1. Primary Energy Efficiency Law

The Bulgarian Energy Efficiency Act ("Bulgarian EEA") was published in the State Gazette ("SG") issue No. 32/2015 and entered into force on 15 May 2015. It transposes into the Bulgarian legislation most of the provisions of Directive 2012/27/EU and Directive 2010/31/EU on the energy performance of buildings. It replaces in its entirety the old Energy Efficiency Act of 2008.

The main purpose of the Bulgarian EEA is to improve energy efficiency as part of the national sustainable development policy by:

-using a system of energy efficiency improvement activities and measures in energy production, transmission and distribution, as well as in final energy consumption;

-setting up energy savings obligation schemes;

-developing the energy efficiency services market and encouraging the delivery of energy efficiency services; and

-setting up financing mechanisms and schemes in order to achieve the national energy efficiency targets.

Some of the provisions of Directive 2012/27/EU have also been transposed by amendments to the Bulgarian Energy Act, the Act for Energy from Renewable Sources, the Public Finances Act, the Accounting Act, the National Standardisation Act, the Spatial Development Act, the Public Procurement Act and the Administration Act.

Further, some important aspects of Directive 2012/27/EU have been transposed via secondary legislation. A number of sector specific ordinances have been adopted under the Bulgarian EEA in this respect. The most relevant of these are:

-Ordinance for the methodologies for setting the national energy efficiency target, the setting of the overall cumulative target, the setting up of an energy savings obligation scheme and the allocation of the individual energy savings targets to the obliged parties;

-Ordinance No. E-РД-04-3 of 4 May 2016 for the eligible measures for obtaining energy savings in final consumption, the manner of proving the energy savings obtained, the requirements to the methodologies for evaluation of energy savings and the manner for confirming energy savings;

-Ordinance No. РД-16-301 of 10 March 2014 for the circumstances for the entry of qualified energy auditors into the public register, the procedure for entry into the register and for obtaining information, as well as the terms and procedure for the attainment of qualification of the auditors;

-Ordinance No. Е-РД- 04-01 of 22 January 2016 for the terms and procedures for performing an energy efficiency audit and certification of buildings, of parts of buildings, as well as the terms and procedure for preparing an energy savings evaluation;

-Ordinance No. Е-РД-19-932 of 23 October 2009 for the terms and procedures for performing the energy efficiency inspection of heating systems with hot-water boilers and of air-conditioning systems, the terms and procedure for preparing an energy savings evaluation;

-Ordinance No. Е-РД-04-05 of 8 September 2016 for the indicators of energy expenditure, the energy performance of enterprises, industrial systems and outdoor lighting systems, as well as the terms and procedures for performing an energy efficiency audit and preparing an energy savings evaluation in industrial enterprises;

-Ordinance No. Е-РД-04-2 of 22 January 2016 for the indicators of energy expenditure energy qualities of buildings;

-Ordinance No. Е-РД-16-647 of 15 December 2015 for determination of the structure and content and the conditions and procedures for providing information;

-Ordinance No. РД-16-301 of 10 March 2014 for the circumstances for registration of those persons performing certification of buildings and assessment for energy efficiency of industrial systems, the order to obtain qualification and the necessary technical means for the performance of assessment and certification activities; and

-Ordinance No. РД-16-346 of 2 April 2009 on the consumption and energy performance indicators of industrial systems and the requirements and procedures for conducting energy efficiency audits on industrial systems.

Some of the secondary legislation in the energy sector, such as the Electricity Market Rules and Natural Gas Market Rules, were also modified accordingly.

Comparison

The adoption of the Bulgarian EEA occurred after considerable delay (since Directive 2012/27/EU should have been transposed into national law by 5 June 2014) and only after the initiation of an infringement procedure by the European Commission against Bulgaria in March 2015. Although the Bulgarian EEA addresses most of the requirements of Directive 2012/27/EU, the European Commission identified transposition gaps in the national legislation and decided to continue the infringement procedure against Bulgaria by sending a reasoned opinion on 22 October 2015.

In order to remediate the gaps in the transposition, the Bulgarian Government proposed further amendments to the Bulgarian EEA and other pieces of primary legislation. The latest amendments were adopted by the Parliament, published in the SG, issue No. 105/2016 and entered into force on 30 December 2016. According to the Bulgarian authorities, Bulgarian legislation should now be fully aligned with Directive 2012/27/EU.

