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Paper short abstract

NGOs in Bulgaria hybridize scientific expertise and legal mobilization to produce counter-expertise that documents ecological harm and non-compliance. This reveals the green transition as an epistemic struggle and calls for transformative environmental justice and co-governance.

Paper long abstract

Bulgaria’s green transition is widely framed as a pathway to resilience and decarbonization. Yet, it often reproduces patterns of environmental injustice by advancing projects through techno-managerial logics that constrain meaningful participation and marginalize local ecological knowledge.

Focusing on the Lobosh (Pchelina) dam, one of the largest reservoirs in southwestern Bulgaria, and broader SHPP development, this paper examines how environmental NGOs such as Balkanka and WWF Bulgaria challenge dominant state narratives. Beyond advocacy, these organizations act as producers of counter-expertise and as accountability actors within environmental governance: through independent water bodies' monitoring, expert-led reporting, and strategic legal mobilization that combines scientific expertise with legal argumentation. They generate hydrological and ecological evidence that is translated into legally actionable claims, documenting environmental harm and demonstrating systematic non-compliance with existing regulations. In doing so, they foreground conflicts between dominant techno-scientific framings and locally grounded epistemologies.

Controversies around SHPP reveal competing claims over ecological impact, and regulatory compliance, while legally entrenched water rights create institutional lock-ins that limit authorities’ responsiveness to ecological stress and public contestation. These dynamics expose the limits of formal participatory mechanisms and the absence of meaningful co-governance arrangements.

The paper argues that Bulgaria’s green transition is not a neutral technical process but a site of epistemic struggle. Democratizing the transition therefore requires a more transformative approach to environmental justice; one that redistributes epistemic and decision-making power and institutionalizes epistemic plurality, so that marginalized voices can genuinely shape socio-environmental futures.