ADVISORY PROGRAM FOR SUPPORT FOR AIR QUALITY MANAGEMENT

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ADVISORY PROGRAM FOR SUPPORT FOR AIR QUALITY

MANAGEMENT

Inception Report

May 2017

Public Disclosure AuthorizedPublic Disclosure AuthorizedPublic Disclosure AuthorizedPublic Disclosure Authorized

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ABBREVIATIONS AND ACRONYMS

BAMEE Bulgarian Association of Municipal Environmental Experts BAT Best Available Techniques

AQMP Air Quality Management Plan

CAA Clean Air Act

CAFÉ Directive Cleaner Air for Europe Directive (2008/50/EC)

CAPE Clean Air Program for Europe (COM (2013) 918 Final) CLRTAP Convention on Long-Range Transboundary Air Pollution CoM Council of Ministers

EAP Environmental Action Program

EC European Commission

EEA Executive Environment Agency EEC European Economic Community

EU European Union

GHG Green House Gas

GoB Government of Bulgaria

IED Industrial Emissions Directive (2010/75/EU)

IIR Informative Inventory Report (Air Emissions Inventory) IPPC Integrated Pollution Prevention and Control

LCP Large Combustion Plant

MAF Ministry of Agriculture and Food

MCP Medium Combustion Plant Directive (2015/2193/EU) MLSP Ministry of Labor and Social Policy

MOEW Ministry of Environment and Waters

MoE Ministry of Economy

MRDPW Ministry of Regional Development and Public Works

MTITC Ministry of Transport, Information Technology and Communications NAMRB National Association of Municipalities in Republic of Bulgaria

NEC Directive National Emission Ceilings Directive (2001/81/EC revised as (EU) 2016/2284)

NMVOC Non-Methane Volatile Organic Compounds NSI National Statistical Institute

OPE Operational Program Environment 2014 - 2020 PA Priority Axis (of an OP)

RAS Reimbursable Advisory Services RDF Refuse Derived Fuel

REAP National Renewable Energy Action Plan

RI Regional Inspectorate (subordinated to MOEW)

STDS Strategy for Development of the Transport System until 2020

WB World Bank

TA Technical Assistance

TPP Thermal Power Plants (LCPs) VOC Volatile Organic Compounds

Country Manager:

Sector Manager:

Antony Thomson Valerie Hickey

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Task Team Leader: Sameer Akbar

DISCLAIMERS

This report was developed by the World Bank team. The findings, interpretations and conclusions expressed in this report do not necessarily reflect the views of the Executive Directors of the World Bank or the governments they represent. The report was produced to provide advisory support to the Ministry of Environment and Waters (MOEW) and does not necessarily represent the views of the Government of Bulgaria or of the MOEW.

ACKNOWLEDGEMENTS

This report was produced by a core team led by Sameer Akbar (Senior Environmental Specialist, Task Team Leader), Eolina Milova Petrova (Senior Project officer, co-Task Team Leader), Iain Maclean (Resident Project Coordinator), Oznur Oguz Kuntasal (International Air Quality Expert), Vasil Zlatev (Local Air Quality Expert), Ivelina Taushanova (Communications Officer). The contribution of Antony Thompson (Country Manager) in the preparation and negotiation of the Advisory Program is also acknowledged here.

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1 Introduction

1.1 Background

Worldwide an estimated 7 million people die prematurely because of air pollution, making it one of the top ten risk factors. In the European Union (EU) alone more than 400,000 premature deaths annually were linked to exposure to fine particulate matter (PM) air pollution in 2010. Bulgaria has some of the highest levels of fine PM pollution in the EU, and the highest rate of premature deaths due to air pollution in Europe. In 2010, almost 12,000 people died prematurely from exposure to fine PM and ozone; in addition, there were 2.1 million lost working days. It is projected that by 2030, without action being taken, some of the most polluted urban centers in Europe will be in Bulgaria.

The EU Clean Air Program for Europe (CAPE) was adopted on December 18, 2013. CAPE identified that if the current (2013) EU legislation is implemented in full, then premature mortality due to particulate matter and ozone will be reduced by 37% in 2025. CAPE continues to set a target of a 52%

reduction in premature mortality by 2030, set against the base year 2005.

In order to achieve the reduction targets for 2030, CAPE required revision of EU air pollution legislation, particularly revision of National Emission Ceilings (NEC) Directive, which was adopted in December 2016. CAPE saw no need for the revision of the Ambient Air Quality Directive (2008/50/EC) but rather that policy should focus on achieving compliance by 2020 at the latest.

Recognizing the need for urgent action to deal with air pollution, the Bulgarian government requested the World Bank to support and strengthen the framework for air quality management in Bulgaria, reducing emissions of air pollutants and associated health impacts in line with the EU Clean Air Policy Package. As a result, the World Bank developed this Reimbursable Advisory Service (RAS) project in partnership with the Ministry of Environment and Water (MoEW). In particular, this project aims to support developing Bulgaria’s policies to reduce emissions of regulated air pollutants and to manage ambient air quality in support of its plans for compliance with EU air quality legislation and with targets set in the revised emissions directive (NEC).

This RAS will be implemented through the MoEW supported by the World Bank’s Advisory Services resources, including World Bank experts. It is envisaged that this will include the development of policy analysis tools, capacity to quantify health impacts, to plan reduction of impacts through cost-effective measures, the promotion of best practices, coordination across Government Departments and delivery agencies, and strengthening of local regulatory and management institutions.

As the Bulgarian approach to air quality management at a local level requires action in Municipalities, the strength of liaison between the MoEW and Municipalities is a key factor in achieving successful implementation of measures to meet air quality standards. While the MOEW provides guidance for preparing local AQM plans, the responsibility for preparation and implementation of the local air quality management plans is delegated to the municipalities, in order to address the main sources of emissions and improve ambient air quality.

Elsewhere in Europe, notably in the UK and France, it has been found that municipalities require considerable support, for example through training, in implementing the national air quality strategy.

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It has also been found that sharing experience of implementing measures in Municipalities gives helpful feedback in adapting the strategy to local conditions. There are also measures that Government of Bulgaria (GoB) can take at the national level to address local air quality.

Furthermore, policy development on air quality requires cooperation between government departments, involving ministries responsible for public health, energy, transport and, crucially, finance and the economy. As air pollution policy is closely linked to climate policy, cooperation between divisions of the MoEW is also required. This is particularly important in the early stages of policy development when it is important to understand factors that will support or impede the process, where will be synergies with other policy area or where there may be potential tradeoffs to manage.

