A modern port for passenger ships and a yacht marina will be built on the island of “St. Kirik and Julita“ near Sozopol. This was announced by the Deputy Prime Minister and Minister of Transport and Communications in resignation, Grozdan Karadjov, after the government meeting. From his words we also understand that by a decision of the Cabinet of Ministers, part of the island is being transferred for management from the Ministry of Culture to the state enterprise “Port Infrastructure“ with the aim of developing the tourist infrastructure and easing the load on the fishing port in the city. So, “Port Infrastructure“ will modernize the quay wall and the entire infrastructure, will build a terminal for servicing passengers and tourist ships, a modern yacht marina, as well as a public access area with the possibility of mooring attraction ships. The Ministry of Culture will retain full access to the island and the ability to develop and protect the archaeological zone. The State Enterprise "Port Infrastructure" will also support the activities of the Center for Underwater Archaeology in Sozopol - soon an Institute for Underwater Heritage of Category 2 under the auspices of UNESCO. The property is expected to be handed over and accepted within a month, after which the development of a DETAILED DEVELOPMENT PLAN (DEP) and CONCEPTUAL PROJECT will begin. A public procurement for the implementation is expected to be announced by the summer. So far so good, something will be done "for the benefit of the family", but what have we not heard.
While the official press releases sound like a hymn to culture, archaeology and UNESCO, under the surface – as always in Sozopol – things are happening in Bulgarian. With one hand the state promises a “Center of the Black Sea Civilization“, and with the other – quietly and businesslikely – cuts up properties, draws new identifiers and distributes territories, as if the detailed development plan is an annoying formality, not a legal requirement. The Council of Ministers gives the property. The Ministry of Culture “visionaries” it. UNESCO blesses it. And somewhere along the route, without noise and without debate, one significant land plot in terms of area and characteristics turns out to be already… two. WITHOUT A PUP ENTERED INTO FORCE, BUT WITH A PROJECT FOR NEW IDENTIFIERS. Without clarity on how to ensure the identity, access, development regimes and compliance with the Law on the Territory of one of the newly formed properties. But with completely real cadastral numbers. Magic!
On paper everything is wonderful: “functional separation“, “mirror compliance“, “preservation of cultural heritage“. In reality, however, the Institute for Immovable Cultural Heritage itself admits (note - the application to the Institute was submitted on January 5, 2026, and the Institute issued a ruling on January 6, 2026, since by law it has the right to issue a ruling up to 2 months after receipt of the relevant documentation) that there are no reasons, no graphic materials, no clarity on how and whether the separation of two new land properties meets the protection regimes, but it proposes to the Minister of Culture to coordinate the submitted documentation for the “Project for amending the cadastral map and cadastral registers for the site: “Project for amending the CCiKR for PI 67800.501.577 under the CC of the city of Sozopol, Sozopol municipality, Burgas region“. Just as quickly, considering the long-standing practice of not complying with the general legal term under the Cultural Heritage Act of 4 months or more, the relevant deputy minister authorized by the Minister of Culture signed the final statement under Art. 84, para. 1 and para. 2 of the Cultural Heritage Act, thereby “legitimizing“ this rather controversial act…
And most of all - there is no answer to the simple question: how exactly is a land plot divided when there is no amendment to the PUP-Regulation Plan or at least a current PUP? Error - there will be a PUP because they will do it, which means the state is violating its own laws!
The case
With the protocol of an interdepartmental commission approved by the Minister of Culture on 10.05.2006, the territorial scope, borders and regulations for the protection of a number of archaeological sites on the territory of the city of Sozopol, including the island of “St. St. Kirik and Julita”, were determined. The Ministry of Defense is also involved here, because the protection of the cultural monument - understand the island, covers the island and a water area 200 meters wide around it. There are protocols of committees on the topic from 14.01.2010, 19.10.2021, from 25.10.2022, from 25.06.2024, etc.
From 25.10.2022, by order of the Deputy Minister of Culture, published in the Official Gazette No. 54/25.06.2024, regulations for the protection of the territory of the island of “St. St. Kirik and Julita" should be followed, because:
- It is defined as a territory for archaeological and geophysical research, conservation, restoration, exhibition and socialization of architectural and archaeological immovable cultural values.
