The changes to the Regulation on Heat Supply were supposed to put an end to the long-standing dispute over the so-called "building installation". Instead, however, they are reigniting the tension. What is wrong again... Energy expert Dimitar Todorov speaks to FACTI.
- Mr. Todorov, the Ministry of Energy has published for public discussion changes to the Regulation on Heat Supply, which should fill the legal vacuum after the cancellation of the old formula for "building installation" (SI). In your opinion, does this new mechanism really solve the problem or simply reformulate it?
- After reviewing the draft Regulation on Amendments and Supplements to Regulation No. E-RD-04-1 of 2020 on heat supply, which the Ministry of Energy presents for discussion, a significant flaw is immediately noticeable - the formula itself is not written. It is not shown what it looks like. I assume that it is not written because the changes are in the draft regulation, and the formula is in the methodology for it. Thus, it remains hidden. But, as far as can be seen from the “new mechanism”, the formula remains the same as the old one. It is written in words what factors are included in the formula. They are the same as the factors in the old formula. There is no difference. That is why the problem is not being solved and is not being reformulated. The Ministry of Energy continues to mock heating consumers, and together with them the Bulgarian and European courts, as was done when the regulation was created in 2020.
- Minister Traykov claims that the new model will take into account the interests of both people who use heating and to those who have turned off the radiators. Is such a balance possible in practice in the same building?
- Minister Traykov probably does not know that there is no new model. There can be no talk of any balancing. His employees have misled him. He himself stated in a television interview that for the energy from the building installation it is best to determine a percentage of the heating energy. Asked what the percentage should be, he replied that it should be “20 and a few“. This means that until now he was not familiar with the changes in the regulation. He does not know that the draft amendments talk about a formula and the factors that are included in it. It is unacceptable for a minister not to know what pitfalls his employees are preparing for him and to expose himself on air. He does not give any justification for these “20 and a few“ percentages.
Then there is a discussion about how the heating bills will be paid when there is still no formula for the building installation. The respected energy expert Elenko Bozhkov said that “a multi-layered formula is difficult to apply and therefore it is more reasonable to calculate the building installation as a percentage of the total heat energy consumption in the building“. As can be seen, this respected energy expert also says that it is best to determine a percentage. There are some inaccuracies in his interview. He did not say what percentage he meant and should not have said “the total heat energy consumption in the building“. The correct one is “the total heating consumption“, as recorded in the balancing accounts.
The words of these famous figures in the energy industry are enough to say that drawing up a new formula is a move in the wrong direction.
- The project envisages that the amount of heat energy for a building installation will be determined by a complex mechanism – with factors such as installed capacity, heating period, outdoor temperature, energy class of the building and climate zone. Does this make the system fairer or does it make it even more incomprehensible to consumers?
- As I have already said, this complex mechanism contains the same factors as exist in the current formula. Nothing new. The same old formula is proposed, which was canceled by the court precisely because it is unfair and incomprehensible. We need to go down a new path. With a letter inv. No. E-94-00-128/26.01.2026 to the former Minister of Energy Zhecho Stankov, to which I have not received a response so far, I made a proposal for a formula for calculating energy from SI, for which I provide justification.
In Art. 10, item 1 of Directive 2012/27 it is written “the billing information shall be accurate and based on actual consumption“. In Art. 155, para. 2 of the Energy Act it is also written that “the heat transfer company or the heat supplier shall invoice the consumed amount of heat energy based on actual consumption at least once a year“. That is, it is stated very clearly that actual consumption must be invoiced.
In unison with these two documents, it can be said that the energy for heating the condominium, written in the equalization accounts, is indeed actual consumption. It is obtained by subtracting the energy for technological costs in the subscriber station and the energy for hot water from the total energy consumption for the facility (according to the readings of the heat meter in the subscriber station, which is a commercial device). The resulting energy for heating can be considered actual. (I say “can be considered“ because the energy for hot water is not measured, but calculated). Multiplying this energy by 0.15, we will obtain the SI energy. The formula I propose looks like this:
Qси = 0.15 Qот
where:
Qси = the energy of the building installation;
Qот = the heating energy from the equalization account;
0.15 = coefficient indicating the share of the energy of the building installation in relation to the heating energy from the equalization account.
Simple, clear, accurate, understandable, accessible and transparent formula!
The coefficient 0.15 is also present in the previous methodology to Regulation 16-334/06.04.2007 on heat supply, it is also present in the current methodology to Regulation E-RD-04-1/12.03.2020, it is also present in item 5.1.1. of the rules for share distribution in Regulation No. 2 of 28.05.2004 on heat supply. And in the Energy and Energy Efficiency Act of 2004 in §69 para.3 it is written “The part of the heat energy given off by the building installation within the meaning of Art. 112c, para. 2, is determined at the rate of 10 percent of the total amount of heat energy for heating the building“. As can be seen, a lower percentage was also proposed.