As an initial step, the MoEW should consider the formation of an inter-directorate group on air quality management, building on existing mechanisms if there is a suitable precedent. Such a group might comprise, within the Ministry of Environment and Water, directorates responsible for:

• Air protection

• Managing Authority because of OPE

• Climate change

• Preventative activities

• Regional Inspectorates

An inter-directorate group of this kind might meet two or three times a year, with work done in between meetings within the network created. As a result, policy development on air quality could be more effective and secure as synergies and tradeoffs are managed within a group of people with mutual understanding and trust.

The World Bank support for the AQM agenda in Bulgaria began in 2014-2015. Upon request by the MoEW, the World Bank undertook a Quick Air Quality Assessment and provided an independent review of the proposed National emission ceilings (NECs) for Bulgaria set by the European Commission (EC) proposed Clean Air Policy Package (CAPP). More specifically, this TA reviewed Bulgaria's position for the NECs for Particulate Matter (PM2.5) and Volatile Organic Compounds (VOCs), with a view to advising the Government of Bulgaria (GoB) on the realistic and achievable NECs for these emissions that are acceptable to both GoB and the EC, taking into account relevant environmental and socio-economic considerations.

In 2016, the Government of Bulgaria requested the World Bank to deliver the RAS and the Advisory Services Agreement was signed on September 28, 2016 between the International Bank for Restructuring and Development (The World Bank Group) and the Ministry of Environment and Water of the Republic of Bulgaria with registration number “P160312”. The Service Agreement became effective on December 28, 2016 following the completion of national procedures for its entry into force.

The RAS is funded through Operational Program "Environment" 2014-2020, which is co-financed by the European Union through European Structural and Cohesion funds. The overall objective of the RAS is to support MOEW by providing inputs to the development of strategic programs for:

• Local air quality management, in order to satisfy the requirements of EU air quality legislation

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(i.e. help to address the issue of current exceedances in 28 municipalities), and

• Meeting air pollution emissions targets as per the upcoming NECs, in the context of the EU Clean Air Policy Package.

The RAS is also expected to contribute to the implementation of Priority Axis 5 of Operational Program Environment, by providing a detailed methodology for determination of Baseline and Target Values for the result indicators for measures, that are eligible for funding under PA 5 of OPE, along with a framework for selecting mitigation measures for the purpose of PA5 of OPE, in line with the broader framework of measures of the municipal AQPs to increase their emission reduction potential.

The overall period of RAS implementation will span a total of 36 months. In scheduling work, priority will be given to activities related to local air quality management during the initial 18 months; activities for meeting air pollution emission targets will be initiated in parallel and will extend into the 24^th month from the entry into force of the revised NEC directive, but will end no later than the 36^th month from initiation of the project. The delivery of project objectives will be strengthened through a number of other activities aimed at strengthening institutional coordination and engagement.

1.2 Objective

1. This Inception Report represents the first output under the Advisory Services Agreement, and marks the end of an eight-week inception period. It has benefitted from previous diagnostic work, and from inputs by the MoEW and other stakeholders.

2. The key objectives of the inception report are:

• To establish a common understanding of the scope of the project, its objectives, results and activities.

• To outline the proposed approach and methodology for the delivery of the Advisory Services and thus, to establish the foundation for the monitoring of the program;

• To present the detailed work plan, timetable and proposed coordination and communication approach for the entire period of the Advisory Services from December 2016 to December 2019.

The main text of the report is deliberately short and does not repeat analysis and findings already made by the Bank and presented to the MOEW in relation to the air quality sector in Bulgaria. Extensive background material is presented in the Annexes.

1.3 General Overview of the Report

Chapter 1 of this inception report explains the need for, and the general background to the RAS.

Chapter 2 presents the framework for the RAS, according to the understanding at the time of its preparation. This understanding is based on negotiations on the agreement and meetings held with some of the main program participants, from the date of signing of the RAS agreement to the date of submission of this report.

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Chapter 3 presents a brief overview of the objectives and deliverables of the RAS, and contains a section on the assumptions and risks for the RAS. The objective and results are derived from the Agreement for Reimbursable Advisory Services.

Chapter 4 presents the work plan for the described activities to support the outcomes and objectives of the RAS.

Chapter 5 presents the time schedule for implementation of the activities in the RAS.

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2 Implementation Framework

2.1 General Issues and Context

The Advisory Services will be designed around the key components of the RAS, which are as follows:

1. Local Air Quality Management – achieving compliance with EU air quality legislation i.e.

implementation of the requirements of the Clean Air for Europe or CAFÉ Directive 2. National Emissions Targets: implementing requirements of the revised National Emissions

Ceilings (NEC) Directive

3. Institutional Coordination and Engagement

In addition to the three main components, it was agreed the RAS would assist the Managing Authority in finalizing methodology for establishing baseline and target values for result indicators for meeting the ex-ante conditionalities for Priority Axis (PA) 5 of Operational Program Environment 2014 -2020 (OPE).

2.1.1 General Overview of the International Regulatory Framework

The starting point for development of EU legislation on air quality was the Convention on Long-Range Transboundary Air Pollution (CLRTAP) of 1979, which remains relevant today. EU legislation on air quality has continued to develop up to the present time and a short history of development of the EU legislation can be found in Annex III.

The current EU legislation is known collectively as the Air Quality Package and is found in Annex IV.

The Air Quality Package is made up of directives and regulations, including those setting limits on emissions to air from both mobile and stationary sources.

Key elements of EU air quality policy which are of particular relevance to this RAS are presented in Table 1.

Table 1. Elements of EU Air Quality Policy

Document Main Significance

EU Thematic Strategy on Air Pollution 2005

• Identifies health impacts of air pollution

• Identifies the cost of air pollution

• Sets 2005 as base year for air pollution CAFÉ Directive 2008/50/EC • Sets monitoring requirements for air quality

• Sets ambient air quality standards

Clean Air Program for Europe 2013 • Reviews effectiveness of existing legislation

• Sets reduction targets for emissions of PM and O3 for 2030

Revised National Emissions Ceilings Directive (EU) 2016/2284

• Sets revised national ceilings for emissions of SO2, NOx, NMVOC, NH3 and PM2.5 to be achieved by 2030 The Thematic Strategy on Air Pollution (2005) was developed to address a requirement of the EC 6th Environmental Action Program (Decision 1600/2002/EC). The Thematic Strategy established interim

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objectives for air pollution, recommended that legislation be modernized and that environmental concerns be integrated into other policies and programs. The Thematic Strategy sets out the health impact and the cost of air pollution.

