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Victory for Citizens: Court Puts an End to Contentious Incineration Project in Sofia

On 2nd May, the Bulgarian Supreme Administrative Court finally decided against the controversial RDF-fueled 180 000 Euro-incineration plant project in the center of Sofia. This decision overturns the 2015 permission granted by the Director of the Regional Environmental and Water Inspectorate, which endorsed Sofia Municipality’s investment plan. Culminating after a lengthy legal battle, this ruling underscores serious deficiencies in public participation and health risk assessment by the authorities.

Initiated nearly a decade ago, the incinerator faced opposition from Environmental Association Za Zemiata, citing significant health risks. The concerns raised were supported by other local and European NGOs, such as CEE Bankwatch Network and Zero Waste Europe. The Administrative Court, echoing concerns raised by citizens and environmentalists, highlighted shortcomings in the air quality impact analysis, failing to account for Sofia’s already high pollution levels. Moreover, citizens expressed concerns that alternative solutions could offer better results in reducing air pollution if properly evaluated.

The European Commission and the European Investment Bank, both approved preliminary funding for the project, disregarding repeated local objections for over a decade. The incinerator was expected to consume up to 30 percent of EU cohesion policy funding for waste management in Bulgaria for the period 2014 to 2020. Earlier last year, the Sofia Municipal Council decided to return EU funding allocated for the project due to legal, administrative, and technical delays, failing to meet the 2023 completion deadline. The court decision reiterates authorities’ failure to ensure adequate public participation and health risk assessment, alongside critiquing inadequate risk evaluations for emissions, including highly carcinogenic substances, and toxic ash production.

Furthermore, the Environmental Impact Assessment (EIA) was faulted for relying on unreliable data for waste estimation which exact details continue to be kept secret from the community. Additionally, the court criticised the inadequate risk assessment of the emissions of highly carcinogenic dioxins and furans, as well as the large amounts of toxic ash the plant would produce.

The planned incinerator’s capacity was set to exceed current RDF production in Sofia by threefold, raising environmental and safety concerns. Unfortunately, the persistence of the municipality to defend this project diverts attention and funding from urgently needed waste management actions such as separate collection and biowaste composting, mandated across the EU from the end of 2023.

This court decision came in the wake of failed attempts for legislative changes at the National Parliament to water down the Environmental protection act and the Environmental Impact Assessment procedures.  

The Administrative court decision confirmed by the Supreme Administrative court translated in English.

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Call for consultants for study on sustainable heating solutions in the Tsarkva neighbourhood of Pernik, Bulgaria

Za Zemiata / CEE Bankwatch Network is looking for a consultant to map the existing situation and identify and analyse sustainable heating solutions for the Tsarkva neighbourhood of Pernik in Bulgaria. 

Za Zemiata and CEE Bankwatch Network are working extensively on implementing a just transition away from fossil fuels in a number of countries in the CEE region, including Bulgaria. Decarbonising the heating sector is a key issue, as the district heating systems in the just transition regions are dominated by coal. 

With funding available from the Just Transition Fund, this is a good time to consider what some solutions for decarbonising the heating in Pernik might be, focusing on buildings that are not connected to the district heating system as a pilot project.  

Pernik is a city with around 80,000 inhabitants; the main district heating provider is Toplofikacia Pernik, and Pernik is the town in Bulgaria with the hightest percentage of district heating customers. The district heating system runs on coal with some biomass. The quaity of the district heating service is questionable, which can be seen from the various accidents with the heat supply in the city which often leave consumers without heating in the winter. One of the key issues with decarbonising the district heating in Pernik is the fact that it is privately owned, therefore the local authority has very limited influence over the decarbonisation process. This is why the municipality is exploring alternative solutions, such as alternative district heating or smaller localised district heating units. Coming up with a solution in a timely manner is of key importance as the district heating operating company has not indicated any interest in decarbonising. 

Subject of the proposal 

The objective of the study is to provide a technical analysis of the current heating situation in Pernik with a specific focus on Tsarvka neighbourhood, which is not connected to the existing district heating. Within the study, it would be beneficial to sketch out what opportunities for district heating based on renewables might be suitable for the area. In addition to a technical feasibility study, an economic feasibility study should be covered by the report, in order to serve as a basis for developing a business case in the future. 

The study will be used to form the groundwork for the heating decarbonisation plan for Pernik’s Tsarkva neighbourhood, help inform decisionmakers’ opinions on what approach to take to sustainable distict heating, and start a conversation on potential funding sources and potential pilot project opportunities. 

The study should be approximately 35-40 pages long. It will be written in Bulgarian and translated in English, with the consultant responsible for translating the Executive Summary. The study should include the following:

1. Executive summary (2 pages)

2. Introduction (2 pages)

 – Outline of the heating situation in Pernik with information about the current heating demand

3. Mapping of the current situation (5 pages)

– Mapping of available data specifically relevant to the Tsarkva neighbourhood and Pernik in local authority documents and – where relevant – government and other stakeholder reports, as well as of the technical and economic aspects of various components of the energy transition in Tsarkva and Pernik (desk research)  

Characteristics of Tsarkva’s heating and cooling systems: size, infrastructure, fuel sources, ownership (some element of field research might be necessary)

4. Recommendations of preferred solutions  (25 pages)

Calculating the renewable potential: this may include deep geothermal, heat pumps, waste heat from industry (not the coal power plant ), solar thermal, heat storage, etc. Biomass should only be considered as a last resort and should not include primary forest biomass, only offcuts from sawmills, crop residues etc.  

