(1)

Pursuant to Regulation (EU) 2018/1999, each Member State is required to submit to the Commission a draft of its integrated national energy and climate plan covering the period from 2021 to 2030 in accordance with Article 3(1) and Annex I of that Regulation. The first drafts of integrated national energy and climate plans had to be submitted by 31 December 2018.

(2)

Bulgaria submitted its draft national energy and climate plan on 15 January 2019. The submission of this draft plan represents the basis and first step of the iterative process between the Commission and Member States for the purpose of the finalisation of the integrated national energy and climate plans and their subsequent implementation.

(3)

Pursuant to Regulation (EU) 2018/1999, the Commission is required to assess the draft integrated national energy and climate plans. The Commission made a comprehensive assessment of the Bulgarian draft national energy and climate plan, taking into consideration the relevant elements of Regulation (EU) 2018/1999. This assessment (2) is published alongside the present recommendation. The below recommendations are based on this assessment. In particular, the Commission's recommendations may address (i) the level of ambition of objectives, targets and contributions with a view to collectively achieving the Energy Union objectives and, in particular, the Union's 2030 targets for renewable energy and energy efficiency as well as the level of electricity interconnectivity that the Member State aims for in 2030; (ii) policies and measures relating to Member State- and Union-level objectives and other policies and measures of potential cross-border relevance; (iii) any additional policies and measures that might be required in the integrated national energy and climate plans; (iv) interactions between and consistency of existing and planned policies and measures included in the integrated national energy and climate plan within one dimension and among different dimensions of the Energy Union.

(4)

In developing its recommendations, the Commission considered, on the one hand, the need to add up certain quantified planned contributions of all Member States in order to assess the ambition at Union level, and, on the other hand, the need to provide adequate time for the Member State concerned to take due consideration of the Commission's recommendations before finalising its national plan.

(5)

The Commission's recommendations with regard to the Member States' renewable ambitions are based on a formula set out in Annex II of Regulation (EU) 2018/1999 which is based on objective criteria.

(6)

With regard to energy efficiency, the Commission's recommendations are based on the assessment of the national level of ambition put forward in the draft integrated national energy and climate plan, compared to the collective level of efforts needed to reach the Union's targets, taking into account the information provided on specific national circumstances, where relevant. The final national contributions in the area of energy efficiency should reflect the cost-effective potential for energy savings and be supported with a robust long-term building renovation strategy and measures to implement the energy savings obligation stemming from Article 7 Directive 2012/27/EU of the European Parliament and of the Council (3). Member States should also demonstrate that they have properly taken into account the energy efficiency first principle, by explaining notably how energy efficiency contributes to the cost-effective delivery of the national goals of a competitive low-carbon economy, security of energy supply and to address energy poverty.

(7)

The Governance Regulation requires Member States to provide a general overview of the investment needed to achieve the objectives, targets and contributions set out in the integrated national energy and climate plan, as well as a general assessment on the sources of that investment. The national energy and climate plans should ensure the transparency and predictability of national policies and measures in order to ensure investment certainty.

(8)

In parallel, as part of the 2018-2019 European Semester cycle, the Commission has put a strong focus on Member States' energy and climate related investment needs. This is reflected in the 2019 Country Report for Bulgaria (4) and in the Commission's recommendation for a Council Recommendation to Bulgaria (5), as part of the European Semester process. The Commission took into account the latest European Semester findings and recommendations in its assessment of the draft integrated national energy and climate plans. The Commission's recommendations are complementary to the latest country-specific recommendations issued in the context of the European Semester. Member States should also ensure that their integrated national energy and climate plans take into consideration the latest country-specific recommendations issued in the context of the European Semester.

(9)

In addition, the Governance Regulation requires each Member State to take due account of any recommendations from the Commission to its draft integrated national energy and climate plan to be submitted by 31 December 2019 and, if the Member State concerned does not address a recommendation or a substantial part thereof, that Member State should provide and make public its reasons.

(10)

Where applicable, Member States should report the same data in their integrated national energy and climate plans and updates in later years as they report to Eurostat or the European Environment Agency. The use of the same source and, where available, of European statistics, is also essential to calculate the baseline for modelling and projections. Using European statistics will allow for a better comparability of the data and the projections used in the integrated national energy and climate plans.

(11)

All elements of Annex I of the Regulation (EU) 2018/1999 are to be included in the final integrated national energy and climate plan. In this context, the macroeconomic and, to the extent feasible, the health, environmental, employment and education, skills and social impacts of the planned policies and measures should be assessed. The public and other stakeholders are to be engaged in the preparation of the final integrated national energy and climate plan. These and other elements are described in detail in the staff working document published alongside this Recommendation (6).

(12)

The integrated energy and climate plans provide the opportunity to coherently define long-term policies and measures, taking into account resulting interlinkages between dimensions in terms of potential synergies or risks. While the policies and measures described in the draft plan seem to consider some interlinkages, their assessment across the five dimensions should be further reinforced in the final plan. The analysis could include quantitative estimates and should also cover possible negative interactions between policies and measures and show how Bulgaria intends to address them. In particular, the synergies between the decarbonisation, energy security and the internal market dimensions and the energy efficiency first principle warrants further assessment. Similarly, the role of energy efficiency in addressing energy poverty should be further looked at. An important element to be further assessed in the final plan, including from the costs and competitiveness angles, is the interaction between the planned continuation of coal based power generation and enhanced use of gas with the decarbonisation dimension. Another element is the impact of biomass use on the accounted removals in the land use and forestry sector. The link between electricity production and the deployment of low-carbon technologies should be further addressed under the research innovation and competitiveness dimension.

(13)

The final integrated national energy and climate plan would benefit from a comprehensive analysis on where the low-carbon technologies sector, including for decarbonising energy- and carbon-intensive industrial sectors, is currently positioned in the global market. The plan would benefit from highlighting areas of competitive advantage and potential challenges, and defining objectives, policies and measures based on them, making appropriate links to enterprise and industrial policy. Interactions with the circular economy and its relevance for greenhouse gas emissions reduction, in particular, could be further emphasised.

(14)

The Commission's recommendations to Bulgaria are underpinned by the assessment of Bulgaria's draft integrated national energy and climate plan which is published alongside this Recommendation (7).

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