A follow-up from the Thematic Strategy was Directive 2008/50/EC “on ambient air quality and cleaner air for Europe” (CAFÉ Directive). The CAFÉ Directive sets monitoring requirements and limit values for ambient air, to be achieved by 2010, for a range of pollutants considered most harmful to human health. The CAFÉ Directive is supported by the so-called 4^th Daughter Directive 2004/107/EC which sets limit values for a further range of pollutants. The CAFÉ Directive sets limit values for SO2, NO2/NOx, PM10/PM2.5, Pb, CO and benzene and target values for O3 with these values required to be met close to ground level where human exposure will be at its maximum. The CAFÉ directive places emphasis on locations where the number humans exposed is greatest, as in the case of the so-called

“agglomerations” which have a population >250,000, although CAFÉ directive recognizes the potential for impact on vegetation especially in the case of O3. In summary, the CAFÉ Directive is directed largely towards the immediate exposure of people to mainly local sources of the specified pollutants.

Implementation of the CAFÉ Directive is the main subject of Activity 1 of the RAS.

The European Commission carried out a review of the effectiveness of air quality legislation which resulted in the preparation of the Clean Air Program for Europe (CAPE) adopted in December 2013. A key element of CAPE was recognition that revision of the CAFÉ Directive was not needed but rather that renewed efforts were required to ensure compliance by 2020 at the latest. CAPE also established more ambitious targets for reduction of levels of particulate matter and ozone to be achieved by 2030.

This required further revision of EU legislation, including revision of the NEC Directive. The full range of revised legislation can be found in the Clean Air Package.

The revised NEC Directive (EU) 2016/2284 was published in December 2016, setting revised targets for reductions in national emissions from all emission sources, of SO2, NOx, NMVOC and NH3 beyond the targets set in the original NEC Directive (2001/81/EC) and for the first time introduced targets for reductions in emissions of PM2.5. In contrast to the CAFÉ Directive, the NEC Directive aims at reducing levels of long-range air pollution and reduction in background levels of the specified pollutants. The targets set in the revised NEC Directive are to be achieved by 2030. Implementation of the revised NEC Directive is the main subject of Activity 2 of the RAS.

2.1.2 EU Sector Policies Related to Air Quality Management

The Thematic Strategy for Air Quality recognized the need for integration of issues of air quality management into strategies and policies for other sectors. Since 2005, the EU has addressed this issue as policies in other sectors have been revised.

An overarching EU Policy is Low Carbon Economy 2050 which sets targets for reductions in emissions of greenhouse gases of 40% by 2030 and 80% by 2050 against a base year of 1990. Activities in relation to air quality management need to be in line with the Low Carbon Economy policy.

In parallel, the EU has developed “Roadmap to a Resource Efficient Europe (Com (2011) 571)” which shows avenues for how Europe's economy can be transferred to being a sustainable economy by 2050.

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Emphasis is on lifecycle and value chain perspectives. All resources including raw materials, energy, water, air, land and soil are to be sustainably managed. Energy efficiency is a part of this strategy.

A key sector in relation to the air quality management is the energy sector. Reduction in energy consumption clearly has economic benefits but the energy sector is responsible for significant emissions to air that can be reduced in line with reduced energy consumption. A key document at EU level is the EU “Energy Package” which is set out in detail in Annex IV. The Energy Package includes targets in reductions of emissions to air for 2020 and for 2030. The Energy Package promotes use of renewable energy sources and increased energy efficiency. Implementation of the Energy Package can be expected to play an important role in achieving the reductions in emissions required by the revised NEC Directive, which is the subject of Activity 2 of the RAS.

The Energy Package also includes Regulation (EU) 2015/1185 setting emission standards for appliances to be used for small scale heating, including domestic heating. Implementation of this regulation provides one option for reducing emissions of PM from the residential heating sector that might be funded under PA 5 of OPE, which is the subject of RAS Activity 1.3(iii).

EU transport policy set limited targets for emissions to air to be achieved by 2020, but the goals set for 2050 are much more ambitious and include a requirement for cities to allow only electric cars. The EU transport policy is listed in Annex IV. Implementation of EU transport policy will play an important role in achieving reductions in emissions to air required by the revised NEC Directive (Activity 2 of the RAS). Early achievement of transport policy goals may also have a role to play in achieving compliance with the CAFÉ Directive (Activity 1 of RAS).

The EU policy, in relation to emissions to air, for the agriculture sector is based on the UNECE Framework Code for Good Agricultural Practice for reducing emissions of ammonia. EU agriculture policy is that Member States ensure that this code is met. The EU agriculture policy is listed in Annex IV. Implementation of the EU Agriculture Policy is vital for achieving reductions in emissions of ammonia as required by the revised NEC Directive, as according to National Emissions Inventory (NIE) 2016, the agricultural sector is responsible for 87% of emissions of ammonia. Reductions in emissions of ammonia is an important part of Activity 2 of the RAS.

In contrast to EU sector policies, current policies in Bulgaria for the transport, energy and agriculture sectors (Annex I) are insufficiently integrated with the environmental sector to achieve the reductions in emissions required to meet the targets in the revised NEC. Emissions from the industrial sector are controlled by permits issued by the ExEA and such permits should be adequate to meet the requirements of the revised NEC, but this needs to be confirmed. The ExEA also issues permits to the large combustion plants in the energy sector. Emissions from these large combustion plants need to be reviewed in line with implementation of the energy package.

The challenge for the RAS is to assist Bulgaria to integrate implementation of air quality policies with polices in the transport, energy, industry, agriculture and residential development sectors as Bulgaria moves in the direction of sustainable development.

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2.1.3 Overview of Compliance with EU Air Quality Legislation in Bulgaria With its accession to the European Union on January 1, 2007, Bulgaria made commitments to reduce emissions to air and to improve air quality, in order to meet the requirements of EU environmental legislation. In this context, the key directives needing to be addressed are the CAFÉ Directive (2008/50/ED) and the NEC Directive (2001/81/EC), revised as Directive (EU) 2016/2284 (see Table 1).

Bulgaria has achieved compliance with its national emissions ceilings set under the NEC Directive (2001/81/EC), as seen in European Environment Agency Report “NEC Directive – Status 2015”.

