National Energy and Climate Plan

Poland

SolarPower Europe Assessment

1. Solar Target

Information available in the NECP
RES target 21-23%
RES-E target 32%
Electricity in the RES target for transport The plan states that there is a target, but it is not included in the plan
Solar target 7.3 GW
Solar target per segment No information

Overall quality and ambition: Poor to intermediate

The Polish RES target of 23% is conditional on getting additional EU funds. Solar targets/ trajectories are inferable from the English summary document but fully included in the full NECP. Solar capacity is expected to reach 7.3 GW by 2030 with about half installed by 2025. The 2040 time horizon is also included (16 GW). Renewable electricity does not seem to be included in transport.

With 5.9 GW of net solar addition in 10 years, ambition seems low compared to today’s annual additions. With the current target, the W/capita ratio in 2030 would be only around 200, much below the expected EU average.

Poland has a large potential to install solar on former coal sites. There is an interest from Polish grid operator in large PV projects to fill in the summer peak demand, partly resulting from the higher capacity of air-conditioning systems.

2. Auctions

Information available in the NECP
General information on auctions Yes
Details of the auction pipeline (schedule and volumes) The amendment to the Act on renewable energy sources, which entered into force on August 29, 2019, made it possible to conduct auctions for the purchase of electricity from renewable energy sources in 2019, for which a capacity volume of over 3,400 MW was envisaged.
Details on auction design Partially: only general remarks about auction mechanisms to stimulate renewable energy are found: the choice of supported areas depends on the preferences of stimulating the development of renewable energy areas, based on economic, environmental and climate conditions, while respecting energy security.

Overall quality and ambition: Intermediate

A major issue for PV in Poland is the high financing costs for PV projects, resulting from the history of retroactive measures. This leads to a difficulty for PV projects to compete with wind projects in the auction basket >1 MW.

Recent distance restrictions (10H rule) have blocked the increase in new capacities of large wind projects, leading to a situation in which, due to the long investment process compared to PV, even in the event of relaxation of distance restrictions, for the next few years the share of wind in basket auctions above 1 MW will be only rudimentary. Therefore, possibilities to support solar farms are potentially opening, the more so that the largest solar farms will be able to go below the reference price for large wind farms in the short term.  One should also bear in mind that meeting of RES target by Poland is only possible through a rapid increase in high capacity in the coming years. Therefore, there is a need for increased volumes of auctions for renewable energy technologies that would allow additional energy to be supplied by 2020. Due to the investment gap of several years regarding the increase of wind potential, the only area of the RES where such large increases in power could occur in Poland is currently photovoltaics. In addition, the government should publish the auction schedule three years in advance, but this has never been the case.

3. Administrative procedures

Information available in the NECP
Assessment of current administrative issues No information
Remedy measures The plan mentions that the government will work at the increased digitalisation of procedures, in order to accelerate and facilitate administrative processes.

The plan also mentions a series of measures related to the certification of installers, notably through a recent regulation. The regulation increases the certification system for installers and ensures a minimum standardisation of the assembly and installation process. It also ensures appropriate documenting and recording and storing of documentation regarding certification proceedings.
Introduction of one contact point for the permit granting procedure (RED II, article 16) The one contact point is the Office of Technical Inspection (Urząd Dozoru Technicznego))

Overall quality and ambition: Intermediate

The plan mentions the need to digitalise administrative procedures, which will be essential to facilitate administrative procedures.

