The National Energy and Climate Plan (NECP) was supposed to be a roadmap for investments and reforms supporting Poland’s sustainable development. However, the current draft is a collection of scenarios without any specific commitments from the government – emphasizes the Reform Institute. The Institute is calling for the NECP to be supplemented with decisions on financing, energy infrastructure development, just transition, electrification, and the circular economy.  

The Reform Institute has submitted several dozen detailed comments (available here in Polish) to the Ministry of Climate and Environment on the updated National Energy and Climate Plan (NECP). Experts point to a number of general and specific shortcomings. 

No strategy for financing climate transition 

The NECP draft does not contain a coherent strategy for mobilizing national and EU funds to support the transition. Meanwhile, without clearly defined sources and mechanisms for financing the changes, Poland will not achieve its ambitious climate goals. 

We need a comprehensive plan that takes into account both national and EU funds, but also recognizes the role of private capital. This will ensure that the available pool of public money is used where it will have the greatest impact – says Aleksander Śniegocki, president of the Reform Institute. 

The document in its current form focuses on available EU funds, ignoring future budget revenues from the ETS2 system and the prospect of implementing the Social Climate Fund. 

The NECP update is the perfect moment to direct all future revenues, both from the EU ETS and the new ETS2, towards financing the energy transition. Over the years, Poland has earned over PLN 100 billion from the sale of emission allowances, but has spent only one hundredth of that amount on zero-emission investments, and one tenth on protective measures for industry. As the latest Supreme Audit Office (NIK) report indicates, most of the funds have disappeared into the budget, financing current expenditures unrelated to the climate – explains Wojciech Augustowski, Senior Public Policy Analyst at the Reform Institute. 

Insufficient support for the just transition of coal regions 

The NECP is intended to become a reference point for the creation of public policies in all sectors of the state and a basis for the design of specific policies in the field of just transition. However, the document omits support mechanisms for regions such as Lubelszczyzna and Zgorzelec County, which are not beneficiaries of the EU’s Just Transition Fund due to the lack of a decision on the date for phasing out coal. 

Therefore, the Reform Institute calls for the urgent presentation of a long-term decarbonization plan and related mechanisms to support a just transition for regions that have been overlooked so far, in order to avoid their marginalization and fill the gap in financing the changes. 

A just transition is not only a matter of environmental protection, but also of social and development policy. The Lublin region with the Bogdanka mine and Bogatynia with the Turów power plant, which are excluded from the Just Transition Fund due to a lack of strategic decisions in recent years, need support from national funds to undergo the transition without social turmoil – emphasizes Maria Niewitała-Rej, Climate and Energy Policy Analyst at the Reform Institute. 

No clear agenda for green electrification of the economy 

he NECP does not outline a clear path towards green electrification, which involves replacing fossil fuels with renewable energy in transport, heating, and industry. The lack of specific solutions in this area is surprising, especially since green electrification is one of the main elements of the ambitious WAM scenario presented in the NECP draft. 

Rapid changes in supply and demand on the electricity market, linked to the electrification of the economy, require a new approach to financing and managing the development of the power grid. Meanwhile, the NECP only briefly describes activities in that area. Citizens and entrepreneurs will not learn how the government intends to change distribution tariffs or increase the flexibility of energy consumers – points out Klaudia Janik, Climate and Energy Policy Analyst at the Reform Institute. 

The neglected potential of the circular economy 

The new version of the NECP still does not include measures to support the circular economy. Experts point to the need for more ambitious initiatives for recycling and effective resource management. 

Effective resource management and waste elimination will accelerate the achievement of climate goals. The circular economy should support and reinforce the goals set out in the NECP. Moving away from the linear model of raw material use in the economy will facilitate, for example, the transformation of heavy industry by reducing the demand for the production of emission-intensive materials – according to Agnieszka Czaplicka, Fellow at the Reform Institute specializing in the circular economy. 

Call to the government – more specifics needed in the NECP 

The Reform Institute, as one of 25 non-governmental organizations, signed an appeal to the Minister of Climate and Environment, Paulina Hennig-Kloska. Among the key demands is the unequivocal adoption of the ambitious WAM scenario as the basis for the NECP and the inclusion of specific commitments in the Plan that will enable its implementation. 

We encourage you to familiarize yourself with the call and a table assessing the consistency of the NECP project with the Fit for 55 package and the REPowerEU plan.