Report: Assessment of Bulgaria’s Long-Term Strategy for climate neutrality

Long-Term Strategies are key instruments for transforming the economies of Member States and achieving the EU’s ambitious climate neutrality goals. However, the relatively loose guidelines of European regulations governing these Strategies have led to wide variations in their scope, specificity, and concreteness across Member States. Strategies which fall short of providing concrete emissions reduction targets will face more challenges in implementing and governing the transition to climate neutrality, especially if they fail to underpin these targets with forward-thinking policies and measures with adequate planning around financing, R&D and the mitigation of socioeconomic impacts. This is the case for Bulgaria, a country with a substantial coal legacy and continued high carbon intensity of its economy, whose Long-Term Strategy is the subject of this report.

Bulgaria’s Long-Term Strategy, published in late 2022, builds upon economy-wide and sectoral emissions trajectories, modelled in 2020 using the same tool as its National Energy and Climate Plan. It does not set emission reduction targets, but rather presents the projections of emissions levels in 2050, and does not set a target for reaching net zero emissions. Generally, our findings indicate that the Strategy is more or less a continuation of the National Energy and Climate Plan and is placed in the now-outdated policy context of 2020, failing to reflect significant step-changes in EU policy ambitions – including the Fit for 55 package and the RePowerEU agreement. The measures and policies proposed thus risk being misaligned with the long-term trajectory that Bulgaria should be on, creating lock-in effects and delaying meaningful climate change mitigation. Another key aspect of the LTS is that it provides insufficient detail on the implementation of proposed policies and measures for decarbonization, including financing mechanisms, the mitigation of social and economic impacts in Just Transition regions, and an adequate governance framework including responsible institutions. As it provides partial coverage of most components of the assessment framework, the LTS receives mostly middling scores – however, key aspects of these components are missing, leading to significant uncertainty as to the role it will play in Bulgaria’s transition to climate neutrality.

Several recommendations emerge from our assessment, which could be applied to future updates of the Strategy. Firstly, the Strategy must be adapted to the current policy context, reflecting increased ambitions such as those put forward in the Fit for 55 package and the RePowerEU Plan. This includes setting a clear net zero emissions target, which should be reinforced throughout the Strategy to provide confidence on Bulgaria’s commitment to achieving its goals as an EU Member State. Secondly, this economy-wide net zero target must be complemented by sectoral targets and emissions reduction pathways, complete with robust policies and measures that lend credibility to the proposed pathways outlined in the LTS. Crucially, the LTS should also provide credible financing, R&D and governance mechanisms to ensure the proposed measures are deployed with high confidence, and that the policies can be implemented independent of political trends. Finally, the proposed decarbonization policies and measures require more in-depth assessment to pinpoint their socio-economic and distributive impacts and provide clear measures for mitigation, an essential element for Bulgaria’s Just Transition. Adopting these recommendations could launch the Long-Term Strategy as a centrepiece of Bulgaria’s transition to climate neutrality, fit for meeting ambitious emissions reductions goals.