COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019 Country Report - BULGARIA Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2019: A Europe that protects its citizens and enhances their quality of life
Date: 2019-04-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Bulgaria, EU environmental policy, application of EU law, climate change policy, environmental law, environmental protection, governance, green economy, public health, quality of the environment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.4.2019  SWD(2019) 113 final  COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019      Country Report - BULGARIA             Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2019: A Europe that protects its citizens and enhances their quality of life   {COM(2019) 149 final} - {SWD(2019) 111 final} - {SWD(2019) 112 final} - {SWD(2019) 114 final} - {SWD(2019) 115 final} - {SWD(2019) 116 final} - {SWD(2019) 117 final} - {SWD(2019) 118 final} - {SWD(2019) 119 final} - {SWD(2019) 120 final} - {SWD(2019) 121 final} - {SWD(2019) 122 final} - {SWD(2019) 123 final} - {SWD(2019) 124 final} - {SWD(2019) 125 final} - {SWD(2019) 126 final} - {SWD(2019) 127 final} - {SWD(2019) 128 final} - {SWD(2019) 129 final} - {SWD(2019) 130 final} - {SWD(2019) 131 final} - {SWD(2019) 132 final} - {SWD(2019) 133 final} - {SWD(2019) 134 final} - {SWD(2019) 135 final} - {SWD(2019) 136 final} - {SWD(2019) 137 final} - {SWD(2019) 138 final} - {SWD(2019) 139 final}  
 
 
This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European  Commission. 
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1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

EXECUTIVE SUMMARY ................................................................................................................................... 3 

PART I: THEMATIC AREAS .............................................................................................................................. 4 

1. 

TURNING  THE  EU  INTO  A  CIRCULAR,  RESOURCE-EFFICIENT,  GREEN  AND  COMPETITIVE  LOW-
CARBON ECONOMY .............................................................................................................................. 4 

Measures towards a circular economy ................................................................................................. 4 
Waste management .............................................................................................................................. 6 
Climate change ...................................................................................................................................... 8 

2. 

PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL .................................................. 10 

Nature and biodiversity ....................................................................................................................... 10 
Estimating natural capital ................................................................................................................... 11 
Invasive alien species .......................................................................................................................... 12 
Soil protection ..................................................................................................................................... 12 
Marine protection ............................................................................................................................... 13 

3. 

ENSURING CITIZENS’ HEALTH AND QUALITY OF LIFE ........................................................................ 15 

Air quality ............................................................................................................................................ 15 
Industrial emissions ............................................................................................................................. 16 
 ................................................................................................................................................. 17 
Noise 
Water quality and management ......................................................................................................... 18 
Chemicals ............................................................................................................................................ 20 
Making cities more sustainable ........................................................................................................... 21 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ................................................................... 24 

4. 

GREEN  TAXATION,  GREEN  PUBLIC  PROCUREMENT,  ENVIRONMENTAL  FUNDING  AND 
INVESTMENTS ..................................................................................................................................... 24 

Green taxation and environmentally harmful subsidies ..................................................................... 24 
Green public procurement .................................................................................................................. 25 
Environmental funding and investments ............................................................................................ 26 

5. 

STRENGTHENING ENVIRONMENTAL GOVERNANCE ......................................................................... 30 

Information, public participation and access to justice ...................................................................... 30 
Compliance assurance ......................................................................................................................... 31 
Effectiveness of environmental administrations................................................................................. 32 
International agreements ................................................................................................................... 34 
Sustainable development and the implementation of the UN SDGs .................................................. 35 

2 

 
 
 
 
Environmental Implementation Review 2019 – Bulgaria 

Executive summary 

However,  proper  implementation  of  nature  protection 
legislation remains a  challenge. Among the main threats 
to  biodiversity  in  Bulgaria  remains  the  loss  of  habitats 
resulting  from  urban  and  infrastructure  development. 
Policy-related weaknesses still include poor enforcement 
of conservation laws and environmental regulations due 
to  absence  of  conservation  objectives  and  measures, 
ineffective management and administration of protected 
areas  as  well  as  insufficient  financing  or  inefficient 
spending of available financing. 

Examples of good practice 

assessment  under 

  Bulgaria  has  taken  steps  to  provide  for  streamlined 
incorporating  the 
environmental  assessments  by 
appropriate 
the  Habitats 
Directive,  the  integrated  pollution  prevention  and 
control  (IPPC)  permitting  process  and  the  ‘Seveso’ 
process  for  chemical  safety  into  its  EIA  procedures. 
Streamlining  helps  to  reduce  the  administrative 
burden,  enhances  coherence  and  accelerates 
decision-making,  and  efforts  should  turn  towards 
adequate implementation of these provisions. 

Bulgaria and the Environmental Implementation Review 
(EIR) 

In the 2017 EIR report, the main challenges identified for 
Bulgaria  for  the  implementation  of  EU  environmental 
policy and law were: 

 
 

 

to improve air quality, 
to  ensure  appropriate  collection  and  treatment  of 
urban waste water; and 
to 
legislation. 

implement 

protection 

properly 

nature 

Since  the  2017  EIR  report,  Bulgaria  has  not  yet  held  a 
national EIR dialogue to discuss those challenges. 

In  2017,  the  Commission  launched  TAIEX-EIR  Peer-to-
Peer  (EIR  P2P)  tool  to  facilitate  peer-to-peer  learning 
between 
environmental 
authorities. 

national 

experts 

from 

Bulgaria  took  part 
reducing emissions from domestic heating. 

in  a  peer-to-peer  workshop  on 

Progress on meeting challenges since the 2017 EIR 

There has been some progress in implementing measures 
addressing  air  pollution.  It  is,  however,  limited  to  the 
adoption  of  legal  acts.  No  effective  implementation  in 
practice  has  been  reported  so  far.  Bulgaria  remains 
among  the  Member  States  with  the  most  pollution-
related  deaths,  number  of  years  of  life  lost  associated 
with  air  pollution,  and  urban  population  exposure  to 
micro-particles. 

There  is  no  significant  progress  in  ensuring  compliance 
with  the  urban  wastewater  collection  and  treatment 
obligations. Currently, close to 26% of the wastewater is 
collected and even less of the load collected is subject to 
secondary  treatment  or  undergoes  more  stringent 
treatment. 

There  is  still  no  overarching  circular  economy  policy 
programme in Bulgaria.  

Waste management continues to be a challenge, despite 
municipal waste generation being below the EU average. 
According  to  the  Commission’s  ‘Early  Warning  Report’ 
(2018),  Bulgaria  is  considered  at  risk  of  non-compliance 
with  the  2020  municipal  waste  recycling  target  of  50 %. 
Bulgaria  has  adopted  a  good 
legal  basis  for  fair 
calculation  of  waste  collection  fees  but  the  law  has  not 
yet entered into force, so the ‘polluter pays’ principle has 
yet to be applied.  

Bulgaria  has  made  substantial  progress  in  providing 
support for mapping and assessment of ecosystems and 
services,  and  for  valuation  and  development  of  natural 
capital accounting systems.  

3 

 
 
 
Environmental Implementation Review 2019 – Bulgaria 

Part I: Thematic Areas 

1. Turning the EU into a circular, resource-efficient, green and 

competitive low-carbon economy 

Measures towards a circular economy 

The  Circular  Economy  Action  Plan  emphasises  the  need 
to  move  towards  a  life-cycle-driven  ‘circular’  economy, 
reusing  resources  as  much  as  possible  and  bringing 
residual  waste  close  to  zero.  This  can  be  facilitated  by 
developing  and  providing  access  to  innovative  financial 
instruments and funding for eco-innovation. 

Following  the  adoption  of  the  Circular  Economy  Action 
Plan in 2015 and the setting up of a related stakeholder 
platform  in  2017,  the  European  Commission  adopted  a 
new  package  of  deliverables  in  January  20181.  This 
included  additional  initiatives  such  as:  (i)  an  EU  strategy 
for plastics; (ii) a Communication on how to address the 
interplay  between  chemical,  product  and  waste 
legislation; (iii) a report on critical raw materials; and (iv) 
a  framework  to  monitor  progress  towards  a  circular 
economy2.  

Examining  the  10  indicators  in  the  circular  economy 
monitoring  framework,  the  circular  (secondary)  use  of 
material in Bulgaria was 4.3 % in 2016 (significantly lower 
than  the  EU-28  average  of  11.7 %).  On  the  other  hand, 
Bulgaria performs in line with the EU-28 average in terms 
of  the  number  of  persons  employed  in  the  circular 
economy, at 1.76 % of total employment in 2016 (EU-28 
average  1.73 %).  The  percentage  of  jobs  in  Bulgaria 
related  to  the  circular  economy  seems  to  have  dropped 
since 2012, when it was 1.83 %. 

In  the  2017  Special  Eurobarometer  on  EU  citizens’ 
attitudes  towards  the  environment,  84 %  of  Bulgarians 
said  they  were  highly  concerned  about  the  effects  of 
plastic  products  on  the  environment  (EU-28  average 
87 %).  89 %  said  they  were  concerned  about  the  impact 
of  chemicals  (EU-28  average  90 %)3.  Support  for  circular 
initiatives  and  environmental  protection 
economy 
measures in Bulgarian society appears to be strong. 
Resource productivity4 (how efficiently the economy uses 
material  resources  to  produce  wealth)  in  Bulgaria  was 

0.30 EUR/kg in 2017 compared to the EU average of 2.04 
EUR/kg  (as  shown  in  Figure  1).  Resource  productivity  in 
Bulgaria  remains  among  the  lowest  in  the EU  together 
with Estonia and Romania5. 

As  pointed  out  in  the  2017  EIR,  no  overarching  circular 
economy policy programme exists in Bulgaria. 
Figure 1: Resource productivity 2010-20176 

The number of EU Ecolabel products and EMAS7-licensed 
organisations in a country can give a rough measurement 
of  the  circular  economy  transition.  These  two  indicators 
show  to  what  extent  this  transition  is  engaging  the 
private  sector  and  other  national  stakeholders.  These 
two  indicators  also  show  the  commitment  of  public 
authorities to policies that support the circular economy. 
As of September 2018, Bulgaria had only 23 products and 
5  licences  registered  in  the  EU  Ecolabel  scheme  out  of 
71707  products  and  2167  licences  in  the  EU8.  Bulgaria 
had 9 organisations registered in EMAS as of May 20189. 

SMEs and resource efficiency 

Bulgarian  SMEs  continue  to  perform  below  the  EU 
average on  environmental aspects of the  Small Business 
Act (see Figure  2).  Since 2008,  only limited progress has 
been made in this area. 

1 European Commission, 2018 Circular Economy Package. 
2 COM(2018) 029. 
3 European Commission, 2017, Special 468 Eurobarometer, ‘Attitudes of 
European citizens towards the environment’. 
4 Resource productivity is defined as the ratio between gross domestic 
product (GDP) and domestic material consumption (DMC). 

5 European Commission, Resource productivity. 
6 European Commission, Resource productivity. 
7 EMAS is the European Commission’s Eco-Management and Audit 
Scheme – a programme to encourage organisations to behave in a more 
environmentally sustainable way. 
8 European Commission, Ecolabel Facts and Figures. 
9 European Commission, Eco-Management and Audit Scheme. 

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Environmental Implementation Review 2019 – Bulgaria 

The  percentages  of  SMEs  that  have  taken  resource 
efficiency  measures  or  that  offer  green  products  or 
services are well below the EU average. 

The  proportion  that  create  more  than  50 %  of  their 
turnover from green products and services is higher than 
in  most  EU countries.  Small  businesses  taking  resource 
efficiency measures receive more public support than the 
EU  average.  Against  this  background,  the  Bulgarian 
support  system  seems  well  equipped  to  reach  out  to 
more SMEs and encourage them to take actions that are 
more ambitious. 
Figure 2: Environmental performance of SMEs10 

efficient.  For  them,  private  sector  funding  and  private 
sector  consultancy  gained  in  importance,  while  public 
sector  funding  and  advice  fell  significantly  compared  to 
2015. 

Among  Bulgarian  companies,  grants  and  subsidies  are 
mentioned by 32 % as useful help; the different types of 
consultancy  are  assigned  similar  importance  (17-18 %) 
slightly less than the EU average (20-23 %). 

There  is  significant  potential  for  raising  awareness  and 
ambition among SMEs to become more resource efficient 
and to develop products and services for green markets. 

Establishing  accessible  and  effective  support  services  is 
an essential element of any strategy — but this is having 
less 
impact  because  Bulgarian  enterprises  currently 
assign little value to external cooperation. 

Eco-innovation 

In  2018,  Bulgaria  ranked  27th  on  the  2018  European 
Innovation  Scoreboard,  as  the  sixth  worst-growing 
innovator  (having  slipped  1.5 %  since  2010)12.  In  2017, 
the  country  was  ranked  last  under  the  Eco-innovation 
Scoreboard  (see  Figure  3).  As  shown  in  Figure  4,  since 
2010, Bulgaria’s performance continues to be well below 
the EU average. 
Figure 3: 2017 Eco-innovation index (EU=100)13 

The  latest  Eurobarometer  on  ‘SMEs,  resource  efficiency 
and green markets’11 asked companies about both recent 
resource-efficiency actions they had taken and additional 
resource  efficiency  actions  they  planned  to  take  in  the 
next  2  years.  The  Eurobarometer  then  compared  these 
responses with responses given to the same questions in 
2015.  Bulgarian  companies  show  a  decline  in  intentions 
to invest  in all eight aspects  of resource efficiency, from 
the already low levels in 2015. 

Only  13 %  of  Bulgarian  companies  (against  a  range  of 
3 %-38 %  in  the  EU  and  an  average  of  22 %)  relied  on 
external  support  in  their  efforts  to  be  more  resource 

10 European Commission, 2018 SBA fact sheet - Bulgaria, p. 14. 
11 Flash Eurobarometer 456 ‘SME, resource efficiency and green 
markets’ January 2018. The 8 dimension were Save energy; Minimise 
waste; Save materials; Save Water; Recycle by reusing material 
internally; Design products easier to maintain, repair or reuse; Use 
renewable energy; Sell scrap materials to another company. 

12 European Commission, European Innovation Scoreboard 2018. 
13 European Commission, Eco-Innovation Observatory: Eco-innovation 
Scoreboard 2017. 

5 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

Figure 4: Bulgaria’s Eco-innovation performance 

Some  of  the  main  challenges  for  eco-innovation  in 
Bulgaria  are  still:  to  increase  investment  opportunities, 
promote  efficient  use  of  resources,  further  develop 
renewable  energy  sources,  and  improve  sustainability 
practices within the transport sector. 

such  as: 

Significant  drivers  of  eco-innovation  have  also  been 
identified, 
increased  awareness  among 
businesses,  citizens  and  government  of  the  benefits  of 
green  products  and  technologies;  highly  skilled  human 
resources  and  knowledge  capital;  and  Bulgaria’s  leading 
regional position in the information and communications 
technology (ICT) sector. 

technologies 

Targeted  support  for  eco-innovation  is  provided,  for 
example,  by  the  National  Innovation  Fund  and  the 
European  Regional  Development  Fund  (by  Operational 
Programme  “Innovation  and  Competitiveness”  2014-
2020).  In  recent  years,  projects  have  been  approved  for 
innovative 
for  environmentally  sound 
treatment of hazardous waste, recovery of waste rubber 
products, production of heat by waste pyrolysis, analysis 
of exhaust emissions, conversion of conventional electric 
vehicles,  etc.  In  2018  Bulgaria  approved  11  National 
Research  Programmes  with  around  EUR  30.5  million  to 
be  spent  in  research  projects  until  2022.  Two  of  these 
programmes  cover  research  related  environmental 
low 
challenges  –  National  research  programme  for 
carbon  energy  for  the  transport  and  households  and 
National 
for  environmental 
protection  and  reduction  of  the  risk  of  adverse 
phenomena and natural disasters with financial resourse 
of  approximately  EUR  3.7  million  and  EUR  3  million 
respectively14.  

research  programme 

Eco-innovation is also promoted by organisations such as 
Cleantech Bulgaria, which is a business network founded 
in  2012  to  promote  sustainable  economic  development 
through clean technologies and green innovation. 

The Eco-innovative Virtual Lab was set  up as part  of the 
EcoInn Danube project co-funded by the Interreg Danube 
Programme.  The  general  objective 
improve 
cooperation  between  people  active  in  eco-innovation, 

is  to 

14 The Republic of Bulgaria, National research programmes. 

6 

with  special  emphasis  on 
application of eco-technologies in the Danube Region15. 

the  development  and 

2019 priority action 

  A  strategic 

integrated 
long-term  view  and  an 
approach  for  mainstreaming  government’s  policies 
to speed up the uptake of the circular economy by all 
economic sectors needs to be developed. 

Waste management 

Turning waste into a resource is supported by: 
(i)  fully 
legislation,  which 
implementing  EU  waste 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate  collection  of  waste,  the 
landfill  diversion 
targets, etc.; 
(ii) reducing waste generation and waste generation per 
capita in absolute terms; and  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This  section  focuses  on  management  of  municipal 
waste16  for  which  EU  law  sets  mandatory  recycling 
targets17. 

