At the meeting of the Commission for the adoption of a specialized map with records of sand dunes, located outside the sea beaches “Kavatsite – Sever” and “Kavatsite – Yug”, held on 29.03.2023 in Burgas, municipality of Sozopol, it was only the representative of the MOEW that expressed a differing opinion and disagreed with the materials and data discussed during the meeting related to the location and the type of sand dunes.

The position of the MOEW in the case under consideration is dictated by the significant discrepancy in the identification of the boundaries of the sand dunes during the multiple surveys related to the procedure for developing the specialized map.

 According to the Ordinance on the creation and maintenance of specialized maps and registers of the sites under art. 6, para. 4 and 5 of the Law on the Organization of the Black Sea Coast, the sand dunes are reflected in the specialized maps and their borders are photographed after indicating their location and determining their type by a botanist, phytocenologist, and an expert in coastal geomorphology. In the last two years, in fulfillment of its responsibilities, the MOEW has entrusted the performance of these activities to various scientists and experts possessing the necessary experience and expertise in the areas related to the identification of sand dunes. They would indicate the boundaries and the type of dunes on site and the results were presented to the Office of Geodesy, Cartography, and Cadastre - Burgas.

As can be seen from the presented results and the developed projects of specialized maps, there are significant differences between the conclusions of the engaged scientists and experts who participated in the site visits. Dunes are considered on the one hand as habitats of certain plant species and communities, and as geological and geomorphological formations on the other. This specificity in the definition of sand dunes creates prerequisites for different interpretations depending on which of the characteristics relevant in determining the presence and type of dunes is leading.

The definition of sand dunes provided in the Law on the Organization of the Black Sea Coast also creates the possibility for different interpretations and leads to diverging results. The need for refinement is pressing.

In determining the presence, type and location of the dunes, objective scientific observations and expertise should be leading and the basis for making adequate decisions. In this particular case, however, the results of the studies, according to the MOEW, do not allow an objective decision to be made.

Refinement of the concept, methodology, and criteria for defining sand dunes, in a way that does not allow for different interpretations, should be a major task for the scientific and professional community, whereby the MOEW will provide full assistance.