– What alternatives might be available in the area and guidance on what the preferred approach should be – technical feasibility aspect 

– What is the economically feasible potential and costs identified with the preferred approaches?

5. Conclusions (2 pages)

The final publication outline will be agreed upon with the consultant prior to the beginning of their work. The consultant will be responsible for drafting the study, and is expected to produce two drafts and a final version. Bankwatch staff will provide comments on the drafts, and will be responsible for the proofreading, translation, design and distribution of the publication. The study will be published, and the consultant should be willing to be mentioned publicly as author. Based on the study, Bankwatch will also produce a shorter briefing paper for policymakers and a wider audience. The consultant might be required to make a few appearances at events (including local events and topical events such as webinars) in order to promote the study and its findings. Any such appearances will be organised and costs covered separately. 


Date  Task due  
26 February  Deadline for submitting offers 
29 February  Selecting the consultant; results from the selection process are communicated to applicants 
5 March  Contract signing; initial coordination call with consultant to discuss general outline of the study 
March – September  Data gathering, analysis and writing 
2 September   First draft; Executive summary complete 
13 September  First round comments 
1 October  Second draft 
14 October  Final comments 
25 October  Final version revised 
4 November  Study published 


A maximum of EUR 10 000 including VAT, half of it to be paid upon the delivery of the first draft and the difference upon delivery of the final version of the study.  


Experts in the field of sustainable energy, with a background in engineering or similar. They should have extensive knowledge of the heating sector and of renewable energy sources. Excellent knowledge of English is required. Knowledge of or previous experience specific to Bulgaria is required.   

How to apply 

Applicants should submit their offers by 26 February to t.todorov@zazemiata.org and veni.kojouharova@zazemiata.org  

The offer should contain: 

  1. CV highlighting the required qualifications and experience.
  2. Application consisting of technical and financial elements. The technical elements comprise a 2-page outline proposal for the study. This should include the consultant’s proposed methodology. The financial elements comprise the financial offer including VAT. The candidate should name at least two references who have agreed to support the application. 
  3. Examples of similar previous work are welcome in support of the application.
  4. Signed statement certifying that the candidate does not fall into any situation that is grounds for exclusion from participation in the procurement (according to Bankwatch’s internal procedures).


The selection criteria will consist of: 

1) Professional capacities: the strength of CV, past reports, reference list of experience in similar or related projects; 

2) Quality of project proposal and alignment with requirements to consider only sustainable energy forms; 

3) Financial offer; 

4) Other added value to the analysis (e.g. knowledge of the local language). 

Applicants will be informed about the selection results by 29 February.  


Candidates will be excluded from participation in a procurement procedure if: 
  • they are bankrupt or being wound up, are having their affairs administered by the courts, have entered into an arrangement with creditors, have suspended business activities, are the subject of proceedings concerning these matters, or are in any analogous situation arising from a similar procedure provided for in national legislation or regulations; 
  • they have been convicted for an offence concerning their professional conduct by a judgement which has the force of res judicata; 
  • they have been guilty of grave professional misconduct proven by any means justifiable; 
  • they have not fulfilled obligations relating to the payment of social security contributions or the payment of taxes in accordance with the legal provisions of the country in which they are established or with those of the country where the contract is to be performed; 
  • they have been the subject of a judgement which has the force of res judicata for fraud, corruption, involvement in a criminal organisation or any other illegal activity detrimental to the Communities’ financial interests; 
  • they are currently subject to an administrative penalty referred to in section 2.3.5 of the Practical Guide to contract procedures for EC external actions: 
Without prejudice to the application of penalties laid down in the contract, candidates or tenderers and contractors who have made false declarations, have made substantial errors or committed irregularities and fraud, or have been found in serious breach of their contractual obligations may be excluded from all contracts and grants financed by the Community budget for a maximum of five years from the date on which the infringement is established, as confirmed following an adversarial procedure with the contractor. That period may be extended to 10 years in the event of a repeated offence within five years of the above-mentioned date. Tenderers or candidates who have made false declarations, have committed substantial errors or irregularities and fraud, may also be subject to financial penalties representing 2% to 10% of the total estimated value of the contract being awarded. Contractors who have been found in serious breach of their contractual obligations may be subject to financial penalties representing 2% to 10% of the total value of the contract in question. That rate may be increased to 4% to 20% in the event of a repeat infringement within five years of the above-mentioned. Where the award procedure proves to have been subject to substantial errors, irregularities or fraud, the Commission shall suspend the procedure and may take whatever measures are necessary, including the cancellation of the procedure. Where, after the award of the contract, the award procedure or the performance of the contract prove to have been subject to substantial errors, irregularities or fraud, the Commission may, depending on the stage reached in the procedure, refrain from concluding the contract or suspend performance of the contract or, where appropriate, terminate the contract. Where such errors, irregularities or fraud are attributable to the contractor, the Commission may in addition refuse to make payments, may recover amounts already paid or may terminate all the contracts concluded with this contractor, in proportion to the seriousness of the errors, irregularities or fraud. The purpose of suspending the contract is to verify whether presumed substantial errors and irregularities or fraud have actually occurred. If they are not confirmed, performance of the contract will resume as soon as possible. A substantial error or irregularity is any infringement of a provision of a contract or regulation resulting from an act or an omission which causes or might cause a loss to the Community budget. 