Figure  5:  Municipal  waste  by  treatment  in  Bulgaria 
2010-201718 

Municipal waste generation in Bulgaria increased in 2017 
(see  Figure  5),  stopping  a  slightly  downward  trend  since 

15 European Commission, Eco-Innovation Observatory: Eco-innovation 
Country Profile 2016-2017: Bulgaria. 
16 Municipal waste consists of mixed waste and separately collected 
waste from households and from other sources, where such waste is 
similar in nature and composition to waste from households. This is 
without prejudice to the allocation of responsibilities for waste 
management between public and private sectors. 
17 See Article 11.2 of Directive 2008/98/EC. This Directive was amended 
in 2018 by Directive (EU) 2018/851, and more ambitious recycling 
targets were introduced for the period up to 2035. 
18 Eurostat, Municipal waste by waste operations. 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

2014,  but  remaining  below  the  EU  average  (435 
to  487  kg/y/inhabitant). 
kg/y/inhabitant  compared 
Figure 5 depicts municipal waste by type of treatment in 
Bulgaria in kg per capita. It shows the landfilled amounts 
have fallen since 2010, composting has increased, and a 
small amount of waste has been diverted from landfill to 
incineration. 

Recycling  of  municipal  waste  (including  composting)  has 
slightly  increased,  to  35 %  in  2017  (see  Figure  6).  The 
recycling  rate  remains  considerably  lower  than  the  EU 
average of 46 %; and significant efforts will be needed to 
meet the 50 % EU recycling target by 202019. One of the 
root causes of the lack of progress in separate collection 
of  recyclable  materials  other  than  metals 
is  the 
competition between the formal and the informal waste 
collection 
the 
incentives  both  of  extended  producer  responsibility 
schemes to invest in separate collection and of citizens to 
participate in it.  
Figure 6: Recycling rate of municipal waste 2010-201720 

systems.  This  competition  affects 

For  this  reason,  in  its  ‘Early  Warning  Report’21,  the 
Commission listed Bulgaria among the Member States at 
risk of missing the 2020 municipal waste recycling target, 
and  recommended  country-specific  actions  to  close  the 
gap.  Even  more  effort  will  be  necessary  to  comply  with 
recycling  targets  for  the  post-2020  period22.  Notable 

19 Member States may choose a different method than the one used by 
ESTAT (and referred to in this report) to calculate their recycling rates 
and track compliance with the 2020 target of 50 % recycling of 
municipal waste. 
20 Eurostat, Recycling rate of municipal waste. 
21 European Commission, Report on the implementation of EU waste 
legislation, including the early warning report for Member States at risk 
of missing the 2020 preparation for re-use/recycling target on municipal 
waste, COM(2018) 656. 
22 Directive (EU) 2018/851, Directive (EU) 2018/852, Directive (EU) 
2018/850 and Directive (EU) 2018/849 amend the previous waste 

7 

progress has been made in increasing composting, which 
stood at 8 % in 2017 but is still below the EU average of 
around 16.5 %. Most of this increase, however, relates to 
non-household 
from 
businesses and parks). 

biodegradable  waste 

(e.g. 

Bulgaria  still  has  one  of  the  highest  landfill  rates  for 
municipal waste in the EU (at 62 % in 2017 compared to 
the EU average of around 24 %). 

Bulgaria  reported  that  all  landfills  which  do  not  comply 
with EU standards have  stopped accepting waste but  its 
implementation record needs to be further improved: as 
a  matter  of  priority,  they  need  to  be  definitively  closed 
illegal  dumpsites  eliminated. 
and  rehabilitated,  and 
Despite  significant  progress 
in  the  closure  of  non-
compliant sites, their rehabilitation remains a challenge. 

In  2013,  Bulgaria  introduced  a  law  that  required  waste 
collection  fees  to  be  calculated  based  on  the  generated 
waste (the ‘pay-as-you-throw’ principle), instead of being 
based on the value of the real estate property. It was due 
to  enter  into  force  on  1 January  2015  but  this  has  been 
postponed a number of times, the last target date being 
1 January  2018.  In  October  2017,  an  amendment  to  the 
Law  on  Local  Taxes  and  Fees  clarified  the  methods  for 
calculating  costs  and  waste  collection  fees,  but  further 
postponed  the 
implementation  of  the  polluter-pays 
principle until 1 January 2020. 

All  municipalities  are  obliged  to  collect  at  least  four 
recycling streams, plus biodegradable waste. There is no 
door-to-door  collection  for  these,  and  waste  collection 
points  are  mainly  for  packaging  materials,  such  as  glass, 
metal and plastic, paper and residual waste.  

A new Ordinance on separate collection and treatment of 
biowaste was adopted in early 2017. The new Ordinance 
stipulates  that  the  amount  of  landfilled  biowaste  must 
not  exceed  109kg  per  capita  by  2020.  Progress  in 
accordance with that target has yet to be measured.  

The landfill tax is set to rise progressively to EUR 48.6 per 
tonne  by  2020.  There 
incentive  scheme  for 
is  an 
municipalities linked to this tax. Those municipalities that 
meet  their  recycling  target  will  not  have  to  pay  landfill 
tax.  This  should  stimulate  the  market  if  the  measure  is 
enforced. 

In  2016,  several  calls  to  use  cohesion  policy  funds  were 
published,  targeting  green  and  other  biodegradable 
waste  collection  and 
treatment.  The  Operational 
Programme makes funding available to municipalities for 
biowaste  treatment23.  Bulgaria  continues  to  set  up 

legislation and set more ambitious recycling targets for the period up to 
2035. These targets will be taken into consideration to assess progress 
in future Environmental Implementation Reports. 
23 The Republic of Bulgaria, Operational programme environment 2014-
2020  

 
                                                                 
 
                                                                                                        
Environmental Implementation Review 2019 – Bulgaria 

Figure  7:  Change  in  total  GHG  emissions  1990-2017 
(1990=100 %)24.  

municipal  sorting  and  mechanical  biological  treatment 
facilities.  Most  of  these  investments  so  far  have  been 
oriented  towards  RDF  preparation  for  combustion  in 
cement kilns, with little focus on recycling. 

Bulgaria is also planning to strengthen legal enforcement 
and control of implementation by municipalities. 

2019 priority actions 

  Address  as  a  matter  of  priority  the  sealing  and 

rehabilitation of non-compliant landfills. 

  Make  continuous  efforts  to  prevent  illegal  dumping 

 

 

of waste, including littering. 
Improve  and  extend  separate  collection  of  waste, 
including 
for  bio-waste.  Set  minimum  service 
standards  for  separate  collection  (e.g.  frequency  of 
collection, types of containers  etc.) in municipalities 
to  ensure  high  rates  of  capture  of  recyclable  waste. 
Develop 
support 
programmes  for  municipalities  to  help  support 
efforts  to  organise  separate  collection  and  improve 
recycling performance.  
Enforce and use economic instruments, such as pay-
as-you-throw. Introduce new instruments to improve 
recyling performance. 

implementation 

and 

run 

Climate change 

The EU has committed to undertaking ambitious climate 
action internationally as well as in the EU, having ratified 
the Paris Climate Agreement on 5 October 2016. The EU 
targets are to reduce greenhouse gas (GHG) emissions by 
20 % by 2020 and by at least 40 % by 2030, compared to 
1990.  As  a  long-term  target,  the  EU  aims  to  reduce  its 
emissions  by  80-95 %  by  2050,  as  part  of  the  efforts 
required by developed countries as a group. Adapting to 
the adverse effects of climate change is vital to alleviate 
its  already  visible  effects  and  improve  preparedness  for 
and resilience to future impacts. 

The EU emissions trading system (EU ETS) covers all large 
greenhouse  gas  emitters  in  the  industry,  power  and 
aviation  sectors  in  the  EU.  The  EU  ETS  applies  in  all 
Member States and has a very high compliance rate. Each 
year,  installations  cover  around  99 %  of  their  emissions 
with the required number of allowances.  

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  effort  sharing 
legislation.  Bulgaria’s  emissions  were  below  its  annual 
emission  allocations  (AEAs)  in  each  of  the  years  2013-
2016. According to preliminary data, Bulgaria had slightly 
higher  emissions  than  the  AEAs  in  2017.  For  2020, 
Bulgaria’s  national  target  under  the  Effort  Sharing 
Decision  is  to  avoid  increasing  emissions  by  more  than 
20 %  compared  to  2005.  For  2030,  Bulgaria’s  target 
under  the  Effort  Sharing  Regulation  will  be  to  have 
emissions no higher than in 2005. 

Under  the  energy  union  initiative,  Member  States  are 
preparing  integrated  national  energy  and  climate  plans 
(NECPs)  and  long-term  climate  and  energy  strategies. 
Bulgaria submitted its NECP in January 2019. 

Under  the  F-gas  regulation,  Member  States  must 
introduce  training  and  certification  programmes  and 
rules  on  penalties,  and  notify  these  measures  to  the 
Commission  by  2017.  Bulgaria  has  notified  both 
measures. 

Figure  8:  Targets  and  emissions  for  Bulgaria  under  the 
Effort Sharing Decision and Effort Sharing Regulation25. 

Accounting  of  emissions  and  removals  from  forests  and 
agriculture are governed by the Kyoto Protocol. Reported 
quantities under the Kyoto Protocol for Bulgaria show net 
removals  of,  on  average,  -7.1  Mt  CO2-eq  for  the  period 

24 Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 
2017Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 
25 Proxy GHG emission estimates for 2017Approximated EU greenhouse 
gas inventory 2017 (European Environment Agency). Member States 
national projections, reviewed by the European Environment Agency. 

8 

 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

2019 priority action 

In this report, no priority actions have been included on 
climate action, as the Commission will first need to assess 
the  draft  national  energy  and  climate  plans  which  the 
Member  States  needed  to  send  by  end  of  2018.  These 
plans  should  increase  the  consistency  between  energy 
and climate policies and could therefore become a good 
example  of  how  to  link  sector-specific  policies  on  other 
interlinked themes  such as agriculture-nature-water and 
transport-air-health.  

2013  to  2016.  In  this  regard,  Bulgaria  contributes  some 
1.9 %  to  the  EU-28’s  annual  average  sink  of  -384.4  Mt 
CO2-eq.  Accounting  for  the  same  period  depicts  net 
debits of, on average, 0.8 Mt CO2-eq, which corresponds 
to  a  negative  contribution  of  -0.7 %  of  the  EU-28 
accounted sink of -115.7 Mt CO2-eq. Bulgaria is one of six 
EU  Member  States  that  show  net  debits 
in  this 
preliminary  accounting  exercise.  Reported  net  removals 
show  minor  variations  with  no  trend,  while  accounted 
net  debits  depict  the  same  variation  with  slight 
decreasing tendencies. 

The  EU  Strategy  on  adaptation  to  climate  change, 
adopted  in  2013,  aims  to  make  Europe  more  climate-
resilient, by promoting action by Member States, better-
informed  decision  making,  and  promoting  adaptation  in 
key vulnerable sectors. By adopting a coherent approach 
and  providing  for  improved  coordination,  it  seeks  to 
enhance the preparedness and capacity of all governance 
levels to respond to the impacts of climate change.  

Bulgaria  is  currently  drafting  its  national  adaptation 
strategy  and  plan,  through  a  project  run  with  advisory 
support  from  the  World  Bank.  The  draft  strategy  is 
underpinned  by  climate  adaptation  assessments  in  nine 
sectors of interest and by a study on the macroeconomic 
implications of climate change. A strategy on adaptation 
to climate change for the  municipality of Sofia has been 
drafted  under  the  EU-funded  project 
‘Transitioning 
towards Urban Resilience and Sustainability ‘TURAS’. 

Figure 9: Greenhouse gas emissions by sector (Mt. CO2-
eq.). Historical data 1990-2016. Projections 2017-203026. 

Bulgaria’s  total  revenues  from  auctioning  emission 
allowances  under  the  EU  ETS  over  the  years  2013-2017 
came  to  EUR 427  million.  100 %  of  the  auctioning 
revenues  have  been  spent  on  climate  and  energy 
purposes. 

26 European Environmental Agency, Total GHG trends and projections. 

9 

 
                                                                 
 
Environmental Implementation Review 2019 – Bulgaria 

2. Protecting, conserving and enhancing natural capital 

Nature and biodiversity 

in  the  EU  by  2020. 

The  EU  biodiversity  strategy  aims  to  halt  the  loss  of 
biodiversity 
full 
implementation  of  the  Birds  and  Habitats  Directives  to 
achieve  favourable  conservation  status  of  protected 
species and habitats. It also requires that the agricultural 
and  forest  sectors  help  to  maintain  and 
improve 
biodiversity. 

It  requires 

Biodiversity strategy 

The  major  national  document  related  to  biodiversity  in 
Bulgaria  is the  second national biodiversity conservation 
plan 2005-2010. The plan has not been updated formally 
but  new  national  priorities  have  been  formulated  and 
implemented. 

Although Bulgaria is a relatively small country (111 001.9 
km2),  due  to 
its  highly  varied  climatic,  geological, 
topographic  and  hydrologic  conditions  it  is  very  rich  in 
biological diversity — 26 % of the total species described 
for Europe occur in its territory and represent more than 
2 % of the  species in the  world27,28. Thus, Bulgaria  ranks 
among the countries with the greatest biological diversity 
in  Europe.  38,55 %  of  the  land  is  covered  by  forests 
situated  mostly  on  mountain  slopes  and  non-arable 
lands. 

Among  the  main  threats  to  biodiversity  in  Bulgaria 
remain  the  loss  of  habitats  resulting  from  urban  and 
infrastructure  development;  unsustainable  agriculture; 
increased  levels  of  air  pollution;  and  exploitation  of 
economically  viable  species.  Policy-related  weaknesses 
still relate to poor enforcement of conservation laws and 
absence  of 
environmental 
conservation  objectives  and  measures; 
ineffective 
management and administration of protected areas; and 
insufficient  financing  or  inefficient  spending  of  available 
financing. 

regulations, 

including 

27 IUCN Red List, Bulgaria’s biodiversity at risk. 
28 Bulgarian biodiversity portal. 

10 

Setting up a coherent network of Natura 2000 sites 

The Birds and Habitats Directives require Member States 
to establish a coherent national network of Natura 2000 
sites.  The  Commission  assesses  compliance  with  this 
requirement  individually  for  each  species  and  habitat 
type  occurring  on  the  national  territory  of  the  Member 
States. 

Bulgaria has designated 233 Natura 2000 sites under the 
Habitats Directive (Sites of Community Importance/SCIs). 
Three of these are entirely marine sites, while 14 include 
marine  sites 
in  their  territory.  Bulgaria  has  also 
designated  119 Natura  2000  sites  under  the  Birds 
Directive  (Special  Protection  Areas/SPAs).  In  total,  the 
SCIs and SPAs cover 41 053.2 km2 of Bulgaria’s territory, 
of  which  38 231.84  km2  is  land  and  2 821.35  km2  is 
marine territory. 

Bulgaria’s  Natura  2000  network  hosts  90  habitat  types 
and  121  species  other  than  birds,  including  28  priority 
habitats  and  8  priority  species,  120  birds  and  70 
migratory birds. 

The terrestrial part of the Natura 2000 network for birds 
is  almost  complete,  with  one  exception.  A  2018 
judgement  of  the  Court  of  Justice  of  the  EU  confirmed 
that  Bulgaria  has  not  designated  sufficient  territories  in 
the Rila mountain for the protection of 17 bird species (C-
97/17). With the implementation of this judgement, the 
terrestrial  part  of  the  network  for  birds  can  be 
considered as completed.  

Bulgaria  still  has  to  address  some  gaps  in  the  network 
under  the  Habitats  Directive.  Apart 
from  missing 
territories  in  Rila  mountain  for  Ursus  arctos  and  Cottus 
gobio,  there  are  several  other  terrestrial  features  to  be 
addressed.  In  addition,  the  latest  assessment  of  the  SCI 
part of the Natura 2000 network shows that there are stil 
some  scientific  reservations  regarding  features  for  the 
marine components of the network29. The Commission is 
monitoring this issue closely. 

Designating Natura 2000 sites and setting conservation 
objectives and measures 

Bulgaria has not yet met its obligations under Article 4(4) 
of  the  Habitats  Directive  to  designate  SCIs  as  special 
areas  of  conservation  (SACs)  and  under  Article  6(1)  to 

29 For each Member State, the Commission assesses whether the 
species and habitat types in Annexes I and II of the Habitats Directive 
are sufficiently represented by the sites designated to date. This is 
expressed as a percentage of species and habitats for which further 
areas need to be designated in order to complete the network in that 
country. The current data, which were assessed in 2014-2015, reflect 
the situation up until December 2013. 

