Energy transition is one of the most significant challenges facing the Polish economy. Successfully implementing this transition requires the involvement of all key stakeholders – experts, entrepreneurs, and government representatives. It is a collective effort that relies on collaboration, knowledge exchange, and the inclusion of diverse perspectives to create a cohesive and effective energy system.
At the outset, we would like to thank the authors of the National Energy and Climate Plan (KPEiK) for the tremendous effort they have invested in preparing this strategic document. We appreciate the comprehensive analysis that goes beyond the energy sector. This holistic approach highlights the interdependencies between various sectors, which is particularly important when analyzing primary energy consumption and electricity demand. The analysis demonstrates that the transition extends beyond electricity generation or even the entire energy sector, encompassing heating and energy distribution, and effectively affects every industry. Particularly enlightening is the presentation of how industrial transformation and electrification contribute to increased global electricity demand while reducing the consumption of primary energy from fossil fuels.
Responsible and well-planned actions in this area have the potential not only to enhance the country’s energy security but also to strengthen its competitiveness in global markets. Sustainable development of the energy sector is the foundation for economic stability and a higher standard of living for citizens. Our remarks, prepared with the utmost care, aim to emphasize the perspective of energy consumers, including industry, whose focus is equally on energy prices, availability, and achieving climate goals.
In our view, ensuring energy security during the transition is a top priority. Maintaining coal as a backup source until sufficient dispatchable capacity is established is essential for the stability of energy supplies. We also emphasize the crucial role of nuclear energy as a stable and emission-free energy source that can reduce dependence on imported fossil fuels. In the transitional period, natural gas should act as a bridging fuel, requiring the expansion of storage capacities and gas infrastructure.
The WAM (With Additional Measures) scenario adopted in KPEiK raises serious concerns due to its ambitious goals for emission reductions and the development of renewable energy sources (RES). We believe that implementing this scenario entails high costs that could burden both industry and households. We fear that this approach risks weakening the competitiveness of Polish industry in global markets, especially given the higher energy costs compared to other economies, such as the United States. There is also a risk that the European Commission will increase pressure on Poland for failing to meet set goals, potentially resulting in additional obligations and restricted access to EU funds.
We note significant discrepancies in the demographic assumptions of KPEiK. The document projects an increase in the population to 37.1 million by 2040, which significantly diverges from Statistics Poland’s (GUS) forecasts predicting a population decline. We believe such unrealistic assumptions could lead to the construction of energy infrastructure misaligned with the country’s actual needs, increasing maintenance costs and placing a greater burden on a shrinking population.
We also observe the lack of a coherent industrial policy in KPEiK. Reliance on non-EU technologies, such as energy storage and photovoltaic panels, increases the risk of delays, rising costs, and loss of competitiveness. We argue that supporting domestic technological industries is essential to foster local economic development and reduce dependence on foreign suppliers. In our view, the energy transition should be seen as an opportunity for the strategic development of Polish industry, not solely as a means of achieving climate goals.
Our greatest concerns relate to the financing assumptions for the transition. Planned investment expenditures of PLN 2.766 trillion exceed the country’s economic capacity and are significantly higher than Poland’s annual GDP in 2020. We believe that financing these investments primarily through charges levied on electricity consumers will significantly raise household living costs and reduce industrial competitiveness, particularly in energy-intensive sectors. We fear this approach may provoke public resistance, jeopardizing the transition’s implementation.
We recommend setting realistic transition goals tailored to the country’s economic capabilities, avoiding excessive societal burdens. Increasing financial transparency by presenting investment costs and energy price forecasts in current values, including all additional charges, is crucial. The transition should also include support for coal-dependent regions to prevent their impoverishment and depopulation.
We urge a revision of the KPEiK transition strategy to ensure its implementation supports the country’s economic development, provides stable and affordable energy supplies, and is socially acceptable. The energy transition should serve as a tool for development rather than a burden on society and industry. In its current form, the document raises serious doubts about its effectiveness and feasibility, requiring significant changes to better address Poland’s real economic and social needs.
We believe that considering these aspects will contribute to creating a document that garners widespread acceptance for the energy transition, a critical condition for Poland’s continued economic prosperity.
Detailed comments are provided in the attachment.