Competent authorities

In order to implement the measures and to achieve the energy savings targets under Directive 2012/27/EU, Bulgaria has developed a complex framework of primary and secondary level norms.

Pursuant to the Bulgarian EEA, the energy efficiency policy in Bulgaria is to be implemented by a number of public authorities. The National Energy Efficiency Strategy of the Republic of Bulgaria, which defines the stages, means and measures to achieve the national energy efficiency target, is to be adopted by the National Assembly.

The Council of Ministers has a particularly important role in this respect, as it adopts, among others:

-the State energy efficiency policy;

-the National Energy Efficiency Action Plans;

-a National Plan for Nearly Zero-Energy Buildings;

-a national plan for improvement of the energy performance of heated and/or cooled State-owned buildings occupied by the State administration; and

-a long-term national programme to encourage investments in implementing measures to enhance the energy performance of buildings of the public and private national residential and commercial building stock.

The practical implementation of those policies and documents is performed by different ministries – in particular the Ministry of Energy, the Ministry of Economy, the Ministry of Regional Development and Public Works, Ministry of Transport, Information Technology and Communications and other public institutions.

Pursuant to the Bulgarian EEA, the Sustainable Energy Development Agency ("SEDA") is charged with the implementation of the State energy efficiency improvement policy. This administrative authority has a central role in this respect and its task and powers are frequently being extended to cover further energy efficiency policies and measures.

Energy Efficiency Targets

The Bulgarian EEA provides that the national energy efficiency target shall be set in the National Energy Efficiency Action Plan, i.e. be adopted by the Parliament. The current National Energy Efficiency Action Plan 2014-2020, although adopted before the transposition of Directive 2012/27/EU into the Bulgarian legislation, has been developed in compliance with the provisions of Article 24(2) of Directive 2012/27/EU.

Energy Efficiency Improvement Activities

The Bulgarian EEA provides for the following energy efficiency improvement activities:

-reduction of energy expenditure in energy production, transmission and distribution, as well as in final energy consumption;

-training and attainment of qualification in the field of energy efficiency of persons delivering energy efficiency services;

-conformity assessment of development-project designs of buildings as regards energy efficient requirements;

-energy efficiency audits and certification of buildings;

-energy efficiency inspection of heating systems with hot-water boilers and air-conditioning systems in buildings;

-energy efficiency audits of enterprises, industrial systems and outdoor lighting systems;

-energy efficiency management;

-delivery of energy efficiency services; and

-raising awareness among households.

EU Sectoral Operational Programmes

Substantial financing for reaching the respective targets is expected to be obtained from the following EU financed Operational Programmes:

-Operational Programme "Innovations and Competitiveness" 2014-2020 (OPIC) is the basic programme document on the national level outlining the aid envisaged for Bulgarian businesses from the European structural and investment funds for the period 2014-2020. The total budget of OPIC amounts to EUR 1.39 billion, with financing from the European Reconstruction and Development Fund of almost EUR 1.18 billion (eighty five percent (85%) of the budget), and national co-financing of EUR 209 million (fifteen percent (15%) of the budget);

-Operational Programme "Regions in Growth" 2014-2020 is a continuation of the programme "Regional Development" 2007-2013;

-Rural Development Programme 2014-2020 aims to improve living conditions in rural areas by facilitating access to quality infrastructure. The activities eligible under the Programme include investments for the improvement of energy efficiency in municipal buildings or other buildings used for the provision of public services; and

-Operational programme on "Transport and Transport Infrastructure" 2014-2020 aims mainly to construct, reconstruct and modernise the transport infrastructure of the country as part of the Pan- European Transport Network.

Another actual programme directly aimed at energy efficiency measures is Programme BG04 "Energy Efficiency and Renewable Energy", financed by the Financial Mechanism of the European Economic Area and the Kingdom of Norway, Iceland and Principality of Liechtenstein. Programme BG04 "Energy Efficiency and Renewable Energy" includes two programme areas "Energy Efficiency" (Programme Area 5) and "Renewable Energy" (Programme Area 6). The programme comprises four grant schemes, a bilateral relations fund and a designated project. The total programme budget is EUR 15,600,288, including EUR 13,260,245 (eighty five percent (85%)) in grant assistance and EUR 2,340,043 (fifteen percent (15%)) in national co-financing.