 
 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

define site-specific conservation objectives and establish 
conservation  measures 
to 
for 
maintain/restore  species  and  habitats  of  community 
interest  to  a  favourable  conservation  status  across  their 
natural range. In September 2018, only 9 of the 233 SCIs 
had their designation orders published. 

in  order 

them 

A  strong  and  urgent  focus  is  essential,  on  setting  site-
specific  conservation  objectives  and  conservation 
measures, setting up an efficient  management  structure 
for  Natura  2000  and  strengthening  the  capacity  of  the 
administration and other bodies dealing with the Natura 
2000 network. 

Bulgaria  has  made  no  progress  since  the  2017  EIR  in 
setting up management bodies for the Natura 2000 sites. 
Management  bodies  are  only  in  place  for  the  sites  that 
overlap with the three national parks and the six nature 
parks.  Management  plans  for  these  nine  parks  exist  but 
some of them are long outdated. Very few other Natura 
2000 sites have management plans in place. 

Integrating  nature  and  biodiversity  policy  into  other 
sectoral policies will not only lead to better management 
of  the  Natura  2000  areas  and  protection  of  species,  but 
could provide additional sources of financing30. 

This  is  particularly  relevant  for  agriculture.  Significant 
destruction  of  high  nature  value  grasslands  seems  to 
have  occurred  in  Bulgaria,  particularly  in  a  number  of 
Natura 2000 sites. 

The 2017 EIR Report referred to the latest report on the 
conservation status of habitats and species; new data will 
be available for the next EIR. 

Communication  initiatives  to  explain  Natura  2000,  its 
objectives,  obligations,  opportunities  and  benefits  both 
at  national  and  regional  level,  especially  in  areas  where 
opposition to the Natura network is found, are still to be 
carried  out  in  order  to  help  avoiding  negative  attitudes 
and gain local people’s support. 

continues.  Many  developments  representing  a  major 
threat  to  conservation  objectives  have  still  been 
authorised. Although Bulgaria  has taken  some  measures 
to address the issue, this structural problem persists and 
the  Commission  regularly  receives  complaints  about 
plans  and  projects  being  authorised  on  the  basis  of 
inadequate  assessments,  or  even  without  appropriate 
assessments.  Bulgaria  would  have  to  enhance  efforts  to 
collect  reliable  data  and  improve  the  quality  of  the 
assessment and permitting procedures. 

2019 priority actions 

objectives 

  Complete the SAC designation process as a matter of 
priority  and  put  in place  clearly  defined  site-specific 
necessary 
conservation 
conservation  measures  for  each  habitat  and  species 
of community interest in all Natura 2000 sites. 
Establish  efficient  management  structures  for  the 
Natura  2000  network,  with  sufficient  administrative 
and financial capacity. 

and 

the 

 

  Address  shortcomings  in  the  implementation  of  the 
nature  directives  (in  particular  the  authorisation  of 
plans  and  projects)  and  integration  of  the  policy  in 
the other sectoral policies. 

Progress 
restoring 
in  maintaining  or 
conservation status of species and habitats 

favourable 

Estimating natural capital 

Considering that Member States report every 6 years on 
the  progress  made  under  both  directives,  no  new 
information  is  available  on  the  state  of  natural  habitats 
and  species,  or  on  progress  made  in  improving  the 
conservation status of species and habitats in Bulgaria, as 
compared to the 2017 EIR Bulgarian Country Report. 

The  practice  of  authorising  plans  and  projects  without 
taking into account the cumulative impact of existing and 
authorised  plans  and  projects  to  Natura  2000  areas 

The  EU  biodiversity  strategy  calls  on  Member  States  to 
map  and  assess  the  state  of  ecosystems  and  their 
services31 in their national territories by 2014, assess the 
economic  value  of  such  services  and  integrate  these 
values  into  accounting  and  reporting  systems  at  EU  and 
national level by 2020. 

Bulgaria has profited from funding under grants provided 
by  Norway  and  the  European  Economic  Area  to  set  up 
national  projects  on  mapping  ecosystems  and  their 
services.  This  allowed  substantial  progress  in  2016  and 

30 European Commission, 2016. Integration of Natura 2000 and 
biodiversity into EU funding (EAFRD, ERDF, CF, EMFF, ESF). Analysis of a 
selection of operational programmes approved for 2014-2020. 

31 Ecosystem services are benefits provided by nature such as food, 
clean water and pollination on which human society depends. 

11 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

2017. The seven projects on nine ecosystems conditions 
by  type  outside  Natura  2000  were  completed  and 
summarised.  Horizontal  topics  (theoretical  guidance, 
landscape-level, pollination and fieldwork in Bulgaria) are 
available electronically. 

A  methodology  for  monetary  valuation  of  ecosystem 
services will be introduced in 2019 and is expected to be 
incorporated  into  national  accounts  as  a  next  step.  The 
Bulgarian Biodiversity Information System provides visual 
maps  of  all  assessments,  including  the  mapping  and 
assessment  projects  and  some  other  projects  that  may 
inform  ecosystem  monitoring  —  such  as  the  East  and 
South  European  Network  for  Invasive  Alien  Species  —  a 
tool  to  support  the  management  of  alien  species  in 
Bulgaria,  citizen  science  and  policy-related  projects  for 
biodiversity outside NATURA 2000. 

At  the  MAES  working  group  meeting  held  in  Brussels  in 
September  2018,  it  was  shown  that  Bulgaria  has  made 
substantial progress since January 2016 in implementing 
MAES (see Figure 10). This assessment was made by the 
ESMERALDA  project32  and  based  on  27  implementation 
questions. The assessment is updated every 6 months. 

Figure 10: Implementation of MAES (September 2018) 

poorer  because 
surveillance until the EU list was adopted. 

listed  species  were  not  subject  to 

Figure  11:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Bulgaria33 

Between  the  entry  into  force  of  the  EU  list  and  18 May 
2018, Bulgaria did not notify the Commission of any new 
appearances  of 
line  with 
Article 16(2) of the IAS Regulation. 

IAS  of  EU  concern, 

in 

As,  according  to  the  baseline  distribution,  coypu 
(Myocastor coypu) still  seems in an early invasion stage, 
Bulgaria is advised to attempt to eradicate this species, to 
avoid considerable long-term management costs. 

Finding  ways  of  improving  its  surveillance  system  and 
data collection would help Bulgaria’s performance in this 
area. 

Invasive alien species 

Soil protection 

Under  the  EU  biodiversity  strategy,  the  following  are  to 
be achieved by 2020:  
(i) invasive alien species identified;  
(ii) priority species controlled or eradicated; and  
(iii)  pathways  managed  to  prevent  new  invasive  species 
from disrupting European biodiversity.  
This  is  supported  by  the  Invasive  Alien  Species  (IAS) 
Regulation, which entered into force on 1 January 2015. 

The  report  on  the  baseline  distribution  (Figure  11),  for 
which Bulgaria did not review its data, shows that of the 
37 species on the first EU list only 4 have been observed 
in  Bulgaria.  All  are  aquatic  species  with  a 
limited 
distribution:  coypu  (Myocastor  coypus),  spiny-cheek 
crayfish  (Orconectes  limosus),  amur  sleeper  (Perccottus 
glenii)  and  sliders  (Trachemys  scripta).  The  data  suggest 
that Bulgaria is less invaded than neighbouring countries, 
but  this  could  instead  indicate  that  the  data  available  is 

32 EU project Esmeralda. 

The  EU  soil  thematic  strategy  underlines  the  need  to 
ensure a  sustainable use of soils.  This  entails preventing 
further  soil  degradation  and  preserving  its  functions,  as 
well as restoring degraded soils. The 2011 Roadmap to a 
Resource Efficient Europe states that by 2020, EU policies 
must  take  into  account  their  direct  and  indirect  impact 
on land use. 

Soil  is  a  finite  and  extremely  fragile  resource  and  it  is 
increasingly degrading in the EU. 

The  annual  land  take  rate  (growth  of  artificial  areas)  as 
provided  by  CORINE  Land  Cover  was  0.14 %  in  Bulgaria 
over  the  period  2006-12,  well  below  the  EU  average 
(0.41 %).  It  represented  755  hectares  per  year,  mainly 

33 Tsiamis K; Gervasini E; Deriu I; D'amico F; Nunes A; Addamo A; De 
Jesus Cardoso A. Baseline Distribution of Invasive Alien Species of Union 
concern. Ispra (Italy): Publications Office of the European Union; 2017, 
EUR 28596 EN, doi:10.2760/772692. 

12 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

mines,  quarries  and  dumpsites,  plus  housing,  services 
and recreation34. 
The percentage of artificial land35 in Bulgaria  (Figure 12) 
can  be  seen  as  a  measure  of  the  relative  pressure  on 
nature  and  biodiversity,  as  well  as  the  environmental 
pressure  on  people  living  in  urbanised  areas.  A  similar 
measure is population density. 
Figure 12: Proportion of artificial land cover, 2015 36 

Bulgaria  ranks  below  the  EU  average  for  artificial  land 
coverage,  with  1.8 %  of  artificial  land  (EU-28  average: 
4.1 %).  The  population  density  is  64.8/km2,  which  is  far 
below the EU average of 11837. 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  or  the  environment.  A  recent 
report  of  the  European  Commission38  estimated  that 
potentially  polluting  activities  have  taken  or  are  still 

34 European Environment Agency Draft results of CORINE Land Cover 
(CLC) inventory 2012; mean annual land take 2006-12 as a percentage 
of 2006 artificial land. 
35 Artificial land cover is defined as the total of roofed built-up areas 
(including buildings and greenhouses), artificial non built-up areas 
(including sealed area features, such as yards, farmyards, cemeteries, 
car parking areas etc. and linear features, such as streets, roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and viaducts, mobile homes, solar panels, power plants, electrical 
substations, pipelines, water sewage plants, and open dump sites). 
36 Eurostat, Land covered by artificial surfaces by NUTS 2 regions. 
37 Eurostat, Population density by NUTS 3 region. 
38 Ana Paya Perez, Natalia Rodriguez Eugenio (2018), Status of local soil 
contamination in Europe: Revision of the indicator “Progress in the 
management Contaminated Sites in Europe” 

13 

taking place on approximately 2.8 million sites in the EU. 
At EU level,  650 000 of these sites have been registered 
in national or regional inventories. 65 500  contaminated 
sites  already  have  been  remediated.  Bulgaria  has 
registered  26  sites  where  potentially  polluting  activities 
have  taken  or  are  taking  place,  and  already  has 
remediated or applied aftercare measures on 20 sites. 

Soil erosion by water is a natural process, but this natural 
process can be aggravated by climate change and human 
activities  such  as  inappropriate  agricultural  practices, 
deforestation,  forest  fires  or  construction  works.  High 
levels  of  soil  erosion  can  reduce  productivity 
in 
agriculture  and  can  have  negative  and  transboundary 
impacts  on  biodiversity  and  ecosystem  services.  High 
levels  of  soil  erosion  can  also  have  negative  and 
lakes  (due  to 
transboundary  effects  on  rivers  and 
transport  of 
and 
volumes 
increased 
contaminants).  According  to  the  RUSLE2015  model 39, 
Bulgaria  has  an  average  soil  loss  rate  by  water  of  2.05 
tonnes per hectare per year (t ha−a yr−y), compared to the 
EU  mean  of  2.46  t ha−a yr−y.  This  indicates  that  soil 
erosion  is  medium  on  average.  Note  that  these  figures 
are  the  output  of  an  EU  level  model  and  can  therefore 
not be considered as locally measured values. The actual 
rate of soil loss can vary strongly within a Member State 
depending on local conditions.  

sediment 

Soil organic matter plays an important role in the carbon 
cycle and in climate change. Soils are the second largest 
carbon sink in the world after oceans. 

Marine protection 

EU coastal and marine policy and legislation require that 
by  2020  the  impact  of  pressures  on  marine  waters  be 
reduced  to  achieve  or  maintain  good  environmental 
status (GES) and ensure that coastal zones are managed 
sustainably. 

The Marine Strategy Framework Directive (MSFD)40 aims 
to achieve good environmental status of the EU’s marine 
waters  by  2020.  To  that  end,  Member  States  must 
develop  a  marine  strategy  for  their  marine  waters,  and 
cooperate  with  the  EU  countries  that  share  the  same 
marine (sub)region. 

The  Convention  on  the  Protection  of  the  Black  Sea 
against  Pollution  (Bucharest  Convention)  contributes  to 
achieving  Bulgaria’s  goals  required  by  the  Marine 
Strategy  Framework  Directive.  The  marine  strategies 
comprise different steps to be taken over six-year cycles. 
The  latest  step  required  Member  States  to  set  up  and 

39 Panagos, P., Borrelli, P., Poesen, J., Ballabio, C., Lugato, E., 
Meusburger, K., Montanarella, L., Alewell, C., The new assessment of 
soil loss by water erosion in Europe, (2015) Environmental Science and 
Policy, 54, pp. 438-447. 
40 Directive 2008/56/EC 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

report their programme of measures to the Commission 
by  31 March  2016.  The  Commission  assessed  whether 
Bulgarian  measures  were  appropriate  to  reach  good 
environmental status (GES)41. 

Bulgaria’s  measures  partially  address  most  pressures  on 
its  marine  environment  and  associated 
relevant 
activities,  which  shows  they  have  been  designed  in  line 
with  their  latest  GES and  target  definitions  and  in  line 
with pressures felt at regional level, but with a few gaps 
(e.g. physical loss and damage caused by port operations, 
land claim and coastal defence). Bulgaria did not report a 
clear timeline for achieving GES; it frequently refers to a 
general  lack  of  knowledge  of  the  state  of  the  marine 
environment and reported that it cannot estimate if GES 
is  expected  to  be  achieved  by  2020,  because  of 
knowledge  gaps.  Overall,  the  Bulgarian  programme  of 
measures  partially  addresses  the  requirements  of  the 
Marine Strategy Framework Directive. 

2019 priority actions 

  Define GES and targets where these do not exist and 

 

 

 

determine timelines for achieving them. 
Provide  more 
information  about  measures  to 
achieve  GES,  establish  more  that  have  a  direct 
impact  on  pressures  and  quantify  the  expected 
reduction of pressure as a result. 
Ensure  regional  cooperation,  where  practical  and 
appropriate,  to  address  predominant  pressures  in 
the Black sea region. 
Ensure reporting of the different elements under the 
Marine  Strategy  Framework  Directive  by  the  set 
deadline. 

41 COM(2018) 562 and SWD(2018) 393. 

14 

 
 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

3. Ensuring citizens’ health and quality of life 

Air quality 

EU clean air  policy and legislation require the significant 
improvement  of  air  quality  in  the  EU,  moving  the  EU 
closer to the quality recommended by the World Health 
Organisation.  Air  pollution  and  its  impacts  on  human 
health,  ecosystems  and  biodiversity  should  be  further 
reduced with the long-term aim of not exceeding critical 
loads  and  levels.  This  requires  strengthening  efforts  to 
reach  full  compliance  with  EU  air  quality  legislation  and 
defining strategic targets and actions beyond 2020. 

The  EU  has  developed  a  comprehensive  body  of  air 
legislation42,  which  establishes  health-based 
quality 
standards and objectives for a number of air pollutants. 

The  emissions  of  several  air  pollutants  have  decreased 
in  Bulgaria43.  The  emission  reductions 
significantly 
between 1990 and 2014, mentioned in the previous EIR, 
continued  between  2014-2016.  Emissions  of  sulphur 
oxides  (SOx)  fell  by  44.34 %  and  emissions  of  nitrogen 
oxides (NOx) by 5.16 %. Meanwhile, emissions of volatile 
organic  compounds  (NMVOCs) 
increased  by  2.22 %, 
emissions of ammonia (NH3)  by 1.78 % and emissions of 
fine  particulate  matter  (PM2.5)  by  2.41 %  between  2014 
and  2016  (see  also  Figure  13  on  total  PM2.5  and  NOx 
emissions per sector). 

Despite the reduction in emissions, additional efforts are 
needed  to  meet  the  emission  reduction  commitments 
(compared  to  2005  emission  levels)  set  by  the  new 
National  Emissions  Ceilings  Directive44  for  the  period 
2020 to 2029 and for any year from 2030. 

Air quality in Bulgaria continues to give cause for serious 
concern.  For  2015,  the  European  Environment  Agency 
estimated  that  about  14 200  premature  deaths  were 
attributable  to  fine  particulate  matter45  concentrations, 
350  to  ozone46  concentrations  and  640  to  nitrogen 
dioxide47  concentrations48.  The  main  sources  of  air 

42 European Commission, 2016. Air Quality Standards 
43 See EIONET Central Data Repository and Air pollutant emissions data 
viewer (NEC Directive) 
44 Directive 2016/2284/EU 
45 Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
(PM2.5) refers to particles with a diameter of 10 (2.5) micrometres or 
less. PM is emitted from many anthropogenic sources, including 
combustion. 
46 Low-level ozone is produced by photochemical action on pollution. 
47 NOx is emitted during fuel combustion e.g. from industrial facilities 
and the road transport sector. NOx is a group of gases comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
48 Air Quality in Europe – 2018 Report, p.64. Please see details in this 

pollution  with  particular  matter  (dust)  are  domestic 
heating  sector  using  solid  fuels,  and  transport.  The  old 
road  transport  fleet  elevates  the  risk  of  exceeding 
nitrogen  oxides  (NOx)  emissions.  Bulgaria  has  not  yet 
implemented  any  structural  measures  to  address  air 
pollution and to align the air quality objectives with key 
specific sectoral policies (e.g. climate, energy, transport). 

