The Citizen Initiative OhridSOS in collaboration with The Animal and Environment Protection Association EDEN have sent the following comments to the National Park Galichica. 

Remarks on the holding of the public hearing

First and foremost we would like to emphasize the violation of the Aarhus Convention which guarantees effective and efficient public inclusion in the decision-making process. The holding of the public hearing violated the Convention in several ways:

1. With the date (holiday period in our country).
2. With the public unavailability of the documents necessary for it (national legislation guarantees a minimum of 15 days for public document insight, unfortunately, the documents for this public hearing were first available barely one week before the date chosen for its holding). Besides, the English and the Macedonian version of the Annex do not correspond, which means that the non-English speaking portion of the Macedonian public will not receive a large part of the information from the English version of the document, which are not included in the Macedonian version too.
3. This is fifth in a row public hearing about the same document. The public was hugely satisfied with the initial SEA where over 90% of the conclusions emphasized the detrimental influence of the planned projects and an abandon scenario was strongly recommended. With the so called ‘improvement and upgrade’ of the SEA the latest version of the document allows for the realization of the majority of proposed projects, and proposes a so called biodiversity offsetting methodology in order to neutralize the inevitable destructive effects on the environment. This points us to the fact that the public is included only pro forma in the decision-making process and its protesting to these unnecessary and harmful projects which will have exceptionally and irreversibly negative consequences to the National Park is not taken into account in any way.
4. There were no representatives from the EBRD at the hearing which left many unanswered questions from the public present, because the questions intended for the EBRD officials could not be answered by any of the public hearing organizers present that day.

Matters such as the intermittent functioning of National Park Galicica’s website during the latest period for comments which made any attempts of accessing the documents needed for public review impossible; the apparent targeting of one of Ohrid SOS’s most prominent members; the continued intransigence to the valid environmental concerns raised by our Initiative; the ongoing total non-function of its English-language section; and the decision to advertise hearings for a UNESCO Biosphere Reserve in a multi-ethnic country in a single language (Macedonian) with a relatively obscure local news medium (Ohrid News) – all indicate that the process for public consultation and disclosure has been manipulated to exclude voices of dissent.

These questions naturally arise from everything stated so far:

1. Is disruption to the public consultation process an indication that decisions have already been made about the 5 projects, and, further, that the entire SEA process is little more than a show to appease onlookers without any genuine concern for biodiversity in the Ohrid-Prespa region?
2. Was Ohrid News truly an appropriate place for an advertisement for a public hearing on the future of an area of UNESCO World Heritage concern? Surely, a national or even international forum would have been more applicable.
3. Why has the English-language side of the NP Galicica website been non-functional for such a long period of time? What provisions have been made to ensure that an international audience can reach documents such as the Citrus Partners LLP SEA?
4. Why, in a multi-ethnic country, have advertisements been placed in Macedonian-language media? Why have they not been presented in more languages and media?
5. What improvements could have been made to the public consultation process?
Remarks on the capacities and the integrity of the PINPG

Capacities of the PINPG

A weakness in the mitigation and offset provisions recommended by the SEA is the level of responsibility placed upon Public Institution National Park Galicica, a point tacitly acknowledged by Citrus Partners LLP. This involves multiple tasks from guarding against poaching for endangered butterfly species to managing the risks created by construction and the road scheme, monitoring and managing biodiversity offsets for the first time to ensuring the integrity of fencing and signage. All of this is before we even consider how much strain controlling far greater volumes of people will have upon PINPG resources or consider aspects such as the need to advise developers of the best course of action.
Any national park authority would struggle with this extra burden, but there are reasons to believe that Galicica’s will experience more problems than most: Firstly, at least in recent history, the national park has not been funded in an ecologically benign way, but through the destructive practice of clear-cutting forests, a fact which should act as a warning for how it may choose/be forced to cover its budget needs in the future. Secondly, the PINPG’s initial willingness to adapt its Management Plan for 2011-2020 at the government’s behest without anything close to sufficient safeguards for the natural environment prior to the Citrus SEA implies that the institution is far from fully committed to its role as protector of regional biodiversity. Thirdly, the EC-documented politicization and corruption of Macedonian institutions undermines PINPG’s ability to function reliably and correctly. Fourthly, the present-day situation of the institution is described by the IUCN as suffering from “low-levels of staff and insufficient budget” and having “little capacity to ensure the effective protection of the national park’s values”. Fifthly, the suggestion that resources could be provided by the government or private companies will be undermined either by cost pressures from investors, for whom the Business Masterplan sells the ski-resort at least in part on cost advantages, or by decision-makers, whom the IUCN believes are “accompanied by a low awareness”.

1. Exactly what are the costs of all the proposed mitigation, offsets and duties that will be required of PINPG? When will a breakdown of this be provided?
2. Given that the Citrus LLP SEA argues that the contribution of PINPG will be crucial to the biodiversity outcome of the proposed projects, why has no full assessment been conducted on its organizational structure, background context, governmental support, capability, expertise and general willingness to complete the tasks required? Based on present-day evidence, does Citrus LLP believe that PINPG is truly capable of protecting biodiversity through the 5 proposed projects? If so/not, why?
3. The Citrus SEA suggests that commitments may be sought from the Macedonian government to finance PINPG for its new roles into the future. Given the sub-standard environmental governance displayed by Macedonia and trends towards budget-cutting for environmental protection seen in other countries during times of economic difficulty, how can such a system robustly conserve National Park Galicica’s biodiversity indefinitely into the future?
4. Alternatively, the Citrus SEA argues that money for PINPG could be sought from the project sponsor for the ski-resort. Will this impact upon the economic viability of the projects? What happens if the ski-resort goes bankrupt? In this case, how will offsets then be funded?
5. If the projects and offsets go ahead, much will depend on the commitment of the Macedonian government either to ensure resources directly/indirectly or to guarantee that rules/monitoring are observed. How does Citrus rate the Macedonian government’s ability/commitment to carrying out this task? What evidence supports this opinion?

