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PGE Polska Grupa Energetyczna SA

PGE is the largest energy company in Poland, focusing on power generation and distribution.

Lobbying Activity

PGE Pushes for Delayed Gas Transition and Reduced Emission Targets

5 Dec 2025
Topic — Commission review updating technical screening criteria for environmental and climate activities under the taxonomy.
Message — PGE requests delaying the 2035 deadline for switching to renewable gases due to supply shortages. They propose reducing greenhouse gas savings requirements for replacing coal plants from 55% to 40%. The company also recommends including electric boilers in the climate taxonomy.123
Why — This would lower compliance costs and allow more gas projects to secure sustainable financing.45
Impact — Environmental goals suffer because lower standards prolong fossil fuel use and slow down decarbonization.6
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PGE Calls for Equal EU Support for Nuclear SMRs

4 Dec 2025
Topic — The consultation explores the future development and deployment of Small Modular Reactors in Europe.
Message — PGE recommends respecting technological neutrality and providing nuclear projects equal access to EU support mechanisms. They call for simplified regulatory procedures and fast-track permitting for projects on former energy-related sites. Additionally, they advocate for including nuclear technologies in future EU funding and financial guarantee instruments.123
Why — These measures would lower capital costs and streamline the conversion of old coal plants.45
Impact — Renewable energy sectors would face increased competition for limited EU climate funding pools.6
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Meeting with Andrzej Celinski (Cabinet of Commissioner Piotr Serafin) and Google and

18 Nov 2025 · Presentation on the state of play of the negotiations of the next MFF, with the special focus on communication activities.

Meeting with Borys Budka (Member of the European Parliament, Committee chair) and TotalEnergies SE and

12 Nov 2025 · ITRE ongoing work

PGE Urges EU Budget Support for Energy Transition and Grids

4 Nov 2025
Topic — Consultation regarding the performance and implementation of the EU’s post-2027 long-term budget framework.
Message — PGE requests earmarked funding for energy grids and district heating to support the transition. They also seek simplified environmental rules and reject proposed new corporate and carbon taxes.123
Why — Secured EU funding would decrease financial risks and prevent firms from becoming net budget contributors.45
Impact — Eastern European households face energy poverty if grid investment costs are passed to local consumers.6
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PGE Demands EU Budget Support for Energy Transition and Grids

4 Nov 2025
Topic — This consultation addresses the EU's post-2027 long-term budget and funding for European competitiveness.
Message — PGE requests earmarked funding for electricity grids and district heating to lower transition costs. They recommend simplifying green investment rules and oppose new corporate taxes that threaten competitiveness. Furthermore, they demand geographical balance in the allocation of competitiveness funds.123
Why — Increased public support would lower investment risks and help PGE secure cheaper capital.45
Impact — Western European companies would lose their current advantage in securing competitive EU innovation funding.67
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PGE Polska Grupa Energetyczna Urges Stronger EU Energy Transition Funding

3 Nov 2025
Topic — A consultation on the European Union's long-term budget starting in 2028.
Message — PGE requests dedicated EU funding for energy projects and decarbonising district heating. They oppose new corporate levies and emission-based revenue rules that burden industry.123
Why — Access to public funds would decrease their market risk and lower borrowing costs.4
Impact — Households could suffer from higher energy bills without public support for grids.5
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PGE Urges EU Support for Coal Transition and Capacity Markets

13 Oct 2025
Topic — Revision of European rules to modernize energy security for a decarbonized and integrated system.
Message — PGE calls for financial support to transition from coal and lignite without compromising grid stability. They advocate for long-term capacity mechanisms and EU ETS reforms to exempt backup generation units.123
Why — This would secure funding for legacy coal assets and reduce carbon costs for backup plants.45
Impact — Environmental objectives are harmed by extended subsidies for fossil fuel infrastructure and higher emission thresholds.67
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Polish energy giant PGE seeks flexibility on green tech standards

10 Oct 2025
Topic — EU rules setting environmental standards for public procurement of clean technologies.
Message — PGE requests flexibility for Member States to adapt solar panel testing to local climates, gradual introduction of wind blade recycling targets over 5 years, and delayed implementation until 2027 instead of December 2025.123
Why — This would give them more time to meet stricter standards and avoid procurement disruptions.4
Impact — Environmental goals are weakened by delaying recycling standards and diluting uniform EU requirements.5
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Polish energy giant urges EU funding and support for electrification infrastructure

9 Oct 2025
Topic — EU consultation on accelerating electrification to achieve climate and industrial competitiveness goals.
Message — PGE requests sufficient public financing for grids and storage in the post-2028 MFF and continuation of the Modernisation Fund after 2030. They call for differentiated support periods for energy storage based on technology, separate financing for pumped hydro groundworks to avoid passing costs to consumers, and maintaining free EU ETS allowances for district heating until decarbonized gases are available.1234
Why — This would reduce their compliance costs and provide public funding for major infrastructure investments.56
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Meeting with Krzysztof Hetman (Member of the European Parliament)

9 Sept 2025 · Energy in the new MFF

PGE Calls For Higher State Aid Limits and Gas Flexibility

5 Sept 2025
Topic — Revision of EU rules exempting certain state aid from prior Commission approval.
Message — PGE requests raising notification thresholds to EUR 150 million and increasing aid intensity to 60% for district heating. They also advocate for continued natural gas support where greener alternatives remain commercially unavailable.123
Why — Higher thresholds would reduce administrative burdens while maximizing public funding for infrastructure.45
Impact — Climate groups lose as prolonged gas usage could delay absolute emission reductions.6
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Polish energy giant urges EU to slash 2040 climate target to 75-80%

29 Aug 2025
Topic — EU proposal to set 90% emissions reduction target for 2040 under European Climate Law.
Message — PGE requests the EU reduce its proposed 90% emissions reduction target to 75-80% for 2040. They argue the current target threatens economic competitiveness, requires unrealistic timeframes, and ignores funding gaps. They want better sectoral balance, adequate impact assessment including country-level analysis, and dedicated funding sources identified before adoption.123
Why — This would reduce carbon allowance costs and resulting electricity prices for their operations.45
Impact — Climate advocates lose stronger emissions cuts needed to meet Paris Agreement goals.67
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Meeting with Marta Wcisło (Member of the European Parliament)

