To:

Dr. Eng. Rositsa Karamfilova

Interim Minister of Environment and Waters

edno_gishe@moew.government.bg

 

Mr. Rosen Hristov

Interim Minister of Energy 

e-energy@me.government.bg

necp@me.government.bg

 

Mr. Atanas Pekanov

Interim Deputy Prime Minister for the EU Funds

atanaspekanov@government.bg

 

Letter № 1207/15.09.2022 г.

 

Position of EA Za Zemiata on: Long-term Strategy for Climate Change Mitigation 2050 of the Republic of Bulgaria

 

In the draft of the Long-term Climate Change Mitigation Strategy 2050 of the Republic of Bulgaria (‘The strategy’) which was put forward for public consultation, we have discovered many inconsistencies, although we are glad that work on the document has recommenced. 

We were unpleasantly surprised to see that the scenarios under consideration set out to achieve only between almost 80% greenhouse gas emission reduction in the scenario aiming to limit the global average temperature to 2°C and between 83% and 84% for the 1.5°C scenario compared to 1990 levels. Therefore, there is no goal for Bulgaria to achieve overall carbon and climate neutrality in the context of European climate policy even before ambition was raised through the European Climate Act. 

A significant problem of the current document – which requires its revision with the involvement of the public at the earliest possible stage – is that it does not integrate the increased climate targets at the European Union (EU) level for 2030 which correspond to a net reduction of minimum 55% of the greenhouse gas emissions (GHG). This fact alone is sufficient for us to state that the Strategy needs to be updated. The potential adoption of the Strategy in its current form will be contrary to the EU’s Fit for 55 plan as well as the REPowerEU plan adopted this year. Moreover, the actual reduction needed, according to climate scientists, is at least 65% by 2030 which was also confirmed by the energy modelling in the Paris Agreement Compatible Scenario (PAC Scenario) for Europe. National PAC scenarios for staying on a global warming trajectory of 1.5C are also currently being developed. 

As you know, the Energy Transition Commission, one of the structures of the European Green Deal Advisory Council (EGTAC) , is currently meeting in our country. The expected outcome of its work: a report outlining scenarios based on extensive energy sector modelling and a roadmap to climate neutrality, which is also a necessary prerequisite/implemented reform for the second payment to Bulgaria under the Recovery and Resilience Plan (RRP). The results of the modelling as well as the recommendations of the expert group will form the base of both the Long-Term Decarbonisation Strategy 2050 and next year’s National Energy and Climate Plan 2030 (NECP). 

The objectives set out in the Strategy need to be reviewed and updated before it is put forward for a second public consultation and then adopted as an integral part of the country’s decarbonisation roadmap. The Strategy is an important guiding document for the decarbonisation of the Republic of Bulgaria as part of its European direction of development. It needs to provide certainty and predictability for the market players to undertake timely and ambitious energy saving measures, to support the increase of the share of renewable energy sources (RES), and to contribute to reducing their dependence on fossil fuels and unreliable external energy suppliers. 

In the current dynamic geopolitical environment which is also full of increasing climate disasters (an example of that are the floods in the Karlovo region), there is a need for a more frequent revision of strategies and plans particularly in the dynamic field of decarbonisation, and particularly of the objectives set out in them, the measures for the implementation of these objectives, and attention should also be paid to the analysis and evaluation of the results achieved. 

For many years Environmental Association Za Zemiata has been advocating for the need of a horizontal systemic multisectoral approach towards the implementation of climate policies and measures in the country. Actions which are hasty or poorly thought out such as the increase of the use of coal in response to geopolitical events have the potential to slow down the overall decarbonisation of the country, to lead to missed opportunities and competitiveness due to late and untimely decarbonisation investments and to further damage the health of citizens, the environment and the climate. 

The current two weeks of public consultation are far from enough to review and provide expert assessment of such a significant document which impacts the future of the main sectors of the economy. We suggest a new public consultation is held after the necessary actualisation of the data and assumptions in the energy modelling is done and in the context of the NECP revision. For effective and constructive new public consultation, we also recommend the inclusion of all relevant data stemming from the B(EST) modelling. 

We also draw attention to the need to carry out a Compatibility Assessment with the subject and conservation objectives of the Natura 2000 protected areas. The environmental assessment of plans and programmes should be carried out in parallel with development, again with the early stage involvement of citizens. At the moment, the Strategy in its current form is a prerequisite for a significant environmental and human health impact in its implementation. 

Comments on the different aspects of the Strategy:

In relation to elements of the scenarios considered in the strategy which are defined as ‘successful under all conditions’ we support the move towards:

  • Maximum level of energy efficiency in all sectors;
  • Increasing the electrification in the transport and heating sectors;
  • Maximum inclusion of RES for energy for heat and electricity;

We advocate for the need of building on the work towards:

  • Decarbonisation of the district heating companies in the country
    • Planned increase of the efficiency of district heating and heat supply
    • Prioritisation and an easy procedure for the connection of consumer-producers of RES to the electricity distribution grid
  • Upgrading and increasing the capacity of the electricity grid, the meters, distribution and balancing systems
  • ‘The use of electrical energy in high-temperature industrial processes’. We advocate for the electrification of all possible high-temperature processes in the industry, supplemented on a small scale by a combination of green hydrogen and/or green ammonia.
  • Energy saving beyond conventional practices. We draw attention to the fact that in the new European legislation, part of the Fit for 55 package, zero energy buildings (ZEB) are no longer referred to as going beyond conventional practices but are the new norm which will come into force initially for new buildings while existing buildings much pursue the highest level of energy efficiency and deep energy renovation. 