Carrying Capacity

Page 223 of the SEA states that the carrying capacity for National Park Galicica is presently unknown. However, Citrus Partners LLP makes no attempt to quantify it, again delaying until the project stage. Meanwhile, taking the slide towards eutrophication as evidence, there are already signs that Lake Ohrid may have even exceeded the limit of anthropogenic stress it is capable of supporting without major disruptive changes to its ecosystem.

1. Do you believe Lake Ohrid is currently under or over capacity? What evidence supports your point of view? Is it responsible to place further strains on a system that is already exhibiting signs of unsustainable use?
2. Why has there been no attempt to quantify the carrying capacity of National Park Galicica when such information is key to understanding the overall effects of the five planned projects? Again, is it responsible to action projects in an area where carrying capacity remains guesswork?
3. How can any biodiversity offset or mitigation measures have any meaning whatsoever if carrying capacity remains unknown?

Given that the accumulation from the various projects will impact Lake Ohrid as a whole and should influence the decision of whether to continue with development at all, should not the issue of carrying capacity be dealt with on a strategic level rather than the project level? Could not postponement to the project level cause the combined threat to become obscured or overlooked?

PINPG Reliability and Independence
As pointed out by the Citrus LLP SEA on page 41, unless powerful stakeholders such as the European Bank of Reconstruction and Development had not raised concerns about the lack of provisions for nature protection in initial plans for the Ohrid-Prespa region, environmental concerns would have been given even less consideration than is presently the case.

1. Given the role of Public Institution National Park Galicica as guardian of regional natural heritage, why did it require foreign banks and others to identify the complete inappropriateness of the original plans?

2. Why did PINPG fail to put forward this point of view beforehand?

3. If the answer is that PINPG lacked the power for its voice to be heard without the support of other stakeholders, how can it be guaranteed to maintain the core nature values of National Park Galicica into the future?

In addition, maintenance of the ecosystem against large visitor volumes, disturbances, habitat fragmentation and general anthropogenic strain will require the full commitment and expertise of PINPG indefinitely into the future. Over this period, assuming Macedonia’s commitment to democracy, we have to expect that many changes of government will take place. These successive governments will have differing attitudes towards environmental protection. At the same time, if the investment proposal for the ski-resort and associated projects attracts interest, private companies whose primary motivation is profit will also seek to influence National Park Galicica for their own needs and ends.

4. In this context, what advance steps will be taken to ensure PINPG’s freedom from political interference and the ecological integrity of its decision-making processes from now into the future?

5. How will the institution be set up in advance to guarantee its practical and financial independence in case of government negligence?
Political Background

Biodiversity offsets remain highly controversial. For example, in the UK, the country from which the Citrus SEA methodology is borrowed, a process of debate, consultation and pilot schemes is taking place over the course of several years before any offsetting policy can be implemented. This has involved a two-month consultation period during which the entire population of the United Kingdom was invited to give opinions, including various expert groups. The process is still ongoing, and it has thrown up numerous concerns about the damage that such policy could cause if used inappropriately. Even experts who are supportive of the general concept have raised countless comments and considerations, suggesting that present solutions are oversimplified. We would like to ask about how this process took place in Macedonia.

1. Why was the issue of biodiversity offsetting not discussed over a lengthy period of time with the involvement of the entire population and the creation of workshops for a wide range of expert groups and stakeholders before any SEA for NP Galicica was considered?

2. What debates and discussions were held at government level before the present biodiversity offsetting policy was decided?

3. What is the logic and theory behind the current decision to employ biodiversity offsetting in Macedonia?

4. In short, how did the Macedonian government decide that biodiversity offsetting is an appropriate direction for the country, how long did this process take, whose opinion was consulted, and what trials have been conducted locally to ensure the success of offsetting methodology?

The Citrus LLP SEA seems to have overlooked the national context in which the NP Galicica developments will take place. Little attempt has been made to understand the Macedonian political framework on a deeper level despite its critical importance to the outcomes of biodiversity offsetting. On this subject, the IUCN states in its 2014 Biodiversity Offsets Technical Study Paper that a “lack of monitoring and enforcement (and thus implementation), often driven by lack of political will” and “inadequate underlying methods” are two of the key reasons for biodiversity offsetting failure.
The OECD reinforces these points in a 2014 Policy Highlights document entitled Biodiversity Offsets: Effective Design and Implementation, which states that monitoring, reporting and verification (MRV) methodologies “able to assess progress toward an offset’s objectives are critical. This includes adequate documentation of management plans, regular monitoring including on-site checks, clear and transparent reporting, and verification by a third party.” The same document elaborates that “MRV frameworks must be supported by appropriate compliance and enforcement measures to create the incentives necessary for offset suppliers to deliver conservation outcomes over time.”
Against this, the European Commission’s 2015 Staff Working Document for the Former Yugoslav Republic of Macedonia describes a country in which “transposition of the acquis on natural habitats and wild fauna and flora is delayed. Implementation of the nature protection acquis and designation of a Natura 2000 network has still not begun.” It also emphasizes that the administrative capacity to implement and enforce environmental legislation in Macedonia is “insufficient at all levels”. “Inadequate” is the term used to describe the country’s environmental monitoring and information systems. In practical terms, this adds up to MRV incompetence and an absence of commitment at government level.

1. Given both the IUCN and OECD’s independent conclusions that monitoring, enforcement and political will are integral elements of biodiversity offsetting success, why has the Citrus LLP SEA failed to fully analyze Macedonia’s general capability in these terms?

2. Why has no investigation of general construction practices in Macedonia been conducted to ascertain whether local standards are adequate enough to ensure zero lasting damage to the environmental integrity of the Ohrid-Prespa region?