- Urgent conservation and restoration works are required for the school building (building with identifier 67800 501.577.1), as well as for other buildings with the potential for granting the status of architectural and construction immovable cultural values (buildings with identifiers 67800.501.577.4 and 67800.501.577.5)
(b.r. – All of them fall into property 67800.501.577, which has its derivatives)
- New construction is allowed if necessary, as well as construction and installation works (repair, reconstruction, etc.) on some of the remaining existing buildings in the properties, only after the preparation of the relevant project documentation are they required to function in accordance with the purpose of the territory.
- THE PLACEMENT OF TEMPORARY MOBILE OBJECTS IS ALLOWED ONLY FOR THE PERIOD OF HOLDING CULTURAL AND EDUCATIONAL EVENTS, WITHOUT THEM BEING PERMANENTLY CONNECTED TO THE TERRAIN, IN COMPLIANCE WITH THE REQUIREMENTS OF ART. 56 OF THE ZUT.
- THE PLACEMENT OF TEMPORARY MOBILE OBJECTS IS ALLOWED ONLY FOR THE PERIOD OF HOLDING CULTURAL AND EDUCATIONAL EVENTS, WITHOUT THEM BEING PERMANENTLY CONNECTED TO THE TERRAIN, IN COMPLIANCE WITH THE REQUIREMENTS OF ART. 56 OF THE ZUT AND THE REGULATIONS FOR THE PROTECTION OF THE TERRITORY.
- Adaptation of studied spaces in which the presence of archaeological structures has not been established is allowed for temporary exhibitions, lapidary expositions, any kind of cultural events.
- The use of the existing concrete road (not reflected in the cadastral map) near the southeastern quay wall is allowed for access to land with identifier 67800.501.578 and the adjacent area provided for use by ships of the General Directorate of the Interior Ministry (Coast Guard) along 66 linear meters of the quay wall.
Interesting
With the Opinion with reference No. 33-00-0327/10.11.2010 of the Deputy Minister of Culture, a Task for the development of a PUP-PRZ for property 67800.501.577 located in the town of Sozopol, island of “St. St. Kirik and Julita" was agreed, and with the opinion with reference No. No. 33-00-014/20.01.2011 of the Deputy Minister of Culture, a PUP-Development Plan for property 67800.501.577 has been coordinated, but there is no information whether it has been approved.
What is happening
The Ministry of Culture requests coordination from the Institute for Immovable Cultural Heritage, and as a basis for coordination, Art. 83 of the Cultural Heritage Act is indicated. However, it turns out that an Application under Art. 84, para. 5 of the Land Code.
However, a SKETCH-PROJECT FOR DIVISION (DIVISION) OF LAND PROPERTY 67800.501.577 DATED 15.12.2025 AND SKETCH-PROJECT № 15-3271187 - 15.12.2025 (B.R. – THE CABINET “ZHELYAZKOV“ HAS ALREADY RESIGNED, BUT THE CASE WITH THE ISLAND, WHICH IS FROM 2010, IS FINDING A RESOLUTION RIGHT NOW???) OF LAND PROPERTY WITH IDENTIFIER 67800.501.621 ON THE BASIS OF CERTIFICATE № 25-380187-15.12.2025
According to the data from the cadastre, the land property with identifier 67800.501.577 (note - no longer exists on the cadastral map of the city of Sozopol, but the two new properties are visible) HAS ALREADY BEEN DIVISIONED AS OF TODAY'S DATE (23.12.2025) INTO TWO INDEPENDENT LAND PROPERTIES: 67800.501.621 with HTP ... “Other type of land property without a specific economic purpose" and 67800.501.622 with NTP “Other type of land property without a specific economic purpose”.
IT APPEARS THAT THE DETERMINATION OF THE TWO NEWLY FORMED LAND PROPERTIES WITH NTP “OTHER TYPE OF LAND PROPERTY WITHOUT A SPECIFIC ECONOMIC PURPOSE” DOES NOT COMPLY WITH THE PROTECTION REGIME.
The need for the separation of a land property with an independent identifier in the context of the need for activities related to the future museum and cultural center of the island is not motivated.
