Letter to the Bulgarian energy and environment ministers

Higher 2030 energy savings target for Bulgaria

Dear Mr. Radev,

Dear Mr. Popov,

We would like to recall that according to Article 4.5 of the updated Energy Efficiency Directive 2023/1793 from 13 September 2023, Member States need to communicate to the European Commission by 1 February 2024 at the latest their updated indicative national energy efficiency contribution if they will be using the updated EU 2020 reference scenario (PRIMES).

In our position statement on the draft update of the National Energy and Climate Plan of the Republic of Bulgaria 2021-2023 (Reference No. MOEW 48-00-38/23.01.2024; ME № Е-92-00-95./22.01.2024), we asked that a national energy efficiency commitment is set, one that exceeds the minimum reduction under the Energy Efficiency Directive (EED) formula, which amounts to no more than 13.71 Mtoe for primary energy and 8.85 for final energy consumption, compared to the 2020 EU reference scenario pre-update.

So far only the Member States have access to the updated 2020 EU reference scenario and the minimum figures for primary and final energy consumption for Bulgaria, respectively, we urge you to be guided by the scenario which has the higher potential for energy savings and to set higher targets accordingly, in line with what is needed to stay within the 1.5 C global average warming threshold.

The benefits of early efforts and actions related to energy efficiency are numerous and substantial, which can be seen in the Horizon 2020 COMBI project^[1]: savings in the energy system, positive impacts on economic well-being, avoided resource use and positive health impacts.

See Figure B in the Co-benefits of a 1.5°C compatible energy transition pathway to 2030, % of 2022 GDP; Source:  “Paris Pact Payoff: Speeding up the green transition for socio-economic co-benefits”

In the implementation of the “Energy efficiency first” principle, every watt of energy that has not been produced is a direct saving which contributes to the energy security of the country as well as to the more efficient and rapid deployment of renewable energy in the energy mix.

In Bulgaria there is a huge untapped potential for energy savings in the building sector: with a focus on multi-household and single-household residential buildings as well as municipal building stock.

Why energy efficiency?

• To reduce the energy intensity of the Bulgarian economy which is more than 4.5 higher than the EU average and more than twice as high compared to the other new Member States^[2];
• Energy efficiency is a practical way to take energy-poor households out of the “energy poor” category in the long term;
• Energy efficiency is an effective means for rapid decarbonisation towards the 1.5C target with a very good return on investments.

A transition that adopts ambitious targets for energy efficiency and for reducing energy use would allow to reduce resource extraction, costs and the material footprint. This is possible because reducing the final energy consumption also reduces the raw materials needed and the emissions from their consumption.

Respectfully,

Radostina Slavkova, Energy and Climate Coordinator, Environmental Association Za Zemiata (Friends of the Earth Bulgaria)

Svetoslav Stoykov, Renovation Coordinator, Environmental Association Za Zemiata (Friends of the Earth Bulgaria)

^[1] Calculating and Operationalising the Multiple Benefits of Energy Efficiency in Europe (COMBI)

^[2] Why is the Bulgarian economy particularly prone to energy shocks from the Middle East? (in Bulgarian) https://www.investor.bg/a/461-bloomberg-tv/383070-zashto-balgarskata-ikonomika-e-osobeno-izlozhena-na-energiyni-shokove-ot-blizkiya-iztok