Executive summary of the report ‘NRRP and the second instalment – is there real progress?’

Author: Petko Kovachev, commissioned by Za Zemiata (Friends of the Earth – Bulgaria)

/The full report, available only in Bulgarian, presents the state of play as of 17 October 2023/


‘On October 7, 2023, Bulgaria officially submitted the documents necessary to receive the second payment under the National Recovery and Resilience Plan (NRRP). This was possible after more than 30 measures were implemented in the last three months. This allowed to catch up with the serious delay in the implementation of the NRRP, as the deadline for these measures was the end of 2022, but they were not delivered on time’. This is how the Ministry of Finance’s communication from 09.10.2023 starts, concerning the second NRRP payment(1)


In our report ‘NRRP and the second instalment – is there real progress?’ we reviewed the implementation of the reforms and investments under the NRRP which are relevant to the implementation of climate policies and for the transition to decarbonisation until mid-October 2023. We reviewed not only activities linked to the energy sector but also those linked to transport, energy efficiency and environmental protection (specifically biodiversity and water management). 


The risks that the successful implementations of the reforms and investments faced have manifested themselves almost in full. These were political, administrative, economic and external. Amongst the political risks, we highlight the political instability, the frequent elections, the lack of regular governments, the lack of political support for certain reforms and projects, as well as their acceptance, delays in the adoption of legal acts, and corruption. The role of trade unions has been significant, as they – often in conjunction with employers’ organisations – have directly or indirectly attacked exactly these NRRP measures. 


The general failings of the administration in general and in particular the Мinistries of Еnergy, Еnvironment and Waters, Regional Development and Public Works, Transport and Communication also has contributed significantly to the delays and stalling of reforms and projects. It is an issue of low capacity but also direct or indirect attempts to resist certain reforms and projects – coupled with concrete actions or inactions, – as well as the corruptive connections of members of the administration. 


Within 2022 (May – September), Bulgaria implemented 22 reforms and projects, which make up the first set of interim targets. Their completion was the condition to receive the first advance payment. With a lot of effort and in a tense political environment, the package was successfully implemented and the first instalment of EUR 1368.9 mln was paid on 16.12.2022. This is how the first (tentative) stage of the implementation of the NRRP was completed. 


By mid-October 2023, when our review period ends, the implementation of the Plan progresses through two more (tentative) stages: 

  1. Second stage: from the receipt of the first instalment to the commencement of the current regular government (16.12.2022 – 06.06.2023).
  2. Third stage with two sub-stages:
  • From 06.06 until mid-September 2023;
  • From mid-September until 07.10.2023.


The second stage is characterised by delays and attempts to amend some of the commitments. Here, on one hand, there is the objective impossibility of adopting legislative reforms due to the absence of a government, but on the other hand – the willingness and efforts by the administration to design these reforms and projects in a way that is strongly influenced by the political and inter-institutional wars in the country. Furthermore, the 48th National Assembly adopted the Decision from 12.01.2023 to significantly renegotiate the NRRP precisely in the field of climate and energy policies. This decision predetermined part of the actions of the subsequent governments and the next 49th National Assembly. At this stage most of the key milestones needed to obtain the second and third NRRP payments were blocked. 


The third stage (from 06.06.2023) started with the loss of valuable time – the period until the end of August was not used effectively. It coincided with the deadline to submit the Territorial Just Transition Plans (TJTPs) and this created an extremely tense situation. The Cabinet presented the main legislative proposals: the Energy Act (EA) and the Renewable Energy Act (REA) as it received them from the caretaker government. These offered formal compliance rather than high quality. 


In the beginning of September, 32 out of the 66 milestones needed to receive the second instalment were still outstanding, including 17 out of the 27 reforms and investments linked to energy and energy efficiency (Таблица 1 и 2/ Table 1 and 2, page 11 – data from EUMIS from 07.09.2023).


Table 1 

Payment Total milestones Fulfilled Unfulfilled Climate, energy and energy efficiency targets  Fulfilled targets for climate, energy and energy efficiency Unfulfilled targets for climate, energy and energy efficiency
1 2 3 4 5 6 7
1 22 22 0 4 4 0
2 66 34 32 27 10 17
3 46 3 43 18 1 17
4 41 0 41 19 0 19
Total: 175 59 116 68 15 53
Source: author’s calculations based on EUMIS data as of 07.09.2023 


For the purposes of this analysis, the climate, energy and energy efficiency milestones of the NRRP include also milestones that have been identified by the author as contributing indirectly to these areas.