IT IS NOT CLEAR FROM THE DOCUMENTATION PROVIDED AT THE MOMENT HOW ACCESS TO THE NEWLY FORMED LAND PROPERTY 67800.501.621 ON THE CADASTRAL MAP OF THE TOWN OF SOZOPOL WILL BE ENSURED.
The proposed contours of the newly formed land properties do not take into account the location of the archaeological structures in the property with identifier 67800.501.577 on the cadastral map of the town of Sozopol. Some of them remain in 67800.501.621 and 67800.501.622 on the cadastral map of the city of Sozopol.
All future activities related to the violation of the integrity of the soil layer in the newly formed properties with identifiers 67800.501.621 and 67800.501.622 on the cadastral map of the city of Sozopol should be carried out after archaeological research and permission from the Municipality of Sozopol, Gospod, cadastre, RDNSK, etc. responsible institutions.
When preparing an Amendment to the Regulation Plan (ed. – such a plan will be made yet, at least that is what has been promised) in accordance with the order (ed. – without a regulation plan, the property should not be legally divided) of the Spatial Planning Act (SPA) for properties 67800.501.621 and 67800.501.622 (ed. – already registered in the cadastre???) in order to determine their functional purpose and regulatory boundaries of the land properties, they must MANDATORY HAVE A FACE (EXIT) TO A STREET or to a road within the meaning of Art. 14, para. 4 of the SPA. (no. – see property 67800.501.621)
Property 621 is in blue, and 622 in white
The assignment of the two new land properties to be envisaged for “Museum, servicing activities, exhibition of archaeological immovable cultural values and landscaping".
The future project documentation regarding land property with identifier 67800.501.577 (new 67800.501.621/ 67800.501.622) on the cadastral map of the city of Sozopol is subject to coordination in accordance with Art. 80 on the basis of Art. 83 and Art. 84 of the Land Code.
What does Art. 80 of the Land Code say
Art. 80. (1) (Amended - SG, issue 82 of 2012, effective 26.11.2012) The development plans shall determine the goals, tasks and methods for development of the protected territories for the protection of the immovable cultural heritage, bound by the protection regimes.
(2) General and detailed development plans for the protected territories and the specific rules and regulations thereto shall be prepared in accordance with the protection regimes for the immovable cultural values.
(3) (Amended - SG, issue 92 of 2009, effective 20.11.2009, amended - SG, issue 54 of 2011, amended - SG, issue 82 of 2012, effective 26.11.2012) The development plans under Art. 78 and the specific rules and regulations thereto, the tasks for their preparation and the sketches with the proposals under Art. 135, para. 2 of the Spatial Planning Act, prior to their approval, shall be coordinated in accordance with the procedure set out in Art. 84.
(4) (Amended - SG, No. 92 of 2009, effective 20.11.2009, amended - SG, No. 82 of 2012, effective 26.11.2012) DEVELOPMENT PLANS AND SPECIFIC RULES AND STANDARDS THEREOF THAT ARE NOT IN ACCORDANCE WITH THE REGIME FOR THE PROTECTION OF REAL ESTATE CULTURAL VALUES SHALL NOT BE APPROVED.)
In conclusion
The answer to how everything is done is obvious – “administratively“ and at the request of high-ranking officials in the government of our country - synchronously, with the consent of all and despite the current legislation!!! With a draft sketch. With an incoming number. With a quick “separation“ in the last days of the next “government“. Without investigating whether the archaeological structures fall into one or the other new property. Without explaining how part of a cultural value remains in one identifier, and another – in the other. Without respecting the Cultural Heritage Law and the regimes for the protection of the group immovable archaeological, architectural and historical immovable cultural value - “the island of St. St. Kirik and Julita“, with the category “national significance“. Without saying who will be responsible if tomorrow it turns out that the “port“ property is more important than the “cultural“ and we are left with yet another yacht port instead of a cultural territory.
The state talks about underwater archaeology, while on land there is classic property archaeology - excavation and wholesale burying of laws, layer by layer, until the desired property configuration is reached. All this - under the noble slogan of culture, science and international recognition.
And what of all this - the important thing is to be alive and well, right!