3. What will now be done to ensure that these considerations are included in the process for NP Galicica?

4. Who will be the third party suggested by the OECD to verify monitoring and reporting?

Finally, do you consider it responsible for a country whose ability to meaningfully enact environmental legislation is assessed by the EU as “insufficient at all levels” to implement biodiversity offsetting in an area of acute ecological sensitivity with World Heritage Status?
Lack of Reliable, Up-to-Date Information

Page 230 states, “Resources to manage the National Park are currently limited and there have not been any comprehensive surveys for many of the species populations that might be affected by changes in the management plan. This lack of reliable, up to date information means that it has not been possible to carry out a comprehensive detailed review of the implications of revision of the Plan and potential impacts resulting from the planned projects for all potentially affected species, including many that are endemic to the local area or the Balkans and many others that are protected within the EU and/or nationally.” This calls into question the entire validity of the SEA.

1. How can any meaningful assessment be conducted, particularly with regard to offsets, when data is incomplete and unreliable?

2. Given that the report is based upon deficient information, to what extent can the SEA conclusions, particularly that certain aspects of the five development projects are offsettable, be trusted?

3. In light of this quotation from page 230, would the makers of the Citrus LLP SEA consider their work to be a success or a failure?

4. Is it a professionally defensible decision to make such far-reaching conclusions as those put forward by the Citrus Partners LLP SEA, given the lack of dependable data?
Remarks on the Biodiversity Offsetting Methodology

In the public meeting, it was mentioned that existing international methodology will be used for the biodiversity offsets programme for National Park Galicica. From documents referenced and examples given in the Citrus LLP SEA supplement annexes, this relies strongly on methodology put forward by the UK.

One of the documents referenced by Citrus LLP in its Briefing on Biodiversity Updates (page 9) is Biodiversity Offsetting Pilots — Technical Paper: the metric for biodiversity offsetting pilot in England, March 2012. This document explicitly states in point 16 that its approach is not fully understood; contains a number of issues that need to be clarified before it can be put into wider use; and is designed for pilot schemes. In other words, it is experimental. Moreover, the above-mentioned UK document is cited specifically for the “time factor” used to quantify Habitat Offset Units, whose maximum multiplier for “years to target condition” is greater than 32.

1. Given that this document was only released in 2012, there cannot possibly have been enough time to assess whether the methodology is viable. Therefore, how can it be appropriate to apply unproven, experimental measures designed for different ecosystems in a totally different geographical region to a Macedonian/Albanian national park and Biosphere Reserve of international ecological significance?

Biodiversity Offsetting Pilots — Technical Paper: the metric for biodiversity offsetting pilot in England, March 2012 also contains an important warning in point 83. It categorically states that “there will be no change to existing levels of protections for our biodiversity. So existing protections for habitats and species (such as those made under the EU Habitats and Species Directive), and the processes that go with them, are not part of the offsetting pilot.” Clearly, then, this methodology has neither been designed nor intended for use in areas with a high protection value that have established safeguarding mechanisms in place and numerous species of particular ecological value. This is further reinforced by point 17, which states that biodiversity offsetting “should not change existing levels of protection for biodiversity.”

2. Given these statements, why is methodology from this document a) being used in conjunction with rezoning, and b) being used in National Park Galicica, where both habitats and species already have established “protections” and “processes that go with them”?

Section 2.3 of the Briefing on Biodiversity Offsets provided by Citrus LLP suggests that the offset calculation used is based on a 2010 paper named Biodiversity Offsets: possible methods for measuring biodiversity losses and gains for use in the UK. For starters, even the title reveals how this paper is focused on UK biodiversity, not that of a karstic Balkan mountain through which the waters of two ancient lakes flow, hinting immediately at non-applicability. This notion is supported by the fact that the paper is “intended to complement the UK’s existing policy and planning system”. Other problems with adapting the methodology to National Park Galicica are immediately evident: The authors emphasize that their work is to be used as a “starting point for the purposes of discussion and debate rather than a recommended final solution” and warn that “rigorous testing would be required to ensure the approach delivers acceptable outcomes”. Since the paper was written a mere five years ago, it is a temporal impossibility for its hypothesis to have been rigorously examined by the present day.
Biodiversity Offsets: possible methods for measuring biodiversity losses and gains for use in the UK also goes so far as to say that there are some circumstances in which use of offsets will “never be appropriate”. Indeed, it gives the example of any UK Biodiversity Action Plan (BAP) habitats with no loss targets as those for which its methodology is likely unacceptable. In addition, the paper works under the assumption that it would “only apply to losses of habitat occurring outside the Natura 2000 network”. In knowledge, therefore, that the Citrus LLP SEA has made its offset calculation based upon a paper that actively points out its own shortcomings, the following questions arise:

3. Why is methodology designed to complement an existing UK framework applied to Macedonia?

4. Why has an offset methodology expressly intended as an entry point to discussion been applied to an ecologically sensitive area as a final solution, despite the recommendation of its authors that it should not be used for such purposes?

5. What justification is there for using the Treweek et al paper as the methodological base for biodiversity offsets at NP Galicica when the paper itself assumes that it will not be employed for Natura 2000 sites, which are the equivalent of Emerald Sites, within the European Union?

6. If Galicica was in the UK, how many of its habitats would be designated as BAPs with a no-loss status?

7. Assuming that the Joanna Treweek listed as a contributing expert is the same Treweek from the mentioned paper, what possible change in attitude has she undergone to suddenly apply her own work outside its stated context?

The guidelines and caveats in Biodiversity Offsetting Pilots — Technical Paper: the metric for biodiversity offsetting pilot in England, March 2012 and the entrenched UK-local hypotheticality of the paper by Treweek et al raise concerns about the professional conduct of Citrus LLP in producing the SEA for National Park Galicica. Understanding that Citrus is a UK company, it must know that the methodology it employs is unproven and incomplete, and that biodiversity offsets as understood by the UK are not intended for areas like Ohrid-Prespa. The very resources it cites make these points conclusively obvious.

