review of the national air pollution control programme – bulgaria · 2020-06-12 · pollution...

Review of the National Air Pollution Control Programme – Bulgaria

___________________________________________________ Final Report for European Commission – DG Environment Specific contract 070201/2018/791186/SER/ENV.C.3

ED 11495 | Issue Number 4 | Date 17/03/2020

Review of the National Air Pollution Control Programme – Bulgaria | i

Ricardo Confidential Ref: Ricardo/ED11495/Issue Number 4

Ricardo Energy & Environment

Customer: Contact:

European Commission - DG Environment Natalia Anderson Ricardo Energy & Environment Gemini Building, Harwell, Didcot, OX11 0QR, United Kingdom

t: +44 (0) 1235 75 3055

e: [email protected]

Ricardo is certificated to ISO9001, ISO14001 and OHSAS18001

Customer reference:

070201/2018/791186/SER/ENV.C.3

Confidentiality, copyright & reproduction:

This report is the Copyright of European Commission. This document has been prepared by Ricardo Energy & Environment, a trading name of Ricardo-AEA Ltd under contract 070201/2018/791186/SER/ENV.C.3 dated 29/11/2018 for the European Commission, however it reflects the views only of the authors, and the Commission cannot be held responsible for any use which may be made of the information contained therein. The contents of this report may not be reproduced, in whole or in part, nor passed to any organisation or person without the specific prior written permission of European Commission. Ricardo Energy & Environment accepts no liability whatsoever to any third party for any loss or damage arising from any interpretation or use of the information contained in this report, or reliance on any views expressed therein, other than the liability that is agreed in the said contract

Author:

Gratsiela Madzharova

Approved By:

Natalia Anderson

Date:

17 March 2020

Ricardo Energy & Environment reference:

Ref: ED11495 - Issue Number 4

Review of the National Air Pollution Control Programme – Bulgaria | ii



Table of contents 1 Introduction ................................................................................................................ 4

Review of the National Air Pollution Control Programmes ................................................ 4

Methodology ...................................................................................................................... 5

NAPCP submission documents ........................................................................................ 6

2 Projected compliance with NECD emission reduction commitments .................... 9

Margin of compliance ........................................................................................................ 9

Projected compliance and consistency with projections submitted under Article 10(2) .. 10

3 Findings of the in-depth NAPCP review ................................................................. 14

NAPCP overview (M) ...................................................................................................... 14

Executive summary (O) ................................................................................................... 14

The national air quality and pollution policy framework (M, O) ....................................... 15

Progress made by current PaMs in reducing emissions and the degree of compliance with

national and EU obligations, compared to 2005 (M, O) .............................................................. 15

Projected situation assuming no change in currently adopted PaMs (M, O) .................. 16

Policy options considered to comply with emission reduction commitments for 2020 and

2030, intermediate emission levels for 2025 and stakeholder consultation (M, O) .................... 16

The policies selected for adoption by sector including timetable for adoption,

implementation and review and responsible competent authority (M, O) .................................. 20

Projected combined impacts of PaMs on emission reductions, air quality and the

environment and associated uncertainties (where applicable) (M, O) ....................................... 23

4 Conclusions and recommendations ....................................................................... 26

Recommendations .......................................................................................................... 27

Appendix 1 Completeness assessment

Appendix 2 Assessment of the risk of non-compliance

Review of the National Air Pollution Control Programme – Bulgaria | iii



Abbreviations

BaP Benzo(a)pyrene

BAT Best Available Technique

BC Black Carbon

CH4 Methane

CO2 Carbon dioxide

EEA European Environment Agency

EU European Union

GHG Greenhouse Gas

kt Kilo tonne

LTO Long-term objectives

NAPCP National Air Pollution Control Programme

NECD National Emission reduction Commitments Directive (Directive (EU) 2016/2284)

NECP National Energy and Climate Plans

NH3 Ammonia

NMVOC Non-Methane Volatile Organic Compounds

NO2 Nitrogen dioxide

NOX Nitrogen oxides

O3 Ozone

PaMs Policies and Measures

PM10 Particulate matter 10 micrometres or less in diameter

PM2.5 Particulate matter 2.5 micrometres or less in diameter

RAG Red; Amber; Green [rating]

SO2 Sulphur dioxide

WAM With Additional Measures

WHO World Health Organisation

WM With Measures

Review of the National Air Pollution Control Programme – Bulgaria | 4



1 Introduction

Review of the National Air Pollution Control Programmes

1.1.1 This report

The following report presents the results of the review of the National Air Pollution Control Programme

(NAPCP) submitted to the European Commission by Bulgaria on 26 September 2019.

EU Member States are required to prepare and report their NAPCP according to the minimum content

and common format (Commission Implementing Decision (EU) 2018/1522)1 stipulated by Article 6 of

the Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants2,

hereafter referred to as the Directive or the NECD3. The NAPCP should demonstrate compliance with

the Member State’s respective emission reduction commitments and set out how compliance will be

achieved.

This review has been undertaken alongside a review of national air pollutant emission projections

developed and reported by Member States under Article 10(2) of the NECD. These reviews have been

commissioned by the European Commission as Service Request 2 under the Framework Contract No

ENV.C.3/FRA/2017/0012 (specific contract 070201/2018/791186/SER/ENV.C.3).

The review of the first NAPCPs and of the air pollution projections with regards to their fulfilment of the

requirements of the NECD will both contribute to the Commission’s reporting on the implementation of

the NECD required under Article 11 of the NECD.

This report feeds into the horizontal review report under the contract which presents conclusions and

recommendations from the review at the EU-level. The horizontal report also contains, for each Member

State, an assessment of its risk of non-compliance with its emission reduction commitments, based on

a cross-analysis of the information provided in the NAPCPs and projection submissions under Article

10(2) of the NECD. This risk assessment is also presented in Appendix 2 to the present report, while

details on the methodology for that complete assessment are found in the horizontal report.

1.1.2 Objectives of the NAPCP review

The purpose of the following report is to determine Member State compliance with the requirements of

the NECD. The scope of the NAPCP review includes:

• The use of the NAPCP common format.

• NAPCP compliance with the minimum content requirements of the Directive (mandatory content

(M)).

• The extent to which the optional content requirements (O) of the Directive are reported and what

added value this brings to the quality of the NAPCP.

• Consistency between the NAPCP and the information in the air pollutant emission projections

that were due to be submitted by Member States by 15 March 2019.

• The extent to which Member States are reliant on additional PaMs (as included in the ‘With

Additional Measures’ (WAM) scenario) to achieve compliance.

1 Commission Implementing Decision (EU) 2018/1522 of 11 October 2018 laying down a common format for national air pollution control

programmes under Directive (EU) 2016/2284 of the European Parliament and of the Council on the reduction of national emissions of certain

atmospheric pollutants, OJ L 256, 12.10.2018, p. 87.

2 Directive (EU) 2016/2284 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, OJ L 344, 17.12.2016, p.1.

3 Directive (EU) 2016/2284 repeals and replaces the previous National Emission Ceilings Directive (2001/81/EC) and is generally referred to as the

new NECD or simply the NECD.




• The extent to which the evidence provided on selected PaMs is robust and the level of confidence

it provides that Member States will achieve their 2020 and 2030 emission reduction commitments.

• The extent to which additional PaMs are put forward in view of wider air quality objectives as

set out in Article 1(2) of the NECD (referring to the objectives of the Ambient Air Quality Directives,

the Union’s long-term objective of achieving levels of air quality in line with the air quality guidelines

of the World Health Organisation (WHO), the Union’s biodiversity and ecosystem objectives

and coherence with climate and energy policy priorities).

• The degree of coherence with other plans and programmes in other policy areas,

predominantly the National Energy and Climate Plans (NECP).

Methodology

The key components of the review process are outlined in Figure 1-1. A comprehensive description of

the process, methodology and checks followed are detailed in accompanying review guidelines which

were provided to the NAPCP reviewers responsible for conducting this report.

Figure 1-1 Overview of the NAPCP review methodology

A central review team was used to conduct the initial screening checks. The purpose of the initial

screening was to document Member State submissions in one central data log. For example, the

information recorded includes the date, language and length of the NAPCP submission; accompanying

annexes are similarly reviewed and logged and links to external websites are checked. The initial

checks also record if the Member State uses the NAPCP common format.

The completeness assessment and in-depth review checks are structured according to the section

headings of the NAPCP common format. Together, the review findings inform the extent to which the

NAPCP is compliant with the minimum content requirements, the extent to which evidence is robust

and the level of confidence that the Member State will achieve its commitments.

NAPCP completeness is rated according to a RAG rating (Red, Amber, Green rating as described in

Appendix 1) while the in-depth checks involve a series of questions with pre-defined responses to be

chosen from, designed to systematically determine the robustness and reliability of the evidence

submitted.




NAPCP submission documents

An overview of the Member State’s NAPCP is presented in the table below. This information was

gathered as part of the NAPCP initial screening.

