ec.europa.eu · Web viewFIRST DRAFT FIRST DRAFT FIRST DRAFT RAS on Air Quality Management – Deliverable 7: National Air Pollution Control Programme RAS on Air Quality Management

National Air Pollution Control Programme, Bulgaria

2020-2030

June 2019

RAS on Air Quality Management – Deliverable 7: National Air Pollution Control Programme

(Project number P160312)

Country Manager:

Practice Manager:

(Co-)Task Team Leaders:

Project Coordinator:

Fabrizio Zarcone

Ruxandra Maria Floroiu

Sameer Akbar, Eolina Petrova Milova

Russell Frost

DISCLAIMERSThis programme was produced by the World Bank team to provide advisory support to the Ministry of Environment and Water (MoEW) in Bulgaria. The findings, interpretations and conclusions expressed in this report do not necessarily reflect the views of the Executive Directors of the World Bank.

ACKNOWLEDGEMENTSThis programme was produced by a core team led by Sameer Akbar (Senior Environmental Specialist, Task Team Leader), and Eolina Petrova Milova (Senior Environmental Specialist, co-Task Team Leader), with substantial inputs from Russell Frost (Project Coordinator), Chris Dore (International Emissions Projections Expert), Vasil Zlatev (Local Air Quality Expert), Stefan Dishovsky (Local Air Quality Expert), Valery Petkov (Local Legal expert), Martin Williams (International Transport Emissions Expert), John Murlis (International Air Quality Expert), Peter Newman (International Industry Expert), Peter Faircloth (International Finance Expert), Oznur Oguz Kuntasal (International Air Quality Expert), Anil Markandya (International Environmental Economics Expert), Anna Spasova (Local Legal Expert), and Adelina Dotzinska (Team Assistant). The contributions of Valerie Hickey (Practice Manager, LAC ENR), Kseniya Lvovsky (Practice Manager, ECA ENR), Ruxandra Floroiu (Acting Practice Manager, ECA ENR) and Fabrizio Zarcone (Country Manager) are also acknowledged.

The World Bank would like to acknowledge the assistance in the form of interviews, meetings, expert opinion, data and knowledge of the experts at the Protection of Air Cleanness Directorate, MoEW, the Climate Change Policy Directorate of MoEW, and the Executive Environment Agency (ExEA); Ministry of Energy; Ministry of Agriculture, Food and Forestry; Ministry of Transport, Information Technology and Communication; and the National Statistical Institute.

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TABLE OF CONTENTS

ABBREVIATIONS AND ACRONYMS........................................................................................................................ ix

FOREWORD.........................................................................................................................................................xiii

2.1. Programme Title, Contact Information and Websites....................................................................................1

2.2. EXECUTIVE SUMMARY....................................................................................................................................2

2.2.1. The National Ambient Air Quality and Pollution Policy Framework........................................................2

2.2.2. Progress Made Since 2005 by Current Policies and Measures in Reducing Emissions and Improving Ambient Air Quality..........................................................................................................................................2

2.2.3. Projected Further Evolution to 2030 Assuming No Change to Already adopted policies and Measures (PaMs)..............................................................................................................................................................4

2.2.4. Options considered for a policy to achieve compliance with the emission reduction commitments for the period 2020-2030, and intermediate emission levels for 2025..................................................................5

2.2.5. Summary of Policies and Measures Selected for Adoption by Sector, Including a Timetable for their Adoption, Implementation and Review, and the Competent Authorities Responsible....................................6

2.2.6. Coherence...............................................................................................................................................8

2.2.7. Projected Combined Impacts of the Policies and Measures (‘With Additional Measures’ – WAM) on Emission Reductions, Ambient Air Quality in the National Territory and in the Territories of Neighbouring Member States and the Environment, and the Related Uncertainties.............................................................8

Conclusions.......................................................................................................................................................9

2.3. The National Air Quality and Pollution Policy Framework............................................................................11

2.3.1. Policy Priorities and Their Relationship to Priorities Set in Other Relevant Policy Areas......................11

Ambient Air Quality Priorities....................................................................................................................11

Emissions Prevention and Control Priorities..............................................................................................12

Relevant Climate Change and Energy Policy Priorities...............................................................................17

Relevant Policy Priorities in Other Relevant Sectors..................................................................................21

2.3.2. Responsibilities Attributed to National, Regional and Local Authorities...............................................24

2.4. Progress made by current PaMs in reducing emissions and improving the ambient air quality, and degree of compliance with national and Union emissions reduction obligations, compared to 2005.................................26

2.4.1. Progress made by current PaMs in reducing emissions and degree of compliance with the national and Union emission reduction obligations............................................................................................................26

Overview....................................................................................................................................................26

Nitrogen Oxides – Historical Emissions and Compliance with Directive 2001/81/EC.................................27

NMVOC – Historical Emissions and Compliance with Directive 2001/81/EC..............................................28

Sulphur oxide – Historical Emissions and Compliance with Directive 2001/81/EC.....................................29

Ammonia – Historical Emissions and Compliance with Directive 2001/81/EC...........................................30

Fine Particulate Matter2.5 – Historical Emissions........................................................................................31

Major Sectoral Sources of Pollutant Emissions in 2016..............................................................................32

2.4.2. Progress Made by Current PаMs in Improving Air Quality, and the Degree of Compliance with National and Union Air Quality Obligations..................................................................................................................34

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2.4.3. Current Transboundary Impact of National Emission Sources..............................................................38

2.5. Projected Further Evolution Assuming No Change to Already Adopted Policies and Measures...................43

2.5.1. Projected Emissions and Emission Reductions (WM Scenario).............................................................43

Summary of Emissions and Emissions Reduction (WM Scenario)...................................................................44

2.5.2. Projected Impact on Improving Air Quality (WM Scenario) and The Projected Degree of Compliance 47

2.5.2.1. Qualitative Description of the Projected Improvement of Air Quality..........................................47

2.5.2.2. Quantitative Description of the Projected Improvement of Ambient Air Quality.........................49

2.6. Policy Options Considered in Order to Comply with the Emission Reduction commitments for 2020, 2030, and Intermediate Emissions Levels for 2025.......................................................................................................50

2.6.1. Details Concerning the Programme and Measures Considered in Order to Comply with the Emission Reduction Commitments (Reporting at PaM Level)........................................................................................50

2.6.2. Impacts on Air Quality and the Environment of Individual PaMs or Packages of PaMs Considered in Order to Comply with the Emission Reduction Commitments.......................................................................55

2.6.3. Estimation of Costs and Benefits of the Residential Heating PaM Package Considered to Comply with the fine particulate matter Emission Reduction Commitments......................................................................55

2.6.4. Additional Details Concerning the Measures Considered from Annex III Part 2 to Directive (EU) 2016/2284 Targeting the Agricultural Sector to Comply with the Emission Reduction Commitments.................................................................................................................................................58

2.7. The Policies Selected for Adoption by Sector, Including a Timetable for their Adoption, Implementation and Review, and the Competent Authorities Responsible.........................................................................................63

2.7.1. PaMs Selected for Adoption and the Competent Authorities responsible...........................................63

2.7.2. Rationale for Choosing the Selected PaMs and an Assessment of Their Coherence with Plans and Programmes in Other Relevant Policy Areas..................................................................................................67

2.8. Projected Combined Impacts of PaMs (With Additional Measures – WAM) on Emissions Reductions, Ambient Air Quality and the Environment, and the Related Uncertainties.........................................................68

2.8.1. Projected Attainment of Emission Reduction Commitments (WAM)...................................................68

2.8.2. Non-linear emission reduction trajectory.............................................................................................72

2.8.3. Flexibilities............................................................................................................................................72

2.8.4. Projected Improvement in Ambient Air Quality (WAM).......................................................................72

2.8.5. Projected Impacts on the Environment (WAM)....................................................................................72

3. IMPLEMENTATION ISSUES...............................................................................................................................72

3.1. Acknowledging the Challenges..............................................................................................................72

3.2. Implementing the Sectoral PaMs..........................................................................................................73

3.2.1. Residential Heating Sector...........................................................................................................73

3.2.2. Road Transport Sector.................................................................................................................77

3.2.3. In order to achieve reduction in emissions of harmful substances from vehicles, the national legislation regulating the quality and the efficient control on the technical inspection preformed on vehicles prior to their registration in the country, as well as during the periodic checks of their technical status when emissions are also inspected, would need to be improved and updated. Agricultural Sector77

3.3. Cross-Sectoral Issues.............................................................................................................................78

3.3.1. Upgrading the National Inventory of Emissions...........................................................................78

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3.3.2. Revising the Emission Projections and Updating the National Air Pollution Control Programme in Future – 2021 and Beyond........................................................................................................................78

4. Conclusions................................................................................................................................................79

ANNEXES.............................................................................................................................................................81

ANNEX I – POLICIES AND RESPONSIBILITIES........................................................................................................82

I.1. Ambient Air Quality Limit and Target Values for Other Air Pollutants Covered by Directive 2008/50/EC and Directive 2004/107/EC.............................................................................................................................82

I.2. EU regulations and transposed EU directives: Existing policies and measures......................................83

I.3. Policy priorities in the Waste and Waste Management Sector...........................................................100

I.4. Summary of the Attributed Responsibilities in the Air Quality Assessment and Management Zones.101

ANNEX II – HISTORICAL EMISSIONS BY MAJOR SECTORS..................................................................................108

II.1. Nitrogen Oxides...................................................................................................................................108

II.2. Non-Methane Volatile Organic Compound (NMVOC).........................................................................108

II.3. Sulphur Oxide......................................................................................................................................109

II.4. Ammonia.............................................................................................................................................109

II.5. PM2.5....................................................................................................................................................109

ANNEX III – Ambient Air Quality Monitoring Trends – at the Levels of Monitoring Stations and Ambient Air Quality Assessment and Management Zones....................................................................................................111

II.6. Sulphur Dioxide...................................................................................................................................111

II.7. Nitrogen Dioxide.................................................................................................................................111

II.8. PM10.....................................................................................................................................................112

II.9. PM2.5....................................................................................................................................................113

II.10. Poly Aromatic Hydrocarbon (PAH)......................................................................................................114

II.11. Carbon Monoxide................................................................................................................................114

II.12. Ozone..................................................................................................................................................115

ANNEX IV – APPROACH TO PROJECTING SECTORAL EMISSIONS IN THE WM SCENARIO AND ADDRESSING UNCERTAINTIES.................................................................................................................................................116

III.1. Energy and Refineries..........................................................................................................................116

III.2. INDUSTRIAL COMBUSTION..................................................................................................................116

III.3. Residential Heating and Other Combustion........................................................................................116

III.4. Road transport....................................................................................................................................117

III.5. Other Transport..................................................................................................................................118

III.6. Industrial processes and Fugitive Emissions........................................................................................118

III.7. Solvent and Product Use.....................................................................................................................119

III.8. Agriculture...........................................................................................................................................119

III.9. Waste..................................................................................................................................................120

ANNEX V – Approximate Estimates of Primary PM10 Emissions Reduction Needed to Comply with Ambient Air Quality Criteria..................................................................................................................................................121

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ANNEX VI – EXISTING AND POTENTIAL ADDITIONAL POLICIES AND MEASURES (PAMS) TO MEET THE EMISSION REDUCTION COMMITMENTS AND FURTHER INFORMATION ON AGRICULTURE SECTOR MEASURES TO CONTROL AMMONIA EMISSIONS, CONTROL FINE PARTICULATE MATTER EMISSIONS, AND PREVENT IMPACTS ON SMALL FARMS...............................................................................................................................................................122

ANNEX VII – COSTS AND BENEFITS OF THE NAQIP RESIDENTIAL HEATING PAM PACKAGE...............................132

ANNEX VIII – DIFFERENCES BETWEEN THE WM AND WAM SCENARIOS...........................................................134

VII.1. Public Electricity and Heat Production................................................................................................134

VII.2. INDUSTRIAL COMBUSTION..................................................................................................................134

VII.3. Residential and Other Stationary Combustion....................................................................................134

VII.4. Road transport....................................................................................................................................135

VII.5. Other Transport – Aviation, Railways and Shipping.............................................................................135

VII.6. Industrial processes and Fugitive Emissions........................................................................................135

VII.7. Solvent and Product Use.....................................................................................................................135

VII.8. Agriculture...........................................................................................................................................135

VII.9. Waste..................................................................................................................................................136

LIST OF FIGURES

Figure 1. Historical Emissions of Nitrogen Oxides.................................................................................................28

Figure 2. Historical Emissions of NMVOC..............................................................................................................29

Figure 3. Historical Emissions of Sulphur Oxide....................................................................................................30

Figure 4. Historical Emissions of Ammonia...........................................................................................................31

Figure 5. Historical Emissions of Particulate Matter.............................................................................................32

Figure 6 Principal emission sources in 2016 (percentage of total reported emissions) according to the National Inventory of Emissions.........................................................................................................................................33

Figure 7. Air Quality Assessment and Management Zones in Bulgaria.................................................................34

Figure 8. Mapping Bulgaria’s modelled contribution of deposited pollutants......................................................38

Figure 9. Mapping Bulgaria’s modelled contribution to SOMO35 (ppb-day) for nitrogen oxides and NMVOC....40

Figure 10. Mapped reductions in the modelled concentrations of PM2.5 and secondary inorganic aerosol from a 15 % reduction in Bulgaria of precursor emissions (sulphur dioxide, nitrogen oxides, ammonia)........................41

Figure 11. Nitrogen Oxides (NOx) Emission Projections (ktonnes) under the WM Scenario................................45

Figure 12. NMVOC Emission Projections (ktonnes) under the WM Scenario.......................................................45

Figure 13. Sulphur Oxide (SO2) Emission Projections (ktonnes) under the WM Scenario.....................................46

Figure 14. Ammonia Emission Projections (ktonnes) under the WM Scenario.....................................................46

Figure 15. Fine Particulate Matter (PM2.5) Emission Projections (ktonnes) under the WM Scenario....................47

Figure 16. Plot of the annual mean PM10 in Bulgaria (2016) against the number of days exceeding 50µg/m3 (ExEA data)...........................................................................................................................................................48

Figure 17. Nitrogen Oxides Emission Projections under the WAM Scenario........................................................69

Figure 18. NMVOC Emission Projections under the WAM Scenario.....................................................................69

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Figure 19. Sulphur oxide Emission Projections under the WAM Scenario............................................................70

Figure 20. Ammonia Emission Projections under the WAM Scenario...................................................................71

Figure 21. PM2.5 Emission Projections under the WAM Scenario..........................................................................71

Figure 22 Roles of Municipalities and Central Government in implementing the compulsory phase-out aspects of the residential heating PaM package...............................................................................................................75

Figure III.1. Non-compliance with sulphur dioxide standards.............................................................................111

Figure III.2. Non-compliance with nitrogen dioxide standards...........................................................................112

Figure III.3. Non-compliance with PM10 standard................................................................................................113

Figure III.4. Non-compliance with PM2.5 standard...............................................................................................114

Figure III.5. Non-compliance with Poly Aromatic Hydrocarbon (PAH) standard.................................................114

Figure III.6. Non-compliance with carbon monoxide standard...........................................................................115

Figure III.7. Non-compliance with ozone standard.............................................................................................115

LIST OF TABLES

Table 1. Bulgaria’s national emission reduction commitments compared with the 2005 base year (in %)..........11

Table 2. Principal EU policy instruments aimed at the prevention and control of harmful substances emissions to air: see Annex I for EU instruments transposed in the Bulgarian legislation....................................................13

Table 3. Authorities and attributed responsibilities in the areas of air quality and air pollution..........................24

Table 4. Bulgaria’s National Emission Ceiling Values (after Directive 2001/81/EC)..............................................26

Table 5. Compliance with Bulgaria’s National Emission Ceiling totals (after Directive 2001/81/EC)....................27

Table 6. Pollutant monitoring coverage in Bulgaria’s AQ zones in 2016...............................................................35

Table 7. Non-compliance of AQ zones with EU ambient air quality standards for sulphur dioxide, nitrogen dioxide, fine particulate matter, PAH and carbon monoxide: 2005-2016.............................................................36

Table 8. Non-compliance of AQ zones with EU standards for ozone: 2008-2010 to 2014-2016...........................37

Table 9. Modelled fate of Bulgaria’s emissions affecting pollutant deposition in neighbouring countries...........40

Table 10. Sector resolution for Projections Calculations......................................................................................43

Table 11. Projected emissions, emission reductions, and commitments compliance (WM Scenario)..................44

Table 12. Additional PaMs considered.................................................................................................................50

Table 13. Additional PaMs considered – information to be reported using the PaMs tool..................................52

Table 14. PaM objectives and types, implementation authorities and Methodology used..................................53

Table 15. Estimated costs and benefits of the residential heating PaMs package in NAQIP.................................57

Table 16. Individual PaMs or package of PaMs selected for adoption, implementation timetable, and competent authorities responsible.........................................................................................................................................64

Table 17. Explanation of the choice of selected measures and an assessment of how selected PaMs ensure coherence with plans and programmes set up in other relevant policy areas.....................................................67

Table 18. Projected emissions, emission reductions, and compliance (WAM Scenario)......................................68

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Table I.1. EU Regulations and Transposed EU Directives having a direct impact on sectoral emissions...............84

Table I.2. EU Regulations and Transposed EU Directives having an Indirect Impact on Sectoral Emissions.........96

Table I.3. Authorities and attributed responsibilities in the air quality assessment and management zones.....101

Table V.1. Estimated reduction in primary PM10 emissions needed to achieve full PM10 compliance................121

Table VI.1. Identification of potential additional PaMs and their relation to existing PaMs...............................122

Table VI.2. Measures considered to control ammonia emissions (Referred to as ‘A’ in section 2.6.4 of Commission Implementing Decision).................................................................................................................127

Table VI.3. Emission Reduction measures to control emissions of fine particulate matter (PM2.5) and black carbon (Referred to as ‘B’ in section 2.6.4 of Commission Implementing Decision)...........................................131

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ABBREVIATIONS AND ACRONYMS

ERC Emission Reduction Commitment

NOx Nitrogen Oxides

SEDA Sustainable Energy Development Agency

RES Renewable Energy Sources

RAS Reimbursable Advisory Services

SIA Secondary Inorganic Aerosol

CO Carbon Monoxide

y Year

LCP Large Combustion Plant (≥50MWth)

d Day

SAMTS State Agency for Technical & Metrological Surveillance

Directive 2008/50/EC EC Directive on ambient air quality and Cleaner Air for Europe (2008/50/EC)

WAM With Additional Measures

Directive (EU) 2016/2284 EU Directive (EU) 2016/2284 of the European Parliament and of the Council of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive 2003/35/EC and repealing Directive 2001/81/EC

FGD Flue Gas Desulphurisation

TFEU Treaty on the Functioning of the European Union

MS Member State of the European Union

EEA European Environment Agency

EC European Commission

EMEP European Monitoring and Evaluation Programme

EU European Union

WBT World Bank Team

ESIF European Structural and Investment Funds

ETS EU Emissions Trading Scheme

EF Emission Factor

RTA Road Traffic Act

SMR Statutory Management Requirements

WMAct Waste Management Act

CAAA Clean Ambient Air Act

EXAAA Executive Agency Automobile Administration

ExFA Executive Forest Agency

EXEA Executive Environment Agency

IIR Informative Inventory Report

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UNECE United Nations Economic Commission for Europe

NRMM Non-Road mobile machinery

AQ Air Quality

QMLS Quantitative Measure of Living Standard

IPPC Integrated Pollution Prevention and Control

CLRTAP Convention on Long-Range Transboundary Air Pollution signed in Geneva on 13 November 1979

LRTAP Protocol to the Convention on Long-Range Transboundary Air Pollution to Abate Acidification, Eutrophication and Ground-level Ozone (Gothenburg Protocol) of 30 November 1999

VOC Volatile Organic Compound

IIASA International Institute for Applied Systems

MRDPW Ministry of Regional Development and Public Works

Mtoe Million Tonne Oil Equivalent

Regulation No 12 Regulation No 12 of 15.07.2010 on limit values for sulphur dioxide, nitrogen dioxide, particulate matter, lead, benzene, carbon monoxide and ozone in the atmospheric air

Regulation No 7 Regulation No 7 of 3.05.1999 on atmospheric air assessment and management

BAT Best Available Techniques

NIE National Inventory of Emissions

NIMH National Institute of Meteorology and Hydrology

NCV Net Calorific Value

NMVOC Non-Methane Volatile Organic Compound

NPV Net Present Value

NAPCP National Air Pollution Control Programme

NAQIP National Air Quality Improvement Programme

NFR National Framework for Reporting

NSI National Statistical Institute

NAMB National Association of Municipalities of Bulgaria

NEC National Emissions Ceilings

OP Operational Programmes

OAP Operational Action Plan

CAP Common Agricultural Policy

PAH Poly Aromatic Hydrocarbon

GHG Greenhouse Gas

LV Limit Value

PaMs Policies and Measures

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AQP

PAC Directorate

Municipal Programme to improve ambient air quality under Art. 27 (1) CAAA

Protection of Air Cleanness Directorate

PM Programme of Measures

PA Priority Axis

CAPP Clean Air Policy Package of 2013

PM Particulate Matter

café 2001 Clean Air Program for Europe from 2001

CAPE 2013-2030 Clean Air Programme for Europe from 2013-2030

RHI Regional Health Inspectorate of the Ministry of Health

RIEWS Regional Inspectorate of MoEW

UNFCCC United Nations Framework Convention on Climate Change

ESD Effort Sharing Decision

WB World Bank

MCP Medium Combustion Plant (≥ 1 <50MWth)

AIC Average Incremental Cost

JRC Joint Research Centre

SCR Selective Catalytic Reduction

WM With Existing Measures

SCR Selective Catalytic Reduction

SEA Strategic Environmental Assessment

BCR Benefit to Cost Ratio

t Tonne (1000 kg)

TPP Thermal Power Plant

TSAP Thematic Strategy on Air Pollution

EMEPA Management of Environmental Protection Activities

MLGAEC Maintaining the Land in Good Agricultural and Environmental Condition

MA Managing Authority

SFA Solid Fuel Appliance

SF Stakeholder Forum

PM2.5 Fine Particulate Matter (PM2.5)

Hg

Directive 2010/75/EU

Mercury

Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions

MoI Ministry of the Interior

MEN Ministry of Energy

MoH Ministry of Health

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MAFF Ministry of Agriculture, Food and Forestry

MoE Ministry of Economy

MoEW Ministry of Environment and Water

MTITC Ministry of Transport, Information Technology and Communications (MoTITC)

MLSP Ministry of Labour and Social Policy

NAQIP National Air Quality Improvement Programme

SO2 Sulphur Dioxide

SOMO35 The Sum of the Hourly Ozone Concentrations Above 35ppb

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FOREWORD

THE NEED FOR A PROGRAMME

Article 6 of Directive (EU) 2016/2284 requires each EU Member State to draw up, adopt and implement a National Air Pollution Control Programme, to be submitted to the European Commission. Article 10 of the Directive requires that Bulgaria, along with all other twenty-seven Member States, provide its first National Air Pollution Control Programme to the European Commission by 1 April 2019.

The primary objective of Bulgaria’s National Air Pollution Control Programme is to meet its emission reduction commitments relative to 2005 under Directive (EU) 2016/2284, thereby moving towards achieving levels of air quality that do not give rise to significant negative impacts on and risks to human health and the environment. Article 1 and Annex II of Directive (EU) 2016/2284 set emission reduction commitments for the years 2020 and 2030 concerning each Member State’s annual anthropogenic emissions of sulphur dioxide (SO2), nitrogen oxides (NOx), non-methane volatile organic compounds (NMVOC), ammonia (NH3) and fine particulate matter (PM2.5).

Article 1 of revised Directive (EU) 2016/2284 requires that the National Air Pollution Control Programme also contribute to other objectives:

i. the EU’s long-term objective of achieving levels of air quality in line with the air quality guidelines published by the World Health Organization;

ii. the EU’s biodiversity and ecosystem objectives in line with its 7th Environment Action Programme; and

iii. enhanced synergies between the EU’s air quality policy and other relevant EU policies, in particular climate and energy policies.

PRESCRIBED CONTENT AND STRUCTURE OF THE PROGRAMME

Annex III to Directive (EU) 2016/2284 specifies the minimum content of a National Air Pollution Control Programme, whilst Article 6(10) of the Directive states ‘The Commission shall also specify, by means of implementation acts, the format of the national air pollution control programmes.’ In fulfilment of this Article, Commission Implementing Decision (EU) 2018/1522 of 11 October 2018 was adopted, laying down a common format for national air pollution control programmes under Directive (EU) 2016/2284.1 The draft National Air Pollution Control Programme presented here adheres strictly to the common format structure stipulated in Commission Implementing Decision (EU) 2018/1522.

Each chapter of the draft National Air Pollution Control Programme presented here correlates sequentially with a particular section in the common format. The correlation is noted at the start of each chapter.

Chapter 1 presents basic information regarding the programme’s date of issue, title, competent authority, contact details and website links.

Chapter 2.2 provides a summary in the format specified in Decision (EU) 2018/1522. The remaining chapters are presented separately as follows.

Chapter 2.3 provides a summary of the relevant policy framework, stating policy priorities concerning air pollution and relevant priorities in other related sectors, and defines the relevant national, regional and local authorities together with their attributed responsibilities. It states Bulgaria’s emission reduction commitments, defines the applicable ambient air quality objectives, refers to existing (already adopted) legislation affecting sectoral emissions of sulphur dioxide, nitrogen oxides, non-methane volatile organic compounds, ammonia and fine particulate matter, and provides a summary of the policy goals and priorities

1 The Commission Implementing Decision is accessible via https://eur-lex.europa.eu/search.html?qid=1548772629270&whOJ=NO_OJ%3D256,YEAR_OJ%3D2018&type=advanced&lang=en&SUBDOM_INIT=ALL_ALL&DB_COLL_OJ=oj-lbalh

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regarding climate change, energy supply and demand, transport, industry, and agriculture. Annex I accordingly provides, inter alia, further details on adopted legislation and related measures, and on the responsibilities of all authorities concerned.

Chapter 2.4 describes the progress made between 2005 and 2016, as reported in Bulgaria’s National Inventory of Emissions of Harmful Substances, in reducing Bulgaria’s national emissions of sulphur dioxide, nitrogen oxides, non-methane volatile organic compounds, ammonia and fine particulate matter, and progress in achieving its air quality objectives. It also summarises available data on the transboundary impacts of Bulgaria’s air pollutant emissions. Annexes II and III provide more detailed data.

Chapter 2.5 presents the emission projections to 2030 for the aforesaid five pollutants assuming unaltered policies and legal measures (PaMs) – the With Existing Measures (WM) scenario. Related to this chapter, Annex IV notes the problems with certain sectors’ emissions as reported in the National Inventory of Emissions and summarises the approach adopted to compensate for these shortcomings in the WM projections. The chapter presents projected compliance with ambient air quality standards under the WM scenario compared with Bulgaria’s emission reduction commitments for 2020 and 2030. An assessment of the progress towards compliance with Bulgaria’s ambient air quality objectives is also presented, with relevant associated information provided in Annex V.

Chapter 2.6, together with Annex VI, identifies the additional policies and measures considered to enable Bulgaria to meet all its emission reduction commitments in 2020 and 2030. The format of the information provided here on the PaMs considered is dictated by a special requirement of Decision (EC) 2018/1522. Namely, that the required information be submitted to the European Commission on-line, using a ‘PaMs tool’ to be supplied by the European Environment Agency. Annex VII and Chapter 2.6 also provide the summary results of an economic analysis of the residential heating package PaM, its costs and benefits. Chapter 2.6 provides specific further details also, concerning policy options targeting ammonia emissions from agriculture.

Chapter 2.7 provides further information concerning the selected additional measures to meet the emission reduction commitments. For each measure, the additional information provided concerns the proposed implementation timetable, interim targets and indicators, the planned timetable for review, and the competent authorities responsible. Chapter 2.7 also provides the rationale for selecting the proposed measures, and an assessment of their coherence with (i) air quality objectives at national level and (ii) with other relevant plans and programmes established by virtue of the requirements set out in national or EU legislation (e.g. national energy and climate plans).

Chapter 2.8 presents the projected combined impacts up to 2030 of the PaMs on emissions reduction and ambient air quality – the With Additional Measures (WAM) scenario. It states the projected compliance with emission reduction commitments and provides an assessment of ambient air quality compliance to the extent possible. The related Annex VIII notes the main differences, at sectoral level, between the WM and WAM scenarios.

Chapter 3 identifies challenges that may be faced in implementing the selected additional policies and measures, and how they may be met. It notes the potential consequences should implementation falter.

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MANDATORY AND OPTIONAL ELEMENTS

The completion of most sections of a National Air Pollution Control Programme as defined in Decision (EC) 2018/1522 is mandatory: all mandatory sections are reported against in Bulgaria’s National Air Pollution Control Programme. However, the Common Format specifies certain sections whose provision by a Member State is optional.

Sections whose provision is optional are noted below, together with a statement as to whether or not they are provided and, where appropriate, the reason for non-provision:

Common format section

SubjectProgramme reference

Comment

2.2 Executive Summary Chap. 2.2 -2.5.2.2 Quantitative description of projected

improvement of air quality (WM)Not provided Constrained by limited air quality

modelling capacity.2.6.3 Estimation of costs and benefits of

additional PaMs considered to comply with emission reduction commitments

Chap. 2.6.3 Provided for residential heating package

2.7.2 Explanation of the choice made to determine additional selected measures

Chap. 2.7.2 -

2.8.4 A Projected numbers of non-compliant and compliant ambient air quality assessment and management zones (WAM)

Not provided Constrained by limited air quality modelling capacity.

2.8.4 B Maximum exceedances of air quality limit values and average exposure indicators (WAM)


2.8.4 C Illustrations demonstrating the projected improvement in air quality and degree of compliance (WAM)


2.8.4 D Qualitative projected improvement in air quality and degree of compliance (WAM) in case no quantitative data is provided in 2.8.4 A through to 2.8.4 C

Chap 2.8.4 An approximate empirical assessment is made for PM and qualitative assessment for other pollutants.

2.8.5 Projected impacts on the environment (WAM)


THE ‘VOICE’ EMPLOYED IN THE PROGRAMME

It must be understood that wherever the terms ‘we’ and ‘our’ are used in this National Air Pollution Control Programme, they are used deliberately and should be taken to mean the Ministry of Environment and Water in particular, and the Government of Bulgaria in general.

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1. Field Descriptions

2. Common Format

2.1. PROGRAMME TITLE, CONTACT INFORMATION AND WEBSITES

It has to be completed at a later stage after consultation with the Ministry of Environment and Water.

Title of the programme National Air Pollution Control Programme, 2019-2030

Date

Member State Republic of Bulgaria

Name of the competent authority responsible for drawing up the programme

Ministry of Environment and Water

Telephone number of the responsible service

Email address of the responsible service

Link to the website where the programme is published

Link(s) to website(s) on the consultation on the programme

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2.2. EXECUTIVE SUMMARY

This section corresponds to section 2.2 of the ‘Common Format’ in Decision (EC) 2018/1552.

2.2.1. THE NATIONAL AMBIENT A IR QUALITY AND POLLUTION POLICY FRAMEWORK

Bulgaria’s policies regarding ambient air quality and the prevention and control of air pollutant emissions (including sulphur dioxide, nitrogen oxides, non-methane volatile organic compounds, ammonia and PM2.5) are based for the most part on European Union legislation. Bulgaria has adopted the air quality objectives set out in Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and cleaner air for Europe (Directive 2008/50/EC), and Directive 2004/107/EC.

Bulgaria’s climate change, renewable energy, and energy efficiency policies are also closely linked with the legislation, strategies and goals of the European Union. Bulgaria’s current National Strategy for Energy expires in 2020, whilst its Strategy for Sustainable Energy Development is under review. It is expected that the relative roles of lignite, nuclear power, and renewable energy will be considered in the newly adopted strategy.

The Ministry of Environment and Water is the national competent authority for environment issues including the prevention and control of air pollutant emissions. Other sectoral Ministries and State Agencies also have relevant responsibilities, whilst the municipalities have primary responsibility for ambient air quality planning and implementation at the local level.

2.2.2. PROGRESS MADE S INCE 2005 UNDER CURRENT POLICIES AND MEASURES IN REDUCING EMISSIONS AND IMPROVING AMBIENT A IR QUALITY

Emission reductions achieved

Bulgaria’s national emission ceilings, set in accordance with Directive 2001/81/EC in connection with the country’s admission to the European Union, were complied with throughout the period 2010 to 2016. Emission trends since 2005 – taken from Bulgaria’s National inventory of emissions of harmful substances submitted in 2018 to the European Commission – have been driven primarily by the implementation of transposed EU-level legislation, policies and measures. In most cases, reported emissions have fallen over time, sulphur dioxide and nitrogen oxides in particular – see charts below (Figures 3 and 2 respectively in Chapter 2.4).

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For the pollutants NMVOC, ammonia and PM2.5, however, the reported progress in reducing emissions has been limited.

Six sectors were predominant sources of emissions in 2016: residential heating was the principal source of PM2.5 and NMVOC emissions, whilst agriculture was the principal source of ammonia emissions. The energy sector (sulphur oxide and nitrogen oxides), road transport (nitrogen oxides and NMVOC), industrial processes and fugitive emissions (NMVOC and sulphur oxide), and solvent use (NMVOC) were the other major contributing sectors in 2016.

Whilst the historical national emissions inventory is of a good standard with respect to completeness, there are key sources whose emissions have been estimated using a Tier 1 methodology. As a result, the estimated

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historical emissions do not include the impact of implemented policies and measures in certain pollutant-source combinations. Consequently, reported emissions for a number of sectors have been over-estimated. This has implications for the projection of emissions beyond 2016.

Progress towards achieving air quality objectives

Good progress has been made since 2005 in reducing the number of Ambient Air Quality Assessment and Management Zones (AQZs) out of compliance with sulphur dioxide air quality limit values and the hourly limit value for nitrogen oxides, but all six AQZs have been persistently non-compliant with PM10 limit values. Despite the overall improvement in sulphur dioxide (SO2) compliance brought about mainly through the implementation of flue-gas desulphurization at Bulgaria’s lignite-fired power stations, the AQZs in which they are located continue to be non-compliant with the SO2 ambient air quality standards. The number of AQZs non-compliant with the air quality limit values for ozone varied between 1 and 4 over the period, with no particular trend being clearly discernible.

Current Transboundary Impact of National Emission Sources

Bulgaria’s emissions mostly impact within the country, especially in urban areas. However, there are transboundary impacts, with Bulgaria’s emissions contributing to the deposition in neighbouring countries of acidifying and eutrophying pollutants, chiefly sulphur, oxidised and reduced nitrogen. Modelling work conducted under the European Monitoring and Evaluation Programme (EMEP) indicates that, of neighbouring EU Member States, Romania probably receives about 10 % of such pollutants emitted from Bulgaria, whilst Greece probably receives about 5 %. Bulgaria’s emissions of nitrogen oxides and NMVOC also contribute to the formation of ozone and secondary organic aerosols, PM2.5 and PM10, but the modelling work suggests the transboundary impacts ought to be relatively small.

2.2.3. PROJECTED FURTHER EVOLUTION TO 2030 ASSUMING NO CHANGE TO ALREADY ADOPTED POLICIES AND MEASURES (PAMS)

Projected emissions and emissions reductions “With Measures” (WM) scenario

Based on analysis of best available data, sulphur dioxide is expected to be ERC-compliant throughout the period, however, nitrogen oxides, NMVOC, ammonia and PM2.5 are not expected to comply fully with their respective ERCs, particularly in 2030 and beyond. Additional policies and legal measures will be needed for the latter four pollutants to comply with the ERCs. Summarized below are the projected emissions and emissions reductions at five-year intervals for 2020, 2025 and 2030. Cells shaded ‘green’ signify ERC compliance, cells shaded ‘orange’ signify non-compliance.