8. Therefore, how can it justify its professional decision to provide offset suggestions based upon this methodology in Macedonia?
Endemic Species Methodology

Even if we would imagine that there were legal and regulatory prerequisites for the application of the biodiversity offsetting methodology in the Republic of Macedonia, how would the institution adapt such methodology to these specific conditions, i.e. an area with endemic species? If you have already chosen the methodology for universal species, which, so to speak, counterpart methodology will you use for the endemic species in the Park? Given that these species do not exist in countries where the proposed methodology was created, does this mean that you should come up with your own new methodology? What is the process of creating such methodology?

Did Citrus LLP follow and comply with the standards and guidelines of BBOP (The Business and Biodiversity Offsets Programme) in the process of selecting a suitable methodology before they selected and recommended the given offsetting methodology as most appropriate and feasible in these conditions? The BBOP point to a limitation criterion of the categories of biodiversity influence that can be neutralized. Has this been done by PINPG or Citrus LLP?

Has the endemic nature of the species been taken into consideration before assessing the biodiversity value?

Generally, how differently will the endemic species be treated in comparison to universal species?
Mitigation Hierarchy

According to the European Union and several other official bodies such as the Business and Biodiversity Offsets Programme referenced by Citrus LLP, the No Net Loss (NNL) initiative should be firmly embedded within the mitigation hierarchy. As such, biodiversity offsets are intended to be a last resort, not a first reaction, and avoidance is the primary aim. The Citrus LLP SEA acknowledges this, and, in section 8.2.1, on page 234, advises that the location for the ski-resort should be reconsidered.

1. With this in mind, can you please demonstrate how the mitigation hierarchy has been followed? For example, what steps have been taken to attempt avoidance options for the project?
2. Why has avoidance been concluded inappropriate for the ski-resort despite clear evidence that this is an unsuitable location?
3. Why is there a total lack of alternatives suggested for the ski-resort project in general?

In the Citrus LLP SEA, focus on certain habitats, such as those covered by the EU Habitats Directive, appears to have distorted the overall principle of protection for nature in general. This is highlighted by the lack of any suggested avoidance or offsets for the EBRD-financed Ohrid to Pestani road section, which is justified on the grounds that Oak-Hornbeam forests are widespread in Macedonia, and, therefore, that destruction of 281Ha is an acceptable cost of the project. The fact that this habitat is considered expendable suggests that it has zero value to local biodiversity. On the other hand, by their very existence alone, one logically assumes that Oak-Hornbeam forests do have some value in terms of nature. This raises numerous questions:

4. What is the precise definition of biodiversity preferred by Macedonia?
5. How has Macedonia decided that this is the most appropriate definition of biodiversity for the needs of its nature?
6. What is the difference between biodiversity and nature?
7. Is there a danger that emphasizing the former could cause damage to the latter to be hidden?
8. What contribution to nature (not biodiversity) does the Oak-Hornbeam make and why is this considered expendable by these terms?

Furthermore, a non-compensated loss of 281Ha of forest will certainly cause a change to the balance of Macedonian ecosystems. One principle of the No Net Loss strategy from which the EBRD (and by extension the Citrus LLP SEA) derives its environmental policy is that it must be seen in the wider context of the 6 EU Biodiversity Targets and the Convention on Biological Diversity (CBD), to which the Republic of Macedonia is bound via accession. In particular, the CBD states, “By 2020, the rate of loss of all natural habitats, including forests, is at least halved and where feasible brought close to zero.” Meanwhile, EU Biodiversity Target 2 expounds the intention that “By 2020, ecosystems and their services are maintained and enhanced by establishing green infrastructure and restoring at least 15% of degraded ecosystems.” NNL is a tool of action to achieve these targets and it is meaningless if disconnected from them. In other words, all of the biodiversity offsets in the Citrus LLP SEA are invalid unless an overall improvement in degraded habitats and the rate of loss of natural habitats is brought close to zero where possible across Macedonia. Therefore, we would like to ask two questions:

9. How does the application of projects in National Park Galicica fit into the full context of the Convention on Biological Diversity and the 6 EU Biodiversity Targets?
10. Why has No Net Loss been selectively applied to certain habitats, i.e. not to Oak-Hornbeam forests, when it should be part of a far-reaching policy goal intended to prevent loss of habitat in general?
Climate Change

Inexplicably, climate change has been omitted from SEA consideration almost entirely. In fact, Citrus Partners LLP only mentions the phenomenon in relation to habitat transformation for alpine and sub-alpine grasslands. The document does touch upon the issue of how the cumulative effects of the ski-resort and changes in weather patterns may cause a severe negative impact to these habitats, but it does not attempt to quantify the effect further or explore it in detail. Moreover, the SEA does not give any thought to how National Park Galicica may become relatively more important during the era of climate change due to the multiplicity of habitats and climate zones, the regulating effects of nearby lakes, its potential to act as a refuge, and its function as a green corridor. Nor does it assess how the fragmentation of habitats caused by roads and ski-runs will act as an obstacle to the relocation of species when temperatures change, thereby inhibiting the fluidity of their reactions and the adjustment of entire habitats. Nothing is mentioned on the subject of how climate change may disrupt the process of biodiversity offsets or how these offsets may hold habitats in climatically inappropriate zones either.

1. Why has the impact of climate change not been discussed more thoroughly or concretely by the SEA despite evidence for its necessity with regard to conservation measures in the present day?
2. How will climate change influence the effectiveness of biodiversity offsets?
3. How will habitats and species be able to adjust fluidly and appropriately to transforming conditions with increased barriers such as roads and ski-pistes, and habitats that are artificially held to certain types to conform with offset needs?
4. What likely importance would the Ohrid-Prespa region have relative to other locations during the era of climate change if no projects were actioned?
5. Will the ability of species to react to climate change be greater or lesser if the projects occur?
6. Is the present day an appropriate time to engage in such massive upheaval in a habitat that could act as a refugium, given the expected fallout from climate transition?