Table 1-1 Overview of the Member State NAPCP submission documents

Initial screening check Response Additional comment

Was the NAPCP submitted by 1 April

2019? N

The NAPCP was submitted on 26

September 2019. The NAPCP was

submitted as a final. However, the

NAPCP clearly indicates that it will

be revised once a consultation with

the Ministry of Environment and

Water is completed.

Was the common format used? Y- fully

The NAPCP follows the Common

Format structures and makes use

of the tables provided within the

Common Format but also provides

additional information.

What is the length of the NAPCP? 107 pages

In addition, seven appendices

(totalling 62 pages) have been

submitted.

What language is the NAPCP reported in? Bulgarian

What language is the supporting

documentation reported in? Bulgarian

How many external documents are

referenced or provided in the NAPCP? 5

Is it possible to identify the required

information in the external documents (i.e.

is the page and chapter reference

provided)?

Y All relevant information is easy to

identify in external documents.

Can all external documents be accessed? Y

Working hyperlinks have been

provided for all six external

documents.

Completeness assessment

A completeness assessment was conducted to identify gaps in reporting according to the minimum

content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).

The completeness assessment also reviewed the extent of reporting of optional content by the Member

States. The results are presented in Appendix 1 to this review. To summarise, the Bulgarian NAPCP

includes the minimum content required for:

• Policy priorities and their relationship to priorities set in other relevant policy areas, described

in section 2.3.1 of the NAPCP.

• Responsibilities attributed to national, regional and local authorities, described in section 2.3.2

of the NAPCP.




• Progress made by current PaMs in improving air quality, and the degree of compliance with

national and Union air quality obligations, described in section 2.4.2 of the NAPCP.

• The current transboundary impact of national emission sources - described in section 2.4.3 of

the NAPCP.

• Projected emissions and emission reductions (WM scenario), described in section 2.5.1 of the

NAPCP.

• Projected impact on improving air quality (WM scenario) described in section 2.5.2 of the

NAPCP.

• 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, provided

in section 2.7.2 of the NAPCP.

• Projected attainment of emission reduction commitments (WAM), described in section 2.8.1 of

the NAPCP.

The completeness assessment found that the NAPCP has not included all minimum content required

for:

• Title of the programme, contact information and websites: A table similar to the one provided

in the common format of the NAPCP has been submitted but not fully completed. In particular,

the date of the NAPCP submission, the responsible competent authority’s contact details and

the links to the NAPCP and the consultation online have not been provided.

• Progress made by current PaMs in reducing emissions, and the degree of compliance with

national and Union emission reduction obligations: The progress made by current PaMs is

described with respect to the degree of compliance achieved. The information is presented in

section 2.4.1 of the NAPCP. However, no hyperlink to publicly available supporting datasets

has been provided.

• Details concerning the PaMs considered in order to comply with the emission reduction

commitments (reporting at PaM level): All information on considered PaMs has been included

in section 2.6 of the NAPCP, however, Bulgaria has not reported this information via the EEA

PaM-tool.

• Impacts on air quality and the environment of individual PaMs or packages of PaMs considered

in order to comply with the emission reduction commitments: This information is not presented.

• 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: All

information on considered PaMs has been included in section 2.6.4 of the NAPCP, however,

Bulgaria has not reported this information via the EEA PaM-tool.

• Individual PaMs or package of PaMs selected for adoption and the competent authorities

responsible: All information on selected PaMs has been included in section 2.7 of the NAPCP,

however, Bulgaria has not reported this information via the EEA PaM-tool.

The NAPCP states that missing contact information and websites links will be provided following the

completion of the consultation process, referring to a consultation with the Bulgarian Ministry of

Environment and Water.

The Member State has reported the following optional content from the NAPCP common format:

• An executive summary has been provided in section 2.2 of the NAPCP.

• The source sectors under the responsibility of the state authority are described in section 2.3.2

of the NAPCP.

• Histograms have been used to demonstrate the progress achieved by current PaMs in reducing

emissions in section 2.4.1 of the NAPCP.




• The data source and methodology for quantitative estimates of transboundary impact have

been provided in section 2.4.3 of the NAPCP.

• The estimation of costs and benefits has been reported for one of the packages of PaMs in

section 2.6.3 of the NAPCP. This information is not provided for all PaMs.

• Measures to reduce NH3 emissions from livestock and a national advisory code of good

agricultural practices for the proper management of harvest residue are included in section

2.6.4.

• Interim targets and objectives for the implementation of selected PaMs have been included in

section 2.7.1 of the NAPCP.

• The projected improvement in air quality under the WAM scenario has been described in

qualitative terms for PM10 and PM2.5 in section 2.8.4 of the NAPCP.




2 Projected compliance with NECD emission

reduction commitments

Margin of compliance

There are several different metrics that can be used to show the “margin of compliance” i.e. the margin

by which compliance with the NECD emission reduction commitments is achieved or missed.

The following two approaches have been used in the overall assessment of NAPCPs and projections

to calculate the margin of compliance:

1. Calculating the difference between an emission reduction commitment and the

projected emission reductions (difference expressed in percentage points) – this

approach is presented in the NAPCP review reports and follows the same approach as required

in the NAPCP format. The emission reduction commitments specified in Annex II of the NECD

are defined as percentage reductions on the 2005 emissions. Projected emissions of pollutants

in 2020 and 2030 are compared to the 2005 emissions to calculate the projected emission

reductions. These projected reductions are then divided by the 2005 emissions to obtain the

projected reductions as a percentage of the 2005 emissions. These percentage reductions are

then compared to the legally binding percentage reduction, with the difference between them

representing the compliance margin expressed as percentage points. As such, negative

percentage points indicate that the emission reduction commitment will not be met.

Figure 2-1 The margin of compliance

Example

A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment

for 2020. If the 2020 projected emission is 360 kt, the projected emission reduction is 140 kt. This

equates to 28% of 2005 emissions. The projected margin of compliance is 8 percentage points. This

is illustrated in the figure below.

200

250

300

350

400

450

500

550

2005 2010 2015 2020

Emission reduction commitment

(% of 2005 emission)

Compliance margin

Compliance threshold




2. Calculating the difference between projected emissions and the compliance threshold

(expressed as a percentage of the compliance threshold) – this approach is presented in

the projections review reports and follows the same approach as used in the context of

emissions inventories.

Given that each emission reduction commitment specified in Annex II of the NECD is defined as a

percentage reduction on the 2005 emissions, these two values can be combined to express a

“compliance threshold” i.e. the maximum emission that can be emitted by a Member State from 2020

and 2030 onwards, and still be compliant with the emission reduction commitment for a pollutant.

Projected emissions (under the WM and WAM scenarios) can be compared to the compliance

threshold, and the compliance margin expressed as a percentage of the compliance threshold.

Example

A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment

for 2020. The maximum the Member State can emit in 2020 to achieve its 2020 emission reduction

commitment (the “compliance threshold”) is 400 kt. If the 2020 projected emission is 360 kt, the

commitment will be met by 40 kt and the projected margin of compliance is 10% of the compliance

threshold.

Mathematically these two approaches are different as they use different reference points. However,

they yield the same conclusions concerning compliance or non-compliance with the NECD

reduction commitments. The largest numerical differences between the two approaches occur when

there are significant differences between the 2005 emissions and the projected emissions for 2020 or

2030 (this is in particular the case for SO2).

The percentage point approach is used in the review of the NAPCP to understand the margin of

compliance between the projected emission reductions presented in the NAPCP and the legally binding

percentage emission reduction commitments (see Section 2.2 of this report).

The results of the projections review and of the assessment of the NAPCPs are brought together in the

risk assessment for individual Member States (see Appendix 2 of this report), using the margin of

compliance expressed as a percentage of the compliance threshold based on projections submitted

under Article 10(2). The methodology for assessing the risk of non-compliance is explained in the

accompanying horizontal review report.

Projected compliance and consistency with projections

submitted under Article 10(2)

• Under the WM scenario, Bulgaria is projected to achieve its 2020-2029 emission reduction

commitments for SO2, NOX and NH3 only. With respect to 2030 onwards emission reduction

commitments, these will be achieved only for SO2 and only by 1 percentage point.

• Under the WAM scenario, Bulgaria is projected to achieve its 2020-2029 and 2030 onwards

emission reduction commitment for all pollutants

The projections presented in this section are derived from the information reported by the Member State

in their NAPCP. Bulgaria’s NAPCP included 2019 projections using historical inventory data with the

reference year of 2016. The same reference year is reported as being used for the projections data

submitted separately by the Member State under the Directive on 18 June 2019. However, the values

in the projections included in the NAPCP for SO2 and NOX in the WM scenario differ slightly (by

approximately 1kt/year) from those submitted for the projections reporting. Nevertheless, the two sets




of projections lead to the same conclusions with respect to attainment of the emission reduction

commitments.