PollutantEmissions (ktonnes) consistent with

inventory for 2016% Emission reduction compared with 2005

Emission Reduction Commitments (%)

2005 2020 2025 2030 2020 2025 2030 2020-2029 2030+Nitrogen Oxides 183.2

97.3 90.3 85.4 47 % 51 % 53 % 41 % 58 %

NMVOC 80.7 67.8 62.5 55.9 16 % 23 % 31 % 21 % 42 %SO2 ** 771.3 81.4 82.2 85.6 89 % 89 % 89 % 78 % 88 %Ammonia 51.6 46.3 47.0 47.0 10 % 10 % 9 % 3 % 12 %PM2.5 30.9 28.9 24.5 18.5 6 % 21 % 40 % 20 % 41 %Date of Emission Projections January 2019

* Nitrogen oxides and NMVOC emissions does not include 3B, 3D and agriculture sectors.** SO2 emissions in baseline 2005 are different from the last value in the National Inventory of Emissions for reasons elaborated in Annex IV.

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Projected impact on improving air quality (WM scenario)The WM projected reduction in national particulate emissions (PM10 and PM2.5) from the residential and transport sources combined (the principal sources of primary emissions) may, in some localities, be sufficient to achieve compliance with PM10 ambient air quality standards by 2020, with a greater extent of compliance in later years. Nevertheless, in the absence of additional measures, Air Quality Zones are likely to remain non-compliant with PM10 even in 2030. This assessment relies on some simplifying assumptions and an empirical association between the annual average monitored PM10 concentration and the annual number of exceedances of the daily Limit Value for PM10 of 50µg/m3, shown in the chart below. This approach has been adopted since Bulgaria has limited capacity for undertaking large-scale pollutant dispersion and ambient air quality modelling.

Plot of the annual mean PM10 in Bulgaria (2016) against the number of days exceeding 50µg/m3 (ExEA data)

Series2; 43.61Series2; 41.07

Series2; 19.66

Series2; 45.17


Series2; 37.19Series2; 41.74Series2; 40.40Series2; 37.79

Series2; 31.40

Series2; 47.16


Series2; 34.84

Series2; 25.71

Series2; 42.82

Series2; 52.67


Series2; 25.05

Series2; 42.74


Series2; 15.30

Series2; 31.75Series2; 29.99Series2; 32.05

Series2; 61.26

Series2; 37.67

No. Days > 50 µg/m3

Annu

al M

ean

PM10

Uncertainties

The WM projected reductions in nitrogen oxides, NMVOCs and NH3 emissions in the WM scenario should contribute to a modest improvement of ambient air quality in Bulgaria. They should also contribute to a reduction in the secondary PM2.5 material and therefore reduce PM concentrations.

2.2.4. OPTIONS CONSIDERED FOR A POLICY TO ACHIEVE COMPLIANCE WITH THE EMISSION REDUCTION COMMITMENTS FOR THE PERIOD 2020-2030, AND INTERMEDIATE EMISSION LEVELS FOR 2025

Main policy options considered

Policy options considered to achieve compliance with Bulgaria’s emission reduction commitments lie in the residential heating, road transport and agriculture sectors. The additional policies and legal measures (PaMs) considered are identified below.

Sector Additional PaMs Considered

Residential heating (National Air Quality Improvement Programme (NAQIP))

- R1: Introduction of national requirements for coal quality, surrogate measures to reduce the moisture content of firewood used in municipalities that fail PM10

ambient air quality criteria and, potentially, a maximum moisture content requirement for firewood [in those areas]

- R2 Bring forward the date at which Regulation (EU) 2015/1185 with regard to ecodesign requirements for solid fuel local space heaters comes into effect; and a compulsory, accelerated phase-out of traditional, polluting solid-fuel heating appliances (stoves) in municipalities where ambient air quality has not complied

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with PM10 LVs; coupled with:- R3: Households affected by the compulsory phase-out of traditional stoves to

switch to heating by natural gas, district heating, electricity or ecodesign-compliant heating appliances.

Road Transport - RT1 Modernisation of vehicle fleet through allowing “cleaner” imports only- RT2: Establishing low emission zones (LEZs) in Sofia and Plovdiv to limit the

demand for access of older, polluting types of road vehicle.Agriculture Implement Good Agricultural Practice Rules to reduce ammonia emissions from

agricultural sources, based on the United Nations Economic Commission for Europe Framework Code for Good Agricultural Practice for Reducing Ammonia Emissions. The Rules will recommend good practices for applying nitrogen containing fertilisers to soils and good practices for managing cattle manure. The Rules will be disseminated through agricultural outreach. The impacts will be monitored by survey, the results feeding back into the

National Inventory of Emissions of Harmful Substances in the Ambient Air and into future emissions projections.

- A1: concerns the application of fertilisers (and manures) to soils- A2: concerns the management of cattle manure.

The residential heating package primarily affects PM and MVOC emissions, whereas the road transport and agricultural PaMs principally affect nitrogen oxides and ammonia emissions respectively. The analysis of benefits and drawbacks shows that all elements of the residential heating package add value for society. The projected pollutant emission reductions resulting from each PaM in isolation, relative to the WM scenario, are summarized below at five-year intervals:

Policies and Measures

Principal Pollutants(s)

Projected emission reduction(kt/y) relative to WM scenario2020 2025 2030

NAQIPR1 + R2 + R3

PM2.5 6.4 10.9 10.0NMVOC 5.6 9.2 8.9

RT1 Nitrogen Oxides

1.4 3.0 4.8RT2 1.6 1.7 4.1A1

Ammonia0.4 0.8 0.9

A2 0.8 2.0 2.1

2.2.5. SUMMARY OF POLICIES AND MEASURES SELECTED FOR ADOPTION BY SECTOR , INCLUDING A T IMETABLE FOR THEIR ADOPTION , IMPLEMENTATION AND REVIEW, AND THE COMPETENT AUTHORITIES RESPONSIBLE

All policy options considered to meet the emission reduction commitments have been selected for inclusion in the National Air Pollution Control Programme. Summarized below, for each package of policies and measures (PaMs) or individual PaM, are the implementation timetable, competent authorities, and review timetable for each policies and measures package.

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Selected Policies and Measures Affecting Energy Consumption – Residential Heating

Selected PaMTimetable for

implementing the selected PaM

Responsible competent authorit(y)(ies) Timetable for review of the selected PaM

PaM implementation PaM enforcement

NAQIPR1 + R2 + R3

2019/20 to 2025/30

Ministry of Environment and Waters, Ministry of Economy, Ministry of Agriculture, Food and Forestry, Ministry of Labour and Social Policy, Municipalities

SAMTS, MAFF, Executive Forest Agency, State Forest Enterprises and municipal forest structures

Annually

Selected Policies and Measures Affecting the Transport Sector

Selected PaM

Timetable for implementin

g the selected PaM

Responsible competent authorit(y)(ies)Timetable for review of the selected PaM


RT1 2020-2021 Ministry of Transport, Information Technology and Communications

Executive Agency Automobile Administration

Annually

RT2 2019-2024 Ministries of Transport, Information Technology and Communications; Environment and Water; and Regional Development and Public Works. Municipalities.

Municipalities Annually

Selected Policies and Measures Affecting the Agriculture Sector

Selected PaMTimetable for

implementing the selected PaM

Responsible competent authorit(y)(ies) Timetable for review of the selected PaM


A1 2019-2030 Ministry of Agriculture, Food and Forestry

Ministry of Agriculture, Food and Forestry

Annually

A2 2019-2030 Ministry of Agriculture, Food and Forestry


Annually

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2.2.6. COHERENCE

An assessment of how the selected PaMs ensure coherence with plans and programmes set up in other relevant policy areas

The assessment of the selected PaMs was based on the same fuel use projections that are in the national strategy for reducing greenhouse gasses and include a reduction in final energy demand for fuels from energy efficient and renewable energy sources. They are wholly coherent with the ambient air quality objectives of Bulgaria and take account of the air quality objectives of neighbouring Member States. PaMs selected include those in the NAQIP which are expected to resolve essentially the principal air quality issue in Bulgaria – particulate matter pollution.

The selected PaMs are also fully coherent with plans and programmes established in other policy areas, such as the current National Energy Strategy; Bulgaria’s greenhouse gas emissions projections and Climate Change programme; and the Energy Efficiency Act.

2.2.7. PROJECTED COMBINED IMPACTS OF THE POLICIES AND MEASURES (‘W ITH ADDITIONAL MEASURES ’ – WAM) ON EMISSION REDUCTIONS, AMBIENT A IR QUALITY IN THE NATIONAL TERRITORY AND IN THE TERRITORIES OF NEIGHBOURING MEMBER STATES AND THE ENVIRONMENT , AND THE RELATED UNCERTAINTIES

Projected attainment of emission reduction commitments (WAM)

Projected emissions under the WAM scenario are consistent with Bulgaria meeting its emission reduction commitments for each of the five pollutants considered. The projected emissions data are presented below and the projected percentage emission reductions are compared with Bulgaria’s emission reduction commitments.

Projected emissions, emission reductions, and compliance with commitments (WAM Scenario)

Pollutant

Emissions (ktonnes) consistent with inventory for 2016

% Emission reduction compared with 2005


2005 2020 2025 2030 2020 2025 2030 2020-2029 2030+

Nitrogen Oxides *

183.2 93.8 84.4 74.7 49 % 54 % 59 % 41 % 58 %

NMVOC * 80.7 62.1 53.3 46.3 23 % 34 % 43 % 21 % 42 %

SO2 ** 771.3 79.6 80.2 83.4 90 % 90 % 89 % 78 % 88 %

Ammonia 51.6 45.0 44.1 43.8 13 % 15 % 15 % 3 % 12 %

PM2.5 30.9 22.2 13.3 7.8 28 % 57 % 75 % 20 % 41 %Date of Emission Projections 27 January 2019

* Nitrogen oxides and NMVOC emissions from 3B, 3D agricultural sources are not taken into account

** SO2 emissions in baseline 2005 are different from the last value in the National Inventory of Emissions for reasons elaborated in Annex IV.

Apart from the pollutant PM2.5, the projected margins of compliance in 2030 are relatively slim. Hence vigilance will need to be exercised to ensure that the efficiency improvements expected under existing

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measures materialize, and that the additional measures are implemented rigorously. In future years, when the emission projections have to be updated (every two years) and the National Air Pollution Control Programme revised (every four years), and if the projected emission reductions are not realized, then further additional measures might need to be identified and applied in order to meet the emission reduction commitments.

Projected improvement in air quality (WAM)

The expected significant reductions in PM2.5 and PM10 emissions – a 75 % reduction nationally between 2016 and 2030, from 31.9 to 7.8 ktonnes/y – should enable PM compliance of all municipalities that have been non-compliant with PM10 limit values in the recent past. Regarding PM10, therefore, we expect that the projected emissions reduction will be accompanied by improvements in air quality and the compliance of all AQZs. Full implementation of the selected PaM package regarding residential heating could allow compliance to be achieved in many municipalities and AQZs by 2025.

It is expected that the projected reductions in emissions of other pollutants will contribute further to improving air quality in Bulgaria and in neighbouring countries and areas. However, the impacts in terms of AQ zone compliance cannot be reported with confidence.

Projected impact on the environment (with additional measures)

See 2.8.5

Methodologies and uncertainties

The National Air Pollution Control programme has been prepared using the best available information. There are incomplete calculations in the historical national inventory of emissions resulting from the adoption of flawed methodologies and data, which are identified in the Programme. It is our intention that these flaws will be addressed prior to the 2021 submission of the emission projections.

CONCLUSIONS

Adopting the best available information available, the present National Air Pollution Control Programme demonstrates that Bulgaria can meet all its emission reduction commitments for 2020 and 2030. However, achieving this goal will depend on five conditions being met.

Condition 1: That the suite of existing policies and legislative measures continues to be applied in the sectors considered in the NAPCP. Relevant existing PaMs include making incremental improvements in material and energy efficiency in industry, residential and other buildings, and transport. They also include applying BAT in industrial and energy transformation installations to prevent or reduce pollutant emissions in a cost-effective manner; and continuing to apply the Nitrates Directive to reduce ammonia emissions from fertilizer use in agriculture.

Condition 2: That the procedures and methodologies employed to produce the National Inventory of Emissions are upgraded in order to reflect real improvements in emissions reduction performance. Preparation of the draft NAPCP has been based on the Inventory submitted to the EC in February 2018, for which 2016 was the last year of emissions data.

Many sector-pollutant combinations in the historical emissions inventory have been estimated using Tier 1 methodologies which, as they assume a constant emission factor over time, have failed to reflect the beneficial impacts of existing PaMs. This factor diminishes the value of the National Inventory of Emissions as a policy tool.

Significant sector-pollutant combinations where this has been an issue, and where compensating adjustments have been made in the emissions projection methodologies, include: agriculture (ammonia emissions from

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manure management and nitrogen fertilizer application); chemical processes (nitrogen oxides emissions from nitric acid production, sulphur oxide emissions from the production of sulphuric acid and, potentially, other chemical products); solvent use (NMVOC emissions from solvent containing products used by householders and others); residential heating (PM emissions from heating appliances using solid fuels).

Methodologies for preparing the historical inventory of emissions need to be upgraded, therefore, in order to serve the purposes of present and future emission projections, and to provide a more reliable means of tracking historical emissions. Institutional barriers to information exchange also impede the reporting of emissions in the inventory with sufficient accuracy, causing knock-on effects for emission projections. The exact composition of chemical products is one example of this issue.

Condition 3: That the additional PaMs proposed for the residential heating, road transport and agricultural sectors are implemented as scheduled. The National Air Quality Improvement Programme (NAQIP) forms an integral component of the National Air Pollution Control Programme, hence the residential heating sector PaM package and road transport Low Emissions Zone PaM have been reviewed extensively by stakeholders in Bulgaria already. Unquestionably, implementation challenges exist in the residential heating and road transport sectors. Both involve measures that would affect trade to varying extents, requiring European Commission approval. Were these approvals not secured, the impacts of the residential heating package would be delivered more slowly, and alternative road transport PaMs would have to be developed.

The residential heating PaM package contains elements that will be unpopular and challenge traditional practices. Effective communication as to why the package is proposed will be essential and the sources of finance will have to be secured and agreed. The cost-benefit analysis undertaken for the residential heating sector demonstrates that the policy package will be beneficial, adding value to society, and indicates a clear overall ranking of the components – though their interrelation needs to be appreciated.

Condition 4: That, when adopted, the impacts of Bulgaria’s Strategy for Sustainable Energy Development are neutral or benign on Bulgaria’s emissions of Directive (EU) 2016/2284 air pollutants. If the impacts are adverse it will be necessary to identify, assess and implement further additional PaMs.

Submission to the European Commission of revised emission projections and an updated National Air Pollution Control Programme is scheduled for 2021 and 2023, respectively, providing time for any impacts from the Strategy for Sustainable Energy Development to be identified.

Condition 5: That efficient inter-Ministerial collaboration is provided for in order to ensure that the NAPCP is implemented, monitored and amended where appropriate in an effective manner. And that appropriate institutional capacity in the areas of emissions inventory preparation and emissions projections is developed in order to facilitate the best practice preparation and submission of (i) a national inventory of emissions of harmful substances in the ambient air, each year (ii) emissions projections every two years, and (iii) a revised and updated National Air Pollution Control Programme every four years.

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2.3. THE NATIONAL AIR QUALITY AND POLLUTION POLICY FRAMEWORK

2.3.1. POLICY PRIORITIES AND THEIR RELATIONSHIP TO PRIORITIES SET IN OTHER RELEVANT POLICY AREAS

Table 1 states Bulgaria’s national emission reduction commitments under Directive (EU) 2016/2284.

Table 1. Bulgaria’s national emission reduction commitments compared with the 2005 base year (in %)

Period

Emission reduction commitments compared with 2005 base year for specific pollutants (%)

Sulphur DioxideNOx Nitrogen

OxidesNMVOC

Ammonia PM2.5

2020-2029 78 % 41 % 21 % 3 % 20 %

From 2030 88 % 58 % 42 % 12 % 41 %

AMBIENT A IR QUALITY PRIORITIES

Bulgaria adopts the ambient air quality objectives set out in Directive 2008/50/EC, Cleaner Air for Europe Programme of 2001 (Directive 2008/50/EC), and Directive 2004/107/EC. Limit Values, target values (where appropriate), averaging periods, maximum permissible number of Limit Value exceedances (where appropriate), and exposure concentration obligations (where appropriate), are given below for sulphur dioxide, nitrogen dioxide, PM10, PM2.5, and ozone. Annex I gives limit and target values for other air pollutants referred to in Directive 2008/50/EC and Directive 2004/107/EC.

Limit values for sulphur dioxide:

The limit values to be met by 1 January 2005 are:

a) 350 µg/m3, for an averaging period of one hour, not to be exceeded more than 24 times a calendar year, with a margin of tolerance of 150 µg/m3 (43 %); and

b) 125 µg/m3, for an averaging period of one day, not to be exceeded more than 3 times a calendar year, with no margin of tolerance.

Limit values for nitrogen dioxide:

The limit values, to be met by 1 January 2010, are:

a) 200 µg/m³, for an averaging period of one hour, not to be exceeded more than 18 times a calendar year, with a margin of tolerance that was set to reach zero by 1 January 2010; and

b) 40 µg/m3, for an averaging period of one calendar year, and a margin of tolerance that was set to reach zero by 1 January 2010;

Limit values for fine particulate matter (PM10):

The limit values to be met by 1 January 2005 are:

a) 50 µg/m3, for an averaging period of one day, not to be exceeded more than 35 times a calendar year, and a margin of tolerance of 50 %; and

b) 40 µg/m3 for an averaging period of one calendar year and a margin of tolerance of 20 %.

Air quality priorities related to PM2.5:

a) The limit value was 25 µg/m3 for stage one for an averaging period of one calendar year to be met by 1 January 2015 (with a margin of tolerance of 20 % on 11 June 2008, decreasing on the next 1 January and every 12 months thereafter by equal annual percentages to reach 0 % by

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1 January 2015). The limit value is 20 µg/m3 for stage two to be met by 1 January 2020, with no margin of tolerance.

b) The target value is 25 µg/m3 for an averaging period of one calendar year. The date by which the target value was supposed to be met was 1 January 2010.

The exposure concentration obligation is 20 μg/m3 and the obligation value was to be met by 2015.

Target value for ozone:

For the objective of protecting human health, the target value is 120 μg/m3, not to be exceeded on more than 25 days per calendar year averaged over three years, with a maximum daily averaging period of eight hours.

For the objective of protecting vegetation, the target value is AOT40 (calculated from 1-h values)/ 18 000 μg/m3

averaged over five years for an averaging period of May to July. Both target values were to be met by 1 January 2010.

EMISSIONS PREVENTION AND CONTROL PRIORITIES

Complementing Bulgaria’s air quality objectives and national emissions reduction obligations, summarized above, Bulgaria has adopted all EU legislation directed at the prevention of control of pollutant emissions in specific sectors. Table 2 states the EU Directives and Regulations that impact significant sectoral emissions of sulphur dioxide, nitrogen oxides, NMVOC, NH3 and PM2.5. It includes key Directives targeting renewable energy and energy efficiency also. Policy regarding renewable energy and energy efficiency, which indirectly impact the emissions of these pollutants is addressed in Section 2.3.1. under the heading of climate change and energy policy priorities. Table 2 summarizes also the aims of each policy instrument, whilst Section I.2 of Annex I summarizes the associated measures and states the EU instruments transposed in the Bulgarian legislation.

The emission reduction effects of these measures from 2005 to 2016, and the impact of other factors over this period, are reported in Section 2.4. Assuming no additional measures, the projected emissions for the period up to and including 2030 are reported in Section 2.5.

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Table 2. Principal EU policy instruments aimed at the prevention and control of harmful substances emissions to air: see Annex I for EU instruments transposed in the Bulgarian legislation

Policy Instrument Scope and Purpose

Directives

Directive 94/63/EC on the control of volatile organic compound (VOC) emissions resulting from the storage of petrol and its distribution from terminals to service stations

Applies to the operations, installations, vehicles and vessels used for storage, loading and transport of petrol from one terminal to another or from a terminal to a service station.

Directive 98/69/EC relating to measures to be taken against air pollution by emissions from motor vehicles and amending Directive 70/220/EEC

Revises type approval testing of light-duty vehicles as specified in the earlier Directive 70/220 to minimize air pollution from these vehicles.

Directive 98/70/EC relating to the quality of petrol and diesel fuels and amending Directive 93/12/EEC

Sets revised technical specifications on health and environmental grounds for fuels to be used for vehicles equipped with positive-ignition and compression-ignition engines.

Directive 2004/42/EC on the limitation of emissions of VOCs due to the use of organic solvents in certain paints and varnishes and vehicle refinishing products and amending Directive 1999/13/EC

Its purpose is to prevent or reduce VOC emissions through limiting the total content of VOCs in certain paints, varnishes & vehicle refinishing products.

Directive 2007/46/EC establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles

Applies to the type-approval of vehicles designed and constructed in one or more stages for use on the road, and of systems, components and separate technical units designed and constructed for such vehicles. It also applies to the individual approval of such vehicles, and to parts and equipment intended for vehicles covered by this Directive.

Directive 2009/28/EC on the promotion of the use of energy from renewable sources and amending and subsequently repealing Directives 2001/77/EC and 2003/30/EC, Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources

Requires that the share of Bulgaria of energy from renewable sources in all types of transport in 2020 is at least 10 % of the final consumption of energy in transport. Share of energy from RES in the final consumption of energy in the transport sector by 2030 – 14 %.

Directive 2009/125/EC establishing a framework for the setting of Eco-design requirements for energy-related products as amended by Directive 2012/27/EU and implemented through Regulations (EU) 813/2013, (EU) 2015/1185, (EU) 2015/1188, and (EU) 2015/1189

Establishes a framework for setting Community Eco-design requirements for energy-related products with the aim of ensuring the free movement of such products within the internal market. Provides for the setting of requirements which the energy-related products must fulfil to be placed on the market and/or put into service.

Directive 2009/126/EC on Stage II petrol vapour recovery during refuelling of Lays down measures aimed at reducing the amount of petrol vapour emitted to the

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motor vehicles at service stations atmosphere during the refuelling of motor vehicles at service stations.

Directive 2010/31/EU on the energy performance of buildings, as amended by Directive 2018/844/EC

Requires that Bulgaria shall adopt a long-term renovation strategy that describes measures to (i) support the renovation of the national stock of residential and non-residential buildings, both public and private, into a highly energy efficient and decarbonized building stock by 2050, and (ii) facilitate the cost-effective transformation of existing buildings into nearly zero-energy buildings.

Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control)

Applies to most industrial activities (potentially) giving rise to pollution. The Directive recasts several earlier Directives including, of importance to Directive 2016/2284: Directive 1999/13/EC on the limitation of emissions of volatile organic

compounds due to the use of organic solvents in certain activities and installations

Directive 2000/76/EC on the incineration of waste (WID) Directive 2001/80/EC on the limitation of emissions of certain pollutants into

the air from large combustion plants (LCPD), affecting inter alia the emissions of sulphur dioxide, nitrogen oxides and particulate material

Directive 2008/1/EC concerning the application of integrated pollution prevention and control (IPPC) and best available techniques (BAT)

Directive 2012/27/EU on energy efficiency, amending Directives 2009/125/ЕC and 2010/30/ЕU and repealing Directives 2004/8/ЕC and 2006/32/ЕC, Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 amending Directive 2012/27/EU on energy efficiency

Establishes a common framework of measures to promote energy efficiency in the Union, in order to ensure the achievement of the main objective of the Union – energy efficiency of 32.5 % by 2030 and paves the way for further energy efficiency improvements beyond that date.

Directive (EU) 2015/2193 25 November 2015 on the limitation of emissions of certain pollutants into the air from medium combustion plants

Lays down rules to control emissions of Sulphur dioxide, nitrogen oxides and dust into the air from medium combustion plants (≥1 MWth < 50 MWth).

Directive (EU) 2016/802 relating to a reduction in the Sulphur content of certain liquid fuels (and amending Directive 1999/32/EC).

Its purpose, through amending fuel quality standards, is to reduce the emissions of Sulphur dioxide resulting from the combustion of certain types of liquid fuels.

Regulations

Regulation (EC) No 715/2007 on type approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information

Establishes common technical requirements for the type approval of motor vehicles and replacement parts such as pollution control devices, regarding their emissions. It establishes inter alia emission limits for carbon monoxide, nitrogen

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oxides total hydrocarbons and NOx and particulate matter for these classes of vehicles. It also lays down rules for in-service conformity, durability of pollution control devices, on-board diagnostic (OBD) systems, measurement of fuel consumption and accessibility of vehicle repair & maintenance data.

Regulation (EC) No 595/2009 on type-approval of motor vehicles and engines with respect to emissions from heavy duty vehicles (Euro VI) and on access to vehicle repair and maintenance information and amending Regulation (EC) No 715/2007 and Directive 2007/46/EC and repealing Directives 80/1269/EEC, 2005/55/EC and 2005/78/EC

Applies to motor vehicles of categories M1, M2, N1 and N2 as defined in Annex II of Directive 2007/46/EC with a reference mass exceeding 2 610 kg and to all motor vehicles of categories M3 and N3, as defined in that Annex. Establishes inter alia emission limits for CO, nitrogen oxides ammonia and particulate matter for these classes of vehicles.

Regulation (EU) No 813/2013 implementing Directive 2009/125/EC with regard to Eco-design requirements for space heaters and combination heaters

Establishes Eco-design requirements – inter alia energy efficiency and nitrogen oxides emissions – for the placing on the market and/or putting into service of space heaters and combination heaters with a rated heat output ≤ 400 kW.

Regulation (EU) 2015/1185 implementing Directive 2009/125/EC with regard to Eco-design requirements for solid fuel local space heaters

Establishes Eco-design requirements – inter alia standards for energy consumption and for the emission of FPMs, organic gaseous compounds (OGC), carbon monoxide and nitrogen oxides – for the placing on the market and putting into service of solid fuel local space heaters with a nominal heat output of 50 kW or less.

Regulation (EU) 2015/1188 of 28 April 2015 implementing Directive 2009/125/EC with regard to Eco-design requirements for local space heaters

Establishes Eco-design requirements for the placing on the market and putting into service of domestic local space heaters with a nominal heat output of 50 kW or less and commercial local space heaters with a nominal heat output of the product or of a single segment of 120 kW or less.

Regulation (EU) 2015/1189 implementing Directive 2009/125/EC regarding Eco-design requirements for solid fuel boilers

Establishes Eco-design requirements – inter alia emissions of particulate matter, organic gaseous compounds, CO and nitrogen oxides – for placing on the market and putting into service solid fuel boilers with a rated heat output of 500 kilowatt (‘kW’) or less, including those integrated in packages of a solid fuel boiler, supplementary heaters, temperature controls and solar devices as defined in Regulation (EU) 2015/1187.

Regulation (EU) 2016/1628 on requirements relating to gaseous and particulate pollutant emission limits and type-approval for internal combustion engines for non-road mobile machinery, amending Regulations (EU) No 1024/2012 and (EU) No 167/2013, and amending and repealing Directive 97/68/EC

Establishes emission limits for gaseous and particulate pollutants emissions from internal combustion engines for non-road mobile machinery. It establishes inter alia exhaust limit values for emissions of carbon monoxide, nitrogen oxides, and particulates for a range of these engines.

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Regulation (EU) 2017/654 supplementing Regulation (EU) 2016/1628 with regard to technical and general requirements relating to emission limits and type-approval for internal combustion engines for non-road mobile machinery

To complete the framework established by Regulation (EU) 2016/1628, it set outs technical and general requirements and test methods relating to emission limits, and EU type-approval procedures for internal combustion engines for non-road mobile machinery.

Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the Governance of the Energy Union and Climate Action

The draft Integrated Energy and Climate Plan for Bulgaria has been drafted and submitted to the EC in line with the requirements of this Regulation.

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RELEVANT CLIMATE CHANGE AND ENERGY POLICY PRIORITIES

General goal 1 (2020): Meeting targets for reduction of GHG emissions under EU law (2020 climate and energy package) and Kyoto Protocol (second commitment period).

- Under the United Nations Framework Convention on Climate Change (UNFCCC) (1992) and the Kyoto Protocol (1998), as amended In 2012 (Doha Amendment) in the period of 2013-2020 Bulgaria is committed to achieve a 20 % reduction of GHG emissions from base year 1988.

General goal 2 (2030): Meeting targets for reduction of GHG emissions under EU law (2030 climate and energy package) and Paris Agreement:

- International efforts to combat climate change from 2020 onwards are regulated by the UN Paris Agreement (2015). In 2015 the EU and its Member States communicated their commitment to a binding target of achieving a 40 % domestic reduction in greenhouse gas emissions by 2030 , at least, compared to 1990. The EU level target is shared between the EU Emissions Trading Scheme (ETS) and what the Member States achieve collectively in sectors outside of the ETS. The ETS sector has to deliver a GHG reduction of 43 % by 2030, and the non-ETS sector – a 30 % reduction – both reductions refer to emissions in 2005.

International commitments adopted by the EU regarding GHG emissions reduction are fulfilled via three major instruments:

- EU ETS for Carbon Dioxide allowances (Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC).

- Effort Sharing Decision (Decision No 406/2009/EC of the European Parliament and of the Council of 23 April 2009, on the effort of Member States to reduce their greenhouse gas emissions to meet the Community’s GHG emission reduction commitments up to 2020). It should be highlighted that Bulgaria is a country with a positive limit under Annex II to ESD and is allowed to increase its greenhouse gas emissions under ESD compared to 2005, but to a limited extent in order to contribute to the independent reduction commitment of the Community (up to 20 % permitted increase as from the base year 2005).

- Regulation (EU) 2018/842 of the European Parliament and of the Council of 30 May 2018 on binding annual greenhouse gas emission reductions by EU MS from 2021 to 2030 contributing to climate action to meet commitments under the Paris Agreement and amending Regulation (EU) No 525/2013. Under this Regulation, Bulgaria’s greenhouse gas emission reductions in 2030 in relation to the 2005 levels shall be at least zero % i.e. less than or no greater than the base year (applicable to the greenhouse gas emissions from Intergovernmental Panel on Climate Change for source categories of energy, industrial processes and product use, agriculture and waste as determined pursuant to Regulation (EU) No 525/2013, excluding greenhouse gas emissions from the activities listed in Annex I to Directive 2003/87/EC.)

Specific National (Bulgarian) Goals and Priorities are set in the Third National Action Plan on Climate Change (2013-2020):

А) Energy: - low-carbon power generation from coal plants; - reducing the carbon intensity of the electricity mix; - modernized development of the central heating system; - accelerated development of decentralized energy production; - development of low-carbon transmission and distribution networks for electricity and natural gas.

B) Energy Efficiency and Renewable Energy Sources (RES): - proactive national policy that stimulates the efficient use of energy resources and the economically

viable development of RES;

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- a proactive national policy to stimulate the efficient use of energy resources and the economically viable development of energy;

- improving the energy performance of buildings. - improving efficiency and realizing savings in final fuel and energy consumption; - increasing the efficiency of transformation of a primary energy carrier; - promoting decentralized energy production, including energy from RES.

C) Industry: - improving energy efficiency in industry; - use of alternative fuels; - building a technology park and business incubator.

D) Waste management: - reduce the amount and prevent the generation of waste that releases greenhouse gases during its

disposal; - capture and burning of biogas from landfilled waste; - capture of biogas at urban waste water treatment plants and its incineration.

E) Agriculture - reduction of emissions from agricultural soils; - reduction of meth emissions from biological fermentation in livestock breeding; - improving the management of manure optimizing the use of plant residue in agriculture; - improvement of management and the technology for the production of rice; - increasing the information and knowledge of the manufacturers of agricultural product and of the

administration concerning their action and effect on climate changes.

F) LALUCF: - increase in the absorption of greenhouse gases; - storage of carbon stocks in forests; - increase the potential of forests to capture carbon.

G) Transport: - reduction of transport emissions; - reducing fuel consumption; - diversification of transportation; - informing and educating consumers.

H) Science and Education:- validation of the climate change issue and reducing GHG emissions in the education process; - concentration of research into the topic of reduction of greenhouse gas emissions and its sectoral

aspects.

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Relevant Energy Policy Priorities

Bulgaria’s Strategy for Sustainable Energy Development is under review at the time of writing (25 February 2019)2.

Hence, the strategic priorities noted below are taken from the current Energy Strategy of the Republic of Bulgaria (2011-2020). Bulgaria’s commitments to a number of supply and demand goals in the energy sector are summarized.

ENERGY STRATEGY (2011-2020)

Strategic Goal: observe EU legislation and participate in and contribute to the fulfilment of EU policy commitments and initiatives such as the Energy Union Strategy and the Energy Security Strategy.

Specific National Goals and Priorities are set in the Energy Strategy of the Republic of Bulgaria (2011-2020): - Reducing dependence on imports of energy resources, especially those with unstable and

unmanageable prices; - Diversification of suppliers and sources; - Diversification of routes; - Less energy use, resulting from improved energy efficiency in production and in energy consumption; - Use of cleaner energy, meaning improving energy mix through increasing the share of low-emission

energy; - Rapid technological progress, incl. introducing new energy (clean coal) technologies; - Maintaining a secure, stable and reliable energy system; - Sustained leading position of energy branch within the structure of the national economy with a clear

foreign trade orientation;- Emphasis on clean and low-emission energy – nuclear and renewable; - Quantity, quality and price balance of electricity produced from renewable sources, nuclear energy, coal

and natural gas; - Transparent, efficient and highly professional management of energy companies.

In relation to ambient air quality and air pollution it is essential to mention that the (2011-2020) Energy Strategy highlights the importance of gasification, envisaging that, by 2020, at least 30 % of households will have access to natural gas for their residential heating needs.

RENEWABLE ENERGY

General goal 1 (2020): Meeting RES targets under EU law (2020 climate and energy package)

- Ensuring that the share of energy from renewable sources in gross final energy consumption in 2020 reaches or exceeds the national overall target for that year set out in the third column of the table in part A of Annex I to Directive 2009/28/EC. Such mandatory national overall targets are consistent with a target of at least a 20 % share of energy from renewable sources in the Community’s gross final consumption of energy in 2020.

- The national overall target of Bulgaria for the share of energy from renewable sources in the gross final energy consumption in 2020 is: Target for share of energy from renewable sources in gross final consumption of energy, 2020

(S2020) – 16.0 %

2 A draft overview was made public early in 2019 and is under discussion. We expect that future submissions of Bulgaria’s revised emission projections and National Air Pollution Control Programme, in 2021 and 2023 respectively, will incorporate the final, adopted Strategy for Sustainable Energy Development.

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- Ensuring that Bulgaria’s share of energy from renewable sources in all forms of transport in 2020 is at least 10 % of the final consumption of energy in transport (Directive 2009/28/EC)

General goal 2 (2030): Meeting targets for reduction of GHG emissions under EU law (2030 climate and energy package):

- Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources stipulates that Member States must collectively ensure that the share of energy from renewable sources in the Union’s gross final consumption of energy in 2030 is at least 32 %. An upwards revision clause by 2023 is also provided for. Member States should set national contributions to meet, collectively, the binding overall EU target as part of their integrated national energy and climate plans in accordance with Articles 3 to 5 and 9 to 14 of Regulation (EU) 2018/1999.

