On March 4 the opinion paper was sent to the Council of Ministries, the Prime-Minister, the Deputy Prime-Minister in charge of the NRRP, the Presidency, the National Assembly as well as other relevant institutions.
Version 1.1 of the National Recovery and Resilience Plan was published more than two months after the end of the public consultation and without any official notice. This Plan will be used by our country to justify before the EU a total of BGN 12 billion of additional funding for dealing with the consequences of the pandemic. Unfortunately, the Plan missed the historical opportunity for transformation of the Bulgarian economy from toll processing and the most carbon-intensive economy in Europe to a value-based economy, producing global innovations from Bulgaria and properly caring for the one-of-a-kind Bulgarian nature. The proposed reforms and investments fail to protect biodiversity or fight the consequences of the climate crisis, and they also fail to ensure the energy transition in its European context or support the prioritization of a circular economy. The new document largely repeats and overlaps with the approach in Version 1, and the absence of any vision cannot be compensated by the excessive use of Brussel’s vocabulary and terminology.
Recurring lack of transparency
The latest version of the Bulgarian plan was published in the late hours of 8 February with no public information to the stakeholders and the general public – no press-releases by the Council of Ministers, no notices to the dozens of organizations, that had officially submitted their proposals during the public consultation process for the First version of the Plan, no press-conference to explain the new proposals in the Version 1.1 and no clarity regarding any subsequent steps. The announced public consultation, required by the EU, resulted in exceptional interest and dozens of organizations sent excellent proposals. Despite that and in spite of the constant prompting by the “Green Restart” Coalition, no mechanism with evaluation criteria for the proposals made was introduced, no selection committee was announced, and no deadline for the processing of the proposals was indicated.
One month after the publishing of Version 1.1 of the Plan, transparency, and dialogue only take the form of mechanical uploading of documents on the website of the Recovery and Resilience Plan. A process, leaving the impression that the Bulgarian government sees no added value in the dialogue with stakeholders and from their expertise.
Europe in the future, and what about Bulgaria?
The funding of the Recovery and Resilience Plan will come from the unprecedented EU Mechanism "Next generation EU", which aims to help Europe exit stronger out of the current crisis, and while fighting the coronavirus, the economies restart programs do not support practices from the past, but are clearly looking forward and address the pressing challenges - climate change and digital transformation. Therefore, the Mechanism requires that in their national plans, EU member states defend the financing they are to receive, via demonstrating reforms and a focus on solving the climate crisis and the transition to a modern – digitally-based economy, taking care of people’s health and the environment.
Version 1.1 of the Plan, published by the Government, contains a justification for the BGN 12 billion, intended for Bulgaria. However, a large share of these funds would not be used for future development, but for financing models and priorities all too well-known from the past. There is no modern vision for the protection of the unique Bulgarian nature, but rather fragmented proposals, where the preservation of the biodiversity and ecosystem approach are mere terms, but not a true foundation for real reforms in the "Green Bulgaria" pillar. The absence of an actual transformation and transition to a decentralized energy system, where people and the business are empowered energy producers, is just barely touched upon, while the proposed large-scale energy-efficiency renovation programs do not meet EU objectives and principles. There is no meaningful reform in education, aimed at preparing students for life in sync with caring for the environment and focused on skills, necessary in the age of automation. What is actually offered is repairs of buildings and basic educational infrastructure. Furthermore, the development of the economy of the future, which would integrate and upgrade all the other parts of the plan, and make Bulgaria a hub of green and digital innovations with modern business, creating jobs and expanding the economic boundaries of the country, still remains misunderstood as a reform and objective of the Plan. Instead, we have been offered a catching up on past intentions, and digital and green innovations in the form of a purchase list for material assets, instead of creating the economy of the future for Bulgaria.
For perspective, here is a brief comparison of the suggested investments. While a total of BGN 2.1 billion are intended for energy-efficient renovation of buildings, Bulgarian biodiversity will be “protected” using just BGN 32 million. Although the Plan mentions several times Bulgaria’s position as a “modest innovator” in the EU as a fundamental problem, merely BGN 87 million are dedicated to innovative small and medium-sized enterprises in the “Innovative Bulgaria” pillar, supporting 28 projects. A total of BGN 2.1 billion will be used for merely purchasing equipment and repairs via the program for the economic transformation of SMEs and its three funds (technological, green, and digitalization), while actual state-of-the-art practices for decarbonization, circular economy, and enterprise-level innovation are given a back seat. Only BGN 33.3 million are intended for supporting a transition to decentralization and true energy independence of households.
Version 1.1 of the Plan, just like Version 1, also lacks an integral approach, connecting its four pillars, and addressing the outlined challenges faced by Bulgaria with the suggested reforms and proposed investments. A large portion of the proposed investments are not transformational, by any 21st century standard, and do not ensure economic recovery, nor significantly support the green and digital transition. An impression lingers that all these investments are actually projects within the operational programs, from the preceding period, which have not been approved.