In Figure 2-2 and Figure 2-3, the emission reductions needed for 2025 are interpolated according to the

2020-29 and 2030 onwards commitments set out in the NECD. Additional information is included to

demonstrate the extent to which the projections meet the Member State commitments (shown, for each

of the pollutants, as the difference expressed in percentage points between the projected emission

reduction described in the NAPCP and the legal commitment). The percentage points do not represent

the extent to which total emissions projected (kt) compare to the emission reduction commitment (in

terms of kt of emissions).

Under the WM scenario, progress towards the 2020-29 emission reduction commitments is as

follows:

• SO2 – The projections of SO2 emissions under the WM scenario show that Bulgaria can comply

with the 2020-29 reduction commitments specified in the NECD with existing measures. In

2020, compliance is projected to be achieved with a margin of 11 percentage points.

• NOX - The projections of NOX emissions under the WM scenario show that Bulgaria can comply



• NMVOC - The projections of NMVOC emissions under the WM scenario show that Bulgaria

cannot comply with the 2020-29 reduction commitments specified in the NECD with existing

measures. In 2020, compliance is projected to be missed with a margin of 5 percentage points.

• NH3 - The projections of NH3 emissions under the WM scenario show that Bulgaria can comply



• PM2.5 - The projections of PM2.5 emissions under the WM scenario show that Bulgaria cannot

comply with the 2020-29 reduction commitments specified in the NECD with existing measures.

In 2020, compliance is projected to be missed with a margin of 14 percentage points.

Under the WM scenario, progress towards the 2030 onwards commitments is as follows:

• SO2 – The projections of SO2 emissions under the WM scenario show that Bulgaria can comply

with the 2030 onwards reduction commitments specified in the NECD with existing measures.

However, compliance is projected to be achieved with a margin of 1 percentage point.

• NOX - The projections of NOX emissions under the WM scenario show that Bulgaria cannot

comply with the 2030 onwards reduction commitments specified in the NECD with existing


• NMVOC - The projections of NMVOC emissions under the WM scenario show that Bulgaria

cannot comply with the 2030 onwards commitments specified in the NECD with existing


• NH3 - The projections of NH3 emissions under the WM scenario show that Bulgaria cannot

comply with the 2030 onwards commitments specified in the NECD with existing measures. In

2030, compliance is projected to be missed with a margin of 3 percentage points.

• PM2.5 - The projections of PM2.5 emissions under the WM scenario show that Bulgaria cannot

comply with the 2030 onwards commitments specified in the NECD with existing measures. In

2030, compliance is projected to be missed with a margin of 1 percentage points.




Figure 2-2 Projected attainment of emission reduction commitments (WM scenario used in the NAPCP)

Note: The extent to which the projections meet the Member State commitments is shown, for each of the pollutants,

as the difference expressed in percentage points between the projected emission reduction described in the

NAPCP and the legal commitment. A negative number indicates that the commitment is projected to be missed.

The projections under the WM scenario demonstrate a gap in compliance with the Member State’s

NECD emission reduction commitments for certain pollutants, so the NAPCP includes projections under

a ‘With Additional Measures’ (WAM) scenario.

Under the WAM scenario, progress towards the 2020-29 emission reduction commitments is as

follows:

• SO2 – The projections of SO2 emissions under the WAM scenario show that Bulgaria can

comply with the 2020-29 reduction commitments specified in the NECD with additional

measures. In 2020; compliance is projected to be achieved with a margin of 12 percentage

points.

• NOX - The projections of NOX emissions under the WAM scenario show that Bulgaria can


measures. In 2020, compliance is projected to be achieved with a margin of 8 percentage

points.

• NMVOC- The projections of NMVOC emissions under the WAM scenario show that Bulgaria

can comply with the 2020-29 reduction commitments specified in the NECD with additional

measures. However, compliance is projected to be achieved with a margin of 2 percentage

points.

• NH3 - The projections of NH3 emissions under the WAM scenario show that Bulgaria can comply

with the 2020-29 reduction commitments specified in the NECD with additional measures. In





• PM2.5 - The projections of PM2.5 emissions under the WAM scenario show that Bulgaria can



points.

Under the WAM scenario, progress towards the 2030 and beyond commitments is as follows:

• SO2 – The projections of SO2 emissions under the WAM scenario show that Bulgaria can

comply with the 2030 onwards reduction commitments specified in the NECD with additional

measures. However, in 2030, compliance is projected to be achieved with a margin of 1

percentage point (same as the WM scenario).

• NOX - The projections of NOX emissions under the WAM scenario show that Bulgaria can


measures. However, in 2030, compliance is projected to be achieved with a margin of 1

percentage point.

• NMVOC- The projections of NMVOC emissions under the WAM scenario show that Bulgaria

can comply with the 2030 onwards reduction commitments specified in the NECD with

additional measures. However, in 2030, compliance s is projected to be achieved with a margin

of 1 percentage point.

• NH3 - The projections of NH3 emissions under the WAM scenario show that Bulgaria can comply

with the 2030 onwards reduction commitments specified in the NECD with additional measures.

However, in 2030, compliance is projected to be achieved with a margin of 3 percentage points.

• PM2.5 - The projections of PM2.5 emissions under the WAM scenario show that Bulgaria can



points.

Figure 2-3 Projected attainment of emission reduction commitments (WAM scenario used in the NAPCP)




Note: The extent to which the projections meet the Member State commitments is shown, for each of the pollutants,

as the difference expressed in percentage points between the projected emission reduction described in the

NAPCP and the legal commitment.

Further analysis related to the risk of non-compliance, taking into account the information provided in

both the NAPCP and the projections submissions, is presented in Appendix 2.

3 Findings of the in-depth NAPCP review

NAPCP overview (M)

• Bulgaria submitted its NAPCP on 26 September 2019.

• The NAPCP adheres to the common format specified by the Commission Implementing Decision

(EU) 2018/1522, pursuant to Article 6 of the NECD.

The NAPCP adheres to the common format specified by the Commission Implementing Decision (EU)

2018/1522, pursuant to Article 6 of the NECD. The NAPCP is made up of one main report of 107 pages

in length. It is accompanied by seven appendices (totalling 62 pages). The complete submission was

made on 26 September 2019. Information on PaMs was reported via the EEA-PaM tool on 17

December 2019.

Of the six external links provided, all are in working order. External references are publicly available.

The references are of the following types:

• One link to Commission Implementing decision (EC) 2018/15;

• Two references to national strategies in the area of innovation and development developed by

relevant national authorities;

• One reference to the National Programme on Atmospheric Air Quality;

• One reference to annual air quality reports;

• One reference to a 2014 IIASA report on urban PM2.5.

The NAPCP indicates that the website link to the NAPCP will be provided at a later stage. The

responsible authority for the NAPCP is the Ministry of Environment and Water. No contact details for

the responsible authority have been provided at this stage. The NAPCP clearly states that these will be

provided at a later stage in a revised version of the NAPCP.

Bulgaria has not clearly indicated whether a consultation has been performed. In section 2.1 of the

NAPCP, Bulgaria has stated that a link to the online consultation will be provided following further

consultations with the Ministry of Environment and Water. Upon review of Bulgarian governmental

websites, it was established that a consultation was completed on 24 July 20194.

The NAPCP states that transboundary pollution from domestic sources is relevant to Bulgaria. The

NAPCP includes the results from the modelling of transboundary impacts, however, no indication of

transboundary consultation being conducted has been provided.

Executive summary (O)

The executive summary follows the common format of the NAPCP (nine pages in length). The

information included in the summary is consistent with the information included in the main body of the

NAPCP.

4 Consultation website, http://www.strategy.bg/PublicConsultations/View.aspx?lang=bg-BG&Id=4466

http://www.strategy.bg/PublicConsultations/View.aspx?lang=bg-BG&Id=4466




The national air quality and pollution policy framework (M, O)

According to the EEA country fact sheet5, the pollutants that represented a challenge to Bulgaria

between 2012 and 2016 included NO2, PM10, PM2.5, O3 and BaP. These are broadly consistent with the

key air quality pollutants identified in section 2.3 of the NAPCP (SO2, NO2, PM10, PM2.5 and O3).

Although BaP has not been included as a priority pollutant in section 2.3, Annex I to the NAPCP clarifies

that the target value for the concentration of BaP in PM10 is 1 ng/m3 and it has not been exceeded since

2012.

The climate change and energy policy priorities listed in the NAPCP refer to the objectives of the

National Energy and Climate Plans. The policy priorities also include objectives on renewable energy

sources and energy efficiency. Furthermore, Bulgaria’s policy priorities for the agriculture, industry and

transport sectors have been included in the NAPCP.

The Bulgarian NAPCP clearly describes the roles attributed to national, regional and local authorities.

Regulatory roles have been assigned to the National Assembly, the Council of Ministers, all Ministries

dealing with the relevant sectors, such as the Ministry of Environment and Water and the Ministry of

Economics, and to municipalities. The implementation and executive roles are shared between

Ministries and national agencies such as the State Agency for Metrological and Technical Surveillance,

Environmental Executive Agency and the Forestry Executive Agency. Overall, there is some overlap

between the type of roles attributed to different authorities. It is unclear whether the set up ensures

coordination and cohesion between different authorities.

