According to the Confederation of Employers and Industrialists in Bulgaria-KRIB, Decision No. Ц-33/14.09.2012 of the State Environmental Protection Agency is unacceptable. We express serious concern that this decision will undoubtedly lead to a loss of confidence and an outflow of Bulgarian and foreign investments not only in energy, but also in all other sectors of the economy. Retroactively changing previously regulated relations and conditions will have a negative effect on the risk profile of Bulgaria as an investment destination, creating a precedent. This will undoubtedly have an adverse impact on the overall assessment of the economic environment and investment climate, as well as deepen cross-subsidization. As a result of this decision, more than 1400 commercial companies producing electricity from RES are faced with the inability to service their obligations under granted bank loans and with the real danger of bankruptcy. Possible transfer of the problem caused by Decision No. Ц-33/14.09.2012. XNUMX of the CEVR on the banking sector and end industrial users would have a tangible effect on the entire Bulgarian economy.
The work and acts of the State Environmental Protection Agency from recent months (including the mechanism changed in mid-July for compensating the costs of the Final suppliers for the electricity purchased at preferential prices from RES, leading to destabilization of the entire system) give rise to the need for an urgent correction of the state position regarding the policy for the promotion of renewable energy and the mechanisms for compensating the preferential tariffs. The correction should not be in the direction of increasing the "green energy" supplement, as this will lead to the collapse of the Bulgarian industry, which is the end user. The practice of burdening energy-intensive industries in Bulgaria with all costs in the energy sector should be stopped immediately, because this leads to loss of competitive advantages, jobs and closing of production.
As an organization representing a significant part of Bulgarian business and combining the interests of representatives from all spheres in the energy sector, including production, distribution, supply and consumption of energy, KRIB stands for the need for a sustainable, long-term energy policy and equal treatment of all investors. We have repeatedly insisted on transparency in the pricing policy, predictability and foreseeability in the actions of the state authorities, and timely information and dialogue with all interested parties. In this sense, KRIB supports the positions of our partners - the American Chamber of Commerce and the German-Bulgarian Chamber of Industry, as well as the Trade Representative of Austria in Bulgaria, expressed in a letter of 33. .t.g. to the Prime Minister of the Republic of Bulgaria.
In view of the above, KRIB insists:
1. To review Decision C-33/14.09.2012 of the DKEVR, as this becomes an occasion for a broad public debate on the policy in the RES sector in Bulgaria and the need for a sustainable legal and regulatory framework in the energy sector. KRIB is ready to initiate such a dialogue, since all interested parties are represented in the organization.
2. The parties affected by Decision Ц-33/14.09.2012 of the State Environmental Protection Agency should be given the opportunity to jointly discuss dispatching problems and jointly prepare general conditions for access to the transmission and distribution networks for producers of electricity from RES. These general terms and conditions should be subject to public discussion and subsequent approval by the SEWRC.
3. To revise the Methodology for compensating the costs of the Public Supplier and Final Suppliers, resulting from their obligations to society for the purchase of electricity at preferential prices from renewable energy sources and from highly efficient combined heat and electricity production, adopted by protocol Decision No. 117/16.07.2012 of the State Environmental Protection Agency with the participation of all interested parties.
4. To create a public register of all power plants, regardless of their primary energy carrier, allowing transparent "online" access to production and price data.
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