However, in contrast with its achievements under the NEC Directive, Bulgaria has struggled to meet the requirements of the CAFÉ Directive (2008/50/EC) and the EC instigated infringement proceedings.

The first round of infringement proceedings concerned excessive levels of SO2 in the three municipalities of Gulubovo, Dimitrovgrad and Pernik. This situation was successfully addressed through reduction of emissions from point sources, specifically reduction in SO2 emissions from thermal power plants (TPP). The reductions achieved in these cases played a role in Bulgaria fulfilling the requirements of the NEC Directive. However, there are recent indications that the situation has again deteriorated in Gulubovo.

Since that time, further infringement proceedings (Procedure for violation No 2010/2109) have been instigated by the EC in respect of levels of PM10 in 28 municipalities. The municipalities are shown in Map 1 below.

Map 1 – 28 Municipalities with Air Quality Issues

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In 2012, further EU concern was expressed about excessive levels of NOx in the case of two municipalities, Sofia and Plovdiv. However EC Decision C(2012) 6051 of 5^th September 2012 was to postpone the deadline for compliance until 31^st December 2013 since which time compliance has been achieved.

The high level of pollutants in the current infringement proceedings involve emissions from smaller individual sources such as domestic heating and vehicles, which are more challenging to manage than large point sources (that are more relevant to meeting the NEC directive). Nonetheless, the significance of this non-compliance has to be recognized in the context of the EU policy, set out above, which clearly identifies the link between air quality and human health.

2.1.4 Air Quality Management in Bulgaria

2.1.4.1 Authorities Responsible for Air Quality (Directly and Indirectly)

The legislation in the EU Clean Air Package, other than the recently revised NEC Directive, has been fully transposed into Bulgarian legislation. A number of different authorities are responsible for sections of it. The full responsibilities of the authorities directly involved and of other authorities and organizations, less immediately involved in air quality management, are set out in Annex V.

2.1.4.2 Main Legislation for Air Quality

The main primary legislation for protection of air quality is the Clean Air Act (CAA) of 1996 which has been regularly updated since then, in line with updates in EU legislation. The CAA is supported by secondary legislation, which is presented in Annex VII.

In addition to the Clean Air Act, the Environmental Protection Act of 2011 contains provisions pertinent to air quality. These are also presented in Annex VII.

2.1.5 Current Air Quality Planning in Bulgaria

In order to fulfill the monitoring requirements of the CAFÉ Directive, MOEW has divided the entire territory of the country into three agglomerations (>250,000 population) and three zones (areas delimited for the purposes of air quality assessment and management). The three agglomerations are Sofia, Plovdiv and Varna and the three zones are Northern/Danubian, Southwestern and Southeastern and shown in Map 2 below.

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Map 2 Zones and Agglomerations for Air Quality Management in Bulgaria

The EEA operates an air quality monitoring program, in line with the CAFÉ Directive, that covers the three agglomerations and the three zones. The results from this program indicate ongoing poor air quality in 28 municipalities, mainly in respect of PM10, but in the case of Sofia Municipality and Plovdiv, poor air quality was also due to high levels of NOx. In recognition of this situation, in 2012, the MOEW required the 28 municipalities¹ to prepare air quality plans in respect of PM10, with two of them, Sofia Municipality and Plovdiv, also required to include NOx.

Despite the operation of these 28 air quality plans, the situation in respect of levels of PM10 remains unsatisfactory in 28 of the municipalities. Levels of NOx have improved in both Sofia Municipality and Plovdiv and generally have been in compliance since 2014.

More recently, the MOEW, through the Managing Authority for OPE, have sought to provide funding, via PA 5 of OPE, for measures to address the situation of ongoing poor air quality. To gain greater insight as to why current AQPs have failed to meet air quality targets, the MA commissioned a study of existing municipal AQPs and the preparation of a methodology to meet the ex-ante conditionalities for PA 5 of OPE.

1 The number of municipalities that needed to prepare air quality plans corresponds to the number of such municipalities as per the text of OPE 2014-2020 at the time of OPE 2014-2020 approval in June 2015.

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The Study² of the existing AQP was entitled “Analysis of Existing Information and Data from the Municipal Ambient Air Quality Plans currently under implementation or revision, Scientific Literature, Existing Experience and others, with a view to the provision of more precise Information for the Purposes of establishing Baseline Value of Result Indicators” and the Methodology was entitled:

“Methodology for Establishment of Target and Baseline Values of the Result Indicators of Priority Axis 5 of the Operational Program Environment 2014-2020 of the Ministry of Environment and Water”³. From the analysis carried out for the MA, it was found in all cases that the AQP was prepared through the contracting of consultants by the municipality, and that the AQPs followed the Guidance prepared by MOEW (Ordinance 7 and Ordinance 12). Nonetheless, the AQPs were found to vary considerably in quality and in content. The variation in quality was especially noticeable in relation to the local emission inventories.

The source of PM10 most frequently encountered in the AQPs was domestic heating. In many cases traditional, inefficient stoves, fueled either by coal or by wood, are used for domestic heating purposes.

Generally, traffic was found to be a lesser source of PM10 with the notable exception of Sofia where NOx is implicated in the secondary formation of PM10, which accounts for approximately 50% of the PM10.

Industry was not found to be a major source of PM10, at least in terms of levels of PM10 found in urban centers. It appears that industry is usually located remote from urban centers and thus has little direct impact. Nonetheless, industry is responsible for the largest point sources of emission which are likely to impact on the background levels of PM10.

The main conclusions concerning AQPs, found in the methodology prepared for MA (p. 11), inventories are:

• based on dispersion modelling using a bottom-up approach (i.e. using local emission data;

• often not complete (not all sources are covered);

• usually not updated annually;

• not updated for all sources every time;

• not using the same methodology for all cities/municipalities.

The common approach taken in the AQPs was to assume that the emissions from sources such as domestic heating or traffic would be reduced by a percentage. The assumed reduction in emissions was then modelled to confirm that the reduction was sufficient to ensure the limit values for PM10 found in the national legislation would be met. However, in many cases, specific measures to reduce emissions e.g. upgrading of a specific number of domestic heating units, were not identified. Lack of specific measures, together with a lack of predicted impact of specific measures, made it extremely difficult for a municipality to monitor progress in implementation of its AQP. This inability to monitor progress is exacerbated in most cases by the reliance on consultants, with the municipality having insufficient

2 Authored by Assoc. Prof. D-r Iliyana Naydenova of Technical University of Sofia, dated 2015.

3 Authored by Assoc. Prof. D-r Iliyana Naydenova of Technical University of Sofia, dated 2015.

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expertise, available in house, to ensure that the AQP is both practicable and that progress can be monitored.

