Европейска схема

5.3. Other legislation or policy instruments

5.3.1 Please list other Community legislation or policy instruments that were considered in the establishment of the National Allocation Plan and explain how each one has influenced the intended allocation and for which activities. 5.3.2 Has any particular new Community legislation been considered to lead to an unavoidable increase in emissions? If yes, please explain why the change in emissions is considered to be unavoidable, and how this has been taken into account.

1. 
   Directive 2003/17/ЕС on the quality of petrol and diesel fuels
   

The Directive requires oil refineries to produce fuel with low sulphur content, as a consequence of which installations falling within the scope of the emission trading Directive face increases in emissions of carbon dioxide from installations covered by the emissions trading Directive. The increase in emissions from those installations will occur in parallel to a decrease in CO₂ emissions from the transport sector.

2. 
   Directive 1999/13/ЕС on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations
   

The Directive sets emission limit values for different activities based on their annual consumption of VOCs for which an integrated permit or an emission trading permit is required. Thermal processing is one of the main methods used for reducing VOCs emissions. The system requires a significant energy input in order to maintain the required operating temperature. This leads to an increase in emissions of carbon dioxide, which has been taken into account during the development of the NAP by providing for a calculative reserve for compulsory measures.

3. 
   Directive 2001/80/ЕС on the limitation of emissions of certain pollutants into the air from large combustion plants
   

Compulsory measures related to the compliance with the requirements of Directive 2001/80/ЕС and the norms it sets for maximum permitted norms of emissions to the ambient air from the large combustion installations for a number of pollutants, also lead an to inevitable increase in emissions of carbon dioxide from those installations. This has been taken into account in the process of development of the NAP by providing for a calculative reserve for compulsory measures.

4. 
   Directive 96/61/ЕС concerning Integrated Pollution Prevention and Control
   

The integrated permit required under this Directive, is an individual administrative act, granting a permit for functioning of certain installations or parts of installations under certain conditions which guarantee the compatibility of the installation with regulatory requirements. The functioning of all installations covered by the emission trading scheme is authorized and defined through the integrated permit, except for combustion plants with thermal power of 20 to 50 MW. The integrated permit, issued under Directive 96/61/ЕС, is used also in the framework of the procedure on issuing of an emission trading permit, which represents a permit for functioning of installations listed in Annex 1 to Directive 2003/87/ЕС. Before the start of the procedure on issuing emission trading permits for installations covered by both Directives, those installations should obtain an integrated permit and implement the measures included in the permit to achieve compliance with the legislation in force. Some of these measures have a direct effect on greenhouse gas emissions level from these installations.

5. 
   Directive 2004/8/ЕС concerning cogeneration
   

The NAP includes sufficient reserves for new cogeneration and for Joint Implementation projects for cogeneration.

6. 
   Directive 2001/77/ЕС concerning the promotion of electricity produced from renewable energy sources
   

Allowances are set aside in the NAP for Joint Implementation projects for production of electricity from renewable sources.

6. Public consultations

6.1 How is this national allocation plan made available to the public for comments? 6.2 How does the Member State provide for due account to be taken of any comments received before a decision on the allocation of allowances is taken? 6.3 If any comments from the public received during the first round of consultation have had significant influence on the national allocation plan, the Member State should summarize those comments and explain how they have been taken into account.

6.1 The businesses participated in the development of the NAP through representatives of their branch organizations in the inter-ministerial working group and they advocate the interests of the operators covered by the emission trading Directive.

Information about the development of Bulgaria’ NAP has been presented to the public through:

• 
  information campaigns organized by the MRDPW and the MEE;
  
• 
  specialized seminars organized by the Bulgarian Industrial Association, Bulgarian International Business Association and other NOGs;
  
• 
  training and workshop within the Dutch project.
  
• 
  media publications;
  
• 
  web-pages of the MOEW, MEE and MRDPW.
  

The various stages in the development of the NAP have been covered by the media which have provided information to the public and facilitated the public debate on this topic. The updated and well structured section on the development of the Nap at the MOEW web-site provide information to all who are interested in the topic..

6.2 After Bulgaria’s NAP has been published on the web-site of MOEW, a special link is available that allows all interested parties to send comments on the NAP within the given timeframe. Gathered comments are summarized by the MOEW and presented to the inter-ministerial working group responsible for the development of the NAP.

6.3 The inter-ministerial working group reviews all comments provided by the public and accepts or declines them with arguments. Results from the working group’s discussions are registered in protocols. To facilitate decision making, consultants from Netherlands and Bulgaria with proved international experience and capacity on climate change provide technical assistance to the working group. The WG will review all comments provided during public consultations and will make decisions, following the procedure described above.