Although the Citrus LLP SEA does mention fragmentation and discusses some mitigation measures such as tunneling to allow access to the lakeshore, investigations still seem incomplete. For example, the SEA points out the effect that infrastructure barriers may have on slow-moving species such as tortoises, but does not go further to explain the consequences of this disruption or give any advice on the design of road fences, a matter of key importance. Moreover, although access to the lake may be guaranteed to some degree by measures at Crno Brdo and Evil Canyon, we can still expect that the movement patterns of species will be affected. This will impact upon trophic cascades and may cause localized imbalances in the ecosystem, such as in areas that large predators are discouraged from reaching. Since trophic cascades in the Ohrid-Prespa region are still not well understood or fully evaluated—another point that undermines the value of the Citrus LLP SEA—the risks here could be unpredictable. Additionally, the threat to the genetic diversity of species as a result of boxing in populations and the risk of a combined negative effect in conjunction with climate change are not properly assessed. Projects such as the road and ski-resort also must be understood in the context of species such as the Balkan lynx. The lynx is critically endangered and therefore needs maximum efforts to ensure its survival. While mitigation measures may reduce some of the dangers it faces, the totality of the projects is nonetheless unlikely to provide any kind of support to the ultimate goal of restoring lynx populations to viable numbers, especially considering that the species particularly requires freedom of movement during the late winter breeding season when the ski resort will be most active.

7. What do we know about localized trophic cascades? How will the movements of mobile species be affected by the projects and how will this impact on hyperlocal ecosystems within Ohrid-Prespa? Is there not a danger that habitat quality reductions resulting from the detachment of important species from narrow areas will negate any quality gains that may be achieved by the proposed offsets?

8. If we do not have sufficient knowledge about trophic cascades, can projects such as the 5 proposed for Ohrid-Prespa be responsibly justified?

9. How will habitat fragmentation impact upon the genetic diversity of slow-moving species over time? Will this be exacerbated by climate change?

10. Are programmes such as the recovery of the Balkan Lynx made more likely or less likely to succeed if the projects are implemented?

Offsets proposed by the Citrus Partners LLP SEA are focused towards habitats and include advice for monitoring certain species. However, it remains a concern that simply creating new areas of similar land and observing the presence of a handful of species is not enough to ensure that a) populations of other non-monitored species are not eradicated or damaged; b) ecosystem services are retained at present-day levels; and c) the efficiency of ecosystem relations that may cross habitat boundaries such as pest control or pollination are conserved.
1. Is there a danger that chosen methods of monitoring offsets may cause failures to be obscured or overlooked? How can this be mitigated?
2. What changes will occur in habitats that either border new offsets or border areas from which habitats have been removed? Will there be any monitoring to ensure that the balance of biodiversity in these areas is not adversely disturbed? If not, why not?
3. Changes in habitat location will presumably accompany movements to slightly different altitudes with differing climates and underlying geography. How will this affect ecosystem composition and what risks accompany this impact?
4. How will the translocation of habitats to offset locations influence the spatial mix of NP Galicica forests and grasslands etc.? How will this manifest in ecosystem functioning? What consideration of habitat mix has been made by the Citrus LLP SEA in designing the offset program?
Underrated Rareness of Oak-Hornbeam Habitats & Danger Underestimation for Gradiste/Ljubanista

The definition of Oak-Hornbeam forests as expendable due to their frequency in Macedonia also ignores the fact that these habitats exist in the near vicinity of Lake Ohrid. This is an important consideration because there are indications that areas surrounding Prespa and Ohrid functioned as a refugium during periods of glaciation. Although inconclusive, research presently suggests that the genetic diversity of species within such refugia or the contact zones between them may be higher than in other locations, and, since genetic diversity influences the ability for species to survive during challenging periods such as climate change, areas where it is elevated deserve particularly stringent protection. Therefore, Oak-Hornbeam forests on the shores of Lake Ohrid should not simply be compared with any other Oak-Hornbeam locations, but Oak-Hornbeam locations within refugia. This would make them much more rare.

1. Why has any measurement of genetic diversity been omitted from the SEA, despite its growing importance to conservation?
2. Why has Citrus SEA declined to quantify the frequency of Oak-Hornbeam in the context of their proximity to Lake Ohrid, the impact that the lake has upon them, and the potential effect on biodiversity/the long-term survival of species that this proximity implies?
3. Why does the Citrus SEA not discuss the issue of refugia in the context of Oak-Hornbeam forests and also the other habitats of the threatened Ohrid-Prespa region?

Habitats whose importance to nature and biodiversity appears underrated by the Citrus LLP SEA also include the lakeshore around Ljubanista and Gradiste. The SEA seems poorly researched in that it does not adequately take into consideration the impact that urbanization is having upon Lake Ohrid. Sources such as the IUCN, UNESCO and scientists devoted to the study of lentic systems all warn that development in the littoral zone is highly destructive and in danger of disestablishing the unique local ecosystem. One argues that the input of pollutative substances such as phosphorous must reduce by 50% over the coming years if the lake is to retain its current oligotrophic status. Others suggest that the anthropogenic stress already placed upon the lake is too high. Meanwhile, species covered by the Bern Convention such as Algyroides nigropunctatus are found in close proximity, and may well have presence in Ljubanista and Gradiste. Accepting these factors, the conclusion of the SEA that the effect of further development at Ljubanista and Gradiste will be marginal seems bizarre.

