments. “They came from Burgas every month and took samples to make sure there was no contamination of the water that leaves the site and enters the river,” claims Atanas Nenov.