BIA STANDPOINT ON A DRAFT UPDATED INTEGRATED ENERGY AND CLIMATE PLAN OF THE REPUBLIC OF BULGARIA 2021-2030

The Bulgarian Industrial Association (BIA) reiterates its support for the implementation of the EU decarbonisation strategy. At the national level, it should be linked to adequate sectoral policies and measures for sustainability, flexibility of the energy system and predictability for business, full consideration of national specificities, including the reduction of GHG emissions since 1988, on which Bulgaria ranks among the global leaders, as well as the implementation of long-term national targets for accelerated convergence of productivity and incomes to the EU-27 average levels.

This calls for urgent changes in the methodological basis and new modelling of the main development expectations and scenarios (GDP, population size, energy consumption projections in the main sectors - household, transport, industry and other key parameters), compared to the framework presented by Bulgaria for average annual GDP growth under the EC reference scenarios to 2020 of 1.017% (1.019% for the EU27) and 1.3% for the period 2024-2030, as estimated by the E3-Modelling baseline model in the EC's 2022 summer macroeconomic forecast.

BIA has repeatedly expressed these principled positions, including in opinions on the draft National Energy Strategy of 2011, in the preparation of the so-called Climate Neutrality Map by the Energy Transition Commission of the Council on the so-called European Green Deal, etc. On 08.11.2023, our latest position on the draft response to the European Commission's query - EUP (2023) 10561 on the non-submission of the draft Updated Integrated National Energy and Climate Plan for the period 2021-2030 to WG 20 Environment of the Council for European Affairs was also presented.

On this basis we propose:

A. The Plan should explicitly include all key historical data and forecast parameters, scenarios and projections and clearly present the methodological apparatus used, in accordance with the EC guidance presented in Part Two (page 245).

B. An approach to updating the INPEC based on new modelling, expectations and ambitious scenarios for developments relative to the baseline macroeconomic framework presented so far by the Ministry of Finance for the purposes of preparing the EC Ageing Report and the EC PRIMES (E3-Modelling) reference scenarios, including the E3-Model, should be formulated and implemented in a clear and explicit manner. by overestimating Bulgaria's average annual GDP growth forecast to 2030 by at least 2.0%.

By comparison, Estonia is projected to have an average annual GDP growth of over 2.6% by 2030, Hungary 2.5%, Latvia 1.9%, Lithuania over 1.6%, Poland 2.3%, Romania 2.9%, Slovenia 2.4%.

C. On this basis, all key assumptions, development scenarios, projections of energy consumption, energy and carbon intensity, including at national and sectoral level, energy efficiency, energy mix (capacity, production and consumption), share of RES in final energy consumption, long-term energy balance, etc. should be reviewed and revised.

D. If necessary, initiate changes in the cited key strategic and sectoral documents, envisaged measures and incentives in the different policy areas (pp. 18-19) to align them with more ambitious targets (NDP 2030) for convergence to the EU27 average productivity and income levels.