Specific National Goals and Priorities are set in Bulgaria’s National Renewable Energy Action Plan (2012-2020) including meeting sectoral RES targets in the Heating and Cooling, Energy production and Transport sectors.

Specific National Goals and Priorities are set in Bulgaria’s National long-term programme for the promotion of use of biomass (2008-2020): - Support for the development and use of renewable energy sources; - Sustainable energy development; - Minimization of the harmful environmental impact from activities in the energy sector; - Mitigation of the effects of climate change and meeting the targets established under the Kyoto Protocol; - Reducing dependence on imported energy resources; - Minimizing the risks associated with the supply of energy.

ENERGY EFFICIENCY

General goal 1 (2020): Meeting Energy Efficiency targets under EU law (2020 climate and energy package)

- The binding EU energy efficiency target is a 20 % increase by 2020 compared to projections (made in 2007).

- The energy efficiency targets set by Bulgaria for 2020 in accordance with Directive 2012/27/EU on energy efficiency are expressed in absolute annual consumption quantities (million tonne oil equivalent, Mtoe), as follows: Primary energy consumption (Mtoe/y) – 1.59 Final energy consumption (Mtoe/y) – 0.716

- Additionally, under Directive 2010/31/EU on the energy performance of buildings, Bulgaria is required to ensure that by 31 December 2020 all new buildings are nearly zero-energy buildings; and that after 31 December 2018, new buildings occupied and owned by public authorities are nearly zero-energy buildings.

General goal 2 (2030): Meeting Energy Efficiency targets under EU law (2030 climate and energy package):

- Under Directive (EU) 2018/844 of the European Parliament and of the Council of 30 May 2018 amending Directive 2010/31/EU on the energy performance of buildings and Directive 2012//27/EU on energy efficiency, Bulgaria shall adopt a long-term renovation strategy that describes measures to (i) support the renovation of the national stock of residential and non-residential buildings, both public and private, into a highly energy efficient and decarbonized building stock by 2050, and (ii) facilitate the cost-effective transformation of existing buildings into nearly zero-energy buildings. The long-term renovation strategy shall set out a roadmap with measures and domestically established, measurable progress indicators, with a view to the long-term 2050 goal of reducing greenhouse gas emissions in the Union by 80-95 %

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compared to 1990. The roadmap shall include indicative milestones for 2030, 2040 and 2050, and specify how they contribute to achieving the EU's energy efficiency targets in accordance with Directive 2012/27/EU.

- Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 amending Directive 2012/27/EU on energy efficiency sets EU 2030 headline targets on energy efficiency of at least 32.5 %. An upwards revision clause by 2023 is also provided. Bulgaria will set indicative national energy efficiency contributions towards the Union’s 2030 targets in its integrated national energy and climate plan in accordance with Articles 4 and 6 of Regulation (EU) 2019/1999. When setting these contributions, Bulgaria will take into account that the Union’s 2030 energy consumption has to be no more than 1 273 Mtoe of primary energy and/or no more than 956 Mtoe of final energy. Bulgaria will notify those contributions to the Commission as part of their integrated national energy and climate plans as referred to in, and in accordance with, Articles 3 and 7 to 12 of Regulation (EU) 2018/1999. Bulgaria will achieve cumulative end-use energy savings at least equivalent to new savings each year from 1 January 2021 to 31 December 2030 of 0.8 % of annual final energy consumption, averaged over the most recent three-year period prior to 1 January 2019.

- a binding energy efficiency target for the EU for 2030 of 32.5 % was agreed between stakeholders with an upwards revision clause by 2023.

Specific National Goals and Priorities are set in National Energy Efficiency Action Plan (2014-2020) - Compliance with individual targets for energy savings by traders of energy; - Improved system of energy audits of enterprises and industrial systems; - Improved energy efficiency of buildings; - Improved energy efficiency of transport.

Specific National Goals and Priorities are set in the National plan for nearly zero energy buildings (2015-2020). It is expected that the implementation of this National Plan will contribute to final energy savings of 23.1 ktoe (267.7 GWh) to 46.2 ktoe (535.4 GWh) of primary energy, representing 10.04 % of the national 2020 energy savings target, without the energy traders.3

RELEVANT POLICY PRIORITIES IN OTHER RELEVANT SECTORS

Relevant transport, industry and agriculture policy priorities are set out below as required in Section 2.3.1 of the Commission Implementing Decision (EU) 2018/1522 of 11 October 2018. Waste management policy priorities are summarised in Chapter I.3 of Annex I.

TRANSPORT

General goal 1 (2020): Meeting targets under EU law (2020 climate and energy package):

- The transport sectors shall contribute to the EU target for GHG emission reductions pursuant to Directive 98/70/EC relating to the quality of petrol and diesel fuels. 4 The Directive introduces a binding target for reducing the life-cycle, greenhouse gas emissions per unit of energy from fuel and energy of 6 % by 31 December 2020, supported by two indicative additional targets (article 7a). Member States may provide that the maximum contribution of biofuels produced from cereal and other starch-rich crops, sugars and oil crops and from crops grown as main crops primarily for energy purposes on agricultural land for the purpose of compliance with the 6 % target shall not exceed 7 % of the final consumption of

3 Savings will be achieved without taking into account the obligations and measures implemented by energy traders, who have separate individual obligations for energy efficiency.4Directive 98/70/EC of the European Parliament and of the Council of 13 October 1998 relating to the quality of petrol and diesel fuels and amending. Council Directive 93/12/EEC.

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energy in transport in the Member States in 2020. Additionally, Directive 98/70/EC sets sustainability criteria for biofuels.

General goal 2 (2030): Meeting targets under EU law (Clean Mobility Package): As per political agreements reached till 2018, the long-term policy objectives for the development of the transport sector on EU level are the following: - By 2030, the goal for transport is to reduce GHG emissions to about 20 % below their 2008 levels; - By 2050, the goal for transport is to reduce GHG emissions to about 60 % below their 1990 levels; - Low-carbon sustainable fuels in aviation should reach 40 % by 2050; - EU carbon dioxide emissions from maritime transport should be cut by 40 % (if feasible 50 %) by 2050

compared to 2005 levels; - The use of ‘conventionally-fuelled’ cars in urban transport shall be halved by 2030; these cars shall be

phased out in cities by 2050; essentially carbon dioxide-free city logistics in major urban centres shall be achieved by 2030;

- Average carbon dioxide emissions of new passenger cars registered in the EU will have to be 15 % lower in 2025 and 35 % lower in 2030, compared to the emission limits valid in 2021;

- compared to the emission limits valid in 2021;- Average carbon dioxide emissions of new vans registered in the EU will have to be 15 % lower in 2025

and 30 % lower in 2030, compared to the emission limits valid in 2021; - Zero- and low-emission vehicles must reach a 35 % market share of sales of new cars and vans by 2030,

and 20 % by 2025.

Specific National Goals and Priorities are set in the Integrated Transport Strategy of the Republic of Bulgaria (2020-2030): - Effective maintenance modernization and development of transport system; - Improved management of transport system; - Development of intermodal transport; - Improvement of condition for the application of the principles of liberated transport market; - Decrease of fuel consumption and improvement in the energy efficiency of transport; - Renovation of the vehicle fleet (with focus on rail transport); - Improved connectivity of the Bulgarian transport system with European Transport System; - Provision of quality and accessible transport in all region of the country; - Limitation of the negative effects of transport on environment and human health; - Increase of security and safety of transport system.

INDUSTRY

The Development Strategy of Bulgaria covers the period until 2020 whilst Bulgaria’s Smart Specialization Strategy 2014-2020 was updated in July 20175. No relevant adopted strategy covers the period beyond 2020.

Both the Development Strategy and the Smart Specialization Strategy of Bulgaria focus on the development of technological infrastructure and optimizing resource efficiency in industry. The industrial development goals are related to attracting more hi-tech industries to operate in Bulgaria. Major priorities are:

- The Smart Specialization Strategy of Bulgaria 2014-2020 outlines key thematic sectors for future investment and development, including: mechatronics (technology combining electronics and mechanical engineering), clean technologies, biotechnology, nanotechnology and food industries.

5 Development Strategy of Bulgaria 2020 is available at http://www.strategy.bg/StrategicDocuments/View.aspx?Id=765Smart Specialization Strategy 2014-2020 is available at https://www.mi.government.bg/files/useruploads/files/ris3_final_11_july_2017_bg.pdf

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http://www.strategy.bg/StrategicDocuments/View.aspx?Id=765

https://www.mi.government.bg/files/useruploads/files/ris3_final_11_july_2017_bg.pdf


- The Development Strategy of Bulgaria 2020 has two strategic goals that relate to industrial policy: (i) establishing infrastructural networks to ensure optimal conditions for the development of the economy and of a healthy environment; and (ii) improving the competitiveness of the Bulgarian economy through guaranteeing a favourable business environment, encouraging investment, implementation of innovations, and improving resource efficiency.

AGRICULTURE AND FORESTRY

Strategic goal 1: protect the quality of groundwater and surface water by preventing their pollution by nitrates from agricultural sources and by promoting the use of good farming practices through proper implementation of Directive 91/676/EEC.

Specific National Goals and Priorities are set in a Programme for the limitation and prevention of pollution caused by nitrates from agricultural sources (2016-2019) adopted jointly by MoEW and MAFF.

Strategic Goal 2: observe EU legislation and participate and contribute to the fulfilment of EU policy commitments and initiatives such as Common Agricultural Policy. EU policy in relation to emissions from the agriculture sector is based on the UNECE Framework Code for Good Agricultural Practice for reducing emissions of ammonia. Its purpose is to provide the Convention’s Parties with easily understandable information on the good practices that are necessary to reduce ammonia emissions from agricultural sources. It is designed to support Parties in establishing or updating their national advisory codes of good agricultural practice to control ammonia emissions. The document is for guidance only, and it is not a prescriptive set of measures for full adoption. The document addresses:

- Nitrogen Management, taking into account the whole Nitrogen Cycle; - Livestock feeding strategies; - Low-emission feeding strategies; - Low-emission manure storage systems; - Low-emission manure spreading techniques; - Limiting ammonia emissions from the use of mineral fertilizers.

Observance of certain environmental practices is related to direct payment for farmers under the Common Agricultural Policy (CAP) which is linked with the so-called ‘greening concept’.

Specific National Goals and Priorities in agriculture are set in:

1. National Programme for Development – Bulgaria 2020 (2012-2020): - Balanced sectoral and structural development of the agrarian sector; - Modernization and technological renewal of farms and infrastructure in the sector. Development and

accelerated introduction of innovations in agricultural practice; - Improving the professional qualification and awareness of farmers; - Conversion of agricultural production into an attractive business that provides stable and fair incomes

to the persons working within it; - Sustainable use and management of natural resources; - Creating a competitive fisheries sector that provides sustainable management of fisheries and

aquacultures; - Achieving a high level of protection of human health and consumers' interests regarding food through

the implementation of an integrated control approach throughout the entire food chain.

2. Strategy for the Digitalisation of Agriculture and Rural Areas in the Republic of Bulgaria, adopted with Council of Ministers Decision No 247 from 2019 which plays an important role for:

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- the Smart Specialisation Strategy of Bulgaria; - reducing the harmful impact of agriculture and food industry on the environment.

Specific National Goals and Priorities in forestry are set in the National Strategy for Development of Forestry Sector in the Republic of Bulgaria (2013-2020):

- Maintaining viable, productive and multifunctional forest ecosystems that mitigate the effects of climate change;

- Conservation, restoration and maintenance of the biological and landscape diversity in forest areas; - Increasing the vitality and competitiveness of the forestry sector; - Utilizing the potential of the forestry sector to develop a green economy – focus on sustainable

production and consumption of biomass as, for instance, a renewable energy resource.

2.3.2. RESPONSIBILITIES ATTRIBUTED TO NATIONAL, REGIONAL AND LOCAL AUTHORITIES

Table 3 identifies the national, regional and local authorities having responsibilities for air quality and air pollution control in Bulgaria, and states the roles attributed to each authority. It also identifies those sectors for which the authority has some control authority. Section I.3 of Annex I scopes the responsibilities within each role.

Table 3. Authorities and attributed responsibilities in the areas of air quality and air pollution

Authority Attributed Responsibilities for Air Quality and Air Pollution

Sectorial Sources of Pollution for

which the relevant authority is responsible

National National Assembly Policy making role:Adoption of primary legislation (statutes)

All

Council of Ministers Policy making role:Adoption of secondary legislation

All

Ministry of Environment and Water (MoEW)

Policy making roleImplementation and enforcement roleMonitoring role

All

Ministry of Economy (MoE) Policy making roleImplementation role

Energy EfficiencyRenewable Energy

Ministry of Regional Development and Public Works (MRDPW)

Policy making roleImplementation role

Energy Efficiency Transport

Ministry of Energy (MEN) Policy making roleImplementation role

EnergyEnergy EfficiencyRenewable Energy

Ministry of Labour and Social Policy (MLSP)


Implementing the Winter Fuel Support Programme (targeted assistance for

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Authority Attributed Responsibilities for Air Quality and Air Pollution

Sectorial Sources of Pollution for

which the relevant authority is responsible

residential heating in winter)

Ministry of Transport, Information Technology and Communications (MoTITC)


Transport

Ministry of Health (MoH) Policy making role Cross-sectorMinistry of Agriculture, Food and Forestry (MAFF)

Policy making roleImplementation roleenforcement role

AgricultureForestry

Ministry of Interior (MoI) Policy making roleImplementation and enforcement role

Burning stubble

State Agency for Technical & Metrological Surveillance (SAMTS)

Implementation and enforcement roleReporting and monitoring role

All

Executive Environment Agency (ExEA)

Implementation roleReporting and monitoring role

All

National Statistical Institute (NSI)

Reporting role Cross-sector

Executive Forest Agency (ExFA) Implementation roleEnforcement role

Forestry

Executive Agency ‘Automobile Administration’ (ExAAA)

Implementation role Transport

Sustainable Energy Development Agency

Implementation roleMonitoring and reporting role

Energy EfficiencyRenewable Energy

National Institute of Meteorology and Hydrology (NIMH)

Reporting and monitoring role Cross-sector

Regional

Regional Inspectorates for Environment and Water (RIEWs), 16 in number

Implementation roleEnforcement role Reporting and monitoring role

All

Regional Health Inspectorates (RHIs) under the MoH, 28 in number

Methodological role Cross-sector

Local

Municipalities (Municipal council)

Policy making roleImplementation and enforcement roleReporting and monitoring role

All

Mayors of the Municipalities Implementation role AllLocal traffic police units under the MoI

Implementation and enforcement role Transport

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2.4. PROGRESS MADE BY CURRENT PAMS IN REDUCING EMISSIONS AND IMPROVING THE AMBIENT AIR QUALITY, AND DEGREE OF COMPLIANCE WITH NATIONAL AND UNION EMISSIONS REDUCTION OBLIGATIONS, COMPARED TO 2005.

2.4.1. PROGRESS MADE BY CURRENT PAMS IN REDUCING EMISSIONS AND DEGREE OF COMPLIANCE WITH THE NATIONAL AND UNION EMISSION REDUCTION OBLIGATIONS

OVERVIEW

Trends in reported historical emissions from 2005 to 2016, and of Bulgaria’s compliance with its national emission ceilings to 2019 are presented. Table 4 gives the emission ceilings agreed with the European Union (EU) on Bulgaria’s accession. Bulgaria’s total emissions have been under the ceilings throughout the period 2010-2016.

The emissions trend data reported here have been taken from Bulgaria’s 2018 submission to Directive (EU) 2016/2284. The trends are primarily driven by the implementation of transposed EU-level legislation, and the resultant policies and measures. In most cases this has resulted in emissions that fall with time. However, economic growth has offset the benefits of existing policies and measures in some instances, resulting in emissions from some sector-pollutant combinations increasing with time.

Table 4. Bulgaria’s National Emission Ceiling Values (after Directive 2001/81/EC)

PollutantTotal (ktonnes/y) Large Combustion Plants (ktonnes/y)

2010 to 2019 2008 to 2011 2012 to 20196

Sulphur Dioxide 836 179.7 103.0

Nitrogen Oxides 247 42.9 33.3

NMVOC 175 - -

Ammonia 108 - -

The historical National emissions inventory is of a good standard with respect to completeness. However, there are key sources whose emissions have been estimated using a Tier 1 methodology. As a result, estimated historical emissions have not captured the impact of implemented policies and measures in certain pollutant-source combinations – significant instances are identified below. Consequently, reported emissions may have been over-estimated. Discussions with other Ministries and governmental organizations involved in compiling the National inventory of emissions have been and are being held to resolve this issue. Calculation methodologies for the historical inventory can be found in Bulgaria’s most recent Informative Inventory Report.

Emissions data presented here are as reported in Bulgaria’s most recent submission to the European Commission under Directive 2016/2284. Table 5 summarizes Bulgaria’s compliance with the national emission ceilings totals in 2010 and 2016, whilst Section 2.4.1. presents emission trends in total and by sector and identifies the major sectoral sources for pollutant emissions in 2016. Annex II provides further details.

6 Bulgaria submitted a plan to the EC in 2010 for the gradual alignment of the remaining non-compliant Large Combustions Plants (LCPs) with defined stages on the application of the acquis. These plans ensured a further reduction in the emissions to a level significantly below the intermediate targets specified in column 4 (LCPs, 2012 to 2019).

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Table 5. Compliance with Bulgaria’s National Emission Ceiling totals (after Directive 2001/81/EC)

PollutantNational Emission Ceiling

(ktonnes/y)Reported National Emissions

(ktonnes/y)

2010 to 2019 2010 2016

Sulphur Dioxide 836 388 105

Nitrogen Oxides * 247 138 125

NMVOC * 175 76 84

Ammonia 108 47 50

* Emissions from 3B, 3D in the agriculture sector are included in the data shown here.

N ITROGEN OXIDES – H ISTORICAL EMISSIONS AND COMPLIANCE WITH D IRECTIVE 2001/81/EC Reported nitrogen oxides emissions have reduced steadily since 2005, primarily driven by the transposition of EU-wide legislation affecting the large-scale combustion plants (LCP) and the road transport sector. Figure 1 shows the trend overall and the changing sectoral composition over this period. Throughout the period, reported national total nitrogen oxides emissions have been below the emissions ceiling of 247 ktonnes (even when the agricultural contribution is included). However, despite declining, aggregate LCP nitrogen oxides emissions have not complied with the ceiling values given in Table 4.

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Figure 1. Historical Emissions of Nitrogen Oxides

0

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NOx Emissions (ktonnes)


Total* 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016ktonne

s 183 179 163 164 148 138 158 141 126 132 132 125

* Emissions from 3B, 3D in the agriculture sector are included in the figures presented.

NMVOC – H ISTORICAL EMISSIONS AND COMPLIANCE WITH D IRECTIVE 2001/81/EC As observed in other EU Member States, NMVOC emissions arise from a wide range of different types of source. The reported national total emissions have been reducing steadily, although there have been slight increases in recent years – see Figure 2. Many of the larger sources have seen a steady decrease but the reductions have been relatively small and offset to an extent by increased emissions from smaller sources across the last few years.

Nevertheless, throughout this period, reported national total NMVOC emissions have been below the emissions ceiling of 175 ktonnes (even when the agricultural contribution is included). Moreover, as noted in Annex II, we consider that reported emissions to date have been overestimated (and emission reductions underestimated) as a result of Type 1 methodologies being used to calculate emissions.

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Figure 2. Historical Emissions of NMVOC

0

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NMVOC Emissions (ktonnes)


Total 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016ktonne

s 96 97 90 90 89 90 91 89 83 82 83 84

* Emissions from agriculture are included in the figures presented.

SULPHUR OXIDE – H ISTORICAL EMISSIONS AND COMPLIANCE WITH D IRECTIVE 2001/81/EC Reported sulphur oxide emissions (as sulphur dioxide) have shown a dramatic decrease since 2005 – see Figure 3. The decrease has been driven primarily by the requirement to reduce emissions from LCPs in the public electricity and heat generating sector, and in industry. Fuel switching in industry has also played a role. The calculated in the inventory historical sulphur dioxide emissions from combustion in these sectors are thought to be realistic in general.

Throughout the period since 2008, reported national total sulphur dioxide emissions have been below the emissions ceiling of 836 ktonnes. Since 2015, aggregate LCP sulphur dioxide emissions have complied with the ceiling values given in Table 5.

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Figure 3. Historical Emissions of Sulphur Oxide

0

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SOx Emissions (ktonnes)


Total 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016ktonnes 778 765 820 571 443 388 516 330 195 189 142 105

AMMONIA – H ISTORICAL EMISSIONS AND COMPLIANCE WITH D IRECTIVE 2001/81/EC

Emissions of ammonia have been and are dominated by emissions from the agriculture sector, particularly emissions from manure management and the application of inorganic fertilizer to crops. Reported emissions reduced between 2005 and 2011, but then increased to 2016 – see Figure 4. Throughout the period, reported national total ammonia emissions have been below the emissions ceiling of 108 ktonnes.

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Figure 4. Historical Emissions of Ammonia

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NH3 Emissions (ktonnes)


Total 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016ktonnes 52 51 52 49 46 47 45 45 46 49 50 50

F INE PARTICULATE MATTER 2 . 5 – H ISTORICAL EMISSIONS

Since 2005, reported PM2.5 emissions have tended to increase slightly – see Figure 5. The trend has been driven by emissions from residential heating. The dominance of fine particulate matter emissions in Bulgaria results from the extensive use of firewood for residential heating.

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Figure 5. Historical Emissions of Particulate Matter

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PM2.5 Emissions (ktonnes)


Total 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016ktonnes 31 32 31 31 29 31 34 34 32 31 32 32

MAJOR SECTORAL SOURCES OF POLLUTANT EMISSIONS IN 2016

Figure 6 identifies the sectors principally responsible for emissions in 2016. The emissions contributions shown are consistent with those in the start year (2016) of the With Existing Measures (WM) scenario – see Chapter 2.5. Sectors principally responsible for respective emissions in 2016 were:

- Public electricity and heat generation (sulphur dioxide and nitrogen oxides)

- Residential heating and other combustion (particulate matter and NMVOC)

- Road transport (nitrogen oxides, NMVOC and particulate matter)

- Agriculture (ammonia)

- Solvent use (NMVOC)

- Industrial processes and fugitive emissions (nitrogen oxides, sulphur dioxide and NMVOC)

It is expected that emissions projections beyond 2016 up to 2030, whether in the WM scenario or in the With Additional Measures7 (WAM) scenario, will be driven mainly by changes in the above sectors. It is noteworthy that the waste sector is not a significant emission source for any of the five pollutants addressed in this National Air Pollution Control Programme.

7 Particular attention is paid to these sectors in developing with WM and WAM scenarios, as detailed in Annexes IV, VI and VIII. However, we consider that solvent use, industrial process and fugitive emissions are over reported in the National Inventory of Emissions – see Annex IV. T Hence their relative significance in 2016 is apparent rather than real.

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Figure 6 Principal emission sources in 2016 (percentage of total reported emissions) according to the National Inventory of Emissions

Nitrogen Oxides

0 5 10 15 20 25 30 35 40 45 50

Road transport

Public electricity and heat generation

Other transport

Residential and other combustion

Industrial combustion

Other sourcesNOx

NMVOC

0 10 20 30 40


Industrial processes and fugitive emissions

Solvent use

Road transport

Other sources

NMVOC

Sulphur Oxide

0 20 40 60 80

Public electricity and heat generation


Industrial combustion


Other sources

SOx

Ammonia

0 20 40 60

Agriculture - livestock

Agriculture - soils



Other sources

NH3

PM2.5

0 20 40 60 80 100


Road transport

Other sources

PM2.5

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2.4.2. PROGRESS MADE BY CURRENT PАMS IN IMPROVING A IR QUALITY, AND THE DEGREE OF COMPLIANCE WITH NATIONAL AND UNION A IR QUALITY OBLIGATIONS

Bulgaria is divided into six Air Quality Assessment and Management Zones – see Figure 7.

Figure 7. Air Quality Assessment and Management Zones in Bulgaria

Source: ExEA, State of the Environment report

The National Air Quality Monitoring network has evolved between 2005 and 2016 with respect to both the number of air quality monitoring stations (AQMs) and the breadth of the pollutants monitored: not all pollutants are monitored in each AQM. For instance:

- Bulgaria had 53 AQMs in 2005 but 48 in 2016;- PM2.5 was monitored at 4 AQMs in 2005, but monitored at 10 AQMs in 2016;- PAH was monitored in 15 stations in 2016.

The number of air quality monitoring stations, including 34 automatic measuring stations (AMS), 9 manual sampling stations (MSS) with subsequent laboratory analysis, 5 DOAS (on the differential optical absorption spectroscopy principles and applications) in each zone in 2016 were:

1. Capital Agglomeration (BG0001) – 7 stations,2. Plovdiv Agglomeration (BG0002) – 3 stations,3. Varna Agglomeration (BG0003) – 3 stations,4. North-Danube (BG0004) – 14 stations,5. South West (BG0005) – 8 stations, and6. South East (BG0006) – 13 stations.

At the level of AQ zone, Tables 6 and 7 summarize the extent of non-compliance with the current EU air quality standards for the main pollutants in the period 2005-2016. Non-compliance was determined as when any concentration in a given MS and period did not meet current air quality standards. Not all pollutants are monitored at every monitoring station. Thus, in the absence of modelling for pollutants, non-compliance with a given air quality standard has been assessed only for the pollutants monitored at the monitoring stations. The whole AQ zone is deemed non-compliant if non-compliance is observed at any one monitoring station.

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Annex III presents the trends in non-compliance with air quality standards at the level of both AQ zone and monitoring station. Table 6 gives the number of monitoring stations in each AQ zone that monitored specific pollutants in 2016.

Table 6. Pollutant monitoring coverage in Bulgaria’s AQ zones in 2016

AQ Zone No. of MSs

Number of MSs monitoring the specific pollutant in 2016

SO2 NO2 PM10 PM2.5 PAH CO O3

BG0001 7 6 6 7 2 3 4 5

BG0002 3 2 2 3 1 1 2 1

BG0003 3 3 3 3 1 1 3 2

BG0004 14 11 10 14 2 2 4 8

BG0005 8 6 5 8 3 4 1 3

BG0006 13 12 11 12 1 4 4 7

Total 48 40 37 47 10 15 18 26

Table 7 shows that particulate material (PM10 especially but PM2.5 also), and pollutants such as PAH associated with PM, has posed a significant and general problem for compliance throughout the period under review. The principal source of PM10 non-compliance has been the burning of solid fuels, wood especially, in conventional stoves and boilers used for residential heating: most exceedances of the daily PM 10 limit value occurred in the winter months, i.e. in the residential heating period.

Conversely, the period saw an increasing trend for compliance with the limit values for sulphur dioxide and carbon monoxide. One AQ zone was non-compliant with the sulphur dioxide 1-hour standard and two with the 24-hour standard, in 2016, whereas five were exceeding the limit values in 2005. Since 2012, all AQ zones have been compliant with the carbon monoxide standard.

The improvement in sulphur dioxide compliance results from the introduction of flu-gas desulphurization installations at large combustion plants in the electricity and heat generation, and industrial sectors, including reductions in the sulphur content of fuels, and a general reduction in the concentration of sulphur dioxide at the regional level. However, up to 2016 the Galabovo AQM station located in the vicinity of the lignite-fired power plants in the Maritsa East complex continued to register non-compliance with the sulphur dioxide limit values, despite the introduction of desulphurization installations.

The trends concerning compliance for nitrogen dioxide are mixed. All AQ zones since 2013 have been compliant with the 1-hour standard for nitrogen dioxide, but the annual average concentration has been exceeded in one and in three AQ zones in 2015 and 2016, respectively. The monitoring station in Pleven recorded non-compliance with the average annual limit value for nitrogen dioxide for 2015 and 2016. The Executive Environmental Agency consider this was because of increased road traffic near the station due to major street renovations in Pleven. Trakia monitoring station in Plovdiv recorded non-compliance with the annual average nitrogen dioxide limit value, but did not exceed the allowed exceedances of the hourly limit value. This was due to high monthly average nitrogen dioxide concentrations in the winter months, especially in January (74.0 µg/m3) and November (62.2 µg/m3). In general, nitrogen dioxide average monthly concentrations at Trakia AQM in Plovdiv in 2016 were above 40 µg/m3 in all months of the year except June and July.

Table 8 refers to monitored ozone concentrations. There has been little overall change in non-compliance status since 2009.

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Table 7. Non-compliance of AQ zones with EU ambient air quality standards for sulphur dioxide, nitrogen dioxide, fine particulate matter, PAH and carbon monoxide: 2005-20168

Pollutant StandardNumber of non-compliant Air Quality Zones

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016Sulphur Dioxide

1-hour: 350 µg/m3, 24 allowed exceedances 5 3 2 1 2 2 2 1 1 1 1 124-hour: 125 µg/m3, 3 allowed exceedances 5 4 2 2 2 2 2 1 1 1 1 2

Nitrogen Dioxide

1-hour: 200 µg/m3, 18 allowed exceedances (2010 standard) 3 3 1 1 3 2 2 3 0 0 0 0

1-year: 40 µg/m3, annual average (2010 standard) 1 2 1 1 2 2 2 2 1 0 3 3

PM1024-hour: 50 µg/m3, 35 allowed exceedances 6 6 6 6 6 6 6 6 6 6 6 61-year: 40 µg/m3, annual average 6 6 6 6 6 6 6 6 6 6 6 5

PM2.5 1 -year: 25 µg/m3, annual average (2015 standard) 2 3 3 3 5 4 4 4 4 4 3 2

PAH 1 -year: 1-year: 1 ng/m3, annual average (2012 standard) 0 5 5 4 4 4 5 5 5 4 5 5

Carbon Monoxide

Maximum 8-hour daily mean: 10 mg/m3 2 2 0 1 1 1 2 0 0 0 0 0

8 Source of data for Tables 7 and 8: http://eea.government.bg/bg/soer/soer-arhiv

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http://eea.government.bg/bg/soer/soer-arhiv


Table 8. Non-compliance of AQ zones with EU standards for ozone: 2008-2010 to 2014-2016

Pollutant StandardNumber of non-compliant Air Quality Zones

2008-2010 2009-2011 2010-2012 2011-2013 2012-2014 2013-2015 2014-2016

Ozone Maximum 8-hour daily mean: 120 µg/m3, 25 allowed exceedances averaged over 3 years 1 2 4 4 2 2 3

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2.4.3. CURRENT TRANSBOUNDARY IMPACT OF NATIONAL EMISSION SOURCES

Bulgaria’s emissions mostly impact within the country, especially in urban areas. However, there are transboundary impacts. Bulgaria’s emissions contribute to the deposition in neighbouring countries of acidifying and eutrophying pollutants, chiefly sulphur, oxidised and reduced nitrogen. They also contribute to ozone formation, through nitrogen oxides and NMVOC emissions, and to secondary organic aerosols, PM2.5 and PM10 resulting from the formation of secondary PM components such as ammonium sulphate and nitrate.

Transboundary impacts have been quantified by the modelling work of EMEP, conducted by the Meteorological Synthesising Centre-West in the framework of the UNECE Convention on Long Transboundary Air Pollution (CLRTAP). The results are reported annually by EMEP and the findings of the most recent are stated here.9

Deposition of Oxidised Sulphur and Nitrogen and Reduced Nitrogen

Figure 8 illustrates the geographical distributions of the deposited pollutants (mg/m2) emanating from Bulgaria, whilst Table 9 indicates the emission percentage deposited in the neighbourhood, and in Bulgaria itself.

Figure 8. Mapping Bulgaria’s modelled contribution of deposited pollutants

Oxidised Sulphur(mg S/m2)

9H.Fagerli et al, Transboundary particulate matter, photo-oxidants, acidifying and eutrophying components, EMEP Status report 1/18, 2018, Norwegian Meteorological Institute, August 2018; and, in Country Reports, M.Gauss et al, Transboundary air pollution by main pollutants (sulphur, nitrogen, ozone) and fine particulate matter in 2014, Bulgaria, Norwegian Meteorological Institute, August 2016.

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Oxidised Nitrogen(mg N/m2)

Reduced Nitrogen(mg N/m2)

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Table 9. Modelled fate of Bulgaria’s emissions affecting pollutant deposition in neighbouring countries

Country / AreaEmissions from Bulgaria by Deposited Pollutant

Oxidised Sulphur Oxidised Nitrogen Reduced Nitrogen

Romania 10 % 12 % 7 %

Greece 5 % 6 % -

Mediterranean Sea 9 % 11 % 6 %

Black Sea 8 % 9 % 9 %

Russian Federation 7 % - 5 %

Ukraine - 6 % 5 %

Other 25 % 20 % 16

Bulgaria 37 % 30 % 52

Ozone and fine particulate matter Contributions

The contribution of Bulgaria’s emissions to ozone and fine particulate matter (PM 2.5) concentrations in other countries arise from chemical reactions that transform precursor pollutants such as sulphur dioxide and nitrogen oxides into the particulate matter components ammonium sulphate and nitrate; and nitrogen oxides and NMVOCs to ozone. The model estimates the effects of an emissions reduction of 15 % on the ozone and PM2.5 concentrations in neighbouring countries.

Health impacts of ozone are assessed using the metric ‘the sum of hourly ozone concentrations above 35ppb’ (SOMO35). Figure 9 maps the modelled contribution of Bulgaria’s emissions of nitrogen oxides and NMVOCs on SOMO35 in neighbouring countries. Nitrogen oxides emissions from Bulgaria have substantially greater impacts on SOMO35 in neighbouring countries than do NMVOC emissions.

Figure 9. Mapping Bulgaria’s modelled contribution to SOMO35 (ppb-day) for nitrogen oxides and NMVOC

Nitrogen Oxides

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NMVOC

Figure 10 maps the modelled effect of a 15 % reduction in the emission of precursors sulphur dioxide, nitrogen oxides and ammonia on the concentrations (µg/m3) of secondary inorganic aerosol and PM2.5 in neighbouring countries. The analysis confirms that the current transboundary impacts of Bulgaria’s precursor emissions on the concentrations of SIA and PM2.5 are minor.

Figure 10. Mapped reductions in the modelled concentrations of PM2.5 and secondary inorganic aerosol from a 15 % reduction in Bulgaria of precursor emissions (sulphur dioxide, nitrogen oxides, ammonia)

Fine Particulate Matter (PM2.5)(µg/m3)

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SIA(µg/m3)

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2.5. PROJECTED FURTHER EVOLUTION ASSUMING NO CHANGE TO ALREADY ADOPTED POLICIES AND MEASURES

2.5.1. PROJECTED EMISSIONS AND EMISSION REDUCTIONS (WM SCENARIO)

Emission projections under the With Existing Measures (WM) scenario have been calculated by following best practice, as presented in the 2016 version of the EMEP/EEA Emissions Inventory Guidebook. Emissions estimates from the latest year in the historical emissions inventory (2016) have been used as a “base year” for estimating emission projections. Table 10 shows the source-sector resolution for which the emission projections have been estimated.