The Study (Para 4.3) states: “No officially accepted procedures for review and approval of the ambient air quality plans by the competent authorities were established in the Ministry of Environment and Water as of the time of the fulfilment of the assignment”.

2.2 Other Areas of National Policy Significant for Air Quality Management

Under the NEC Directive (2001/81/EC), Bulgaria is required to report annually total emissions of SO2, NOx, NH3 and NMVOCs. The report is called “Informative Inventory Report” (IIR) which accompanies the National Inventory of Emissions which is also submitted. Emissions from the main sectors, energy, transport, industry and agriculture, taken from National Inventory of Emissions 2015 (Submitted 2017), are summarized in Table 2. It should be noted that unlike the revised NEC Directive (EU) 2016/2284, NEC Directive (2001/81/EC) did not require reporting of PM2.5 emissions.

Table 2 – National Emissions as reported in National Inventory of Emissions 2015 (Submitted 2017)

Sector SO2 NOX NH3 NMVOC PM2.5

Energy 66% 24% - - 1%

Transport 1% 39% - 14% 9%

Agriculture - - 87% 24% -

Industry 22% 24% 9% 21% 8%

Total Emission in kt 142 132 34 93 29

The full list of emission sources required to be reported in the National Emissions Inventory is found in Annex II. The main sources of emissions are summarized in Table 2 and for the sake of clarity, smaller sources have not been included. Examination of Table 2 shows just how predominant the sectors energy, transport, agriculture and industry are as sources of emissions to air. This predominance is recognized by the EU. Policy integration has increased in importance and EU sector policies for energy, transport and agriculture (Annex IV) have been prepared with measures to reduce emissions to air included in the main sector policy. EU policy for industry is set by the Industrial Emissions Directive (IED) 2010/75/EU where the use of best available techniques is required for control of all emissions, including emissions to air. IED also provides for control of emissions of VOCs for many activities.

In order to reduce emissions to air, the challenge facing Bulgaria is not just to meet the requirements of the CAFÉ Directive, but also to meet the requirements of the revised NEC Directive, which requires ambitious additional longer-term measures to be applied over the period from 2016 to 2030 and beyond.

Examples of longer-term measures are improved energy efficiency and increased use of renewable energy. Both measures lead to reductions in energy use, thereby reducing emissions to air arising from combustion of fossil fuels. It should be recognized that, neither of these measures will provide an immediate reduction of PM10 emissions to air (as required by CAFÉ Directive) but over a longer period both measures will assist in achieving the targets set in the revised NEC Directive.

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Relevant Bulgarian sector strategy documents, including the Third Action Plan of Climate Change, are found in Annex 1 where key sections of the document are presented. In their current form, these national strategies appear to be insufficiently integrated with environmental sector policies to meet the requirements of the CAFÉ Directive and the revised NEC Directive. Policy integration is an issue that will be addressed in both Activity 1 and Activity 2 of the RAS.

2.3 Main Stakeholders Involved in Air Quality Management in Bulgaria

Clean air is a relatively “new topic” in the Bulgarian public domain. While at national level Bulgaria has adopted the relevant EU legislation, its implementation presents certain challenges as it requires multisector coordination with the actual implementation to be carried out at local level. This is not unique to Bulgaria, because many countries in Europe are also learning by doing.

The stakeholders for air quality management can be classified by their function into three large groups, namely:

• Stakeholders setting up the rules

• Stakeholders managing air quality and responsible for actual implementation

• Stakeholders with overseeing and enforcement role

The first group consists of four important institutions, the National Assembly, Councils in municipalities, the European Commission and European Parliament. The National Assembly is the highest authorizing authority in Bulgaria at political level, which adopts national legislation and holds weekly hearings (broadcast live on national radio and TV) of all ministers who are expected to answer questions put by MPs and to provide information about ongoing reforms and updates on current affairs.

Each bill brought to parliament is reviewed by at least one of the 17 Parliamentary Committees before being presented for voting. Usually voting is divided into two hearings.

At municipal level, the role of parliament is executed by Municipal City Councils – legislative bodies that have the right to vote local ordinances and to impose penalties. Each of the 265 municipalities in Bulgaria has a council, consisting of 11 to 61 members depending on the size of population in a given municipality.

The EU institutions and authorities and their legislative roles are not highlighted in this report, but in general they are an important stakeholder in setting EU policy and standards on air quality and monitoring implementation by Member States.

The second group consists of bodies and institutions directly responsible for air quality management.

While the MOEW, its 16 regional inspectorates, the EEA and the municipalities have been identified as the key stakeholders for air quality management, enforcement and monitoring, there are many other government bodies and agencies that have indirect responsibilities related to the topic. For example, urban planners, architects and designers at municipal level play an important role in establishing and enforcing environmental rules and regulations at local level. In Section 3 of the RAS, it is planned that a full stakeholder analysis will be carried out to establish a complete list of the actors involved directly or indirectly in air quality management. In addition to establishing a list, a mapping of the key stakeholders, setting out their interactions in such terms as “power” and “influence” will be made. In

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the meantime, an initial list of the stakeholders is now provided, with their main responsibilities being set out in Annex V.

The third group of stakeholders exercises a role of adjudication of the law. Judiciary is the main national stakeholder empowered to oversee the implementation of legislation. Bulgaria has made important progress towards the creation of an independent judiciary, especially in the development of formal arrangements separating the judiciary from the other branches of the government and giving it considerable administrative autonomy. The administration of justice in Bulgaria is based on three instances. The courts are state bodies that administer justice in civil, criminal and administrative cases.

Against the growing trend within the EU for administrative appeals to courts against municipalities for not complying with clean air requirements, the Bulgarian judiciary has a very important role to play.

Another example of stakeholders in this group comes from the civil society and environmental watchdog groups of activists. The trade unions and academia also could be seen as overseeing entities, but with a more neutral and objective voice. The stakeholder mapping planned under this RAS is expected to provide more detailed information about the stakes and holders within these three groups.

The diagram below provides an illustration of our current understanding of the key stakeholders as per the three groups:

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Civil society also performs an overseeing/policing role. The global number of registered NGOs in Bulgaria is over 40 000. In 2014 alone, there were 1446 new associations and 283 new foundations.