Progress made by current PaMs in reducing emissions and

the degree of compliance with national and EU obligations,

compared to 2005 (M, O)

3.4.1 Progress made by current PaMs in reducing emissions

While the progress achieved by current PaMs has been described in section 2.4.1 of the NAPCP, no

information has been provided on the current PaMs driving these emission reductions. The NAPCP

briefly mentions that the progress has been achieved mainly due to policies which were implemented

in response to EU transport policy but does not provide further detail. The emission reductions are

described annually per pollutant and sector for the period between 2005 and 2016.

The NAPCP does not explain whether any PaMs targeting NH3, PM2.5 and black carbon from the

agriculture sector have been introduced.

Bulgaria has used histograms to illustrate the emission reductions per pollutant and sector.

3.4.2 Progress made by current PaMs in improving air quality

The Bulgarian NAPCP indicates that PM10, PM2.5 and PAH represent a key challenge for improving air

quality.

The impacts of current PaMs on improving air quality have been described in section 2.4.2. However,

as in the case of emission reductions, no information has been provided on what current PaMs have

contributed to improved air quality other than for the agriculture sector.

The impacts of current PaMs in improving air quality have been expressed in terms of a number of air

quality zones where air quality limits were exceeded per year, between 2005 and 2016. For the

pollutants SO2, NO2 and CO2 the number of exceedances gradually decline over the years whereas for

5 Air pollution country fact sheets 2018: https://www.eea.europa.eu/themes/air/country-fact-sheets/2018-country-fact-sheets [last accessed:

30/01/2019]

https://www.eea.europa.eu/themes/air/country-fact-sheets/2018-country-fact-sheets




PM10, PM2.5 and PAH no significant changes are observed. This indicates the need for additional PaMs

to target pollutant concentration reductions for the three pollutants.

No example graphics have been included to illustrate the impacts of current PaMs on air quality trends.

3.4.3 Current transboundary impact of national emission sources

The current transboundary impacts of domestic emission have been described quantitatively based on

the outputs of modelling presented in the reports by EMEP6. Maps illustrating the dispersion of NOX,

SO2, PM2.5, NH3 and NMVOC across neighbouring countries are included.

No information is provided on whether a transboundary consultation has been performed or is planned.

Projected situation assuming no change in currently adopted

PaMs (M, O)

The projected situation assuming no change in currently adopted PaMs is presented in Section 2.5 of

the NAPCP. As discussed in Section 2 of this report, according to the NAPCP projections under the

WM scenario Bulgaria is projected to miss the 2020-2029 emission reduction commitments for NMVOC

and PM2.5 and the 2030 onwards emission reduction commitments for all pollutants apart from SO2.

Furthermore, according to the NAPCP projections under the WM scenario, emission levels are

projected to increase for SO2 and NH3 between 2020 and 2025. Overall, additional PaMs are required

to comply with the emission reduction commitments specified in the NECD.

The emissions projections in the NAPCP are from 27 January 2019 and are derived from 2016 historical

emissions inventory data. As these projections were developed only eight months prior to the

submission of the NAPCP they are expected to capture all current PaMs in the WM scenario.

The qualitative description of the projected improvements in PM10 and PM2.5 emission concentrations

states that with no additional measures, exceedances could be expected in several air quality zones.

Policy options considered to comply with emission reduction

commitments for 2020 and 2030, intermediate emission

levels for 2025 and stakeholder consultation (M, O)

• Seven PaMs have been considered across three different sectors, namely agriculture, transport,

and residential heating.

• The information has not yet been reported via the EEA PaM-tool. The NAPCP states that this will

be done in due course.

3.6.1 Summary of the information reported

The assessment presented in this section is based on the information reported in the main body

(Section 2.6) of the NAPCP. Bulgaria has not reported PaMs via the EEA PaM-tool.

Bulgaria has considered seven additional PaMs. Two of these are for agriculture, three are for energy

consumption for residential heating and the remaining two are for transport. The three PaMs considered

for residential heating have been included in a package, whereas the remaining PaMs are considered

as single PaMs.

6 https://www.emep.int/publ/reports/2016/Country_Reports/report_BG.pdf

https://www.emep.int/publ/reports/2016/Country_Reports/report_BG.pdf




The considered PaMs are sufficiently clear. All PaMs in the residential heating sector are proposed as

a part of the National Programme for Action on Atmospheric Quality 2018-2024.

Energy consumption (A single package of 3 PaMs)

Introduction of national requirements for coal quality, legislative measures to reduce the moisture

content of wood for heating used in municipalities currently in excess of PM10 standards and the

possible introduction of maximum moisture content requirements for firewood in the same regions.

Earlier introduction of Regulation (EU) 2015/1185 with regard to the ecodesign requirements for solid

fuel space heaters. Mandatory accelerated phase-out of traditional solid fuel heaters (stoves) in

municipalities where air quality does not meet the PM10 pollutant concentration limit values.

Households affected by the compulsory withdrawal of traditional stoves to switch to natural gas-fired

boilers, district heating, electric heating or heating appliances that meet the ecodesign requirements.

Transport (2 single PaMs)

Modernising the fleet by restricting vehicle imports to low-emission vehicles.

The creation of low emission zones in Sofia and Plovdiv in order to limit access for high polluting

means of transport.

Note: All PaMs have been selected for adoption.

3.6.2 Pollutants targeted and projected emission reductions

The pollutants for which the emission reduction commitments are projected to be missed under the WM

scenario are NOX, NMVOC, NH3 and PM2.5. The considered PaMs are reported to reduce emissions of

all of these, as well as SO2. In terms of numbers of considered PaMs per pollutant: five PaMs are

expected to reduce NOX emissions, five for NMVOC, five for PM2.5, three for NH3 and three for SO2.

Some PaMs will reduce emissions of more than one pollutant. The PaMs considered do not address

BC separately to PM2.5.

Emission reductions of considered PaMs have been quantified only at the package level for the PaMs

included in a package (for energy consumption for residential heating), and for the individual PaM level

for single PaMs. The expected emission reductions are reported in kilo tonnes per year for 2020, 2025

and 2030.

Table 3-1 presents the total emission reductions estimated for PaMs considered for adoption, as

presented in the NAPCP. The NAPCP states that the same information will be submitted via the EEA-

PaM tool.

Agriculture (2 single PaMs)

Application of rules on best agricultural practice for fertilisers use.

Application of best agricultural practice for manure management.




Table 3-1 Projected total emission reductions from the PaMs considered for adoption (kt/ year)

Pollutant 2020 2025 2030

SO2 1.8 2.0 2.1

NOX 3.6 5.9 10.8

NMVOC 5.8 9.2 9.6

NH3 1.3 2.9 3.0

PM2.5 6.7 11.3 10.7

The PaMs considered target pollutants with the greatest compliance gap with the emission reduction

commitments. When comparing the total emission reductions estimated for PaMs considered for

adoption (Table 3-1) to a 2005 baseline, the PaMs considered expect to deliver the following emission

reductions in 2020, 2025 and 2030:

• SO2: 0.2 percent in 2020, 0.3 percent in 2025 and 2030.

• NOx: 2 percent in 2020, 3 percent in 2025 and 6 percent in 2030.

• NMVOC: 7 percent in 2020, 11 percent in 2025 and 12 percent in 2030.

• NH3: 3 percent in 2020, 3 percent in 2025 and 6 percent in 2030.

• PM2.5: 22 percent in 2020, 37 percent in 2025 and 35 percent in 2030.

3.6.3 Coherence between the PaMs considered and policy priorities

According to the policy priorities outlined in section 2.3 of the NAPCP, action should be prioritised in

the following areas:

• electricity production and energy consumption;

• mobility management and control of emissions from road transport, mainly in urban areas;

• NH3 emissions from fertilisation of agricultural land and from livestock farming;

The considered PaMs relate to energy production and consumption, transport and agriculture which

correspond to these policy priorities.

3.6.4 Responsible authorities and timescales for implementation of PaMs considered

The considered PaMs have been described as the following types of instruments in the NAPCP:

pollution control direct to source (four PaMs), awareness-raising (four), regulatory (three), voluntary

(two) and fiscal (one). All single PaMs and the package of PaMs have been assigned several types of

instruments to ensure full implementation. While the promotion of certain behaviours and/or awareness-

raising is an instrument for implementing most of the PaMs, for which there is lower certainty of success,

other instruments are also indicated which improves the likelihood of the intended effects being

achieved. Overall, this represents a balanced approach.

Responsibility for implementation of the seven PaMs has been assigned across ministries, national

agencies, regional authorities and private companies. The actors involved by sector are as follows:

• Energy consumption (residential heating): The Ministry of Economic Affairs, the Ministry of

Environment and Water, Ministry of Agriculture, Food and Forestry, Ministry of Labour and

Social Policy, the Forest Executive Agency, State forest enterprises and municipal forestry

structures, regional authorities, State agency for metrological and technical surveillance,

Sustainable Energy Development Agency, Residential heating companies and firms.




