TO:

Mr. Atanas Pekanov,

Deputy Prime Minister for the EU Funds and 

Chairman of the Green Deal Advisory Council (GDAC)

atanaspekanov@government.bg

 

Ms. Iva Petrova,

Deputy Minister of Energy

e-energy@me.government.bg

 

Dr. Maria Trifonova PhD, Co-Chair, Energy Transition Commission

mgtrifonova@feb.uni-sofia.bg

 

Mr. Kaloyan Stoychev,

k.stoychev@government.bg

 

Members of the Energy Transition Commission Secretariat

etc@me.government.bg

sec.energy@me.government.bg

 

Members of the Energy Transition Commission 

 

Letter no. 1209/27.09.2022 

 

Subject: Position statement on the work of the Energy Transition Commission, part of GDAC, the proposals on the assumptions considered in the reference scenario and the framework of ETC’s report, as presented by the Ministry of Energy 

 

On behalf of the environmental organisations Environmental Association Za Zemiata and Greenpeace – Bulgaria which, due to their similarity, have common representation in  the Energy Transition Commission in the face of Mr. Todor Todorov from Za Zemiata (Member) and Ms Meglena Antonova from Greenpeace – Bulgaria (Deputy), we would like to express our support for commencing the process of integrated energy modelling based on the Pathways Explorer tool, as started by the current co-chair of the ETC – Dr. Maria Trifonova. It allows for an easy comparison of energy sector decarbonisation models and it also shows how it complements the necessary measures in other sectors of the economy in an accessible way for the public. 

We believe that the use of the chosen model is appropriate and meets the commitment to develop a roadmap to achieve climate neutrality for Bulgaria, including the accelerated phase out of fossil fuels such as coal from the energy mix  (Reform 9 (C4.R9) of the Commission’s decision for the NPRR approval). 

In addition, the modelling’s preparation and a report with conclusions and recommendations to Members of the Bulgarian Parliament is the Energy Transition’s Commission’s main task at the moment, which is why we consider it important that a model such as that of the Pathway Ehttps://docs.google.com/document/d/1O9YY71dyLwq85TgfWJCBzuAq_I7Izo8y_EQYkHXgfBQ/edit?usp=sharingxplorer tool is applied in order to consider the scenario for the accelerated phase out of coal by 2030, so that the final outcome is consistent and comparable to the ambition of neighbouring EU member states. This final result must be in line with the stated energy sector decarbonisation goal with a focus on the reduction of carbon emissions from electricity production by 40% taking the baseline levels from 2019 until the end of 2025. 

The consideration of a 2030 scenario which is consistent with the 40% reduction target for coal emissions in the energy sector will allow the assessment of the possibility to decarbonise the economy in a way that allows also for the identification of possible measures for a just transition, the identification of financial needs and the assessment of the environmental and socio-economic impact of the energy sector’s transformation.

Our recommendations on the ETC report framework, presented by the Ministry of Energy: 

  • We generally support the presented report framework;
  • In the ‘Conclusions and recommendations’ part, we believe it is important to look into the “Public costs” not only from the perspective of the investments needed but also with regards to all costs to society; particularly the so-called external costs such as health costs and environmental costs but also the indirect spend such as government subsidies for the different types of energy production; 
  • When developing the recommendations for the 2030 decarbonisation targets, these need to be considered in the context of the same longer-term 2050 targets with a clear vision to achieve complete and real climate neutrality in the country by mid-century;
  • When developing the recommendations for the inclusion of coal in the energy mix, it would be beneficial to consider other technologies and sources of greenhouse gas emissions which will have to be phased out in the same timeframe;
  • In Chapter 2 we support and endorse the implementation of an integrated model which will project the energy and materials usage, the greenhouse gas emissions and the subsequent impacts on society and the environment;
  • In Chapter 3 we support the consideration of the two main scenarios – by 2030 and 2038 and we have specific comments on some of the assumptions suggested in the comparative table of the scenarios, part of the ETC discussions;
  • In Chapter 3, line 1 we give special consideration to some of the assumptions below
  • In Chapter 3, line 3, we reiterate the need for comprehensiveness of the criteria against which the scenarios will be assessed and we insist for the inclusion of health costs, the environmental effects on air, water, soil and climate, social effects incl the dependency of vulnerable households on the continued use of fossil fuels such as coal, the possible economic consequences of non-compliance with environmental law, the risks of unplanned and sudden liquidation of enterprises in the coal sector, the cost of adequate and fair compensation for villages such as Beli Bryag, Troyanovo, Kovachevo which are threatened with eviction due to the expansion of the Maritsa East Mines;
  • In Chapter 4 we recommend that special attention is paid to the connectivity of the European energy market and the ambition to further deepen its integration, including the high decarbonisation targets of neighbouring countries, investment in smart grids and the opportunities to provide demand-response services; 
  • In Chapter 4 we also believe it is appropriate to take into consideration the opportunities that the decentralised energy production from renewable sources provides for the participation of small producers, both individual and in communities and for businesses to cover their own energy needs, thus improving the energy efficiency of the system and reducing demand.

Our comments on the assumptions in the comparative table of selected models required for the preparation of an updated reference scenario:

  • We strongly recommend energy efficiency assumptions and behavioural change to be the key starting point when devising the reference scenario; 
  • We support the adoption of the most ambitious possible deep renovation targets, incl. 3% per year deep renovated residential buildings by 2050. The need for additional funding, coming from previous fossil fuel subsidies, must be also taken into consideration; the need of the qualification of construction professionals and the quality performance of construction activities; 
  • We recommend double-checking the data sources and estimates for the construction of new capacities especially with regards to large-scale renewables projects – such as hydropower and onshore wind plants; also projects for new or converted thermal power plants using biomass; in the context of the planned mass support for the construction of renewable energy plants as a consequence of the European plan REPowerEU, these projects need to be as specific and environmentally friendly as possible, incl. to be aimed at future priority areas (so-called ‘go-to areas’); 
  • We insist for the inclusion of a detailed economic justification for the maintenance of fossil fuel capacity including when assuming that they are to be maintained as a reserve or using carbon capture technologies;
  • Economic justification is necessary in assessing the need of the construction of new nuclear capacity in the scenario’s timeframe, as is currently in the Compass Lexecon model;
  • We support the assumption that the construction of new gas capacities is economically unjustifiable; the existing gas capacities and district heating companies need to be supplemented by RES, as well as by solar district heating, industrial heat pumps and seasonal storage and shortly after – retired; 
  • The analyses should also consider the potential of geothermal sources particularly in the context of Geothermal Energy 2.0, which bases its development on the heat of the earth’s subsurface rather than underground water. 

 

Kind regards,

Todor Todorov,

Environmental Association Za Zemiata

Meglena Antonova,

Greenpeace – Bulgaria

 

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