Yes all BGtoll gantries are also speed cams!
https://bnr.bg/en/post/101911996/bulgaria-s-toll-system-now-detects-speeding-fines-to-be-issued-soon

This is quite evil so the BG toll cams should be mapped as toll cams and additionally as speed cams 

https://web.archive.org/web/20231205015804/https://bnr.bg/en/post/101911996/bulgaria-s-toll-system-now-detects-speeding-fines-to-be-issued-soon

https://archive.is/IbcZT