Figure  13:  PM2.5  and  NOx  emissions  by  sector 
Bulgaria49 

in 

Bulgaria did not provide data for the years 2015 and 2016 
of  sufficient  quality  to  allow  meaningful  analysis  of 
attainment  of  environmental  objectives.  For  2017, 
exceedances  related  to  the  annual 
limit  value  for 
nitrogen  dioxide  (NO2)  in  1  (out  of  6)  air  quality  zones 
(Plovdiv). Exceedances have also been registered related 
to  particulate  matter  (PM10)  in  5  (out  of  6)  air  quality 
zones  (including  Plovdiv,  Burgas,  and  Sofia),  and  related 
to fine particulate matter (PM2.5) in 3 (out of 6) air quality 
zones (Plovdiv, Sofia, and Ruse). For sulphur dioxide (SO2) 
exceedances  have  been  reported  for  two  air  quality 
zones.  Furthermore,  the  target  values  regarding  ozone 
and benzo(a)pyrene concentrations are not being met in 
some  instances.See  also  Figure  14  on  the  number  of  air 
quality zones where limits for NO2, PM2.5, and PM10 were 
exceeded. 
According to the European Court of Auditors (ECA)50, EU 
action to protect human health from air pollution has not 
delivered  its  expected  impact.  There  is  a  risk  that  air 
pollution  is  being  underestimated  in  some  instances 

report as regards the underpinning methodology). 
49 2016 NECD data submitted by Member State to the EEA. 
50 European Court of Auditors, Special report no 23/2018, Air pollution: 
Our health still insufficiently protected, p.41. 

15 

 
 
                                                                 
 
 
                                                                                                        
Environmental Implementation Review 2019 – Bulgaria 

because  it  may  not  always  be  monitored  in  the  right 
places.  Member  States  are  now  required  to  report  both 
real-time  and  validated  air  quality  data 
the 
Commission51. In the case of Bulgaria, this reporting has 
unfortunately been delayed in recent years. 

to 

Figure  14:  Air  quality  zones  exceeding  EU  air  quality 
standards in 201752  

through 

The  persistent  breaches  of  air  quality  requirements  (for 
PM10  and  SO2),  which  have  severe  negative  effects  on 
health  and  the  environment,  are  being  followed  up  by 
the  European  Commission 
infringement 
procedures  covering  all  the  Member  States  concerned, 
including  Bulgaria.  As  regards  PM10  exceedance,  the 
Commission  referred  Bulgaria  to  the  European  Court  of 
Justice,  which  ruled  on  the  matter  in  Case  C-488/15, 
confirming the Commission’s position. The aim is to have 
adequate  measures  put  in  place  to  bring  all  zones  into 
compliance. 

51Article 5 of Commission Implementing Decision 2011/850/EU of 
12 December 2011 laying down rules for Directives 2004/107/EC and 
2008/50/EC of the European Parliament and of the Council as regards 
the reciprocal exchange of information and reporting on ambient air 
quality (OJ L 335, 17.12.2011, p. 86) requires Member States to provide 
up-to-date data. 
52 EEA, EIONET Central Data Repository. Data reflects the reporting 
situation as of 26 November 2018. 

16 

2019 priority actions 

 

Take action to reduce the main emission sources, in 
the context of the forthcoming National Air Pollution 
Control Programme (NAPCP). 

  Accelerate  the  reduction  of  nitrogen  oxide  (NOx) 
emissions and nitrogen dioxide (NO2) concentrations. 
This  will  require,  for  example,  further  reductions  in 
transport  emissions  —  particularly  in  urban  areas 
(and  may  require  proportionate  and  targeted  urban 
vehicle access restrictions) and/or fiscal incentives. 
  Accelerate  reductions  in  particulate  matter  (PM2.5 
and  PM10)  emission  and  concentration;  this  will 
require, for example, further reductions in emissions 
from  heat  generation  and  energy  production  using 
solid  fuels,  or  the  promotion  of  efficient  and  clean 
district heating. 

  Upgrade  and  improve  the  air  quality  monitoring 
network,  and  ensure  timely  reporting  of  air  quality 
data. 

  Build on the “Coal regions in transition” initiative to 
reduce the use of coal for domestic heating in order 
to limit air pollutants emissions.  

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 
(i) protect air, water and soil; 
(ii) prevent and manage waste; 
(iii) improve energy and resource efficiency; and  
(iv) clean up contaminated sites.  
To  achieve  this,  the  EU  takes  an  integrated  approach  to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial Emissions Directive53 (IED). 

The  below  overview  of  industrial  activities  regulated  by 
the  IED  is  based  on  the  ‘industrial  emissions  policy 
country profiles’ project54. 

industrial 

In  Bulgaria,  around  475 
installations  are 
required  to  have  a  permit  based  on  the  IED55.  Industrial 
sectors in Bulgaria with the most IED installations in 2015 
are 
‘other  activities’  (30 %,  mainly  food  and  drink 
production, intensive rearing of poultry or pigs, pulp and 
paper  production  and  textiles)  and  waste  management 
(21 %),  followed  by  the  chemical  industry  (18 %,  mostly 
pharmaceutical products) (see Figure 15). 

53 Directive 2010/75/EU covers industrial activities carried out above 
certain thresholds. It covers energy industry, metal production, mineral 
and chemical industry and waste management, as well as a wide range 
of industrial and agricultural sectors (e.g. intensive rearing of pig and 
poultry, pulp and paper production, painting and cleaning). 
54 European Commission, Industrial emissions policy country profile – 
Bulgaria. 
55This overview of industrial activities regulated by IED is based on the 
project on industrial emissions policy country profiles.  

 
 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

Figure  15:  Number  of  IED  industrial  installations  by 
sector in Bulgaria (2015)56 

installations 
significant for non-hazardous waste. 

in  2008),  while  energy/power 

is  most 

The  sectors  contributing  most  to  air  emissions  are: 
energy  /  the  power  sector,  for  sulphur  oxides  (SOx), 
nitrogen  oxides  (NOx),  cadmium  (Cd),  arsenic  (As), 
chromium  (Cr),  copper  (Cu),  lead  (Pb),  mercury  (Hg), 
‘other  activities’  (mostly 
nickel  (Ni)  and  zinc  (Zn); 
intensive  rearing  of  poultry  or  pigs  and  surface 
treatment), for non-methane volatile organic compounds 
(NMVOC)  and  ammonia  (NH3);  chemicals,  for  sulphur 
oxides  (SOx)  and  nitrogen  oxides  (NOx);  iron  and  steel, 
for cadmium (Cd), mercury (Hg) and zinc (Zn); and energy 
refining, 
and 
polychlorinated dibenzofurans (PCDD/F). The breakdown 
is shown in the following graph. 

for  polychlorinated  dibenzodioxins 

Figure 16: Emissions to air from IED sectors and all other 
national total air emissions in Bulgaria (2015) 

The  enforcement  approach  under  the  IED  gives  citizens 
substantial  rights  to  obtain  relevant  information  and  to 
participate in the permitting process for IED installations. 
This  empowers  NGOs  and  the  general  public  to  ensure 
that  permits  are  appropriately  granted  and  their 
conditions respected.  

Best available techniques (BAT) reference documents and 
BAT conclusions are developed through the exchange of 
information  between  Member 
industrial 
associations,  NGOs  and  the  Commission.  This  ensures  a 
good  collaboration  with  stakeholders  and  better 
application of the IED’s rules. 

States, 

Thanks  to  the  national  competent  authorities’  efforts  to 
apply the legally binding BAT conclusions and associated 
BAT  emission  levels  in  environmental  permits,  pollution 
has decreased considerably and continuously in the EU. 

For  example,  by  applying  the  recently  adopted  BAT 
emission levels for large combustion plants, emissions of 
sulphur dioxide will be  cut  on average by between 25 % 
and 81 %, nitrogen oxide by between 8 % and 56 %, dust 
by  between  31 %  and  78 %  and  mercury  by  between 
19 %  and  71 %.  The  extent  of  the  reduction  depends  on 
the situation in individual plants. 

The most significant challenge for Bulgaria is the pressure 
on  the  energy/power  sector  arising  from  the  need  to 
comply  with  emission  limit  values  laid  down  in  the  IED 
and with the recently adopted implementing rules setting 
best  available  techniques  (BAT)  and  associated  emission 
levels for that sector. These implementing rules will need 
to be applied by mid-August 2021 at the latest. 

2019 priority actions 

  Review permits to comply with new BAT conclusions. 
 
Strengthen  control  and  enforcement  to  ensure 
compliance with BAT conclusions. 

  Address  the  pressure  on  the  power  sector  arising 
from  the  need  to  comply  with  emission  limit  values 
under  the 
IED  and  with  the  recently  adopted 
implementing rules on BAT and associated emission 
levels for that sector, to be  implemented by August 
2021. 

Regarding  water  emissions,  the  sectors  energy/power, 
chemicals,  metals  and 
‘other  activities’  are  more 
significant  than other sectors. The metals  sector is  most 
significant  in  the  generation  of  hazardous  waste  (even 
after  the  reported  closure  of  one  of  the  main  metal 

Noise 
The  Environmental  Noise  Directive57  provides  for  a 
common  approach  to  avoiding,  preventing  and  reducing 
the harmful effects of exposure to environmental noise. 

56 European Commission, Industrial emissions policy country profile – 
Bulgaria. 

57 Directive 2002/49/EC. 

17 

 
 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health-related  issues 
in the EU58. 
Based  on  a  limited  set  of  data59,  environmental  noise 
causes at least around 700 premature deaths per year in 
Bulgaria  and  is  responsible  for  around  2 900  hospital 
admissions.  Noise  also  disturbs  the  sleep  of  some 
480 000  people  in  Bulgaria.  Noise  mapping  for  the 
is 
previous  reporting  round  (reference  year  2011) 
complete as are the action plans (reference year 2013). 

These  instruments,  adopted  after  a  public  consultation 
had  been  carried  out,  should  include  the  measures  to 
keep noise low or reduce it.  

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  a  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework Directive  will  ensure that EU citizens benefit 
from good quality and safe drinking and bathing water. It 
will  further  ensure  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 

The  existing  EU  water  legislation60  puts  in  place  a 
protective  framework  to  ensure  high  standards  for  all 
water  bodies  in  the  EU  and  addresses  specific  pollution 
sources  (for  example,  from  agriculture,  urban  areas  and 
industrial  activities).  It  also  requires  that  the  projected 
into  the 
impacts  of  climate  change  are 
corresponding  planning 
risk 
management  plans  and  river  basin  management  plans, 
including  programme  of  measures  which  include  the 
actions  that  Member  States  plan  to  take  in  order  to 
achieve the environmental objectives. 

instruments  e.g. flood 

integrated 

Water Framework Directive 

reported 

the  second 
Bulgaria  has  adopted  and 
generation  of  river  basin  management  plans  under  the 
the  European 
Water 
Commission  has  assessed 
the 
development  since  the  adoption  of  the  first  river  basin 

Framework  Directive  and 

status  and 

the 

58 WHO/JRC, 2011, Burden of disease from environmental noise, 
Fritschi, L., Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), 
World Health Organisation, Regional Office for Europe, Copenhagen, 
Denmark. 
59 European Environment Agency, Noise Fact Sheets 2017. 
60 This includes the Bathing Waters Directive (2006/7/EC), the Urban 
Waste Water Treatment Directive (91/271/EEC) (on discharges of 
municipal and some industrial wastewaters), the Drinking Water 
Directive (98/83/EC) (on potable water quality), the Water Framework 
Directive (2000/60/EC) (on water resources management), the Nitrates 
Directive (91/676/EEC) and the Floods Directive (2007/60/EC). 

18 

management  plans,  including  suggested  actions  in  the 
EIR report 2017. 

The  most  significant  pressures  on  rivers  in  Bulgaria  are 
from  unknown  anthropogenic  pressure  (23%),  point 
source  pressures  from  urban  waste  water  (22%)  and 
diffuse 
For 
groundwater  bodies  the  most  significant  pressure  is 
diffuse  pollution  from  agriculture  (50%)  and  diffuse 
pollution related to discharges which is not connected to 
sewerage network (49%). 

agriculture 

pollution 

(19%). 

from 

The most significant impact on surface water bodies was 
nutrient pollution (40%) and organic pollution (25%). For 
groundwaters the most significant impacts was nutrient 
pollution (27%) and chemical pollution (11%).  

There  are  still  significant  gaps  in  the  establishment  of 
reference conditions  for all  water categories and quality 
elements in Bulgaria and there are still significant gaps in 
the  quality  elements  monitored  (hydromorphological 
quality elements are for example not monitored in lakes 
and  transitional  waters).  There  have  been  increases  in 
the  number  of  surveillance  and  operational  sites 
regarding the  ecological status in rivers, transitional  and 
coastal waters, and decreases in the numbers of sites in 
lakes.  

The  ecological  status/potential  is  good  or  better  in  46% 
of all classified river  water bodies as  illustrated in figure 
17.  This  shows  that  Bulgaria  has  a  long  way  to  go  to 
achieve the good status/potential objectives set down in 
the Water Framework Directive. 

Overall in Bulgaria in the second RBMP, there has been a 
net increase in the number of monitoring sites and water 
bodies  monitored  for  chemical  status 
in  all  water 
categories. 

Between  the  first  and  second  river  basin  management 
plans  there  was  progress  with  the  development  of  a 
range  of  common  national  methodologies  and  guidance 
documents  regarding  monitoring  and  assessment  of 
chemical  status  but  some  issues  remain,  including  the 
fact  that  a  very  large  proportion  of  water  bodies  has 
unknown  status.  There  has  been  a  decrease  in  the 
proportion  of  water  bodies  with  good  chemical  status 
and increase of water bodies with unknown status. Good 
chemical  status  of  surface  water  bodies  is  not  expected 
to  be  fully  achieved  by  the  end  of  the  third  planning 
cycle. 

The  monitoring  situation  of  quantitative  status  of 
groundwater  bodies  shows  overall  drawbacks  although 
the situation improved in certain River Basin Districts and 
the  status  changes  show  mixed  results,  with  some 
improvement and some deterioration. The assessment of 
groundwater quantitative status has improved. 

Groundwater  bodies 
failing  good  chemical  status 
increased  since  the  first  river  basin  management  plan 

                                                                 
Environmental Implementation Review 2019 – Bulgaria 

from 54 (31%) to 58 (34%). The application of a common 
national  methodology  for  assessment  of  the  chemical 
status and the availability of more data for analysis, may 
have 
the  groundwater  bodies  classified 
impacted 
chemical status. 

Figure 17: Ecological status or potential of surface water 
bodies in Bulgaria61. 

bathing water was of poor quality in Bulgaria63. Detailed 
information on Bulgarian bathing waters is available from 
a  national  portal64  and  via  an  interactive  map  viewer  of 
the European Environment Agency65. 
Figure 18: Bathing water quality 2014-201766 

Bulgaria did not ensure that the river basin management 
plans  clearly  identify  the  gap  to  good  status  or  that  the 
programme of measures is designed and implemented in 
order to ensure that gap is closed. The use of exemptions 
is not adequately justified. 

A  large  number  of  significant  pressures  have  been 
reported and many seem to be addressed with measures 
in  the  programme  of  measures.  There  are,  however, 
obstacles  to  their  implementation,  including  delays.  A 
critical  factor  for  their  success  is  the  availability  of 
funding to support the required investments.  

Drinking Water Directive 

As regards drinking water, no new data is available since 
the last Environmental Implementation Review62. 

Bathing Water Directive 

Figure  17  shows  that  in  2017,  out  of  the  95  Bulgarian 
bathing  waters,  44.2 %  were  of  excellent  quality,  47.4 % 
of  good  quality  and  6.3 %  of  sufficient  quality  (64.9 %, 
28.7 %  and  5.3 %  respectively  in  2016).  In  2017,  one 

61 EEA, WISE dashboard. 
62 Compliance with the Drinking Water Directive microbiological and 
chemical parameters as last reported was very high. 