• Transport: Ministry of Transport, Information Technology and Communications Ministry of

Internal Affairs, Ministry of Regional Development, Road Transport Administration.

• Agriculture: The Ministry of Agriculture, Forestry and Food.

Overall, the responsibilities are spread across all levels of governance and involve all relevant actors.

However, it should be recognised that adequate coordination will be necessary in the presence of so

many actors involved.

None of the PaMs considered by Bulgaria were in place prior to the development of the NAPCP,

according to the information presented in section 2.6 of the NAPCP. The start of the PaMs

implementation period is planned for 2020 and ends in 2030. This allows 10 years for the individual

PaMs and packages of PaMs to be implemented and deliver the required emission reductions, which

is considered realistic.

3.6.5 Details of the methodology for evaluation and selection of PaMs

Table 14 in section 2.6 of the NAPCP provides information about the methodology for the evaluation

and selection of PaMs. For PaMs in the energy consumption (residential heating) sector a bottom-up

analysis approach was used, and for PaMs in the transport sector, the COPERT model was used.

Finally, measures in the agriculture sector were evaluated by national experts. The NAPCP does not

clearly detail the bottom-up analysis and expert evaluation approaches followed. Additional cost-benefit

analysis has been conducted for measures in the residential heating sector, as explained in section

2.6.3 of the NAPCP.

3.6.6 Estimation of costs and benefits of the individual PaM or package of PaMs

considered

In section 2.6.3, the cost and benefits have been presented for four individual PaMs in the residential

heating sector. These correspond to the three considered PaMs identified earlier in this sector but with

an additional breakdown to more specific policy actions. The total investment for these measures is 426

million EUR from 2016 to 2030 on the basis of 2018 prices. The most expensive measures include the

early adoption of the solid fired space heaters meeting eco-design standards (276 million EUR until

2030), followed by the transition to heating with natural gas (100 million EUR until 2030).

The benefits valuation only considers PM2.5. The estimated cost per tonne of abated PM2.5 ranges from

715 EUR to 11 297 EUR. In all instances, the benefits of implementing the measures outweigh the

associated costs. The highest benefit/cost ratio (6) is observed for the transition to natural gas for

heating.

3.6.7 Impacts on air quality and the environment of individual PaMs or packages of

PaMs considered

Section 2.6.2 of the NAPCP provides only a qualitative explanation of the air quality benefits of the

PaMs considered for adoption. It explains that the full implementation of PaMs considered in the

residential heating sector could lead to 80 percent reduction of PM10 emissions and significantly improve

compliance with air quality limits in all air quality zones. Actions in the transport sector would further

contribute to improved compliance with air quality standards. The NAPCP states that NMVOC and NH3

emissions would also be reduced as a result of the considered PaMs, thus delivering further air quality

benefits.




The policies selected for adoption by sector including

timetable for adoption, implementation and review and

responsible competent authority (M, O)

• All PaMs considered have been adopted. The total emission reductions estimated for the

considered PaMs are similar to the additional emission reductions projected under the WAM

scenario.

• The PaMs have been proposed on the basis of emission reductions and consistency with national

policy priorities. The total emission reductions achieved by the considered PaMs are largely

consistent with the additional emission reductions projected under the WAM scenario.

• All mandatory and optional PaMs in the agriculture sector described in Annex III Part 2 of the

NECD have been or are in the process of being introduced in Bulgaria, according to the NAPCP.

• The PaMs are well described and the types of PaMs selected are relevant and matches the main

pollution challenges; however, there is a risk that the transport PaMs may not lead to the

estimated emissions reductions, the energy consumption PaMs may be difficult to implement or

enforce and the agriculture PaMs rely on voluntary uptake.

• Funding sources are not identified which may affect the credibility of the PaMs proposed for

adoption.

3.7.1 Assessment of the credibility of the PaMs selected for adoption per sector

According to section 2.7 of the Bulgarian NAPCP, all considered PaMs have been selected for adoption

and included in the WAM scenario. In comparison to the information listed in section 2.6. of the NAPCP,

the proposed implementation periods listed for selected PaMs are between 2019 and 2030 rather than

2020 and 2030. The PaMs have been selected on the basis of their projected impact in reducing

pollutant emissions and improving air quality, as well as on the basis of their consistency with national

policy priorities and existing policies.

Since all PaMs considered have been selected for adoption, the projected emission reductions from

PaMs selected for adoption are the same as presented in Table 3-1. Overall, the projected emission

reductions from the additional PaMs are largely consistent with the additional emission reductions

projected under the WAM scenario included in the NAPCP. The only exception is for PM2.5 emission

reductions in 2025 for which the difference is of 1% and could be attributed to rounding error.

Sections 2.6 (PaMs considered for adoption) and section 2.7 (PaMs selected for adoption) provide

detail for PaMs in all sectors, including specific actions, implementation periods, interim targets and

indicators, and planned implementation reviews. The key information provided for PaMs in each sector

and the credibility of the PaMs are described below.

Energy consumption (residential heating)

According to the information presented in sections 2.6 and 2.7 of the NAPCP, the actions associated

with the implementation of the selected PaMs for the residential heating sector include:

• Implementation and compliance with requirements for wood as a household fuel;

• Shifting from traditional stoves to natural gas-fired appliances with a dispersed gas supply network

(using ready-to-use connections or new connections to existing network);

• Switching from conventional stoves to district heating networks (using ready connections or new

connections to existing networks);




• Transition from traditional stoves to eco-labelled stoves.

The following interim indicators have been listed to track the implementation of the PaMs:

• The introduction of regulation on the use of coal in residential heating in 2019.

• Information awareness campaigns to be conducted with residents from 2019 onwards.

• The introduction of regulations on wood-burning in residential heating in 2020.

• Replacement of all stoves by 2025 in municipalities that are currently not meeting the air quality

pollutant concentration requirements.

The NAPCP does not present information on specific challenges related to the implementation of the

PaMs. All PaMs included in the residential heating package will be implemented through regulatory

instruments, direct emission control at source and information instruments. Some of the PaMs for this

sector may be difficult to implement and enforce which would impact their credibility. For instance, the

implementation of requirements on the use of wood for domestic heating would require an assessment

of how much wood is purchased from regulated traders and how much is self-gathered. In addition, the

NAPCP review finds that the interim indicator of replacing all stoves by 2025 in municipalities which are

not compliant with air quality requirements may be challenging to implement in practice.

The PaMs for this sector are the only ones that are projected to contribute to SO2 emission reductions

and are estimated to deliver the greatest emission reductions of NMVOC and PM2.5; contributing to 93

percent of the additional reductions for both pollutants in 2030 under the WAM scenario.

Transport

According to the information presented in sections 2.6 and 2.7 of the NAPCP, the actions associated

with the implementation of the selected PaMs for the transport sector include:

• Reducing emissions from transport by only permitting imports of low-emission vehicles;

• The introduction of Clean Air Quality Zones in Sofia and Plovdiv.

The following interim indicators have been listed in the NAPCP to track the PaMs implementation

progress:

• The introduction, approval and implementation of regulatory measures;

• Quantitative results from the restrictions on vehicle imports;

• Conducting research to inform the development of Clean Air Quality Zones;

• Estimating the impacts of Clean Air Quality Zones;

The NAPCP does not present challenges related to the implementation of the PaMs. It also does not

explain how the restriction of imports of high-emission vehicles will lead to a shift in consumer

behaviour. It is possible that people may prefer to keep their cars for longer rather than purchasing new

and more expensive low-emission vehicles or would prefer buying cheaper vehicles that are not low-

emission from second-hand vehicle vendors. Overall, the willingness of consumers to buy low-emission

vehicles could play a key role in the successful implementation of this PaM. Although Clean Air Zones

can be successful in reducing ambient air pollutant concentrations in specific areas, they may increase

air pollutant concentrations elsewhere through diverting traffic. Therefore, there is uncertainty with

respect to the potential of this PaM to achieve net pollutant emission reductions.

The restriction on vehicle imports will be implemented through regulatory instruments and direct control

of emission at the source. In comparison, Clean Air Quality Zones will be implemented through

regulatory, economic and awareness raising instruments.

PaMs in this sector are the main contributors to NOX emission reductions contributing to 84 percent of

the additional reductions in the WAM scenario in 2030. While the introduction of Clean Air Quality Zones

is a credible PaM, it has limitations that may hinder the attainment of emission reductions in practice.




The restriction of import of high-emission vehicles assumes modal shift, which by definition diminish the

credibility of the PaM.

Agriculture

Section 2.6.4 of the NAPCP provides a comprehensive overview of current PaMs in the agriculture

sector, key gaps, and additional measures considered and selected to address the emission reduction

gap.

