Are the Expendables over the Bulgarian legislation?

Are the Expendables over the Bulgarian legislation?

The shooting of the Hollywood production is affecting one of the three most significant underground bat habitats in Europe.

The Devetaki Cave hosts wintering colonies of bats, reaching up to 60 000 individuals. Therefore this unique natural landmark is a part of the NATURA 2000 European network as well as a protected area in line with the Bulgarian legislation. A total of 13 protected species of bats winter in the cave and their disturbance is strictly forbidden in this period, as they are particularly vulnerable in winter. Despite that, it turned out that in violation of the order for designation of a protected area, the Regional Inspectorate of Environment and Waters (RIEW) – Pleven has consented the shooting of the movie in the Devetaki Cave.

We have received the assurance of Boyana Film that there will be no activities, threatening the bats and other cave dwellers”, said a representative of RIEW Pleven in an interview for Radio Vidin on November 11th 2011.

Unfortunately the on-site examination carried out by the Bat Research and Conservation Center verified that the “assurance” is not kept. Large-scale constructions were reported in the cave. In addition to the specially constructed bridge, construction material is being piled up in the natural habitat, a rail is being installed, trucks and construction machinery are constantly entering the site and tens of workers are preparing the sets. The noise and light pollution are affecting the semi-dark part of the cave, as well as sites, which are certainly used by bats during winter roost.

There is no information on any permanent expert control and the scale of the negative impact on the wintering bats is presently unknown.

The question of why RIEW Pleven has “given consent” for activities which are in obvious violation of the designation order and are violating the Protected Areas Act, the Biodiversity Act as well as international agreements Bulgaria has ratified (Habitats and Birds Directives, EUROBATS Agreement) remains open.

“We are all fans of the actor cast of the Expendables and are happy that such productions are shot in Bulgaria. However, Bulgaria is a constitutional state and we cannot accept violation on the nature conservation legislation” says Elena Stoeva from Green Balkans NGO.

The Devetaki Cave is an object of international significance in terms of bat conservation. We are insisting on the Bulgarian institutions to undertake urgent measures for conserving the species of the cave” adds Antonia Hubancheva from the Bat Research and Conservation Center at NHM, BAS.

The environmentalists suppose that the team of the film production is not familiar with the significance of the object and the consequences of the shooting and consider the Bulgarian institutions primarily responsible for obeying our national legislation.

Additional information:

The cave has been designated as a natural landmark with Order No RD238 / 07.06.1996. The regimes of the protected area as stated in the designation order point 3 state as follows: “All activities, leading to disturbance, harming, killing or chasing bats are strictly forbidden.”

The access to the cave is strictly forbidden in the period June 1st – July 31st, while during the rest of the year (August 1st – May 31st) only “scientific expeditions and tourist visits” are allowed. The bare allowing of a movie crew and shooting in the cave are explicit violation of its designation order, and therefore of the Protected Areas Act and the Bulgarian legislation.

The Devetaki Cave is inhabited by 13 species of bats, enlisted as “protected” in Annex 3 at Article 37 of the Biodiversity Act. For them “chasing and disturbance, especially during breeding, raising of young, roosting or migration” are strictly forbidden.

The cave is included in two sites of the NATURA 2000 European environmental network: “Devetashko Plato” BG0000615, SCI of Directive 92/43/EC and “Devetashko plato” BG0002102 SPA of Directive 2009/147/EC.

Two of the bat species, inhabiting the Devetaki Cave and objects of conservation of the “Devetashko plato” BG0000615 site in line with Directive 92/43/EC are enlisted in the IUCN Red List: Long-fingered bat (Myotis capaccinii), Mehely’s horseshoe bat (Rhinolophus mehelyi), and the activities harming these species are criminalized by the Bulgarian legislation (the provisions of Article 278d of the Criminal code enforced for activities harming these species, and the provisions of Article 278v of the Criminal code enforced in case of damaging the protected area).
There might also be violations in the procedure of coordinating the construction of the concrete bridge with the MoEW. These will be additionally investigated.

For more information, please contact:
Antonia Hubancheva – Bat Research and Conservation Center – phone: +359 883316946, е-mail:
Dobromir Dobrinov – Green Balkans – phone: +359 884004667, е-mail:

Map of the Protected Area and the adjacent Protected Areas (BG) 1,20 MB b (pdf) download
Designation Order of the Devetaki Cave (BG) 15,00 KB b (doc) download
Signal sent by Green Balkans to the RIEW (BG) 324,00 KB b (doc) download
Signal to the Natural History Museum (BG) 36,64 KB b (pdf) download
The entrance of the cave before and after clearing off the vegetation (BG) 270,19 KB b (pdf) download