Bulgaria Most of the distributed solar projects are not true pro­sumer projects, however, as Bulgaria’s legal framework is not fully developed in this field yet. The bulk of the distrib­uted solar photovoltaic market in Bulgaria is made up of installations smaller than 30 kW which receive feed-in tar­iffs. A total of 1,777 such installations were connected to the grid between 2008 and 2020, amounting to 43 MW. 139 No data is available on how many solar photovoltaic sys­tems are installed purely for self-consumption, not con­nected to the distribution system. However, anecdotal evi­dence suggests a growing number of companies have shown interest in such systems since 2018 – which would make sense as such customers have had to move to mar­ket-based prices instead of regulated ones. Interviews with commercial customers who have installed such systems suggest that they expect a payback time of five to seven years under the 2019-2020 market conditions. 140 Nevertheless, additional financing for households is still needed in order to make rooftop solar systems afforda­ble. PUBLIC PARTICIPATION IN DECISION-­MAKING ON ENERGY POLICY AND INFRASTRUCTURE As an EU country, Bulgaria has to apply the full range of legislation which enables public participation in environ­mental decision-making, including the EIA, SEA, Water Framework and Habitats Directives. It also has an active en­vironmental civil society. However, as decision-making is highly influenced by corruption and state capture, as well as geopolitics, 141 public participation has a limited impact on the actual decisions made. As a result, Bulgaria is home to some very long-running public environmental campaigns such as the battle to keep the Kresna motorway out of a valuable natural gorge south of Sofia and the campaign to prevent the Belene nuclear power plant being built in a seismically active area in north­ern Bulgaria, both of which have lasted on and off for dec­ades. RECOMMENDATIONS AND NEXT STEPS Heavily energy intensive and fossil-fuel-dependent, Bulgar­ia needs to focus on energy efficiency measures, particu­larly good quality building renovations. This must include a plan on what to do about buildings built without permits, as these usually fall outside of renovation schemes but house the most vulnerable people. Energy poverty needs to be addressed much more actively, with concrete meas­ures and a data collection and monitoring system put in place. Bulgaria needs to actively plan a fossil fuel phase-out and revitalise a phase-in of sustainable forms of renewable en­ergy. Instead of presenting energy transition as a burden, its opportunities need to be emphasised to the public. One important element to enable the inclusion of house­holds is to systematically reduce administrative barriers, fees such as excise tax, and surcharges on small and medi­um-sized solar photovoltaic systems, make it easier to con­nect to the grid and export the surplus electricity. This re­quires a comprehensive policy and regulatory environment to catalyse investments in line with the EU Renewable En­ergy Directive’s provisions on prosumers. 142 The EU funds available for just transition need to be used to build a just and climate-resilient society, based on a more realistic and time-bound plan for a coal phase-out. This will need more initiative by local actors and the state to deliver an inclusive energy transition through a strong political commitment involving different stakeholders, including trade unions and local communities. Such plans need to be built from the bottom up. Such efforts must go hand in hand with continued improve­ment of public participation in decision-making, tackling corruption and applying EU law, which go far beyond the energy sector. Only this way can the energy transition suc­ceed. Bulgaria’s membership in the EU at least means that the Eu­ropean Commission can open infringement procedures which can result in fines for the country. This provides some incentive to comply with EU law, but often after the fact, meaning that public participation is frequently still on the level of firefighting rather than creating policy. 139 Toby D. Couture, Toma Pavlov and Teodora Stoyanova, Scaling-up Distributed Solar PV in Bulgaria. 140 Toby D. Couture, Toma Pavlov and Teodora Stoyanova, Scaling-up Distributed Solar PV in Bulgaria. 141 Pippa Gallop, Emily Gray, Elena Nikolovska, Alexandru Musta ță , and Raluca Petcu, PEET The Political Economy of Energy Transition in Southeast Europe – Barriers and Obstacles. 142 Based on recommendations from Toby D. Couture, Toma Pavlov and Teodora Stoyanova, Scaling-up Distributed Solar PV in Bulgaria. 29