Column 1 shows the numbers of advance payments up to the end of 2023. In column 2, the total number of intermediate targets (milestones) for each advance payment; in column 3, the number of milestones fulfilled for each payment; in column 4, the number of milestones not fulfilled for each payment; in column 5, the climate, energy and energy efficiency targets identified in each payment; in column 6, the climate, energy and energy efficiency targets fulfilled; in column 7, the climate, energy and energy efficiency targets not fulfilled.

The distribution of the 68 climate, energy and energy efficiency targets (including good governance) is as follows:


Table 2

Ministry Total Fulfilled Unfulfilled
1 2 3 4
Ministry of Energy (ME) 23 5 18
Ministry of Environment and Waters (MOEW)  4 0 4
Ministry of Regional Development and Public Works (MRDPW)   10 5 5
Ministry of Transport and Communication (MTC)   12 2 10
Ministry of Economy and Industry 1 1 0
Ministry of Agriculture and Food 3 0 3
Ministry of Innovation and Growth  8 2 6
МE/Ministry of Innovation and Growth (MIG)  1 0 1
MOEW/ME 3 0 3
Total: 68 15 53
Source: author’s calculations based on EUMIS data as of 07.09.2023.


The table reflects the change of the responsible ministry for the development of the Mobility Promotion Act – MIG instead of MOEW. 

Column 1 – responsible institution; column 2 – total number of climate, energy and energy efficiency milestones for which the institution is responsible for the four advance payments; column 3 – number of climate, energy and energy efficiency milestones fulfilled; column 4 – number of climate, energy and energy efficiency milestones not fulfilled.

Since mid-September, mass mobilisation has started in order to fulfil the conditions to receive the second payment under the NRRP. The issue was not just the NRRP implementation progress, but also the expectation that these funds will solve some of the budgetary issues. Under extreme time pressure and pressure from the Ministry of Finance formal progress was made, and in the end 62 out of the 66 milestones needed to receive the second instalment were reported. Was this the quality implementation sufficient to move forward the necessary decarbonisation and green transition actions? Our answer is – likely no. 


In this complex environment the implementation of various reforms and the delivery of investments have been carried out with varying speed, quality and completeness. There were cases in which the reform started on time and in the implementation process there were objective or subjective issues, delays, postponements and in the end – a sprint to complete them in the last possible moment. This is what happened with the drafting of the Roadmap to Climate Neutrality and with the adoption of the amendments to the two key legislative acts in the energy sector – the Energy Act and the Renewable Energy Act. Investments in the transport sector happened under complete lack of transparency and there is still no information about how some of the reforms have happened and what result has been achieved, but they have still been marked as completed in the Information System for the Management and Monitoring of EU Funds in Bulgaria (EUMIS).


On the other hand, there is good progress in the energy efficiency programmes in buildings, specifically in the part related to public consultations, announcements and tendering. It remains to be seen how the actual works will be carried out. There is one big weakness here, however, which is relevant as a whole to the implementation of energy efficiency policies. There is a lack of an adequate campaign to explain to citizens what the benefits of their financial contributions to these programmes are. This is why there is currently a low level of interest in the newly announced tenders which are no longer 100% grant schemes. 


Work within the main institution responsible for decarbonisation – the Ministry of Energy – was slow, there was a lack of communication with the stakeholders, the reform proposals were on the verge of only meeting the minimum requirements, and the texts needed to actually carry out the projects were not drafted. This is particularly relevant for the reforms related to active citizens, energy communities and others. We believe that significant internal changes need to happen in the Ministry of Energy if Bulgaria wants to speed up its implementation processes and to fulfil the set targets. The same can be said for the other two ministries – of Environment and Waters and the Regional Development and Public Works, where strong motivation is needed to carry out the activities linked to the NRRP. 


In the end of August, the tension caused by the large number of key milestones that were not implemented was already felt (it should be recalled that 32 out of the 66 milestones needed to receive the second payment instalment were still not completed in the beginning of September, including 17 of the 27 reforms and investments linked to energy and energy efficiency). The attempts to finalise the TJTPs for the just transition of the coal regions and the Roadmap for Climate Neutrality generated resistance amongst miners and energy workers in the Maritsa East power complex. Their attacks were also extended towards the NRRP. 


In the meantime, the Council of Ministers and the National Assembly have been rapidly adopting the final amendments to the Law on Amendment and Supplementation of the Renewable Energy Act and the Energy Act, as well as all other reforms. This rush leads to formal decisions which do not guarantee the successful implementation of the reforms. A typical example of this are the legislative amendments related to prosumers/active citizens/active customers and energy communities which we can already identify as not working – without further legislative amendments. 


On 28.09.2023, the Council of Ministers approved a draft update of the budget under the National Recovery and Resilience Plan of the Republic of Bulgaria in light of the reduced maximum EU grant funding, calculated in accordance with Article 11 (2) of Regulation (EU) 2021/241, tasked the Minister of Finance to inform the European Commission of this decision and authorised him to conduct negotiations with the Commission during the procedure for the assessment of the submitted draft. The draft itself is a list of NRRP investments for which it is proposed to either be removed completely or for their funding to be modified. Under this decision, two very important projects, related to decarbonisation and conservation of natural resources were dropped: C8.I4. Intermodal Terminal Ruse and C9.I2. Digitalisation for integrated management, control and efficient use of water. For years Bulgaria has been postoping the construction of intermodal terminals which would reduce the transit road traffic at the expense of rail traffic; water management in the country leads to a huge waste of this resource. 