The Recovery and Resilience Plan offers catching-up with the past, fails to seize the opportunity to ensure qualitative development of the economy and society, and instead “programs” Bulgaria for more poverty and lagging behind. Therefore, the “Green Restart” Coalition insists on the urgent revision of Version 1.1 of the Plan, in order to ensure the successful economic recovery of the country and acceleration of the green and digital transition in Bulgaria. The Coalition is ready to provide free and focused support in this substantial process and, to this end, we have developed specific proposals for direct amendments to the Second version of the Plan, which we insist on being incorporated in the subsequent, revised version before the final approval of the document by the European Commission.
We, the Coalition “Green Restart” Coalition, clearly state to those responsible for drafting the Plan, that:
- We demand funding not merely for energy efficiency, but for energy decentralization and independence;
- We demand not merely energy-efficient renovation of buildings, but rather the development of an overall methodology for the implementation of the circular economy principles into the renovation and construction of buildings;
- We demand not only a hydrogen economy of thermal power plants burning hydrogen gas but rather –real green hydrogen production and development of the hydrogen-based industry;
- We demand not merely an ecosystem approach to Natura 2000 but preserved and interconnected ecosystems, preserving biodiversity and sequestering carbon;
- We demand not just irrigation agriculture, but high-tech agriculture adapted to climate change and ensuring high standards of ecosystem protection and restoration;
- We demand not merely a program for improving the innovative capacity of scientific organizations and higher education institutions that used to be “modern” years ago, but the development of a special, funded program for national development of start-up businesses in universities and specialized centers, with access to scientific infrastructure;
- We demand not merely an admission of the problem that Bulgaria is among the “modest innovators” in the EU, but real actions in support of the innovative economy by establishing a Fund for the support of innovative, green small and medium-sized enterprises and a facilitating regulatory infrastructure;
- We demand not simply new industrial parks following a decades-old concept, but the establishment of modern regional innovation hubs, connecting business, and science, supporting the development of local business, based on Industry 4.0, and entry of Bulgarian companies on foreign markets;
- We demand a structured and timely transition to a circular economy in Bulgaria, according to the EU’s Circular Economy Action Plan, which is a key pillar of the European Green Deal.
- We demand the development and implementation of a framework policy on education and information dissemination on the topics of Bulgaria’s sustainable economic development.
- We demand an awareness campaign aimed at reaching the widest possible audience, regarding the socioeconomic and environmental issues, faced by Bulgarian society, as well as the approaches and means for solving them. We demand priority elaboration and implementation of educational methodologies with regard to the topics of sustainable development and circular economy, as a key priority of the Plan.
With this letter, the “Green Restart” Coalition, would like to use the occasion, to ask for the organizing of a working meeting with representatives of the Council of Ministers team, involved in the development of the Plan, where our experts, representing scientific, business and environmental conservation organizations, would present their specific proposals for the improvement of the Plan. Thus, we can contribute to the development of future programs and help bring Bulgaria closer to the standards for transparent consultation processes and dialogue with stakeholders. You can find attached our detailed proposals (in the Bulgarian language), divided into subjects, based on the expertise of the organizations in the Coalition.
The “Green Restart” Coalition, also insists on:
- Ensuring transparency – publishing a report on which of the proposals from the public consultation process have been approved and based on what criteria, as well as which of these proposals were rejected and based on what criteria; announcement of the selection team;
- Urgent disclosure of the following steps under the Plan – when the final version of the Plan will be presented to the European Commission and what is the process, leading to that stage;
- Ensuring transparency of the process of negotiation of the Plan with the European Commission by the fixed deadline - 30.04.2021;
- The establishment of a mechanism for continuous involvement of the stakeholders in the last stage of approval of the Plan – how representatives of the civic sector, business, and science would be able to comment on the reforms and investments, proposed in Version 1.1 of the Plan;
- Mandatory Strategic environmental assessment of the Plan and full disclosure of the outcome of the assessment;
- Mandatory implementation of a process for public evaluation of the projects, proposed in the Plan against the European taxonomy for sustainable finance;
- The incorporation of the five urgent measures from the latest Position of the “Green Restart” Coalition, in the amended version of the Plan.
Based on the understanding that the decisions for reforms and investments for the transition to a green and innovative economy, made now, will determine Bulgaria’s development for the decades to come, we, the members of the “Green Restart” Coalition, insist that all available expertise and resources in Bulgaria must be used to make the necessary amendments to the Plan. We must create programming that opens new horizons for the development of Bulgaria, based on leading global practices and standards, thus, positioning Bulgaria as a true factor in the economic and community development of Europe and the entire world. There is still time until the Plan’s final submission deadline and we call upon the government to embed ideas and approaches, which go beyond catching-up and program prosperity in the automation age and foster collective environmental and climate stewardship. Mindful of Bulgaria’s future, we will readily contribute our expertise.
Respectfully,
Coalition „Green Restart”
Sasha Bezuhanova,
Founder of MOVE.BG
Vesselina Kavrakova,
CEO of WWF Bulgaria
Denitza Petrova,
CEO of "Greenpeace" – Bulgaria
Svetoslav Stoykov,
Co-founder and CEO of the "Institute for Circular Economy"
You can find our detailed proposals here in the Bulgarian language.
