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Assessment for Bulgaria (Pernik)

Status: Draft Plan
Date of plan: 02.08.2022
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Overall Plan Rating

There are also some indicators rated as not consistent with the just transition. These are marked as red on the traffic light system and should be the foremost priorities to address and improve on. The indicators are organised under their corresponding principles in the Annex to this report.

Principle 1

The TJTP should be sustainable and deliver on long-term, international and EU climate commitments such as the Paris Agreement and EU 2030 and 2050 climate objectives.
Indicates a commitment to reduce GHG emissions but by < 55% emissions reduction versus 1990 levels by 2030 OR it does not indicate a need to reduce emissions at all
Identifies the opportunities to increase renewable energy in the region and specific actions, projects or targets are proposed
Does not Identify the opportunities to increase energy efficiency or reduce energy use in the region or nationally
Comments: The plan fails to foresee the need for energy efficiency and energy demand reduction in the outdated district heating system of Pernik.

Principle 2

The TJTP should not lead to prolonged fossil fuel use or promote false solutions to the transition to climate neutrality. As a guide, coal should be phased out by 2030.
A phase-out of coal is planned or implied (the fossil fuel is recognised as in terminal decline), but the end date is after 2030 or undefined
No phase-out of fossil gas is planned or implied
Does not propose to phase out fossil fuel subsidies, or even proposes to introduce new or increase existing ones

Principle 3

The TJTP should lead to sustainable economic diversification at the local, regional and national level.
Promotes economic diversification, but there is no consideration of the need for new industries to be sustainable
Comments: The economic diversification plans for Pernik region are focused on industry hubs and logistics with no specific sustainability focus or aim.
Recognises the value of SMEs and start-ups for economic diversification, but does not set out clearly how it will provide support to develop and incentivise them
Indicates a link to and a need for consistency with the NECP, but does not clearly link investments for sustainable economic diversification and decent job creation to it
Comments: The Bulgarian NECP does not factor clear coal transition and needs to be updated.

Principle 4

The TJTP should address social inequalities, improve interregional solidarity, decrease inequalities and tackle injustices.
Justifies why certain regions should receive support with reference to the underlying economic and employment impacts of the transition, and justifies the choice objective criteria or comparative data
Comments: The plan states that while Pernik is the least affected of the 3 Bulgarian coal regions, 2 600 jobs are directly at risk with more indirect losses, due to energy-intensive industry.
Prioritises employment support and job search assistance for workers directly losing their jobs as a result of the transition AND other worker groups, including those who may be indirectly affected
Comments: The plan identifies youth and economically disadvantaged groups.
Identifies some of the existing and future skills, training and education gaps at regional level on the basis of objective and quality skills forecasts, or sets out a process to identify them - but  focuses on a limited range of sectors or only on workers directly affected by the transition or who have already lost their jobs
Comments: There is insufficient detail, with only a focus on IT/digital skills mentioned.
Foresees targeted investments sufficient to remedy these gaps and create decent, sustainable and resilient jobs for all current (and future) workers in the region
Comments: Pernik's proximity to the capital Sofia makes such targeted high-tech industry investments much more likely and the Plan identifies steps to pursue them.
Recognises that new jobs created by the transition should represent decent work, meaning they provide an equivalent or higher wage than existing jobs, provide access to collective bargaining and ensure safe, healthy working conditions and reasonable working hours. It foresees measures to address these issues
Comments: Foresees 900 jobs created in relevant support industries.
Recognises some inequalities and identifies some measures to address those arising from the transition, such as a minimum income support, energy poverty reduction or early pensions. But the TJTP does not consider existing inequalities or address all inequalities identified with planned measures
Comments: The plan focuses mostly on inequalities among the workers involved in the coal sector, but does not focus on general population inequality, energy poverty (especially Pernik residents, relying on coal-powered district heating), and does not include such indicators.
Identifies the potential changes to quality of life arising from the transition and includes some targeted measures to address residual negative factors, such as air and water quality issues
Comments: he plans focuses on rehabilitation and contains indicator on rehabilitated and "greened" areas RCR 52 (only a small 100 ha area), but falls short of analysing the problem of air, water and soil pollution or proposing nature-based solutions for the region.
makes reference to the importance of supporting gender equality but does not propose any dedicated activities or priorities to achieve this

Principle 5

The TJTP should not harm EU environmental and climate objectives and values.
Does not include activities which would negatively impact environmental and biodiversity indicators relating to:
- Biodiversity
- Air pollution
- Accessible greenspace (land take)
- Water quality