Table 10. Sector resolution for Projections Calculations

NFR Sector Title NFR Sector Title

1A1a Electricity/heat generation (solid fuel)

2A,B,C,H,I,J,K,L Industrial Processes

1A1a Electricity/heat generation (liquid fuel)

2D, 2G Solvent and other product use

1A1a Electricity/heat generation (gas) 3B1a Cattle Dairy1A1a Electricity/heat gen. (biomass) 3B1b Cattle Non-Dairy1A1b Refineries 3B2 Sheep1A2 Manufacturing Industries &

Construction – Fuel combustion3B3 Swine

1A3bi Road transport, Passenger cars 3B4a Buffalo1A3bii R.T., Light duty vehicles 3B4d Goats1A3biii R.T., Heavy duty vehicles 3B4e Horses1A3biv R.T., Mopeds & Motorcycles 3B4f Mules and asses1A3bv R.T., Gasoline evaporation 3B4g Poultry1A3bvi R.T., Automobile tyre & brake wear 3B4h Other Livestock1A3bvii R.T., Automobile road abrasion 3Da1, 3Df Inorganic N-fertilizers1A3a,c,d,e Off-Road & Non-Road transport 3Da2,3,4, 3Db Organic Fertilisation of Soil1A4a Commercial & institutional 3Dc,d Cultivated Crops1A4b Residential stat. & mob. (solid fuel) 3De Farm-level agricultural operations1A4b Residential stat. & mob. (liquid fuel) 3F,I Field stubble burning & other

agriculture1A4b Residential stat. & mob. (gas ) 5 Waste1A4b Residential stat. & mob. (biomass) 6A Other1A4c Agriculture, forestry, and fishing1A5 Other Combustion1B Fugitive emissions

For each of these source sectors, consideration has been given to how the activity may change in the future, and how the pollutant specific emission factors may change in the future. Numerous year-specific activity data “drivers” and emission factor “drivers” were then calculated, either from the best available projected data or by using expert judgement. Individual drivers were then applied to each of the source sectors. In this way, a representation of the WM scenario was built up. Annex IV provides an overview of the approaches and data adopted, including a consideration of associated uncertainties.

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As stated in Annex IV, the fuel consumption values adopted in the WM scenario are those of the most recent greenhouse gas emissions projections. The greenhouse gas projections incorporate Bulgaria’s energy efficiency commitments, which may be especially significant for the residential heating sector. For example, an energy retrofit programme for multi-family buildings is in place to assist households in Bulgaria to invest in energy efficiency, though at the time of writing it is uncertain whether the above-mentioned multi-family building programme will be available in future. Nevertheless, the WM scenario emissions projections presented here assume implicitly the achievement of Bulgaria’s energy efficiency commitments under its climate change and energy policies.

Investments in energy efficiency in buildings have several benefits. Enhancing the energy performance of a building, for example by reducing energy demand through thermal insulation and preventing heat losses from ill-fitting windows, will reduce heating costs and produce a more comfortable indoor environment. By improving the affordability of thermal comfort, the health of vulnerable members of the population, especially the old, the very young, the sick and the socially disadvantaged, can be improved during the winter months. It can also reduce the requirement for installed heating capacity and prevent installation of over-sized and unnecessarily costly heating appliances. This is particularly relevant to the residential sector, where there is an aging building stock and where maintenance may not be up to the professional level required to ensure that draft-proofing and thermal insulation is installed as part of general updating. Other benefits result from the use of efficient lighting and domestic equipment, with lower electricity costs and lower loads on circuits and wiring. We are aware that it is general experience in the EU for investments in energy efficiency – particularly in roof insulation, draft proofing and efficient, well-fitted windows – to be highly cost-effective.

SUMMARY OF EMISSIONS AND EMISSIONS REDUCTION (WM SCENARIO)

Table 11 summarizes the projected emissions under the WM scenario, and compares these with the emission reduction commitments (ERCs). Emission reduction values in cells shaded ‘green’ meet the ERCs whilst those in cells shaded ‘orange’ do not. We expect that sulphur dioxide would comply with the ERC throughout the period, whilst nitrogen oxides, NMVOC, ammonia and particulate matter would exceed the ERCs scenario, especially for 2030 and beyond. Additional Policies and Measures will be needed to comply with the ERCs for the latter four pollutants. Figures 11 through to 15 present the projected total emissions and sectoral breakdowns for each pollutant to 2030.

Table 11. Projected emissions, emission reductions, and commitments compliance (WM Scenario)10

PollutantEmissions (ktonnes) consistent with

inventory for 2016% Emission reduction compared with 2005


2005 2020 2025 2030 2020 2025 2030 2020-2029 2030+Nitrogen Oxides 183.2

97.3 90.3 85.4 47 % 51 % 53 % 41 % 58 %

NMVOC 80.7 67.8 62.5 55.9 16 % 23 % 31 % 21 % 42 %Sulphur Dioxide 771.3

81.4 82.2 85.6 89 % 89 % 89 % 78 % 88 %

Ammonia 51.6 46.3 47.0 47.0 10 % 10 % 9 % 3 % 12 %PM2.5 30.9 28.9 24.5 18.5 6 % 21 % 40 % 20 % 41 %Date of Emission Projections 27 January 2019

10 Nitrogen oxides and NMVOC emissions from agricultural sources are omitted from the totals in this Table and Figures 10 to 14. Emissions of sulphur dioxide in the base year, 2005, differ from the latest value in the National Inventory of Emissions, for the reasons explained in Annex IV.

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Figure 11. Nitrogen Oxides (NOx) Emission Projections (ktonnes) under the WM Scenario

0

20

40

60

80

100

120

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

NOx

Electricity Generation Industrial Combustion Residential & Other Combn

Road Transport Other Transport Ind. Processes & Fugitives

Solvent Use Waste Other

Ceilings

Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 97.3 91.4 91.0 91.0 90.4 90.3 89.3 88.2 87.1 86.2 85.4

Figure 12. NMVOC Emission Projections (ktonnes) under the WM Scenario

0

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60

70

80

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

NMVOC

Electricity Generation Industrial Combustion Residential & Other CombnRoad Transport Other Transport Ind. Processes & FugitivesSolvent Use Waste OtherCeilings

Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 67.8 66.8 65.8 64.7 63.6 62.5 61.4 60.4 59.3 58.2 55.9

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Figure 13. Sulphur Oxide (SO2) Emission Projections (ktonnes) under the WM Scenario

0

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180

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

SO2

Electricity Generation Industrial Combustion Residential & Other CombnRoad Transport Other Transport Ind. Processes & FugitivesSolvent Use Agriculture - Livestock Agriculture - SoilsWaste Other Ceilings

Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 81.4 79.5 80.2 80.8 81.5 82.2 82.8 83.5 84.1 84.8 85.6

Figure 14. Ammonia Emission Projections (ktonnes) under the WM Scenario

0

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60

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

NH3


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Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 46.3 45.9 45.9 46.2 46.6 47.0 46.4 46.4 46.6 46.8 47.0

Figure 15. Fine Particulate Matter (PM2.5) Emission Projections (ktonnes) under the WM Scenario

0

5

10

15

20

25

30

35

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

PM2.5


Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 28.9 28.0 27.2 26.3 25.4 24.5 23.6 22.8 21.9 21.0 18.5

2.5.2. PROJECTED IMPACT ON IMPROVING A IR QUALITY (WM SCENARIO) AND THE PROJECTED DEGREE OF COMPLIANCE

2.5.2.1. QUALITATIVE DESCRIPTION OF THE PROJECTED IMPROVEMENT OF A IR QUALITY

The principal pollutant of concern for air quality in Bulgaria is particulate matter, most primary emissions arising from residential heating (solid fuels). Road transport is of less significance, though an issue in the highly urbanized areas of Sofia and Plovdiv. As described in Section 2.4.2 and Annex II.1, all six of Bulgaria’s Air Quality Zones were non-compliant with PM10 air quality criteria in 2016.

Bulgaria has limited capacity for undertaking large-scale pollutant dispersion and transport modelling. Hence, assessing the impacts of projected particulate emissions reduction on air quality has been made using a proxy approach. This relies on an empirical association between the annual average monitored fine particulate matter (PM10) concentration and the annual number of exceedances of the daily Limit Value for fine particulate matter of 50µg/m3. Figure 16 shows that, in Bulgaria, an annual average PM 10 concentration of 30 µg/m3 is a good surrogate for compliance with the maximum annual number of exceedances (35) of the PM 10 daily Limit Value.11

11 The chart shown is drawn for all AQMs in 2016 but a plot of average values over several years shows a similar association.

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Figure 16. Plot of the annual mean PM10 in Bulgaria (2016) against the number of days exceeding 50µg/m3 (ExEA data)


Series2; 19.66

Series2; 45.17



Series2; 31.40

Series2; 47.16


Series2; 34.84

Series2; 25.71

Series2; 42.82

Series2; 52.67


Series2; 25.05

Series2; 42.74


Series2; 15.30

Series2; 31.75Series2; 29.99Series2; 32.05

Series2; 61.26

Series2; 37.67

No. Days > 50 µg/m3

Annu

al M

ean

PM10

The proxy approach relies also on three simplifying assumptions:

- Monitored ambient air PM10 comprises (i) a component resulting from emission sources within a municipality, and (ii) a regional and transboundary component comprising transported and secondary particulate matter;

- The concentration in air of PM10 derived from emissions sources within a municipality is directly proportional to the quantity of primary fine particulate matter emitted within the municipality, and that all such emission sources of significance are known.

- The regional & transboundary component, in concentration terms (µg/m3), is uniform across non-compliant municipalities. Assessments have adopted a value derived from a source apportionment study of ambient air quality in Bulgaria.12

Based on these assumptions, the degree of PM10 emissions reduction (ER) needed to achieve full compliance with the fine particulate matter ambient air quality criteria is estimated using the formula:

% ER = 100 x (AA – TA) / (AA – RTC)

where:

ER is the emissions reduction needed to achieve compliance with both annual average PM10

concentration and the maximum annual number of exceedances of the daily LV for PM10.

AA is the monitored annual average PM10 in a municipality (µg/m3)

TA is the target annual concentration – determined empirically as 30 µg/m3 from monitoring data and the observed relationship between annual average and the annual number of daily exceedances. See Figure 15

RTC is the estimated regional & transboundary contribution (µg/m3) – taken as 16µg/m3.

Comparing the emissions reduction needed with those expected in a given scenario provides an indication of a likely evolution in ambient air quality regarding particulate matter. The proxy approach has been applied to ambient air quality monitoring data for 2016. The results indicate that the emissions reductions required for PM10 compliance ranges from about 9 % to 69 % in those municipalities where the annual average fine particulate matter concentration in 2016 exceeded 30 µg/m3 – see Table V.1 in Annex V.

12 A study by IIASA for the European Commission has shown that the average combined natural and transboundary contribution to annual PM2.5 in 14 Bulgarian traffic stations was ~6 µg/m3 and that the contribution of national emissions from outside the cities was a further ~10 µg/m3, making a total of ~16 µg/m3. Study available at: http://pure.iiasa.ac.at/id/eprint/11152/1/XO-14-073.pdf

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http://pure.iiasa.ac.at/id/eprint/11152/1/XO-14-073.pdf


Relative to year 2016, our emission projections for the WM scenario indicate that national PM 2.5 from the residential heating and transport combined (the principal sources of primary emissions) would be lower by ~10 %, ~26 % and ~47 % respectively in 2020, 2025 and 2030.13 In some localities the projected reduction in emissions might be sufficient to achieve compliance with PM10 ambient air quality standards by 2020, with greater extent of compliance in later years. Nevertheless, in the absence of additional measures, all Air Quality Zones are likely to remain non-compliant with PM10 even in 2030. Hence, additional policies and measures will be needed.

The projected reductions in nitrogen oxides, NMVOCs and ammonia emissions in the WM scenario will contribute to a modest improvement of ambient air quality in Bulgaria. Apart from the expected lower concentrations of these pollutants in air, we expect the reduced emissions will contribute also to lower rates of formation of secondary PM2.5 and PM10 and, therefore, to lower concentrations of PM2.5 and PM10 in the ambient air. These would be additional to the effects of reduced primary fine particulate matter emissions.

2.5.2.2. QUANTITATIVE DESCRIPTION OF THE PROJECTED IMPROVEMENT OF AMBIENT A IR QUALITY

A quantitative description of the projected improvement in ambient air quality cannot be provided in the format suggested in section 2.5.2.2 of the Commission Implementing Decision. There is insufficient information and air quality modelling capacity in Bulgaria to make such quantitative forecasts.

13 Our projections data assume the PM2.5 to PM10 ratio for particulate material emitted from residential heating and road transport is constant.

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2.6. POLICY OPTIONS CONSIDERED IN ORDER TO COMPLY WITH THE EMISSION REDUCTION COMMITMENTS FOR 2020, 2030, AND INTERMEDIATE EMISSIONS LEVELS FOR 2025.

2.6.1. DETAILS CONCERNING THE PROGRAMME AND MEASURES CONSIDERED IN ORDER TO COMPLY WITH THE EMISSION REDUCTION COMMITMENTS (REPORTING AT PAM LEVEL)

We have identified additional policies and measures (PaMs) through a staged process:

1. Stating the more significant of the existing PaMs applying within significant sectors identified in Chapters 2.3 and 2.5. This draws on the policy baseline in Chapter 2.3 and Annex I.

2. Identifying potential additional PaMs that are either new or could be developed as extensions of the existing PaMs. Annex I explains briefly the identification process.

Table VI.1 in Annex VI summarises the output of stages (1) and (2).

3. Qualitative screening of the potential additional PaMs against certain criteria: (i) whether it would impact one or more sectors whose contribution to the national emissions of a pollutant is significant, (ii) that the potential measure is feasible regarding legal requirements, technical considerations, and effects on society, (iii) that overall costs relative to likely benefits are expected to be favourable, and (iv) its acceptability within Government and amongst stakeholders.

Noting only potential PaMs that pass stage (3), Table 12 identifies the PaMs selected for consideration. They lie in the residential heating, road transport, and agricultural sectors.

The residential heating PaMs form a package, imported from the proposed National Air Quality Improvement Programme (NAQIP) adopted by the Council of Ministers. The National Air Quality Improvement Programme addresses a serious air quality issue, the long-standing non-compliance of certain municipalities with ambient air quality standards, and the resultant adverse health impacts. It directly impacts the emission of not only PM2.5 and PM10, but of black carbon also. Bulgaria’s national energy efficiency commitments are embedded in the WM scenario. Nevertheless, wherever possible, we will endeavour to operationalise these commitments in the residential heating sector through encouraging the adoption of energy efficiency measures during the implementation of the NAQIP.

Table 12. Additional PaMs considered

Sector Additional PaMs Considered

Residential heating Package (NAQIP)

- R1: Introduction of national requirements for coal quality, surrogate measures to reduce the moisture content of firewood used in municipalities that fail PM10 air quality criteria and, potentially, a maximum moisture content for firewood requirements (in those areas)

- R2 Bring forward the date at which Regulation (EU) 2015/1185 with regard to ecodesign requirements for solid fuel local space heaters comes into effect; and introduce a compulsory, accelerated phase-out of traditional, polluting solid-fuel heating appliances (stoves) in municipalities where ambient air quality has not complied with PM10 LVs; coupled with:

- R3: Households affected by the compulsory phase-out of traditional stoves to switch to heating by natural gas (reconnection and new connections), district heating (reconnections and new connections), or Eco-Design compliant heating appliances.

Road Transport - RT1 Modernisation of vehicle fleet through allowing “cleaner” imports only- RT2 Establishing low emission zones (LEZs) in Sofia and Plovdiv to limit the access

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of polluting vehicles.Agriculture - C1: Implement Good Agricultural Practice Rules to control ammonia emissions

released from agricultural sources, based on the United Nations Economic Commission for Europe’s Framework Code for Good Agricultural Practice for Reducing Ammonia Emissions. It will recommend good practices for applying nitrogen-containing fertilisers to soils. Its effect should also strengthen the implementation of the Nitrates Directive. The Rules will be disseminated through agricultural outreach. The impacts will be monitored by survey, the results feeding back into the


- A2 Implement Good Agricultural Practice Rules to control ammonia emissions released from agricultural sources, based on the United Nations Economic Commission for Europe’s Framework Code for Good Agricultural Practice for Reducing Ammonia Emissions. It will recommend good practices for managing cattle manure. As for PaM A1: The Rules will be disseminated through agricultural outreach. The impacts will be monitored by survey, the results feeding back into the


Industrial installations and combustion plants apply Best Available Techniques (BAT) and operate under complex permits issued under Directive 2010/75/EU. The development of stricter policies and measures for these sectors would be inappropriate at this time.

Tables 13 and 14 provide the further information on the PaMs selected for consideration, information that will be submitted to the EC using the PaMs tool.

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Table 13. Additional PaMs considered – information to be reported using the PaMs tool

PaM descriptionPollutants affected

PaM objective

s

PaM Type

Implementation period

Implementation Authorities Methodology used

Expected emission reductions (ktonnes/y) relative to WM scenario

Qualitative Uncertainty DescriptionStart Finish Type Name 2020 2025 2030

NAQIP residential heating packageR1 + R2 + R3

Nitrogen Oxides

See Table 14

See Table 14

2020 2030

See Table 14 See Table 14 See Table 140.6 1.2 1.9

Medium

NMVOC 5.6 9.2 8.9

Sulphur Dioxide 1.8 2.0 2.1

Ammonia 0.0 0.0 0.0

PM2.5 6.4 10.9 10.0

Modernise road vehicle fleet through import controlsRT1

Nitrogen Oxides

See Table 14

See Table 14

2020 2030


Medium

NMVOC 0.1 -0.2 -0.9


Ammonia 0.1 0.1 0.0

PM2.5 0.1 0.2 0.4

NAQIP Low Emission Zones in major conurbationsRT2

Nitrogen Oxides

See Table 14

See Table 14

2020 2030


Medium

NMVOC 0.1 0.2 1.6


Ammonia 0.0 0.0 0.0

PM2.5 0.2 0.2 0.3

Fertilizer use: good practiceA1

Ammonia See Table 14

See Table 14

2020 2030 See Table 14 See Table 14 See Table 14 0.4 0.8 0.9High

Cattle manure management: good practiceA2

Ammonia See Table 14

See Table 14

2020 2030 See Table 14 See Table 14 See Table 14 0.8 2.0 2.1

High

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Table 14. PaM objectives and types, implementation authorities and Methodology used

PaM description PaM objectives PaM TypeImplementation Authorities Methodology used

Type Name

NAQIP residential heating packageR1 + R2 + R3

2. Energy supply: Other: cleaner fuels2. Energy consumption:Efficiency improvement of appliances

Source-based pollution controlInformationRegulatory

MinistryMinistryMinistryMinistryNational AgencyNational AgencyNational AgencyNational Agency

Local AuthoritiesCompanies

Ministry of Economy (submits notification to the EC on proposed measures when necessary; participates in drafting regulation on requirements on solid fuels as per Art. 8a of the CAAA)MOEWMAFFMSLPExecutive Forest AgencyState Forest Enterprises and municipal forest structuresSAMTSSEDAMunicipalities (Municipal bodies)Gas and DH Companies

Bottom-up assessment based on the numbers of households in PM10 non-compliant municipalities using stoves for heating

Modernise road vehicle fleet through import controlsRT1

2. Transport: Deployment of pollution abatement technologies on vehiclesDemand management/reduction

Source-based pollution controlRegulatory

MinistryNational Agency

MTITCExecutive Agency Automobile Administration (ExAAA)MOI

COPERT model

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NAQIP Low Emission Zones in major conurbationsRT2

2. Transport: Demand management/reduction

Economic instrumentsInformationRegulatory

MinistryMinistryMinistryLocal Authorities

MOEWMTITCMRDPWMunicipalities (Municipal bodies)

Professional judgement and COPERT model

Fertilizer use: good practiceA1

2. Agriculture: Low emission application of fertilizer/ manure on cropland and grassland

Source-based pollution controlVoluntary/negotiated agreementsInformationEducation

MinistryMAFF Professional judgement

Cattle manure management: good practiceA2

2. Agriculture: Improved animal waste management systems

Source-based pollution controlVoluntary/negotiated agreementsInformationEducation

MinistryMAFF Professional judgement

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2.6.2. IMPACTS ON A IR QUALITY AND THE ENVIRONMENT OF INDIVIDUAL PAMS OR PACKAGES OF PAMS CONSIDERED IN ORDER TO COMPLY WITH THE EMISSION REDUCTION COMMITMENTS

The expected impacts of the considered additional measures for reducing particulate matter emissions from residential heating have been assessed in the NAQIP.14 Specifically, the NAQIP addresses the emissions of particulate material from residential heating in municipalities that have not complied with PM10 air quality criteria, and from road transport in Sofia and Plovdiv only. The PaM directed at residential heating and PM 10

emissions has the co-benefits of reducing the emissions of PAH and black carbon.

Estimates show that the package of PaMs considered may reduce primary PM 10 emissions in the non-compliant municipalities by ~80 %. As determined using the methodology outlined in Section 2.5.2., the expected degree of emissions reduction is greater than that needed to achieve PM10 compliance in the relevant municipalities. Consequently, it is possible that all Air Quality Zones in Bulgaria could become compliant regarding PM10 by 2025 through the full implementation of NAQIP in the residential heating sector, supported by implementing additional PaMs considered in the road transport sector.

The residential heating PaM is expected to have knock-on impacts through reducing the emissions of NMVOCs and ammonia, contributing further to an improvement in Bulgaria’s ambient air quality.

2.6.3. ESTIMATION OF COSTS AND BENEFITS OF THE RESIDENTIAL HEATING PAM PACKAGE CONSIDERED TO COMPLY WITH THE FINE PARTICULATE MATTER EMISSION REDUCTION COMMITMENTS

Following on from the extensive analyses undertaken for NAQIP, which aims to achieve compliance with PM 10

ambient air quality goals, further analysis has been made of the costs and benefits of the additional PaMs considered for reducing PM2.5 emissions from residential heating. 15 Though not a mandatory requirement of Decision (EU) 2018/1522, this further analysis has been undertaken to underpin and emphasise the significance of this PaM package, which aims to resolve as quickly as possible Bulgaria’s most pressing ambient air quality issue. The analysis has been undertaken in harmony with the national emissions projections (WM and WAM). The approach adopted in the analysis is presented here. Further details of the methodology may be found in Annex VII.

The analysis has estimated the costs and benefits of the additional measures considered for reducing PM2.5

emissions from residential heating in municipalities that have not complied with PM 10 air quality limit values. The work is consistent with the (non-mandatory) requirements set out in Decision (EU) 2018/1522. It demonstrates the commitment of the Bulgarian government to fully understand the measures being considered for achieving the necessary emissions ceilings and their associated costs and benefits. In particular, it wishes to ensure that the measures can be justified on economic grounds and add value to society. The analysis is also intended to provide an indication of the relative costs and cost-effectiveness of the various measures as an aid to future planning and decision making.

The measures evaluated are those on which the emissions profiles have been defined:

Setting and ensuring compliance with fire-wood requirements

Switching from conventional stoves to central gas supply (reconnections and new connections)

Switching from conventional stoves to district heating networks (reconnections and new connections)

Switching from conventional stoves to ecolabel-stoves

14 The official draft of the NAQIP is published on the web for the purpose of conducting public consultations: http://www.strategy.bg/PublicConsultations/View.aspx?@lang=bg-BG&Id=384615 A constant ratio of PM2.5 to PM10 has been assumed throughout the emission projections methodology and in this analysis.

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http://www.strategy.bg/PublicConsultations/View.aspx?@lang=bg-BG&Id=3846


Note that reconnections and new connections to central gas supply and to district heating networks are treated as separate measures in this analysis.

The analysis uses an incremental approach. That is, investment and operating costs are calculated net of any costs that are avoided in the With Measures (WM) scenario as a result of implementing the additional measure. This is especially relevant to the calculation of operational costs. For example, the direct operational costs of switching from a conventional stove to a modern eco-label stove are calculated as the full direct costs of operating the modern stove minus the direct operating costs of operating the traditional stove. A similar approach is taken with investment costs, although here the only costs avoided when replacing or shifting from a stove to another energy source are the costs that would otherwise be incurred in replacing end-of-life stock. Note that the summary table below shows investment costs as absolute expenditure requirements and are not offset against any avoided costs.

All financial values are resource costs based on constant 2018 market prices. The analysis does not consider the effects possible financing arrangements (such as subsidies) might have on the affordability or financing of the costs. Appliance and fuel prices used in the analysis are the average of a range of prices estimated for core cost items.

PM2.5 emissions reductions from implementing the measures result in a fall in the damage caused to human health. The economic impact of emissions reductions is the number of premature deaths avoided as a result of implementing the measures. In this assessment, damage to human health avoided is calculated using estimates from the literature of the value of statistical life (VOSL) and of the number of premature fatalities caused per unit of energy used for heating when burning wood in open fireplaces. Health benefits are recurring and cumulative over time. The value of the benefits (avoided premature fatalities) calculated in this way is compared to the costs of the measures using discounted cash flow analysis. The value of statistical life used in the calculations reflects the low end of relevant estimates from the literature.

The analysis uses an integrated emissions16-CBA model to estimate the costs and benefits of the measures separately and combined. It incorporates the emissions calculations, and the assessment period corresponds to the time frame over which the emissions profiles have been calculated (2016 to 2030). Parameters estimated over the assessment period for each measure are:

- Emission reductions- Investment costs - Operational costs - Net financial cash flows (after residual values)- Financial costs / tonne of PM2.5 reduced (the core measure of cost-effectiveness)- Physical and monetised values of the economic (health) benefits associated with emission reductions- Net present values (benefits minus costs) and associated benefit-cost ratios (the core measures of net

benefit (or cost) to societyInvestment expenditures are incurred in switching from conventional stoves to alternative energy sources (natural gas and district heating networks) and to alternative appliance types (ecolabel stoves).

- Each year, 1 % of conventional stoves are projected to switch to natural gas and 1 % to district heating, half being new connections and half reconnections. This replaces 96 000 stoves: 52 000 by natural gas and 44 000 by district heating. Emission reductions achieved as a proportion of total reductions over the assessment period are 15 % for gas and 12 % for district heating.

- In addition, 158 000 conventional solid-fuel stoves are projected to switch to ecological alternatives (different from central heating or natural gas connections), contributing 29 % to total emissions reductions over the assessment period.

- The introduction of requirements for wood is a key measure. The assumption is made that conventional wood stoves switching from poor quality high moisture wood to “dry” wood leads to a

16 CBA – cost benefit analysis

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reduction in PM2.5 emissions of 34 %. This measure is estimated to account for 44 % of the cumulative, total emission reductions projected over the assessment period.

Table 15 summarizes the key findings from the analysis.

Table 15. Estimated costs and benefits of the residential heating PaMs package in NAQIP

PaM component

Cost (€) per

tonne PM2.5

reduced

Absolute value of the investment

until 2030 (€ m)

Cumulative

emissions reduced (t

PM2.5)

NPV of Benefits minus

costs (€m)

Benefit/Cost Ratio

(BCR)

Cost Year

Cost-effectivenes

s and BCR ranking

Reconnection to gas

715 12 7 510 121 38.2 2018 1

New connection to gas

11 297 100 7 510 73 2.4 2018 6

Reconnection to district heating

1 256 10 6 398 101 21.8 2018 2

New connection to district heating

3 733 28 6 398 91 7.3 2018 3

Fuel quality requirements

8 137 017 45 546 584 3.4 2018 5

Switch to ecolabel stoves

4 806 276 29 509 350 5.7 2018 4

5 954* 426** 102 871** 1 321** 4.6*

Qualitative description of costs and benefit estimates: The assessment is based on incremental costs and benefits: the difference between WM and WAM scenarios. Total investment costs over the assessment period are shown in absolute terms and are undiscounted. All values are in constant 2018 prices. A real discount rate of 6 % is used in the DCF analysis. Benefits are calculated as premature deaths avoided and are valued using value of statistical life (VOSL) – see Annex VII.*The value is the weighted average of the values in the columns above.**The value is the sum of the values in the columns above.

Amongst other things, Table 15 shows the ranking of individual components of the PaM package according to cost-effectiveness and BCR criteria. Cost effectiveness gives an indication of the financial effectiveness of a measure, whereas the BCR indicates whether a measure, or collection of measures, can be justified in economic terms i.e. value added to society. The analysis shows that all component measures add value to society (BCR > 1). The rankings are the same for each criterion. Using these criteria, the measures rank, in decreasing order: 1. Reconnection to gas 2. Reconnection to district heating 3. New connection to district heating

17 The absolute value of investment for the Fuel Requirements measure is 0 since no additional expenditure is necessary. This measure must be implemented since it is an administrative/legislative measure. The analysis recognises the need of additional resources for the implementation of this measure – these resources are earmarked as operational costs. Hence, the measure is not the most cost-effective one, as the last column of Table 15 demonstrates and as elaborated in more detail in Appendix VII.

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4. Switch to ecolabel stoves 5. Fuel quality requirements 6. New connection to gas

2.6.4. ADDITIONAL DETAILS CONCERNING THE MEASURES CONSIDERED FROM ANNEX III PART 2 TO D IRECTIVE (EU) 2016/2284 TARGETING THE AGRICULTURAL SECTOR TO COMPLY WITH THE EMISSION REDUCTION COMMITMENTS

Part 1 of Annex III of Directive (EU) 2016/2284 sets out the minimum content of the National Air Pollution Control Programmes (NAPCP) which has to be adopted by the respective Member State in order to achieve the required respective national reduction commitment for each of the air pollutants in Directive (EU) 2016/2284.

Part 2 of Annex III deals specifically with controls on the emissions of ammonia from agriculture. This is especially important since agriculture is the largest source of ammonia emissions up to 90 % of the national total emissions). Ammonia is also a known precursor to secondary PM2.5 and PM10 formation. However, achieving reductions of these emissions can be particularly difficult as they involve dealing with animal waste and fertilisers.

Part 2 also:

Provides links between Directive (EU) 2016/2284 and the UNECE Framework Code for Good Agricultural Practice for Reducing Ammonia Emissions of 2014;

Stresses the legal requirement to make use of Best Available Techniques (BAT) under Directive 2010/75/EU;

Prohibits the use of ammonium carbonate fertilisers and introduces approaches by which Member States may reduce ammonia emissions from inorganic fertilisers;

Introduces the need for the development of a whole nitrogen cycle;

Provides the possibility for a ban on the open-field burning of agricultural harvest residue and waste and forest residue.

Bulgaria will also take into account the regulations of the Common Agricultural Policy (CAP) beyond 2020 made by the European Commission in 2018, which are not yet adopted, to control emissions from agriculture. These proposals aim to make the CAP more responsive to current and future challenges such as climate change or generational renewal, while continuing to support European farmers within a sustainable and competitive agricultural sector.

Measures to reduce ammonia emissions

The present situation in Bulgaria regarding emissions of pollutants from agriculture in Directive (EU) 2016/2284 is summarised below:

Good Agricultural Practice Rules to reduce ammonia emissions from agricultural sources.

- Draft of Good Agricultural Practice Rules to reduce ammonia emissions from agricultural sources;

- The draft is based on the UNECE Framework Code for Good Agricultural Practice for Reducing Ammonia Emissions.

o Management of nitrogen, taking into account the full nitrogen cycle;

o Feed strategies for livestock;

o Low-emission systems for livestock buildings;

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o Low-emissions systems for manure storage;

o Low-emission techniques for manure spreading; o Options for limiting ammonia emissions from mineral fertilisers application.

- Once approved, the Rules will be disseminated through agricultural outreach. The impacts will be monitored by survey, the results feeding back into the National Inventory of Emissions of Harmful Substances in the Ambient Air and into future emissions projections.

Establishing a national budget for nitrogen:

o For the year 2017, MAFF’s Agro-statistics Department supplied Eurostat with national level data (prepared by BFSA) on the annual use of nitrogen and phosphorus active substance quantities in agriculture;

o By an agreement, approved on 16 November 2017 at the 35th meeting of the European Statistical System Committee (ESSC), national input and output data on nitrogen and phosphorus shall be gathered and submitted every two years;

o The data transfer deadline is 30 June of year (T + 2). The dataset shall cover nitrogen and phosphorus inputs and production in agriculture under specific indicators (mineral fertilizers, livestock manure per species, other organic fertilizers, biological nitrogen fixation, atmospheric nitrogen deposition, seeds and propagating material, nitrogen emissions into the air, feed production, removed/burned residues, etc.);

o Data for these different indicators shall be used by Eurostat to prepare the Gross Nutrient Balance (GNB), which is a key indicator for numerous agri-environmental policies. It is also meant to be an indicator for potential surplus or deficit threats for the agricultural system with regard to these two significant soil and plant nutrients – nitrogen and phosphorus.

Use of ammonium carbonate fertilizers:

Ammonium carbonate fertilisers are banned under the Gothenburg Protocol, of which Bulgaria is a signatory and ratified in 2005. According to information from MAFF, ammonium carbonate fertilisers are not in use in Bulgaria.

One of the conclusions to be drawn from the projected emissions under the current WMs scenario is that the emissions reduction will not cover the ammonia reduction commitments by 2030. Therefore, additional measures in the agricultural sector are being proposed in order to comply with the obligations undertaken by 2030:

- A1 – Fertilisers: stronger motivation to comply with the requirements of the Nitrates Directive and, by observing the Good Agricultural Practice Rules, to reduce ammonia emissions from agricultural sources. It is estimated that the levels of ammonia emissions from fertilisers and manure use will be reduced by a total of 25 % for the whole period. This is included in the projection estimates for a 10-year period (2016-2026), with an annual reduction of 2.5 %;

- A2 – Manure: more widespread application of good agricultural practices in manure management will be ensured through the implementation of the Good Agricultural Practice Rules to reduce ammonia emissions from agricultural sources. It is estimated that the levels of ammonia emissions from manure management will be reduced by a total of 20 % for the whole period. This is stated in the projection estimates for the period 2016-2026, with an expected annual reduction of 2 %;

Measures to reduce fine particulate matter (PM2.5) and soot emissions

Banning the open-field burning of agricultural waste:

- The Agricultural Land Conservation Act is in effect in Bulgaria (prom. SG No 35/24.04.1996, amended: Issue SG No 83/09.10.2018):

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- Pursuant to Article 5(4), users of agricultural lands are held responsible for open-field burning of stubble and other vegetable waste in the agricultural land and are required to partake in the fire extinguishing efforts;

- Pursuant to Article 6 (1) (2) of the said Act, open field burning of stubble and other vegetable waste in agricultural land is prohibited;

- The law imposes sanctions on those who burn stubble. Violations are established most often after an alert has been issued. The Minister of Agriculture, Food and Forestry issues regulation to form a committee including officials from the Regional Directorate of Agriculture (RDA), the mayor of the settlement and a representative of DG Fire Safety and Civil Protection. Violation acts are drawn up by RDA officials.

o As per Article 41a (1), a fine of BGN 1 500 to 6 000 shall be imposed on the user of agricultural land, where open-field burning of stubble and other vegetable waste has been carried out;

o Pursuant to Article 44 (1), the violation shall be established by an act of officials appointed by the Minister of Agriculture, Food and Forests, and in the event of violations on lands of the municipal land fund, as well as in cases under Article 41a (1) – by officials appointed by the municipality’s mayor.

o The penalty decree is issued by the Minister of Agriculture, Food and Forestry or by an authorized official or, respectively, by the municipality’s mayor or an official authorized by the latter.

o Acts, issued by persons under Article 44(1), shall be sent to Agriculture State Fund so as to sanction violations of the Guidelines for Practical Application of the Requirements for Maintaining the Land in Good Agricultural and Environmental Status. (National Standard No 6);

o The owners of land where open-field burning has been found to have taken place are liable to have their financial subsidies removed.

Preventing Impact on Small Farms

Common Agricultural Policy (CAP)

Eighty-five per cent of the total ammonia emissions in Bulgaria come from agriculture. In addition, burning of stubble is popular among Bulgarian farmers, although the practice has been prohibited by national law. As such improved management of agricultural practice has significant potential benefits for meeting the requirements of Directive (Eu0 2016/2284.

Experience shows that local farmers are very responsive to economic incentives created to influence their behaviour. For example, connecting direct payments under current CAP framework with certain environmental obligations which led to significant reduction of emissions from stubble burning (information provided by MAFF).