16 Jul 2025 · energy security

Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

PGE Polska Grupa Energetyczna S.A. (PGE) welcomes the opportunity to provide its feedback as part of the evaluation of the EU Emissions Trading System (EU ETS) and the Market Stability Reserve (MSR). Please find our detailed feedback attached. Our key messages: - The EU ETS managed to reduce emissions in the covered sectors by around 50% from 2005 to 2024, primarily driven by the power sectors efforts. However, it is unlikely that such a pace can be maintained in the future, as the abatement costs of the remaining emissions are significantly higher and the reductions are more challenging from a technological point of view. - The EU ETS parameters should be considered in a broader context of global competitiveness, affordability, and system stability. While promoting emissions reductions, the EU ETS must not threaten economic growth, the EUs defence spending plans and security of supply. - The EU ETS must be reformed, to ensure market liquidity (both in the short- and long-term perspectives) as well as reactions to major price shocks. The parameters of MSR, such as the EUA invalidation rule or intake rates, need to be modified. Furthermore, the total number of allowances in circulation (TNAC) is not an efficient indicator reflecting market liquidity. - The design of the mechanisms dedicated to preventing major price shocks (Article 29a of the EU ETS Directive), which is based on the multipliers of the average historical EUA prices, is ineffective and should be modified. - With the expected market scarcity and increasing prices, many market participants will adopt a buy-and-hold strategy of banking the allowances. Such allowances will not be available on the market, but will still be included in TNAC. It means that the changes in both the MSR and the Article 29a mechanism are even more urgent. Their activation should reflect the broader economic context, and a dedicated new institutional design to manage the supply of allowances should be considered. Furthermore, the market transparency must be improved. - The Modernisation Fund should be continued after 2030, and its size shall be increased up to at least 4.5% of the total quantity of allowances (the sum of the current 2% standard allocation and 2.5% of the additional allocation). In order not to limit the current flows of revenues for the Member States and possibly the EU budget, the additional allocation can be made from the volumes dedicated to the Market Stability Reserve. - The Innovation Fund shall be implemented in a way that ensures geographical balance across the EU. The methodology of calculating avoided emissions, should allow the use of national benchmarks. - The rules, which allow excluding from the EU ETS the reserve or backup units (Article 27a of the EU ETS Directive), should be extended, so they can support the dispatchable sources that are working on demand of the Transmission System Operator and thus support intermittent renewable sources. - The free allocation to district heating should be maintained after 2030, to prevent rising heating costs in European cities where gas units will need to operate. - Waste incineration installations should not be covered by the obligation to surrender carbon allowances. It will not improve market liquidity, but increase the power and heat prices, as well as impose costs on the solution that is less GHG-intensive than landfills.
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PGE Demands Fairer Geographic Distribution for EU Innovation Funding

8 Jul 2025
Topic — This consultation evaluates the performance and future operations of the EU Innovation Fund.
Message — PGE proposes that access to funds be more geographically balanced to better serve Central and Eastern Europe. They suggest the application process should allow for national benchmarks to reflect local decarbonization potential. Finally, the company calls for a two-stage application process to simplify early project documentation.123
Why — This would make Polish energy projects more competitive for receiving EU financial support.4
Impact — Western European countries would lose their dominant share of the fund's financial resources.5
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Meeting with Ondřej Krutílek (Member of the European Parliament)

3 Jul 2025 · Gas storage, Grids package

Polish utility PGE seeks expansion of the EU Modernisation Fund

13 May 2025
Topic — The initiative evaluates operating rules for the Modernisation Fund to improve climate action investments.
Message — PGE calls for extending the fund past 2030 and increasing its size. They seek more flexibility for national governments and full coverage of costs.123
Why — The utility would secure higher subsidies and more influence over fund governance.4
Impact — Social programs could receive less priority if funds focus strictly on industrial decarbonization.5
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Meeting with Jessika Roswall (Commissioner) and

28 Apr 2025 · Water Resilience Strategy

PGE Group backs taxonomy simplification but seeks clearer definitions

24 Mar 2025
Topic — The initiative aims to simplify EU Taxonomy reporting requirements for companies.
Message — PGE requests a clearer definition for operational costs and changes to financing regulations. They support removing complex pollution rules to improve clarity for businesses.123
Why — New reporting thresholds and fewer tables would lower data collection and verification costs.45
Impact — Financial institutions may face extra work if required data is missing from publications.6
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PGE Urges EU to Exempt Offshore Wind from Procurement Rules

7 Mar 2025
Topic — Evaluation of EU directives governing public procurement in energy and transport sectors.
Message — PGE seeks to exclude offshore wind projects from procurement rules and increase financial thresholds. They also advocate for restricting third-country contractors and introducing criteria favoring European suppliers.123
Why — PGE would enjoy faster project delivery and reduced competition from international firms.45
Impact — Non-EU manufacturers and new market entrants face higher barriers and potential exclusion.67
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

PGE Polska Grupa Energetyczna S.A. welcomes the draft implementing act on final products and main specific components. The list of the main specific components (Annex) in the offshore wind technologies sub-category should also include the power cables: inter-array cables; export cables - subsea cables; export cables - onshore cables.
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Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

PGE Polska Grupa Energetyczna S.A. (PGE) welcomes the initiative to clarify the role of non-price criteria (NPC) in renewable auctions in the European Union. Please find attached the comments of PGE.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

3 Feb 2025 · Exchange of views on simplification and the energy market

Meeting with Ditte Juul-Joergensen (Director-General Energy) and European Chemical Industry Council and

28 Jan 2025 · Competitiveness, Clean Industrial Deal and energy and their impact on European industry.

Polish Energy Giant Backs EU Allocation Rules, Warns of Investment Delays

8 Jan 2025
Topic — EU rules on free emission allowances for district heating decarbonization investments.
Message — PGE welcomes the new rules linking additional emission allowances to decarbonization investments in district heating. However, they warn that investor delays beyond their control could jeopardize the EUR 2.5 billion in investments needed by 2030.123
Why — This support would reduce their EUR 2.5 billion decarbonization costs and protect customers from price increases.45
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Meeting with Adam Jarubas (Member of the European Parliament) and Polskie Towarzystwo Energetyki Cieplnej

