GALAB DONNEV, CARETAKER PRIME MINISTER
ROSEN CHRISTOV, CARETAKER ENERGY MINISTER
ROSITSA KARAMFILOVA, CARETAKER MINISTER FOR ENVIRONMENT AND WATER
ATANAS PEKANOV, CARETAKER DEPUTY PRIME MINISTER FOR MANAGEMENT OF EU FUNDS
FRANCE TIMMERMANS, EXECUTIVE VICE-PRESIDENT OF THE EC, EUROPEAN GREEN PACT PORTFOLIO
ELISA FERREIRA, EUROPEAN COMMISSIONER FOR COHESION AND REFORM
EUROPEAN COMMISSIONER FOR ENERGY
SELYN GAUER, HEAD OF THE WORKING GROUP ON RECOVERY AND SUSTAINABILITY
DELYAN DOBREV, CHAIRMAN OF THE PARLIAMENTARY ENERGY COMMITTEE
STANISLAV ANASTASOV, CHAIRMAN OF THE PARLIAMENTARY COMMITTEE ON ENVIRONMENT AND WATER
DENITSA SIMEONOVA, CHAIR OF THE PARLIAMENTARY COMMITTEE ON THE EUROPEAN UNION
Subject: Request to withdraw the project of the Ministry of Energy of „Strategic vision for the development of the electricity sector of the Republic of Bulgaria 2023 – 2053.“
On behalf of the Environmental Association „Za Zemiata“ we address you in connection with the draft of the so-called „Strategic Vision for the Development of the Electricity Sector of the Republic of Bulgaria 2023 – 2053“ („Strategic Vision“) published on 17.01.2022, which was subsequently adopted by the Decision of the Council of Ministers No. 49 of 20.01.2023 and by virtue of this decision must be submitted for consideration by the National Assembly.
We urge the Government to rescind this decision and the Ministry of Energy to withdraw the draft „Strategic Vision“ for a number of reasons, among which the following stand out:
- We find it very strange that a caretaker government with a limited mandate, which has failed in the clear and specific task of sending the three territorial fair transition plans to the European Commission (EC) before the end of 2022 – thus causing the country to lose €100 million from the Fair Transition Fund, has decided to serve all the lobbying interests in the energy sector with an absurd energy strategy until 2053.
- The proposed „Strategic Vision“ is of very low quality, completely inadequate to Bulgarian national interests as well as to modern European requirements, and is not subject to revision.
- „The Strategic Vision is also economically unjustified. The investments required are over EUR 60 billion, but it is not clear how they will affect the implementation of the climate commitments made by the country. Instead, dubious solutions are being relied on, such as the construction of new nuclear capacity and the corrupt Belene NPP project.
- In this document is evident the aspiration through energy mega-projects to continue the oligarchic-corruption model in the Bulgarian energy sector, which has led to a huge delay in the processes related to the energy transition, not to mention the implementation of a fair transition.
- An example of one of the megalomaniac ideas is the large-scale production of green hydrogen – for export and for balancing the Bulgarian electricity system. We are asking ourselves a lot of questions, such as: what infrastructure do we have for exporting hydrogen – how will we build it, how much will it cost, with what investments; how will it be justified to export – what are the calculations for the production needed, how much green hydrogen will be needed by the industry in Bulgaria in the first place, do we have such production capacity; will there be buyers?
- There is no environmental assessment. There was no public consultation, and the presentation of the document was made with limited public access.
- Incorrect reference and justification of key findings in the Strategic Vision to the work of the Energy Transition Commission (ETC), on which we have a representative. The document in question has not been circulated to members, nor has it been discussed.
- We already have a ‘Strategic Vision for the Development of the Electricity Sector’, as well as for the whole economy for the same time period. It should be recalled that very recently, on 20.10.2022, the Council of Ministers adopted a strategic document identical in nature to the Energy Union Governance Regulation, the ‘Long-Term Climate Change Mitigation Strategy 2050 for Bulgaria’. In its current form, this document also fails to meet the requirements for achieving EU climate neutrality and needs to be revised in due course.
We are left with the impression that the philosophy of this document is electoral promises to all and sundry, and nothing more. The only sensible solution is to withdraw the ‘Strategic Vision’ and for national institutions to focus on the update of the National Energy and Climate Plan 2030, which the EC will expect in initial form by 30 June 2023, with the earliest possible involvement of all stakeholders.
Climate and Enegy Team
This publication is part of the LIFE project „Together For 1.5“, co-financed by the European Union. The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the European Union or CINEA. Neither the European Union nor the funding body can be held responsible for them.
For more information on the project
Official page of the project