These documents show that 15% is a real percentage, discussed by many energy specialists, experts, specialists in the Ministry of Energy, even MPs, it has been adopted and applied for 25 years, which gives full reason to use it in calculating the energy from SI. This is the formula.
- According to the new rules, condominiums will continue to be able to choose a percentage for building installations between 20 and 40%. Is this enough freedom for people, or does it actually create new conflicts between neighbors?
- These percentages now exist in Art. 63, para. 2, item 2, letter gg of Regulation No. E-RD-04-01 on heat supply. But, note, only as a possibility, if an agreement is reached on a certain percentage at the General Assembly of the condominium. They were determined by statistical processing of the results for the energy of the building installations, taken from a representative sample of equalization accounts throughout the country. But these results were obtained by calculating according to the formula that was canceled by the court, i.e. they are not correct. It is not possible, I would say it is stupid, to perform statistical processing of data that is known in advance to be incorrect. The percentages between 20 and 40 should disappear from the regulation. An agreement between the owners on a certain percentage cannot be reached, because those using radiators will want a higher percentage for the building installation in order to pay less for their radiators. Owners who do not use radiators, but another type of heating, will want a lower percentage. In reality, there will be conflicts between the neighbors. Experience shows that an agreement cannot be reached.
- You have repeatedly criticized the charging of the so-called “service units“ and the mixing of metered and unmetered heat. Do the changes in the regulation solve this problem?
- According to the regulation on heat supply, risers are heating devices. They must be considered separately from the building installation. For this reason, the changes in the regulation do not apply to them. However, when determining the energy released by risers, another curious case arises. The risers are charged with official share units and they, together with the units from the radiators, form the total sum of share units. The share distribution company "Techem", in a letter dated 25.01.26, writes: "The value for 1 unit in kWh. is determined as the total amount of heating energy divided by the sum of the units reported by the individual radiator devices in all properties, including the charged official units for heating units without devices". The very fact that there are "charged official units" is terrifying. This means that the share units of the radiators 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 Regulation on Heat Supply and its methodology 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 consumer group consists of all radiators with distributors, and the other consumer group is all risers that do not have distributors. The Ministry of Energy still has a lot of work to do.
- The draft stipulates that district heating companies will provide monthly information on all components involved in the calculation of the building installation. Will this lead to real transparency, or will most consumers still not be able to check their bills?
- There is no need to provide any information. The formula proposed by the Ministry of Energy for discussion is the same as the old one. It was canceled by the court. In short - there are no components. If, despite everything, the formula remains in the regulation, no matter what information the district heating companies provide, consumers will still not be able to check their bills.
- Why has the issue with the building installation remained unresolved for so many years - is it a complex technical problem or a conflict of interest in the heat supply system?
- Measuring the energy from the building installation is a truly complex technical problem. For this purpose, an additional heat meter must be installed in each building at the property boundary, i.e. after the heat exchanger for heating in the subscriber station. The measurement itself must be done by external specialists and under certain conditions for setting the thermostatic valves of the radiators in each apartment. All this excludes any discussions on this topic.
It is more correct to say that district heating companies and share distribution companies have an interest in using the existing formula for calculating the energy from the building installation, because through it they increase the energy consumed by it by more than 30%. This means that the energy for heating from the radiators will be less. Therefore, subscribers with radiators will pay less and will not have an interest in giving them up. And this means more distributors sold, more fees for their inspection. Moreover, these fees are raised without any grounds and control, as in banks. And what will happen to them next year, when distributors and water meters for hot water will have to be replaced with ones with remote reading? According to the law, they are the property of the subscribers, and they will spend a lot of money on metering devices, account management, and monthly replacement and reporting fees.
- Why is no one in the Ministry of Energy paying attention to your proposals?
- I assume that many responsible persons have interests that my proposals violate. In addition, I believe that our institutions, including many in the media, are completely irresponsible towards citizens' signals. I have no other explanation for the lack of responses to my signal that the heat distributions are illegal, sent back in February 2025 to the Energy Committee in the National Assembly with entry number PG-51-5194-D-21/07.02.25, to BNT News on Bulgarian National Television with entry number 10-01-362/ 07.02.25, to Izpra se BG with entry number 001/07.02.25. The Ministry of Energy has not responded to my letter mentioned above about the formula, although I have reminded it twice by e-mail about the lack of response. I have no hope for a successful end to this discussion on changes to the Heat Supply Regulation.