At the end of 2025, the Supreme Administrative Court (SAC), and subsequently the European Court in Luxembourg, repealed the formula for the building installation from the Heat Supply Regulation, as opaque and not allowing for accurate reporting of the individual consumption of each household. However, this regulation and its methodology still contain opaque, inaccurate and incomprehensible formulations. What are they... Energy expert Dimitar Todorov speaks to FAKTI.
- Mr. Todorov, there are still opaque, inaccurate and incomprehensible formulations in the methodology for reporting individual heating consumption. Should the court rule on them too?
- To date, it is not possible to understand how the energy value of the share units is determined. How long will we tolerate the wrong equalization bills for heating? This is very important, because it determines the heating bills. This energy value, multiplied by the number of units from the distributor on the radiator, determines the energy consumed by it. On this occasion, I wrote a letter to the share allocation company “Techem Services“ EOOD, entry No. 25101886/15.12.2025, asking for an answer to the following question: “In the equalization bill, under “Distribution of expenses“ the energy for “Heating of property“ is written. In this energy, in addition to the energy from the radiators, is the energy from the risers included, since they are considered, according to the heat supply regulation, heating devices? I took the liberty of writing them two answers in the letter, which I was thinking about:
1. If the energy from the risers is not included in the total heating energy, then the power of the risers is included in the formula for calculating the energy from the building installation (SI). This means that the energy from the risers is paid twice - once to the SI and a second time to heat the properties.
2. If the energy from the risers is included in the “heating of a property for a condominium building (CEC)“, then the determination of the energy of one share unit is not correct, because only the radiators have distributors. The units of the radiators should reflect only the energy released by the radiators.
- And the answer was…
- It is necessary to explain why my question is completely reasonable. It is known that the units of the distributors are relative and if the energy that they distribute is not known, their energy value will not be known.
I received a response from “Techem“ in a letter ref. No. 25101886/15.01.26 that THE STRANG-LIRES, ACCORDING TO THE REGULATION, ARE ATTACHED TO UNITS OF THE EQUIPMENT and they, together with the units of the radiators, form the total sum of units of the units.
I quote from the letter: “The value for 1 unit in kWh. is defined as the total amount of heating energy divided by the sum of the units reported for individual radiator devices in all properties, including the officially charged units for heating units without devices“.
- Officially charged units mean…
- The very fact that there are “charged official units“ is terrifying. This means that the radiator units do not reflect only the energy of the radiators, but also some other energy, of which no owner has any idea how much it is in quantity.
What is being done on the basis of the heat supply regulation and the methodology to it fundamentally contradicts the requirements of item 1 “Object and scope“ of the BDS/EN 834 standard for the use of distributors. Two different consumer groups cannot be mixed (item 3.6 of the standard). One user group consists of all radiators with distributors, and the other user group is all risers that do not have distributors.
- Do you see any way out of this, to put it mildly, mistaken situation?
- Apart from the fact that distributors are illegal, for which I provided a number of evidence in a previous interview with you, I will say that a way out can be sought. But I do not say whether it will be found. At the end of the BDS/EN 834 standard there is Annex A.4 “Heat loss not controllable by the user“. It is written there: “The heat output from the pipes that pass through the consumer cannot be controlled by the consumer (forced heat consumption) and must be taken into account in the consumption-based pricing if the share of heat output from the pipes significantly affects the accuracy of the distribution ([7] ,[8], [9])“. The literature used is in German.
- Now it remains to have someone translate…
- This means that the Ministry of Energy and the share allocation companies must make an effort to translate the mentioned literature into Bulgarian, read and understand it, and then publish the most important excerpts that shed light on the problem. Only then will it be possible to claim that the current method, by assigning share units to the risers, using the maximum specific building consumption (MSPC) and the capacities at design temperatures, is correct. Otherwise, everything written in the equalization accounts is wrong.