Specific measures for environment, climate change and energy efficiency were also included within the scope of other programmes for the 2014-2020 period.

Kozloduy International Decommissioning Support Fund

In 2015, two projects aimed at improving the energy efficiency of public buildings were implemented, for a total value of EUR 30.4 million, co-financed by the Kozloduy International Decommissioning Support Fund (KIDSF) – administered by the EBRD and funded by international donors within the so-called "non-nuclear window". The financial support amounts to one hundred percent (100%) of the project value.

KIDSF also financed a project on energy efficiency of municipal street lighting systems, which is valued at EUR 10.655 million and funded entirely from KIDSF.

National Programmes

The main Bulgarian national programme in the field of energy efficiency is the National Programme for Energy Efficiency of Residential Buildings. Under this programme, BGN 1 billion (approximately EUR 511 million) are provided by the Government in the form of a bank guarantee, which the Council of Ministers provides to the Bulgarian Development Bank to attract resources and secure financing for the programme's activities. The programme includes all municipalities and will last for a period of two (2) years, with the option to extend should the financial resources be available. Financing will come in the form of a State grant for all buildings which meet the requirements. Eligible are residential buildings, constructed by industrial means, with more than 36 apartments.

Another important programme addressed to households is the credit facility for energy efficiency in the household sector, which is financed by the EBRD. A total of 3,052 residential energy saving projects were financed and implemented in 2015, to a total value of BGN 9,755,101; the estimated equivalent savings are estimated at 14,145 MWh/year in electricity and 9,654 t CO2-eq/year in greenhouse gas emissions. The beneficiaries include households and associations of home owners which can receive consumer loans combined with technical and financial assistance provided free of charge via local banks and intended for energy efficiency improvement and RES utilisation. The eligible measures include the installation of energy efficient windows and doors, walls, roofs and floor insulation, high-efficiency burners and biomass-fuelled boilers and systems, water heater solar collectors and systems; energy efficient gas- fuelled boilers and systems; thermal pump systems for heating and air-conditioning; photovoltaic systems for buildings; district heating substations and systems or gas installation in buildings and recuperative ventilation systems.

The Bulgarian Energy Efficiency and Renewable Sources Fund (FEEVI) is another possible financing source for energy efficiency projects. It offers to Bulgarian companies, municipalities and private individuals beneficial financial products in the field of energy efficiency such as credits below market interest rates, partial credit guarantees and portfolio guarantees. In 2015, FEEVI extended loans to six energy efficiency improvement projects for a total value of BGN 1,479,253 (approximately EUR 755,751). These are expected to result in annual energy savings of 1,865 MWh and a reduction of annual greenhouse gas emissions of 2,800 t CO2-eq.

Comparison

Since 2007 when Bulgaria became a member of the EU, the country has made important progress in implementing energy efficiency measures. The results achieved with respect to the national target set in accordance with Directive 2006/32/EU evidence that Bulgaria has exceeded its indicative target for the period 2008-2015 by one point four percent (1.4%).

However, the implementation of Directive 2012/27/EU and the achieving of the national energy savings targets and the targets for reducing the energy intensity of the national economy provided for in Bulgaria’s Energy Strategy requires implementation of a number of measures and programmes to alleviate the impact on businesses, households and the public sector. The Bulgarian government recognises the importance and positive impact that energy efficiency measures may have on the national economy and energy consumption and are constantly extending the measures and programmes to implement energy efficiency savings for the country.

According to the Bulgarian EEA, the total cumulative target for the 2014-2020 period was set as an accumulation of new energy savings each year of at least one point five percent (1.5%) of the average annual value of the total volume of energy sales to final customers within Bulgaria in 2010, 2011 and 2012, excluding the volume of sales of energy used in the transport sector, under Eurostat Code B_101900. The target was reduced by up to twenty five percent (25%) by applying the options in Article 7 (2) a) and d) of Directive 2012/27/EU.

