Poland’s Energy and Climate Plan to 2030 – not sufficient EU perspective

The draft National Energy and Climate Plan 2021-2030 (NECP) was published on 15 January, five days after the entry into force of the Regulation on the governance of the Energy Union and Climate Action ¹. It is good that the Ministry of Energy submitted the document on time. However, this is only a draft for public and regional consultations; but also, for the review of the European Commission. What proposals does it contain and how does it fit into EU policy?

Five most important comments to Poland's NECP

• When presenting emission reduction plans, the NECP makes insufficient reference to commitments made at EU level, which should be its fundamental function.

The key priority of the NECP is to present a national strategy for achieving jointly agreed targets within the EU. The current draft of the document does not meet this objective. The Ministry forecasts that emissions in the ETS in Poland will decrease by app. 9% (compared to 2005). During this time, EU emissions are expected to drop by 43%, for which the ETS has been designed. As a consequence the proposed NECP scenario will therefore additional burden (costs of CO2 emission allowances) on electricity and heat consumers.

• RES are underused both in the power sector and heating (system and individual).

The RES targets adopted last year assume that in 2030 their share in gross final energy consumption will reach 32%. In NECP it equals 21%. NECP does not consider the advantages for energy security resulting from the increase in the share of RES in the power and heating sectors, which would improve the deteriorating fuel balance of the country and the imbalance between supply and demand. NECP does not take into account the changes related to the continuous cost reduction of technologies based on renewable energy sources. It does not formulate instruments supporting the development of RES (e.g. changes in the energy market), which would increase the flexibility of the system and allow for greater integration of RES.

• The NECP does not provide guidelines for energy efficiency measures.

The NECP sets a target of 23% reduction in primary energy consumption by 2030, although at the same time it forecasts that it can be reduced by a maximum of 18.6% by 2030. Meanwhile, the increase in the demand side response (DSR) in the energy market has not been taken into account to a sufficient degree, and there is no reference to sector coupling, i.e. electrification of heating and transport, which can contribute to improving the management and energy efficiency of the power system. With regard to district heating, NECP did not define specific objectives and methods for improving the energy efficiency of buildings and reducing the demand for non-renewable primary energy.

• The strategic government documents submitted for public consultation (NECP and PEP2040) present discrepancies.

The Ministry of Energy published NECP on the day when the public consultations of the Poland's Energy Policy until 2040 (PEP2040) were finished.  However, these documents are inconsistent in the scope of, among others, forecasts of electricity demand, generation capacity structure, or a unified presentation of data, which enables comparison. Despite these differences, the most important comments on the electricity mix that we submitted to the PEP2040 project (Poland's Energy Policy 2040 in the spotlight) also apply to the NECP: delay of the nuclear power project, the insufficient attention paid to energy costs and the risk of not meeting EU objectives.

• Lack of a comprehensive view of thе entire area of heat supply and recognition of synergies between different segments of the energy sector.

The NECP considers district heating only through the prism of district heating systems that pursue their primary function, which is the supply of heat. However, it does not see a second, even larger segment of the heating sector – individual heating – and does not present appropriate policies and measures for it. In Poland, system and non-system heat supply is responsible for about 30% of primary energy consumption. Therefore, it affects the air quality and energy security of the country. There is also a lack of reference to the potential benefits of coordination between the entire district heating sector (system and non-system) and the national power sector.

A well-designed NECP can leverage synergies between security of supply, reduction of greenhouse gas emissions, development of RES and energy efficiency. It would then serve as a roadmap for the transformation of the Polish energy sector and would make it possible to obtain EU funds allocated for this purpose. Finally, the NECP should serve as a basis for the development of future plans, including a low-emission strategy up to 2050. It is worth adopting a plan that meets these expectations in public consultation and dialogue with the European Commission. The credibility of the energy and climate actions presented by us will have an impact on Poland's position in the European Union and in the world.

Detailed comments and recommendations provided to the Ministry of Energy are available in Polish for download in the attached file.