The two biggest trade unions in the country along with around 50 universities in the country are other important stakeholders that could play an overviewing role.

2.4 Coordination and Collaboration Platform to Support Project Implementation

Effective air quality management requires strong cooperation and engagement of all stakeholders – as outlined in paragraph 2.3. Therefore, it is considered that in addition to the inter-directorate group at MOEW, a formalized cooperation across institutions is needed to support implementation of the RAS.

This should take the form of inter-institutional (multi-stakeholder) collaboration platform(s) as proposed in paragraphs 2.4.1 and 2.4.2 to support the implementation of:

(i) Activity 1 of the RAS ‘Local Air Quality Management: achieving compliance with EU air quality legislation” and

(ii) Activity 2 of the RAS ‘National Emissions Targets: implementing requirements of the revised National Emissions Ceilings Directive”.

The main stakeholders for Activity 1 of RAS (CAFÉ Directive) are seen as being different to those involved in Activity 2 of RAS (revised NEC Directive). This difference arises because implementation of the CAFÉ Directive is mainly an operational issue, with the options for implementation being relatively well known, as the CAFÉ Directive was to be fully implemented in all Member States by 2010. The nature of the stakeholders involved in Activity 1 is expected to evolve as the RAS moves from identifying and prioritizing measures (Activity 1.3) to be selected at municipal level, towards the drafting of a Strategic Program (Activity 1.5), with such a strategy likely to require inputs from a number of ministries. These ministries have been added to the list for this coordination platform for inclusion as work in Activity progresses towards preparation of a Strategic Program.

In contrast implementation of the revised NEC Directive (to be supported under RAS Activity 2) is strategic in nature, with a need to integrate national policy across a number of areas in order to develop high levels of synergy. As the revised directive was published only recently (December 2016), until now no Member State has experience in implementation. The requirements of the revised NEC Directive are challenging and need to be met over the period 2017 to 2030 and beyond. Careful harmonization of national policies in the sectors described in paragraph 2.1 is needed in order to minimize the costs to the country and strengthen benefits to society as a whole.

The World Bank will provide support to the MOEW in establishing the collaboration platforms for Activities 1 & 2 at the start of the implementation phase of the RAS. The collaboration platforms will help with ensuring coordination and cooperation amongst various stakeholders, in addition to generating ownership for the air quality management measures to be taken. It is proposed that both collaboration platforms, are chaired by the relevant vice-minister from the MOEW; or co-chaired at the vice-minister level by MOEW and another relevant ministry (i.e., Energy or Transport). If necessary, for purposes of strengthening cooperation between stakeholders, additional support for these platforms will be requested from the GoB.

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2.4.1 Coordination and Collaboration Platform for Activity 1

The CAFÉ directive has implications for the residential, transport (private and public) and agricultural sectors all of which, based on the review of AQPs4, are known to impact on air quality at present. In addition, the industrial and energy sectors also impact on air quality, particularly in the so called

“background level” of pollution, and need to be included as appropriate in AQPs.

The initial aim of Activity 1 is to resolve the immediate issues of compliance. This means producing an updated template for AQPs for the impacted municipalities and providing assistance in identifying the optimum use that can be made of funding under the full range of OPs 2014 -2020 to resolve issues of air quality.

The longer-term aim should be to ensure the effectiveness of measures included in AQPs, to extend air quality monitoring, if this is considered necessary, and to ensure ongoing compliance with the CAFÉ legislation. This means identifying local issues that fall within the competence of municipalities to resolve and ensuring these continue to be addressed in AQPs. However, it needs to be recognized that longer-term compliance with CAFÉ also will be strongly supported when reductions in emissions are delivered in response to meeting requirements of the revised NEC Directive.

Table 3 Collaboration Platform for Activity 1

Proposed Collaboration Platform for Activity 1

Organization Key Responsibilities Role in Collaboration Platform Air Protection

Directorate MoEW

• national legislation on air quality

• providing guidance on AQ planning

• overall responsibility for air quality in Bulgaria

• Direction of Collaboration Platform

Executive

Environment Agency

• operating air quality monitoring stations

• data on air quality

• issuing integrated environmental permits

• preparing registers of VOC users and MCP

• Support to MOEW with data

Relevant* RIEWs • consulted on AQP

• control industry

• control polluters

• Support to MOEW with local knowledge

Relevant*

Municipalities

• prepare AQP

• implement AQP

• Coordination of all Municipality plans relevant to air quality

• Identification of measures for AQPs

4 Analysis of existing information and data from the Municipal Ambient Air Quality Plans currently under implementation or revision, scientific literature, existing experience and others, with a view to the provision of more precise information for the purposes of establishing baseline value of the result indicators Assoc. Prof. D-r Iliyana Ivanova Naydenova Sofia, 2015.

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• Identification of funding for AQPs National Statistics

Institute

• estimate national statistics on emissions of pollutants to air

• Provision of relevant data

Ministry of Regional Development and Public Works

• OP regions in Growth – funding:

• Insulation of buildings (public and private)

• New vehicles for public sector

• Greening of city centers

• Improved infrastructure including roads, walkways, cycle tracks etc.

• Coordination of measures under OP RG to support air quality measures

Ministry of Health • health impacts of air quality • Support development of AQPs with health data

Relevant* Health RIs • consulted on AQPs • Support development of AQPs with health data

Ministry of Labor and Social Policy

• winter heating assistance scheme

• Ensure winter heating assistance scheme supports AQP

Relevant* Traffic Police

• data on vehicles and vehicle movements

• Provision of relevant data Relevant* Public

Transport Operators

• data on public transport vehicles

• Provision of relevant data Relevant* District

Heating Operator

• data on district heating usage • Promote expansion of existing systems

• Develop public support for district heating

• Provision of relevant data National Association

of Municipalities in Republic of Bulgaria

• information on municipalities

• Provide organizational support for municipalities

• Ensure exchange of information Bulgarian Association

of Municipal

Environmental Experts

• environmental experts in municipalities

• Provide exchange of information between experts

Civil Society Organisations if considered appropriate

• Ensure the views of the public are taken into consideration

Ministry of Agriculture • control of agriculture activities

• Identify measures for improved control of burning of agricultural waste

Ministry of Economy • OP Innovation and Competiveness

• Coordination of measures under OP IC to support achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the

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new upcoming emission caps and with the achievement of air quality targets Ministry of Finance • Control of national funds • Ensure that where central financing of

measures to reduce emissions to air is needed that it is not unduly withheld Ministry of Interior • Control of vehicle

inspection and movements

• Promote improved control of vehicle maintenance and vehicle movements National Institute for

Metrology and Hydrology of

Bulgarian Academy of Science

• Weather forecasting • Provide metrological data and assist in the forecasting of potential air

pollution events

*Relevant = from a municipality experiencing poor air quality

2.4.2 Coordination and Collaboration Platform for Activity 2

The revised NEC Directive has been under development since the Gothenburg Protocol was revised in 2012. The EU has increasingly revised its sector policies in the energy, transport and agriculture to be in line with its environmental policy, and in particular to enable implementation the revised NEC. The EU legislation controlling emissions from industry and controlling waste has been revised and updated, again in line with reducing emissions to air.