According to the Bulgarian EEA, individual targets are allocated to the following three groups of obliged parties:

-energy traders;

-owners of industrial systems with an annual energy consumption in excess of 3,000 MWh; and

-owners of buildings that are within the central or local government estate and are in use, and have a total building floor area of more than 1,000 m² (from 2015, the threshold was lowered to 250 m²).

In order to achieve their individual targets, the obliged parties may implement energy efficiency improvement measures in different sectors, among others: transport, industry and households, commerce, civil society organisations, agriculture, forestry and fishery, services. The obliged parties may implement measures that achieve energy savings in the energy transformation, distribution and transmission sectors, including by means of efficient district heating and cooling systems infrastructure.

Annually, (not later than 1 March), the obliged persons must submit reports to SEDA on the implementation of the EE measures and the progress towards the achievement of their individual EE targets. Based on the reports submitted to SEDA by 1 March 2016, the evaluation of the EEOS results were included in the annual report on the implementation of NEEAP. For the period 2008-2015 the obliged energy traders achieved forty three percent (43%) of their total energy savings targets.

Achieving the individual targets by energy traders

This measure was set up in Article 10 of the Bulgarian EEA and repealed in 2015, assigning individual energy savings targets to be achieved by energy traders generating energy sales to end-consumers exceeding the equivalent of 75 GWh/year, having more than 10 employees or an annual turnover of more than BGN 4 million (approximately EUR 2,045,167). The overall target to be achieved by energy traders by 2016 was set to 4,644 GWh of energy savings.

The Directive introduced a new energy efficiency obligation scheme for energy traders and the newly adopted Bulgarian EEA in 2015 defined the obliged parties which were included in the obligation scheme. Under Article 14(4) of the Bulgarian EEA, the overall cumulative target under the obligation scheme is allocated in the form of individual energy savings targets among the following obliged parties:

-end suppliers, providers of last resort, traders holding a license for the activity of "trading in electricity" having annual sales of electricity to end-users in excess of 20 GWh;

-heat transmission undertakings and heat energy suppliers having annual sales of heat energy to end- users in excess of 20 GWh;

-end-suppliers and traders in natural gas having annual sales to end-users in excess of 1 million m3;

-traders in liquid fuels having annual sales to end-users in excess of 6,500 t of liquid fuels, with the exception of fuels for transport purposes; and

-traders in solid fuels having annual sales to end-users in excess of 13,000 t of solid fuels.

The energy traders above are required to submit annual reports to SEDA, which provide for their activities and measures to lower energy consumption. The deadline for submission of these reports is 1 March of the following year.

SEDA implemented a project for enhancing the institutional capacity of the Sustainable Energy Development Agency to create incentives and enable energy traders to meet their obligations under the Bulgarian EEA. The project is funded under the Operational Programme Development of the Competitiveness of the Bulgarian Economy. One of the main project goals was to increase the volume and to improve the quality and economic return of implemented energy efficiency measures by creating energy savings market that will function on the basis of tradable white certificates.

Achieving the individual targets by the owners of industrial systems

The energy audits of industrial systems are a statutory energy efficiency measure according to the Bulgarian EEA and Ordinance No. РД-16-346 as of 2 April 2009 on the consumption and energy performance indicators of industrial systems and the requirements and procedure for conducting energy efficiency audits on industrial systems. Mandatory energy efficiency audits are to be conducted at least once every four (4) years by any of the following:

-large industrial and services enterprises which are not SMEs (i.e. enterprises which have an average annual number of more than 250 employees; and an annual turnover exceeding BGN 97.5 million (approximately EUR 49.6 million) or a fixed tangible assets value exceeding BGN 84 million (approximately EUR 42.95 million) – Article 3 of the Small and Medium-Sized Enterprises Act);

-industrial systems with annual energy consumption exceeding 3,000 MWh; or

-outdoor lighting systems, located in settlements with population exceeding 20,000 residents.

The energy audit may be performed only by qualified and SEDA-accredited auditors, as described in Article 59 of the EEA.

SMEs and the owners of industrial systems subject to mandatory energy audits, which implement an energy or an environmental management system subject to certification by an independent body for conformity to European or International Standards, are exempted from the requirements for mandatory energy efficiency audits, provided that the management system implemented thereby includes an energy audit of the enterprise or industrial system concerned.