Bulgaria has already established a draft Code of Good Agricultural Practice for the Control of NH3

Emissions and a National Nitrogen Budget. The draft Code includes actions such as nitrogen

management taking in consideration the full nitrogen cycle, animal feed strategies, low-emission

housing systems for animal housing, approaches to low-emission manure storage and application and

approaches to NH3 using mineral fertilisers. Therefore, the Code fully complies with the requirements

laid down in Annex III Part 2 of the NECD. Once approved, the Code will be distributed amongst

agricultural actors.

The Code is used for the implementation of the additional measures in the agriculture sector which are

included in the WAM projections. The additional PaMs selected for adoption recommend the application

of best practices in fertiliser use and manure management. While the NAPCP does not clearly explain

if the Code is mandatory or voluntary, the two measures in the agriculture sector have been listed as

voluntary/negotiated procedure instruments which suggest that the code is voluntary. Due to the

voluntary nature of the additional PaMs, there is uncertainty how it will be enforced and thus whether

the projected emission reductions from the agriculture sector in the WAM scenario can be achieved.

The PaMs selected for adoption in the agriculture sector are the only ones to provide additional NH3

emission reductions under the WAM scenario in 2030. Apart from voluntary/ negotiated procedure

instruments, the PaMs have been defined as instruments for pollution control at source, information and

educational campaigns. There is an overall uncertainty of whether the voluntary requirements would

lead to emission reductions in practice.

3.7.2 Feedback from the consultation undertaken

Despite clear evidence that the stakeholder consultation was completed at the time the Bulgarian

NAPCP was submitted, Bulgaria has not included any relevant feedback arising from the consultation

with respect to selected PaMs. Bulgaria has stated that the feedback would be integrated into the

NAPCP at a later stage; however, it has not provided any explanation of this approach.

3.7.3 Sources of funding

Sources of funding for the implementation of the additional PaMs adopted are not presented in the

NAPCP. This affects the credibility of the PaMs because their implementation is dependent on the funds

available.

3.7.4 Coherence with plans and programmes set up in other relevant policy areas

Section 2.7.2 of the NAPCP makes it clear that some of the selected PaMs are a part of the National

Programme for Atmospheric Air Quality Improvements. These PaMs have been included in the NAPCP

to ensure coherence between the two programmes. Furthermore, the NAPCP states that coherence

has been ensured or will be ensured between additional PaMs selected for adoption and the following

policies:

• The National Energy Strategy;

• National objectives for energy efficiency and renewable energy as a part of the NECP;

• The Energy Efficiency Regulation, transposing Directives 2010/31/EC, as amended by Directive

(EC) 2018/844 on Energy Efficiency in Buildings, and Directive 2012/27/EC, as amended by

Directive (ЕС) 2018/2002 on energy efficiency;




• The National Programme for Energy Efficiency in residential buildings;

However, no further details as to how consistency has been ensured or will be ensured have been

provided.

Projected combined impacts of PaMs on emission

reductions, air quality and the environment and associated

uncertainties (where applicable) (M, O)

• The projections show compliance with the emission reduction commitment for 2020-2029

and 2030 onwards for all pollutants with additional measures.

• Bulgaria has not reported the use of non-linear trajectory.

3.8.1 Likelihood of achievement of projected emission reductions

The projected emissions reductions under the WAM scenario have been reported in section 2.8 of the

NAPCP. According to the NAPCP projections, emission reductions under the WAM scenario for 2020

and 2030 are projected to achieve the national emission reduction commitments in the NECD.

Conclusions from the NAPCP review on whether the projected emission reductions per pollutant are

likely to be realised in practice are presented in Table 3-2.

Table 3-2 Likelihood of achieving the projected emissions reductions (WAM scenario)

Do the PaMs selected for adoption

target the key emitting sectors?

Are the projected emission reductions for

2020 and 2030 likely to be achieved?

SO2 N/A.

The largest emitting sector of SO2 is

the energy production sector.

However, no measures have been

introduced to target SO2 from this

sector. The emission reduction

commitments for this pollutant are

projected to be achieved under the

WM scenario, although by a margin of

1 percentage point.

Partly.

The projected reductions of SO2 with additional

measures is dependent on the success of

measures in the residential heating sector

which could be challenging to implement. As

noted earlier, the implementation of

requirements on the use of wood for domestic

heating would require an assessment of how

much wood is purchased from regulated

traders and how much is self-gathered.

It is noteworthy that quantified impacts of the

PaMs in the residential heating show only

minor additional reductions of SO2 since

compliance with emission reduction

commitments is demonstrated under the WM

scenario in the NAPCP projections, and

therefore the lack of credibility of PaMs in the

residential heating package will have only

minor impacts on the total SO2 reductions.

NOX Partly.

The largest emitting sectors for NOX

are transport and energy production.

Additional PaMs targeting NOX have

Partly.

The additional reductions of NOX under the

WAM scenario are dependent on the

successful and timely implementation of two

measures in the transport sector for which

there is some uncertainty over their credibility.




Do the PaMs selected for adoption

target the key emitting sectors?

Are the projected emission reductions for

2020 and 2030 likely to be achieved?

only been considered and adopted for

transport.

As noted earlier, one of these relates is a

modal shift measure which is not credible.

NMVOC Partly.

The largest emitting sectors for

NMVOC are combustion in other

sectors (commercial, institutional,

residential, agriculture and fishing

stationary and mobile combustion),

fugitive emissions from fuels sectors

and solvents and other product use.

Additional PaMs targeting NMVOC

have been introduced in the residential

heating and the transport sectors.

However, the introduction of the Clean

Air Zone may lead only to the diversion

of traffic and may not overall reduce

emissions from the transport sector.

Therefore, it has been concluded that

the PaMs selected only partially target

the key emitting sectors.

Partly.

The largest additional emission reductions for

NMVOC are to be achieved from the PaMs in

the residential sector. As noted earlier, some

of the PaMs in this sector may be difficult to

implement (e.g. requirements on use of wood

for domestic heating). The NAPCP provides

information on the quantified emissions

reductions for NMVOC as a result of the

residential heating PaM package, however,

there is no breakdown of the emission

reductions per each PaM included in the

package. Therefore, the impact of PaMs which

are not credible could not be fully assessed.

NH3 Yes.

According to the projections reporting,

the key contributing sectors for NH3

are the other sectors (commercial,

institutional, residential, agriculture and

fishing stationary and mobile

combustion). Additional PaMs

targeting NH3 have been introduced in

the agriculture sector, and therefore

the PaMs selected target the key

emission sector.

Partly.

The reductions would depend on the voluntary

uptake of good agriculture practices and their

application by farmers, and therefore the

PaMs would be difficult to enforce.

PM2.5 Yes.

The key contributing sector to PM2.5

according to the projections reporting

is the Other sectors (Commercial,

institutional, residential, agriculture and

fishing stationary and mobile

combustion). The key additional PaMs

targeting PM2.5 will be introduced in

the residential heating sector, therefore

addressing part of the key source.

Yes.

The largest additional emission reductions for

NMVOC are to be achieved from the PaMs in

the residential sector. As noted earlier, some

of the PaMs in this sector may be difficult to

implement (e.g. requirements on use of wood

for domestic heating). The NAPCP provides

information on the quantified emissions

reductions for PM2.5 as a result of the

residential heating PaM package, however,

there is no breakdown of the emission

reductions per each PaM included in the

package. Therefore, the impact of PaMs which

are not credible could not be fully assessed.




This analysis of the credibility of the PaMs in achieving emission reductions has also been used in the

assessment of the risk of non-compliance, presented in Appendix 2.

3.8.2 Deviation from the linear trajectory for 2025

Bulgaria has reported that a non-linear trajectory is not applicable since emissions reductions between

2025 and 2030 follow an overall linear trajectory. Under the WAM scenario, marginal increases are

projected for SO2 between 2020 and 2025 (0.6 kt), however these do not affect the overall linearity of

the trajectory.

3.8.3 Use of flexibilities

Bulgaria has not used flexibilities.

3.8.4 Projected impacts on air quality and the environment.

It is stated in the NAPCP that Bulgaria has limited capacity with respect to air quality modelling. The

projected improvements in air quality have been estimated on the basis of statistical methods. The

calculations are performed only for the pollutants which represent a challenge, i.e. PM10 and PM2.5.

Overall, the NAPCP projects significant improvements in PM2.5 and PM10 between 2016 and 2030 under

the WAM scenario. It is estimated that around 2025, most air quality zones will be compliant with

pollutant concentration limits. Graphics have not been used to illustrate the projected improvements in

air quality.

Bulgaria has reported that they have insufficient access to information and capacity available to assess

the projected impacts on the environment.




4 Conclusions and recommendations The Member State submitted the NAPCP after the deadline for the submission of final NAPCPs, i.e. on

1 April 2019. It is suggested in the text that the NAPCP will be revised and resubmitted following the

completion of a further consultation with the Ministry of Environment and Water. Overall, Bulgaria has

therefore not fulfilled the reporting obligation under Article 10 (1) of the NECD.