Urban Waste Water Treatment Directive  

The Accession Treaty with Bulgaria set the  final deadline 
for  reaching  compliance  with  the  Urban  Waste  Water 
Treatment Directive as the end of 2014. Despite ongoing 
investment  in  building  necessary  infrastructure,  mainly 
supported  by  the  EU  Funds,  Bulgaria  is  still  having 
difficulty  in  complying  with  the  Directive,  as  shown  by 
collection and treatment  rates. Overall in Bulgaria, close 
to  26 %  of  waste  water  is  collected,  and  20.4 %  of  the 
load collected is subject to secondary treatment. 6.7 % of 
the waste water load collected undergoes more stringent 
treatment.  The  Commission 
infringement 
proceedings  against  Bulgaria  in  2017  to  address  these 
issues. 

started 

of 

the 

and 

treatment 

The  estimated  investment  needed  to  ensure  adequate 
collection 
remaining 
agglomerations  is  EUR 2 145  million67.  According  to  the 
latest  information  provided  by  Bulgaria,  final  projects 
should  be  finished  by  2023,  far  beyond  the  2015  final 
internal 
should 
deadline.  Bulgaria 
management 
the 
planning 
and 
infrastructure  projects  for  agglomerations  in  breach  of 
the Directive as soon as possible. 

its 
complete 

improve 
to 

63 European Environment Agency, 2017. European bathing water quality 
in 2016, p. 17. 
64 Ministry of Health, national bathing waters portal.  
65 EEA, State of bathing waters. 
66 European Environment Agency, 2018. European bathing water quality 
in 2017, p. 21. 
67 European Commission, Ninth Report on the Implementation Status 
and the Programmes for Implementation of the Urban Waste Water 
Treatment Directive (COM(2017) 749) and Commission Staff Working 
Document accompanying the report (SWD(2017)445). 

19 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

Nitrates Directive 

According to the last report on the implementation of the 
Nitrates Directive, for 2012-2015, groundwater quality is 
very slightly worse than in the previous reporting period. 
The  percentage  of  stations  reaching  or  exceeding  40  or 
50  mg  nitrate  per  litre  rose  from  26.1 %  to  26.8 %  and 
from  18.1 % 
respectively.  For  nitrate 
concentrations  in  surface  water,  the  situation  is  fairly 
stable  and  there  were  some  improvements  in  terms  of 
the reduction of eutrophication of surface water. 

to  18.7 % 

Bulgaria  adopted  a  new  action  programme  in  2017.  It  is 
important  that  the  measures  adopted  are  implemented 
appropriately and properly enforced in order to reach the 
water quality objectives. 

Floods Directive 

The  Floods  Directive  established  a  framework  for  the 
assessment and management of flood risks, aiming at the 
reduction  of  the  adverse  consequences  associated  with 
significant floods. 

Bulgaria  has  adopted  and  reported  its  first  Flood  Risk 
Management Plans under the Directive and the European 
Commission conducted an assessment.  

The  Commission’s  assessment  found  that  good  efforts 
were made with positive results in setting objectives and 
devising  measures  focusing  on  prevention,  protection 
and  preparedness.  The  assessment  also  showed  that,  as 
was  the  case  for  other  Member  States,  Bulgaria’s  Flood 
Risk  Management  Plans  do  not  yet 
include  an,  as 
complete as possible, estimation of the cost of measures 
with  identification  of  specific  sources  of  funding.  In 
addition,  there  is  scope  for  expanding  the  use  of  cost-
benefit  analysis  for  the  prioritisation  of  measures  that 
lend themselves to this. 

2019 priority actions 

 

 

 

 

Improve  monitoring  capacities  with  a  view  to  lower 
dependence  on  expert  judgment  for  assessing  the 
ecological  status/potential  of  water  bodies 
in 
accordance with the Water Framework Directive. 
Ensure that projects, which potentially can affect the 
status of water bodies, are thoroughly assessed and 
justified  in  line  with  the  requirements  in  the  Water 
Framework Directive (Article 4(7)). 
Step  up  efforts  to  address  compliance  gap  with  the 
Urban Waste Water Treatment Directive. 
Take  steps  to  clarify  the  method  for  selecting 
measures,  including  the  use  of  cost/benefit  analysis 
in relation to the Flood Risk Management Plans. 

Chemicals 

The  EU  seeks  to  ensure  that  by  2020  chemicals  are 
produced and used in ways that minimise any significant 
adverse  effects  on  human  health  and  the  environment. 
An  EU  strategy  for  a  non-toxic  environment  that  is 
conducive  to  innovation  and  to  developing  sustainable 
substitutes,  including  non-chemical  options,  is  being 
prepared. 

legislation68  provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
for  businesses 
ensures  stability  and  predictability 
operating within the internal market. 

In  2016,  the  European  Chemicals  Agency 
(ECHA) 
published  a  report  on  REACH  and  the  CLP69  Regulation 
that showed that enforcement activities are still evolving. 
Member  States  cooperate  closely  within  the  Forum  for 
Information  on  Enforcement70.  This 
Exchange  of 
cooperation  has  shown  that  there  is  scope  to  increase 
the  effectiveness  of 
the  enforcement  activities, 
particularly  for  registration  obligations  and  safety  data 
sheets where the level of non-compliance is still relatively 
high. 

Whilst progress has been made, there is room to further 
improve and harmonise enforcement activities across the 
EU,  including  controls  on  imported  goods.  Enforcement 
remains  weak  in  some  Member  States,  particularly  for 
controls  on  imports  and  supply  chain  obligations.  The 
enforcement  architecture 
in  most  EU 
countries and enforcement projects reveal differences in 
compliance between Member States. 

is  complex 

A 2015 Commission study emphasised the importance of 
harmonised  market  surveillance  and  enforcement  when 
implementing  REACH  at  Member  State  level,  deeming  it 
to  be  a  critical  success  factor  in  the  operation  of  a 
harmonised single market71. 

In March 2018, the Commission published an evaluation 
of  REACH72.  The  evaluation  concludes  that  REACH 
delivers  on  its  objectives,  but  that  progress  made  is 
slower  than  anticipated.  In  addition,  the  registration 
dossiers often are incomplete. The evaluation underlines 
the need to enhance enforcement by all actors, including 

68 Principally for chemicals: REACH (OJ L 396, 30.12.2006, p.1.); for 
Classification, Labelling and Packaging, the CLP Regulation (OJ L 252, 
31.12.2006, p.1.), together with legislation on biocidal products and 
plant protection products. 
69 European Chemicals Agency, Report on the Operation of REACH and 
CLP 2016. 
70 ECHA, On the basis of the projects REF-1, REF-2 and REF-3. 
71 European Commission. (2015). Monitoring the Impacts of REACH on 
Innovation, Competitiveness and SMEs. Brussels: European 
Commission. 
72 COM(2018) 116. 

20 

                                                                 
Environmental Implementation Review 2019 – Bulgaria 

in  particular  for 
registrants,  downstream  users  and 
importers,  to  ensure  a  level  playing  field,  meet  the 
objectives  of  REACH  and  ensure  consistency  with  the 
actions envisaged to improve environmental compliance 
and  governance.  Consistent  reporting  of  Member  State 
enforcement activities  was considered  important  in that 
respect. 

from 

the  harmful 

In Bulgaria, the Ministry of Environment and Water is the 
competent  authority  for  REACH.  REACH  and  the  CLP 
implemented  through  the  Law  on 
Regulation  are 
protection 
impact  of  chemical 
substances and mixtures. The law allocates responsibility 
for  REACH  and  CLP  enforcement  to  a  number  of 
enforcing  authorities. 
It  requires  other  competent 
authorities to cooperate and share information with the 
bodies  responsible  for  REACH  and  CLP  enforcement  and 
specifies  the  need  for  coordinated  and  harmonised 
enforcement  by  the  means  of  joint  inspections  and 
common 
other 
measures. The Law also lays down offences and penalties 
for contravention of REACH and CLP requirements73. 

enforcement 

guidelines, 

among 

Cooperation  between  the  Ministry  of  Environment  and 
Water,  the  Ministry  of  Economy  and  the  Executive 
Agency ‘General Labour Inspectorate’ is ensured through 
the  Standing  Committee  for  implementation  of  REACH. 
The Ministry of Environment and Water organises annual 
workshops  for  training  and  exchange  of  information 
between  the  competent  authority  and  the  enforcement 
authorities.  Awareness-raising  activities  have  been 
carried  out  via  articles 
information 
seminars, a website and social media74. 

in  newspapers, 

Making cities more sustainable 

EU policy on the urban environment encourages cities to 
put  policies  in  place  for  sustainable  urban  planning  and 
design.  These  should  include  innovative  approaches  to 
urban  public 
sustainable 
buildings,  energy  efficiency  and  urban  biodiversity 
conservation. 

transport  and  mobility, 

Europe  can  be  seen  as  a  union  of  cities  and  towns. 
Around  75 %  of  the  EU  population  live  in  urban  areas75 
and  this  figure  is  projected  to  rise  to  just  over  80%  by 
205076.  Urban  areas  pose  particular  challenges  for  the 
environment  and  human  health,  but  they  also  provide 
opportunities  for  using  resources  more  efficiently.  The 
EU encourages municipalities to become greener through 

73 ECHA, National Inspectorates – Bulgaria.  
74 European Commission, Member States Reporting under REACH art. 
117 / CLP art.46  
75 European Commission, Urban Europe, 2016. 
76 European Commission, Eurostat, Urban Europe, 2016, p.9. 

21 

initiatives  such  as  the  Green  Capital  Award77,  the  Green 
Leaf Award78 and the Green City Tool79. 

Financing greener cities 

Bulgaria has assigned almost EUR 724.3 million, or almost 
20 %  of  its  allocation  under  the  European  Regional 
Development  Fund 
sustainable  urban 
development80.  It  is  also  part  of  the  European  Urban 
Development Network81. 

(ERDF), 

to 

Participation in EU urban initiatives and networks 

Though  not  as  leading  partners,  Bulgarian  municipalities 
are generally involved in EU initiatives on environmental 
protection and climate change. 

involved 

Four  municipalities  (Burgas,  Smolyan,  Sofia  and  Varna) 
are 
initiative  to  support 
sustainable  urban  development,  through  six  of  its  15 
different thematic networks82. 

in  the  URBACT 

includes  seven  municipalities 

Several  Horizon  2020  network  projects  have  also 
contributed  to  the  sustainability  of  Bulgarian  cities. 
representing 
CIVITAS 
Bulgaria  in  a  common  effort  to  achieve  cleaner  and 
better transport in cities83. Yugozapaden Region is part of 
the  Mild  Home  initiative,  where  partners  from  seven 
countries  have  joined  forces  to  develop  workable  plans 
for  energy  efficient  homes  and  an  eco-village  concept 
that can cater for the needs of medium- and low-income 
families84. Sofia (Oborishte) is one of the three STACCATO 
to  demonstrate 
project  European  capital  districts 
sustainable  energy  concepts  in  existing,  representative, 
residential areas85. 

Twenty-five  Bulgarian  cities  are  involved  with  the  EU 
Covenant  of  Mayors.  As  of  July  2018,  Assenovgrad, 
Burgas,  Dobrich  and  Gabrovo  had  already  implemented 
their  action  plans  and 
their  results  were  being 
monitored.  The  other  21  cities  have  presented  their 
climate action plans and commitments86. 

These  urban 
initiatives  and  networks  should  be 
welcomed and encouraged, as they contribute to a better 
In  2017,  19.2 %  of  Bulgarian 
urban  environment. 
population  living  in  cities  considered  their  residential 

77European Commission, European Green Capital  
78European Commission, European Green Leaf Award  
79European Commission, Green City Tool  
80EU Structural Funds — Single Information Web Portal, Partnership 
Agreement 2014-2020, 2014, p. 150. 
81 European Commission, The Urban Development Network. 
82 URBACT, Associated Networks by country. 
83 European Commission, Horizon 2020 Civitas Project. 
84 European Commission, Mild Home: Building affordable, energy 
efficient homes and villages 
85 EU Smart Cities Information System. 
86 Covenant of Mayors for Climate and Energy, Country signatories. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

area  to  be  affected  by  pollution,  grime  or  other 
environmental problems, down from 20.3 % in 201687. 

Nature and cities 

In  Bulgaria,  18 %  of  the  Natura  2000  network  is  to  be 
found  within  functional  urban  areas88.  This  is  slightly 
above the EU average of 15 % (see Figure 18). 

Figure  19:  Proportion  of  Natura  2000  network 
Functional Urban Areas (FUA) 89 

in 

To ensure  integrity of the Natura 2000  sites, the law on 
Biodiversity  sets  out  particular  requirements  for  spatial 
development  plans,  regional  plans  for  the  development 
of wooded areas, forestry plans and programmes and the 
national  and  regional  programmes  drafted  according  to 
procedures established by other acts. They must include 
measures  and  activities  to  conserve  features  of  the 
landscape which are essential for the migration, dispersal 
and  genetic  exchange  of  plant  and  animal  populations 
and  species  —  either  because  the  areas  are  linear  and 
continuous,  or  because  they  act  as  stepping  stones. 
Public awareness of the opportunities offered by Natura 
2000  is  still  not  sufficient.  More  effort  is  needed  to 
inform  people  about  ways  of  effectively  cohabiting  with 
natural  habitatas,  species  and  their  habitats  without 
negatively affecting their status. 

There  are,  however,  positive  examples  which  should  be 
acknowledged. 

Karlovo  is  one  of  the  cities  participating  in  the  EnRoute 
project  (Enhancing  Resilience  of  Urban  Ecosystems 
through Green Infrastructure) as part of MAES, which ran 
from 2017 until 2018. The project aimed to introduce the 
MAES approach into the local policy arena, with a view to 
contributing 
green 
infrastructure in cities and in urban contexts. 

deployment 

further 

to 

of 

innovation  and  governance  via 
up  urban  resilience, 
nature-based  solutions.  An  open  innovation  ecosystem 
approach  bringing  together  city  governments,  SMEs, 
academia  and  civic  society  is  used  to  co-produce  usable 
and actionable knowledge. 

Urban sprawl 

Bulgaria had a weighted urban proliferation rate, at 0.98 
UPU/m2 90 in 2009 compared to a European average (EU-
28+4) of 1.64 UPU/m2 91. 

Traffic congestion and urban mobility 

The number of passenger cars in Bulgaria has increased, 
to  3.1  million  in  2016.  The  ratio  of  passenger  cars  per 
1000  habitants  increased  from  418  in  2014  to  443  in 
2016. 

This increase is translated into more hours spent annually 
in  road  congestion,  from  30.4  in  2014  to  31.9  in  2016. 
Bulgaria has the seventh-highest figures in the EU92. 

With a congestion level of 29 %, in comparison with other 
cities with population over 800 thousand, Sofia is the 24th 
most  congested  city  in  geographical  Europe  (out  of  43 
large  cities  on  the  list)  and  83rd  in  the  world  (out  of 
182)93. 

Bulgaria  records  a  high  usage  of  passenger  cars  and  in 
2015,  car  trips  represented  almost  80 %  of  the 
passenger-kilometres  travelled,  which  is  just  below  the 
EU-28  average.  Bulgaria  has,  however,  much  higher 
usage  of  buses  and  coaches  than  the  EU-28  average  — 
17.5 %  against  the  EU-28’s  9.4 %.  On  the  other  hand, 
Bulgaria’s use of rail is much lower (2.2 % vs 7.6 %)94. 

The  city  of  Burgas  participates  in  the  Horizon  2020 
project COproductioN with NaturE for City Transitioning, 
INnovation  and  Governance  (CONNECTING)  which  aims 
to co-develop the policy and practices necessary to scale 

87 European Commission, Eurostat, Pollution, grime or other 
environmental problems by degree of urbanisation. 
88 European Commission, Definition of Functional Urban Areas. 
89 European Commission, the 7th Report on Economic, Social and 
Territorial Cohesion, 2017, p. 121. 

90 Urban Permeation Units measure the size of the built-up area as well 
as its degree of dispersion throughout the region. 
91 EEA, Urban Sprawl in Europe, Annex I, 2014, pp.4-5. 
92 European Commission, Hours spent in road congestion annually. 
93 TOMTOM TRAFFIC INDEX 
94 European Commission, Transport in the EU trends, 2018. 

22 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

Urban air quality 

Of the main challenges observed in this report, air quality 
—  to  an  extent  related  to  traffic  congestion  —  requires 
special priority both at central and local level. 

Transport  represents  almost  a  quarter  of  Europe’s 
greenhouse  gas  emissions  and  is  the  main  cause  of  air 
pollution 
in  Bulgaria 
increased by 10 % from 2012 to 201695. 

in  cities.  Transport  emissions 

In 2016, 87 % of Bulgaria’s urban population was exposed 
to PM10 concentrations above the EU standards. That is 9 
percentage  points  higher  than  the  2015  figure  of  78  % 
and  10  persentage  points  less  than  the  2014  figure  of 
97 %.96  

95 European Environment Agency, Greenhouse gas data viewer. 
96 Bulgaria – air pollution country fact sheet 2018. 

23 

 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

Part II: Enabling framework: implementation tools 

4. Green taxation, green public procurement, environmental 

funding and investments 

Green taxation and environmentally harmful 
subsidies 

incentives, 

Financial 
taxation  and  other  economic 
instruments  are  effective  and  efficient  ways  to  meet 
environmental  policy  objectives.  The  circular  economy 
action  plan  encourages  their  use.  Environmentally 
harmful  subsidies  are  monitored  in  the  context  of  the 
European  Semester  and  the  energy  union  governance 
process. 