13 Nov 2024 · Przyszlosc sektora ciepowniczego w Polsce

Meeting with Mirosława Nykiel (Member of the European Parliament)

6 Nov 2024 · Feedback after hearings with Commissioners-designates

PGE calls for fairer GHG calculations for low-carbon fuels

24 Oct 2024
Topic — A consultation on the methodology for assessing greenhouse gas savings from low-carbon fuels.
Message — PGE requests that the Commission provide regular, timely updates to national emission intensity figures. They also propose more flexibility when fuel production exceeds certain operating hour limits.12
Why — This would prevent unfair penalties caused by outdated data and rigid emission thresholds.34
Impact — Producers in fossil-heavy regions lose competitive fairness due to outdated emission data.56
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Meeting with Eszter Lakos (Member of the European Parliament)

23 Oct 2024 · Energy policy - dinner sponsored by PGE

Meeting with Dan Nica (Member of the European Parliament) and ENEL SpA and

22 Oct 2024 · Debate on challenges and opportunities for the energy sector with focus on Romania and CEE Countries

Meeting with Mirosława Nykiel (Member of the European Parliament)

11 Sept 2024 · Presentation of work of PGE S.A.

Meeting with Michał Szczerba (Member of the European Parliament) and Polish Electricity Association and GAZ-SYSTEM S.A.

11 Sept 2024 · Staff meeting with the representatives of the polish energy sector

Meeting with Marta Wcisło (Member of the European Parliament)

16 Jul 2024 · Energy transformation

Meeting with Borys Budka (Member of the European Parliament)

16 Jul 2024 · Polish energy sector

Meeting with Krzysztof Hetman (Member of the European Parliament)

16 Jul 2024 · EU Energy Policy

Meeting with Łukasz Kohut (Member of the European Parliament)

16 Jul 2024 · Industrial matters

Meeting with Ondřej Krutílek (Member of the European Parliament)

16 Jul 2024 · EU climate and energy policies (2024-2029)

Meeting with Michał Kobosko (Member of the European Parliament)

16 Jul 2024 · Energy Market in the EU

Meeting with Adam Jarubas (Member of the European Parliament)

17 Apr 2024 · future of polish energy sector including h2 production

Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič)

17 Apr 2024 · Fit for 55 implementation

PGE urges flexible weighting for non-price renewable auction criteria

1 Mar 2024
Topic — EU initiative to clarify non-price criteria for national renewable energy auctions.
Message — PGE requests EU-wide tools to verify that vendors meet sustainability and resilience standards. They advocate for national flexibility and increasing non-price criteria scoring weights.123
Why — Focusing on past experience favors the Polish incumbent over newer market entrants.4
Impact — Low-cost international manufacturers might be excluded by strict European supply chain requirements.5
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Polish energy giant challenges strict EU carbon allowance rules

22 Dec 2023
Topic — EU regulation updating free allocation rules for emission allowances under ETS.
Message — PGE requests flexibility in the 20% free allocation reduction penalty, allowing proportional cuts based on unimplemented audit recommendations rather than automatic penalties. They seek exemptions for installations being replaced by 2030 and ability to use realistic current costs for payback calculations. They want investments since 2016 counted toward emission reduction targets and published climate plan data limited to essential information.123
Why — This would reduce compliance costs and preserve free allowances worth millions while avoiding penalties for minor violations.456
Impact — Climate goals lose enforcement as diluted audit requirements slow efficiency improvements in heating sector.7
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Meeting with Róża Thun Und Hohenstein (Member of the European Parliament)

13 Dec 2023 · Combating Late Payments, Energy Market, Green Transition

Meeting with Róża Thun Und Hohenstein (Member of the European Parliament)

17 Nov 2023 · Single Market, Energy, Green transition in Poland

Meeting with Adam Jarubas (Member of the European Parliament)

14 Nov 2023 · Future of Polish energy sector

Meeting with Nicolás González Casares (Member of the European Parliament, Rapporteur) and ENEDIS

17 Oct 2023 · Electricity Market Design

Meeting with Jerzy Buzek (Member of the European Parliament)

17 Oct 2023 · situation in Poland

Meeting with Ditte Juul-Joergensen (Director-General Energy)

28 Sept 2023 · Energy Transition

Meeting with Franc Bogovič (Member of the European Parliament, Rapporteur) and Clean Air Task Force, Inc.

19 Sept 2023 · Meeting on small modular nuclear reactors (SMR)

PGE urges flexibility in EU climate-neutrality plans for district heating

1 Sept 2023
Topic — EU regulation on climate-neutrality plans for free emission allowances under ETS revision.
Message — PGE requests allowing joint climate-neutrality plans for multiple installations owned by the same entity, flexibility to adjust plans as market conditions change, and realistic timelines with detailed milestones starting from 2030 rather than 2025. They also want natural gas cogeneration explicitly recognized as a decarbonization pathway.1234
Why — This would reduce administrative burden and give them more time to plan investments.567
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PGE Warns Against Overcomplicating EU Modernisation Fund Rules

29 Aug 2023
Topic — The consultation addresses updated rules for operating the EU's energy transition Modernisation Fund.
Message — PGE requests that public consultation should not impact the decision on financing from the Modernisation Fund. They argue against five-year limits on schemes and renewing applications yearly to avoid financial risk. The company also insists that rules should not set any new requirements retroactively for projects.123
Why — Eliminating these rules would provide PGE with greater long-term planning and financial predictability.4
Impact — Local communities lose influence as their opposition would not affect project funding decisions.5
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PGE Advocates for CCS Support in Power and Heating

8 Aug 2023
Topic — The initiative assesses how carbon capture technologies can help decarbonize the European economy.
Message — PGE requests that CCS support includes the power and district heating sectors. They urge the Commission to fund CO2 transport infrastructure across the Union. Finally, they suggest a certification system for negative emissions under the ETS.123
Why — This enables PGE to maintain gas-fired plants while avoiding high carbon prices.45
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PGE urges phase-in of new EU sustainability reporting rules

5 Jul 2023
Topic — Consultation on draft standards for company sustainability and environmental reporting disclosures.
Message — PGE calls for a gradual phase-in of reporting requirements and audit obligations. They suggest refining standards and clarifying vague metrics to ensure better data quality.12
Why — The company would avoid facing disproportionate financial and organizational costs from sudden, complex requirements.34
Impact — Investors and regulators lose the ability to easily compare environmental data between different companies.5
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PGE backs 80% climate target while warning against stricter limits

