The American Chamber of Commerce in Bulgaria would like to share with you its position regarding the published Impact Assessment Report on the Draft Integrated Energy and Climate Plan of the Republic of Bulgaria (INECP) – 2024 Update. With this position, we also express our support for the statement issued by our colleagues at the Bulgarian Wind Energy Association.
We would like to explicitly emphasize that we do not question either the national significance of INECP as a tool for fulfilling the Republic of Bulgaria’s commitments under the Paris Agreement, the European Green Deal, and Directive (EU) 2023/2413, nor the public interest in protecting the Natura 2000 network.
Precisely because of INECP’s significance, AmCham shares the insistence that the assessment documents, upon which subsequent permitting procedures will be based, meet the highest standards of legal and scientific soundness.
We firmly believe that, as presented, the Reports do not meet this standard. We have identified a combination of substantial legal violations, methodological flaws, and internal contradictions which, individually and collectively, compromise the validity of the conclusions and the legal soundness of the recommended measures. It is particularly concerning that these assessment documents could effectively limit the ability to develop precisely the capacity that INECP itself relies on to achieve the national energy and climate goals. It is unacceptable for a strategic document to call for the development of renewable energy, while the assessment accompanying that document – through general geographic restrictions and buffer zones, without sufficient technological and territorial differentiation – effectively hinders its implementation.
In light of the foregoing, we submit the following reasoned requests:
- The EIA and SEA procedures should not be concluded,
- The EIA Report and the SEA Report should be returned for substantial revision,
- The internal logical contradiction in the SEA Report should be resolved,
- Unjustified use of outdated documents whose legal effect has expired,
- The measures set forth in Section 6.2 should be completely revised and revoked,
- It should be explicitly stipulated that the introduction of measures and restrictions arising from the EIA for IPEK 2024 does not apply to investment proposals and projects for which, as of the date of adoption of the final opinion, there are EIA decisions, compatibility assessment decisions, or other individual administrative acts issued pursuant to the Environmental Protection Act and the Biological Diversity Act,
- The public comment period for the revised draft should be extended.
We believe that the sustainable development of industry and the protection of the environment and water resources can go hand in hand. We believe that, in the context of intensified competition at the regional and global levels, Bulgaria must find ways to retain and attract investors in clean industries with high added value. Furthermore, the energy transition is crucial to the country’s national security, and it must not be hindered by disproportionate, obstructive measures such as those set forth in Section 6.2 of INECP’s Environmental Impact Assessment Report.