There is reduced funding for four other investments in energy and energy efficiency: C3.I2, Investment 2.2a Grant scheme for combining renewable electricity sources with local storage (for enterprises – editor’s note), C4.I1 Support for the renovation of building stock, C4.I5 Pilot projects for the production of green hydrogen and biogas, and C4.I8. National infrastructure for storage of electricity from renewables (RESTORE). The reduction in funding for these projects is BGN 950 564 139 or 26.13% of their total value. At the same time, this represents 83.81% of the total funds reduction for the entire NRRP, amounting to BGN 1 134 239 406. Together with the dropped projects worth BGN 180 160 000, the total amount of the reduction in energy and climate related projects is 99.69%. In other words, the main fund reductions are at expense of the most important goal of the NRRP – the decarbonisation of the Bulgarian energy sector and the transition to a green economy. 


Here is the final result – after the completion of the interventions on the measures that had to be prepared in order to receive the second NRRP payment (15.10.2023): 


Table 1А

Payment Total milestones Fulfilled Unfulfilled Climate, energy and energy efficiency targets  Fulfilled targets for climate, energy and energy efficiency Unfulfilled targets for climate, energy and energy efficiency
1 2 3 4 5 6 7
1 22 22 0 4 4 0
2 66 62 4 27 25 2
3 46 6 40 18 1 17
4 41 2 39 19 2 17
Total: 175 59 116 63 32 36
Source: author’s calculations based on EUMIS data as of 15.10.2023.


For the purposes of this analysis, the climate, energy and energy efficiency milestones of the NRRP include also milestones that have been identified by the author as contributing indirectly to these areas.

Column 1 shows the numbers of advance payments up to the end of 2023. In column 2, the total number of intermediate targets (milestones) for each advance payment; in column 3, the number of milestones fulfilled for each payment; in column 4, the number of milestones not fulfilled for each payment; in column 5, the climate, energy and energy efficiency targets identified in each payment; in column 6, the climate, energy and energy efficiency targets fulfilled; in column 7, the climate, energy and energy efficiency targets not fulfilled.

The distribution of the 116 climate, energy and energy efficiency targets (including good governance) is as follows:


Table 2А

Ministry Total Fulfilled Unfulfilled
Second payment instalment Total Second payment instalment Total Second payment instalment 
1 2 3 4 5 6 7
Ministry of Energy (ME) 23 12 13 12 10 0
Ministry of Environment and Waters (MOEW)  4 2 2 2 2 0
Ministry of Regional Development and Public Works (MRDPW)   10 5 6 5 4 0
Ministry of Transport and Communication (MTC)   12 5 5 3 7 2
Ministry of Economy and Industry 1 0 1 0 0 0
Ministry of Agriculture and Food 3 0 0 0 3 0
Ministry of Innovation and Growth  8 2 3 2 5 0
МE/Ministry of Innovation and Growth (MIG)  1 0 0 0 1 0
MOEW/ME 3 0 0 0 3 0
MRDPW/ME/SEDA 2 1 2 1 0 0
MRDPW/MEOW/MTC/ME 1 0 0 0 1 0
Total: 68 27 32 25 36 2
Source: author’s calculations based on EUMIS data as of 15.10.2023.


The table reflects the change of the responsible ministry for the development of the Mobility Promotion Act – MIG instead of MOEW. 

Column 1 – responsible institution; column 2 – total number of climate, energy and energy efficiency milestones for which the institution is responsible for the four advance payments; column 3 – number of climate, energy and energy efficiency milestones for which the institution is responsible for the second payment; column 4 – number of climate, energy and energy efficiency milestones fulfilled; column 5 – milestones fulfilled for the second payment; column 6 – number of climate, energy and energy efficiency milestones not fulfilled; column 7 – milestones not fulfilled for the second payment.


What conclusions could we draw?

  1. The prolonged political crisis is a destroyer of good and timely decisions. The main damage is:
    • It causes politicians to speak untruths and to attack sensible proposals (in this case – related to NRRP) due to purely expedient political and personal ambitions;
    • It hinders and even blocks the possibility of adequate communication with the other stakeholders on specific issues or on the whole NRRP. 
  2. As usual, the old weakness of the administration has manifested itself: to expect instructions for every action, for every step in one direction or another. At the same time we can see again that where the status quo needs to be preserved, bureaucrats do not hesitate to act. If we want to make progress and to use EU funds efficiently, as well as national funds, we need to commit to a fundamental reform of the administration of all levels.
  3.  It has become clear that the interdependence of strategic documents and plans such as the NRRP, the National Energy and Climate Plan and the TJTPs can play a bad trick, especially in a period of crises with the threads of blockades, strikes and political attacks (demands for resignations). This requires a very strong communication strategy to all stakeholders which is currently lacking.
  4. Part of this communication strategy is the system EUMIS (Information System for Management and Monitoring of EU funds in Bulgaria). Unfortunately, in the process of drafting this report, we have encountered some serious flaws. Two of these are the following: 1) the lack of information updates (for example when a certain reform is transferred from one institution to another) and 2) the lack of information for procedures that are allegedly closed. The cases, outlined in Annex 2, provide us with a reason to request an extensive review of EUMIS by its managers. The system is Bulgaria’s contribution to efforts to make it easier to work with potential EU funds beneficiaries, to clear public communication and open information. It would be a shame to lose this valuable asset (and to compromise its credibility). 
  5. With regards to the quality of the NRRP activities of interest to us in the last 12-15 months, as we have often pointed out, requires a separate analysis. Here we have attempted to touch upon some elements of such a qualitative analysis but within the timeframe, which coincided with the second substage of the third stage of NRRP implementation, such a comprehensive examination has been impossible to conduct. 