23 Jun 2023
Topic — The EU is developing a 2040 emissions reduction target to reach climate neutrality.
Message — PGE supports a 75-80% reduction target but rejects goals exceeding 80%. They want the burden balanced across the economy and continued free carbon allowances.123
Why — Lowering the target helps the company avoid excessive investment costs and price volatility.45
Impact — Consumers and farmers would face higher heating bills and rising food prices.67
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PGE Urges EU to Include Nuclear and CCU as Strategic

21 Jun 2023
Topic — The consultation concerns a proposal to scale up European manufacturing of net-zero technologies.
Message — PGE requests the inclusion of nuclear energy and carbon utilization as strategic technologies. They also recommend making carbon capture targets indicative rather than fixed.12
Why — This would enable PGE to secure regulatory support for its diverse energy portfolio.3
Impact — Member States face potential financial uncertainty regarding the allocation of their national carbon revenues.4
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PGE Urges EU Support for Large-Scale District Heat Pumps

25 May 2023
Topic — The initiative addresses barriers to heat pump deployment to meet European Green Deal targets.
Message — PGE requests support for large-scale and high-temperature heat pumps in district heating systems. They also propose removing fees for using water bodies as ambient heat sources. Regulations should recognize these technologies as tools for electricity grid flexibility and stability.123
Why — Integrating heat pumps into existing networks would lower investment and decarbonization costs.45
Impact — Consumers may face higher installation costs due to strict new refrigerant regulations.6
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Response to Interservice consultation on the electricity market design reform - REMIT

22 May 2023

The PGE Group would like to highlight the following issues with regard to the proposed changes in the Regulation on wholesale energy market integrity and transparency and the Regulation establishing a European Union Agency for the Cooperation of Energy Regulators: 1. The proposal does not provide for a clear and precise determination of the amount of losses for electricity and natural gas that qualify for the obligation to publish insider information. This issue is being raised continuously by market participants but has not been addressed in the proposal. The proposed changes to Regulation 1227/2011 (REMIT Regulation) in Article 1 point [2] [a] and Article 1 point [2] [b] regarding insider information do not address the above mentioned issue. What is more the changes proposed to the definition of insider information in Article 1 point [2] [a], in our opinion, do not specify the concept of insider information at all and may cause even greater problems with its interpretation. Additionally the definition of a person professionally arranging or executing transactions as proposed in Article 1 point [2] [h] is not precise. Based on this definition it is difficult to qualify entities as being PPAT or not. 2. The proposal does not introduce an end of any responsibility for reporting of a market participant as soon as relevant data is transferred to Registered Reporting Mechanism (via an entity approved and indicated by ACER charging reporting fees). This issue should be addressed in relevant changes to Commission Implementing Regulation (EU) No 1348/2014 on data reporting implementing Article 8(2) and Article 8(6) of Regulation (EU) No 1227/2011 of the European Parliament and of the Council on wholesale energy market integrity and transparency. 3. The proposal does not introduce a change regarding the entities obliged to publish fundamental data mentioned in Article 8 of REMIT Regulation. This data should only by published by Transmission System Operators, Storage System Operators, LNG Storage Operators and Distribution System Operators. 4. The proposal needs clarification regarding the definition of consumption capacity and the definition of final customer in order to state whether that customer becomes a market participant under the REMIT regulation. This definition should also focus on the issue of a single economic entity exerting a joint influence on the wholesale energy market prices due to being located in different relevant geographical markets. Currently the REMIT regulation lacks guidance on how to calculate this joint influence. Additionally end customers should be excluded from the reporting obligation, regardless of their consumption capacity. This however necessitates a precise specification whether, in case end customers are excluded from the reporting obligation, energy traders are obliged to obtain from end customers declarations on the use of purchased electricity only for their own use and whether the end customer, regardless of his consumption capacity, automatically becomes a participant in the wholesale market in case he indicates that he resells the purchased electricity. 5. The proposal does not introduce an obligation of public consultations prior to adopting important decisions by ACER related to REMIT e.g. publication of guidelines. Such an obligation should be included in the proposal as it would not only enhance market transparency but would also allow market participants to get acquainted with ACERs decisions in advance and would allow market participants to enter into dialogue with ACER regarding those decisions.
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Polish energy giant PGE urges SF6 equipment phase-out delay

25 Apr 2023
Topic — EU consultation on technical criteria for environmentally sustainable activities in financial investments.
Message — PGE calls for a phase-in period regarding the ban on SF6 gases in electrical equipment. They state the transition must be realistic to protect grid reliability and supply security.12
Why — Maintaining existing equipment would avoid operational risks and protect against tariff spikes.3
Impact — Energy consumers face potential price hikes if transition costs are passed through tariffs.4
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Meeting with Róża Thun Und Hohenstein (Member of the European Parliament)

18 Apr 2023 · The future of energy situation, plans and problems to achieve the Fit For 55

Meeting with Nicolás González Casares (Member of the European Parliament, Rapporteur) and E.ON SE and European Network of Transmission System Operators for Electricity

18 Apr 2023 · Electricity Market Design

Meeting with Maria da Graça Carvalho (Member of the European Parliament, Shadow rapporteur)

18 Apr 2023 · Electricity Market Design

Meeting with Carlos Zorrinho (Member of the European Parliament)

18 Apr 2023 · electricity market design

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur) and Euroheat and Power and The European Association for the Promotion of Cogeneration

14 Feb 2023 · Staff member attended event 'Decarbonizing heat: the key to Europe’s energy independence'

Meeting with Jens Gieseke (Member of the European Parliament)

