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The energy efficiency law is not suitable for our economy
Dipl. Eng. Lyuben Mashkin, BNCIE *
AUTHOR: Atanas Georgiev

* BNCIE/BNKPE - Bulgarian National Committee for Industrial Energy
(the full version of the interview is in Bulgarian language)

Mr. Mashkin, what should be the place of energy efficiency in the energy policy of Bulgaria?

- The strong development of energy efficiency (EE) legislation in the last several years, which culminated in a stand-alone legislation for EE, is a result of our striving toward implementation of EU policies in this field and toward reaching the energy efficiency levels in other member-states. Unfortunately, the results that we have, are discredited because of many mistakes of our government.

For example, laws are being developed and voted without the presence of a national Energy Efficiency Strategy. The lack of strategy, unfortunately, is a vicious practice of our governments, which is also seen in the energy strategy project - it is developed without the presence of a national economic strategy.

There are other problems as well - we are transposing European legislation without considering the specifics of our economy and the way of thinking in Bulgaria. We have a legislation with very strong administrative, bureaucratic and sanctioning character, but there are no incentives. This is contradicting to the European practice in this field.

In addition to this, the factual fragmentation of the energy efficiency policy is present - three ministries are responsible for this matter: the Ministry of Economy, Energy and Tourism, the Ministry of Regional Development and Public Works, and the Ministry of Environment and Water. This is a serious hinder for efficient policy implementation and is contradicting to the sustainable energy sector development.

It is obvious that we need a governmental structure, which will unite all activities of the current three institutions in this field in order to conduct the sustainable energy development policy.

The strategic goals of such policy should be secure energy supplies; efficient use of energy resources; intensive use of renewable energy sources; and protecting the environment while producing and consuming energy resources.

What are the main flaws of the current national Law for Energy Efficiency and what changes should be made in it?

- The general concept of the energy efficiency improvement policy for our economy is not clear, or even almost not present. The law is a legislative basis, which should ensure the conditions for achieving the goals of the Strategy. In the same time, such strategy is not present. The existing Strategy for development of the energy sector until 2012, in which energy efficiency is also mentioned, is obsolete and we still do not have a new one.

The creation of an Energy efficiency strategy is a topic since a long time and there is some information on the development of a Concept and project for an Energy Efficiency Strategy, but it is still to enter into a discussion phase.

Several years ago a project for a National Energy Efficiency Strategy was developed with external financing, but it was not promoted and used, even though it was developed with broad implementation of the European practice in this field.

The current law is developed in a way to correspond to the Directive 2006/32/EC, but it also includes some new matters, which makes it a large document. The text is also full of texts which are meant to be in the secondary legislation, which makes it too detailed and creates difficulties in writing the secondary legislation.

The law divides vaguely the energy efficiency actions in two fields: buildings and industrial systems. These two parts are very different and could not be subjected to general conditions, especially if general conditions are meant for buildings. We are especially alarmed by the directive text in Article 1, Part 2, which leaves aside from the law a large part of energy consumers in our economy. According to this text, the following industries are not subject to this law: cement, glass, ceramic, chemical, metallurgical, etc. with the reason that they are subject to special environmental regulations. Using this approach, why buildings, which are subject to the regional development ministry, are inside this law?

This article should be removed as the energy efficiency in the latter industries is not limited only to diminishing of emissions, but includes as well improvement of energy supplies and increasing the competitiveness of production.

Besides this, there is no text currently in the law about energy efficiency in the transport sector, in agriculture, in water management, coal and metals mining, electricity and heat production, etc.

With these texts the law should be called “Energy efficiency for buildings and SMEs”.

It is a mistake that there is nothing about energy efficiency standards in this variant of the law. They are widely used in the European practice as an efficient measure for affecting and managing energy efficiency.

In the National Energy Efficiency Strategy, cited above, the energy efficiency standards are one of the main directions for implementing the policy in this field.

All the changes that we offer can be seen in the document attached (only in Bulgarian).

What are the hinders and what should be the incentives for consumers to invest in energy efficiency?

- The whole text of the law is full of obligations, requirements and sanctions, which make it too bureaucratic and pressing, in stead of supportive for consumers. The law is stressing on programs, plans and reports of economy measures, but there is nothing about energy efficiency management and about management of energy consumptions, which should be first and which is very needed. Even the change in the way of thinking is not set as a priority - so there are no measures for information, qualification, training, preparation, etc.

A difference between European and Bulgarian practice is that here the state administration works very weakly with NGOs, which is also illustrated by the energy efficiency law.

Also in the whole text there is still no word about credit lines for financing energy efficiency, which are very important for the implementation of these activities. There is something mentioned only about the Energy Efficiency Fund.

What is the effect of the law on energy services in Bulgaria?

- Currently the law is not creating conditions for competition and for lowering energy efficiency services prices, which is a contradiction to market economy principles. For instance, there is no clear mechanism for the relations between retail energy traders and end consumers without harming the interests of the former.

This law has a lobbyist nature, and creates conditions for business for very specific companies in the energy efficiency field - especially in the buildings sector.

A big hit on auditing companies was also the fact that large energy consumers were left outside the text of the law.


Dipl. Eng. Lyuben Mashkin is chairman of the Bulgarian National Committee for Industrial Energy (BNCIE/BNKPE).

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