Bluelink Submitted Recommendations for Revision of the National Recovery and Resilience Plan

Bluelink prepared recommendations for the revision of the draft National Recovery and Resilience Plan (NRRP) published on 16.04.2021. The recommendations were submitted to the Deputy Prime Minister for European Funds Management, the Head of the EC Representation in Bulgaria and several line ministries.

The opinion contains recommendations under Pillar 2.B Green Bulgaria and Pillar 2.C Connected Bulgaria from the NRRP and the components included in them: Low Carbon Economy, Sustainable Agriculture and Transport Connectivity. The recommendations are aimed, on one hand, at improving the planned projects, increasing the budget of some of the measures, as well as including additional measures that are necessary and will directly lead to nature protection, and on the other hand, will help mitigate the effects of climate change. The expert opinion prepared by Bluelink also contains horizontal recommendations regarding the implementation of the principles of the circular and bio-economy in all 4 pillars of the NRRP.

The proposals made were prepared within the project "Fostering Public Debate on Green Recovery and Resilience in Bulgaria". The strategic goal of the project is to contribute to the improvement of the dialogue with various stakeholders and professional groups that will be directly affected by the implementation of the NRRP.
With the support of the Green European Foundation gef.eu, BlueLink conducted a study of the application of the so-called Green Recovery and Resilience Mechanism  from the COVID-19 pandemic in Bulgaria and 3 selected EU member states (Portugal, Latvia and Slovakia) and the prepared NRRPs in them. As a result of the research, the three most problematic policy areas in the Bulgarian NRRP in the Green Bulgaria pillar were identified and recommendations were developed to achieve compliance with the applicable EU regulations, criteria and requirements.

Based on the analysis, Bluelink experts prepared position papers with proposals for “greening” of the NRRP in the selected three problematic thematic areas and specific proposals for achieving compliance with the applicable EU requirements in these areas of the plan. The opinions were presented and discussed in a number of meetings held in the period April-May 2021 with representatives of political parties, institutions, branch organizations, NGOs and other target groups that support the greening of NRRP.

The main conclusions of the analysis in the field of Sustainable Agriculture policy are that agriculture in Bulgaria needs real support and good policies, not concrete and diesel pumps. The draft NRRP in this policy area envisages a little over BGN 870 million, of which 97% will go to the state enterprise "Irrigation Systems" for drainage of natural wetlands and concrete irrigation canals. Transformation of agricultural projects is needed to meet the criteria of the European Commission and contribute to the adaptation of Bulgarian agriculture to climate change and to synchronize with the new strategy "From farm to fork".

In the "Low Carbon Economy" policy area, the NRRP does not contain any intention to take action to get the Bulgarian economy out of the linear model of production. This is evident from the total planned resource of BGN 100 million (app. EUR 50 million) to support the transition to a circular economy in the plan, which is extremely insufficient in terms of funds and as a time period for which to invest and achieve real results in the direction of transformation to a circular economy. Some of the most important reforms for Bulgaria to start applying the principles of the circular economy include: approaches to increase understanding and capacity in the administration at national, regional and local levels as well as among local businesses in terms of implementing the principles of the circular economy; development and implementation of specific state and municipal programs and schemes for circular economy; identifying and promoting industries and sectors with high potential to apply the principles of the circular economy.

The planned measures for adaptation to climate change and energy transformation in NRRP are unambitious and inadequately supported by investments. Blulink's opinion states that a targeted stimulation of the production and storage of energy from renewable sources for own needs should be sought by easing the administrative procedures for investors, incl. and when two or more investors would like to organize into an "energy cooperative" for the production and storage of "green energy". The plan needs to provide financial incentives based on financial instruments and not so much on direct grant schemes. It is recommended to join the European Hydrogen Backbone initiative, drop out investments that are not directly related to the development of railway transport, and in the new energy efficiency programs it is necessary to create preconditions for obtaining the maximum social, economic and environmental effect from their implementation, accompanied by a gradual increase in the own contribution of the building owners.

The text was prepared within the framework of the project № GEF-21-17 “Fostering Public Debate on Green Recovery and Resilience Process in Bulgaria”. The project is organised by the Green European Foundation with the support of Bluelink and with the financial support of the European Parliament to the Green European Foundation.

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