14 Feb 2023 · Austausch zur Europapolitik

Response to Amendment to Registry Regulation

13 Feb 2023

1) OTC transactions data The data on the bilateral transactions on the OTC market should be further harmonized across EU and made available for the relevant competent authorities. This would ease the cooperation, e.g. where the verification of the operators transactions and/or financial situation is required. 2) Omnibus accounts The proposed amendments should also improve the transparency and data access for European Securities and Markets Authority (ESMA) to the omnibus accounts of the financial entities. ESMA has already signaled in its report from 28 March 2022 that in case of some financial entities, the data from the Union Registry does not allow to distinguish between omnibus and own accounts. The changes should allow to identify the ultimate beneficial owners of the allowances, or at least collect the relevant data about them (e.g. about the institution type and its origin country) by ESMA. In the above-mentioned report, ESMA (section 5.8) encourages the timely implementation of the requirement for the identification of accounts holders with LEIs, as well as to increase the harmonization of the data in line with the standards and structures used in regulatory reports under MiFID/EMIR and invites the Commission to consider assessing defining assets protections rules when accounts in the Registry are used as omnibus accounts.
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Meeting with Patrizia Toia (Member of the European Parliament) and Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien

10 Feb 2023 · Packaging and Packaging Waste Regulation (meeting taken by the assistant responsible)

Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

8 Feb 2023 · To discuss the Electricity Market Design Reform

Response to Review of cogeneration reference values

29 Dec 2022

PGE Polska Grupa Energetyczna S.A. (hereinafter: PGE S.A.) welcomes the Commissions proposal to amend Delegated Regulation (EU) 2015/2402 of 12 October 2015 reviewing harmonised efficiency reference values for separate production of electricity and heat in application of Directive 2012/27/EU (hereinafter: HRV Regulation). Please find attached a detailed position of PGE S.A. on the most relevant aspects included in the Commissions proposal.
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Meeting with Bas Eickhout (Member of the European Parliament) and Google and

29 Nov 2022 · Politico's Sustainable Future Week 2022

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

29 Nov 2022 · Emissions Trading System and Just Transition Fund

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Response to Review of the de minimis aid Regulation

25 Jul 2022

PGE Polska Grupa Energetyczna S.A. response to the public consultation on exemptions for small amounts of aid (de minimis aid) PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE”) welcomes the opportunity to share views on the revision of the Commission Regulation (EU) No 1407/2013 of 18 December 2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid (hereinafter: “de minimis Regulation”). PGE supports the main reason for reopening de minims Regulation i.e. the need to adjust the ceiling of EUR 200 000 as the amount of de minimis aid to the current situation including the unpreceded inflation and the vast increase of the investment costs caused by interruption of supply chains as the result of the Russia’s invasion of Ukraine. It is an extraordinary situation for economic entities - some of the trade and supply channels have not yet been rebuilt after the COVID-19 pandemic, and now companies have to deal with the consequences of the conflict in Eastern Europe. The new ceiling should reflect not only the inflation rate - differing substantially among the EU member states, but also , ahead of the upcoming winter, the State aid rules need to be relaxed to give sufficient instruments to overcome the results of the economic and energy crisis. For the sake of coherence among State aid rules, the level of the new ceiling under de minimis Regulation should be adjusted to the Temporary Crisis Framework for State Aid as adopted in March 2020 stated the maximum cap for schemes of limited amounts of aid to be EUR 1.8 million per undertaking, which was further extended to EUR 2.3 million in November 2021. Taking from this example, PGE suggest extending the de minimis threshold up to EUR 1 800 000 to a single undertaking over any period of three fiscal years indexed by the EUROSTAT inflation rate. Moreover, since vertically integrated utilities conduct activities, which are not in a competitive relationship such as energy generation, trading and distribution in some cases, it should be allowed for different companies within the same capital group to separately calculate State aid amounts up to the de minimis threshold. This practice would better reflect the reasoning of the CJEU presented in the Case C-882/19 [Sumal, S.L. v Mercedes Benz Trucks España, S.L.], which shows that the companies that may constitute an economic unit may be very different from one group to another and the activity of the subsidiary companies is not always inextricably linked. This would increase investment opportunities in key technologies and provide the appropriate and necessary flexibility in terms of swift developing of different technologies. It will also speed up the development of renewables and strengthen the energy independence from the imported fossil fuels.
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Response to Regulation on REPowerEU chapters

19 Jul 2022

PGE S.A. would like to thank for the opportunity to provide its feedback on the Regulation of the European Parliament and of the Council amending Regulation (EU) 2021/241 as regards REPowerEU chapters in recovery and resilience plans and amending Regulation (EU) 2021/1060 , Regulation (EU) 2021/2115, Directive 2003/87/EC and Decision (EU) 2015/1814. Please find attached our response to the public consultations.
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PGE Polska Grupa Energetyczna Urges Flexible District Heating Targets

11 Jul 2022
Topic — The consultation addresses barriers to renewable energy projects and Power Purchase Agreements.
Message — PGE requests that higher climate targets do not increase goals for large district heating systems. They also propose counting renewable electricity as heat and suggest penalties for slow permitting authorities.123
Why — This allows the company to avoid technically unfeasible investments in their existing large-scale heating networks.4
Impact — Environmental groups may lose protections if economic costs are prioritized over nature conservation.56
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Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)

7 Jul 2022 · EPBD

PGE Poland urges EU to maintain flexible industrial emission limits

23 Jun 2022
Topic — This consultation concerns the revision of EU rules governing industrial emissions.
Message — PGE requests maintaining flexible emission ranges instead of enforcing the strictest limits. They argue against frequent permit reviews and propose that operators determine optimal levels.123
Why — PGE would avoid massive capital investments and significantly lower compliance costs.45
Impact — Local residents and advocacy groups lose expanded legal rights to seek health compensation.67
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Meeting with Marek Belka (Member of the European Parliament)

7 Jun 2022 · Meeting with Wanda Buk (Vice-President of the Management Board of PGE) on taxonomy

PGE Group calls for reduced burden in sustainability directive

23 May 2022
Topic — This consultation addresses the proposed EU directive on corporate sustainability due diligence obligations.
Message — PGE calls for a reasonable administrative burden by aligning requirements with existing reporting regulations. They suggest leaving climate aspects for separate legislation to ensure a more coherent framework. The group also proposes distinguishing between comprehensive requirements for direct and indirect suppliers.123
Why — Limiting the scope would help the company avoid overwhelming administrative and resource costs.4
Impact — Environmental goals are undermined if companies are not required to adopt climate transition plans.5
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Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

18 May 2022 · To to discuss the ‘Fit for 55’ Package and, more specifically the proposed revision of the Energy Performance of Buildings Directive