We draw attention on the need to rethink:

  • The development of biomass and gas fuels for domestic use through modern technologies (item 4), as households currently rely too much on heating from wood often in highly inefficient installations. Stimulating the biomass combustion from forestry will lead to increased pressure on forests and emissions will rise at a rate that cannot be compensated. The country still has no plans to take into account the sustainable origins of different types of biomass. The usage of biomass can be tolerated only after an analysis of the environmental and climate footprint and subject to sustainability criteria. 
    • The ‘transition from using traditional combustion stoves to heating systems using natural gas’ in the residential sector, referred to in the text. It is necessary to eliminate this trend, especially in the current gas crisis and the politicisation of gas supply in the context of the war in Ukraine. Bulgaria is in an especially favourable position with only 3.2% domestic gasification. It is completely wrong and short-sighted to seek a switch to natural gas in the residential sector and for the current use in public buildings, alternatives such as heat pumps should be encouraged. 
  • The use of gas in the industrial sector. According to the text, the use of gas in the industry is also planned and it includes the construction of new gas infrastructure. We consider this a pointless investment both in the residential sector and in the industry; it is unnecessary to invest in a) increasing consumption and b) building new gas infrastructure considering the EU’s climate goals and the gas phase out targets. Investing in gas will effectively lead to a double investment as we know that gas phase out will be sought within the next decade. In this sense, direct investment in renewables is more adequate and timely. What is written in the text, that gas consumption will increase by 2030 is also no longer relevant as it is clear that gas is losing its role as a transitional fuel and that an exit is being sought rather than an increase of the consumption considering the gas prices. Gas prices also make replacing coal with gas a non-viable solution. In view of these comments, we can again conclude that this document has not been updated as the measures involving gas are already outdated and do not match the updated EU policies and do not take into account the gas crisis and the current geopolitical context. 
  • Waste. With regards to the waste sector, there is a major contradiction between the circular economy measures and the projections for the increase of the amount of waste used as fuel in the Renewable energy and energy efficiency section. Waste is not inherently a renewable fuel especially in the light of the circular economy objectives, whereas materials are not destroyed by incineration but used for as long as possible and for as many cycles as possible. An exception is the anaerobic decomposition of separately collectd biowaste which produces not only clean green energy but also compost (soil conditioner). However, according to the hierarchy of waste management, the goal to prevent food waste has priority. By the same logic, instead of relying on capturing biogas from old landfills and active landfills, it makes the most sense to invest in separate collection of biowaste and preventing it from going into landfills, so that from environmental damage (landfill gas, methane emissions), biowaste can turn into environmental benefit in the form of biogas, compost and a store of greenhouse gas emissions. A priority measure should be the separate collection not only of ‘green’ (i.e garden) waste but also of food/kitchen waste by citizens, institutions, commercial establishments and markets. Accordingly, the investment in anaerobic decomposition needs to be targeted now only towards sludge from water treatment, but primarily towards the treatment of food and similar waste. 
  • Electricity export. The assumption of energy consumption increase seems to ignore the huge potential for energy saving measures in the building stock which could lead to real reductions of electricity consumption as well as interest in renewable energy for own use by businesses and households. Forecasting constant exports of electricity is not appropriate with the many investments of neighbouring countries in RES but also other energy carriers, which would reduce their import needs proportionally. 
  • Carbon capture and storage for electricity generation
  • Technological emissions. It is unacceptable for all scenarios to consider using CCS but not the natural ways of keeping carbon out of the atmosphere. For example, composting separately collected biowaste stores carbon dioxide in soils long-term on an average of about 11% of the compost’s weight – i.e. for every tonne of fresh compost, between 60-150 kg of carbon dioxide equivalent is sequestered long-term. Given the obligation for separate collection of household biowaste from 21 December 2023 and considering the large untapped potential of the organic waste in Bulgaria, a far better step than CCS would be to direct resources and efforts towards the rapid roll-out of the separate collection of biowaste from households across the whole country as well as towards ensuring its subsequent efficient processing to a compost – including encouraging on-site composting to save transport emissions. This policy would have a beneficial impact on the quality of soils in the country. We believe there are far cheaper and nature-based solutions to capture and store carbon dioxide than using CCS, CCU and BECGS. 
  • Non-carbon emissions. Key sources of climate emissions such as from methane leaking into the atmosphere, a highly potential greenhouse gas, have not been taken into consideration. 
    • It is unacceptable in the 2C or even the 1.5C scenarios to project residual GHG emissions such as 20% and 10% and an incomplete decarbonisation of the economy. Priority should be given to exploiting the potential for natural and non-invasive ways of long-term carbon storage such as forest planking, restoring marine ecosystems. Afforestation, improved forest management, soil carbon sequestration, peatlands and blue carbon management are examples of methods that can increase the biodiversity and functions of ecosystems, the employment and local livelihoods, depending on the context. In contrast, afforestation or production of biomass crops for BECGS or biocoal when poorly implemented can have adverse socio-economic and environmental impacts, including on biodiversity, food and water security, local livelihoods and indigenous people’s rights, especially when implemented at large scale and when land tenure is uncertain.  
    • We recommend you take into consideration EA Za Zemiata’s report on carbon capture and storage. 

Conclusion:

The strategy needs to reflect our country’s new climate commitments, strengthened by the Fit for 55 package. Following an update in this direction, including to reflect the Energy transition Commission’s energy modeling, a new public consultation should be carried out in due course, providing the necessary (additional) information on the results and the assumptions of the model used. 

Kind regards,
Energy and Climate team
Environmental Association Za Zemiata

 

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