Heating, heat meters, building installation… What do the institutions tell us, what does the EU think, how is it in our country… Dimitar Todorov, an energy expert, speaks in front of FACTI.
- Mr. Todorov, in many letters and complaints to various institutions in our country you claim that the heat allocators used by the companies for share distribution and district heating to determine the energy consumed for heating are illegal. Can you justify this?
- The justification for this claim is seen from the following:
1. Heat allocators are used in accordance with the European Directive 2012/27 EU on energy efficiency. For their use for the purpose of energy distribution, a standard BDS EN 834 was created. This standard states the following: “It is necessary to determine this total heat consumed by measuring the required amount of fuel or the amount of heat supplied (the latter by means of a heat meter, for example).”
It is immediately apparent that district heating companies use these distributors without measuring the heat energy for distribution.
It is calculated because, in order to arrive at the energy to be distributed, the following must be subtracted from the readings of the total heat meter in the subscriber station:
a) the technological costs of energy in the subscriber station, which are calculated according to the formula (item 4.1. of the Methodology for the share distribution of heat energy in buildings - condominiums);
b) the amount of heat energy for domestic hot water supply (DHW), which is determined by calculation according to Art. 5 of the Methodology;
c) the amount of heat energy for the building installation, which is determined by calculation, according to the formula from the Methodology, item 6.1.1.
2. The violation of the Measurements Act is also obvious. In Art. 3 of this Act it is written: “In the Republic of Bulgaria only units permitted by this Act are used.” And in Art. 11, para. 1 it is written: “Units of measurement permitted for use are the units of the International System of Units (SI), units used with the International System of Units, and their component units.” In Para. 2 of the same Article it is said: “The units under Para. 1 are used for the measuring instruments and for the results of the measurements performed.”
In a letter of the National Assembly, ref. No. PG-2194-D-123/04.12.2012, the chairman of the parliamentary committee in the 41st National Assembly on economic policy, energy and tourism Martin Dimitrov writes: “…individual distributors are not defined as commercial metering devices, and unlike individual heat meters, they do not measure absolute values, but relative ones and therefore do not have an indicator for a specific physical quantity.” Note, this is said by a legislator who uses the word “relative” and with a magnifying glass he cannot find it in the Measurements Act.
This same legislator does not answer the questions:
a) Where is the laboratory for testing heat allocators located?
b) By what standard can one check whether a heat allocator is upright and shows correctly?
3. In order to use the same allocators for energy metering with radiators of different types, sizes and numbers of fins, the installer introduces coefficients into them according to special tables. Isn't human intervention in determining the heat allocator readings a prerequisite for corruption?
The Bulgarian Institute of Metrology claims on its website, in the "Questions and Answers" section, that it does not deal with heat allocators because they are not measuring devices. They cannot be checked and compared with a standard.
This is quite enough to show that the distributors distribute some calculated energy, not measured, and that the standard and laws are not respected. What rule of law are we talking about?
- You write, write, but do you have any answer?
- The signal was sent to the Energy Committee of the 51st National Assembly with entry No. PG-51-5194-D-21/07.02.2025, to the Bulgarian National Television, BNT News with entry No. 10-01-362/07.02.2025, to the Civil Platform “Stand Up.BG“ with entry No. 001/07.02.2025. I have not received a response from any of these institutions. I also sent it by email to the Ombudsman of the Republic of Bulgaria, Velislava Delcheva. The answer was that there was no better alternative for now, without giving an opinion on the legality of the distributors.
- You claim that the distributors were put into use on the basis of a European Directive and the Energy Act. Why are they illegal?
- You are absolutely right, but there is a contradiction in the laws here. It was created by the deputies in the National Assembly. I have already pointed out that the Energy Act contradicts the Measurements Act and that the requirements of the standard are not met. This contradiction deepened even further when the Energy Act obliged all subscribers of district heating companies to replace their distributors with those with remote reading. This law transposed Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 amending Directive 2012/27/EU on energy efficiency. In Art. 140, para. 7 of the Energy Act states that the heat distributors and water meters, which almost everyone has, must gradually be rebuilt or new ones purchased and installed with remote reading by 01.01.2027.
Replacing the currently existing distributors and water meters for hot water with those with remote reading means huge costs for subscribers.
Your colleagues have already published data from a report by the Ombudsman of the Republic of Bulgaria Diana Kovacheva, which shows that “the transition from devices with visual reading to devices with remote reading will cost household customers over 100 million leva for the period 2021-2026”. According to Ombudsman Diana Kovacheva, 572 thousand households must replace their distributors and water meters with new ones with remote reading by January 1, 2027.
According to her, this involves about 1.276 million radiator distributors and 660 thousand hot water meters, and nearly 93% of these devices are owned by household customers and their replacement is entirely at their expense.
Please note that all these millions will flow out of the pockets of subscribers for some illegal, absolutely useless means of distributing heat energy.
To be continued…