4. Will the level of pollutants to Lake Ohrid rise or fall as a result of the developments at Ljubanista and Gradiste? If it will rise, exactly which pollutants can be expected and what results will they have?
5. Why does the SEA give such slight attention to Gradiste and Ljubanista 1 & 2 despite the numerous powerful sources arguing that increased construction on the lakeshore is ill-advised?
6. Is Citrus Partners LLP fully aware that Lake Ohrid is one of the few concretely identified ancient lakes on Earth? If so, should not the risk-factor associated with Ljubanista and Gradiste be revised upwards?
Economic Arguments

Economic benefits for the development of National Park Galicica are repeatedly put forward by the Citrus SEA as a positive consequence of the proposed projects. However, at no point is this backed up by any reasoned discussion or supporting evidence. No consideration is given to alternative models of wealth creation that do not increase pressure on sensitive habitats and no mention of the economic costs or potential loss of ecosystem services is mentioned. While we accept that the SEA is not the correct forum for long economic debates, we also feel it is inappropriate for the document to make unverified and one-sided claims.
Neither is the economic case for the projects entirely unquestionable. To begin, a draft report compiled by the University of Gothenburg to advise the Macedonian government on how to adjust to climate change suggests that ski-resorts are an ill-advised venture. This opinion is backed up by several other studies that forecast widespread difficulties for European ski-resorts over the coming years. Specific to National Park Galicica, the Supplemental Annex to the SEA contains an unsourced quote that appears to originate with Ecosign on page 1. It reveals that the necessary studies have not yet been completed to ascertain whether the location is suitable for a ski-resort at all. This is anything but a firm economic base for a proposal. Meanwhile, the added benefits of constructing an expressway across the eastern coast of Lake Ohrid are also doubtful, given that existing connections to Albania are already viable.
No cost appraisal is offered either. If the projects are facilitated as planned, the stress placed upon Lake Ohrid could greatly increase. This will require the large-scale, ongoing creation and maintenance of infrastructure in order to preserve the lake’s water quality. In a worst-case scenario, a Lake Biwa situation may manifest too, requiring a massive investment to alleviate strain upon the watershed following over-urbanization. The potential for nature-based tourism or scientific research could also be diminished if offsets are implemented to a less than perfect degree, meaning that the development of one tourism sector will only come at the expense of another, and cause more damage at the same time. As if this was not enough, a loss of both direct and crossover economic benefits will ensue if implementation of the ski-resort and associated developments causes UNESCO to reevaluate regional heritage status, a step which could also reduce regional ability to generate support and resources for future conservation schemes. This is without mentioning the complicated matter of bank loans and Macedonian national debt, and the sale of national park land at below market value.
Moving on to ecosystem services, local ecologists have warned that bat species may be disturbed as a result of proposed actions in the national park. These creatures subdue insect populations and thereby reduce agricultural reliance on pesticides, which in turn safeguards the integrity of local waters. Should their populations reduce, a costly fallout will ensue. This is one example, but there are likely to be many more. However, citing evidence is not entirely possible because research has either not been conducted or is not readily available.

The SEA strangely mentions jobs during construction as an economic advantage as well. This is valid, but it could be applied to any project. The same number of people could equally be employed in the development of an advanced scientific unit and the construction of elite-level visitor centers to make the Ohrid-Prespa region a European epicenter of biological research and ecotourism, or projects in other locations with lesser ecological necessity. Job creation does not have to be tied to a ski-resort and road project within the boundaries of a national park.

1. What background checks on the validity of the economic argument has Citrus Partners LLP conducted to confirm that these projects will indeed benefit the local economy?
2. How can the ski-resort project be said to offer economic positives when the necessary data for weather conditions has yet to be provided to demonstrate whether the location is appropriate for a ski-resort at all? Is there not a huge danger of an ecologically damaging “white-elephant” project ensuing?
3. Why are economic benefits mentioned as a positive, but economic costs neither explored nor described as a negative?
4. Can job creation during construction really be put forward as an economic advantage of this particular project, when it may equally apply to any large-scale alternative actioned in a less ecologically sensitive zone or with less ecologically damaging consequences?
5. What will be the potential economic consequences of
a) loss of UNESCO status;
b) cost of increased infrastructure to protect habitats and species, most notably Lake Ohrid, over indefinite time periods;
c) reduction of ecosystem services from non-offset habitats such as Oak-Hornbeam;
d) foregoing income from certain forms of sustainable tourism that are not compatible with the mass-tourism model discussed by the SEA, but currently developing and/or displaying high potential for growth;
e) the clean-up operation needed if the extended sewerage for additional projects and associated urbanization fails to treat more than 25% of wastewater (the current estimate for the catchment) over a period of ten years;
f) the expected percentage increase in visitors to the mountain resulting in an equal percentage increase in accidental fires?

6. What is the present estimated value of National Park Galicica’s ecosystem services? If this has not been quantified, can any valid conclusions of the economic risks, advantages and disadvantages of the five projects be meaningfully completed? In addition, without such information, how can the success/failure of any biodiversity offsets be fully gauged?
Justification for Other Projects

As a de facto Natura 2000 site, overriding public interest must be demonstrated before projects like the 5 proposed can occur in National Park Galicica. As we have already explained, the economic argument is oversimplified, flawed and does not give enough attention to the monetary losses that could follow. It cannot be considered an overriding public interest at least until a complete and robust analysis is presented and discussed from all angles.

On page 228, the SEA reveals that it is assuming that the Macedonian government has undertaken the full process necessary to demonstrate overriding public interest. However, a European Commission staff working document (page 4) describes the Macedonian political situation over the past year as suggestive of “breaches of fundamental rights, interference with judicial independence, media freedom and elections, as well as politicisation and corruption.” Additionally, in the section Environment and Climate Change of the same document (page 68), it is stated “Public consultations with stakeholders continue to not always be properly applied, and results not always fully reflected in decisions.” If these statements are true, the process of demonstrating overriding public interest for the projects at National Park Galicica needs to be reviewed in great detail by an independent body, as the conditions are not ideal for thorough debate and involvement to determine such matters inclusively and fairly.

Moreover, since this is a large-scale task relevant to the entire development of the Ohrid-Prespa region, requiring large resources and specific skills, the Citrus LLP SEA’s advice that the official presentation of overriding public interest can be delayed until the project level is inappropriate.