We will take the following measures into account in this regard:

- The current CAP (applicable since 2013) contains “greening” and “cross-compliance” mechanisms. Under the “greening” mechanism, farmers receiving direct payments are obliged to apply certain practices that benefit the environment and the climate (e.g. crop diversification);

- “Cross-compliance” is a mechanism that links direct payments to compliance by farmers with basic standards concerning the environment, food safety, animal and plant health and animal welfare, humane treatment of animals, as well as the requirement of maintaining land in good agricultural and environmental condition. There are two elements of the “cross-compliance” mechanism: “statutory management requirements” and “good agricultural and environmental conditions”.

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At the national level, MAFF has issued Guidelines for the implementation of statutory management requirements, with Part I of these Guidelines applying to ammonia fertilizers and manure.

In 2016, MAFF adopted also Guidelines for Practical Application of the Requirements for Maintaining the Land in Good Agricultural and Environmental Status, in particular:

- National standard No 1 prohibiting the use of ammonia fertilisers and manure in buffer zones:

of at least 5-meter width in flat areas, along surface water bodies (rivers, streams, canals, lakes, dams, sea), rice fields excluded;

of at least 10-meter width in flat areas when liquid fraction of manure is used for fertilization;

of at least 10-meter width when fertilizing sloped areas;

of at least 50-meter width when fertilizing steep inclined areas.;

- National standard No6 prohibiting burning of stubble.

National standards are mandatory for farmers who receive direct payments, who are beneficiaries under Articles 46 and 47 of Regulation (EU) 1308/2013 establishing a common organization of the markets of agricultural products and repealing Regulations (EEC) 922/72, (EEC) 234/79, Directive 1037/2001 and (EC) 1234/2007 or who are beneficiaries under certain measures under the Rural Areas Development Programme 2014-2020. The National standards for good agricultural and ecological status do not repeal the obligations land owners and land users have under the Agricultural Land Conservation Act, the Agricultural Land Ownership and Use Act, as well as under other relevant legislation.

The interaction between environmental commitments, direct payments from EU funds and national standards on agriculture probably will continue under the new CAP rules applicable beyond 2020. The legislative framework of the new CAP is still not adopted yet. However, EC has stated its intentions to create a new CAP that will be more responsive to current and future challenges such as climate change and generational renewal, while continuing to support European farmers within a sustainable and competitive agricultural sector.

The future CAP (post 2020) will be based on 9 clear objectives in order to continue to ensure access to high-quality food and strong support for the European farming model. Four of these could be linked to the emissions of pollutants under Directive (EU) 2016/2284 (but mainly to ammonia emissions), namely:

- Climate change action;

- Environmental care;

- Preservation of landscapes and biodiversity;

- Protection of food and health quality.

The existing mechanisms of “greening” and “cross-compliance” will be simplified and merged in a single “conditionality” mechanism. Conditionality will be a system of linkage between area- and animal-based CAP payments and a range of obligations. When recipients of CAP payments do not meet the obligations, the payments may be reduced. These obligations will originate either in CAP legislation (in the case of "guidelines for practical application of requirements for good agricultural and environmental condition") or in non-CAP directives and regulations (in the case of "statutory management requirements" ). All the GAEC standards and some of the SMRs will concern the environment, water, soil, and biodiversity/landscapes.

Under the new CAP rules, Member States will have more opportunities to tailor the application of the conditionality mechanism to its specific local needs and priorities. In the case of GAEC standards, the EU-level rules will set out only the essence of each standard and Member States will decide on the detail of implementation. Member States may also choose to implement a given standard differently for different regions – according to soil, climate, land use, farming structures etc. Member States may also lay down additional standards to meet the EU's objectives. In the case of most SMRs, Member States have already decided how to implement the non-CAP legislation in question via proper arrangements in their national law.

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Fundamentally, Member States will be required to adopt a national plan on the implementation of CAP clarifying how they plan to achieve the CAP’s environmental objectives.

Bulgaria will review and if necessary, amend the present controls on the emissions of pollutants from agriculture under Directive (EU) 2016-2284 once the new rules on CAP are adopted.

Table VI.2, in Annex VI presents Table 2.6.4 of the Commission Implementing Decision (EU) 2018/1522 on the ‘Additional details concerning the measures from Annex III Part 2 to Directive (EU) 2016/2284 targeting the agricultural sector to comply with the emission reduction commitments’.

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2.7. THE POLICIES SELECTED FOR ADOPTION BY SECTOR, INCLUDING A TIMETABLE FOR THEIR ADOPTION, IMPLEMENTATION AND REVIEW, AND THE COMPETENT AUTHORITIES RESPONSIBLE

2.7.1. PAMS SELECTED FOR ADOPTION AND THE COMPETENT AUTHORITIES RESPONSIBLE

Table 16 presents the selected PaM package and PaMs included in the National Air Pollution Control Programme, conforming to the scope and general format defined in Decision (EU) 2018/1522.

Section 2.7.2 presents the rationale for choosing the selected PaMs and assesses their coherence with ambient air quality objectives and other relevant plans and programmes established by virtue of the requirements set out in national or Union legislation.

Chapter 3 addresses the implementation of the selected additional PaMs and associated challenges.

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Table 16. Individual PaMs or package of PaMs selected for adoption, implementation timetable, and competent authorities responsible

Name and brief description of individual PaM or package

of PaMs

Currently planned year of adoption

Relevant specific

comments in consultation(s)

Currently planned timetable (years) for

implementation

Monitoring of implementation progress

Currently planned timetable for

review1

Competent responsible

authorit(y)(ies)Start End Interim targets Indicators

NAQIP (National Programme

for Ambient Air Quality

Improvement)Residential heating packageR1 + R2 + R3

2019 [To follow post-consultation]

2019-2020

2025-2030 Replace all stoves by 2025 in non-compliant municipalities

Regulation on coal quality requirement in place 2019

Policies for firewood in place as of 2020

Information disseminated to public 2019

Numbers of stoves replaced

Adopted regulations

Implementation of policies% of compliance of firewood

Information published

Numbers of households switching to gas / district

Annually until 2026 MOEWMOECONOMYMAFFMSLPExecutive Forest Agency (ExFA)State Forest Enterprises and municipal forest structures

Municipalities (Municipal bodies)Gas and DH CompaniesSAMTSSustainable Energy Development Agency

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Name and brief description of individual PaM or package

of PaMs

Currently planned year of adoption

Relevant specific

comments in consultation(s)

Currently planned timetable (years) for

implementation

Monitoring of implementation progress

Currently planned timetable for

review1

Competent responsible

authorit(y)(ies)Start End Interim targets Indicators

heatingRoad transport Modernize the vehicle fleet through allowing “cleaner” imports onlyRT1


2020 2021 Legislation complete

Impact of measure quantified

Decisions by Council of Ministers and the EC

Surveys of imports

Annually MTITCEXAAAMOI

Road transport: Low emission zones (LEZ) in Sofia and PlovdivRT2


2019 2024Dependent

on AQ status

Adoption of policy measure by Parliament and Council of Ministers

LEZ process complete in Municipalities

Impacts assessed

Parliament and Council process complete

LEZ (Low emission zones) planning approval

Reduced nitrogen oxides and PM pollution levels

Annually MOEWMTITCMRDPWMunicipalities (Municipal bodies)

Agriculture: Good practice for using fertilizers31


2019 2030+ Ammonia emission rate from fertilizer application to be reduced by 25 % by 2026-28

Reported application rates

Annually Ministry of Agriculture, Food and Forestry

Agriculture: Good practice for cattle manure management32


2019 2030+ 30 % compliance with best practice by 2030

Farm surveys of current practice

Annually Ministry of Agriculture, Food and Forestry

1 Currently planned for review every four years unless stated otherwise.

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2.7.2. RATIONALE FOR CHOOSING THE SELECTED PAMS AND AN ASSESSMENT OF THEIR COHERENCE WITH PLANS AND PROGRAMMES IN OTHER RELEVANT POLICY AREAS

Table 17 summarizes the rationale for choosing the selected PaMs and provides an assessment of their coherence with ambient air quality objectives at a national level and with those of neighbouring Member States. It also provides a summary of how the selected PaMs are coherent with other relevant plans and programmes established by virtue of the requirements set out in national or EU legislation.

Table 17. Explanation of the choice of selected measures and an assessment of how selected PaMs ensure coherence with plans and programmes set up in other relevant policy areas

Aspect Explanation / Assessment

Rationale for determining the final set of selected measures (optional inclusion)

The impact of the measures agreed within the NAQIP were taken as a starting point, followed by identifying Additional Measures required to achieve the respective emissions reductions where existing PaMs and NAQIP were projected not to produce sufficient national emission reductions. Each of the measures listed in Section 2.6.1 was assessed to identify the most appropriate Additional Measures to meet the respective emission reduction commitments for Bulgaria on the following basis:- Those which could make the respective largest contribution to meeting the

national reduction commitments under Directive (EU) 2016/2284; starting with the most cost-effective measures, where identified;

- Feasibility regarding the current and emerging Legal requirements (both EU and national); Coherence with Industrial strategies; Effect on society taking into account both economic and health

benefits.

Coherence of the selected PaMs with air quality objectives(mandatory inclusion)

The measures chosen for the National Air Pollution Control Programme include those agreed for the NAQIP. With the additional measures proposed, we expect Bulgaria’s ambient air quality objectives to be achieved. The PaMs in the National Air Pollution Control Programme are wholly coherent with the ambient air quality objectives of Bulgaria. They are also fully coherent with the ambient air quality objectives of neighbouring Member States.

Coherence of the selected PaMs with other relevant plans and programmes established by virtue of the requirements set out in national or Union legislation(mandatory inclusion)

The PaMs in this National Air Pollution Control Programme are or will be fully coherent with the:- National Energy Strategy:- Bulgaria’s greenhouse gas emissions projections and Climate Change

programme, including its commitments to energy efficiency and use of renewable energy resources

- Energy Efficiency Act, transposing: Directive 2010/31/EU on the energy performance of buildings

subsequently amended by Directive (EU) 2018/844; and Directive 2012/27/EU on energy efficiency subsequently amended

by Directive (EU) 2018/2002; and the- National Programme for Energy Efficiency of Multi-Family Residential

Buildings (started 2015).

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2.8. PROJECTED COMBINED IMPACTS OF PAMS (WITH ADDITIONAL MEASURES – WAM) ON EMISSIONS REDUCTIONS, AMBIENT AIR QUALITY AND THE ENVIRONMENT, AND THE RELATED UNCERTAINTIES

Emission projections under the With Additional Measures (WAM) scenario have built upon the WM emission projections methodology, adopting the selected additional measures identified in Section 2.7.1. Best practice, as presented in the 2016 version of the EMEP/EEA Emissions Inventory Guidebook, has been adopted. The same sector resolution adopted for the WM emissions projections applies – see Section 2.5.1 Table 10.

2.8.1. PROJECTED ATTAINMENT OF EMISSION REDUCTION COMMITMENTS (WAM)

Table 18 summarizes the projected emissions under the WAM scenario and assesses whether or not the emission reduction commitments (ERCs) are met. Emission reduction values in cells shaded ‘green’ meet the ERCs. This is the case for all pollutants for both 2020 and 2030. Figures 17 through to 21 present the projected total emissions and sectoral breakdowns for each pollutant to year 2030. Annex VIII summarizes the changes from the WM scenario that result from adopting the selected PaMs.

Table 18. Projected emissions, emission reductions, and compliance (WAM Scenario)18

Pollutant

Emissions (ktonnes) consistent with inventory for 2016

% Emission reduction compared with 2005


2005 2020 2025 2030 2020 2025 2030 2020-2029 2030+

Nitrogen Oxides *

183.2 93.8 84.4 74.7 49 % 54 % 59 % 41 % 58 %

NMVOC * 80.7 62.1 53.3 46.3 23 % 34 % 43 % 21 % 42 %

Sulphur Dioxide

771.3 79.6 80.2 83.4 90 % 90 % 89 % 78 % 88 %

Ammonia 51.6 45.0 44.1 43.8 13 % 15 % 15 % 3 % 12 %

PM2.5 30.9 22.2 13.3 7.8 28 % 57 % 75 % 20 % 41 %Date of Emission Projections 27 January 2019

* Nitrogen oxides and NMVOC emissions from 3B, 3D agricultural sources are omitted

18 Nitrogen oxides and NMVOC emissions from agricultural sources are omitted from the totals in this Table and Figures 10 to 14. Emissions of sulphur dioxide in the base year, 2005, differ from the latest value in the National Inventory of Emissions, for the reasons explained in Annex IV.

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Figure 17. Nitrogen Oxides Emission Projections under the WAM Scenario

0

20

40

60

80

100

120

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

NOx

Electricity Generation Industrial Combustion Residential & Other Combn

Road Transport Other Transport Ind. Processes & Fugitives

Solvent Use Waste Other

Ceilings

Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 93.8 87.4 86.5 86.1 85.1 84.4 82.5 80.6 78.5 76.7 74.7

Figure 18. NMVOC Emission Projections under the WAM Scenario

0

10

20

30

40

50

60

70

80

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

NMVOC

Electricity Generation Industrial Combustion Residential & Other CombnRoad Transport Other Transport Ind. Processes & FugitivesSolvent Use Waste OtherCeilings

Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 62.1 60.2 58.4 56.7 55.0 53.3 51.7 50.4 49.0 47.7 46.3

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Figure 19. Sulphur oxide Emission Projections under the WAM Scenario

0

20

40

60

80

100

120

140

160

180

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

SO2


Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 79.6 77.7 78.3 78.9 79.6 80.2 80.8 81.5 82.1 82.7 83.4

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Figure 20. Ammonia Emission Projections under the WAM Scenario

0

10

20

30

40

50

60

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

NH3


Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 45.0 44.4 44.1 44.0 44.0 44.1 43.2 43.2 43.4 43.6 43.8

Figure 21. PM2.5 Emission Projections under the WAM Scenario

0

5

10

15

20

25

30

35

2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

PM2.5


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Total 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030ktonnes 22.2 20.2 18.3 16.6 14.9 13.3 11.9 10.9 9.9 8.8 7.8

2.8.2. NON-LINEAR EMISSION REDUCTION TRAJECTORY

The emission projections for all pollutants between 2025 and 2030 follow a broadly linear trajectory of reduction, with no substantial step changes in emissions between 2025 and 2030.

2.8.3. FLEXIBILITIES

Bulgaria has no intention of taking up the option of including flexibilities to demonstrate compliance with the emission reduction commitments from 2020 onwards.

2.8.4. PROJECTED IMPROVEMENT IN AMBIENT A IR QUALITY (WAM)

The application of policies and the implementation of additional measures are expected to lead to significant reductions in PM2.5 and PM10 emissions. Nationally, the projections indicate that PM2.5 emissions will reduce by 75 % between 2016 and 2030, from 31.9 to 7.8 ktonnes/y. Locally, specifically in those municipalities that have not complied with PM10 ambient air quality criteria in the recent past, we expect that PM reductions of greater than 75 % may result from implementing the existing and selected additional PaMs. In every case, the expected reductions exceed the calculated minimum levels of reduction needed for compliance that are shown in Annex V. Regarding PM10 , therefore, we expect that the projected emissions reduction will be accompanied by improvements in ambient air quality and the compliance of all Air Quality Zones with PM 10 standards. Full implementation of the selected PaM package regarding residential heating could allow compliance with standards to be achieved in many municipalities and AQ zones by 2025.

For other pollutants, impacts in terms of AQ zone cannot be reported with confidence, for the reasons noted in Section 2.5.2. It is, however, expected that the projected reductions in the emission to contribute further to improving ambient air quality in Bulgaria and in neighbouring countries and areas. As commented in Section 2.5.2.1 regarding future ambient air quality in the WM scenario, it is expected the lower emissions of nitrogen oxides, NMVOC and ammonia to contribute also to lower rates of formation of secondary PM2.5 and PM10 and, therefore, to lower concentrations of PM2.5 and PM10 in the ambient air. These would be additional to the impacts resulting from reduced primary PM emissions.

2.8.5. PROJECTED IMPACTS ON THE ENVIRONMENT (WAM)

There is insufficient information and ambient air quality modelling capacity in Bulgaria to project the impacts on the environment of the existing and additional policies and measures combined. Hence this optional assessment cannot be provided. Modest impact reductions may be expected.

3. IMPLEMENTATION ISSUES

3.1. ACKNOWLEDGING THE CHALLENGES

We recognize that implementing the National Air Pollution Control Programme will be challenging. Challenges ahead lie in: (i) implementing the additional policies and measures (PaMs) identified for the residential heating,

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road transport, and agricultural sectors, (ii) the introduction and application of upgraded methodologies for preparing the National Inventory of Emissions of Harmful Substances in the Ambient Air so that it may serve in future as a tool for policy development and review, (iii) preparing revised emission projections in 2021, and every two years thereafter, and (iv) preparing a revised National Air Pollution Control Programme in 2023. The next scheduled set of emission projections and the updated National Air Pollution Control Programme will need to incorporate Bulgaria’s Strategy for Sustainable Energy Development. It will also have to accommodate feedback on the actual performance of sectors in managing their emissions of pollutants to air. Potentially, should for any reason the future emission projections indicate that the emission reduction commitments are at risk not being met, it might also be necessary to identify additional PaMs. Meeting these challenges may require:

That the institutional will to take action, and the capacity to do so, are strengthened where relevant;

Effective communication to help overcome barriers and gain support for action;

Gaining the agreement of the European Commission to enable the implementation of certain market-related measures in the residential heating and road transport sectors;

Securing and mobilizing the financial resources needed for implementation;

Effective local planning to deliver the implementation of residential heating measures over the required timescale;

Institutional coordination at the inter-Ministry level.

Implementation issues concerning the additional PaMs are identified first, on a sector by sector basis starting with the residential heating package, followed by the identified cross-sectoral issues.

3.2. IMPLEMENTING THE SECTORAL PAMS

3.2.1. RESIDENTIAL HEATING SECTOR

As stated previously (see Table 12 in Section 2.6.1) this PaM package, currently under consideration by the Council of Ministers, comprises several elements:

- Fuel quality requirements or their equivalent, most significantly for the moisture content of firewood in Municipalities that have persistently failed to comply with fine particulate matter Limit Values;

- Bringing forward the date at which Regulation (EU) 2015/1185 for stoves comes into effect, from 1 January 2022 to 1 January 2020, or as close to the latter date as possible;

- A compulsory, phasing out of traditional solid-fuel fired stoves over a five-year period, from 2020 to 2024 inclusive, in those Municipalities that have persistently failed to comply with fine particulate matter Limit Values;

- Adoption of alternative heating methods – natural gas where available, district heating where available, and stoves that meet the ecodesign requirements – the choice being guided by the results of the cost-benefit analysis presented in Chapter 2.6.3.

Moisture content of firewood

Given the socio-economic conditions and traditional practices prevailing in Bulgaria, enforcing a mandatory upper moisture content for wood to be sold or used as firewood may be impractical. Hence, in the short-term to medium term, at least, it is proposed to adopt surrogate, organizational methods to reduce the moisture content of the firewood burned. Provided implementation and enforcement are conducted with a sense of purpose, the surrogate, organizational methods would help obviate the polluting emissions when wood is burned:

- Legal ban on the sale of firewood by weight. The current legal framework allows the sale of wood by tonne or by cubic meter. However, selling wood by weight incentivizes traders to sell wood with a high

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moisture content. The Regulation on the terms and conditions of assigning activities implementation in the forest territories that are state or municipal property and on the use of wood and non-wood forest products should explicitly exclude the option to sell firewood by weight.

Amend the practice of the public’s direct harvesting of firewood, which amounts to about 208 000-325 000 m3

per year. In practice, there is no restriction on when harvesting can take place. Hence it is possible that no account is taken of the benefits of drying wood before the winter burning season. Direct harvesting of firewood by physical persons should, especially in areas with deteriorated ambient air quality, be allowed for a restricted period only terminating for instance in August. Given the value of this component measure, as demonstrated in the cost-benefit analysis presented in Chapter 2.6.3., effort needs to be made to implement it as soon as possible, and to enforce it thereafter. If after a trial period of several years such organizational measures do not bring about the desired effect, then options for setting limiting moisture contents for firewood sold and used may have to be developed and implemented. SNAQMP provides further details on identified options.

Developments in the Implementation of Eco-Design Regulation for Stoves

The Ecodesign Regulations prevent the placing on the market and putting into service appliances that fail to comply with minimum standards in terms of design and emissions performance. Commission Regulation (EU) 2015/1185 is not due to come into effect until 1 January 2022. For Bulgaria to meet its obligations to comply with Directive 2008/50/EC as soon as possible, and meet its emission reduction commitments under Directive (EU) 2016/2284, it is clearly desirable to bring this enforcement date forwards. New legislation regarding the requirements for solid fuel appliances will need to be adopted but Bulgaria must first notify the European Commission of its intention and prove that all conditions under Article 114, paragraph 5 of the Treaty on the Functioning of the European Union, are satisfied.

Whilst the MoEW is happy to play a supportive role in drafting the relevant legislation on the requirements for solid fuel appliances, as well as in preparing the notification to the EC of the Government’s intent, it does not have the authority to initiate that procedure. If the appropriate arm of Government fails to notify the EC of its intent to bring forward the date of the Regulation coming into effect, or the EC declines to approve this initiative, then implementing the compulsory phase-out of traditional stoves in the target municipalities will be delayed. This would have knock on adverse health impacts and increase the risk that the Government of Bulgaria will incur fines for failing to comply with the ambient air quality Limit Values of Directive 2008/50/EC.

Compulsory phase out of traditional, solid-fuel fired stoves in the PM10 non-compliant Municipalities

This measure is will apply to all municipalities that are not in compliance with Directive 2008/50/EC PM10 limit values. Each municipality has its own unique circumstances, but a universal two-phase approach with identified tasks in each is set out in the NAQIP. A well-organized preparatory phase, involving inter-related communication and planning tasks, will be beneficial for the succeeding implementation phase. The government and the municipalities have distinct but related roles in implementing the policy package, which are summarized in Figure 22 and the following text:

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Figure 22 Roles of Municipalities and Central Government in implementing the compulsory phase-out aspects of the residential heating PaM package

=

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7 Identify the imple mentation finance

needed

0/8 Identify financial sources & mobilises the needed resources

6 Plan for the removal and disposal of phased-out appliances

5 Determine zone priorities for appliance phase-out.

4 Determine the support needed by the economically vulnerable.

3 Determine cost-effective substitute

heating options

Effective project management

Bring forward Eco-Design Regulation EU 2015/1185

Adoptimplementing

Regulation

Adoptimplementing Regulation

Clarify CAAA to permit the establishment of LEZs

RIEWS

RIEWS

Municipality

Implement the phase out

-

0/9 Revise the AQP

1. Public consultation in affected Municipality

-

2. Determine the scope and scale of the LEZ and

intervention needed

PREPATORY PHASE

IMPLEMENTATION PHASE

CENTRAL GOVERNMENT

MONITOR

APPROVAL



Additional to bringing forward the implementation of the Eco-Design Regulation for stoves, the central Government amended the Clean Ambient Air Act (CAAA) in order to provide the municipalities with an unambiguous authority to establish a Low Emission Zone(s) (LEZ) in the area for which it has administrative responsibility. LEZs have been implemented in a number of other European countries to address the problem of emissions from solid fuels used in the residential heating sector. Lessons may be distilled from this experience, and they are summarised in the NAQIP.

Essential tasks for which municipalities will be responsible in the preparatory phase are presented in Figure 8, tasks running in order from ‘0’ to ‘9’. The sequence is not proposed as a rigid structure. Some tasks such as public consultation will need to be ongoing, for instance, whilst others will be iterative. We expect that the World Bank team may provide some initial capacity building support for this process in 2019.

The NAQIP provides further detail for the preparatory tasks shown in Figure 22 and summarized below.:

‘Task 0’ – initiate two iterative activities that will need to be pursued throughout this phase: (i) revision of the municipality’s Air Quality Programme, and (ii) identifying supplementary financing sources

Task 1 – Conduct public consultation on the measure and its implementation. Public consultation will need to be held at intervals throughout the preparatory phase, and into the implementation phase. It should provide advanced notice on why the phase-out programme is needed, emphasizing the health benefits, and introduce the impending actions, with full information on what is to happen and why. Raising awareness of the benefits that will flow from the proposed measures – including those that promote the partial drying of firewood – and giving people an opportunity to express their voice/s as to how the measure should be implemented. Consideration will be given to holding some form of consultation at the beginning and closure of each task identified in Figure 22. We expect that the phase-out measure will be unpopular with the public. Hence, why, when and how the measure will be introduced; the benefits it will bring; the alternative heating arrangements on offer; and the support mechanisms that will be put in place, needs to be explained and discussed. Public consultation will be the responsibility of the affected municipality. But Central Government, with the initial assistance of a World Bank team of experts, may provide some guidance.

Task 2 – Identify the number and locations of households having solid-fuel fired appliances that are subject to this measure. Preparing this inventory is essential to help assess the scope and scale of the intervention that will be necessary in any given municipality. In municipalities having relatively small populations, where the urban density is relatively low also, a field survey might be an appropriate technique to use. For larger, more intensely urbanized municipalities, a semi-automated mapping technique might be more appropriate. The LEZ and its boundaries may be based on the initial findings.

Task 3 – Determine the cost-effective alternative heating option/s that may be offered to affected householders in each municipality. The cost-benefit analysis summarized in Section 2.6.3 provides general guidance on the ranking of alternative heating options. But viable and cost-effective heating arrangements may vary from municipality to municipality, depending on the existence of centralized gas networks and district heating schemes and the extent of their coverage. Specific cost estimates will need to be prepared by or for each municipality, taking local conditions and costs into account.

Task 4 – Determine the financial support to be provided to the economically vulnerable. The costs of providing social support (through the Winter Support Programme (WSP) or an extension of it) to poor households will need to be determined for and by each municipality. As it is responsible for the WSP scheme, the Ministry of Labour and Social Policy will need to be involved in the assessment – or at least informed as a consultee.

Task 5 – Determine the geographical zones to be prioritized for appliance phase-out. This issue might be felt most acutely by the physically larger and more populous municipalities. Deciding the phase-out schedule in detail will require priorities to be set. Prioritizing according to the population density of solid-fuel appliances is one option – utilizing mapping techniques such as illustrated in the NAQIP. But

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considerations such as the layout of a central gas network or district heating system might favour alternative priorities. Responsibility for making this strategic decision will lie with the municipality in consultation with local stakeholders.

Task 6 – Determine what is to be done with the solid-fuel appliances removed from households. Appliances to be phased-out should be removed from households by the municipality, or agents acting on its behalf, in order to avoid their entering the informal market. The removed appliances should be recycled for their material content or, if that is not possible, disposed of safely as waste.

Task 7 – Determine the fiscal costs of implementing the phase-out measure. The fiscal costs of the intervention, including the costs of providing social support (through the WSP or an extension of it), will need to be determined in each municipality. They will be the sum of all costs identified through Tasks 2-4 and 6. The schedule of fiscal costs incurred through the implementation phase will be influenced by the zoning priorities established in Task 5.

Task 8 – Mobilize the necessary funding support from sources identified earlier in the preparatory phase. As noted above, work to secure funding support should be regarded as an ongoing activity and not left to the end. The municipality will need to determine not only the level of finance needed in the implementation phase, but also the external sources of finance to be tapped, supplementing its own resources. Municipalities will need to apply for and put into place the selected financing mechanisms for which they are eligible.

Task 9 – Finalize the Ambient Air Quality Programme and secure RIEW approval. Prior to implementing its AQP, each affected municipality should have revised its Air Quality Programme and had it approved by the responsible RIEW and Municipal Council.

The implementation phase will require effective project management and supervision. Again, this is a municipal responsibility. Implementation should be monitored by the RIEW. Public consultation will need to continue at intervals to consider progress made, the next steps in the implementation period, and the experiences of the public and municipality of the programme’s roll-out.

3.2.2. ROAD TRANSPORT SECTOR

Modernising the composition of the vehicle fleet through imposing restrictions on the import of used vehicles, as proposed in PaM RT1, constitutes a restriction on that the free movement of goods on the internal market. This PaM would need the approval of the EC to proceed.

Were the EC to not approve the proposed controls on import of used vehicles, the Government would have to seek to identify and implement alternative PaMs – almost certainly in the road transport sector – having at least equal projected impacts on nitrogen oxides emissions.

The efficiency and applicability of the measure related to imposing restrictions on the import of used vehicles may be analysed in the updated NAPCP which would demonstrate whether the respective measure is feasible and efficient, and whether alternative measures are undertaken to achieve a similar impact on nitrogen oxides emissions.

Regarding PaM RT2, within the NAQIP, lessons learned from experience elsewhere in Europe on the implementation of LEZs for reducing the entry of older vehicles into city centres will be applied. As stated above, regarding residential heating, Central Government proposes to amend the Clean Ambient Air Act (CAAA) in order to provide municipalities with unambiguous authority to establish a Low Emission Zone(s) (LEZ) in the area for which it has administrative responsibility.

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3.2.3. IN ORDER TO ACHIEVE REDUCTION IN EMISSIONS OF HARMFUL SUBSTANCES FROM VEHICLES , THE NATIONAL LEGISLATION REGULATING THE QUALITY AND THE EFFICIENT CONTROL ON THE TECHNICAL INSPECTION PREFORMED ON VEHICLES PRIOR TO THEIR REGISTRATION IN THE COUNTRY, AS WELL AS DURING THE PERIODIC CHECKS OF THEIR TECHNICAL STATUS WHEN EMISSIONS ARE ALSO INSPECTED, WOULD NEED TO BE IMPROVED AND UPDATED . AGRICULTURAL SECTOR

The agricultural sector is diverse, dispersed and inherently conservative. Getting farmers to change their practices will take time and persistence. Once the Good Agricultural Practice Rules are adopted, the BAFS affiliated to MAFF will need to implement an outreach programme, with periodic surveys to evaluate uptake, as identified in PaMs A1 and A2.

Uptake may be slow initially, hence persistence will be needed. However, the 2030 ammonia reduction commitment for Bulgaria is modest, and there is good reason to believe that persistence allied to an imaginative outreach programme will enable the 2030 emission reduction commitment for ammonia to be met.

3.3. CROSS-SECTORAL ISSUES

3.3.1. UPGRADING THE NATIONAL INVENTORY OF EMISSION S

The methodologies used to prepare the National Inventory of Emissions need to be upgraded. A World Bank team of experts has helped us to identify the key areas requiring attention and will help specify the additional data that have to be collected in future. Specific institutional issues that have inhibited improvements being introduced in the past have been identified. Though how these issues may be resolved has not been decided at the time of writing.

3.3.2. REVISING THE EMISSION PROJECTIONS AND UPDATING THE NATIONAL A IR POLLUTION CONTROL PROGRAMME IN FUTURE – 2021 AND BEYOND

We recognise that there is a need to strengthen inter-ministerial collaboration for overseeing the preparation of emission projections and updating the National Air Pollution Control Programme in future. Existing arrangements will be strengthened and goals will be set to foster effective working of an inter-Ministerial group.

Development of the MoEW’s capacity to prepare emission projections will be assisted in 2019 by experts from the World Bank.

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4. CONCLUSIONS

Adopting the best available information available, the National Air Pollution Control Programme demonstrates that Bulgaria can meet all its emission reduction commitments for 2020 and 2030. However, achieving this goal will depend on five conditions being met.

Condition 1: That the suite of existing policies and legal measures continues to be applied in the sectors considered in the programme. Relevant existing PaMs include making incremental improvements in material and energy efficiency in industry, residential and other buildings, and transport. They also include applying BAT in industrial and energy transformation installations to prevent or reduce pollutant emissions in a cost-effective manner; and continuing to apply the Nitrates Directive to reduce ammonia emissions from fertilizer use in agriculture.

Condition 2: That the procedures and methodologies employed to produce the National Inventory of Emissions of Harmful Substances in the Ambient Air are upgraded in order to capture real improvements in emissions reduction performance. Preparation of the draft National Air Pollution Control Programme has been based on the Inventory submitted to the EC in February 2018, for which 2016 was the last year of emissions data.

Many sector-pollutant combinations in the historical emissions inventory have been estimated using Tier 1 methodologies which, as they assume a constant emission factor over time, have failed to capture the beneficial impacts of existing PaMs. This factor diminishes the value of the National Inventory of Emissions as a policy tool.

Significant sector-pollutant combinations where this has been an issue, and where compensating adjustments have been made in the emissions projection methodologies, include: agriculture (ammonia emissions from manure management and nitrogen fertilizer application); chemical processes (nitrogen oxides emissions from nitric acid production, sulphur oxide emissions from the production of sulphuric acid and, potentially, other chemical products); solvent use (NMVOC emissions from solvent containing products used by householders and others); residential heating (PM emissions from heating appliances using solid fuels).

Methodologies for preparing the historical inventory of emissions need to be upgraded, therefore, in order to be compatible with present and future emission projections, and to provide a more reliable means of tracking historical emissions. Institutional barriers regarding information exchange also impede the reporting of emissions in the inventory with sufficient resolution, causing knock-on effects for making emission projections. The emissions from the chemical products manufacturing sector provide an instance of this issue.

Condition 3: That the additional PaMs proposed for the residential heating, road transport and agricultural sectors are implemented as scheduled. The National Air Quality Improvement Programme (NAQIP) forms an integral component of this National Air Pollution Control Programme. Hence the residential heating sector PaM package and road transport Low Emissions Zone PaM have already been reviewed extensively by stakeholders in Bulgaria. Unquestionably, implementation challenges lie in the residential heating and road transport sectors. Both involve measures that would affect the free movement of goods on the internal market to varying extents, requiring European Commission’s approval. Were these approvals not secured, the impacts of the residential heating package would be delivered more slowly, and alternative road transport PaMs would have to be developed.

The residential heating PaM package contains elements that will be unpopular and challenge traditional practices. Effective communication as to why the package is proposed will be essential and the sources of finance will have to be secured and agreed. The cost-benefit analysis undertaken for the residential heating sector demonstrates that the policy package will be beneficial, adding value to society, and indicate a clear overall ranking of the components – though their interrelation needs to be appreciated.

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Condition 4: That, when adopted, the impacts of Bulgaria’s Strategy for Sustainable Energy Development are neutral or benign on Bulgaria’s emissions of air pollutants under Directive (EU) 2016/2284. If the impacts are adverse it will be necessary to identify, assess and implement further additional PaMs.

Submission to the European Commission of revised emission projections and an updated National Air Pollution Control Programme is scheduled for 2021 and 2023, respectively, providing time for any impacts from the Strategy for Sustainable Energy Development to be accommodated.

Condition 5: That efficient inter-Ministerial working is put in place to ensure that the programme is implemented, monitored and amended where appropriate in an effective manner. And that appropriate institutional capacity in the areas of emissions inventory preparation and emissions projections is developed in order to facilitate the best practice preparation and submission of (i) a national inventory of emissions each year (ii) emissions projections every two years, and (iii) a revised and updated National Air Pollution Control Programme every four years.

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ANNEXES

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ANNEX I – POLICIES AND RESPONSIBILITIES

I.1. AMBIENT A IR QUALITY L IMIT AND TARGET VALUES FOR OTHER A IR POLLUTANTS COVERED BY D IRECTIVE 2008/50/EC AND D IRECTIVE 2004/107/EC

Directive 2008/50/EC and the supporting Directive 2004/107/EC cited in Section 2.3 have been transposed by Bulgaria in:

- Environmental Protection Act - Clean Ambient Air Act - Regulation No 14 of 23.09.1997 on limit values of permissible concentrations of harmful substances in

the air in towns and cities - Regulation No 7 of 3.05.1999 on atmospheric air assessment and management - Regulation No 11 of 14.05.2007 on the Norms for Arsenic, Cadmium, Mercury, Nickel and Polycyclic

Aromatic Hydrocarbons in the Ambient Air - Regulation No 12 of 15.07.2010 on norms for sulphur dioxide, nitrogen dioxide, fine particulate

matter, lead, benzene, carbon monoxide and ozone in the ambient air

Section 2.3.1. of the Programme sets out the applicable limit and target values for the specific air pollutants that the Programme addresses. Applicable limit and target values for other air pollutants are given below.