Nevertheless, the plan could consider additional measures. The Polish grid connection procedures lack clarity: there is no clear deadline for all the steps of the procedures. In addition, PV is not evaluated as such by the grid operator but considered like wind energy. This results into regular delays and grid access refusals

4. Prosumers

Information available in the NECP
Current prosumer share As of September 30, 2019, 106,000 renewable energy micro installations connected to the 5 largest Distribution System Operators (DSO) with a total installed electrical capacity over 684 MW.
Targets for prosumers No information
The plan proposes to increase the share of prosumers by facilitating regulatory and technical requirements for micro installations and aggregation of procsumer's energy. However, there is no specific target.
Support schemes for prosumers The plan names prosumer financial support programs, such as the 'My Current' program with a pool of funds of PLN 1 billion. The goal is to increase energy production from photovoltaic sources. The program assumes co-financing of new 2-10 kW solar photovoltaic installations. It is anticipated that 200,000 beneficiaries will benefit from the subsidy.
Collective self-consumption framework No information
Currently, there is no collective self-consumption scheme in Poland. However, in the future, the plan will include local energy communities and group of households sharing generated energy.

Overall quality and ambition: Intermediate

There is a supportive environment for prosumers, but there are no measures for supporting collective self-consumption in communities. 

SolarPower Europe welcomes the effort of the Polish Ministry to have a quantitative assessment of the share of self-consumption, as well as an assessment of the share of grid injected and self-consumed electricity.

However, the potential for self-consumption can be revised upwards. As a reference, the European Commission’s study on “Residential Prosumers in the European Energy Union” foresaw in 2017 that the potential for residential PV was 14,8GW and that 4,94 million households were suitable for PV self-consumption.

Self-consumption is increasingly competitive but suffered from the history of retroactive which disincentivised consumers to invest into PV and which increased the cost of financing.

5. Power Purchase Agreements

Information available in the NECP
Assessment of current barriers to PPA development No information
Enabling framework for PPAs No information

Overall quality and ambition: Intermediate

The plan does not address the existing barriers to PPAs.

The PPA market is developing in Poland, with to date 7 projects of 112 MW.

However there remains some substantial barriers to its development:

• Regulatory requirements for direct energy supply: One of the basic types of corporate PPA is the so-called private wire PPA, based on a direct line between the producer and receiver of electricity. However, having regard to Polish legal regulations regarding the use of a direct line, namely the need to obtain the consent of the President of the Energy Regulatory Office for its construction, with full discretion of the authority in this respect, the development of this type of agreement is doubtful, and certainly difficult. To this should be added the need to obtain a license for the distribution of electricity and all other obligations related to the status of the distribution system operator, which effectively discourages the choice of this type of solution.

  • Short-term commerce instruments on the Energy Stock Exchange (TGE): Another factual barrier for corporate PPAs on the Polish market is the ability to set energy prices on the Polish Energy Stock Exchange only in a three-year perspective. Of course, trading companies may offer products in the long term, but the costs of risk associated with them, which are passed on to end users, are unacceptable.
  • Generally unstable regulatory framework for the RES in recent years (“Distance Act”, unclear rules of taxation of windfarms, disputes considering Green Certificates”)
  • No long-term-policy considering energy prices

In addition, in Poland, the interpretation of the ETS State Aid Guidelines allows those energy intensives sourcing electricity from conventional power generation to get compensation for the indirect EU ETS costs. On the contrary, those companies sourcing renewable electricity are not entitled to any compensation. This problem is reported also by the study on the “Competitiveness of corporate sourcing of renewable energy in Europe” released by the Directorate-General for Energy on 28 June 2019. Yet, the new draft ETS Guidelines are also clearing important ambiguities deriving from Par. 11 of the former ETS Guidelines.

6. Flexibility and storage

Information available in the NECP
Assessment of current demand-side flexibility and storage capacity No information
Targets for battery storage No information
Targets for demand side response Partially: only generic reference to development of demand-side response.
Support framework for flexibility (market access, balancing markets, network charges) The plan refers to implementation of measures to integrate power system, including balancing market prices revision, support to aggregation and rollout of smart meters.
Support schemes for storage No information

Overall quality and ambition: Intermediate

The plan acknowledges the need of improving system flexibility and mentions several areas of activity, including restructuring of electricity markets, rollout of smart meters and possibility of increase flexibility through prosumers and electric vehicles. This said, there are no specific references to battery storage, and DSR is only briefly mentioned.