The NAPCP has been submitted using the common format established by the Commission

Implementing Decision (2018/1522) but has not met the requirement to report via the EEA PaM-tool.

Nevertheless, Bulgaria has stated that the information included in the NAPCP will be reported via the

EEA PaM-tool at a later stage.

Most of the minimum content required by the common format is presented in the NAPCP. Specific gaps

relate to:

• the contact details of competent authorities.

• indication of whether a stakeholder consultation has been undertaken.

• links to the NAPCP online and the consultation document.

• a link to the inventory used to inform the emission projections.

With respect to links to the NAPCP online and the consultation document, it is stated that these will be

included in the revised version of the NAPCP.

The NAPCP identifies a gap in compliance with the Member State NECD emission reduction

commitments with existing PaMs (WM scenario). Thus, additional PaMs are considered and selected

for adoption in the NAPCP.

Bulgaria has considered and selected for adoption seven additional PaMs. The analysis of the additional

PaMs considered and selected for adoption has demonstrated that:

• The PaMs have a proportionate spread across the main emitting sectors and pollution sources

and targeting of the key pollutants that represent a challenge.

• The PaMs adopted are projected to reduce emissions from the sectors responsible for

significant emissions of NECD pollutants, except in the cases of NOX and SO2, for which no

PaMs have been considered or adopted for the largest contributing sector i.e. energy

production.

• The optional cost and benefits have been presented for four individual PaMs in the residential

heating sector. The total investment for these measures is 426 million EUR from 2016 to 2030

on the basis of 2018 prices.

• The NAPCP includes a qualitative explanation of the air quality benefits of the PaMs considered

for adoption. The explanation highlights significant improvements of PM1o, NMVOC and NH3

pollutant concentrations.

• The assessment of credibility of the PaMs selected for adoption in the WaM scenario concluded

that the descriptions provided suggest that some of the PaMs in the transport sector will depend

on behavioural change (i.e. modal shift) and may only relocate emissions rather than reduce

them. This may influence the extent to which the projected NOX emission reductions will be

achieved in practice.

• Furthermore, the likely implementation issues with some of the PaMs in the energy supply

(residential heating) sector, such as the requirements on use of wood for domestic heating, can

lead to smaller than the projected reductions for SO2, NMVOC and PM2.5.

• For NH3, reducing emissions to the projected levels will depend on which PaMs will actually be

implemented and the level of adoption of measures listed in the “National Advisory Code of




Good Agricultural Practice to Control Ammonia Emissions”. These aspects are not clearly

defined in the NAPCP.

According to the NAPCP projections, with the selected PaMs under the WAM scenario, Bulgaria is

projected to achieve all reduction commitments for 2020-2029 and 2030 onwards. However, 2030

onwards commitments for SO2, NOx, NMVOC and NH3 are projected to be narrowly attained.

While the NAPCP review has found inconsistencies between the NAPCP projections and those

submitted under Article 10(2), the inconsistencies do not affect the overall projected compliance with

emission reduction commitments.

According to the assessment of the risk of non-compliance integrating the findings from the NAPCP

and the projections’ reviews (Appendix 2), Bulgaria is at high risk of not complying with its 2020-2029

NOx, NMVOC and NH3 commitments and 2030 onwards NOx, NMVOC and NH3 commitments. This

assessment is driven by the finding that major improvements are needed to improve the quality of

projections for NOx, NMVOC and NH3 and by the low margin of compliance projected for all pollutants

under the WAM scenario submitted under Article 10(2).

Recommendations

Recommendations are prioritised according to the following categories:

1. Ensuring compliance – non-compliance with the NECD, where the minimum content is not

reported and/or the Member State does not demonstrate how it may achieve its emission reduction

commitments.

2. Areas for improvement – the NAPCP is reported to be compliant with its emission reduction

commitments and provides the minimum content required by the common format but areas for

improvement to strengthen compliance have been identified.

3. Encouragements – where optional reporting and/or the NAPCP could be closely aligned with the

guidance document on preparation of initial NAPCPs to strengthen the quality of the NAPCP.

Ensuring compliance

• The NAPCP does not currently include a date of submission, contact details for competent

authorities, indication of whether a stakeholder consultation has been conducted and link to the

NAPCP consultation online. Bulgaria should incorporate these within the NAPCP.

• The Bulgarian NAPCP suggests that an NAPCP consultation has not yet been performed. Bulgaria

should perform an NAPCP consultation and include evidence of it within the NAPCP. Furthermore,

a link to the consultation online should be also included.

• Bulgaria should transparently report on the PaMs considered and selected for adoption, rectifying

key omissions pointed out in this review report. The EEA PaM-tool should be used for this purpose

to facilitate consistent reporting of the PaMs considered and then selected for adoption, and

provision of all minimum content required. Using the EEA PaM tool, Bulgaria should also report

information on the impacts of individual PaMs and packages of PaMs considered for adoption on

air quality and the environment. Finally, Bulgaria should present stakeholder feedback with regard

to selected PaMs.

• Bulgaria should include a complete reference to the national inventories underpinning the NAPCP

projections to ensure transparency.

Areas for improvement

• Under the WAM scenario, the 2030 commitments for SO2, NOx, NMVOC and NH3 are projected

to be achieved with a margin of 3 percentage points for NH3 and 1 percentage point for all other

pollutants . It is recommended that further PaMs to those selected for adoption in the NAPCP are

considered by Bulgaria to address this.




• In addition, the projections used in the NAPCP could be fully aligned with the projections submitted

as a part of the Member State projections reporting requirement for SO2 and NOx in 2020 and

2030.

• In accordance with the NECD, where appropriate, transboundary consultations shall be conducted

(Article 6(6)). Member States should provide links to relevant website(s) on the consultation

undertaken (section 2.1.1. of the common format). Bulgaria identifies transboundary air pollution

transfers with neighbouring countries. However, evidence is needed to show that consultation on

the NAPCP has been undertaken with the affected neighbouring countries or if no consultation has

been undertaken then on the reasons why.

Encouragement

• Bulgaria is encouraged to include a reference to WHO guidelines values when lying down the

national air quality priorities (section 2.3.1 of the common format).

• Furthermore, Bulgaria is encouraged to provide details about the current PaMs implemented

and included in the WM scenario, preferably per sector, for all sectors (in addition to information

provided for the agriculture sector).

• The Bulgarian NAPCP includes an outline of the transboundary impact of air pollution but does

not include any details concerning the methodology applied. An outline of the methodology

used to develop the quantitative data reported, and/or signposting to the methodology used

would strengthen the robustness and transparency of the data provided

• The Bulgarian projections used in the NAPCP are based on historical inventory data with the

reference year of 2016. It is advised that Bulgaria bases its NAPCP emission projections on

the latest inventory (i.e. 2017).

• To strengthen the expected projected compliance with the EU air quality limit values, Bulgaria

could consider progress towards achieving the air quality values included in the WHO

guidelines.




Appendix 1 Completeness assessment

A completeness assessment was conducted to identify gaps in reporting according to the minimum

content requirements of the common format (Commission Implementing Decision (EU) 2018/1522)7.

The completeness assessment also reviewed the extent of optional reporting by Member States.

For mandatory reporting requirements, the status has been assessed using the traffic light RAG rating

as presented in the table below.

Table 4-1 Traffic light RAG rating for completeness assessment of mandatory reporting

Red No information provided for mandatory reporting requirement

Amber Evidence is incomplete or unclear to meet reporting requirement

Green Evidence is sufficient to meet reporting requirement

N/A Mandatory reporting requirement not relevant for the given Member State or

mandatory only when available and not available in the given Member State (e.g.

where mandatory reporting requirements apply only where a non-linear emission

reduction trajectory is followed)

Table 4-2 Assessment of the NAPCP compliance screening with the minimum content requirements

Reference to the NAPCP common

format

RAG

Rating Explanation

2.1 Title of the programme contact

information and websites

Amber A table similar to the one provided in the

common format of the NAPCP has been

submitted but not fully completed.

Specifically, the date of the NAPCP

submission, the responsible competent

authorities’ contact details, indication of

whether a stakeholder consultation has been

conducted and the link to the NAPCP and

the consultation online have not been

provided. Bulgaria has stated that missing

information will be provided following the

completion of the consultation process.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas

Green Bulgaria has provided detailed information

regarding policy priorities in the areas of

national air quality, climate change and

energy, transport and agriculture. No specific

policy priorities have been provided for the

industry sector. However, policy priorities

focusing on clean development have been

provided and these are relevant to the

industry sector.

7 Commission Implementing Decision (EU) 2018/1522 of 11 October 2018 laying down a common format for national air pollution control

programmes under Directive (EU) 2016/2284 of the European Parliament and of the Council on the reduction of national emissions of certain

atmospheric pollutants.





format

RAG

Rating Explanation

2.3.2 Responsibilities attributed to

national, regional and local authorities

Green The responsibilities attributed to national,

regional and local authorities are described.