There will now be two months of negotiations with the European Commission on the second payment instalment request. When and how it will occur and whether in the meantime the implementation of commitments, related to the receipt of the third and fourth payment, what deadline extensions will be agreed on them and also how the implementation of the already reported investments and reforms will continue, remains to be seen. We will follow these because they are important for Bulgaria. Not for yet another transition but for its sustainable progress towards decarbonisation, towards a greener economy and a greener life. 

  1. https://www.minfin.bg/bg/news/12357


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Pernik: an example of successful energy transformation or a hostage of the corporate interests of energy oligarchs and trade unions in Stara Zagora?

The political crisis that has lasted for more than two years has completely blocked the processes of energy and economic transformation.

Because of politicians’ subordinance to lobby interests that call for the continued use of coal, at the end of 2022 Bulgaria lost EUR 100 million from the Just Transition Fund (JTF) due to the missed submission deadline to the European Commission of the Territorial Just Transition Plans (TJTPs) for the three coal regions: Stara Zagora, Pernik, and Kyustendil.

Thus, at the end of 2023, Bulgaria remains the only country out of all the EU Member States that does not have approved Territorial Just Transition Plans. 

At the end of September, we saw trade union protests blocking major highways while holding and chanting anti-EU slogans, targeting the European Green Deal and the TJTPs. This showed the continued trend of manipulating the people in the Stara Zagora region.

In fact, these protests have further blocked the government’s work to finalise and send the plans to Brussels. They have also led to the signing of an absurd agreement between the government and the trade unions, which contains unrealistic demands and promises. However, a further outcome is a situation in which the interests of Pernik and Kyustendil are not taken into account in any way.

In fact, the funds from the Just Transition Fund are of crucial importance for Pernik because this region is ready to undertake the energy transition. It is evident that the municipality of Pernik has very ambitious plans to make an economic and energy transition, with work already underway on some of the projects.

The resources from the fund, which amount to around EUR 92 million, could attract and multiply private capital and make the process of the region’s energy and economic transition even more certain. Pernik has the desire and the opportunity to become a positive example of a successful energy transition that could unlock the process for other regions.

The municipality is implementing the replacement of public transport buses with new and environmentally friendly ones in connection with the ambition to improve the air quality in the city. Improving the energy efficiency of buildings is also an important part of the measures that are set out in the municipal plans, along with the replacement of the heating appliances of some households in the city with environmentally friendly alternatives. An industrial park relying on renewable energy technologies is also planned.

These ambitions of the municipality, combined with the low level of unemployment in Pernik and in the region, are good precursors of a successful energy and economic transition.

For more than seven years, Za Zemiata (Friends of the Earth – Bulgaria) and CEE Bankwatch have enjoyed good cooperation with active civil society organisations in Pernik on important issues for the city, such as clean air and illegal coal mining, and in the last four years, there has also been favourable cooperation with the municipality. 

The blocking of Pernik and Kyustendil from receiving funds due to the lack of readiness in Stara Zagora and the surrounding region cannot continue, as the time frames for the preparation, submission, funding and implementation of activities under the JTF projects are very short and rely on quick action and timely planning.

We urge the government to take immediate action to ensure that the adoption of the Territorial Just Transition Plans by the European Commission is no longer delayed and to make the necessary changes to the plans in order to unlock the much-needed funds for the coal regions.

Politicians should remember that the TJTPs and these European funds are intended for the development of small and medium-sized businesses, the creation of new, green jobs and the reskilling of those employed in the sector, where necessary and if they are willing.

Blocking and delaying the energy transition process due to lobbying interests will worsen the consequences of the inevitable, gradual closure of the coal industry for economic reasons. And with the closure of the mines and the coal-fired power plants due to lack of capacity to compete with other players in the European energy market, there will no longer be the possibility to use the Just Transition Fund and other EU funds to mitigate the effects of this change on those employed in the sector.


Bulgaria-plans for 4 new nuclear reactors in a time of long political crisis

Although in Bulgaria we had 5 parliamentary elections in 2 years, the policies regarding the nuclear the energy did not change.

Politicians and Parliament made decisions to build 4 new nuclear reactors. 2 in Kozloduy and 2 in Belene. They choose Western reactors without giving up the Russian reactors in Belene.

