13 September 2023
The draft Territorial Plan for Just Transition of the Pernik Region should be revised and supplemented with concrete measures to ensure the protection of the interests of residential customers of heating services in the city of Pernik, with a focus on supply security and setting the lowest possible prices. This opinion was sent by Ombudsman Diana Kovacheva to the Minister of Energy Rumen Radev on the occasion of the draft’s publication for public consultation (Draft TPJP).
“The plan for accelerated closure of facilities in "Toplofikatsia-Pernik" AD, which currently provides district heating water and heat supply services to about 20 thousand households in the city of Pernik, causes deep concern and anxiety. I note with concern that thousands of household customers of the district heating company in the city of Pernik have not been identified as an interested party in the low-carbon transition. There are no guarantees that their interests will be protected after 2026. In this regard, I believe that a significant gap in the Draft TPJP is the lack of a vision for the future of the district heating supply in the city of Pernik,” writes Prof. Kovacheva.
She notes that the draft in question suggests four possible options. One is the electrification of heating, the second one is industrial reconstruction and technological transition to another energy source, other than coal, in TPP "Republika", part of "Toplofikatsia-Pernik" AD, in order to reduce carbon emissions. In the third option TPP "Republika" will not switch to another energy source and will be closed in 2027. This means that it will be replaced by renewable energy sources (RES), with 105 MW of electrical power, 502 MW of thermal power - photovoltaics, green hydrogen, geothermal energy, wind turbines or biomethane. The fourth option is the hypothesis that TPP "Republika" will not switch to another energy source and will be closed in 2027, and the necessary replacement capacities for the heat supply of domestic customers in Pernik will not have been built by this date.
The Ombudsman points out that a significant shortcoming of the information made available for public consultation is the lack of data on whether each of these options has been examined by the Ministry of Energy, whether consultations have been held with the licensing company for the 'heat transfer' activity in the territory of Pernik and how in each of these scenarios the interests of household customers to receive a reliable, high-quality and continuous heat supply at affordable prices will be protected.
“The question is whether, when switching to electrification of the heating for condominium buildings, the electricity distribution networks in Pernik and the internal electrical installations in the buildings and in the homes of citizens can easily absorb the additional electrical loads. If it is planned to replace coal-fired thermal power with heat power from renewable energy sources, have studies been conducted on their location and, accordingly, on the usability of the existing heat supply infrastructure,” asks Diana Kovacheva.
She emphasizes that it is important not to require from household customers, in the transition to low-emission heating, to make significant out-of-pocket costs for the construction of new facilities or internal installations.
“I consider it fair that if such investments are necessary, they should be fully financed with public funds, as they arise from decisions of public institutions,” affirms Prof. Kovacheva.
She also points out that based on information from the Ministry of Energy, on 9 August this year the TPJPs for the regions of Stara Zagora, Pernik and Kyustendil will be sent to the European Commission for approval as a key condition for the three regions most affected by the energy transition to receive support worth EUR 1.15 billion.
The Ombudsman underlines that the draft plan for Pernik region states that the envisaged energy transition paths take further account of the Recovery and Resilience Plan for Bulgaria (RRP) approved in May 2022, assuming that coal-fired electricity generation will cease by 2038. Such a path is mandated by a decision of the National Assembly of 12 January 2023. Diana Kovacheva demands to know why the low-emission transformation of TPP “Republika” has been accelerated to take place by 2026.
“Is there a risk that thousands of household customers of the district heating company in the city of Pernik will be left without services in 2027 and what specific steps will be taken to prevent energy insecurity for consumers”, asks the Ombudsman and demands that the Ministry of Energy give an assessment to what extent it is realistic that investments in new replacement low-emission or RES thermal facilities will take place at a rapid pace in the next three years.