5. Overriding public interest is surely something that must be demonstrated before any further steps are made. Why, therefore, is it being delayed to the project level?
6. At project level, is it possible that conflicts of interest may affect the analysis of the Macedonian government’s demonstration of overriding public interest? Is not a thorough independent verification at the strategic level more appropriate?
7. Given the above quotation from the EC staff working document, can any trust be placed in government explanations of overriding public interest?
8. The Citrus SEA LLP states that the Macedonian government will have to prove overriding public interest at the project level according to “appropriate criteria”. What are these criteria? Who will set them?
9. Whatever they are, the criteria referenced in the previous question will require evidence to be supplied. Presumably, at least some of this evidence will be sourced from the Macedonian government. Again, given the EC statement above, how can such evidence be relied upon? How can reviewers at project level realistically perform the necessary background checks to verify it? Do they have the resources to do so?

Justifications for specific projects are also problematic, containing haphazard logic. For example, the reasons put forward for the express road are to facilitate tourism development, while reducing vehicle operating costs and time; lessening pressure on the existing road to avoid peak time congestion, improve safety and improve the visitor experience; and connecting through to Albania. “Reducing vehicle operating costs”, saving a few minutes of journey time, and avoiding the odd traffic jam at certain specific times of year surely cannot be said to override the nature interest of one of the most biodiverse mountains in Europe and associated ancient lake. It is also unclear how the visitor experience to an area known for its sublime natural beauty and ecological heritage will be improved by the presence of a huge road. Tourism development may even be undermined by the project if it hastens the loss of World Heritage Status, detracts from attempts to build nature-based visitor attractions, and proves to be the “permanent scar” that the SEA envisages on page 213. Connectivity to Albania is another wrongheaded justification since the existing road already performs this function; the SEA does not foresee any major, direct economic boost from the project; and another, faster link to a highway in neighboring Albania is already in use less than 30 kilometers from the town of Ohrid. Finally, improving safety is more likely to be achieved through better enforced road laws, education, and awareness programs than by encouraging more cars on faster roads, and alternative approaches to congestion such as discouraging large volumes of people from traveling at the same time or improving public transport could ameliorate congestion.

10. From the points listed related to the express road above, how can any overriding public interest be demonstrated?
11. What analysis has been conducted to ascertain the root cause of accidents? How often is reckless driving and intoxication a factor in road-based safety issues? Will not a faster road with greater vehicle volume simply create more road dangers?
12. Has any attempt been made to quantify whether tourists would prefer an express road or beautiful mountain scenery to be part of their Ohrid-Prespa experience? If not, to what degree is the justification that the road will improve their experience justifiable?

The issue of whether developing the tourism industry is truly a matter of overriding need as suggested by the Citrus LLP SEA in connection with the express road on page 60 should also be analyzed in more detail. Present tourism trends are identified in numerous sources, both scientific and conservation, as one of the most ominous threats to the future integrity of Lake Ohrid, and some experts believe the industry to be tipping the lake’s ecosystem over the edge. Meanwhile, a PESETA study on climate change indicates that the traditional visitor markets of northern Europe may reduce tourism flow to the south if summers warm in their home countries. This perhaps indicates that the overriding need for the area is not more development according to the same model but both a diversification of its economy into other, less damaging sectors and realignment of the current tourism offer towards more ecologically friendly forms.

13. Understanding the danger that current tourism modes are creating for Lake Ohrid, as well as the hazardous potential of mass-tourism, can an express road to facilitate more of the same really be described as a public need? Is it not a greater need that regional development evolves into different fields (already evident as successful) to reduce impact on the environment?
14. Dr. Tobias Lenz, a group leader in Evolutionary Immunogenomics at the Max Planck Institute for Evolutionary Biology explained Lake Ohrid ecosystems as harboring “biological diversity that must be protected at all costs, not only because it is the basis of life on earth, but also because it may provide information and cues towards medical therapies and biotechnological innovations of great economic value” and as offering “a unique opportunity to study the natural history of our planet”. Meanwhile, Hauffe et al explained that Lake Ohrid represents an almost globally unique example of an accessible observation theater with adequate natural and scientific infrastructure for biodiversity research, and other papers laude ancient lakes for their provision of “prime models for the study of in situ evolution” and allowance of “quasi-experimental approaches”. Given these statements, is not an express road that will add strength to modes of tourism that are undermining Lake Ohrid’s ecosystem better understood as a threat to public needs than as a benefit?

Other justifications put forward by the Citrus LLP SEA are nothing short of dizzy. At one point, the document argues that urbanization is taking place anyway, and so sees no reason not to develop infrastructure that will accelerate lakeshore construction. At another, it opines that habitats such as Oak-Hornbeam are already degraded, so running a road across them is of little consequence. This kind of logic is a downward spiral and the antithesis of nature protection. The ongoing urbanization that presently threatens Lake Ohrid and National Park Galicica is not an excuse to generate greater urbanization; it is a reason to search other solutions that will not lead to this outcome and to enforce greater protection. Existing degradation of habitats is also not a necessary condition to prime them for more destruction; it is a motivation for improving their status. The best solution to a broken window at home is not to smash another one.

15. If the degraded state of Oak-Hornbeam is justification for the express road, could not the potentially degraded state of National Park Galicica after all the projects have been completed be used as an excuse for more development in the future? At what point should this logic stop?
16. Similarly, if current trends towards urbanization excuse the construction of an express road that will cause increased urbanization, will this not create a vicious circle in which more urbanization is always accepted as a reason to allow more urbanization?
General Remarks on the SEA Contents

Project Level

The Citrus SEA proposes that many forms of assessment should be delayed to the project level. There is a fear that this will hide the cumulative and crossover impacts of the various developments, perhaps even unintentionally.
Certain of the tasks held off until the project level also would seem to be relevant to central evaluation issues. Comprehensive analysis of species and populations is lacking (page 230); overriding public interest has not been demonstrated; and carrying capacities are a mystery. All of these issues should be resolved before any further action is taken as they relate to the entire matter of whether development to National Park Galicica should be permitted in the first place.
Indeed, the Citrus LLP SEA points to the importance of dealing with issues at a strategic level on page 255.