2.4.1 Progress made by current PaMs

in reducing emissions, and the degree

of compliance with national and Union

emission reduction obligations

Amber The progress made by current PaMs is

described with respect to the degree of

compliance achieved. The information is

presented in section 2.4.1 of the NAPCP.

However, no hyperlink to the publicly

available supporting datasets has been

provided.

2.4.2 Progress made by current PaMs

in improving air quality, and the degree

of compliance with national and Union

air quality obligations

Green The progress made by current PaMs is

described in section 2.4.2 of the NAPCP.

The section describes compliance between

2005 and 2016.

2.4.3 Where relevant, current

transboundary impact of national

emission sources

Green Current transboundary impacts have been

described for each key pollutant.

2.5.1 Projected emissions and

emission reductions (WM scenario)

Green Emission projections under a WM scenario

are provided with respect to the national

emission reduction commitments as

specified in the NECD.

2.5.2 Projected impact on improving

air quality (WM scenario)

Green A description of the projected improvements

in air quality has been provided only for

PM10, as the only pollutant which presents a

challenge to air quality for Bulgaria.

2.6.1 Details concerning the PaMs

considered in order to comply with the

emission reduction commitments

(reporting at PaM level)

Green Bulgaria has not reported via the EEA PaM-

tool. However, these are reported within the

NAPCP.

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 (where available)

Red Bulgaria has not provided information on the

impacts on air quality and the environment of

individual PaMs or packages of PaMs

considered for adoption.

2.6.4 Additional details concerning the

measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the


Green Additional details concerning the measures

from Annex III Part 2 to the NECD have

been provided in section 2.6.4.

2.7.1 Individual PaMs or package of

PaMs selected for adoption and the

competent authorities responsible

Green Bulgaria has not submitted its PaMs via the

EEA-PaM tool. However, these are reported

within the NAPCP.





format

RAG

Rating Explanation

2.7.2 Assessment of how selected

PaMs ensure coherence with plans

and programmes set up in other

relevant policy areas

Green Coherence of adopted PaMs with other

plans and programmes in the relevant policy

areas is presented in section 2.7 of the

NAPCP.

2.8.1 Projected attainment of emission

reduction commitments (WAM)

Green The emissions for 2005, 2020, 2025 and

2030 have been reported in the format

required by the common format. The

information is presented in section 2.7.1

2.8.2 Non-linear emission reduction

trajectory

Green Bulgaria has reported that a non-linear

trajectory is not applicable since emissions

reductions between 2025 and 2030 follow an

overall linear trajectory. Under the WAM

scenario, minor increases are projected for

SO2 in 2025 but these are of less than 1kt

and do not affect the overall linearity of the

trajectory.

2.8.3 Flexibilities N/A Flexibilities are not used.

The rating used for the completeness assessment of optional reporting by Member States refers to only

two categories, whereby the Member State either reported the information (Green) or it did not (White).

This rating reflects the fact that the reporting is optional and therefore where the information was not

provided, or where it was incomplete or unclear, the assessment should not consider this a gap in

reporting.

Table 4-3 Rating for completeness assessment rating of optional reporting

Green Evidence is sufficient to meet reporting requirement

White No information provided for optional reporting requirement or evidence is

incomplete or unclear to meet optional reporting requirement

Table 4-4 Completeness assessment of the NAPCP for the optional content requirements


format

RAG

Rating Explanation

2.2 Executive summary Green Bulgaria has provided an optional executive

summary.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas: Reference to WHO

guideline values

White The WHO air quality guidelines are not

referred to among the national air quality

priorities listed.

2.3.2 Responsibilities attributed to

national, regional and local authorities:

Green Where relevant, the source sector under the

responsibility of the state authority is stated.





format

RAG

Rating Explanation

Source sectors under the responsibility of

the authority

2.4.1 Progress made by current PaMs in

reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations: Provision

of graphics

Green Bulgaria has used histograms to illustrate

pollutant reductions per sector for all key

pollutants.

2.4.2 Progress made by current PaMs in

improving air quality, and the degree of

compliance with national and Union air

quality obligations: Provision of graphics

and progress made in a specific air quality

zone

White No maps or histograms illustrating air

concentrations and the number of compliant

air quality zones have been included. The

progress has not been described with regard

to specific air quality zones.

2.4.3 Methodologies and data used to

show the current transboundary impact of

national emission sources

Green The data source is provided for the

quantitative data reported. The methodology

used is referred to but not described.

2.5.1 Associated uncertainties of the

projected emissions and emission

reductions (WM scenario)

White The uncertainties associated with the WM

scenario projections have not been reported.

2.5.2 Quantitative data on the projected

impact on improving air quality (WM

scenario)

White Bulgaria has reported that the quantification

of the estimated improvement in ambient air

quality cannot be presented in the format

proposed in section 2.5.2.2 of the

Commission Implementing Decision.

2.6.1 Details about additional pollutants

concerning the PaMs considered in order

to comply with the emission reduction

commitments: Reporting of affected

pollutant(s) beyond the scope of the

NECD

White According to the PaMs considered for

adoption described within the NAPCP, no

additional pollutants have been targeted.

2.6.3 Estimation of costs and benefits of

the individual PaM or package of PaMs

considered in order to comply with the


Green The estimation of costs and benefits has

been reported for one package of PaMs in

section 2.6.3 of the NAPCP.

2.6.4 Additional details concerning the

optional measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the


Green Measures to reduce NH3 emissions from

livestock and a national advisory code of

good agricultural practices for the proper

management of harvest residue are included

among the additional PaMs considered.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible: Reporting of

Green Bulgaria has set interim targets and

objectives for the implementation of selected

PaMs. These are described in section 2.7 of





format

RAG

Rating Explanation

relevant comments arising from the

consultation and provision of interim

targets and indicators

the NAPCP. The relevant comments arising

from the consultation are said to be made

included in the NAPCP at a later stage.

2.7.2 Explanation of the choice of

selected measures and an assessment of

how selected PaMs

Green An explanation of the selected PaMs is

provided in section 2.6.3 of the NAPCP.

2.8.4 Projected improvement in air quality

(WAM)

Green The projected improvement in air quality and

the degree of compliance has been

described in qualitative terms, for pm10 and

pm2.5 only.

2.8.5 Projected impacts on the

environment (WAM)

White Bulgaria has reported that there is

insufficient information and capacity

available in Bulgaria to assess the projected

impacts on the environment




Appendix 2 Assessment of the risk of non-compliance The description of the methodology used for this assessment is presented in the Horizontal Report. In

the following tables, the information used in the decision tree process is presented in black font.

Information not used in the decision tree process is presented in grey font and italics.

Where information is required but not reported, the response to the decision tree question is ‘not

reported’ (NR). Where information is not required and not reported, the response to the decision tree

question is ‘not applicable’ (n/a).

Risk of non-compliance with 2020-2029 emission reduction commitments

Decision tree question Relevant

scenario

2020 – 2029

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes Yes No Yes No

WAM Yes Yes Yes Yes Yes

Are the projections

submitted under Article

10(2) considered to be of

good quality?

WM,

WAM

Partially No No No Partially

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM Partially Yes Yes Yes Yes


Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM Partially Partially Partially Partially Yes

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections


10(2))

WM Yes

(53)

No

(10)

No

(-6)

No

(8)

No

(-17)

WAM Yes

(54)

No

(13)

No

(3)

No

(10)

Yes

(10)

Risk of non-compliance M H H H L

Additional comments on

high risk scores

The review has concluded that Bulgaria is at a high risk of non-

compliance with the emission reduction commitment for NOx,

NMVOC and NH3 for 2020-2029. This is driven by:

• Major improvements to the projection’s methodologies recommended in the review.

• Compliance projected by a margin lower than 20%.




Risk of non-compliance with 2030 emission reduction commitments

Decision tree question Relevant

scenario

2030 onwards

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes No No No No


Are the projections


10(2) considered to be of

good quality?

WM,

WAM

Partially No No No Partially

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM Yes Partially Yes Yes Yes


Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM Yes Partially Partially Partially Yes

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections


10(2))

WM Yes (10) No (-11) No (-19) No (-3) No (-1)

WAM Yes

(11)

No

(3)

No

(1)

No

(4)

Yes

(57)

Risk of non-compliance L H H H L

Additional comments on

high risk scores

The review has concluded that Bulgaria is at a high risk of non-

compliance with the emission reduction commitment for NOx,

NMVOC and NH3 for 2030. This is driven by:

• Major improvements to the projection’s methodologies

recommended in the review.

• Compliance projected by a margin lower than 20%.

The Gemini Building

Fermi Avenue

Harwell

Didcot

Oxfordshire

OX11 0QR

United Kingdom

t: +44 (0)1235 753000

e: [email protected]

ee.ricardo.com

review of the national air pollution control programme – bulgaria · 2020-06-12 · pollution...

Documents