13.11.2009

OPINION OF KRIBB REGARDING THE NATIONAL QUOTA ALLOCATION PLAN (NPRP) 2008-2012.

After a detailed discussion of the latest version of the NPRK 2008-2012 with its members who are directly affected by it, the Confederation of Employers and Industrialists in Bulgaria (KRIB) believes that there are again relapses from previous actions during the preparation of the plan, which led to to the unfortunate result - its rejection by the European Commission. KRIB has always defended and continues to defend the principled position that NPRK 2008-2012 should support companies that have shown environmental responsibility and invested and continue to invest on a large scale in clean technologies, despite the current global economic crisis. NPRK 2008-2012 is one of the ways for business to recover part of these investments, which led to a real reduction in greenhouse gas emissions released into the atmosphere. The plan is an emanation of the Ministry of Education and Culture's policy to support or not support environmentally friendly technologies. The careful analysis of the NPRK 2008-2012 shows a tolerated attitude on the part of the MoEW towards the district heating sector, whose requests to increase the quotas were satisfied, contrary to the European requirements for non-discriminatory treatment of individual sectors. A similar opinion was expressed by other business representatives participating in the working group. Doubts are being raised that a business, a part of which has a dubious reputation, is being tolerated again. There are complaints from KRIB member companies that the quotas for industries such as the fertilizer industry and the sector of lime producers, which have suffered from the economic crisis; companies with Joint Implementation projects that have invested huge funds in ecology; the oil refining industry, are further harmed by quota cuts in the latest version of the plan. The MoEW and the consultants on the 2008-2012 NPRK are currently exhibiting an unjustified negative attitude towards the metallurgy sector, after the Bulgarian Association of the Metallurgical Industry (BAMI) objected to the toleration of district heating and indicated some inconsistencies in the discussed NPRK. KRIB objects to requiring metallurgical enterprises additional data or data that they have already declared in their verified reports.

Despite expectations that the plan will be prepared according to objective criteria, this is not happening. The MoEW decided not to have a new meeting to discuss the plan, with the aim of its faster approval and movement, relying on the fact that its acceptance and approval by the European Commission was significantly delayed. Thus, the damaged sectors are put in a situation where they cannot defend themselves, and at a later stage they will also pay the price of the delay (not their fault) of the plan, by being forced to buy the missing quotas. Favoring one sector, which is, among other things, a monopoly and as such has a guaranteed market (and is not interested in investing in environmentally friendly technologies) and placing some industries at a disadvantage compared to it, causes the negative reaction of business to the last option of NPRK 2008-2012 Reiterating its principled position that the plan should support companies that have invested and continue to invest in environmentally friendly technologies, KRIB, as a representative of Bulgarian business, intends to protect its members in all possible ways in within the law, and will not oppose if some members of the Confederation decide to refer the European Commission.

KRIB insists on a new meeting of the interdepartmental working group to take into account the indicated weaknesses.