On May 12.2023, the Constitutional Court rejected the request of deputies from the pro-Russian, pro-nuclear parties of the Socialists (BSP) and „Vazrazhdane“ to establish the unconstitutionality of a decision of the 48th Parliament to conduct negotiations with the US government regarding the conclusion of a construction agreement of new nuclear power at the Kozloduy NPP with the AP 1000 technology, adopted by the parliament on January 12, 2023. These parties are in favor of using Russian reactors, for this reason they wanted the Constitutional Court to stop the parliament’s decision on the AP 1000.

18.5.2023 The French energy company „Electrites de France“ (EDF) has presented, through Bulgarian Energy Minister Rosen Hristov, a detailed plan of how a pre-project study would be carried out on the possibilities of completing the frozen project for the construction of the Belene NPP.

An engineering contract is to be developed and signed for the construction of two units of 1,000 megawatts each, using the existing Russian VVER-1000 equipment at the Belene site. Their completion with French conventional technology is pending. This will be the subject of the contract.The caretaker government’s intention to sign an engineering contract with France’s EDF to study whether Belene NPP could be completed using Western technology was announced at the end of March. Previously, the Minister of Energy informed that such a study is planned to be conducted by the American „Westinghouse“ for two new reactors at the site of the Kozloduy NPP.

According to the analysis plan submitted by EDF, this will take between nine months and one year, the energy department explained.

It is likely that for both analyzes – from EDF and Westinghouse, the National Electric Company, owner of the assets for the Belene NPP, and the Kozloduy NPP New Powers company, specially created for new reactors in Kozloduy, will pay respectively

Of course, it should be kept in mind that these contracts refer only to pre-project engineering studies and not to construction.

Photo: Unsplash

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Stara Zagora and the region between the ‘bright’ coal past and the green future

In February and March, Za Zemiata (Friends of the Earth Bulgaria) organised several events in Stara Zagora and Galabovo, dedicated to the just energy transition and the opportunities it provides for the development of the region. The meetings were attended by stakeholders who have so far been absent from the dialogue, but whose voice is key for the future of the region – representatives of the civil society, of the small and medium enterprises, academics from the Thracian University. Despite the efforts to foster a dialogue between business, civil society, academia and the institutions, the absence of the municipality, which was invited but did not attend the meetings, was notable.

Our organisation and participation in these events, as well as in events organised by other civil society organisations, are part of our information campaign in the coal regions on the topic of just energy transition, the Territorial Just Transition Plans (TJTP) and the opportunities they provide for the overall development of the coal regions. 

The information campaign is, in fact, part of the government’s core obligations in relation to the Just Transition Mechanism, rather than an obligation of the NGO sector. 

Unfortunately, we have seen the absence of such a campaign at the national level, with the President, government and politicians instead preferring to focus on fighting for people’s votes in yet another snap general election (the fifth in two years).

The main problem in the coal regions is the lack of transparency in decision-making, the lack of information, which is a responsibility of the government. There is no way to have a successful energy transition, if people do not have information about what this transition is and how it will impact them, there is no information about the potential for positive change. All that is heard is what is in the media – the threats of the representatives of the mines, the thermal power plants and the accompanying voices of the syndicates and politicians that with the transition away from coal, people will be left without jobs and with no prospects. 

During the protest against the pollution from the Brickell TPP and the Maritza 3 TPP in September last year.

At the meetings, we noticed a very different sentiment from what is being presented in the media as ‘people’s opinions’ – in fact, the moment they get information, people become more open to change and start thinking about alternative solutions and the development of other industries. The claim that there will be no jobs and people will be left on the streets also proved to be untrue. Representatives from the Employers’ Club, the Thracian University, the Chamber of Builders, and people from the enterprises in the area all say that they have an issue with finding staff. That then is to say, there are jobs, but the workforce has been absorbed by the mines. If investment in the industrial zone were not stopped, it has the potential to develop and therefore to attract more new businesses with new job opportunities. 

When we presented the real guidelines in the draft for the Territorial Just Transition Plan for Stara Zagora and the region, and the highlights from the Just Transition Fund, we noticed that for most representatives of the civil society, the small and medium enterprises, this was new information. For two years politicians and the different governments had not found it necessary to ask the people in the region what their suggestions and preferences are. This is a huge loss of public energy, of the prospect of using people’s expertise in favour of producing better territorial plans, tailored to the specificities of the region. 

Even though there is a historical attachment to the coal industry, it is far from the only thing in the region. People are proud of their cultural and historical heritage which they want to develop, as well as with their fertile lands that have potential for development. There is a recognition that all other industries have been disrupted at the expense of mine development. 

During the protest against the pollution from the Brickell TPP and the Maritza 3 TPP in September last year.

At our meeting in Galabovo, one of the most affected places, people were unanimous that no government representatives or politicians had come to them to inform them about the territorial plans or to ask them about their opinions. The confusion of the roles of the non-governmental sector and the government on their part proved that people need to hold someone accountable for this lack of transparency. The positions of the local citizens refuted the claims of politicians and trade unions that everyone in the region wants for the mines and TPP Brikel to continue to operate – an important highlight was that everyone was against Brikel, which is poisoning people in the town, although a large part of the lives of the participants in the meetings has passed there. All examples of corruption and illegal pollution of the region by this power plant are known, as well as the cover-up of the problems by the responsible authorities. Any politician that goes to Galabovo and promises to preserve jobs in TPP Brikel should know that he is promising to continue poisoning people with air rich in various chemical compounds based on sulphur and nitrogen, that are harmful to them. 