7. Grid integration

Information available in the NECP
Assessment of current state of play The plan mentions that the interconnection level of Poland is 15%.
Measures for renewable grid integration As the share of renewable energy is considered to increase by 2030 and 2040 (mainly offshore wind), the administration is planning to develop the grid infrastructure by investing in smart metering, aggregation, distribution, and transmission infrastructure.

Overall quality and ambition: Poor

While Poland is planning to develop solar, included distributed solar, the plan does not contain a proper assessment of challenges it might create, nor propose clear measures to facilitate grid integration of renewables.

Methodology

The assessment of National Energy and Climate Plans was based on both quantitative and qualitative criteria:

–    Quantitative criteria assessed the availability of the right amount of information in the plan. European countries developed their NECP on the basis of a template defined in the Governance Regulation (Annex I). The assessment consisted in evaluating the level of information available, based on legal obligation of member states and best practices.

–    Qualitative criteria assessed the ambition of the plans with regards to solar PV development as well as the quality of the proposed measures compared to the barriers faced by solar PV developers. This qualitative assessment has been made based on interviews with local industry representatives, when available.

For each category, each parameter was affected a coefficient dependent on their importance. 

The details of the grading system adopted is presented below.

Based on these criteria, an evaluation of each NECP has been carried out. All grades has been converted to a scale from zero (minimum) to six (maximum) points. All grades have been rounded to the nearest 0.5.

The assessment is based on SolarPower Europe’s best knowledge at the time of publication.

Category

Assessment criteria

Grade

1. Solar Target

Presence of a solar target


Presence of a solar target disaggregated per segment


Overall quality and ambition*


1 point


1 point


2 points


2. Auctions

Presence of information


Details on the auction pipeline (schedule and volumes)


Details on the auction design


Overall quality and ambition

1 point


1 point



1 point


2 points

3. Administrative procedures

Presence of an assessment of current administrative issues


Presence of measures to address issues


Introduction of a “one contact point” system for the permit granting procedure, as per the RED II, article 16


Overall quality and ambition

1 point



1 point


1 point




2 points

4. Prosumers

Details on current prosumer share and support schemes


Presence of objective or trajectory for prosumers development


Presence of support schemes for prosumers


Presence of provisions for collective self-consumption


Overall quality and ambition in prosumers


1 point



1 point



1 point


1 point


2 points


5. Power Purchase Agreements (PPAs)

Assessment of barriers to PPAs


Presence of measures to develop an enabling regulatory framework


Overall quality and ambition

1 point


1 point



2 points

6. Flexibility and Storage


Assessment of current demand-side flexibility and storage capacity


Presence of objective and/or provisions on battery storage


Presence of objective and/or provisions on demand side response


Presence of a support framework for flexibility (market access, balancing markets, network charges)


Presence of support schemes for storage


Overall quality and ambition

1 point



0,5 point



0,5 point



1 point



1 point


2 points

7. Grid Development

Presence of information on the current grid development or existence of a grid development plan or assessment of the challenges related to grid integration of renewables


Presence of measures to improve grid connection and integration of renewables


Overall quality and ambition


0,5 point





0,5 point



2 points


*For the assessment of the level of ambition across the solar targets, a conversion from TWh to GW has been necessary in a number of cases. In order to do so, average solar irradiance levels have been taken from Solargis’ Solar Resource Maps of Europe (https://solargis.com/maps-and-gis-data/download/europe). SolarPower Europe Global Market Outlook 2020-2024 data for cumulative capacity in 2019 has been used to calculate net solar PV additions by 2030. Moreover, in order to infer the W/capita ratio in 2030, the projections of EU population per country have been retrieved from the United Nation World Population Prospects 2019 (available at https://population.un.org/wpp/Download/Probabilistic/Population/).

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