PGE Polish Energy Group Urges Proportional Methane Emission Rules

15 Apr 2022
Topic — EU legislation regarding monitoring, reporting, and verification of methane emissions in energy.
Message — PGE requests narrowing the operator definition to exclude households and consumers. They advocate for lower reporting frequency and exemptions for closed mines.12
Why — Fewer reporting requirements would significantly reduce administrative burdens and technical costs.3
Impact — Climate monitoring efforts suffer if reporting is suspended or certain mines exempted.4
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and EUROPEAN TRADE UNION CONFEDERATION

14 Apr 2022 · ETS Revision

PGE Urges Grid Upgrades and Relaxed Wind Permitting Rules

12 Apr 2022
Topic — Consultation on accelerating renewable energy project permitting and Power Purchase Agreement facilitation.
Message — PGE calls for increased grid infrastructure funding and rules enabling cable pooling for installations. They recommend relaxing minimum distance requirements for wind farms and exempting agreements from procurement laws. Improved market liquidity is also sought to reduce financial risks for long-term contracts.1234
Why — These changes would allow PGE to overcome current investment barriers and reduce hedging costs.56
Impact — Local residents and transparency advocates lose protections from distance regulations and public procurement oversight.78
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Meeting with Michael Bloss (Member of the European Parliament)

5 Apr 2022 · ETS

Meeting with Morten Petersen (Member of the European Parliament)

5 Apr 2022 · Fit for 55 Package

Meeting with Mohammed Chahim (Member of the European Parliament, Rapporteur) and The European Steel Association

5 Apr 2022 · CBAM

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur)

4 Apr 2022 · Gas storage regulation

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

25 Mar 2022

PGE Polska Grupa Energetyczna S.A. (hereinafter: "PGE S.A.") acknowledges revising the provisions on the energy performance of buildings (hereinafter: "EPBD") as another important element of climate and energy policy leading to the achievement of climate neutrality of the European Union by 2050. Buildings account for 40% of energy consumed and 36% of direct and indirect greenhouse gas emissions associated with energy supply in the EU. It is therefore advisable to create an appropriate legal framework that allows the building sector to make a greater contribution to new greenhouse gas reduction targets. Yet on the other hand, any new requirements should primarily be achievable by all Member States, taking into account their different starting points and characteristics of energy supply. In Poland, there is a very large potential for modernisation of the individual heating sector, which accounts for approximately 75% of heat consumed in Poland. Bearing in mind the need to minimise air pollution and improve its quality, the Polish Government has adopted the objective of limiting the use of solid fuels in individual heating systems. One of the priorities is to move away from coal combustion in households in cities by 2030, and in rural areas by 2040. Given the role of district heating in Central and Eastern European as well as in Scandinavian countries, it is crucial for the new EBPD provisions to enable greater use of district heat from efficient district heating and cooling systems, including heat generated in high-efficiency cogeneration. District heating produced in efficient district heating systems as well as heat from high-efficiency cogeneration should provide a tool for the gradual decarbonisation of building sector, eliminating low-stack emissions and inefficient individual heating sources. For that reason, PGE S.A. encourages to enable connecting new buildings to every efficient district heating system after 2030, not only to those based on renewable energy and waste heat. In the opinion of PGE S.A., implementation of overarching climate objectives in the building sector should not lead to the risk of failure to ensure peak winter demand in the heating sector in Member States and regions with low external temperatures and more demanding climate conditions. However, it may eventually happen if new provisions are to become effective as proposed by the Commission. Both criteria and timeframe, particularly for new buildings, will be extremely difficult to implement technically, especially in large urban agglomerations supplied with heat by district heating systems with centralised generation capacities of several hundred megawatts. Consequently, costs of constructing buildings would increase significantly and the possibilities of connecting new users to existing district heating systems, which in 2030 would not be fully based on renewables or waste heat, would be significantly reduced. In this sense, PGE S.A. stresses the need to maintain consistency in all legislative proposals currently under discussion, which together will have a cumulative impact on the district heating sector. PGE S.A. also draws attention to the impact of the new EPBD provisions on the operation and development of electricity distribution grids, including the market for flexibility services and the role of electricity within national electricity grids in the context of implementing new objectives for building sector. Please find attached a detailed position of PGE S.A. on the most relevant aspects included in the Commission’s proposal.
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Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

17 Mar 2022 · Fit for 55 package and Just Transition Fund

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

17 Mar 2022 · Fit-for-55

Meeting with Pascal Canfin (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Mar 2022 · Fit for 55

Meeting with Marian-Jean Marinescu (Member of the European Parliament)

9 Mar 2022 · Fit for 55

Meeting with Franc Bogovič (Member of the European Parliament)

8 Mar 2022 · Meeting on energy prices and FF55

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

8 Mar 2022 · RePowerEU

Meeting with Bogusław Liberadzki (Member of the European Parliament)

8 Mar 2022 · Exchange of views

Response to Revision of the Energy Tax Directive

16 Nov 2021

Position of PGE Polska Grupa Energetyczna S.A. on the proposal for a recast of the Council Directive 2003/96/EC of 27 October 2003 restructuring the Community framework for the taxation of energy products and electricity • The revision of Council Directive 2003/96/EC of 27 October 2003 restructuring the Community framework for the taxation of energy products and electricity leads to a significant increase in the excise duty burden for cogeneration. This is due to the fact, that the European Commission's (hereinafter: "EC") proposal does not apply, as is currently the case, an optional exemption from excise duty of energy products and electricity used in the processes of combined electricity and heat production. These changes will increase the price of heat and electricity produced in cogeneration and result in additional distributional effects borne by households. Therefore, we call on the Council to modify the Commission’s proposal by allowing the exemption from taxation for electricity and energy products used to produce heat and electricity in cogeneration. • Linking the possibility of exemption from taxation to fulfilment of the criteria for high-efficiency cogeneration and efficient district heating, in the light of the proposed amendments to the EED, is a further burden on the sector and consumers and appears to contradict the present approach of the European Commission promoting cogeneration. Therefore, we call on the Council to allow the exemption from taxation of electricity and heat to apply also for those units which currently meet the definition of high-efficiency cogeneration, regardless of any future changes to this definition (grandfathering). • The transitional periods in the proposed formula often contain the same rate of taxation at the end of the transitional period as at the beginning, while representing a significant increase in taxation over the present situation. These periods should be extended. In addition, the rates should be more differentiated. At the beginning of the transitional period the rates should correspond to current levels to avoid further price shocks and should gradually increase to the target level. • The Commission’s proposal allows Member States to apply tax exemptions or reductions for certain types of energy. In our opinion, in order to really promote environmentally friendly technologies, these exemptions should not be optional, with the decision left to the Member State, but mandatory. This will guarantee both producers and consumers that the regulatory environment will not change abruptly. • The annual indexation of tax rates based on the harmonised index of consumer prices excluding energy and unprocessed food published by Eurostat will contribute to further increases in energy prices, which are currently reaching record levels. Drastic increases in energy costs are already being felt and constitute a significant burden on industry and households, and the new taxation rules will accelerate this. For this reason, the abandonment of the indexation of tax rates should be considered. • It should be borne in mind that the revised taxation rules will hit end consumers, consumers in households, and that the mechanisms to protect consumers may be insufficient in low-income Member States. Please find attached a detailed position of PGE S.A. on the most relevant aspects included in the Commission’s draft proposal.
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Response to Review of Directive 2012/27/EU on energy efficiency