Limit values for benzene:

The limit value is 5 µg/m3, for an averaging period of one calendar year and a margin of tolerance that was set to reach zero % by 1 January 2010. The limit value was to be met by 1 January 2010.

Limit values for carbon monoxide:

The limit value is 10 mg/m3 for an averaging period of maximum daily eight hour with a margin of tolerance of 60 %. The limit value was to be met by 1 January 2005.

Limit values for lead:

The limit value is 0.5 µg/m3 for an averaging period of one calendar year, with a margin of tolerance of 100 %, to be met by 1 January 2005. Limit value to be met only by 1 January 2010 in the immediate vicinity of the specific industrial sources situated on sites contaminated by decades of industrial activities. In such cases, the limit value until 1 January 2010 will be 1.0 µg/m3. The area in which higher limit values apply must not extend further than 1 000 m from such specific sources.

Target value for arsenic:

The target value is 6 ng/m3. The target value is for the total content in the PM10 fraction averaged over a calendar year. Bulgaria is under an obligation to take all necessary measures not entailing disproportionate costs to ensure that, as from 31 December 2012, this target value is not exceeded.

Target value for cadmium:

The target value is 5 ng/m3. The target value is for the total content in the PM 10 fraction averaged over a calendar year. Bulgaria is under an obligation to take all necessary measures not entailing disproportionate costs to ensure that, as from 31 December 2012, this target value is not exceeded.

Target value for nickel:

The target value is 20 ng/m3 The target value is for the total content in the PM10 fraction averaged over a calendar year. Bulgaria is under an obligation to take all necessary measures not entailing disproportionate

costs to ensure that, as from 31 December 2012, this target value is not exceeded.

Target value for benzo(a)pyrene:

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The target value is 1 ng/m3. The target value is for the total content in the PM10 fraction averaged over a calendar year. Bulgaria is under an obligation to take all necessary measures not entailing disproportionate costs to ensure that, as from 31 December 2012, this target value is not exceeded.

I.2. EU REGULATIONS AND TRANSPOSED EU DIRECTIVES: EXISTING POLICIES AND MEASURES

Table I.1 summarizes the policy instruments in Bulgaria that have a direct impact on specific sectoral emissions, whilst Table I.2 summarizes those that have an indirect, co-beneficial impact.

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Table I.1. EU Regulations and Transposed EU Directives having a direct impact on sectoral emissions

Adopted EU policy instrument Sectors affected Measures summary Bulgarian transposing/ implementation policy acts

Directive 2001/81/EC of the European Parliament and of the Council of 23 October 2001 on national emission ceilings for certain atmospheric pollutants.

Revised by Directive 2016/2284 see below

All The aim of the NEC Directive was to limit the emission of acidifying and eutrophying pollutants, and ozone precursors. By the year 2010 at the latest, Member States shall limit their annual national emissions of the pollutants Sulphur dioxide (SO2), nitrogen oxides (NOx), volatile organic compounds (NMVOC) and ammonia (NH3) to amounts not greater than the emission ceilings laid down in Annex I therein. Member States required to ensure that the emission ceilings laid down in Annex I are not exceeded in any year after 2010.

Environmental Protection Act

Clean Ambient Air Act

Climate Change Mitigation Act

Regulation No 6 on methods and procedures for the measurement of harmful substance emissions from stationary sources

Regulation on the quality requirements for liquid fuels, the conditions, the terms and the manner of their control

Regulation on emission limit values for sulphur dioxide, nitrogen oxides and dust released from large combustion plants

Regulation No 16 of 12.08.1999 on the reduction of VOC emissions from storage, loading or unloading and transportation of petrol

Regulation No 7 of 21 October 2003 on emission limit values for volatile organic compounds released into the environment mainly in ambient air as a result of the use of solvents in certain installations

Regulation on the limitation of emissions of volatile organic compounds by the use of organic solvents in certain paints, varnishes and auto-reprocessing products

Regulation No 1 of 27.06.2005 on limit values for admissible emissions of harmful substances (pollutants) emitted in the atmosphere by facilities and activities with stationary sources of emissions

Regulation No 4 of 5 April 2013 on the conditions and requirements for the construction and operation of incineration plants and co-incineration plants.

Regulation No 12 of 15.07.2010 on norms for sulphur dioxide, nitrogen dioxide, fine particulate matter, lead,

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benzene, carbon monoxide and ozone in the ambient air

Regulation on the procedure and method of organizing the national inventories of the emissions of harmful substances and greenhouse gases in the atmosphere

Directive (EU) 2016/2284 of the European Parliament and of the Council of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive 2003/35/EC and repealing Directive 2001/81/EC.

All The Directive revises the national emission ceiling regime established by Directive 2001/81/EC to align it with the international commitments of the EU and the Member States. To that effect, the national emission reduction commitments for any year from 2020 to 2029 in the revised NECD are identical to those set in the revised Gothenburg Protocol (the revised NECD, recital 7).

The Directive sets revised targets for reductions in national emissions from all emission sources, of sulphur dioxide, nitrogen oxides, NMVOC and ammonia beyond the targets set in the original NEC Directive (2001/81/EC). Directive (EU) 2016/2284 also includes a ceiling for PM2.5, in addition to ceilings for the four pollutants included in Directive 2001/81/EC. The targets set in the revised NEC Directive are to be achieved by 2030.




Regulation on reducing national emissions of certain ambient air pollutants

Regulation No 6 on methods and procedures for the measurement of harmful substance emissions from stationary sources






Regulation No 1 of 27.06.2005 on limit values for admissible emissions of harmful substances (pollutants) emitted in the atmosphere by facilities and activities with stationary sources of emissions

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Regulation No 12 of 15.07.2010 on norms for sulphur dioxide, nitrogen dioxide, fine particulate matter, lead, benzene, carbon monoxide and ozone in the ambient air

Regulation on the procedure and method of organizing the national inventories of the emissions of harmful substances and greenhouse gases in the atmosphere

Directive 94/63/EC of 20 December 1994 (Stage I Directive) on the control of volatile organic compound (VOC) emissions resulting from the storage of petrol and its distribution from terminals to service stations, as amended by Regulations (EC) 1882/2003 and (EC) 1137/2008

Fuel storage and distribution – energy industries (NMVOC)

The Directive aims to reduce emissions from volatile organic compounds due to evaporation of petrol in the fuel storage and distribution chain. The Directive applies to the operations, installations, vehicles and vessels used for storage, loading and transport of petrol from one terminal to another or from a terminal to a service station. The Directive lays down harmonized technical specifications for the design and use of:- storage installations at terminals;- equipment for loading and unloading mobile containers at

terminals;- mobile containers;- equipment for loading into storage installations at service

stations.



Regulation No H-32 of 16.12.2011 on the periodic technical condition tests for road vehicles

Directive 98/70/EC of 13 October 1998 relating to the quality of petrol and diesel fuels

Road transport This Directive sets, in respect of road vehicles, and non-road mobile machinery (including inland waterway vessels when not at sea), agricultural and forestry tractors, and recreational craft when not at sea: technical specifications on health and environmental grounds for fuels to be used with positive ignition and compression-ignition engines, taking account of the technical requirements of those engines; a target for the reduction of life cycle greenhouse gas emissions. Member States shall require suppliers to reduce as gradually as possible life cycle greenhouse gas emissions per unit of energy from fuel and energy supplied by up to 10 % by 31 December 2020, compared with the fuel quality



Regulation on the conditions, order and manner of preparation and verification of the reports of the fuel and energy suppliers for transport

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baseline requirements.

Directive 2004/42/EC of 21 April 2004 on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain paints and varnishes and vehicle refinishing products and amending Directive 1999/13/EC

Industrial processes placing controls on use of solvents in surface coatings

The purpose of this Directive is to limit the total content of VOCs in certain paints, varnishes, and vehicle refinishing products, to prevent or reduce air pollution resulting from the contribution of VOCs to the formation of tropospheric ozone. To achieve this objective, the Directive approximates the technical specifications for certain paints and varnishes and vehicle refinishing products.




Regulation (EC) 715/2007 of 20 June 2007 on type approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information

Road transport This Regulation establishes common technical requirements for the type approval of motor vehicles (vehicles) and replacement parts, such as replacement pollution control devices, with regard to their emissions. In addition, this Regulation lays down rules for in-service conformity, durability of pollution control devices, on-board diagnostic (OBD) systems, measurement of fuel consumption and accessibility of vehicle repair and maintenance information. This Regulation shall apply to vehicles of categories M1, M2, N1 and N2 as defined in Annex II to Directive 70/156/EEC with a reference mass not exceeding 2 610 kg. Euro V and Euro VI emission Limits for nitrogen oxides emissions and particulate matter mass are stipulated in Annex I to this Regulation.

Road Traffic Act

Directive 2007/46/EC of 5 September 2007 establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles, as amended by (numerous) Commission Regulations.As of 31.08.2020 it will be repealed and substituted by Regulation 858/2018.

Road transport This Directive establishes a harmonized framework containing the administrative provisions and general technical requirements for approval of all new vehicles within its scope and of the systems, components and separate technical units intended for those vehicles, with a view to facilitating their registration, sale and entry into service within the Community. Specific technical requirements concerning the construction and functioning of vehicles shall be laid down in application of this Directive in regulatory acts.

Road Traffic Act

Regulation No 60 of 2009 on approval of the type of new motor vehicles and their trailers.

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Commission Regulation (EC) 692/2008 of 18 July 2008 implementing and amending Regulation (EC) 715/2007, as amended by Commission Regulations (EU) 566/2011, (EU) 459/2012, (EU) 630/2012, (EU) 143/2013, (EU) 171/2013, (EU) 195/2013, (EU) 519/2013, (EU) 136/2014, (EU) 2015/45, (EU) 2016/427 and (EU) 2016/646.

Regulation (EC) No 692/2008 should be repealed with effect from 1 January 2022 and only Regulation (EC) No 2017/1151 will remain valid.

Road transport This Regulation lays down measures for the implementation of certain provisions of Regulation (EC) No 715/2007: Articles 4 (manufacturers’ type approval obligations), 5 (type approval requirements and tests) and 8 (implementation measures with regard to access to vehicle repair and maintenance information).

Road Traffic Act

Regulation No 60 of 24.04.2009 for approval of the type of new motor vehicles and their trailers

Regulation (EC) 595/2009 of 18 June 2009 on type-approval of motor vehicles and engines with respect to emissions from heavy duty vehicles (Euro VI) and on access to vehicle repair and maintenance information and amending Regulation (EC) 715/2007, Directive 2007/46/EC, and repealing certain directives

Road transport This Regulation establishes common technical requirements for the type-approval of motor vehicles, engines and replacement parts with regard to their emissions. This Regulation also lays down rules for in-service conformity of vehicles and engines, durability of pollution control devices, OBD systems, measurement of fuel consumption and carbon dioxide emissions and accessibility of vehicle OBD and vehicle repair and maintenance information.

This Regulation shall apply to motor vehicles of categories M1, M2, N1 and N2 as defined in Annex II of Directive 2007/46/EC with a reference mass exceeding 2 610 kg and to all motor vehicles of categories M3 and N3, as defined in Annex II of Directive 2007/46/EC. Euro VI Emission Limits for nitrogen oxides emissions and particulate matter mass are stipulated in Annex I to this Regulation.

Road Traffic Act

Regulation No 60 of 24.04.2009 for approval of the type of new motor vehicles and their trailers

Directive 2009/126/EC of 21 October 2009 on Stage II petrol vapour recovery during refuelling of motor vehicles at service station

Road transport This Directive lays down measures aimed at reducing the amount of petrol vapour emitted to the atmosphere during the refuelling of motor vehicles at service stations.



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Directive 2009/125/EC (Eco-design Directive) of 21 October 2009 establishing a framework for the setting of Eco-design requirements for energy-related products (recast), as amended by Directive 2012/27/EU

Residential Heating Sector

This Directive establishes a framework for the setting of Community Eco-design requirements for energy-related products with the aim of ensuring the free movement of such products within the internal market. It provides for the setting of requirements which the energy-related products covered by implementing measures must fulfil in order to be placed on the market and/or put into service. It contributes to sustainable development by increasing energy efficiency and the level of protection of the environment, while at the same time increasing the security of the energy supply.

Technical Requirements Towards Products Act

Regulation on the additional measures related to the implementation of regulations adopted pursuant to Art. 15 of Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of Eco-design requirements for energy-related products

Directive 2010/75/EU of 24 November 2010 on Industrial Emissions

This far-reaching Directive recasts 7 other Directives:

- IPPC Directive (2008/1/EC),

- Large Combustion Plants Directive (2001/80/EC),

- Waste Incineration Directive (2000/76/EC),

- Solvents Emissions Directive (1999/13/EC)

- Three Directives on Titanium Dioxide: (78/76/EEC), (82/883/EEC) & (92/112/EEC)

Stationary combustion ≥ 50MWth

Electricity & heat generation – public, and Industry

Industrial production processes (specified)

Agriculture (intensive livestock operations)

Waste

Fugitive emissions

Product use (solvents)

Achieve limiting emission concentrations of nitrogen oxides, sulphur dioxide and particulate matter and defined minimum sulphur dioxide removal rates.

Use best available techniques (BAT)

Use BAT to comply with the indicative emissions limits associated with BAT




Regulation on the conditions and procedure for issuance of integrated permits


Regulation No 3 of 22.05.2013 on requirements for installations producing titanium dioxide


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Commission Regulation (EU) 582/2011 of 25 May 2011 on emissions from Heavy Duty Vehicles (Euro VI) implementing and amending Regulation (EC) 595/2009, as amended by Commission Regulations (EU) 64/2012, (EU) 519/2013, (EU) (EU) 133/2014, (EU) 136/2014, (EU) 627/2014 and (EU) 2016/1718

Road transport This Regulation lays down measures for the implementation of certain provisions of Regulation (EC) No 595/2009: Art. 4 (obligations of the manufacturers); article 5 (requirements and tests); article 6 (access to information); article 12 (Redefinition of specifications). It also amends Regulation (EC) No 595/2009 and Directive 2007/46/EC (Framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles.)

Road Traffic Act

Regulation (EU) 168/2013 of 15 January 2013 on the approval and market surveillance of two or three-wheel vehicles and quadricycles (framework regulation for type approval of motorcycles), as amended by Commission Delegated Regulation (EU) 134/2014

Road transport This Regulation establishes the administrative and technical requirements for the type-approval of all new two- or three-wheel vehicles and quadricycles, as well as systems, components and separate technical units for them as categorized in Article 4 and Annex I (‘L-category vehicles’), that are intended to travel on public roads, including those designed and constructed in one or more stages, and to systems, components and separate technical units, as well as parts and equipment, designed and constructed for such vehicles. This Regulation also applies to enduro motorcycles (L3e-AxE (x = 1, 2 or 3)), trial motorcycles (L3e-AxT (x = 1, 2 or 3)) and heavy all terrain quads (L7e-B) as categorized in Article 4 and Annex I therein. Euro IV and Euro V emission Limits for nitrogen oxides emissions and particulate matter mass are stipulated in Annex VI to this Regulation.

Road Traffic Act

Regulation No 117/10.01.2005 for approval of new motor vehicles category L

Regulation (EU) 167/2013 of 5 February 2013 on the approval and market surveillance of agricultural and forestry vehicles, as amended by Commission Delegated Regulations (EU) 1322/2014, (EU) 2016/1788 and (EU) 2016/1628.

Agriculture and Forestry This Regulation establishes the administrative and technical requirements for the type-approval of new agricultural and forestry vehicles, systems, components and separate technical units such as tractors (categories T and C); trailers (category R); interchangeable towed equipment (category S).

Agricultural and Forestry Machines and Equipment Registration and Control Act

Regulation No 7/28.12.2017 on type approval of agricultural and forestry vehicles and their system, components and parts

Commission Regulation (EU) 813/2013 of

Emissions from heaters This Regulation establishes Eco-design requirements for the placing on the market and/or putting into service of space heaters

Regulation on the additional measures related to the implementation of regulations adopted pursuant to Art.

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2 August 2013 implementing Directive 2009/125/EC regarding ecodesign requirements for space heaters and combination heaters

and combination heaters with a rated heat output ≤ 400 kW, including those integrated in packages of space heater, temperature control and solar device or packages of combination heater, temperature control and solar device. Requirements for emissions of nitrogen oxides for different types of heater are stipulated in Annex II, s. 4 therein.

15 of Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products

Directive 2013/53/EU of 20 November 2013 on recreational craft and personal watercraft and repealing Directive 94/25/EC

Water transport This Directive lays down requirements for the design and manufacture of recreational craft and partly completed recreational craft; personal watercraft and partly completed personal watercraft; components listed in Annex II when placed on the Union market separately, hereinafter referred to as ‘components’; propulsion engines which are installed or specifically intended for installation on or in watercraft; propulsion engines installed on or in watercraft that are subject to a major engine modification; and watercraft subject to major craft conversion. Annex II, s. 2 stipulates exhaust emission requirements for nitrogen oxides.

Technical Requirements Towards Products Act

Regulation for the essential requirements and compliance assessment of recreational craft and personal watercraft

Commission Delegated Regulation (EU) 134/2014 of 16 December 2013 on L-category vehicles supplementing Regulation (EU) 168/2013, as amended by Commission Delegated Regulation (EU) 2016/1824 on vehicle functional safety requirements, to vehicle construction and general requirements, and to environmental and propulsion unit performance requirements

Road transport This Regulation establishes the detailed technical requirements and test procedures regarding environmental and propulsion unit performance for the approval of L-category vehicles and the systems, components and separate technical units intended for such vehicles in accordance with Regulation (EU) No 168/2013 and sets out a list of UNECE regulations and amendments thereto. Different test type requirements are stipulated in the annexes of the Regulation.

Road Traffic Act

Regulation No 117/10.01.2005 for approval of new motor vehicles category L

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Commission Delegated Regulation (EU) 2015/96 of 1 October 2014 supplementing Regulation (EU) 167/2013, as amended by Delegated Commission Regulation (EU) 2016/1788 on agricultural and forestry vehicles

Agriculture and Forestry This Regulation establishes the detailed technical requirements and test procedures regarding environmental and propulsion unit performance with respect to pollutant emissions and permissible external sound levels, and the approval and market surveillance of agricultural and forestry vehicles, their engines and their systems, components and separate technical units in accordance with Regulation (EU) No 167/2013.

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Commission Regulation (EU) 2015/1185 of 24 April 2015 implementing Directive 2009/125/EC regarding Eco-design requirements for solid fuel local space heaters

Residential heating and other sectors where space heating is required

This Regulation establishes Eco-design requirements for the placing on the market and putting into service of solid fuel local space heaters with a nominal heat output of 50 kW or less. Requirements for emissions of particular matter and nitrogen oxides for different types of solid fuel boiler are stipulated in Annex II, s. 2 therein.

Regulation on the additional measures related to the implementation of regulations adopted pursuant to Article 15 of Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products

Commission Regulation (EU) 2015/1188 of 28 April 2015 implementing Directive 2009/125/EC regarding Eco-design requirements for local space heaters


This Regulation establishes Eco-design requirements for the placing on the market and putting into service of domestic local space heaters with a nominal heat output of 50 kW or less and commercial local space heaters with a nominal heat output of the product or of a single segment of 120 kW or less. Requirements for emissions of nitrogen oxides for different types of local space heathers are stipulated in Annex II, s. 2 therein.

Regulation on the additional measures related to the implementation of regulations adopted pursuant to Article 15 of Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products

Commission Regulation (EU) 2015/1189 of 28 April 2015 implementing Directive 2009/125/EC regarding Eco-design requirements for solid fuel boilers


This Regulation establishes Eco-design requirements for placing on the market and putting into service solid fuel boilers with a rated heat output of 500 kW or less, including those integrated in packages of a solid fuel boiler, supplementary heaters, temperature controls and solar devices. Requirements for emissions of particular matter and nitrogen oxides for different types of solid fuel boiler are stipulated in Annex II, s. 1 therein

Regulation on the additional measures related to the implementation of regulations adopted pursuant to Article 15 of Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of Eco-design requirements for energy-related products

Directive (EU) 2015/2193 of 25 November 2015 on the limitation of emissions of certain pollutants into the air from medium combustion plants

Stationary combustion ≥ 1 < 50MWth

Industry (fuel combustion)

This Directive lays down rules to control emissions of Sulphur dioxide (SO2), nitrogen oxides (NOx) and dust into the air from medium combustion plants (thermal input l ≥ 1 MW and < 50 MW). This Directive also lays down rules to monitor emissions of carbon monoxide (CO).

Implementation is to take place between 2024 and 2029


Regulation on the limitation of emissions of certain pollutants into the air from medium combustion plants

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Directive (EU) 2016/802 of 11 May 2016 relating to a reduction in the sulphur content of certain liquid fuels

Road transport

Waterways

Manufacturing & Process Industry (fuel combustion)

The purpose of this Directive is to reduce the emissions of Sulphur dioxide resulting from the combustion of certain types of liquid fuels and thereby to reduce the harmful effects of such emissions on man and the environment. Reductions in emissions of Sulphur dioxide resulting from the combustion of certain petroleum-derived liquid fuels shall be achieved by imposing limits on the Sulphur content of such fuels as a condition for their use within Member States' territory, territorial seas and exclusive economic zones or pollution control zones.



Regulation (EU) 2016/1628 of 14 September 2016 on requirements relating to gaseous and particulate pollutant emission limits and type-approval for internal combustion engines for non-road mobile machinery, amending Regulations (EU) 1024/2012 and (EU) 167/2013, and amending and repealing Directive 97/68/EC

Non-road transport

Agriculture

Forestry

This Regulation establishes for certain categories of NRMM engines emission limits for gaseous and particulate pollutants as well as the administrative and technical requirements relating to EU type-approval. This Regulation also lays down certain obligations in relation to non-road mobile machinery in which such engine is being, or has been, installed, as regards the emission limits for gaseous and particulate pollutants from such engines. Exhaust emission limits for nitrogen oxides and particulate matter mass are stipulated in annexes to the Regulation

Agricultural and Forestry Equipment Registration and Control Act

Commission Delegated Regulation (EU) 2017/654 of 19 December 2016 supplementing Regulation (EU) 2016/1628 of the European Parliament and of the Council with regard to technical and general requirements relating to emission limits and type-approval for internal combustion engines for non-road mobile machinery

Non-Road mobile machinery

Agriculture

Forestry

This Regulation sets various requirements and procedures with regard to technical and general requirements relating to emission limits and type-approval for internal combustion engines for non-road mobile machinery within the scope of Regulation (EU) 2016/1628.

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Commission Delegated Regulation (EU) 2017/655 of 19 December 2016 supplementing Regulation (EU) 2016/1628 of the


Agriculture

This Regulation establishes detailed arrangements with regard to the selection of engines, test procedures and reporting of results relating to monitoring of gaseous pollutant emissions from in-service internal combustion engines installed in non-road mobile

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European Parliament and of the Council with regard to monitoring of gaseous pollutant emissions from in-service internal combustion engines installed in non-road mobile machinery (Text with EEA relevance.)

Forestry machinery using portable emission measurement systems. This Regulation applies to monitoring of the gaseous pollutant emissions from the following categories of in-service engines of emission Stage V installed in non-road mobile machinery: NRE-v-5; NRE-v-6.

Commission Implementing Regulation (EU) 2017/656 of 19 December 2016 laying down the administrative requirements relating to emission limits and type-approval of internal combustion engines for non-road mobile machinery in accordance with Regulation (EU) 2016/1628 of the European Parliament and of the Council.


Agriculture

Forestry

This Regulations sets administrative requirements relating to emission limits and type-approval of internal combustion engines for non-road mobile machinery in accordance with Regulation (EU) 2016/1628, such as requirements for templates, reports and data structure

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Commission Regulation (EU) 2017/1151 of 1 June 2017 supplementing Regulation (EC) No 715/2007 of the European Parliament and of the Council on type-approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information, amending Directive 2007/46/EC of the European Parliament and of the Council, Commission Regulation (EC) No 692/2008 and Commission Regulation (EU) No 1230/2012 and

Road transport This Regulation lays down measures for the implementation of Regulation (EC) No 715/200 on type-approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information.

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repealing Commission Regulation (EC) No 692/2008.

Directive 2010/31/EU of The European Parliament and of The Council of 19 May 2010 on the energy performance of buildings


Construction

Member States shall ensure that by 31 December 2020, all new buildings are nearly zero-energy buildings and that after 31 December 2018, new buildings occupied and owned by public authorities are nearly zero-energy buildings.

Member states shall adopt long-term renovation strategy describing measures to support the renovation of the national stock of residential and non-residential buildings, both public and private, into a highly energy efficient and decarbonized building stock by 2050, facilitating the cost-effective transformation of existing buildings into nearly zero-energy buildings.

Energy Efficiency Act

Regulation on requirements for labelling and providing standard information on product related to energy consumption in relation to the consumption of energy and other resources.

The Directive explains that a ‘nearly zero-energy building’ means a building that has a very high energy performance, as determined in accordance with Annex I. The nearly zero or very low amount of energy required should be covered to a very significant extent by energy from renewable sources, including energy from renewable sources produced on-site or nearby.

Regulation No E-RD-04-1 of 22.01.2016 on Energy Efficiency Audit, Certification and Assessment of Energy Saving of Buildings

Regulation No Е-RD-04-2 of 22.01.2016 on the energy consumption indicators and energy characteristics of buildings

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Table I.2. EU Regulations and Transposed EU Directives having an Indirect Impact on Sectoral Emissions

Adopted EU policy instrument Sectors affected Measures summary Bulgarian transposing policy instrument

Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC

All sectors with the potential to release Greenhouse gases

This Directive regulates the operation of EU ETS. The EU ETS is currently in its third phase (2013-2020) where two major pillars are established: GHG emission from aviation and GHG emission from stationary installations. The rules for phase 4 (2021-2030) are already adopted in Directive (EU) 2018/410 of the European Parliament and of the Council of 14 March 2018 amending Directive 2003/87/EC to enhance cost-effective emission reductions and low-carbon investments, and Decision (EU) 2015/1814. This Directive is designed to contribute to reducing the overall greenhouse gas emissions of the Union by at least 40 % below 1990 levels by 2030. In principle, Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with Directive (EU) 2018/410 by 9 October 2019.


Directive 2009/28/EC of The European Parliament and of The Council of 23 April 2009 on the promotion of the use of energy from renewable sources

Road transport The Directive sets binding RES targets as follows:

- Each Member State shall ensure that the share of energy from renewable sources, calculated in accordance with Articles 5 to 11, in gross final consumption of energy in 2020 is at least its national overall target for the share of energy from renewable sources in that year, as set out in the third column of the table in part A of Annex I. Such mandatory national overall targets are consistent with a target of at least a 20 % share of energy from renewable sources in the Community’s gross final consumption of energy in 2020. In order to achieve the targets laid down in this Article more easily, each Member State shall promote and encourage energy efficiency and energy saving.

- Each Member State shall ensure that the share of energy from renewable sources in all forms of transport in 2020 is at least 10 % of the final consumption of energy in transport in that Member State.

- National overall target of Bulgaria for the share of energy from renewable sources in gross final consumption of energy in 2020 is set in Annex I to Directive 2009/28/EC.

Energy from Renewable Sources Act

Regulation No RD-16-869 of 2.08.2011 for the calculation of the total share of energy from renewable sources in the gross final energy consumption and the consumption of biofuels and renewable energy in transport

Regulation No RD-16-1117 of 14.10.2011 on the conditions and procedure for issuing, transferring, revoking and recognizing guarantees of origin of energy from renewable sources

Regulation on sustainability criteria for biofuels and liquids fuels from biomass

Regulation No RD-16-558 of 8.05.2012 on the collection and provision of information through the National Information System on the potential, production and consumption of energy from renewable sources in the Republic of Bulgaria

Decision No 406/2009/EC of the All sectors with the Reduction of GHG emissions not covered by EU ETS are regulated by Climate Change Mitigation Act

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European Parliament and of the Council of 23 April 2009 on the effort of Member States to reduce their greenhouse gas emissions to meet the Community’s greenhouse gas emission reduction commitments up to 2020

potential to release Greenhouse gases

the Effort Sharing Decision (ESD). In accordance with the ESD, each Member State shall, by 2020, limit its greenhouse gas emissions at least by the percentage set for that Member State in Annex II to this Decision in relation to its emissions in 2005. The limit set for Bulgaria is up to 20 % increase of GHG emission limits in 2020 compared to 2005 greenhouse gas emissions.

Directive 2010/31/EU of The European Parliament and of The Council of 19 May 2010 on the energy performance of buildings

Residential Heating

Construction

Member States shall ensure that by 31 December 2020, all new buildings are nearly zero-energy buildings and that after 31 December 2018, new buildings occupied and owned by public authorities are nearly zero-energy buildings.

Member states shall adopt long-term renovation strategy describing measures to support the renovation of the national stock of residential and non-residential buildings, both public and private, into a highly energy efficient and decarbonized building stock by 2050, facilitating the cost-effective transformation of existing buildings into nearly zero-energy buildings.


Regulation on requirements for labelling and providing standard information on product related to energy consumption in relation to the consumption of energy and other resources.


Regulation No E-RD-04-2 of 22.01.2016 on the energy consumption indicators and energy characteristics of buildings

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Directive 2012/27/EU of European Parliament and of The Council of 25 October 2012 on energy efficiency

All sectors using energy

The binding EU energy efficiency target is 20 % by 2020 relative to projections. Individual energy efficiency targets are set by the Members States in accordance with Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC.


Energy Act

Regulation on the methodologies for the determination of the national energy efficiency target and the determination of the common cumulative target, the introduction of an energy savings obligation scheme and the allocation of individual energy saving targets among the obligated persons


Regulation No E-RD-04-2 of 22.01.2016 on the energy consumption indicators and energy characteristics of buildings

Regulation No E-RD-04-05 of 8.09.2016 for the determination of energy consumption indicators, the energy characteristics of enterprises, industrial systems and systems for external artificial lighting, and determining the terms and procedure for carrying out the audit for energy efficiency and energy savings assessment.

Regulation No Е-RD-04-3 of 4.05.2016 on the eligible measures for realization of energy savings in final consumption, the ways of proving the achieved energy savings, the requirements for the methodologies for their evaluation and the ways of their confirmation

Regulation (EU) 2018/842 of the European Parliament and of the Council of 30 May 2018 on binding annual greenhouse gas emission reductions by EU MS from 2021 to 2030, contributing to climate action to meet commitments under the Paris Agreement, and amending Regulation (EU) No 525/2013.

All Bulgaria’s greenhouse gas emission reductions in 2030 in relation to the 2005 levels shall be at least zero % i.e. less than or no greater than the base year (applicable to the greenhouse gas emissions from IPCC source categories of energy, industrial processes and product use, agriculture and waste as determined pursuant to Regulation (EU) No 525/2013, excluding greenhouse gas emissions from the activities listed in Annex I to Directive 2003/87/EC.).

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I.3. POLICY PRIORITIES IN THE WASTE AND WASTE MANAGEMENT SECTOR

Strategic Goal 1 (2020): observe EU legislation (including Directive 2008/98/EC, Directive 1999/31/EC) and meet relevant national targets:- No later than 1 January 2020 there shall be preparation for re-use and recycling of waste materials,

including paper and cardboard, metal, plastic and glass from households and similar waste from other sources of at least 50 % of the total weight of such waste.

- The systems for treatment of construction and demolition waste shall ensure no later than 1 January 2020 its preparation for re-use, recycling and other recovery of materials from non-hazardous construction and demolition waste, including in backfilling operations using waste to substitute other materials, in quantities not less than 70 % of the total weight of waste, excluding naturally occurring material defined in category 17 05 04 in the list of waste pursuant to Decision 2000/532/EC.

- No later than 31 December 2020 the quantity of deposited biodegradable household waste shall be limited to 35 % of the total quantity of such waste generated in the Republic of Bulgaria in 1995. This provision transposes the obligations of Bulgaria under Directive 1999/31/EC of 26 April 1999 on the landfill of waste.

- Fulfilment of the established schedule for the termination of existing landfills for non-hazardous waste that do not satisfy the requirements of Directive 1999/31/EC.

General goal 2 (2030): Strategic Goal 2 (2030): observe EU legislation and participate and contribute to the fulfilment of EU policy commitments and initiatives such as the Circular Economy package:

- At least 55 % municipal waste to be recycled by 2025, at least 60 % by 2030, and at least 65 % by 2035 - At least 50 % of the plastic packaging waste to be recycled by 2025 - Hazardous household waste to be collected separately by 2022, bio-waste by 2023, and textiles by 2025 - By 2035 the amount of municipal waste that is landfilled must be reduced to 10 % or less of the total

amount of municipal waste generated.

Specific National Goals and Priorities are set in the National Waste Management Plan (2014-2020): - Achieving a resource -efficient and sustainable waste management - Improvement of waste prevention and waste management - Better use of resources - Prevention and reduction of the harmful effects of waste on the environment - Development of new markets and new jobs - Support of the central and local authorities in relation to the focusing of limited financial resources from

national and EU sources on priority projects in the field of waste management

Specific National Goals and Priorities are set in National Strategic Plan for Gradual Reduction of Biodegradable Waste (2010-2020): - Gradual reduction of the amount of deposited biodegradable waste in accordance with

Directive 1999/31/EC - Improvement of the overall management of biodegradable waste - Reduction of the amount of greenhouse gases generated and released from landfills - Reduction of the harmful effects of landfills on the environment

Specific National Goals and Priorities for the construction and demolition sector, to ensure the sustainable development of the Republic of Bulgaria, are set in the National Strategic Plan for Construction and Demolition Waste Management (2011-2020): - An integrated framework for the management of construction waste - Reducing the negative environmental impact caused by the generation of construction waste - Increasing resource efficiency

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- Increasing the liability of polluters - Stimulating investment into waste management

Specific National Goals and Priorities are set in the National Strategic Plan for Sludge Management from Urban Wastewater Treatment Plants on the Territory of Bulgaria (2014-2020): - Unification of national and international legislation and environmental standards; - Protecting public health and the environment through better sludge management; - Clean water resources; - Restoration of land and soil functions; - Reduce the use of natural resources; - Sustainable development; - Improvement of technological standards for sludge management; - Drastically reducing the amount of landfill sludge; - Increase the amount of recycled and re-used sludge at reasonable prices; - Enhancing technical and managerial capacity by developing regional strategies and concepts for sludge

management

I.4. SUMMARY OF THE ATTRIBUTED RESPONSIBILITIES IN THE A IR QUALITY ASSESSMENT AND MANAGEMENT ZONES

Table I.3 elaborates the responsibilities attributed to the authorities identified in Table 3 of Section 2.3.2.

Table I.3. Authorities and attributed responsibilities in the air quality assessment and management zones

Authority Attributed Responsibilities Relevant to this Programme

National AuthoritiesNational Assembly Policy making role:

- Adoption of all primary legislation (statutes) in Bulgaria (including Environmental Protection Act and Clean Ambient Air Act).