The lack of vision and strategy at a level further than the next elections was demonstrated by politicians, as the necessary reforms in the energy sector which have the potential to unlock investments and open the market in Bulgaria, were sacrificed for the sake of party and oligarchic interests to preserve the status quo and the energy megaprojects. Even the loss of €98 million at the end of 2022 due to the failure to submit the Territorial Just Transition Plans also failed to awaken the sense of responsibility of the politicians. 

People are not prepared by the government for the upcoming changes in the energy sector, and it is the duty of politicians to present correct information for the opportunities that the energy transition gives to people and regions. If the government is not prepared to implement a smooth and just energy transition, to draw up quality territorial plans and send them to Brussels, the Bulgarian people will miss the opportunity to use EU funds for a smooth transition. What will happen is that economic coercion will close down the coal mines and power plants without compensation for those employed in the coal industry. 

It is high time Bulgarian politicians and governments start taking responsibility for the damage caused to society and the country’s economy as a consequence of their refusal to fulfil their obligations to reform the energy sector and for serving corrupt, oligarchic schemes. For this reason, the idea of both government and President to renegotiate the National Recovery and Resilience Plan with the European Commission without a guarantee of concrete measures and reforms, leading to an energy transition, is doomed to failure. Renegotiating the Plan will block and delay for months the implementation of important for the households and businesses projects such as the energy efficiency programme for multi-family residential buildings, the programme for individual RES capacities and batteries for businesses and others, which will actually reduce the bills of the households and businesses, as well as our energy dependence on foreign fossil fuel suppliers. 

The lack of vision and strategy, as well as populism, will result in the impossibility to have a smooth, just energy transition which can lead to positive changes for both mine workers and the entire coal regions, and risks an abrupt transition the price for which we will all pay. 

Read the article in Bulgarian 


The Parliament’s populism will come at a high price

The amendments in the Recovery and Resilience Plan, which the outgoing parliament wants to make, set a dangerous long-term trap and the coal-dependent regions are particularly vulnerable

Keeping the coal plants open at all costs for an undefined period is a populist move, harmful for Bulgaria’s interests. The shortsighted election games have long-term consequences, and any delay increases the risk that the country will lose the money for energy transformation, requalification, compensation for workers in the energy sector and the rehabilitation of the sites. 

Last week’s parliamentary decision obliges the Council of Ministers to take all necessary action by 31 March 2023 to renegotiate the targets for reducing carbon emissions from coal power generation by 40% by the end of 2025, as well as keeping coal-fired power plants open at least until 2038. The decision conveniently overlooks the fact that the current deadline for closing the coal plants, written into the NRRP, is also 2038 and the renegotiation initiative lacks adequate proposals and interim targets for how it will be fulfilled. 

The pattern of Bulgarian politicians to have a very low horizon, which extends only until the next elections, and a complete lack of vision is once again reestablished. The political crisis, ongoing for two years now, is showcased in the frequent elections, short-lived parliaments and the rule of the President through caretaker governments. The consequences are the primitive and populist propaganda used by the politicians who are unscrupulously intent on attracting more voters for the next elections. This is how short-term political interests trump the long-term national ones, says Todor Todorov from the Energy and Climate team at Za Zemiata. 

The grouping of the state-owned Maritsa East 2 with small, extremely polluting power plants like Maritsa 3 in Dimitrovgrad, associated with Hristo Kovachki, is a move which entirely protects the private interest of shady businessmen. Conveniently overlooked was the fact that Maritsa East 2 became profitable because of the war in Ukraine, and prior to that it was on the brink of survival, reporting losses of 182 mln leva in 2021, with a debt of 1.3 bln leva to its parent company, Bulgarian Energy Holding, and only state aid sustained its existence. 

The loss of funding means that Bulgaria will have to look for other sources to finance compensations for the workers in the coal power plants and mines once the coal-fired power plants will have to close on a market basis. 

Although it is legally possible to renegotiate the Recovery and Resilience Plan at any point, this means that it has to be defended with arguments – something that we did not see during the discussions. It is certain that the possible renegotiation will delay the second and third payments under the plan, which means that EUR 1.5 bln will not enter the Bulgarian economy and finance the energy transformation. Only 20 measures have been implemented out of the 46 set out in the RRP and 10 of these unfulfilled commitments are precisely those of the Ministry of Energy. Due to the missed deadline to submit the Territorial Just Transition Plans (TJTP) by the end of 2022, Bulgaria has already lost EUR 100 mln from the Just Transition Fund (JTF). 

The Parliament has demonstrated the same lack of responsibility and incompetence with the task that was allocated to the government – to initiate the construction of two new Westinghouse AP 1000 type reactors in Kozloduy NPP without any economic analysis whether there is the need for new nuclear capacity in the country. Taking into account the fact that an interim government takes on the task of presenting Bulgaria’s long-term economic strategy until 2053, we are observing yet another attempt to predetermine the country’s economic and energy development for decades to come by people who are only temporarily in power and also completely irresponsible. 

Photo: https://www.parliament.bg/