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The changes to the “Best Available Techniques Reference Document for Large Combustion Plants” will heavily affect coal power plants in Bulgaria

Despite the resistance of some countries, including Bulgaria, a special committee of the EU Member States adopted a new “Best Available Techniques Reference Document for Large Combustion Plants” (“LCP BREF”) in April 2017. The LCP BREF is drafted by a special body, called the European Integrated Pollution Prevention and Control Bureau (“IPPC Bureau”). BREFs are the main reference documents used by competent authorities in the Member States when issuing operating permits for installations with a significant pollution potential in Europe.

The approved rules set out new lower limits to the harmful emissions released in the air from Large Combustion Plants (units of over 50MWt). They should be implemented by 2022.

Preliminary research by a consultancy company commissioned by the European Climate Foundation indicates that the costs to bring all installations up to the new environmental requirements for Bulgaria will be about EUR 1.2 billion. Our country thus ranks fourth in Europe for the maximum amount of investments needed after Poland, the Czech Republic and Romania.

The few options available to the coal power plants to comply with the new ecological requirements include:

  • not modernising and shutting the plants down;
  • investing and modernising, which could possibly lead to an increase in the electricity prices; or
  • requesting a derogation with a temporary delay in applying the new requirements by proving that the value of the modernization would not offset the benefits to the environment and the society.

In Bulgaria, the three large coal power plants from the Maritza-Iztok complex will together seek a consultant who is familiar with the European environmental norms and who will assess the costs for the modernization of the plants.

If the extra costs or investments that the installations have to make are much larger or are disproportionately greater than the benefits to the society and environment, the Bulgarian Environmental Executive Agency, which will coordinate the applications with the European Commission, may grant a derogation to the relevant power plant.

The six-month deadline for the large coal power plants to apply for a derogation before the Executive Environmental Agency started in the beginning of August. It will become clear next year which power plants will be granted derogation with a delay in implementing the new rules.

Authors

Picture of Dimitar Zwiatkow
Dimitar Zwiatkow
Partner
Sofia