1. If project level assessments turn up new information about species, certain aspects may prove non-offsettable. If this situation occurs, is it possible that the Ohrid-Prespa region will end up with half a ski-center, a resort with no road, or vice versa? Would this not lead to overwhelming pressure to complete projects that have environmentally damaging consequences?
2. The thorough investigation of species populations has been delayed to the project level. What guarantees are there that the project sponsors will take such evaluations seriously? How much will it cost them? What incentive will they have to fulfil this role correctly, given that it will complicate and slow their work, and generate greater expenditure? Who will monitor this process, and how can they be relied upon?
3. Since, from page 230, we understand that the current SEA has been based upon incomplete information that is not reliable and we also know that National Park Galicica is a relative hotspot for biodiversity with presence of endemic species, is it reasonable to expect that even more offsets than currently defined may be necessary? If so, where exactly will they go? If offsets are required outside the park, will this be appropriate for endemic species?
4. Do you agree that leaving important issues to the project level may cause the overall level of danger to biodiversity to be underestimated? What steps can be taken to ensure that the bigger picture remains accurate so that the full consequences of National Park Galicica development remain visible?

Artificial Snow

The Citrus LLP SEA suggests that the issue of artificial snow should be left to the project level, but, since it is of key interest to the overall viability, impact, cumulative effects and sustainability of the ski-resort in both economic and ecological terms, the issue seems appropriate for consideration at the SEA level. Numerous points require attention:
5. Given the likely relationship between the specific chemical parameters of Lake Ohrid water and its unique ecosystem, what tests will be compiled to ensure that artificial snow cannot cause any disruption?
6. The impact of artificial snow on the seasonal rhythms of Crocus cvijici is mentioned by the SEA. What other species will face disruption to their cycles as a result of prolonged snow coverage?
7. How will seasonal interactions between species, particularly those that migrate, be affected by the presence of artificial snow? How will climate change complicate this interaction?
8. How will humidity and other environmental parameters such as temperature be affected on a micro-local level by artificial snow production? How will this impact on surrounding environments?
9. How can any meaningful conclusion be completed about whether the effects of the National Park Galicica ski-resort are offsettable when so many details about artificial snow-making, such as the source of supply water, impacts of water abstraction, chemical influence and quantity of additional run-off are missing, especially considering the mountain’s particular geological structure and the lake’s sensitive water quality?
10. Certain research (not conducted locally) suggests that artificial snow has a significant effect on species composition that increases over time, and argues that ski-pistes should not be considered in areas with high conservation value. What is your response to this in reference to NP Galicica?
Underground Channels

Although the SEA mentions the connection between Lake Prespa and Lake Ohrid via underground channels, it does not discuss the impact that the various projects may have upon this system. Since the channels control the chemical specificity of Lake Ohrid’s water, and, by extension, the lentic ecosystem, any interference could have large scale ecological consequences.
1. What changes will take place either to underground channels or to the water within these channels in consequence of the five projects suggested for NP Galicica?

2. Why has so little importance been attached to this matter in the SEA?

3. Has Citrus LLP considered information given in this paper titled Assessment of Ecological Importance and Anthropogenic Change of Subaquatic Springs in Ancient Lake Ohrid?

Cumulative Impact

The SEA makes the slightly ironic comment that “given the protected nature of the area, it is reasonable to assume that no other projects are likely to be implemented in the foreseeable future.” This statement is only valid if held to within the narrow confines of the national park. Several other projects, such as the developments at Lagadin, on the northern coast of Lake Ohrid, and, most notably, at Studenchishte Marsh, are also intended for the littoral zone and their impacts could amplify the effects of the projects at Galicica.
4. How will the potential loss of Lake Ohrid’s final wetlands interact with the five development proposals, all of which will happen within the lake’s watershed?
5. Why does the Citrus Partners LLP SEA fail to make any consideration of the other projects foreseen for the Ohrid-Prespa region external to National Park Galicica, when it is reasonable to expect cumulative effects from these projects in combination with the Galicica 5? Should not the cumulative impact be recalculated with this in mind?

Rezoning proposed for National Park Galicica appears to run contrary to the Macedonian Law on Nature Protection, which apparently states that a zone must have lost its natural values before it can be reassigned. Moreover, although the SEA emphasizes that newly designated boundaries will increase the area of ZAM by 1.3% and bring the park closer to the 75% threshold laid down by the IUCN, it does not talk about how the more intensive use of the ZSU in other areas may limit the ability of the national park to make ZAM gains larger than 1.3% in the future. In other words, the NP Galicica could be exchanging a significant percentage gain in the future for a relatively insignificant one now.
The SEA does not give any explanation for why the ZAM/ZSU boundaries have been chosen in their current form. Presumably, these distinctions are not arbitrary, so an overview of how and why they have been selected appears key to the discussion of whether changing them is environmentally valid.
Finally, the SEA does not take into consideration the wider effects of rezoning or the consequences that they may have in the social arena. Rezoning in Galicica may instigate development in other protected areas across Macedonia with a cumulative impact upon biodiversity.

1. Is our understanding of the Law on Nature Protection correct that a zone must have lost its natural values before any changes in status can occur? If so, please can you demonstrate that natural values have indeed been lost?
2. Why are the present-day Zones of Active Management in their current positions? What motivated their selection?
3. Will the potential for National Park Galicica to approach the IUCN 75% benchmark for national parks be greater or lesser than the present day, if the five projects are actioned?
4. In your opinion, what message does the rezoning of national parks send to the Macedonian people about the value of conservation and nature protection? Is it likely to encourage or discourage ecological consciousness and appreciation of biodiversity?
5. If the developments are allowed to proceed in National Park Galicica, do you agree that construction in other national parks and protected areas is more likely to occur? Please explain your answer.
Considering the above the Animal and Environment Protection Association “EDEN” and the Ohrid SOS Citizens’ Initiative strongly object the implementation of the proposed projects and we recommend that the PINPG starts considering alternative tourism as a source for its financial stability, which unlike the proposed amendments to the 2011-2020 Management Plan, is in complete accordance with the law for its establishment and existence.


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