Council of Ministers

Council of Ministers(continuation)

Policy making role:- Adoption of secondary legislation, including legislation determining the

technical and qualitative requirements for liquid fuels, the limit values for content of lead, sulphur and other harmful substances (pollutants), as well as the conditions, the procedure and the method of control over liquid fuels and legislation for implementation of ecodesign requirements;

- Determination of emission limit values for harmful substances – pollutants (sulphur dioxide, nitrogen oxides and dust), released in the atmosphere by large combustion plants (LCPs) and determination of the rules to control the emissions of sulphur dioxide, nitrogen oxides and dust into the air from medium combustion plants (MCPs), as well as the rules to monitor the emissions of carbon monoxide into the air from MCPs, via the issuing of an Regulation;

- Adoption of regulations on restricting the emissions of VOCs from the use of organic solvents in certain paints, lacquers and car refinishing products with the aim of preventing and minimizing ambient air pollution;

- Approval of the National Programme for Ambient Air Quality Improvement;- Approval of the National Air Pollution Control Programme;- Approval of the Transitional National Plan (TNP) for phasing out of LCPs and

submission of the Plan to the European Commission;- Approval of the programmes for gradual abatement of the total annual

emissions of certain harmful substances (pollutants): sulphur dioxide, nitrogen oxides and others emitted to the ambient air from certain operating sites and

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Authority Attributed Responsibilities Relevant to this Programmeactivities, such as large combustion plants.

Ministry of Environment and Water

Policy making role:- Adoption of regulations approving limit values for harmful substances

(pollutants) in the ambient air and limit values for deposits of harmful substances (pollutants) – jointly with the Ministry of Health;

- Adoption of regulations approving alert thresholds for the levels of harmful substances (pollutants) in the ambient air – jointly with the Ministry of Health;

- Adoption of secondary legislation in environmental sector;- Drafting of legislation and providing support in getting legislation passed in the

National Assembly or the Council of Ministers;- Drafting of strategic documents in the environmental sector;- Adoption of a Programme of measures for the limitation and prevention of

pollution caused by nitrates from agricultural sources in the vulnerable areas, jointly with the Ministry of Agriculture, Food and Forestry.

Implementation and Enforcement role:- Implementation of the EU Clean Air Policy Package;- Implementation of the governmental policy on environmental protection

(including preservation of the AAQ);- Certification and sanctioning of violations of CAAA;- Management of the Operational Programme ‘Environment’, which funds a range

of measures related to the implementation of municipal AQPs;- Approval of the plans for RIEWs’ control activities;- Control of fire safety within protected areas that are in the exclusive ownership

of the state;- Implementation of measures for protection of water quality by preventing

nitrates from agricultural sources polluting ground and surface waters;- Issuing of guidance on the implementation of Regulation No 7 of 21.10.2003 on

emission limit values of volatile organic compounds released in to the environment, mainly in the ambient air as a result of the use of solvents in certain installations.

Monitoring role:- Drafting a monitoring programme for assessment of the level of compliance with

the requirements of Regulation limiting emissions of volatile organic compounds from the use of organic solvents in certain paints, varnishes and vehicle refinishing products, jointly with ExEA;

- Monitoring of the implementation of Regulation limiting emissions of volatile organic compounds from the use of organic solvents in certain paints, varnishes and vehicle refinishing products, jointly with the respective RIEW;

- Collection of information on the implementation of Regulation No 16 of 12.08.1999 on the reduction of VOC emissions from storage, loading or unloading and transportation of petrol by RIEWs and MTITC;

- Monitoring and reporting on the implementation of Regulation No 7 of 21.10.2003 on emission limit values of volatile organic compounds released into the environment mainly into the ambient air as a result of the use of solvents in certain installations.

Ministry of Economy Supporting role in policy-making:- Adoption and/or drafting of secondary legislation (Eco-design).Implementation role:- Participation in the implementation of the policy to promote energy efficiency

and the use of renewable energy sources (RES).

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Authority Attributed Responsibilities Relevant to this ProgrammeCoordinating role:- Interaction with ministries, state agencies and non-governmental organizations

in relation to the development of a low carbon and resource-efficient economy, protection of the environment and limiting climate change according to its functional competence.

Ministry of Regional Development and Public Works

Policy making role:- Drafting technical legislation and national requirements in the area of survey,

design, implementation, maintenance and demolition of constructions, and their harmonisation with the EU legislation in order to create the necessary conditions for safe, energy-efficient and accessible constructions with sustainable natural resources use.

Implementation role:- Implementation of urban development and housing policies, including energy

efficiency in the residential sector;- Implementation of road infrastructure development jointly with MTITC;- Management of the National Programme for Energy Efficiency in multifamily

residential buildings;- Management of the Operational Programme ‘Regions in Growth’, which funds

a range of activities having a positive impact on AQ including new public transport vehicles, and the insulation of buildings (both public and private).

Ministry of Energy Policy making role:- Adoption and/or drafting of secondary legislation (Energy Efficiency, RES);- Drafting of national strategic documents (Energy, Energy Efficiency, RES);- Transposition of EU law in the energy sector.Implementation role:- Implementation of the State policy in the energy sector including the

diversification of energy sources, and the EU Energy Package;- Implementation of the State policy in relation to renewable energy and energy

efficiency;- Encourage the use of energy from RES.

Ministry of Labour and Social Policy

Policy making role:- Adoption of secondary legislation on winter fuel supplement programme.Implementation role:- Implement the winter fuel supplement programme (social benefits for heating)

that provides support to economically vulnerable members of society.Ministry of Transport, Information Technology and Communications

Policy making role:- Adoption and/or drafting of secondary legislation (Transport);- Drafting of strategic documents (Transport).- Implementation of the State policies in the transport sector, whereas road

infrastructure development aspects are carried out jointly with MRDPW.Ministry of Health Policy making role:

- Issuing regulations approving limit values for harmful substances (pollutants) in ambient air and limit values for deposits of harmful substances (pollutants), jointly with MoEW;

- Issuing regulations approving alert thresholds for the levels of harmful substances (pollutants) in the ambient air, jointly with MoEW.


Policy making role:- Adoption and/or drafting of secondary legislation (Agriculture and Forestry);- Drafting of strategic documents (Agriculture and Forestry);- Adoption of guidelines for application of the statutory management

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Authority Attributed Responsibilities Relevant to this Programmerequirements;

- Adoption of national standards for good agricultural and environmental condition of the land;

- Adoption of rules and recommendations on the use of nitrogenous fertilizers and manure as contained in the Good Agricultural Practice Rules for prevention of water pollution caused by nitrates from agricultural sources and in the Programme for the limitation and prevention of pollution caused by nitrates from agricultural sources in the vulnerable areas, adopted jointly with MoEW.

Implementation role:- Implementation of the State policy in the field of agriculture and forestry;- Supervision over farming and breeding activities;- Control over activities such as manure spreading that cause emissions of

ammonia, which is strongly associated with the secondary formation of FPM10;- Implementation of NRMM Directive, including overseeing the approval and

market surveillance of agricultural and forestry vehicles;- Management of the Rural Development Programme, which funds a range of

activities that may have a positive impact on AQ;- Protection of water quality by preventing nitrates from agricultural sources

(relating to the use of manure and nitrogenous fertilizers) polluting ground and surface waters.

Enforcement role:- Enforcement of the ban on field-burning of harvest and other plant residues.

Ministry of Interior Policy making role:- Adoption of fire safety rules applicable to agricultural lands, forests and

protected areas.Implementation and enforcement role:- Implementation and enforcement of fire safety rules applicable to agricultural

lands, forests and protected areas.State Agency for Technical & Metrological Surveillance

Implementation and Enforcement role:- Supervision of product compliance with technical requirements, including the

requirement of the eco-design Directive;- Control over the quality of liquid fuels.Reporting and monitoring role:- Development and maintenance of a liquid fuel quality monitoring, control and

information system.Executive Environment Agency (ExEA)

Implementation role:- Support on implementation of state policies in the field of environmental

protection;- Issuing of integrated environmental permits, in line with the requirements of

the Industrial Emissions Directive (IED, 2010/75/EU). Reporting and monitoring role:- Preparation of the National Inventory of Emissions (NIE) and annual reporting;- Management of the National system for monitoring of the environment;- Air quality monitoring to meet the requirements of the CAFE Directive (air

quality monitoring network comprising 48 stations);- Preparation of the monitoring programme, annually, in consultation with RIEWs

and MoEW;- Stack-gas monitoring at industrial sites;- Maintenance of the National Register of Activities using Organic Solvents (IED);

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Authority Attributed Responsibilities Relevant to this Programme- Development of the National Register of Medium Combustion Plants in line with

Directive (EU) 2015/2193.National Statistical Institute (NSI)

Reporting role:- Provision of statistical data to the ExEA, which uses the data to prepare the NIE;- Provision of annual information on the types and quantities of liquid fuels placed

on the market to the SAMTS;- Storage of data from the national census of population.

Executive Forest Agency (ExFA)

Implementation role:- Supervision of the compliance with the Forestry Act;- Supervision and methodological guidance to the operation of bodies and

entities assigned functions under the Act – including State Enterprises that are responsible for organizing the wood-sourcing process in State forests.

Enforcement role:- Enforcement of the ban on burning of stubble and plant residues.

Executive Agency ‘Automobile Administration’ (ExAAA)

Implementation role:- Licensing and supervision of different transport activities (public transport of

passengers and cargo);- Supervision of technical fitness of vehicles via authorization and supervision of

inspection stations that test vehicles at first registration and that conduct periodic technical inspections of road vehicles, including the inspection of exhaust emissions.

Sustainable Energy Development Agency

Implementation role:- Support on implementation of State policies in the field of energy efficiency and

RES.Reporting and monitoring role:- Data collection and report drafting on fulfilling energy efficiency and RES

targets.National Institute of Meteorology and Hydrology (NIMH)

Reporting and monitoring role:- Oversight of the preparation of an AQP at municipal level through membership

of the Programme Council (though, in practice to date, its role has been confined to providing meteorological data);

- Operation of a network of 36 meteorological stations;- Access to a “super computer”, for modelling purposes, which provides NIMH

with the potential capacity to run a range of sophisticated air quality models.

Regional AuthoritiesRegional Health Inspectorates (RHIs) under the MoH,(Total 16 in number)

Implementation role:- Support on implementation of State policies in the field of environmental

protection;- Oversight of the municipality’s preparation of its AQP (as a member of the

Programme Council);- Review of draft AQP prior to Municipal Council approval;- Implementation of fire safety measures in protected areas that are in the

exclusive ownership of the State.- Issuing administrative acts/coordination statements for investment proposals,

plans and programmes under Chapter VI of the Environment Protection Act. Issuing coordination statements for complex permits for the use of installations and facilities under the regulations of Chapter VII of the Environment Protection Act.

Enforcement role:

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Authority Attributed Responsibilities Relevant to this Programme- Control and management of the activities related to ensuring clean ambient air

in the respective territory;- Enforcement of environmental legislation concerning industrial emission

sources;- Immediate control over the condition and the operation of sites with sources

of emissions to the ambient air, on the operation of the treatment plants and on the emissions from individual sources;

- Immediate control over the state and the exploitation of sites with sources of emissions in the ambient air, the functioning of treatment facilities and the emissions from the individual sources as per the territorial jurisdiction of the respective RIEW under Article 19 of the CAAA.

- Establishment and sanctioning of violations of CAAA.Reporting and monitoring role:- Oversight (monitoring) of the municipality’s implementation of its AQP,

including whether the envisioned emission values are reached within the specified timeframe;

- Informing the municipality of non-compliances with CAFE limiting values (based on AQ monitoring) and providing instructions to it on how to prepare an air quality programme (AQP);

- Annual updating of lists of atmospheric emissions sites subject to mandatory emission control.

Regional Health Inspectorates (RHIs) under the MoH,(Total 28 in number)

Implementation and methodological role:- When requested by municipalities, RHIs provide methodological assistance to

the municipal administration in preparing its air quality programme (as part of the Programme Council).

- Upon receiving notification from the competent authorities about a registered exceedance of certain alarm limit values, to provide recommendations to the population and to the medical specialists for prevention of the harmful impact of pollutants on the human body and limiting the health risk;

- Based on air quality monitoring data, to draft recommend measures to be undertaken by municipal authorities.

Local AuthoritiesMunicipalities(Municipal bodies)

Policy making role:- Adoption of secondary legislation – local (municipal) ordinances;- Adoption of municipal strategies;- Development and adoption of programmes for abating the levels of pollutants

in the ambient air and for reaching the established limit values (where the total mass of the emissions leads to exceeding the limit values for harmful substances in the ambient air and of the limit values for emissions);

- Development and adoption of an operational action plan determining the measures which are to be undertaken where there is a risk of exceeding the established limit values or alert thresholds;

- Establishing Low Emission Zones (LEZs).Implementation and enforcement role:

- Control and management of the activities related to ensuring clean ambient air in the territory of the municipality;

- Implementation and enforcement of LEZs;- Organization and regulation of automobile traffic in the towns and villages

with a view to ensuring the ambient air quality is maintained (in co-ordination with the authorities of the Ministry of the Interior);

- Immediate control over the condition and the operation of sites with sources

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Authority Attributed Responsibilities Relevant to this Programmeof emissions to the ambient air, on the operation of the treatment plants and on the emissions from individual sources on the territory of the municipality as per Article 24(1) in relation to Article 19(3) of the CAAA.;

- Undertaking other actions to ensure ambient air cleanliness on the territory of the municipality as per Article 29 of the CAAA.

Reporting and monitoring role:- Establishment of local systems for monitoring and control of ambient air

quality in the territories of the Regions (in co-ordination with the Ministry of Environment and Water).

Mayors of the MunicipalitiesMunicipal Councils

Implementation and enforcement role:- Implementation of municipal ambient air quality (AAQ) programmes and

performing other actions to ensure ambient air cleanliness on the territory of the municipality as per Articles, 27, 28a and 30 of the CAAA.

- Issuing opinions under approval procedures for investment proposals, plans and programmes under Chapter VI of the Environment Protection Act. Issuing coordination statements for complex permits for the use of installations and facilities under the regulations of Chapter VII of the Environment Protection Act.

Local traffic police units under the MoI

Implementation and enforcement role:- Registration of motor vehicles;- Supervision and implementation of the legal provisions for type-approval of

motor vehicles;- Introduction of traffic regulations in municipalities with poor air quality (with

the agreement of the municipality);- Immediate control over motor vehicles as sources of emissions (jointly with

MoTITC).

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ANNEX II – HISTORICAL EMISSIONS BY MAJOR SECTORS

ANNEX II

II.1. N ITROGEN OXIDES

Public electricity and heat generation: Nitrogen oxides emissions from electricity generation have decreased substantially in the latter part of the time series. Emission reductions are primarily through the implementation of measures to meet stricter emission limit values at plants of ≥ 50MW capacity. These measures are related to plant modernization, the replacement of old boilers and burners, and the introduction of abatement equipment such as selective non-catalytic reduction (SNCR). We expect that Bulgaria’s Strategy for Sustainable Energy Development will detail any major changes to the fuel mix used for electricity and heat production, and the role that nuclear and renewables are expected to play in future years. The strategy will also outline the national capacity for electricity generation and determine whether Bulgaria continues to be a significant net exporter of electricity. Any resultant changes will be incorporated in the revised emissions projections and National Air Pollution Control Programme due to be submitted to the European Commission in 2021 and 2023, respectively.

Road transport Emissions from road transport make a major contribution to Bulgaria’s total nitrogen oxides emission. The NIE indicates that nitrogen oxides emissions have declined by 20-25 % between 2005 and 2016, though emissions have plateaued over recent years. New car sales are of the most up to date Euro standards, and are hence much lower emitters. However, the expense of a new car is out of the reach of many Bulgarians, and a large fraction of the cars introduced to Bulgaria each year have been imported as second-hand vehicles, and this continues to the case. Many imported cars are old, from pre-Euro to those built to meet Euro 3 emissions standards. Therefore, the progress made towards the use of cleaner cars (Euro 4 and above) through vehicle fleet turnover has been much slower than in many other European countries. In addition, the benefit of using more modern vehicles has been offset by the substantial growth in car ownership. Since 2005 the number of vehicles in Bulgaria has increased by 24 % (with passenger cars accounting for approximately 80 % of all registered vehicles). Bulgaria’s Inventory Information Report 2018 reported an increase of about 60 % in annual mileage for passenger cars in 2016, compared to 2005. Emissions from road transport have been calculated in detail using the COPERT model.

Nitric Acid Production The historical emissions inventory reports that nitric acid production makes a substantial contribution to the national total of nitrogen oxides emissions. However, the methodology that has been used to estimate emissions has not taken into account any emissions reductions that have arisen from improved production processes or the introduction/existing use of abatement equipment. Hence, it is considered that the reported historical emissions have been substantially over-estimated: alternative estimates have been used as a basis for the emission projections (see Annex IV).

II.2. NON-METHANE VOLATILE ORGANIC COMPOUND (NMVOC)

Residential heating The extensive use of wood for heating in the residential sector means that this source has been a significant contributor to the NMVOC emissions total. Reported emissions from this sector have increased since 2005.

Road transport Fleet turnover in Bulgaria has been slower than in other Member States due to the importation of older, second-hand cars. In addition, there has been a substantial growth in the number of cars. As a result, NMVOC emissions have shown only a steady decrease since 2005.

Industrial processes and Fugitive Emissions The largest source of fugitive NMVOC emissions are coal mining, and oil refining and distribution. Activity levels for these sources has increased across the time series. The largest NMVOC source within industrial processes is food and drink manufacture. A Tier 1 method has been

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used to estimate emissions, hence the emissions reductions that may have occurred haven’t been captured in the calculation.

Solvent Use Emissions from industrial processes and solvent use also have been estimated using a Tier 1 methodology. This approach is limited in the extent to which it can represent the historical trend in emissions, and, in particular, the impact of nationally specific policies and measures. For example, emissions from domestic solvent use have been based on population. Hence no account has been taken of the impact of the VOC Solvents Emissions Directive (1999/13/EC), nor of Directive 2004/42/EC, both of which are known to have delivered substantial NMVOC emissions reductions in other Member States.

II.3. SULPHUR OXIDE

Public electricity and heat generation: Sulphur dioxide emissions are dominated by the public electricity and heat generation sector. Lignite is used extensively for electricity and heat generation. The combustion of lignite results in relatively high emissions compared to other fuels, but it is used extensively because it is a local resource. Since 2005, sulphur oxide emissions have fallen substantially, by 95 %, primarily through the implementation of measures to meet stricter emission limit values at plants of ≥ 50MW capacity. These measures are related to plant modernization, the replacement of old boilers and burners, and the introduction of flue gas desulphurization (FGD). In addition, whilst the consumption of lignite has steadily increased across the time series, since 2007 the growth slowed and there were some years where lignite consumption decreased. The combined effect is a substantial emissions reduction in the latter part of the time series.

Chemical processes (sulphuric acid production): The historical emissions inventory reports that process emissions from the production of chemicals (specifically, sulphuric acid) make a substantial contribution to the national total of sulphur oxide emissions. As aggregate emissions from Large Combustion Plants have declined, the contribution – as a percentage of the national total – made by reported emissions from chemical production have increased, reaching 25.5 % in 2016. However, the methodology used to estimate the emissions from the sources in this sector has not taken into account any emissions reductions that have arisen from improved production processes or the introduction/existing use of abatement equipment. Hence, it is considered that the reported historical emissions have been substantially over-estimated: different estimates have been used as a basis for estimating projections (see Annex IV).

II.4. AMMONIA

Agriculture – Livestock (Manure management): Manure management emissions have been calculated using a Tier 1 methodology, which is almost exclusively driven by changes in the number of livestock. Reported emissions have decreased since 2005. However, this method is not detailed enough to capture the impact of many policies and measures already put in place to reduce emissions: it is expected to over-estimate emissions.

Agriculture soils (fertilizer application): Emissions have substantially increased since 2005, reflecting the growth in inorganic fertilizer application (the availability of organic fertilizer falling with decreasing livestock numbers). However, a Tier 1 method has been used for estimating emissions from the application of fertilizer. Hence, there are similar issues concerning the inability to represent the impact of changes in farming practices in recent years, changes driven substantially by EU-wide legislation such as the Nitrates Directive (91/676/EEC), and the publication of the CLRTAP “Framework Advisory Code of Good Agricultural Practice for Reducing Ammonia Emissions”.

II.5. PM2. 5

Residential Heating and Other Combustion The dominance of fine particulate matter emissions from the residential combustion of wood is not commonly observed in other EU Member States: hence, existing EU-wide policies and measures are not particularly targeted at reducing fine particulate matter emissions from this sector. Reported emissions in recent years suggest there may have been some reductions, perhaps resulting

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from an increase in use of gas, electricity and district heating. However, historical emissions from this sector have been estimated using a Tier 1 methodology. Hence the impacts of the uptake of more modern, cleaner appliances has not been not taken into account in the reported emission estimates.

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ANNEX III – AMBIENT AIR QUALITY MONITORING TRENDS – AT THE LEVELS OF MONITORING STATIONS AND AMBIENT AIR QUALITY

ASSESSMENT AND MANAGEMENT ZONES

II.6. SULPHUR D IOXIDE

Concentrations of sulphur dioxide in Europe in general are well below the EU standards. However, sulphur dioxide limit values in 2016 were still exceeded in Bulgaria. The main source of sulphur dioxide emissions in Bulgaria are the lignite-fired power plants in the Maritsa East complex. The Galabovo air quality station located in the area of the Maritsa East complex has registered non-compliance with sulphur dioxide limit values continually in the period 2005-2016.

Figure III.1. Non-compliance with sulphur dioxide standards

2005; Number of non-com-pliant sta-

tions; 62006;

Number of non-com-pliant sta-

tions; 3


tions; 4 2008; Number of non-com-pliant sta-

tions; 2



tions; 2


tions; 42012;

Number of non-com-pliant sta-

tions; 1


tions; 2


tions; 2


tions; 1


tions; 1

2005; Number of non-com-pliant AQ zones; 5 2006;

Number of non-com-pliant AQ zones; 3

2007; Number of non-com-pliant AQ zones; 2










Non-compliance 1-hour SO2 standard

Number of non-compliant stations Number of non-compliant AQ zones



tions; 4


tions; 3


tions; 4



tions; 2



tions; 1


tions; 2


tions; 1


tions; 1


tions; 2













Non-compliance 24-hour SO2 standard


Source: Source: ExEA State of the Environment Reports 2005-201619

Compliance with both the 1-hour and 24-hour sulphur dioxide standards has improved in the period 2005-2016 as shown in Figure III.1. The main reasons are the improved desulphurization rate at coal-fired power plants and application of integrated pollution prevention and control (IPPC), now subsumed into the Industrial Emissions Directive.

II.7. N ITROGEN D IOXIDE

Compliance with the nitrogen dioxide standards was assessed by comparing the registered concentrations with the current nitrogen dioxide standards, enforced in 2010.

The trend in nitrogen dioxide concentrations is not constant, but is mostly downward. Since 2013 all AQ zones have been compliant with the 1-hour nitrogen dioxide standard. Nevertheless, after a period of three years

19 The sources of data for all the figures in Annex III are the State of Environment Reports for the period 2005-2016, available at: http://eea.government.bg/bg/soer/soer-arhiv

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Number of non-compliant stations


Number of non-compliant AQ zones



http://eea.government.bg/bg/soer/soer-arhiv


(2011-2014) of improved compliance with the annual limit value for nitrogen dioxide, it has been exceeded at three stations in three AQ zones in 2016. In addition, the location of two AQ monitoring stations that were regularly non-compliant with either the hourly or the annual average nitrogen dioxide limit values was changed in the autumn of 2015. These are namely the Sofia Orlov Most AQM (relocated in October 2015) and Plovdiv Banya Starinna AQM (relocated in September 2015).

Figure III.2. Non-compliance with nitrogen dioxide standards


tions; 3



tions; 2


tions; 1


tions; 6


tions; 2


tions; 3


tions; 4


tions; 0


tions; 0


tions; 0


tions; 0













Non-compliance with 1-hour NO2 standard


2005; Number of non-com-

pliant stations; 2


pliant stations; 4


pliant stations; 1


pliant stations; 2


pliant stations; 4


pliant stations; 2


pliant stations; 4


pliant stations; 2 2013; Number

of non-com-pliant stations;

1 2014; Number of non-com-

pliant stations; 0


pliant stations; 3


pliant stations; 3


pliant AQ zones; 1


pliant AQ zones; 22007; Number

of non-com-pliant AQ zones; 1


pliant AQ zones; 1


pliant AQ zones; 2


pliant AQ zones; 2


pliant AQ zones; 2


pliant AQ zones; 22013; Number

of non-com-pliant AQ zones; 12014; Number



pliant AQ zones; 3


pliant AQ zones; 3

Non-compliance with 1-year NO2 standard


Source: EXEA

The main sources of nitrogen dioxide emissions are road transport and industry. Due to implementation of IPPC, nitrogen dioxide emissions from industry have declined. Nevertheless, emissions from road transport continue to be an issue, especially for larger cities. Non-compliance with annual nitrogen dioxide limit values in 2015 and 2016 are registered in the biggest cities in Bulgaria – Sofia, Plovdiv, and Varna, and additionally in Pleven.

II.8. PM10

All AQ zones were non-compliant with PM10 standards in the period 2005-2010. Therefore, PM10 is the pollutant of the greatest concern for Bulgaria. Non-compliance is registered at ambient air quality monitoring stations located in cities. The main source of PM10 emissions is residential heating using solid fuels, wood especially.

Figure III.3 shows there has been some downward trend in the number of non-compliant stations for the 24-hour limit value and especially with the annual average fine particulate matter limit value in the period 2005-2016. The number of non-compliant stations with the 24-hour limit value was at its peak in 2010 (46 non-compliant stations), but has plateaued at around 33-37 non-compliant stations in the period 2013-2016. Moreover, there is a more marked decrease in the number of non-compliant stations with the annual average

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limit value. In 2016, non-compliance with the annual average limit value was registered at 13 stations and in five AQ zones – Varna Agglomeration AQ zone was compliant in 2016.

Figure III.3. Non-compliance with PM10 standard

2005; Number of non-compli-ant stations; 37

2006; Number of non-compli-ant stations; 422007; Number

of non-compli-ant stations; 34




of non-compli-ant stations; 40







pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6

Non-compliance PM10 24-hour standard



pliant stations; 28


pliant stations; 342007; Number


27


pliant stations; 28


pliant stations; 32


pliant stations; 32


pliant stations; 29


pliant stations; 25


pliant stations; 24








pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 6


pliant AQ zones; 5

Non-compliance PM10 1-year standard


Source: EXEA

II.9. PM2. 5

Compliance with the PM2.5 standard was assessed by comparing the registered concentrations with the current PM2.5 limit value, enforced in 2015.

There were 10 air quality monitoring stations that monitored PM2.5 in 2016, compared to 4 in 2005. Three of the air quality monitoring stations that monitored PM2.5 in 2016 were background stations, located outside of cities. Therefore, the territorial coverage of PM2.5 sampling is much smaller than the one of PM10. Figure III.4 indicates there has been a decrease in non-compliance with PM2.5 limit values since 2015, keeping in mind the small number of stations that monitor this pollutant.

The average exposure (AE) limit value for the population for PM 2.5 is the average annual concentration of all urban background stations for three consecutive years, taking the average concentration of 2008, 2009 and 2010 as a reference value. An AE of 20 µg/m3 was supposed to be achieved by all Member States in 2015. The AE in 2016 (the annual average concentrations of 2014, 2015 and 2016) for Bulgaria was 22.9 µg/m3, down from around 34 µg/m3 in the 2010 base year.

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Figure III.4. Non-compliance with PM2.5 standard


pliant stations; 2


pliant stations; 3


pliant stations; 3


pliant stations; 3


pliant stations; 5


pliant stations; 5


pliant stations; 5


pliant stations; 5


pliant stations; 5


pliant stations; 5


pliant stations; 3 2016; Number


2

2005; Number of non-compli-ant AQ zones; 2




2009; Number of non-compli-ant AQ zones; 52010; Number

of non-compli-ant AQ zones; 4




2014; Number of non-compli-ant AQ zones; 42015; Number

of non-compli-ant AQ zones; 32016; Number

of non-compli-ant AQ zones; 2

Non-compliance with PM2.5 standard


Source: EXEA

II.10. POLY AROMATIC HYDROCARBON (PAH)

Compliance with the PAH standard was assessed by comparing the registered concentrations with the current PAH limit value, enforced in 2012. There were 15 ambient air quality stations monitoring PAH in 2016, compared to 17 in 2005. Three out of the 15 stations are background stations, outside of cities. Data concerning the number of stations where non-compliance were registered for the years 2007 and 2009 but are now missing.

Figure III.5. Non-compliance with Poly Aromatic Hydrocarbon (PAH) standard


pliant stations; 0



pliant stations; 6


pliant stations; 6


pliant stations; 9



8


pliant stations; 7















Non-compliance with PAH standard


Source: EXEAData about the number of stations where non-compliance was registered for the period 2007-2009 is missing.

Figure III.5 shows there has been no clear trend in PAH concentrations. The number of stations where exceedances were registered is rather stable across the period 2005-2016. In addition, there is an upward trend in non-compliance in 2015 and 2016. The main source of PAH emissions is residential heating on solid fuels.

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II.11. CARBON MONOXIDE

Since 2012 there have been no registered exceedances of the carbon monoxide limit value in any station in Bulgaria – see Figure III.6. Before 2012, exceedances occurred mainly at stations in Sofia.

Figure III.6. Non-compliance with carbon monoxide standard


pliant stations; 2


pliant stations; 2


pliant stations; 0


pliant stations; 2


pliant stations; 1


pliant stations; 2


pliant stations; 2


pliant stations; 0


pliant stations; 0


pliant stations; 0


pliant stations; 0


pliant stations; 0













Non-compliance carbon monoxide 8-hour standard


Source: EXEA

II.12. OZONE

Compliance with the ozone standard has been assessed by comparing the registered concentrations with the maximum number of permissible exceedances, averaged over three years, of the maximum 8-hour daily value. In 2016, 27 ambient air quality stations monitored ozone.

Figure III.7. Non-compliance with ozone standard

2008-2010; Number of

non-compli-ant stations; 1














non-compli-ant AQ zones;

1



2



4



4 2012-2014; Number of


2



2



3

Non-compliance withozone 3-year average standard


Source: EXEA Non-compliance with the ozone standard has been rather stable. Since the period 2012-2014, non-compliance has been registered only at background stations, outside of cities.

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ANNEX IV – APPROACH TO PROJECTING SECTORAL EMISSIONS IN THE WM SCENARIO AND ADDRESSING UNCERTAINTIES

ANNEX III

III.1. ENERGY AND REFINERIES

Projected fuel use, by fuel type (lignite, coal, natural gas and oil), for public electricity and heat generation, and refineries, was taken from the greenhouse gas emissions projections to ensure consistency. The consumption of biomass was taken from the National Renewable Energy Action Plan.20

The existing National Transitional Plan (NTP) was taken into account by allocating fuel from NTP installations to non-NTP installations after 2020. We expect that these plants will be brought up to comply to the relevant emissions standards rather than be shut down, but the effect on the emissions calculations is the same.

Emissions factors for electricity and heat generating stations were scaled for future years, compared with that in 2016, as follows:

NMVOC, Ammonia & PM2.5: No change for any fuel types Nitrogen Oxides Emission factors of NTP electricity and heat generating plants are assumed to be

reduced by 30 % in 2021. Emission factors of non-NTP electricity and heat generating plants are assumed to remain constant across the time series.

Sulphur Dioxide The efficiency of flue gas desulphurisation installed in coal power stations is assumed to remain unchanged.

Sulphur Dioxide The efficiency of flue gas desulphurisation installed in lignite power stations is assumed to increase linearly from 96 % sulphur removal in 2016 to 97 % efficiency in 2021.

For refineries, fuel consumption data were taken from the GHG emission projections. Emission factors were assumed to remain unchanged.

III.2. INDUSTRIAL COMBUSTION

Projected fuel use in industrial combustion, by fuel type, was taken from the greenhouse gas emissions projections by summing fuel used for iron and steel production, non-ferrous metals, the chemicals industry, paper and pulp, food and drink.

It has been assumed that emission factors for all pollutants are reduced by 1 % per year across the 2016 – 2030 timeline. This has been chosen to represent the continued introduction of industrial best practice and improvements in efficiencies, which will reduce the emission rate in future years.

Combustion emissions from refineries and mobile machinery used in industry were also included in this sector, with the same methodology. This is a small source.

III.3. RESIDENTIAL HEATING AND OTHER COMBUSTION


In making emission projection estimates, our calculations have been undertaken by fuel type and by appliance type. The historical emissions have been estimated using a Tier 1 approach, which does not account for any impacts on emissions arising from changes to the appliance types in use. A more detailed approach is needed for estimating emission projections – one that accounts for changes in the appliances in use. So, a Tier 2 method has been used to estimate emission projections in future years. To avoid any discontinuity in the time series when there is a change in methodology, emissions in future years have been calculated using a Tier 2 approach: emissions in all years have then been rescaled to ensure no discontinuity. This follows best practice, as presented in the EMEP/EEA Emissions21 Inventory Guidebook.

20 National Renewable Energy Action Plan, adopted by Decision per Protocol № 1/09.01.2013 of the Council of Ministers. 21The rescaling factor for the emission projections is determined by estimating 2016 with both Tier 1 and Tier 2 approaches.

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Projected fuel use data for the residential sector, by fuel type, were taken from the greenhouse gas emissions projections, which take into account Bulgaria’s energy efficiency commitments under its climate change and energy policies. We wish to stress the importance of this feature of the WM scenario, given the significant role that energy efficiency can play in reducing the energy demand of residential heating while producing a more comfortable indoor environment and improving the health of vulnerable members of the population.

The following appliance types were included:

Fireplaces

Heating stoves o Conventional stove o Advanced/ecolabel stoves & boilers o Pellet stoves & boilers

Single house boilers o Conventional boiler o Advanced/ecolabel stoves & boilers o Pellet stoves & boilers

Medium boilers o Medium Auto boilers o Medium Manual boilers

The distribution of appliances was compiled by drawing on GAINS data and using expert judgement on both the current distribution and expected turnover. This gave the appliance distribution for 2000, 2005, 2010, 2015, 2020, 2025 and 2030. Intermediate years were populated by interpolation. Intermediate years were populated by interpolation.

Emission factors for each appliance type were assumed to be constant across the time series.

Other Types of Combustion Other sources included in this sector were calculated as follows:

Commercial and institutional stationary combustion installations – fuel was taken from the national GHG emissions projections calculations, and emission factors were assumed to reduce by 1 % per year, to reflect improvements in efficiencies and the use of more modern appliances.

Stationary and mobile combustion installations, which are sources of emissions and are used in agriculture, forestry and fishing– fuel was taken from the national GHG emissions projections calculations. Emissions from these sources are dominated by mobile machinery. Emission factors for these mobile machinery sources were assumed to reduce at the same rate as that observed for passenger cars. The intention being to approximate the introduction of more stringent controls in emissions, but without requiring extensive assumptions to underpin a detailed calculation.

III.4. ROAD TRANSPORT

Road transport fuel use was taken from the greenhouse gas emissions inventory projections to ensure consistency.

The passenger car fleet and HGVs were considered in detail. The composition of the future vehicle fleet needs to be estimated to obtain emission factors (EFs) for future years. The following method was used to generate EFs for future years:

Passenger cars and HGVs were split into Euro classes for each year. This was done by reviewing the fleet turnover from historical years, to provide information on the most likely fleet turnover for future years. Fleet turnover took into account the importation of less modern second-hand vehicles. By

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drawing on historical trends, it was possible to estimate the percentage of the passenger cars and HGVs by Euro standard for each year out to 2030.