Meeting the requirements of the revised NEC Directive (target date of 2030) will impact on most economic sectors and require measures that go beyond improvement of “business as usual” measures.

The key sectors are those in which large quantities of fossil fuel is burnt, namely the energy and transport sectors. The EU Energy Package and the EU Policy on Transport are to found in Annex IV.

Industry is required to operate to BAT under the IED and expected to make greater use of renewable energy as the EU Energy Package is implemented. The legislation on Medium Combustion Plant Directive (EU) 2015/2193 is coming into force and is expected to be implemented over the coming years.

In the waste sector, moves away from landfill will be continued as a “zero waste” society is developed following the EU “Circular Economy Package” of 2014.

The agriculture sector is expected to follow the EU policy on agriculture, which is focused on use of good agricultural practice aimed at reducing emissions of NH3.

Many of the main policies needed for implementation of the revised NEC Directive have been set is sector policies at EU level. The speed at which these policies are adapted for Bulgaria and the balance between these policies are issues to be discussed between the stakeholders in order to minimize the cost of compliance and to maximize the benefits to society as a whole.

The proposed coordination mechanism for Activity 2 is set out below but other stakeholders will need to be involved at least from time to time.

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Table 4 Collaboration Platform for Activity 2

Proposed Collaboration Platform for Activity 2

Organization Key Responsibilities Role in Collaboration Platform Air Protection

Directorate, MoEW

• national legislation for limiting emissions from static and mobile sources

• overall implementation of revised NEC Directive

• Leadership of Collaboration Platform (supported by Minister/Deputy Minister and if necessary Government of

Bulgaria) Climate Change

Directorate, MOEW

• National Policy on Climate Change Mitigation

• Enhancing synergy between climate change and air quality policies Preventative Activity

Directorate, MoEW

• EIA for infrastructure

• integration of

environmental policies

• Facilitate EIA for infrastructure required for achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets

• Ensure EIA in general supports achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets

Ministry of Energy • implementation of energy package

• overall energy policy

• Ensure energy policy is fully aligned with/for achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets

• Ensure no developments in the energy sector run contrary to achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets Ministry of Agriculture

and Foods

• implementation of EU agriculture policy

• control of biomass

• control of Rural

Development Program for Bulgaria

• quality of equipment imported

• Ensure energy policy is fully aligned with/for achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets

• Ensure that good agricultural practice in line with EU policy is followed by all in the agricultural sector contrary in line with/for achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new

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upcoming emission caps and with the achievement of air quality targets Ministry of Transport,

Information Technology and Communications

• implementation of EU transport policy

• Ensure transport policy is fully aligned with with/for achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets

• Ensure no developments in the transport sector run contrary to achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets Ministry of Economy • implementation of EU

economic policy

• quality of vehicles imported

• quality of fuels on the market

• control of OP Innovation and Competitiveness

• Ensure full compliance of the economic policy with achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets

• Ensure only vehicles and equipment meeting the latest EU quality standards are imported

• Ensure all liquid fuels sold meet the EU standards

• Coordination of measures under OP IC to support achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets Ministry Labor and

Social Policy

• control of winter fuel supplement

• Ensure winter heating assistance scheme supports AQP

Ministry of Regional Development and Public Works

• control of OP Regions in Growth

• Coordination and promotion of measures under OP RG to support air quality measures

Ministry of Education and Science

• control of OP Science and Education for Smart Growth

• Coordination of measures under OP SESG to support air quality measures Ministry of Finance • control of overall national

investment

• Ensure that financing of measures required for achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new upcoming emission caps and with the achievement of air quality targets is not unduly hindered

Ministry of Interior • control of traffic police

• control of vehicles • Assisting achievement of the targets relating to harmful emissions into the atmosphere, pursuant to the new

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upcoming emission caps and with the achievement of air quality targets by thorough enforcement of controls on vehicle quality

Energy and Water Regulatory Commission

• cost of energy • Ensure thorough and appropriate control of providers of district heating

Executive Environment Agency

• preparation of National Inventory of Emissions and the Informative Inventory Report

• data on air quality

• Provision of data to allow measurement of progress towards meeting air quality targets

National Statistics Institute

• holds national data relevant for preparation of National Inventory of Emissions

• Assist Executive Environment Agency in providing data needed to prepare National Inventory of Emissions National Association of

Municipalities in Republic of Bulgaria

• represent municipalities • Provide data/information on activities of municipalities towards meeting the air quality targets

Civil Society Organisations if considered appropriate

• can provide alternative views on implementation

• Ensure that the concerns of the public are taken into consideration

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3 Program Objectives and Results

3.1 Objectives

The main objective of the Agreement for advisory services ("Agreement") is to support the MOEW, in providing inputs to the development of strategic programs for local air quality management in order to satisfy the requirements of EU air quality legislation and meeting the air pollution emission targets in the context of the EU Clean Air Policy Package. The Agreement is also expected to contribute to the:

• Improvement of air quality management through identification of opportunities for enhanced dialogue and cooperation between key parties.

• Identify synergies between different national strategies in order to reduce the cost of achieving national emissions targets.

• Strengthening the regulatory capacity of the relevant competent authorities in order to improve control of emissions to atmosphere. Three activities have been planned for the RAS:

o Activity 1 - Local Air Quality Management – achieving compliance with EU air quality legislation

o Activity 2 - National Emissions Targets: implementing requirements of the revised National Emissions Ceilings (NEC) Directive

o Activity 3 - Institutional Coordination and Engagement

The success of the program to achieve the common objectives will be monitored through the timely delivery of the deliverables found in Table 3.

3.2 Deliverables

The deliverables of the program and the dates for their delivery are presented in Table 3 and are aligned with the Schedule to the Agreement on Advisory Services, taking into account the effectiveness of the Agreement. The Activities that lead to the achievement of these results are described in Chapter 4.