12 Nov 2021

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the recast of the Directive 2012/27/EU of the European Parliament and of the Council on energy efficiency (hereinafter: “EED”) as an opportunity for a reasonable adaptation of the current regulations to the Union’s climate neutrality objective by 2050. For that reason, the new EED provisions should prove further the leading role of Member States in establishing the agenda for energy efficiency measures and the need to recognize the role of low-carbon high-efficiency cogeneration in the district heating sector. It remains a key aspect for countries like Poland, facing the biggest challenges related to coal phase-out in district heating systems and the need to increase the share of renewables in its energy mix. New definition of an “efficient heating and cooling system” as proposed by the Commission will have a tremendous impact on district heating systems, especially those based on natural gas high-efficiency cogeneration. The Polish specificity pertains to the fact that urban agglomerations are covered by large-scale district heating systems with high production capacities (i.e. hundreds of megawatts of ordered thermal capacity). Nearly 6 million households in Poland, out of a total of around 14 million, use this type of heating. High-efficiency cogeneration, mainly based on natural gas or biomass, is the most preferred technology due to Poland’s weather conditions, required temperature parameters and high capacities of district heating systems, which cannot be fully replaced with low-temperature renewables. For existing efficient district heating systems, an adequate transition period should be introduced for adapting to the new requirements in order to avoid that these systems suddenly lose their status. In this context, it is crucial to address the specificities of large heating systems since in most cases it will not be technically feasible to achieve the proposed shares of renewable energy and waste heat. At the same time, these systems should not be deprived of their efficient status. PGE S.A. proposes to maintain the key role of the share of cogeneration and high efficient cogeneration and to make the milestones and the shares of renewable heat and waste heat more realistic. The combined production of heat and electricity in high-efficiency cogeneration is pivotal for obtaining primary energy savings and high generation efficiency, which directly means meeting the overarching objectives of the directive. PGE Capital Group is currently carrying out investments related to the replacement of coal-fired heating units with high-efficiency natural gas cogeneration plants. This investment programme will not be fully implemented until 2030. Introduction of the limit of direct CO2 emissions for units using fossil fuels, as proposed by the Commission, as of January 1, 2026, threatens the implementation of this programme, since it is not possible to complete all investments by the end of 2025. Failure to meet the new criterion may put at risk the financing possibilities and, consequently, delivering uninterrupted heat supply to end users, including industrial and vulnerable ones affected with energy poverty. That being the case, PGE S.A. calls for the introduction of appropriate transitional period, which means that the new definition should not be applied earlier than from 2030. Moreover, the proposal lacks the methodology on calculating emission threshold acknowledging specificities and distinctive conditions of operation of cogeneration units. Please find attached a detailed position of PGE S.A. on the most relevant aspects included in the Commission’s proposal.
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Response to Revision of Alternative Fuels Infrastructure Directive

9 Nov 2021

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the draft Regulation of the European Parliament and of the Council on the deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU (hereinafter: "AFIR proposal") as an important element of the “Fit for 55” legislative package and one of the key milestones to achieve climate neutrality by 2050. PGE S.A draws attention to the following key issues including the impact of the AFIR proposal on the PGE’s Capital Group distribution company – PGE Dystrybucja S.A. (hereinafter: "DSO"). First of all, the need for greater electrification of the economy where possible (stationary aircrafts, ports, public transport), as raised in the Art. 9-13 of the AFIR proposal, is the right direction for “hard to decarbonise” sectors. However, the newly proposed obligations regarding a minimum coverage of publicly accessible recharging points dedicated to light and heavy-duty vehicles on the road network translate i.a. directly into increased expectations on distribution system operators (DSOs) to connect recharging points, which will consequently affect distribution system in terms of additional investment cost and its functioning on the daily basis. Therefore, implementation of the tasks resulting from the proposed AFIR regulation should not result in excessive obligations for DSOs. According to the Electricity Market Directive (hereinafter: "EMD"), priority in developing the necessary recharging infrastructure for electric vehicles should be given to fully market-based players. Taking into account the objectives for the expansion of the recharging network (publicly accessible recharging points) proposed in the AFIR proposal, a detailed and multi-variant analysis of the preparation of the electricity network for the implementation by DSOs of potential tasks resulting from the AFIR proposal is necessary. Unfortunately, such an analysis is not provided by the impact assessment of the AFIR proposal. The Commission proposes in the Art. 5 of the AFIR proposal greater freedom in the range of authentication methods and payment systems, which should create a more competitive market. Art. 14 of the AFIR proposal refers to assessing the potential of electric vehicles to contribute to the flexibility of the electricity system, including considering bi-directional electricity flows. In this respect, the requirements for the assessment by the national regulatory authorities will entail the need to define the processes for collecting the relevant data, as well as the catalogue and the origin of such data. Principal issues, such as determining the area-based connectivity and efficient operation of the system should remain to be addressed at national level. Monitoring of progress (Art. 14 and 15, Annex I) will be based on the national policy framework (Art. 13) for the development of the market for alternative fuels in the transport sector and the deployment of the relevant infrastructure. In this process, the impact of the new regulation on the electricity distribution network should be considered. At the same time, there is a need to ensure the provision of real-time information on alternative fuels infrastructure, taking into account new digital services, and the integration of electrical vehicles with the electricity network (the so-called smart data ecosystem). The missing element here seems to be provisions addressing the cyber security of recharging installations, which tremendous role increases with the scale of digitisation and dependence of elements of the entire system. Please find attached a detailed position of PGE S.A. on the most relevant aspects included in the proposal.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