AND neither does it include significantly harmful activities as defined by the EU Taxonomy or which would lead to unsustainable use of natural resources or which would lead to ecosystem harm
Comments: The included measures under the new Pernik industrial hub do not include direct conversion of greenland or other adverse impacts, although energy intensive development of the area poses such risks.
Foresees no investments in infrastructure which could directly or indirectly lead to greater greenhouse gas emissions
Comments: No explicity fossil fuel investments. Hydrogen and biogas investment do not include major new pipelines, but implementation must be monitored.
Identifies actions or possible activities to improve some biodiversity and environmental indicators. These activities and actions cover at least one of the following categories:
- Biodiversity
- Air pollution
- Accessible greenspace (land take)
- Water quality
Includes programme specific indicators (section 2.5) to measure biodiversity or environmental quality
Comments: Comments: RCR 52 indicator for rehabilitated areas included, but no dedicated nature-based solutions.
Foresees no new investment in waste incineration or landfill capacity.
Includes or prioritises new activities which would favour a circular, rather than a linear economy and which will not increase greenhouse gas emissions.
Comments: Not many specifics on circular economy

Principle 6

The TJTP should respect the polluter pays principle.
The TJTP identifies - or commits to identify - the entities responsible for existing environmental damage, but does not establish how the Polluter Pays Principle will be respected when making investment decisions
Comments: It is not clear that the mining and power generation facilities can cover all recultivation and cleanup costs, which for Pernik region include difficult to quantify past damages from underground mining, solely using their own dedicated funds.

Principle 7

The TJTP should be supported by adequate, coordinated and long-term public and private funding sources.
EU funds and national public funds are identified to support the just transition: other sources of public funding than the Just Transition Fund and the Pillar III of the Just Transition Mechanism are identified, including national sources. Funding sources are targeted to the most appropriate activities or to address funding gaps
Comments: NRRP complementarities identified
Private funding sources are not identified and public funding appears to be the sole source of funding identified for the activities and the investments outlined in the TJTP
Comments: No private funding sources leveraged

Principle 8

The TJTP should be designed, monitored and evaluated through meaningful partnerships which engage all stakeholders in an open, inclusive and ongoing process, especially at local level. Social dialogue and collective bargaining should be central pillars of the transition when it comes to the labour market and enterprises.
A coordination body is established but membership of the coordination body requirements and composition may be unclear.


Details on procedures are vague without transparency on timing and schedules for such meetings, or on how, when or where information on process and relevant documents will be published in an accessible place. Alternatively the majority of information must be directly requested from the institution responsible rather than openly available.
Comments: Not many details about the function of the regional coordination unit.
Includes no identification of stakeholders, their roles and status in the process


Includes an incomplete identification of stakeholders, missing key groups and which is inconsistent with the comprehensive list identified in Article 3 of the European Code of Conduct on Partnership, even if roles and status of the stakeholders identified in the process are indicated
Limited detail on how stakeholder views and consultation inputs were integrated into the final plan, or how they will be (beyond a commitment to a consultation, for example).  Detail on stakeholder engagement plans for the preparation, implementation, monitoring and evaluation of the TJTP is also limited.
The plan recognises the need to support capacity building of some stakeholders, particularly those with limited resources, to enhance their engagement
Skip, it is too early to say/don’t know
Comments: No public consultation on final draft yet.
Tripartite social dialogue is part of the planning process. At least some labour unions and social partners have been engaged in social dialogue during the development of the TJTP. Social dialogue is conducted to address the impacts of the transition on sectors which are phasing out and transforming, but not necessarily for emerging sectors.

Principle 9

The TJTP should take a place-based, local approach to strategy design and implementation.
Identifies NUTS 3 regions which will require targeted action and prioritises measures for the specific NUTS 3 regions concerned
Notes the need for community engagement and acknowledges existing or planned community initiatives, but does not indicate how these will be integrated into the TJTP or how the community will be engaged and informed

Principle 10

The TJTP should be developed based on high quality, independent and objective analysis of the challenges and opportunities of the transition for regions.
The indicators and/or data included in the TJTP are high quality, focused at the regional level and are appropriate to the goals of the fund to address the socioeconomic challenges arising from the transition to climate neutrality, but do not cover all aspects of the just transition, focusing for example on the energy transition only
The TJTP foresees a revision process by the Member State but the process is vague, for example it does not include a date, or an evaluation of implementation so far
Attachment: 02082022_JTP_Pernik_BG_f1.pdf