Ecological association "For the Earth" with serious criticism of the low emission zones in Sofia

The proposed low emission zones are unambitious, poorly justified and crafted without extensive public debate. In this form, "For the Earth" does not support their introduction and calls for the postponement of its planned July 21 adoption by the Metropolitan Municipal Council until the fall, with the municipality using the time until then to actually consult with the citizens and eliminate the weaknesses in the current proposal. This was commented on today by "For the Earth" in its statement. On June 16, the Metropolitan Municipality announced a public consultation on its draft Ordinance on the creation of zones with low emissions of harmful substances and the reduction of sources of atmospheric air pollution on the territory of the municipality. The consultation ended on 18 June.

We will limit burning from stoves… where there are no stoves

The zone with low emissions in terms of domestic combustion will cover only 9 more central areas of Sofia from 2025, in which stoves ceased to be a mass phenomenon long ago, and the most polluted and polluting neighborhoods remain unaffected. In practice, in the first stage, restrictions will be imposed on a very modest 5.5% of the total 54,611 polluting households in the city (SO uses NSI data from 2011). According to the statements of the municipality, we can expect an effect of only 72 tons per year of reduction of FPCH10 emissions, compared to the total amount of 2,262 t/year of FPCH10, which are emitted into the atmosphere from the stoves in winter. Or, to put it briefly, we will optimistically limit pollution from burning in the city by 3.18%.

Ivaylo Khlebarov from For the Earth commented: "The ban on the use of solid fuels for heating from 01.01.2025 affects only buildings on streets or in places with a built and functioning central heating and/or gas distribution network. It's as if SO forgot that there is heating with electricity, which can also be more profitable than that of thermal power plants or fossil gas. The de facto significant reduction in pollution is postponed by GERB until after 2030 – 6 years after the deadline set in the National Air Quality Program, 13 years after the first judgment by the European Court and 9 years after citizens condemned the CO for inaction regarding air quality. This is nonsense!'

Sofia - European capital of britches 2030

The introduction of a Zone with low emissions from transport in Sofia is the other main measure included in the Ordinance.

It will only work for a period of 3 months from the beginning of December to the end of February. The decision apparently does not take into account nitrogen dioxide (NO2) pollution from cars, which research by For the Earth has clearly shown can be reported throughout the city year-round, not just during the three winter months.

It will cover two areas - a small and a large ring - located in the central part of the city. Since the zones occupy a relatively small share of the territory of Sofia, there is a danger that the total volume of emissions will remain unchanged. The municipality's own surveys show that the majority of drivers (70%) consider continuing to drive their cars, bypassing the zone (as it is too small, it will not discourage people from driving).

It is likely that traffic and air pollution will shift along the boundaries of the rings mainly at the expense of those who live and work there - similar to what happened with the introduction of paid parking zones. Traffic outside the proposed rings has not been studied and there is no way to assess whether this redistribution of emissions would have a net positive or negative effect on the city.

Even more dubious appear to be the rules regarding the categories of cars covered and the stages of introducing restrictions for them. They are such that only the oldest vehicles will always be affected. Even with the introduction of the "strictest" measures in 2028 in the so-called big ring will continue to have the right to enter diesel cars manufactured after 2007, and gasoline cars - after 1998. It is important to ask ourselves how many 30-year-old cars will really be in motion and regularly enter the central part of the city?! Even in the relatively modest area of ​​the small ring, which covers only the so-called "Ideal center" of Sofia, and after 2028 it will be possible to drive diesel cars at 18 years old.

Dragomira Raeva from For the Earth commented, "With these half-hearted measures, the Metropolitan Municipality risks making the introduction of a Zone with low emissions from transport in the city meaningless." If it does not achieve an effect, it would turn a significant part of society against such a useful and proven practice in many European capitals. Modern management of transport needs in large (but not only) European cities focuses on limiting the use of the private car with attractive incentives to choose alternatives in the form of public transport, walking, cycling and carpooling. We see no such approach and such a vision is reflected in the Ordinance on PPE from transport."

A hasty decision with potentially very negative results

According to "For the Earth", to a large extent these problems, in addition to the reluctance of Mayor Fandakova to take effective measures, are also largely due to the gaps in the process of creating the legal basis for it. According to the association, this process is extremely important because it predetermines both the quality of the measures themselves and the acceptance of the subsequent restrictions by society. Therefore, it had to be accessible and public - with a public debate preceding the Ordinance. Thus, it would be the natural legal form of the consensus understanding of what the zone should be - temporally and spatially, at what stages of introduction and under what conditions. Such a conversation and process did not take place, despite the organization's attempts since 2021 to convince the leadership of the Metropolitan Municipality of the need for a clear, open and inclusive process.

"For the Earth" commented, "Besides a real public debate, the analytical base to defend a given vision of a low-emissions zone is also missing. We currently have a draft ordinance and fragmentary analyses. Therefore, we cannot say what the purpose of the Ordinance is, what will be achieved with the measures in it, whether these are the best measures in relation to the financial resources, technical possibility and minimal interference in the freedoms of citizens to realize the goals. An approach that deprives us of any predictability and portends tepid public support for the Ordinance. It is possible that it may even fall on appeal to the courts because of these vices.''

With their Opinion, "For the Earth" insists that the vote on the Ordinance be postponed until the fall, until then serious efforts are made to remove, if not all, then at least most of the gaps.