Owners of industrial systems with annual energy consumption exceeding 3,000 MWh constitute one of the groups of obliged persons which were allocated individual energy savings targets to be met by 2016, as prescribed in Paragraph 4 of the Transitional and Closing Provisions of the Bulgarian EEA. The overall individual target to be achieved by obliged industrial systems owners by 2016 was 839.2 GWh/year.

Achieving individual energy savings targets by owners of buildings

The individual energy savings targets of the owners of government and local authority public buildings were first set on the basis of a total floor area of more than 1,000 m², in line with the statutory requirements in force at the time the targets were set. Following the transposition of Directive 2010/31/EU into national law, however, the floor area threshold was lowered to 250 m², which is effective since 9 July 2015.

The overall target to be achieved by 2016 by the owners of government and local authority public buildings was set at 521 GWh. More than half of the individual target allocations for this group of obliged persons were achieved during the three (3) year 2011-2013 implementation period of NEEAP. To ensure implementation of individual energy savings targets, the national law stipulates that government and local authorities are to draw up energy efficiency improvement programmes. The full range of energy efficiency improvement measures are eligible to achieve the individual energy savings targets.

The obliged persons report their energy efficiency improvement programme implementation to SEDA on an annual basis by 31 March of the following year. Based on these reports, SEDA analyses the achievement of individual energy targets by obliged public building owners.

Comparison

In accordance with Directive 2012/27/EU, the Bulgarian EEA provided for a total cumulative target for the 2014-2020 period of at least one point five percent (1.5%) of the average annual value of the total volume of energy sales to final customers within the territory of the country in 2010, 2011 and 2012, excluding the volume of sales of energy used in the transport sector, under Eurostat Code B_101900. The target was reduced by up to twenty five percent (25%) by applying the options in Article 7 (2) a) and d) of the EED.

The "Methodology for the operation of the energy efficiency obligation schemes" was developed in accordance with the requirements of Article 7 of Directive 2012/27/EU. This national methodology has been drawn up in line with the framework provided in paragraph 4 of Annex V to Directive 2012/27/EU. When designating the obliged persons, Bulgaria does not include transport fuel distributors or retailers in the obligation scheme.

With the new Bulgarian Energy Efficiency Act (adopted and published in SG No. 35 of 15 May 2015) the threshold for obliged persons was changed. In order to reach their targets, obliged persons may implement horizontal measures aimed at increasing the energy efficiency of final customers, such as awareness and promotional campaigns. They may also pay contributions to the Energy Efficiency and Renewable Sources Fund or access other specialised funds, programmes, measures, schemes and mechanisms used to finance measures to increase the energy efficiency of final customers, including agreements concluded with beneficiaries.

Bulgarian legislation complies with the provisions of Directive 2012/27/EU. The Bulgarian EEA and the respective Ordinances provide a framework of requirements to ensure that energy auditors have the proper qualification and have the necessary experience and equipment to perform energy audits.

Qualification of energy auditors

The EEA provides the general requirements for energy auditors. Details on the procedure for licensing and the requirements are provided in Ordinance No. RD-16-301 of 10 March 2014 on the circumstances, subject to entry in the register of: (i) persons performing certification of buildings and energy efficiency audits of industrial systems; (ii) procedures for obtaining information from records; (iii) conditions and procedures for acquisition qualifications; and (iv) the necessary technical means to carry out inspection and certification activities.

Energy efficiency audits of enterprises, industrial systems and outdoor lighting systems may be performed only by those persons entered in a registry maintained by SEDA.

Auditors should be merchants who have at their disposal certain devices and staff consisting of energy efficiency consultants, who meet the following criteria:

-have completed higher education in the field of technical sciences in a professional field and specialties, which is recognised in the Republic of Bulgaria or in another EU Member State, or in another State, which is a contracting party to the Agreement on the European Economic Area, or in the Swiss Confederation, or have completed secondary technical education;

-have experience in a relevant position of not less than two (2) years for holders of a Masters' degree, not less than three (3) years for holders of a Bachelors' degree, and not less than six (6) years for persons who have completed secondary technical education; and

-hold a certificate of a successfully passed examination for the attainment of the qualification necessary to perform the activities listed above at higher technical schools specialised in the professional fields of energy, electrical engineering, and architecture, civil engineering and geodesy, or relevant education from another EU Member State, or from another State which is a contracting party to the Agreement on the European Economic Area, or from the Swiss Confederation.