In 2015, fossil fuel subsidies stayed among the highest in 
the  EU,  mainly  due  to  public  support  for  coal.  Post-tax 
subsidies (which include not only price-gap subsidies but 
also the negative externalities associated with the use of 
fossil  fuels,  such  as  local  air  pollution,  faster  climate 
change  and  congestion)  added  up  to  EUR 18  billion  in 
2015102. 

Figure  20:  Environmental  tax  revenues  as  %  of  GDP 
(2017) 103 

than 

slightly  higher 

from  environment-related 

taxes 
Bulgaria’s  revenue 
remains 
the  EU  average. 
Environmental taxes accounted for 2.68 % of GDP in 2017 
(EU-28 average: 2.4 %) (see Figure 19), and energy taxes 
for 2.31 % of GDP (EU-28 average 1.84 %)97. In the same 
year,  environmental  tax  revenues  accounted  for  9.07 % 
of  total  revenues 
from  taxes  and  social  security 
contributions (EU-28 average: 5.97 %). 

Revenue  from  labour  tax  makes  up  a  low  proportion  of 
total tax revenues in Bulgaria: at 34 %, it was the lowest 
in the EU in 2016, while the implicit tax burden on labour 
was  23.5 %  (only  higher  than  Malta) 98.  Consumption 
taxes  remained  relatively  high  (the  highest  in  the  EU,  at 
51.3 %)  measured  by  their  share  of  total  taxation: 
indirect taxation accounts for the main part of the fiscal 
system. 

Nevertheless,  the  2018  European  Semester  report  on 
Bulgaria  picked  up  on  the  situation  of  environmental 
taxation on transport fuels99. Although they form a larger 
part  of  tax  revenue  than  in  other  Member  States,  tax 
rates on the main motor fuels (petrol and diesel) are just 
above  the  minimum  EU 
level  and  have  not  been 
increased  since  2011  for  petrol  or  since  2013  for  diesel. 
On  the  other  hand,  some  progress  has  been  made  on 
reducing  the  ‘diesel  differential’  (the  difference  in  the 
price of diesel versus petrol) since 2005100. In 2016, diesel 
was  still  taxed  at  a  lower  rate  than  gasoline  (0.33 
euro/litre against 0.363 euro/litre) 101. 

97 Eurostat, Environmental tax revenues, 2018. 
98 European Commission, Taxation Trends Report, 2017. 
99 European Commission, European Semester: Country Report Bulgaria 
2018, p. 21. 
100 European Environment Agency 2016, Environmental taxation and EU 
environmental policies, p. 27. 
101 European Environment Agency 2016, Environmental taxation and EU 
environmental policies, p. 28. 

By  amendments  to  the  Law  on  Local  Taxes  and  Fees,  in 
November  2018,  Bulgaria 
‘ecological 
component’ to the formula for calculation of the vehicule 
tax. Though it is still for the local authorities to decide on 
the  precise  value  of  this  component,  the  law  gives 

introduced  an 

102 European Parliament and IMF, Fossil Fuel Subsidies, 2017, pp. 10-11. 
103 Eurostat, Environmental tax revenues, 2018. 

24 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

margins  of  variation  for  each  ecological  cathegory104. 
Electric vehicles are exempted from vehicle tax. 

(EMEPA)  and  is  then  redistributed  to  environmental 
projects and initiatives.  

In 2016 the National Trust Ecofund started a pilot scheme 
encouraging  the  use  of  electric  and  plug-in  hybrid 
vehicles in the public administration. The scheme is in the 
framework of the ongoing Investment Climate Program. 

The  central  administration, 
its  territorial  units  and 
municipal administrations are eligible for funding. Each of 
them  can  apply  for  funding  for  a  maximum  of  three 
vehicles. 
There  are  no  CO2-based  motor  vehicle  taxes105  and 
incentives  to  purchase  cars  with  lower  CO2  emissions 
were  rare  in  2016.  There  were  some  incentives  to  use 
them,  linked  to  annual  circulation  taxes,  road  tolls,  and 
congestion  or  low  emission  zone  charges,  but  none 
related  to  their  acquisition  or  the  use  of  public 
infrastructure106. 

On  the  bright  side,  renewable  energy’s  share  of  energy 
consumption in the transport sector, which was very low 
in the past, has increased considerably in recent years. In 
2015,  it  was  almost  at  the  EU  average107.  The  main 
support  scheme  for  renewable  energy  sources  used  in 
transport 
is  a  quota  system.  This  scheme  obliges 
companies  importing  or  producing  petrol  or  diesel  to 
ensure  that  biofuels  make  up  a  defined  percentage  of 
their  annual  fuel  sales.  Biofuels  are  also  supported 
through a fiscal regulation mechanism. 

The  use  of  alternative  and  clean  fuels  in  new  passenger 
cars sold in Bulgaria remained one of the lowest in the EU 
in the past few years, with a market share of only 0.04 % 
in  2016.  Despite  the  intention  to  promote  the  use  of 
alternative  fuels108,  the  number  of  electric  charging 
points  is  the  second  lowest  in  the  EU-28,  with  only  1.7 
charging  points  per  100 000  inhabitants  in  peri-urban 
areas  in  2017.  This  means  there  are  only  22  publicly 
accessible charging points in Bulgaria109. 
Bulgaria has had water abstraction charges since 2001110. 
The  price  charged  for  amounts  and  sources  of  water 
abstraction  have  changed  since  then.  The  revenue  from 
the  charges 
for 
Management  of  Environmental  Protection  Activities 

is  collected  by 

the  Enterprise 

104 Bulgarian law gives hiest values of the ecological component for 
vehicles without cathegorisation and vehicules of ‘Euro 1’ and ‘Euro 
2’cathegories, and lowest values for vehicules of cathegory ‘Euro 6’ and 
‘EEV’.  
105 European Automobil Manufacturers Association, Co2 based motor 
vehicle taxes in the EU.  
106 EEA, Appropriate taxes and incentives do affect purchases of new 
cars.  
107 Eurostat, Share of transport fuel from renewable energy sources.   
108 Tax exemption for vehicles with electric engines since 2018. 
109 European Commission, Transport in the European Union, 2018, p. 
31. 
110Sharkov, A.: Water abstraction charges in Bulgaria, The Institute for 
European Environmental Policy.  

Green public procurement 

The  EU  green  public  procurement  policies  encourage 
Member  States  to  take  further  steps  to  apply  green 
procurement  criteria  to  at  least  50 %  of  public  tenders. 
The European Commission is helping to increase the use 
of  public  procurement  as  a  strategic  tool  to  support 
environmental protection. 

The purchasing power of public procurement amounts to 
around  EUR 1.8  trillion  in  the  EU  (approximately  14%  of 
EU GDP). A substantial proportion of this money goes to 
sectors  with  a  high  environmental 
impact  such  as 
construction  or  transport.  Therefore,  green  public 
procurement  (GPP)  can  help  to  significantly  lower  the 
negative  impact  of  public  spending  on  the  environment 
and  can  help  support  sustainable  innovative  businesses. 
The Commission has proposed EU GPP criteria111. 

The  National  Strategy  for  Development  of  the  Public 
Procurement  Sector  defines  the  strategic  framework  of 
the state policy in the field for the period 2014–2020 and 
includes  a  measure  to  promote  GPP.  The  national 
strategy is implemented through the National Action Plan 
to  promote  green  public  procurement  for  the  period 
2014-2020. The latter inter alia previews the elaboration 
of  practical  handbook  on  GPP  aimed  at  facilitating  such 
procurement  in  Bulgaria.  This  measure  is  implemented 
by  the  ongoing  project  “Methodological  Support  for  the 
Development  of  Green  Public  Procurement  in  Bulgaria” 
funded 
cooperation 
under 
specific 
programme.  Moreover, 
methodological  guidelines  are  issued  on  an  ongoing 
basis. 

Bulgarian-Swiss 
general 

and 

the 

Some mandatory rules on GPP use have been drawn up. 
They  cover  energy  efficiency  requirements  for  awarding 
public  contracts  for  the  supply  of  products;  energy 
consumption, according to EU energy labelling legislation 
e.g. for office  equipment  and tyres, and eco-design. The 
rules are  set  out  in the Energy Efficiency Act.  Guidelines 
are  available  on  how  the  energy  efficiency  and  energy 
savings  requirements  apply  to  procuring  equipment  and 
vehicles, and to purchasing and/or renting buildings with 
high  energy  efficiency  rates.  These  were  drawn  up  and 
adopted  jointly  by  the  Sustainable  Energy  Development 
Agency 
Procurement  Agency. 
Environmental performance requirements for the supply 

Public 

and 

the 

111 In the Communication ‘Public procurement for a better 
environment’ (COM (2008) 400) the Commission recommended the 
creation of a process for setting common GPP criteria. The basic 
concept of GPP relies on having clear, verifiable, justifiable and 
ambitious environmental criteria for products and services, based on a 
life-cycle approach and scientific evidence base. 

25 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

of  vehicles,  in  line  with  Directive  2009/33/EC  on  the 
promotion  of  clean  and  energy-efficient  road  transport 
vehicles, have also been published. The rules are set out 
in the Public Procurement Act and the ordinance defining 
the  methodology  for  calculating  certain  costs  for  the 
vehicle’s life cycle112. 

Bulgaria  is  aiming  to  step  up  the  use  of  green  public 
procurement  criteria  in  funding  from  national  and  EU 
Investment 
sources.  Therefore,  under  the  Climate 
Programme of the national trust Ecofund, when selecting 
a supplier it requires EU GPP criteria to be met for costs 
to qualify as eligible113. 

It  has  also  approved  Guidelines  for  Integration  of  the 
Environmental  and  Climate  Change  Policies  in  European 
Structural  and  Investment  Funds  (ESIF).  The  Guidelines 
set  general  and  specific  criteria  for  evaluating  project 
proposals  relevant  to  specific  environmental  policies.  A 
specific  criterion  requiring  the 
is 
included.114 

inclusion  of  GPP 

Monitoring  is  carried  out  on  the  basis  of  statistical  data 
from  the  national  procurement  register  (PPR).  The 
electronic  register  for  public  procurement  kept  by  the 
Public Procurement Agency allows enquiries to be made 
concerning GPP for specific product groups115. 

A  European  Parliament  study  shows  that  Bulgaria  has 
partially implemented the GPP national action plan116. 

Environmental funding and investments 

European  Structural  and  Investment  Fund  (ESIF)  rules 
oblige  Member  States  to  promote  environment  and 
climate  in  their  funding  strategies  and  programmes  for 
economic, 
rural 
development and maritime policy. 

social  and 

territorial 

cohesion, 

Achieving  sustainability  involves  mobilising  public  and 
private  financing  sources117.  Use  of  the  European 
Structural  and  Investment  Funds  (ESIFs)118  is  essential  if 
countries  are  to  achieve  their  environmental  goals  and 
into  other  policy  areas.  Other 
integrate 

these 

112 European Commission, 2017. Documentation on National GPP Action 
Plans. 
113 The National Trust EcoFund, Investment Climate Programme. 
114 The Republic of Bulgaria, Operational programme environment 
2014-2020.  
115 European Parliament, 2017, ‘Green public procurement and the EU 
action plan fort he circular economy’. 
116 European Parliament, Green Public Procurement and the Action Plan 
for the Circular Economy, 2017, pp. 79-80. 
117 See, for example, Action plan on financing sustainable growth 
(COM(2018) 97).  
118 i.e. the European Regional Development Fund (ERDF), the Cohesion 
Fund (CF), the European Social Fund (ESF), the European Agricultural 
Fund for Rural Development (EAFRD) and the European Maritime and 
Fisheries Fund (EMFF). The ERDF, the CF and the ESF are referred to as 
the ‘cohesion policy funds’. 

instruments such as Horizon 2020, the LIFE programme119 
and the European Fund for Strategic Investments (EFSI)120 
may also support the implementation and spread of good 
practices. 

European Structural and Investment Funds 2014-2020 

Through  10  national  programmes,  Bulgaria  has  been 
allocated  EUR 9.88  billion  from  the  ESIF  for  2014-2020. 
With a national contribution of EUR 1.86 billion, Bulgaria 
has a  total budget  of EUR 11.73 billion to be invested in 
various areas, from creating jobs and growth to providing 
an  innovation-friendly  business  environment,  advancing 
social inclusion and protecting the environment121. 

Cohesion policy 

For  2014-2020,  Bulgaria  has  been  allocated  around 
EUR 7.6  billion  (current  prices)  in  total  cohesion  policy 
funding,  including  EUR 2.28  billion  under  the  Cohesion 
Fund,  EUR  3.57  billion  from  the  ERDF,  EUR 1.52  billion 
from  the  ESF,  EUR 165.6  million  for  European  Territorial 
Cooperation  and  EUR 55.2  million 
the  Youth 
Employment Initiative122. 

for 

key 

funds  are 

instruments 

sustainability  of 

The  European 
for 
comprehensive  environmental protection in the EU. The 
investment priorities for 2014-2020 in Bulgaria have been 
set  out  in  a  Partnership  Agreement.  These  include: 
raising  competitiveness  and 
the 
economy;  developing  sustainable  and  environmental 
friendly  modes  of  transport  along  Trans-European 
Networks 
integrated  urban 
stimulating 
development  in  priority  areas  within  selected  cities  in 
Bulgaria;  improving  management  of  water  and  other 
including  biodiversity  and  Natura 
natural  resources, 
2000, closing the gap with the acquis and increasing the 
efficiency  of  water  and  waste  management  as  well  as 
strengthening  the  capacity  of  public  administration  and 
the judiciary and promoting good governance. 

(TEN-T); 

funds 

The  allocation  under  cohesion  policy 
for 
Operational  Programme  Environment  (OPE)  for  2014-
2020  is  EUR 1.5  billion,  which  rises  to  about  EUR 1.77 
billion with national co-financing123. The Cohesion Fund is 
supporting projects in the field of water management, air 
quality  and  of  floods  and  landslides  risk  prevention  and 
management.  The  ERDF  is  supporting  projects  in  the 
fields  of  waste  management,  Natura  2000  and 
biodiversity. 

The  ERDF 
increase  waste 
recycling capacity by 105 000 tonnes/year, to implement 

is  supporting  projects  to 

119 European Commission, LIFE programme. 
120 European Investment Bank, European Fund for Strategic 
Investments, 2016. 
121 European Commission, European Structural and Investment Funds 
(Country factsheet Bulgaria), 2017. 
122 European Commission, Cohesion Policy and Bulgaria, 2014. 
123 European Commission, Operational Programme Environment.  

26 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

flood  protection  measures  benefiting  more  than  2.75 
million people, to  increase by 1.5  million the number of 
people  served  by 
improved  waste  water  treatment 
facilities and to improve water supply for 220 000 people, 
among many other investments124. 

Figure  21:  ESIF  2014-2020  —  EU  allocation  by  theme, 
Bulgaria (EUR billion)125 

Rural development 

The  Bulgarian  Rural  Development  Programme  (RDP) 
outlines  the  country’s  priorities  for  using  EUR 2.9  billion 
funds  available  for  the  7-year  period  2014-2020.  This 
funding includes EUR 2.3 billion from the EAFRD, EUR 551 
million  of  national  co-funding  and  EUR 29  million  of 
additional national funding top-ups126 127. 

The  RDP  has  a  solid  environmental  approach,  aiming  to 
convert  46 000  ha  to  organic  farming  and  to  implement 
agri-environmental measures in other 113 000 ha. Some 
840  operations  will  tackle  resource  efficiency,  climate 
change and energy efficiency128. In fact, 49 % of the RDP 
funds  will  be  used  for  these  and  other  environmental 

priorities  included  under  the  ecosystems  management 
and resource efficiency sections129. 

the  EAFRD-RDP  projects 

One  of 
the 
modernisation  of  energy  infrastructure  in  rural  areas 
through the introduction of solar street-lighting systems, 
a  project  selected  as  best  practice  in  renewables  by  the 
Bulgarian Rural Network130. 

supports 

for 

integrating  environmental 
The  two  key  areas 
concerns  into  the  common  agricultural  policy  (CAP)  are: 
(i)  using  the  EAFRD  to  pay  for  environmental  land 
management and other environmental measures and (ii) 
ensuring  the  CAP’s  first  pillar  (the  direct  payments 
system) 
is  used  effectively  with  regard  to  cross-
compliance and payments for ‘greening’. Bulgaria’s direct 
payments envelope for 2014-2020 is EUR 5.1 billion, 30 % 
of  which  is  being  allocated  to  greening  practices  to 
diversification, 
benefit 
maintaining  permanent  grassland  and  dedicating  5 %  of 
arable land to environment-friendly measures131. 

environment: 

crop 

the 

The latest financial data available (relating to 2007-2013) 
show  that  the  absorption  rate  of  rural  development 
funds in Bulgaria was 89.9 %, lower than the EU average 
(97.3 %)132. 