Table 5 - Deliverables and Dates

Deliverables Implementation

Timeline 0 Inception report, which includes a review of the description of the

working methodology on various tasks

February 28, 2017

1 Proposed Communications Plan March 28, 2017

2 Preliminary Report on Activity 1.3 March 28, 2017

3 Final Measures Report August 28, 2017

4 Strategic Plan under Activity 1.5 March 28, 2018

5 Sectoral Measures under Activity 2.4 June 28, 2018

6 National Program under Activity 2.5 February 28, 2019

7 Report on Capacity Building under activity 3.4 October 28, 2019

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3.3 Summary of Risks and Risk Mitigation Measures

The table below summarizes the key risks and risk mitigation measures relevant to this program.

Table 6 - Summary of risks and risk mitigation measures

Risk area Risk level Description of risk and

explanation of risk level Risk mitigation measures

Assessment of residual

risk 1. Overall risk for achieving the national emission targets

Ability of the

Government to ensure coordination of policies in the key areas of sustainability, climate change, energy including renewable energy, transport, agriculture, forestry, social housing and environmental protection

Significant Reducing emissions to atmosphere requires effective coordination of policies across a number of ministries

Involvement of a range of ministries is necessary and policies to be well coordinated and finally, enforced. The project team proposed to the government a coordination and collaboration platform involving all key authorities in development and coordination of the proposed policy measures. Strong support from the Government is required to coordinate the actions of line ministries to assist the client (MOEW) to meet the commitments entered into by Bulgaria in the field of air quality.

Medium

Ability to include all parts of the population in resolution of issues of poor air quality

High Meeting the air quality standards requires changes in behavior in some of the more disadvantaged parts of society, particularly in relation to domestic heating.

Meetings of housing and energy ministries at national level together with the housing/planning departments of municipalities and societal representatives will be held regularly The project communication component is designed in a way to support the government in addressing behavior and perception issues through better communication and capacity building at local level.

Medium

2. Specific risks associated with the implementation of the tasks Human resource

capacity of the Client

Medium

The Air Protection Directorate within the MOEW is the direct beneficiary of the activities. The Directorate has the necessary

This current project will support the Air

Protection Directorate in the MOEW in their task of fulfilling the requirements of the EU air quality legislation and will seek to build capacity through

Medium

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Risk area Risk level Description of risk and

explanation of risk level Risk mitigation measures

Assessment of residual

risk capacity, but the staff is

overloaded.

promoting and supporting improved

communication between different institutions.

Recommendations are not accepted

High

Many of the reductions in emissions to air will require significant changes of behavior in some of the more socially

disadvantaged parts of society.

Behavior change remains challenging.

Awareness raising and involvement of

stakeholders and representatives in the process of planning such improvements will be supported

under the project. Medium

Coordination with public sector stakeholders

High

At present limited cooperation between line ministries appears to be common place. Coordination of a range of major national strategies is considered vital to improve effectiveness of implementation and to avoid unnecessary costs. Inadequate coordination may create additional emissions and sub- optimal investment.

Improved collaboration and coordination amongst public sector institutions is required. Regular meetings between stakeholders are planned as part of the RAS. Such meetings will be more effective if supported by Government and chaired at least at Deputy Minister level. The proposed coordination and collaboration platforms in the form of

working groups would help address this risk.

Medium

Access to information

Medium

Current levels of inventory information available for local level use are far from adequate to allow good air quality

management planning at local level.

The collection of data at local level will be discussed with a view to improving commonality of approach and for downsizing of data from national level The RAS will support strengthening the procedures for preparing local inventories.

Low

Implementation of PA 5 OPE

Medium

The MA has worked with the World Bank in the development of methodology and indicators but commitment of the

municipalities to prepare appropriate projects is not clear

The team will work in close collaboration with MA and municipalities to encourage development of projects

Medium

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4 Work Plan

This Chapter provides information on planned activities to achieve a specific objective and produce the agreed results. The Chapter is organized by components related to the results, in the manner specified in the Agreement on advisory services, with some clarifications as explained below.

4.1 Coordination Committee

A Coordination Committee (Activity 3.2) is planned to ensure effective operation of the RAS. In parallel collaboration platforms (Activities 1.3 & 2.3) are planned to discuss and coordinate specific technical issues. The Coordination Committee will represent the client and will include at least a representative of the Air Protection Directorate and the MA and will be chaired by the Deputy Minister having responsibility for air quality. The coordination committee is responsible for checking timely delivery of the RAS.

4.2 Initial Activities to Prepare for Project Implementation

The first activities concerned the setting up of the initial implementation team and the establishment of an office for the RAS. This work was completed prior to the formal approval of the RAS on December 28, 2016. The inception workshop is planned to be held on March 1, 2017 with an invitation to all the stakeholders outlined in this report. The activities planned for the RAS are presented below in this section of report and will be presented to the stakeholders at the workshop.

4.3 RAS Activity 0 - Implementation of PA 5 of OPE 2014-2020

The MA requested the Bank to support the implementation of PA5 of OPE by proposing a methodology for implementation of PA 5 of OPE 2014 – 2020. While fitting in the framework of activity 1, the work on this methodology was launched few months before project effectiveness, to help the MA fit within the timeframe for complying with an ex-ante conditionality for OPE, set by the EC. The World Bank input to this will be a proposed methodological framework based on review of a work previously carried out for MA, and take into account the comments made by Peer Review of this previous work, further developing the approach and methodology for determining the baseline and target indicators for PA5.

Following from this work, the RAS team would assist the preparation of emission inventories for the domestic heating and public transport sectors for 28 municipalities, which could be used according to the proposed methodology to calculate the baseline and target indicators for PA5 of OPE. Furthermore, a framework for selection of measures to be supported by PA5 will also be proposed. The preliminary report will be delivered by end March 2017 (Activity 1.3 (iii)).

4.4 RAS Activity 1 - Implementation of CAFÉ Directive

Activity 1 is concerned with implementation of the CAFÉ Directive and consists of five sub-activities, set out below. It is planned that this work will be carried out between January 2017 and March 2018, with delivery dates shown in Paragraph 5 below.

1.1 Review of Administrative and Technical Baseline 1.2 Analyze the State of Non-compliance and Compliance

ADVISORY PROGRAM FOR SUPPORT FOR AIR QUALITY MANAGEMENT