Within five (5) years as of the registration in the registry maintained by SEDA, energy auditors must renew their registration by submitting an application stating their current qualifications and experience. SEDA is the authority responsible for controlling the energy auditors’ qualifications and for the quality of the energy audits conducted by them.

Performance of energy audits

The energy audits requirements, the indicators of energy expenditure, the energy performance of enterprises, industrial systems and outdoor lighting systems, as well as the terms and procedures for performing an energy efficiency audit and preparing an energy savings evaluation are regulated by Ordinance No. E-RD-04-05 of 8 September 2016.

Annually, not later than 31 January, the owners of enterprises, industrial systems and outdoor lighting systems which are subject to a mandatory energy efficiency audit must submit a template declaration to SEDA containing the characteristics of the respective entity. Information based on these declarations is entered into a public register maintained by SEDA.

Energy efficiency inspections are performed for heating systems with hot-water boilers of an effective rated output for space heating purposes of more than 20 kW and for air conditioning systems in buildings of a rated output of more than 12 kW.

Comparison

Bulgarian authorities have adopted a detailed and strict legal framework in order to ensure that energy efficiency audits will be performed by qualified and experienced specialists. The legal framework also contains detailed instructions on how an energy efficiency audit is to be performed which are the monitored parameters and what are the possible measures to be undertaken.

The Republic of Bulgaria has adopted several legislative acts to address the requirements of Directive 2012/27/EU.

Energy Strategy of the Republic of Bulgaria until 2020, promulgated in SG issue No. 43/07.06.2011

The main priorities set out in the strategy are to restrain the negative impacts on the climate, reduce the energy consumption of the economy and increase the energy efficiency by twenty percent (20%) in order to limit the external dependency of the EU on imported energy resources, and encourage the economic growth and employment levels possible. The Strategy conveys that energy efficiency is of the highest priority in the energy policy of the Member States.


National Energy Efficiency Action Plan 2014-2020, adopted in July 2014

The NEEAP 2014-2020 is an acknowledgment that energy efficiency is of high importance in the long range energy strategy of the country. The NEEAP was developed in accordance with the requirements set out in Directive 2012/27/EU. It ensures the inclusion of all obligations under the EE Directive, as well as

taking into account the requirements of Directive 2010/31/EU on the energy performance of buildings.

In order to ensure improved energy efficiency, the NEEAP covers the following topics:

-Adoption of horizontal measures

-Energy efficiency obligatory schemes and alternative policy measures;

-Energy audits and management systems;

-Metering and billing measures;

-Adoption of consumer information programmes and trainings;

-Availability of qualification, accreditation and certification schemes; and

-Measures related to energy services.

-Buildings

The NEEAP refers to the National Long-Term Programme for the Mobilisation of Investments In the Implementation of Measures to Improve the Energy Performance of Buildings, which includes an overview of the national building stock (housing and public buildings), formulation of economically efficient approaches to improving the energy performance of buildings, taking into account the building

types and the climate zone and the State policy in the area of technical regulation and harmonisation of energy efficient legislation for the buildings sector.

-Buildings of public bodies

Referring to the Bulgarian EEA, the NEEAP provides that the measures to enhance the energy performance of at least five percent (5%) of the total floor area should be taken annually in all heated and/or cooled State-owned buildings occupied by the State administration. The State bodies should develop and adopt energy efficiency programmes and are bound to implement energy efficiency

management, including submitting of annual reports on energy efficiency management and the energy efficiency programmes to SEDA.

-Public sector

SEDA and the Public Procurement Agency have jointly developed Guidelines on the Application of Energy Efficiency and Energy-Saving Requirements When Awarding Public Contracts for the Supply of Equipment and Vehicles. In 2010, these Guidelines became an appendix to the Public Procurement Act. As a result, the Government and the local authorities are purchasing energy in a more efficient manner since 2010, further to the Instructions for Implementation of the Requirements for Energy Efficiency and Energy Savings in Public Procurement for the Supply of Equipment and Vehicles to Minimise Costs for the Duration of Their Exploitation.

Also, reference is made to the National Action Plan for the Promotion of Green Public Contracts 2012- 2014, which was developed and adopted in 2012.