European Maritime and Fisheries Fund 

Bulgaria  receives around EUR 113  million in co-financing 
for  fisheries  and  the  maritime  sector,  with  an  EU 
contribution  of  EUR 88  million133.  Several  projects 
benefiting the environment have been financed under OP 
priorities one (sustainable fisheries) and two (sustainable 
aquaculture).  The  share  for  environmental  projects  is 
around 54 % — more than EUR 61 million134. 

The output  of organic  aquaculture will be increased and 
unwanted catches  will be reduced. Action to reduce the 
number  of  old  ships  will  also  help  to  reduce  GHG 
emissions135. 

The Connecting Europe Facility 

The Connecting Europe Facility (CEF) is a key EU funding 
instrument  developed  specifically  to  direct  investment 
into 
digital 
infrastructure.  It  aims  to  address  identified  missing  links 
and bottlenecks and promote sustainability. 

transport, 

European 

energy 

and 

124 European Commission, DG REGIO database for Bulgaria. 
125 European Commission, European Structural and Investment Funds 
Data By Country. 
126 European Commission, Factsheet on 2014-2020 Rural Development 
Programme for Bulgaria, 2017, p. 1. 
127 The European Network for Rural Development, 2014-2020 Rural 
Development Programme: Key facts & figures (Bulgaria), 2016. 
128 European Commission, Factsheet on 2014-2020 Rural Development 
Programme for Bulgaria, 2017, pp. 2-3. 

129 European Commission, Factsheet on 2014-2020 Rural Development 
Programme for Bulgaria, 2017, pp. 4-5. 
130 European Network for Rural Development, Transition to Greener 
Rural Economies, 2018, p. 21. 
131 European Commission, CAP in your country (Bulgaria), p. 2. 
132 COM/2017/0554. 
133 European Commission, European Maritime and Fisheries Fund in 
Bulgaria, 2015. 
134 European Commission, European Maritime and Fisheries Fund in 
Bulgaria, 2015, p. 2. 
135 European Commission, ESIF Data for Bulgaria  

27 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

By  the  end  of  2017,  Bulgaria  had  signed  agreements 
worth EUR 406 million for projects under the Connecting 
Europe Facility136. 

EUR 350  million  has  been  allocated  to  modernising  core 
improving  energy  efficiency  and 
network  corridors, 
reducing the emission of pollutants137. 

Horizon 2020 

Bulgaria  has  benefited  from  Horizon  2020  funding  since 
the programme started in 2014. As of January 2019, 174 
participants  have  been  granted  a  maximum  amount  of 
EUR 25.8 million for projects from the Societal Challenges 
environmental 
work 
issues138 139.  

dealing  with 

programmes 

In  addition  to  the  abovementioned  work  programmes, 
climate and biodiversity expenditure is present across the 
entire  Horizon  2020.  In  Bulgaria,  projects  accepted  for 
funding  in  all  Horizon  2020  working  programmes  until 
December  2018  included  EUR  35  million  destined  to 
climate  action  (46.2 %  of  the  total  Horizon  2020 
contribution  to  the  country)  and  EUR  3.8  million  for 
biodiversity-related  actions  (5 %  of  the  Horizon  2020 
contribution to the country)140. 

Several  projects  are  achieving  success.  The  C-BIRD 
project  is  trying  to  exchange  knowledge  and  develop 
cooperative  models  and  focusing  on  environmental  and 
economic  advantages141.  The  TURAS  project 
is 
transforming stressful urban areas into more sustainable 
spaces142. 

LIFE programme 

For  2014-2017,  the  EU  allocated  EUR 13  million  to 
Bulgarian  projects143.  The  LIFE  project  ‘Birds  on  power 
lines’  is  among  these  projects,  taking  action  to  protect 
threatened  birds  by  retrofitting  hazardous  overhead 
powerlines  to  make  them  safer  in  Natura  2000  sites  in 
West  Bulgaria.  The  EU  contribution  is  around  EUR 2 
million144. 

136 European Commission, European Semester Country Report for 
Bulgaria, 2018, p. 16. 
137 European Commission, CEF Transport in Bulgaria, p. 2. 
138 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). A maximum grant amount is the maximum 
grant amount decided by the Commission. It normally corresponds to 
the requested grant, but it may be lower. 
139 i.e. (ii) Food security, sustainable agriculture and forestry, marine 
and maritime and inland water research and the bioeconomy; (iii) 
Secure, clean and efficient energy; (iv) Smart, green and integrated 
transport; and (v) Climate action, environment, resource efficiency and 
raw materials. 
140 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). 
141 European Commission, Supporting EU-wide sustainable rural 
development. 
142 European Commission, Nature-based solutions for urban dwellers. 
143 Commission services based on data provided by EASME. 
144 European Commission, LIFE Birds. 

Since 2007, when the LIFE Programme was launched for 
Bulgaria, a total of 35 projects have been co-financed 145 
including a capacity building project focused on widening 
the access to the LIFE Programme.  

Currently,  there  are  four  ongoing  projects  in  Bulgaria 
under  call  2017  that  are  tackling  diverse  environmental 
themes,  including  Natura  2000,  autochthonous  species 
and habitat restoration.  

The  Conservation  and  Restoration  of  11 Natura  2000 
Riparian  and  Wetland  Habitats 
(Riparian  Habitats 
Project146)  was  selected  as  one  of  the  Best  LIFE-Nature 
projects in the EU, as were the BulPlanNet project (a pilot 
network  of  small  protected  sites  for  Plant  Species  in 
Bulgaria)147  and  the  Vultures’  Return  project  (for  the 
recovery  of 
large  European 
Vultures)148. 

the  populations  of 

European Investment Bank 

EIB loans in Bulgaria amounted to nearly EUR 1.68 billion 
for 2013-2017 149. In 2018 alone, the EIB Group 150 loaned 
Bulgarian  businesses  and  public  institutions  more  than 
EUR 217  million  (see  Figure  21).  Of  this,  no  money  was 
directly 
in  environment-related  projects. 
Nevertheless,  other  projects  are  indirectly  connected  to 
environmental protection. 
Figure 22: EIB loans to Bulgaria in 2018151 

invested 

European Fund for Strategic Investments 

The European Fund for Strategic Investments (EFSI) is an 
initiative to help overcome the current investment gap in 
the  EU.  The  EFSI  has  mobilised  more  than  EUR 419 
million in Bulgaria as of January 2019, and the secondary 
investment  triggered  by  those  funds  is  expected  to  be 
more than EUR 1.8 billion152. 

145 European Commission, LIFE in Bulgaria, 2017.   
146 European Commission, Riparian Habitats. 
147 European Commission, BulPlantNet. 
148 European Commission, Vultures Return. 
149 European Investment Bank, The EIB in Bulgaria in 2017, 2017. 
150 The EIB Group includes EIB and EFSI investments and loans. 
151 EIB, Bulgaria and the EIB. 
152 European Investment Bank, The EIB in Bulgaria, 2018. 

28 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

National environmental financing 

Bulgaria  spent  EUR 304.8  million  on  environmental 
protection  in  2016,  a  15 %  decrease  from  2015153.  86 % 
of  these  national  payments  were  allocated  to  waste 
management  activities  (EU-average:  49.7 %).  EUR 2.8 
million was allocated to waste water management (0.9 % 
of  total)  and  0.3 %  of  environmental  expenditure  was 
allocated  to  protecting  biodiversity  and  the  landscape 
(EUR 0.8  million).  Between  2012  and  2016,  general 
government  funding  for  environmental  protection  came 
to EUR 1.63 billion154. 

As  it  has  been  mentioned  several  times  through  the 
report,  one  of  the  main  challenges  for  Bulgaria  is  to 
ensure  that  environmental  financing  remains  at  an 
adequate level. Existent financial gaps in sectors such as 
waste  management,  green  infrastructure  or  biodiversity 
implementation  of  EU 
are  delaying 
environmental  law  and  policies.  Therefore,  ensuring 
financial  resources  to  reduce  the  implementation  gap 
should be considered as a priority for the country. 

the  correct 

2019 priority action 

  Mobilise  investment,  including  through  EU  funds,  in 
waste  prevention,  separate  collection  and  recycling, 
as  well  as  addressing  air  pollution,  enhancing 
biodiversity and green infrastructure. 

153 Eurostat, General Government Expenditure by function, 2018. 
154 No data is available on the funds used for pollution abatement. 

29 

 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

5. Strengthening environmental governance 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention:  
(i) access to information;  
(ii) public participation in decision making; and  
(iii) access to justice in environmental matters.  

It is of crucial importance to public authorities, the public 
and  business  that  environmental  information  is  shared 
efficiently  and  effectively155.  Public  participation  allows 
authorities  to  make  decisions  that  take  public  concerns 
into account. Access to justice is a set of guarantees that 
allows  citizens  and  NGOs  to  use  national  courts  to 
protect the environment156. It includes the right to bring 
legal challenges (‘legal standing’)157. 

Environmental information 

Environmental  information  is  provided  via  the  main 
portal of the Ministry of Environment and Water and its 
Executive  Environmental  Agency.  The  portal  is  divided 
across  two  main  websites:  a  Ministry  website  and  an 
Agency website.  The content relates to both nationwide 
the 
and  European 
environment  and  legislation.  The  sites  hold  most  of  the 
legal  information,  reports  and  multiple  links  to  relevant 
sites.  

information  on 

the  state  of 

information 

Environmental 
is  provided  for  the  key 
environmental  topics:  air,  water,  soil,  biodiversity  and 
waste.  Vital  information  is  under  Preventive  Measures, 
which  covers environmental assessment  procedures and 
related public registers. A number of portals are running 
or  are  under  development,  e.g.  on  public  registries  on 
EIAs,  SEA,  chemical  use  by  industries,  the  biodiversity 
monitoring system and waste.  

There  is  some  overlap  between  the  type  of  information 
on  the  Ministry’s  main  site  and  on  that  of  the  Agency. 
The latter provides  more  information about  the state of 
the  environment,  monitoring  data  and  links  to  the 

155 The Aarhus Convention, the Access to Environmental Information 
Directive2003/4/EC and the INSPIRE Directive 2007/2/EC together 
create a legal foundation for the sharing of environmental information 
between public authorities and with the public. This EIR focuses on 
INSPIRE. 
156 The guarantees are explained in Commission Notice on access to 
justice in environmental matters, OJL 275, 18.8.2017 and a related 
Citizen’s Guide. 
157 This EIR looks at how well Member States explain access to justice 
rights to the public, and at legal standing and other major barriers to 
bringing cases on nature and air pollution. 

Regional 
Inspectorates  for  Environment  and  Water. 
Searching  for  general  information  is  easy;  searching  for 
specific information takes more time. 

is 

Bulgaria’s  performance  on  the  implementation  of  the 
INSPIRE  Directive 
lagging.  Performance  has  been 
reviewed based on its 2016 implementation report158 and 
the  most  recent  monitoring  data  from  2016159  (Bulgaria 
was  late 
in  providing  monitoring  results  for  2017). 
Additional  efforts  are  needed  to  identify  and  document 
spatial  data,  make  the  data  accessible  through  services 
and prioritise environmental datasets in implementation, 
in  particular  those  identified  as  high-value  spatial  data 
sets 
implementation  of  environmental 
legislation160. 

the 

for 

Figure  23:  Access  to  spatial  data  through  view  and 
download services in Bulgaria (2017) 

Public participation 

through 

implemented  mainly 

The Aarhus Convention and related European legislation 
is 
the  Bulgarian 
Environmental  Protection  Act.  There  are  also  some 
sector-specific  provisions.  The  Council  of  Ministers 
created  a  central  portal  (http://www.strategy.bg)  to 
allow  adequate  participation 
in  the  preparation  of 
legislation and policies. The Ministry of Environment and 
Water also publishes information on plans, programmes 
and  projects.  Eurobarometer  figures  from  2017  show 
that in Bulgaria, there is quite a high level of agreement 
(73 % of respondents) that an individual can play a role in 
protecting  the  environment.  This  has  fallen  since  the 
2014  Eurobarometer  results  and  the  level  of  confidence 
is significantly lower than the EU-28 average of 87 %. 

158 INSPIRE BG country sheet 2017. 
159 INSPIRE monitoring dashboard. 
160 European Commission, List of high value spatial data sets. 

30 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

Access to justice 

Bulgaria  lacks  official  websites  providing  the  public  with 
practical information on environmental access to justice. 

Bulgaria’s  approach  to  legal  standing  is  still  restrictive 
and  based  on  direct 
interest.  Bulgarian  courts 
consistently deny standing to citizens and environmental 
NGOs  to  contest  the  content  of  Air  quality  plans.  The 
Bulgarian  Supreme  Administrative  Court  (SAC)  recently 
recognised  the  legal  standing  of  other  parties  in  a  case 
concerning  the  legality  of  a  management  plan  for  the 
Pirin  national  park,  and  referred  to  the  case-law  of  the 
Court  of  Justice.  However,  it  is  not  clear  how  significant 
this precedent will be for other cases. 

A  recent  amendment  of  the  Administrative  Procedural 
Code, entering into force on 1 January 2019, significantly 
increases  the  cost  of  cassation  referrals  to  challenge 
environmental authorisations161, which is likely to create 
a  barrier  to  access  to  justice  for  the  appellants  at  the 
second instance, and limits court review to one level only 
land  use  and 
for  referrals  related  to  change  of 
exploration of underground resources.  

2019 priority actions 

 

 

Improve  access  to  spatial  data  and  services  by 
making  stronger 
linkages  between  the  central 
INSPIRE  website  and  regional  portals,  identify  and 
document  all  spatial  datasets  required  for  the 
implementation  of  environmental  law162,  and  make 
the data and documentation at least accessible ‘as is’ 
to  other  public  authorities  and  the  public  through 
the  digital  services  provided  for  in  the  INSPIRE 
Directive. 
Ensure that there is legal standing for environmental 
NGOs  to  bring  legal  challenges  on  air  pollution  and 
nature. 

Compliance assurance 

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste163.  It 
includes  support  measures  provided  by  the  authorities, 
such as:  
(i) compliance promotion164;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring165; and  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement166.  
Citizen  science  and  complaints  enable  authorities  to 
liability167 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

Compliance promotion and monitoring 

Online  information  to  farmers  on  how  to  comply  with 
obligations on nitrates and nature is an indicator of how 
actively  authorities  promote  compliance  in  areas  with 
serious implementation gaps. The official websites of the 
relevant  Bulgarian  authorities  lack  structured,  detailed 
information  for  farmers  on  how  to  comply  with  these 
obligations. 

Environment 

and  Water 

Major  industrial  installations  present  serious  pollution 
risks.  Public  authorities  are  required  to  have  plans  to 
inspect  them  and  to  make  individual  inspection  reports 
available  to  the  public168.  The  regional  offices  of  the 
Ministry  of 
(Regional 
Inspectorates  for  Environment  and  Waters,  National 
Parks and River Basin Directorates) publish their plans for 
monitoring and control activities169 online, together with 
the  lists  of  entities  subject  to  monitoring  under  various 
relevant  laws,  including  industrial  emissions  legislation. 
The  Regional  Inspectorates  for  Environment  and  Water 
(RIEWs)  publish  monthly  activity  reports  covering  the 
number  of 
inspections  carried  out,  the  number  of 
recommendations provided, and the number of penalties 

163 The concept is explained in detail in the Communication on ‘EU 
actions to improve environmental compliance and governance’ 
COM(2018)10 and the related Commission Staff Working Document, 
SWD(2018)10. 
164 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
165 This EIR focuses on inspections of major industrial installations.  
166This EIR focuses on the availability of enforcement data and co-
ordination between authorities to tackle environmental crime. 
167 The Environmental Liability Directive2004/35/EC, creates the 
framework. 
168 Article 23, Industrial Emissions Directive2010/75/EU. 
169 The Ministry of Environment and Water, plans for monitoring and 
control activities.  

161 NGOs and members of the public would have to pay a fee of around 
EUR 2500 to appeal EIA decisions for with material interest over EUR 
5000. 
162 European Commission, Priority list of data sets for eReporting  

31 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

imposed,  including  fines170.  Some  inspection  reports  are 
also made publicly available. 

useful  step  towards  building  stronger  enforcement 
capacity.  

Citizen science and complaint handling 

Environmental liability 

Involving  citizens,  through  citizen  science  and  in  other 
ways, can deepen knowledge about the environment and 
help  the  authorities  in  their  work.  No  information  has 
been found on the use of citizen science in Bulgaria. The 
availability  of  clear  online  information  about  how  to 
make  a  complaint  is  an  indicator  of  how  responsive 
authorities  are  to  complaints  from  the  public.  Citizens 
can  report  matters  and  make  complaints  to  Regional 
Inspectorates of Environment and Water via a telephone 
hotline  (Green  hotline)  or  by  email.  The  Regional 
Inspectorates  of  Environment  and  Water 
keep 
anonymous monthly public records on  such submissions 
and  the  measures  taken  to  address  them  by  the 
competent authorities. They are handled openly, without 
disclosing the identity of the complainant. Information on 
the  action  taken  is  published  on  the  websites  of  the 
Ministry  of  Environment  and  Water  and  its  regional 
offices. 