The vehicle fleet information for each year was then combined with the EFs (for each Euro class for each pollutant). These were taken from the EMEP/EEA Guidebook.

The result is a weighted EF (for each pollutant, and for each year) that represents the vehicle fleet for any given year.

III.5. OTHER TRANSPORT

Projected Fuel consumption data for aviation and shipping (domestic and international bunkers) have been taken from the GHG emission projections calculations. However, these data are not used as absolute values, they are used to scale the emissions estimates from 2016.

Emission factors for all transport sources were assumed to reduce at the same rate as that observed for passenger cars. The intention being to approximate the introduction of more stringent controls in emissions, but without requiring extensive assumptions to underpin a detailed calculation.

III.6. INDUSTRIAL PROCESSES AND FUGITIVE EMISSIONS

The method that has been used for the historical emission estimates is a Tier1 approach (e.g. sulphuric acid production multiplied by an international default emission factor that is constant across the time series changed). The method has significant limitations in accuracy, and has failed to capture the impact of historical policies and the impacts of abatement measures in recent years. As a result, we consider that historical emissions have been overestimated, particularly in recent years of the inventory.

So, where data and expert opinion were available, a new emission for 2016 was calculated, which differed from that in the historical emissions inventory. Activity data drivers and emission factor drivers were then applied to this revised emission estimate to obtain the projections.

Nitrogen Oxides from Nitric Acid Production

Nitrogen oxides emissions and nitric acid production data were obtained from the two companies manufacturing nitric acid in Bulgaria. From this it was possible to deduce a year-specific emission rate, which was noted to have substantially reduced over time, resulting from improved process yields and the introduction of emission reduction equipment. It is assumed that this change has been brought about through commercial considerations and the permitting process, through which the application of Best Available Techniques (BAT) is required via the IPPC Directive and Directive 2010/75/EU.

Revised nitrogen oxides emissions were calculated for 2005 and 2016. The substantially lower emission figure for 2016 was used as a basis for estimating emissions projections. The revision to 2005 was considered to be negligible, and hence no change was made to the nitrogen oxides emission reduction commitments for 2020 and 2030.

The emission rate and production level were assumed to be constant for all future years.

Sulphur Dioxide from Sulphuric Acid Production

A similar process was used as that outlined above for nitrogen oxides emissions from nitric acid production. This resulted in a revised sulphur oxide emission total for 2016. Importantly, the revisions also impact the sulphur oxide emissions in 2005. Consequently, it has been necessary to calculate revised emission reduction commitments for both 2020 and 2030 (the percentage reductions are unchanged, but the absolute value of emissions in 2020 and 2030 that need to be achieved are revised because the 2005 base year is revised).

Other Industrial Processes

Projected activity data were available for a number of other industrial processes. This allowed activity data drivers to be compiled.

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Historical emissions, activity data and emission factors were obtained for several production processes. From this it was possible to consider the trends in emission factors, and project these into future years to generate emission factor drivers.

The activity data drivers and emission factor drivers (where available) were then applied to the 2016 emission. Where drivers could not be determined, it was assumed that the 2016 emission remains constant for all years out to 2030.

NMVOC from Fugitive Sources

Fugitive emissions of NMVOC primarily arise from: Coal mining and handling Oil refining and storage Distribution of oil products

To estimate emission projections, activity levels for coal mining and handling have been scaled by using future gross electricity consumption, and emissions from oil refining and distribution have been rescaled by projected passenger car fuel use. Emission factors are assumed to reduce by 1 % per year to reflect the increased use of emission controls and BAT.

This relatively simple approach has been necessary because it has not been possible to obtain source data that allows more detailed calculations to be made.

III.7. SOLVENT AND PRODUCT USE

NMVOC emissions in the historical inventory use a simple Tier 1 approach. This does not take into account the emissions reductions that will have occurred in response to Directive 1999/13/EC, Directive 2004/42/EC and related legislation. As a result, the NMVOC emissions in the historical inventory are significantly overestimated.

To calculate emission projections, the 2016 emission estimate has been scaled by population. This is to ensure consistency with the Tier 1 calculation used to estimate the historical emissions.

Emission factors are assumed to decrease by 1 % each year across the whole time series as a representation of lower solvent content in products and improved emissions control and recovery in industry.

This approach has been taken as a relatively simple means of representing the reduced solvent content of products and the increases adoption of best practice in industry to prevent and control NMVOC emissions. In reality, it is expected that substantial emission reductions occurred in earlier years, which have not been represented by the Tier 1 approach in estimating the historical emissions. It has not been possible to obtain information to estimate the NMVOC historical emissions with a Tier 2 approach.

III.8. AGRICULTURE

The trend in total nitrogen excretion by livestock type was determined data on livestock numbers and weight/animal values provided by the Ministry of Agriculture, Food and Forestry (MAFF). Estimates of future inorganic fertiliser applied to soils was also provided by MAFF. Collectively, this represents good estimates of future activity data.

The use of a Tier 1 method for the historical emissions creates a significant limitation on the detail that can be used to estimate future emissions: numerous parameters are expected to change in future years and the effects of these changes cannot easily be accounted for in the current method.

Furthermore, it has not been possible to obtain information to quantify the impacts of agricultural good practice introduced and applied to comply with the EU’s Water Framework Directive (and specifically the Nitrates Directive), Integrated Pollution Prevention and Control (IPPC), and the recently revised National Emissions Ceilings Directive. Hence, it has been necessary to use expert judgement.

Hence, the following has been assumed:

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Pigs and Poultry: The emission rates for manure management of pigs and poultry are assumed to reduce by 5 % each year from 2016 to 2021, where the value remains at 75 % of the 2016 value for all future years. This is an attempt to represent the impact of IPPC on intensive farming of pigs and poultry, and the more general adoption of best practice in agriculture.

Fertiliser: The emission rate for fertiliser application (organic and inorganic) is assumed to reduce by 2 % each year from 2016 to 2026. This is to represent the impact of the Nitrates Directive and implementation of good agricultural practice.

Whilst these impacts have been introduced for projections, i.e. years after 2016, in reality there will have been impacts prior to this which are not accounted for in the historical inventory.

III.9. WASTE

Emissions from waste make a small contribution to national totals, so a simple method has been used.

Future population has been used as an activity data driver, and emission factors are assumed to be constant across all years out to 2030.

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ANNEX V – APPROXIMATE ESTIMATES OF PRIMARY PM 10 EMISSIONS REDUCTION NEEDED TO COMPLY WITH AMBIENT AIR QUALITY CRITERIA

Table V.1 shows the result of applying the empirical prediction formula explained in Section 2.5.2.1. The minimum necessary reduction in primary PM10 emissions needed to achieve compliance with PM10 ambient air quality criteria vary from municipality and municipality, ranging from 9 % to 69 %.

Table V.1. Estimated reduction in primary PM10 emissions needed to achieve full PM10 compliance

Air Quality Zone Municipality22 Population

31.12.2016Average PM10 in 2016

(µg/m3)

ER Needed (%) for Full

ComplianceBG0001 Sofia 1 236 047 37.6 35

BG0002Plovdiv 343 424 47.8 56Asenovgrad 49 250 43.6 49

BG0004

Ruse 144 936 40.5 43Pleven 98 467 52.9 62Shumen 76 967 36.4 31Veliko Tarnovo 68 478 32.1 13Vratsa 53 570 37.7 35Vidin 42 801 61.3 69Montana 39 838 47.2 55Lovech 33 426 31.4 9Gorna Oryahovitza 29 478 41.7 46

BG0005

Pernik 74 110 36.5 32Blagoevgrad 69 567 41.1 44Kardzhali 43 022 37.8 36Smolyan 28 160 42.7 48

BG0006

Burgas 202 766 31.6 10Stara Zagora 136 781 31.8 11Sliven 87 322 34.0 22Haskovo 71 686 40.4 43Pazardzhik 68 963 37.0 33Dimitrovgrad 35 074 45.2 52Nesebar 12 548 32.8 17Galabovo 7 613 37.2 34

It should be noted that reductions in nitrogen oxides, NMVOC, Sulphur dioxide and ammonia emissions will be beneficial also, through reducing the formation of secondary PM2.5 and PM10.

22 Average PM10 concentration in Sofia excludes data from the background monitoring station at Kopitoto. Concentration data for Dimitrovgrad, Pazardzhik, Pleven, and Sliven are for 2015, the latest year where a full monitoring record exists.

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ANNEX VI – EXISTING AND POTENTIAL ADDITIONAL POLICIES AND MEASURES (PAMS) TO MEET THE EMISSION REDUCTION COMMITMENTS AND FURTHER INFORMATION ON AGRICULTURE SECTOR MEASURES TO CONTROL AMMONIA EMISSIONS, CONTROL FINE PARTICULATE MATTER

EMISSIONS, AND PREVENT IMPACTS ON SMALL FARMS

Table VI.1 identifies significant existing PaMs that may contribute further to emissions reduction to 2030 and provide a basis for developing additional potential PaMs. It also identifies potential new and extension PaMs that could contribute to achieving compliance with the unmet emission reduction commitments revealed in the WM scenario projections. These were pre-determined by the forecasts while maintaining only the current PaMs.

Potential additional policies and measures were identified principally through an extensive analysis – supplemented by technical and public consultation – of options for reducing air pollution by particulate matter, focused on reducing primary PM emissions from (i) solid-fuel fired appliances in the residential heating sector and (ii) diesel-powered passenger vehicles in the road transport sector. The National Air Quality Improvement Programme (NAQIP) is an output of that analysis, drawn on by the National Air Pollution Control Programme.

Other potential additional measures have been identified by experts and subjected to review with stakeholders in meetings and workshops.

Table VI.1. Identification of potential additional PaMs and their relation to existing PaMs

Policy Existing Measures and Identified Potential Additional Measures

Stationary Combustion: Public Electricity and Heating, and IndustryIndustrial Emission Directive 2010/75/EU: application to- Large combustion plants, LCPs

≥50 MW – public electricity and heating, industry

Existing Measures- Operation of LCPs under comprehensive permits, updated where

required in line with adopted BAT Conclusions; applying BAT to prevent and control pollutant emissions in order to comply with permit conditions including emission LVs.

Potential Additional Measures Identified- No additional measures identified.

Industrial Emission Directive 2010/75/EU: application to- Public electricity & heating –

LCPs in the Transitional National Plan (TNP)

Existing Measures- Reformation of the LCPs in Bulgaria’s Transitional National Plan to

bring them into compliance with the relevant emission limit values by 2020, or their closure.


Medium Combustion Plants (MCP) Directive (EU) 2015/2193: application to- Various sectors using MCPs,

heating units of 1 to <50 MW capacity

Existing Measures- MCPs to operate under environmental permits issued or

registration.Potential Additional Measures Identified- No additional measures identified.

National Energy Efficiency Action Plan 2014-2020 for- EU energy efficiency targets

for 2020 and, under discussion, for 2030

Existing Measures- Implement measures identified in the National Energy Efficiency

Action Plan 2014-2020;- Measures taken to achieve Bulgaria’s 2020 energy efficiency

targets.Potential Additional Measures Identified- Bulgaria’s pledged contribution to reduce gross final consumption

of energy through its integrated national energy and climate plans (dependent on the provisions of the awaited National Energy

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Strategy).Residential and other Combustion

Eco-Design for Stoves for Residential Heating EU Regulation2015/1185

Existing Measures- Replacement of existing solid-fuel fired stoves with compliant

models at a turnover of 1/20th of current national stock a year, starting Jan 1, 2022

Potential Additional Measures Identified- See NAQIP measures below.

Eco-Design for Boilers for Residential Heating, EU Regulation 2015/1189

Existing Measures- Replacement of existing solid-fuel fired boilers with compliant

models at a turnover of 1/20th of current national stock a year, starting Jan 1, 2020.

Potential Additional Measures Identified- See NAQIP measures below.

National Air Quality Improvement Programme (NAQIP) to achieve compliance with ambient air quality LVs: Residential Heating component

Existing Measures- Eco-Design regulations for stoves and boilers (see above)Potential Additional Measures Identified- Fuel quality requirements for coal (nationally) and, potentially, the

moisture content of firewood (in areas of ambient air quality non-compliance)

- Surrogate measures to reduce the moisture content of the firewood used in municipalities that fail PM10 ambient air quality criteria

- Bring forward by two years, to Jan 1, 2020, the date at which Regulation EU 2015/1185 for stoves comes into effect (eco-design for residential heating stoves).

- Compulsory, accelerated phase-out of traditional, polluting solid-fuel heating appliances (stoves and, potentially, boilers) in municipalities where air quality has not complied with PM10 LVs

- Households affected by the compulsory phase-out of stoves to switch to heating by natural gas, district heating, or the use of Eco-Design compliant (Ecolabel) heating appliances.

Directive (EU) 2018/844 of 30 May 2018 amending Directive 2010/31/EU on the Energy Performance of Buildings;andDirective 2012/27/EU on energy efficiency regarding both residential and non-residential buildings (heating)

Existing Measures- Implementation of Energy Efficiency Act- National Programme for Energy Efficiency of Multi-Family

Residential Buildings (started 2015).- Apply minimum requirements to the energy performance of new

buildings and existing buildings undergoing major renovation or retrofitting.

- Adopt national plan for increasing the number of nearly-zero energy buildings.

- Ensure that by December 31, 2020, all new buildings are nearly-zero energy and that, after December 31, 2018, new buildings occupied and owned by public authorities are nearly-zero energy buildings.

- Establish a long-term renovation strategy (RS) to support the renovation of the national buildings stock, to become highly energy efficient and decarbonised (nearly-zero energy) by 2050, including. a road map with measures, measurable progress indicators, and indicative milestones for 2030 and beyond.


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National energy strategy (2011) Existing Measures- The national energy strategy to 2020 adopted in 2011 set a target

for 30 % of households to be connected to gas by 2020, to be achieved by a national accelerated gasification programme.


Road TransportComposition of the fleet (passenger vehicles, public transport, light and heavy-duty vehicles) – influenced by EU Directives and implementing Regulations regarding the type approval of motor vehicles

Existing Measures- Euro 1 to Euro 6 type criteria for vehicle performance – exhaust

emissions.- Incentivise the modernization of the vehicle fleet composition by

modifying the annual vehicle tax regime, applicable from 2019, so that tax depends on the age, engine type (power) and Euro standard. Electric vehicles are exempted from tax.

Potential Additional Measures Identified- Accelerating the vehicle fleet modernisation through:

i. Vehicle checking scheme – cancelling the registration of vehicles that do not meet the required Euro standards e.g. if a catalyst or Diesel Particulate Filter (DPF) has been removed from a vehicle.

ii. Government of Bulgaria (with an advance approval of the EC) to restrict the import of pre-Euro 4 vehicles with the primary objective of preventing the ‘dumping’ of older diesel vehicles into the Bulgarian market.

iii. Subsidised scrappage of older diesel vehicles (assuming controls on their import).

Municipality programmes and Proposed NAQIP

Existing Measures- Construction and operation of the Sofia Metro;- Introduction of electric buses;- Range of other, miscellaneous measures at municipal level.Potential Additional Measures Identified- Establish low emission zones (LEZ) to reduce numbers of pre-Euro

and Euro 1 vehicles entering centres of Sofia and Plovdiv.

Other Transport including Shipping

Agriculture, construction & other sectors that use off-road vehicles and machinery controls from- European Non-Road Emission

Regulations transposed into Bulgarian law

Existing Measures- Enforce requirement that sales of new machinery are to the

appropriate standard.- Implement Stage VI of the Regulations, which comes into effect in

2019-2020.Potential Additional Measures Identified- Establish and implement a voluntary clean construction scheme;- Devise DPF retrofit scheme and implement through voluntary

measures or as conditions of planning and development consents.International inland waterways- MARPOL revised Annex VI

(similar requirements to SCLF (Measure 20 above) but for inland shipping

Existing Measures- Implement from January 1, 2020 the progressive reduction in

emissions of sulphur dioxide, nitrogen oxides and particulate matter and the introduction of emission control areas (ECAs) to reduce emissions of those air pollutants further in designated sea areas.


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Industrial Processes and Fugitive EmissionsIndustrial Emission Directive 2010/75/EU (IED) for- Inorganic chemical

production, e.g. nitric acid, ammonia, and sulphuric acid

Existing Measures- Comprehensive permits issued to large industrial installations- Application of BAT and cost-efficiency measures at these

installationsPotential Additional Measures Identified- No additional measures identified.

Industrial Emission Directive 2010/75/EU (IED) for- Oil Refineries

Existing Measures- Integrated permits issued under IPPC regulatory control of oil

refineries.- Application of BAT to control off-gas flaring, as indicated in

relevant BREF documents.Potential Additional Measures Identified- No additional measures identified.

Sulphur Content of Certain Liquid Fuels (SCLF) EU/2016/802 for Heavy Fuel Oil, Gas Oil and Marine Fuels

Existing Measures- Maximum sulphur content of Heavy Fuel Oil and Gas oil used in

Combustion Plants and for Marine Fuel (unless abatement equipment fitted) in territorial waters, other waters and at berth.


Road transport: fuel storage, supply and vehicle refuelling:- Regulation No 16 of

12.08.1999, last amendment of 06.02.2018 transposing Directives 94/63/EC and 2009/126/EC

Existing Measures- Continued implementation of Stage I and Stage II measures to

prevent or at least minimise the emission of NMVOCs from fuel storage and distribution, and vehicle refuelling at service stations.


Solvent UseIndustrial Emission Directive 2010/75/EU (IED) for- Various industrial sectors that

use solvents and/or generate NMVOCs

Existing Measures- Plants operating in the coating, printing, food & drink sectors to

operate under complex permits or upon registration.- Application of BAT to prevent and control NMVOC releases air.Potential Additional Measures Identified- No further measures identified.

Directive 2004/42/EC- Domestic and commercial

products containing solvents

Existing Measures- Reduce or eliminate the solvents content of products (paints,

varnishes, fungicides, etc) used by households and in commercial premises.

Potential Additional Measures Identified- Scheme to promote safe recycling/disposal of the stock of solvent-

based products held by householders and others

AgricultureManagement of manure- Acts issued for the

implementation of Directive (EU) 2016/2284 (on

Existing Measures- Implementation of Nitrates Directive regarding application of

manure to soilPotential Additional Measures Identified

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the national emissions ceilings of some ambient air pollutants), Annex III, Part 2

- Implement Good Agricultural Practice Rules to Reduce Ammonia Emissions from agricultural sources

- Reduce ammonia emissions from livestock manures using methods shown to have a higher reduction potential than the reference method described in the Ammonia Guidance.

Soils: application of nitrogen fertilisers

Existing Measures- Transposing the Nitrates Directive- Application of measures in the Nitrates DirectivePotential Additional Measures Identified- Implement Good Agricultural Practice Rules to Reduce Ammonia

Emissions from agricultural sources- Adoption of methods having a greater potential to reduce

ammonia emissions, e.g. by applying at the appropriate time for the crops.

Harvest residues Existing Measures- Maintain enforcement of the ban on open-field burning of harvest

residues.Potential Additional Measures Identified- Establish a Good Agricultural Practice Rules for the proper

management of harvest residues.Other

Control of Mineral Dust from Construction sites and from roads

Potential Additional Measures Identified- Produce and promote a voluntary code of practice for site

managers

As required under Section 2.6.4 of the Commission’s Implementing Decision (EU) 2018/1522, Tables VI.2 and IV.3 respectively provide further information on the inclusion of PaMs to control emissions form the agricultural sector of (i) ammonia and (ii) fine particulate matter. A brief description of how the policy options have taken the impacts on small farms into account is provided. Member States may, for instance, exempt small and micro farms from those measures where possible and appropriate in view of the applicable reduction commitments.

Mandatory measures under the Commission’s Implementing Decision are listed in these tables in bold font, discretionary measures in normal font.

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Table VI.2. Measures considered to control ammonia emissions (Referred to as ‘A’ in section 2.6.4 of Commission Implementing Decision)

MeasureIs the PaM included in the

national air pollution control programme?

Section/page

number in the

programme

Has the PaM been applied exactly?

Preventing impacts on small and micro farms

(referred to as ‘C’ in Commission Implementing Decision)

1. Establish a Good Agricultural Practice Rules to Reduce Ammonia Emissions from agricultural sources, in line with the UNECE Framework Code for Good Agricultural Practice for Reducing Ammonia Emissions of 2014, covering at least the following items:

1) Nitrogen management, taking into account the whole nitrogen cycle

2) Livestock feeding strategies3) Low-emission manure spreading techniques4) Low-emission manure storage systems5) Low-emission animal housing systems6) Possibilities for limiting ammonia emissions

from the use of mineral fertilisers

YesNational code prepared in draft as Good Agricultural Practice Rules to reduce

ammonia emissions released into the ambient

air from agricultural sources.

Awaiting approval by Council of Ministers

PaM A1 deals with item 1fPaM A2 deals with items

1b, 1c and 1d

p. 45-47, 51-53 and 112-

113

Yes, the National code follows the form of the

UNECE reference document.

MAFF is considering exemption for small and micro farms and is developing definitions of farms that will be exempt.

2. Establish a national nitrogen budget to monitor the changes in overall losses of reactive nitrogen from agriculture, including ammonia, nitrous oxide, ammonium, nitrates and nitrites, based on the principles set out in the UNECE Guidance Document on Nitrogen Budget.

YesNational nitrogen budget

prepared in line with international statistical

reporting requirements.

p. 51-52 and 112-113

[As above] Not applicable

3a. Prohibit the use of ammonium carbonate fertilisers Not applicable P. 52 Not applicable Not applicable

3b. Reduce ammonia emissions from inorganic fertilisers using the following approaches:

1) Replacing urea-based fertilisers by ammonium

YesPaM A2 deals with fertilizer application best practice

p. 45-47, 51-53 and 112-

113

Yes, the National code will be disseminated and its impacts

MAFF is considering exemption for small and micro farms and is developing definitions of farms

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Section/page

number in the

programme




nitrate-based fertilisers2) Where urea-based fertilisers continue to be

applied, using methods that have been shown to reduce ammonia emissions by at least 30 % compared with the use of the reference method, as specified in the Ammonia Guidance Document to prevent and reduce ammonia emissions from agricultural sources

3) Promoting the replacement of inorganic fertilisers by organic fertilisers and, where inorganic fertilisers continue to be applied, spreading them in line with the foreseeable requirements of the receiving crop or grassland with respect to nitrogen and phosphorus, also taking into account the existing nutrient content in the soil and nutrients from other fertilisers.

Order No 09-977-09.11.2017 Programme of measures to limit and Prevent Vulnerable areas from Nitrate Pollution from Agricultural sources.1. Limit on winter periods

for application of organic and mineral/inorganic nitrogenous fertilisers

2. Evenly distributed by means of specialised equipment

3. Fresh manure not to be used: solid manure to be stored at least for 6 months and liquid for 4 months

4. Organic fertilisers ploughed in on the day of application

5. Limits on application rates

monitored that will be exempt.

4. Reduce ammonia emissions from livestock manure by using the following approaches:

1) Reducing emissions from slurry and solid manure application to arable land and grassland, by using methods that reduce emissions by at least 30 % compared with the reference method described

YesPaM A2 concerns good practice in cattle manure management[see also ‘Guidance on the practical implementation of

p. 45-47, 51-53 and 112-113

[As above] [As above]

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Section/page

number in the

programme




in the Ammonia Guidance Document and on the following conditions:

i. Promoting the replacement of inorganic fertilisers by organic fertilisers and, where inorganic fertilisers continue to be applied, spreading them in line with the foreseeable requirements of the receiving crop or grassland with respect to nitrogen and phosphorus, also taking into account the existing nutrient content in the soil and nutrients from other fertilisers.

ii. Not spreading manures and slurries when the receiving land is water saturated, flooded, frozen or snow-covered

iii. Applying slurries spread to grassland using a trailing hose, trailing shoe or through shallow or deep injection

iv. Incorporating manures and slurries spread to arable land within the soil within four hours of spreading

2) Reducing emissions from manure storage outside of animal houses, by using the following approaches:

i. For slurry stores constructed after 1 January 2022, using low-emission storage systems or techniques which have been shown to reduce ammonia emissions by at

standards for maintaining the soil in good agricultural and ecological status 2016’]

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Section/page

number in the

programme




least 60 % compared with the reference method described in the Ammonia Guidance Document, and for existing slurry stores at least 40 %

ii. Covering stores for solid manureiii. Ensuring farms have sufficient manure

storage capacity to spread manure only during periods that are suitable for crop growth

3) Reducing emissions from animal housing, by using systems which have been shown to reduce ammonia emissions by at least 20 % compared with the reference method described in the Ammonia Guidance Document

4) Reducing emissions from manure, by using low-protein feeding strategies which have been shown to reduce ammonia emissions by at least 10 % compared with the reference method described in the Ammonia Guidance Document.

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Table VI.3. Emission Reduction measures to control emissions of fine particulate matter (PM2.5) and black carbon (Referred to as ‘B’ in section 2.6.4 of Commission Implementing Decision)

Measure

Is the PaM included in the

national air pollution control

programme?

Section/page number in the

programme

Has the PaM been

applied exactly?



1a. Ban open field burning of agricultural harvest residue and waste and forest residueAny exemptions to this ban shall be limited to preventive programmes to avoid uncontrolled wildfires, to exterminate pest or to protect biodiversity.

Yes(existing measure)

p. 52 and 112-113 Yes -

1b. Monitor and enforce stricter implementation of any such ban on the open field burning of agricultural harvest reside and waste and forest residue.

Yes(existing measure)

p. 52 and 112-113 Yes MAFF is considering exemption for small and micro farms and is developing definitions of farms that will be exempt.

2. Establish Guidelines to good agricultural practices for the proper management of harvest residue on the basis of the following approaches:

a) Improvement of soil structure through the incorporation of harvest residue

b) Improved techniques for incorporation of harvest residuec) Alternative use of harvest residued) Improvement of the nutrient content and soil structure through

incorporation of manure as required for optimal plant growth, thereby avoiding burning of manure (farmyard manure, deep-straw bedding).

no - - -

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ANNEX VII – COSTS AND BENEFITS OF THE NAQIP RESIDENTIAL HEATING PAM PACKAGE

Approach

Projections of emissions and fuel use in the residential sector form the starting point for the analysis. The With Existing Measures (WM0 scenario is based on projections of changes in the composition of heating appliances over the emissions projection period. The With Additional Measures (WAM) scenario specifies within non-compliant municipalities additional shifts in the composition of appliance types considered necessary to achieve compliance. These include shifts towards district heating, central gas supply, fuel quality requirements for wood burnt in residential stoves, and modern eco-label stoves.

Using this information, the number of the different types of appliances is calculated. These include the number of traditional appliances shifting to higher quality wood, those shifting to eco stoves, and those being replaced by connections to district heating or gas. In making this analysis it is assumed that all residences have the same energy output demand, irrespective of heating source (taken to be 8 MWh/heating season). With this information, and knowing the thermal energy conversion efficiency and emission factors of the different heating sources, the number of traditional appliances affected by each measure is determined. From this, the following calculations are made:

- The number of traditional stoves shifting to high quality (lower moisture) wood, the operational cost implications of this and the extent of PM2.5 emission reduction achieved by it

- The number of traditional stoves shifting to eco label stoves, the investment and operational cost implications of this and its impact on PM2.5 emissions

- The number of traditional stoves shifting to district heating and central gas supply networks (reconnections and new connections), the investment and operational cost implications of this and its impact on PM2.5 emissions

With this information two key parameters are calculated: the cost effectiveness (as €/tonne PM2.5 reduced) and the economic benefit of each measure (as €/tonne PM2.5 reduced). From this the costs and benefits of each measure are compared and reported as benefit-cost ratios and NPV (net social benefit or cost). These parameters are also calculated for all measures combined.

The measures are then ranked according to cost-effectiveness and benefits-costs ratio criteria. Note that these lead to the same ranking, but whereas cost effectiveness gives an indication of the financial cost of a measure, the benefit-cost ratio is an indication of whether a measure (or collection of measures) can be justified in economic terms (value added to society).

Principal Findings

Using these criteria, the measures rank in decreasing order:

1. Reconnection to gas

2. Reconnection to district heating

3. New connection to district heating

4. Switch to ecolabel stoves

5. Fuel quality requirements

6. New connection to gas

The ranking of measures according to their relative cost-effectiveness or benefit-cost ratios is identical. This is because cost-effectiveness is calculated as the financial cost per tonne of PM2.5 avoided. As the benefit from a tonne of PM2.5 avoided is the same regardless of the source of the reduction, it follows that ranking by benefit-cost ratios must mirror the ranking by cost-effectiveness. A positive benefit-cost ratio is an indication that a measure adds value to society and can therefore be used to support implementation of the measure.

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I. All measures individually and combined are assessed to be economically viable

II. Total (absolute) investment costs over the assessment period are estimated to be about €426 million (constant 2018 values).

III. Reconnection to gas, reconnection to district heating and new connections to district heating are the three most cost-effective measures, and between them account for 20 % of estimated emissions reductions over the assessment period.

IV. Switching to eco-label stoves is the fourth-most cost-effective measure. The measure has a unit cost of PM2.5 reduced that significantly higher than reconnections to either gas or district heating, but only slightly higher than that for new connections to district heating. The measure accounts for 29 % of cumulative projected emissions.

V. The introduction of fuel quality requirements is the fifth most cost-effective measure, with a significantly higher cost per tonne of emission reduced than shifting to eco-label stoves. Although investment costs are taken to be zero, and compliance enforcement costs are relatively low, the higher prices assumed to be paid for compliant “dry” wood result in high unit costs of emissions reduced.

VI. Switching to new gas connections is the least cost-effective of the measures. Cost per tonne of PM 2.5

reduced is 40 % higher than that for fuel quality requirements and almost double that for all measures combined.

VII. The average incremental cost per tonne of PM2.5 avoided for all measures combined is €5 954.

VIII. The total discounted benefits and costs of all measures combined are €1 717 million and €374 million, respectively, giving a positive net present value of €1 321 million and a benefit-cost ratio of 4.6.

Preparing the assessment has necessitated a number of assumptions based on professional knowledge. The complexity of accounting for the many variables that characterise analysis of this kind cannot be overstated. In order to estimate the before and after situations for each measure it is necessary to take into account differences and interactions between fuel quantities and qualities, appliance types, efficiencies and emissions factors. As a result, it is an uncertain process. Nevertheless, the outcomes reported are considered to be robust and may serve as practical guidance for officials when preparing municipal strategic air quality plans and for reaching realistic decisions about the scope, composition, costs, affordability and financing of the various measures.

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ANNEX VIII – DIFFERENCES BETWEEN THE WM AND WAM SCENARIOS

The sections below summarize qualitatively the changes from the WM scenario to the WAM scenario that result from the selected PaMs.

ANNEX IVANNEX VANNEX VI

VII.1. PUBLIC ELECTRICITY AND HEAT PRODUCTION

There is an impact on the electricity and heat generation sector from a PaM introduced to reduce particulate emissions from the residential heating sector. In this PaM, it is expected that some householders will switch from burning solid fuels (wood and coal) to using gas, district heating and or electricity.

A corresponding increase in fuel consumption to meet the additional domestic electricity demand has been estimated. And the fuel consumption of the sector increased accordingly (relative to the WM scenario). This results in a slight increase in emissions from the electricity and heat generating sector.

Refineries: No change from the WM scenario.

VII.2. INDUSTRIAL COMBUSTION

No change from the WM scenario.

VII.3. RESIDENTIAL AND OTHER STATIONARY COMBUSTION

The listed additional PaMs concern fuel quality, modernization of heating appliances, and fuel switching.

Fuel quality requirements – Coal and Wood

In this PaM, fuel quality requirements are introduced for the sulphur content of coal and the moisture content of wood:

The total energy demand is assumed to be unchanged from the ‘with measures’ scenario.

Coal is assumed to either be imported, or sourced from the Pirin mine to reduce SOx emissions. In addition, this PaM reduces the mass of coal consumed because imported coal has a higher net CV.

The mass of wood consumed each year is assumed to decrease (because the wood contains less water)

I These measures are applied in municipalities which do not comply with ambient air quality

standards23. This accounts for 56 % of the population.

Modernization of Solid-Fuel Heating Appliances – Ecolabel standardUnder this PaM, all new appliances entering the market in 2020 and beyond are assumed to be of an advanced/ecolabel standard, the introduction of the ecolabel regime for stoves being brought forward to 2020 from 2022. The PaM adopts also a compulsory phase-out of traditional heating appliances in municipalities that are not achieving ambient air quality standards. This will accelerate the modernisation of the national heating stock.

23 Asenovgrad, Blagoevgrad, Burgas, Devnya, Dimitrovgrad, Dobrich, Galabovo, Gorna Oryahovitsa, Haskovo, Kardzhali, Lovech, Montana, Nesebar, Pazardzhik, Pernik, Pirdop, Pleven, Plovdiv, Ruse, Shumen, Sliven, Smolyan, Sofia, Stara Zagora, Varna, Veliko Tarnovo, Vidin, and Vratsa.

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Fuel Switching – Wood to Gas or Electricity/District Heating

Linked to the compulsory phase-out aspect of the above PaM, it is expected that some households in the municipalities out of compliance currently with ambient air quality standards will switch from solid-fuel fired appliances to residential heating using natural gas or a district heating system.

VII.4. ROAD TRANSPORT

The selected additional PaMs concern:

Limiting the import of new passenger cars to “higher” Euro standards, to avoid importing more polluting vehicles from other countries.

A corresponding increase in fuel consumption to meet the additional domestic electricity demand has been estimated. And the fuel consumption of the sector increased accordingly (relative to the WM scenario).

These result in the following changes to the vehicle fleet composition over time:

Import of “clean” passenger cars

It expected that second hand cars imported into Bulgaria will be at least Euro 4 and that the proportion of Euro 5 and 6 passenger cars will increase compared to the WM scenario. In addition, it is assumed that this will accelerate the move away from diesel to petrol passenger cars, when compared with the WM scenario.

Establishment of LEZs

It is expected that Low Emission Zones will further incentivize the modernization of the vehicle fleet, and hence the penetration of Euro 5 and 6 passenger cars is increased compared to the above WAM scenario.

VII.5. OTHER TRANSPORT – AVIATION , RAILWAYS AND SHIPPING


VII.6. INDUSTRIAL PROCESSES AND FUGITIVE EMISSIONS


VII.7. SOLVENT AND PRODUCT USE


VII.8. AGRICULTURE

The selected additional PaMs concern the management of cattle manures and the application of nitrogenous fertilisers. The Ministry of Agriculture, Food and Forestry is undertaking a full assessment of the agriculture sector with the intention of producing an agriculture strategy. The two measures below are representative of the additional PaMs which will be included in the agriculture strategy to reduce emissions:

Fertiliser application: A strong drive to ensure compliance with the Nitrates Directive and implementation of good agricultural practice in fertiliser application, will achieve further reductions in ammonia (NH3) emissions. The rate of ammonia emissions from the application of nitrogenous fertilisers (inorganic and organic) is expected to reduce by 2.5 % each year from 2016 to 2026. The same is assumed for nitrogen oxides (NOx) and NMVOC emissions, where present.

Cattle manure management: Implementing best practice in cattle manure management will increase the rate of reduction of ammonia emissions. The emission rates of manure management for cattle are

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expected to decrease by 2 % each year from 2016 to 2026. The same is assumed for nitrogen oxides and NMVOC emissions, where present.

As the agriculture strategy is formed, the Ministry of Environment and Water will work jointly with the Ministry of Agriculture, Food and Forestry to define the scope for adopting additional PaMs which are targeted at reducing ammonia emissions (and also have the effect of reducing the emissions of other pollutants).

VII.9. WASTE


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