-Industry

Bulgaria is focusing on overcoming the high energy intensity of its economy. Among others, the following measures have been adopted in the national legislation:

-the application of an integrated approach to the control of emissions from industrial sources on all components of the environment by issuing integrated permits;

-use of biomass in the combustion plants of the systems;

-energy efficiency audits and implementation of the measures prescribed; and

-development of public private partnerships for the implementation of energy efficiency measures.

-Transport

The growing energy demand in the transport sector is driven by the rapidly increasing number of vehicles and their annual mileage, which comes at the expense of a decrease in the use of the more energy efficient rail transport. A non-exhaustive list of measures to address this issue is provided in the National Climate Change Action Plan as follows:

-the rehabilitation and modernisation of the road infrastructure in order to allow for optimal travelling speeds and ensure that vehicle engines operate in the optimum mode;

-introduction of intelligent transport systems on national roads and in urban environments;

-reduction the relative share of trips with private motor vehicles by improving public urban transport and promoting non-motorised transport;

-increasing the share of electrified urban transport by rail, metro, trolleybuses and tramcars;

-development and promotion of the use of hybrid and electric vehicles;

-ensuring that fiscal policy stimulates savings and less use of conventional fuels;

-reduction the number of urban transport vehicles using conventional fuels by 2020; and

-trainings in energy efficient driving.

-Other topics covered by the NEEAP

-Promotion of efficient heating and cooling methods; and

-Energy transformation, transmission, distribution and demand response.

Funding required for the implementation of the measures provided in the NEEAP is provided partly by the State, Operational Programmes "Innovations and Competitiveness" 2014-2020, "Transport and Transport Infrastructure" 2014-2020 and Rural Development Programme 2014-2020.

Comparison

Bulgaria has implemented all requirements under Directive 2012/27/EU by adopting national plans and strategies, aimed at resolving the problems of energy efficiency in the major sectors with high reliance on energy. The long-term strategy and the NEEAP consider the relevant energy efficiency factors and propose corresponding solutions on how the ultimate goal can be achieved at a national level.

According to Directive 2012/27/EU, Bulgaria is obliged to set an indicative national energy efficiency target, taking into account national circumstances.

The NEEAP sets out a national indicative energy savings target for 2020 of 716 ktoe (kilotonne of oil equivalent)/y in final energy consumption (FEC) and 1,590 ktoe/year in primary energy consumption (PEP), of which 169 ktoe/year is from conversion, transmission and distribution in the energy sector. The contribution of each source to the achievement of the 2020 national energy savings target of 716 ktoe/year in FEC is as follows:

-203 ktoe/year from optimal utilisation of available financial resources; and

-486 ktoe/year from fulfilment of the individual targets of energy traders under the obligations scheme.

The national indicative energy efficiency target is defined as a forty one percent (41%) reduction in Bulgaria’s primary energy intensity ("PEI") in 2020 compared to its PEI in 2005.

The NEEAP is developed in accordance with the EED requirements on the basis of a template which ensures the inclusion of all obligations. The requirements of Directive 2010/31/EU on the energy performance of buildings are also taken into account.

The annual report on the implementation of the NEEAP in 2015 contains an evaluation of the progress towards the achievement of the national target – twenty six percent (26%) of the whole target was achieved in the period 2014-2015.

Article 4 of Directive 2012/27/EU requires Bulgaria to establish a long-term strategy for the renovation of buildings. The Bulgarian national long-term programme for the mobilisation of investments in the implementation of measures to improve the energy performance of buildings is part of the NEEAP. It includes an overview of the national building stock (housing and public buildings), formulation of economically efficient approaches to improving the energy performance of buildings, taking into account the building types and the climate zone and the State policy in the area of technical regulation and harmonisation of energy efficiency legislation for the buildings sector. The Programme creates a financial framework for guiding the investment decisions of investors, builders and financial institutions. Currently the Programme is under the process of revision and update.

Comparison

Bulgaria's set national indicative energy efficiency target is defined as a forty one percent (41%) reduction in Bulgaria’s PEI in 2020 compared to its PEI in 2005.

2. Specific Provisions of the Law

3. Obligations

4. Mandatory Audit of Large Industry

5. Strategies

6. Targets

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