Enforcement 

identifies  problems,  a  range  of 
When  monitoring 
responses may be appropriate. Reports on inspections of 
industrial installations or summaries of their findings are 
published on the websites of the regional environmental 
inspectorates  in  a  user-friendly  manner.  The  Ministry  of 
information  on 
Environment  and  Water  compiles 
it  monthly  in  the 
sanctions  imposed  and  publishes 
relevant  section  of 
the 
information  does  not  allow  conclusions  to  be  drawn  on 
whether 
sanctions  were  effective  and  whether 
installations  complied  after  follow-up  measures  and 
enforcement  action  were 
Information  on 
responses  to  cross-compliance  breaches  on  nitrates  and 
nature is lacking. 

its  website171.  However, 

taken. 

is  especially  challenging. 

Tackling  waste,  wildlife  crimes  and  other  environmental 
offences 
It  requires  close 
inspectors, 
cooperation  and  coordination  between 
customs authorities, police and prosecutors. However, no 
information  could  be  identified  on  official  websites  on 
formal or informal cooperation between these, and there 
are  no  published  statistics  on  trafficking  in  endangered 
species,  illegal  trafficking  in  waste  or  surface  water 
pollution.  The  establishment  of  a  national  network  of 
prosecutors  specialized  on  environmental  cases  is  a 

170 The Regional Inspectorate of Environment and Water – Veliko 
Turnovo. Randomly selected examples of website of RIEW Veliko 
Turnovo. All RIEWs follow same approach in presenting the 
information.  
171 MoEW control activities. 

The  Environmental  Liability  Directive  (ELD)  establishes  a 
framework  based  on  the  ‘polluter  pays’  principle  to 
prevent  and  remedy  environmental  damage.  The  2017 
EIR 
information  on 
environmental  damage,  on  financial  security  and  on 
establishing  guidance.  The  Commission  is  still  collecting 
evidence on the progress made. 

focused  on  gathering  better 

2019 priority actions 

  Better 

inform 

the  public  about 

compliance 
promotion, monitoring and enforcement by, at least, 
ensuring availability of online information to farmers 
about  how  to  comply  with  obligations  on  nitrates 
and nature. 
Publish more detailed and structured information on 
the  outcomes  of  enforcement  action  and  of  the 
follow-up to detection of cross-compliance breaches 
on nitrates and nature. 
Ensure  more 
dealing with environmental crime work together. 
Improve  financial  security  for  liabilities  and  ELD-
guidance  and  publish  information  on  environmental 
damage. 

information  on  how  professionals 

 

 

 

Effectiveness of environmental 
administrations 

in 

involved 

implementing 

Those 
environmental 
legislation at EU, national, regional and local levels need 
to have the knowledge, tools and capacity to ensure that 
the  legislation  and  the  governance  of  the  enforcement 
process bring about the intended benefits. 

Administrative capacity and quality 

The quality of a country’s institutions, both governmental 
and judicial, is a key determining factor for its well-being. 
Administrative  capacity  is  increasingly  recognised  as  a 
pre-requisite  for  delivering  the  EU’s  treaty  obligations 
and  objectives,  such  as  creating  sustainable  growth  and 
jobs, 
EU 
membership172. 

and  maximising 

benefits 

from 

the 

Bulgaria is a unitary state with three administrative tiers 
— central, regional and local. The structure of the public 
administration reflects these three levels. 

The Ministry of Environment and Water is the central and 
main authority in the environmental sector in Bulgaria. It 
is  responsible  for  drafting  and  implementing  national 

172 European Commission, Quality of Public administration — Toolbox 
2017 edition. 

32 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

environmental  policy;  for  devising  the  environmental 
regulation system; and for coordinating and control over 
the  protection,  conservation  and  rational  utilisation  of 
natural  resources,  waste  management  policy  and  water 
for 
management  policy. 
coordination  and  management  of  financial  resources  on 
environmental  matters, 
the  Operational 
Programme 
the  environment.  The  Executive 
Environmental  Agency  reports  to  the  environment 
minister  and  carries  out  management,  coordination  and 
information tasks for environmental protection.  

responsible 

including 

is  also 

for 

It 

The 16 Regional Inspectorates of Environment and Water 
(RIEWs)  are  territorial  units  of  the  Ministry.  They  have 
regulatory,  information,  monitoring  and  control  tasks; 
their  main  activity  is  to  enforce  environment  law.  They 
have  the  power  to  impose  sanctions  and  monitor  the 
performance  of  municipalities  and  other  players.  They 
also provide a 24-hour ‘Green Hotline’ for environmental 
information  and  alerts.  The  four  basin  directorates  are 
regional authorities of the Ministry with responsibility for 
water basin management. They cover the four river basin 
districts in Bulgaria: the Danube River, the Black Sea, the 
East  Aegean  and  the  West  Aegean.  The  three  national 
park  directorates  (NPD)  —  Rila,  Pirin  and  Central  Balkan 
—  are  also  regional  authorities  of  the  Ministry.  Their 
tasks 
implementing  the  parks’ 
management plans.  

include  drafting  and 

Municipalities  are  the  basic  administrative-territorial 
units  of  self-governance.  The  powers  of  municipalities 
vary  from  full-scale 
legal  powers  regarding  waste 
to  drafting  policies  and  providing 
management, 
information  on  and 
for  administrative 
procedures such as SEA and EIA, for which the RIEWs are 
responsible. They  may also participate in procedures for 
designating  protected  areas  and  drafting  management 
plans for protected areas173. 

support 

Central, regional and local administrations must have the 
ability  to  carry  out  their  own  tasks  and  work  effectively 
with  each  other  within  a  system  of  multi-level 
governance. 

With  a  governance  score  of  0.26,  Bulgaria 
is  still 
performing significantly below the EU average of 1.1 with 
regard to the government effectiveness index, as well as 
the regulatory quality index. It still ranks last in the EU for 
the rule of law and control of corruption174. 

Improving  the  quality  of  services  and  introducing  e-
government  has  been  a  key  priority 
in  public 
administration  reform  for  almost  two  decades.  Progress 
in  this  area  is  slow,  but  some  improvement  in  service 
delivery  is  already  evident,  particularly  in  terms  of  ease 

of  access  and  greater  transparency.  The  expectation  is 
that  digitisation  could  also  improve  transparency  and 
therefore  lead  to  reduced  corruption,  which  is  not 
evident  at  present.  Nevertheless,  public 
sector 
information has become widely available and is the area 
in which Bulgaria has its highest ranking175. 

As  noted  in  the  2017  EIR,  unstable  policies  and  lack  of 
trust  in  key  public  institutions  such  as  the  judiciary  are 
significant  deterrents  to  investment  in  the  Bulgarian 
economy  and  lead  citizens  and  environmental  NGOs  to 
opt to address their concerns about possible breaches of 
environmental  legislation  to  the  European  Commission, 
even in areas not covered by EU law. While a number of 
reforms 
practical 
implementation is delayed. Businesses are still concerned 
shortcomings  and 
institutional 
about 
public 
in 
supply. 
insufficient 
administration 
is  slow. 
Governance in the public sector could benefit from more 
transparency, 
long-term 
rules 
perspective176. 

reform  and  e-government 

corruption, 
labour 

adopted, 

Progress 

clearer 

been 

have 

their 

and 

a 

Non-conformity continues to be an insignificant factor in 
infringement  proceedings  against  Bulgaria,  as  Bulgaria 
generally  transposes  environmental  directives  on  time 
and  correctly.  Poor  application  and  enforcement  of 
environmental  legislation,  however,  are  still  a  major 
cause of infringement proceedings. 

Air  quality,  appropriate  assessment  under  the  Habitats 
Directive,  waste  management  and  urban  waste  water 
treatment  remain  the  most  problematic  issues.  The 
application  of  the  Directives  on  environmental  impact 
assessment (EIA) and strategic environmental assessment 
(SEA)  are  also,  to  some  extent,  raised  as  part  of 
complaints in the above areas. 

Coordination and integration 

Environmental 

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised 
(EIA) 
Directive177 into national law provides an opportunity for 
countries  to  streamline  their  regulatory  framework  on 
environmental  assessments.  Bulgaria  transposed  the 
Directive by the deadline of May 2017.  

Impact  Assessment 

environmental 

Bulgaria  is  one  of  the  Member  States  providing  for 
The 
streamlined 
Commission strongly encourages that approach to reduce 
duplication  and  avoid  overlaps 
in  environmental 
assessments  applicable  for  projects.  Streamlining  helps 
to  reduce  unnecessary  administrative  burden.  It  also 

assessments. 

173 UNECE, Environmental performance review (EPR) Bulgaria,2017, 
p. 28. 
174 World Bank, 2017 Worldwide Governance Indicators. 

175 Zankina, E.:Public administration characteristics in Bulgaria, 2017. 
176 Council Recommendation, Bulgaria 2018 (para 17). 
177 Directive 2014/52/EU. 

33 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

accelerates  decision-making,  without  compromising  the 
quality of the environmental assessment procedure178. 

Since Bulgaria’s accession to the EU, its national law has 
successively  incorporated  appropriate  assessment  under 
the Habitats Directive (in 2007), the integrated pollution 
prevention  and  control  (IPPC)  permitting  process  (in 
2008)  and  the  ‘Seveso’  process  for  chemical  safety  (in 
2015)  into  its  EIA  procedures.  EIA  therefore  provides  a 
single  environmental  ex  ante  quality  assurance  system 
for development proposals, extensions and amendments. 

Adaptability, 
(eGovernment) 

reform 

dynamics 

and 

innovation 

Bulgaria ranks  23rd out  of the 28 EU Member States on 
digital  public  services  in  the  2018  Digital  Economy  and 
Society  Index,  with  a  score  of  49  (lower  than  the  EU 
average  of  58)179.  In  terms  of  eGovernment,  Bulgaria  is 
progressing,  but  at  a  slower  pace  than  other  EU 
countries. A number of steps have been taken to improve 
digital  public  services.  A  strategic  framework  is  in  place; 
in 
the  State  e-Government  Agency  (SEGA),  created 
December  2016,  is  now  fully  operational;  and  the  ICT 
budget  framework  has  been  optimised.  The  number  of 
eGovernment users has increased compared to last year 
and is now in line with the EU average 180. 

Enabling financing and effective use of funds 

finance 

investment 

for  business.  Grants 

improve 
European  Structural  and  Investment  Funds 
access  to 
from  the 
operational programme Innovation and Competitiveness 
mainly  benefit  SMEs  for 
in  machinery, 
innovation  and  energy  efficiency.  Commercial  banks  are 
developing  a  loan  portfolio,  expected  to  reach  EUR 600 
million, guaranteed by the operational programme ‘SME 
Initiative’.  Further,  a  EUR 150  million  agreement  was 
signed  by  the  Bulgarian  Development  Bank  (BDB)  under 
the  EU  Investment  Plan  to  finance  small  and  medium-
scale  projects,  but  the  overall  role  of  the  BDB  in  the 
economic  environment  remains  unclear.  Venture  capital 
and business angel financing are still lagging. The start-up 
ecosystem  is  still  largely  dependent  on  public  support; 
however, there is a significant delay in implementing the 
available  public 
first 
agreements  with  local  financial  institutions  arising  from 
the  Fund  Manager  of  Financial  Instruments  in  Bulgaria 
calls were signed in December 2017, but for very limited 
amounts.  According  to  local  stakeholders,  continuity, 

instruments.  The 

financial 

political  independence  and  suitability  for  market  needs 
are  critical  for  further  improving  the  local  financing 
ecosystem181. 

2019 priority action 

  Bulgaria 

can 

further 

overall 
environmental  governance  (such  as  transparency, 
citizen  engagement,  compliance  and  enforcement, 
as well as administrative capacity and coordination). 

improve 

its 

International agreements 

The  EU  Treaties  require  the  EU  environmental  policy  to 
promote  measures  at  international  level  to  deal  with 
regional or worldwide environmental problems. 

The EU is committed to strengthening environmental law 
and its implementation globally. It therefore continues to 
support  the  Global  Pact  for  the  Environment  process, 
which  was  launched  by  the  United  Nations  General 
Assembly  in  May  2018182.  The  EIR  is  one  of  the  tools  to 
ensure  that  the  Member  States  set  a  good  example  by 
respecting  European  Union  environmental  policies  and 
laws and international agreements.  
Forests:  EU  Timber  Regulation  (EUTR)183/  Forest  Law 
Enforcement,  Governance 
(FLEGT) 
Regulation184 

Trade 

and 

From  March  2015  to  February  2017,  Bulgaria  only 
reported on the annual plan for checks on operators for 
domestic  timber,  not  for  imported  timber.  Bulgarian 
competent authorities have performed more checks than 
originally  planned  (725, 
instead  of  610)  on  4013 
estimated operators placing domestic timber onto the EU 
market.  So  far, two fines  (each EUR 175)  were appealed 
against  and  a  court  decision  is  expected.  Additionally,  a 
number of checks were conducted on traders185. 

Generally, Bulgaria  has provided relevant  information to 
the  EU  with  regard  to  penalties  issued.  It  reported 
conducting  420 414  inspections  (on  persons,  vehicles 
etc.) 
law 
in  2016,  with  22 519  breaches  of  forest 
identified  leading  to  17 404  notices  of  administrative 
breaches.  In  terms  of  cooperation  (Article  12  EUTR), 
Bulgaria is mainly working with national customs and tax 
agencies. 

178 The Commission issued a guidance document in 2016 regarding the 
setting up of coordinated and/or joint procedures that are 
simultaneously subject to assessments under the EIA Directive, Habitats 
Directive, Water Framework Directive, and the Industrial Emissions 
Directive, OJ C 273, 27.7.2016, p. 1. 
179 European Commission, Digital Economy and Society Index Report 
2018, Digital Public Services. 
180 European Commission, 2018 DESI Country profile, Bulgaria 

181 European Commission, 2018 Country Report, Bulgaria, p. 45. 
182 UN General Assembly Resolution 72/277 and Organizational session 
of the ad hoc open-ended working group.  
183 Regulation (EU) No 995/2010. 
184 Regulation (EC) No 2173/2005. 
185 390 checks were conducted on traders. 

34 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Bulgaria 

Genetic  resources:  Nagoya  Protocol  on  Access  to 
Genetic Resources and the Fair and Equitable Sharing of 
Benefits Arising (ABS)186  

Bulgaria  is  one  of  only  two  countries,  with  Austria,  that 
have  not  yet  submitted  or  announced  (for  2019)  a 
Voluntary National Review on the SDGs to the UN. 

In  accordance  with  the  EU  Regulation  on  access  and 
benefit-sharing (ABS), which transposes into the EU legal 
order the measures required to comply with the Nagoya 
Protocol,  Bulgaria  has  designated 
its  competent 
authorities and introduced sanctions for infringements of 
the  Regulation.  No  due  diligence  declaration  has  been 
submitted  so  far  and  no  penalties  have  been  applied. 
Bulgaria  submitted its  first report  to the Commission on 
implementation  of  the  EU  ABS  Regulation  at  the  end  of 
2017. 

International  wildlife 
the  Convention  on 
trade: 
International  Trade  in  Endangered  Species  of  Wild 
Fauna and Flora (CITES)187 

Bulgaria has established relevant national authorities for 
the  international  wildlife  trade  and  regularly  processes 
requests for import, export, re-export, and intra-EU trade 
documents.  

Reports  on  seizures  of  illegal  wildlife  shipments  (in 
particular  those  reported  every  6  months  to  TRAFFIC 
under  its  contract  with  the  Commission,  and  those 
exchanged  through  the  EU-TWIX  platform)  show  the 
extent of the customs authorities’ activity. 

To  ensure  the  EU  wildlife  action  plan  (2016)  is  fully 
implemented  and  to  improve  the  rate  of  detection  of 
illegal activities, Bulgaria has carried out targeted actions, 
e.g. the ‘LIFE for Danube Sturgeons’ project, which aims 
to  combat  sturgeon  poaching  and 
in 
caviar188. 

illegal  trade 

Sustainable development and the 
implementation of the UN SDGs 

Sustainable development links environmental, social and 
economic policies in a coherent framework and therefore 
helps  to 
legislation  and 
policies. 

implement  environmental 

Bulgaria  has  not  adopted  a  national  sustainable 
development strategy. 

The  implementation  of  Agenda  2030  and  its  SDGs  does 
not seem to have the same priority in Bulgaria as in most 
other  Member  States.  Currently,  there  is  no  single 
institution  responsible  for  coordinating  implementation 
is  no  evidence  of  an  active 
of  the  SDGs  There 
interinstitutional  process  to  devise  a  national  SDGs 
programme. 

186 Regulation (EU) No 511/2014. 
187 The Convention on International Trade in Endangered Species of 
Wild Fauna and Flora (CITES). 
188 EU LIFE project, LIFE for Danube Sturgeons. 

35