9 Nov 2021

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the revision of the Directive on the promotion of the use of energy from renewable sources as a prerequisite to further streamlining green energy in the pursuit to achieve climate neutrality by 2050. With a new Union’s target of at least 40% of renewable energy in gross final energy consumption by 2030, we believe that there is still room for improvements and enablers to reach it. In any case, in our view, district heating sector should be considered with a special attention. By 2030, biomass potential will be limited due to new sustainability criteria while deploying heat pumps or concentrated solar power at scale has also constraints in large systems. To facilitate the uptake of renewables in heating and cooling as well as in district heating and cooling, it is necessary to introduce a mechanism to calculate renewable electricity as renewable heat while ensuring that no double counting of renewable electricity takes place. In our view, neither effective directive nor draft proposal does not allow that. These changes would fit for a wider promotion of the electrification of heating and district heating. The Commission proposed to increase the indicative annual growth of the share of renewable energy in the district heating and cooling to 2.1 pp. in the period 2021-2025 and 2026-2030, without the possibility of choosing a different way for fulfilling this obligation. We support maintaining the indicative nature of the target, however taking into account the specificity of the operation of heating systems in Poland, in particular those based on natural gas cogeneration, we believe that the target should not be arbitrarily changed and its non-binding nature should be maintained. Achieving an increase other than 1 pp. annually in the period of 2021-2025 is not technically feasible. Moreover, any potential changes of this target for the period 2026-2030 should be decided not earlier than in 2025 provided that the possibility to count renewable electricity towards heating and district heating target is introduced. Further restrictions of sustainability criteria, a cascading principle, and a proposal of granting no support to electricity-only installations using biomass are excessive. Biomass is one of the block’s key renewable energy sources and with the current criteria, there are already robust grounds to ensure that biomass for energy purposes is obtained without causing a significant harm to the environment. PGE S.A. supports facilitating the uptake of power purchase agreements being an alternative for existing support schemes. Yet, the Commission’s proposals on joint renewable energy projects are insufficient as they do not reflect the realities of such projects, in particular offshore wind farms. For example, we believe that it is worth to consider amending the definition of such projects to include those within international consortia or joint ventures, i.e., without the physical connection of the Member States involved. Please find attached a detailed position of PGE S.A. on the most relevant aspects included in the Commission’s draft proposal.
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

9 Nov 2021 · RED III

Polish energy giant urges EU carbon market reforms to enable transition

8 Nov 2021
Topic — Revision of EU emissions trading system directive and market stability reserve.
Message — The company requests increasing the Modernisation Fund proportionally to higher climate ambition, maintaining natural gas eligibility for district heating, and reconsidering the heat benchmark increase from 1.6% to 2.5% annually. They argue current proposals create structural imbalances where investment needs exceed national EU ETS revenues.123
Why — This would provide more allowances to finance their transition to 50% renewable energy by 2030 while reducing carbon compliance costs that currently exceed €2.5 billion annually.45
Impact — Polish households face €110 billion in additional costs if carbon market imbalances aren't addressed and allowance shortfalls force domestic investment financing.67
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PGE urges EU to prevent carbon price surge from market stability reserve changes

5 Nov 2021
Topic — EU proposal to modify market stability reserve rules for carbon trading scheme
Message — PGE requests that allowances in the reserve be used to stabilize prices rather than cancelled, and that member states with structural deficits access MSR allowances to finance energy transition. They oppose combining the increased linear reduction factor with additional cap reductions.123
Why — This would reduce compliance costs and prevent carbon prices rising beyond assumed levels.45
Impact — Environmental advocates lose stronger carbon market scarcity measures that drive faster decarbonization.6
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

The PGE Group would like to highlight the following issues with regard to the proposed revision of the Non-Financial Reporting Directive (NFRD). 1. We welcome the extension of the scope of the Corporate Sustainability Reporting Directive (CSRD) to all large companies, which in our opinion will allow for the creation of level-playing field. 2. The reporting obligations which are being introduced in the CSRD (Art.19a and Art.29a) will be very burdensome for companies. These obligations will have an organizational and financial impact for companies as they will imply significant changes in the process of data collection and processing and in the corporate structure of companies. This is especially true in case of large capital groups with many subsidiaries. Such changes are necessary – however their implementation should take place in a sustainable way. The revision of NFRD should not lead to disproportionate reporting obligations for companies, especially if the value added of these obligations for the users is minimal or absent. 3. Additionally the proposal requires companies to provide forward-looking information and information about the past in relation to sustainability matters. The proposal does not contain information regarding the length of the period for which retrospective and forward-looking reporting has to be done. The general statement in the proposal about “short, medium and long-term time horizons” (Art. 19a, par.3; Art. 29a, par.3) does not allow companies to conclude about the length of such a period. Therefore a clear period should be indicated for which companies should provide information in relation to sustainability matters. 4. Additionally the proposal requires companies to report information on sustainability of their value chain, their business relationships and their supply chain. This obligation is especially burdensome and complicated as it will require companies to investigate sustainability aspects of their business relationships and their supply chains. In this case a phase-in approach should be applied which would allow companies to phase-in step-by-step the reporting regarding issues described in Art.19a and Art.29a of the proposal with reporting covering business relationships of the company and its supply chain in the last step. 5. Reporting information on intangibles (Art. 19a par. 2, Art.29a par.2) is very problematic. Intangibles are very hard to define and to measure and an obligation to report them adds excessive burden to the companies. Therefore this obligation is undesirable or at best premature. It should either be removed or considered to be included in the CSRD in the coming years – this would allow companies to adequately prepare for the reporting of intangibles. 6. In case of statutory audit and assurance a phase-in approach should be applied. Such an approach would allow companies to adequately prepare for the new reporting obligations. It would also allow assurance practices for sustainability information to develop properly. 7. The CSRD proposal should be coherent and consistence with the EU Sustainable Finance framework so as not to leave room for ambiguities. Therefore links between the CSRD proposal and this framework should be accounted for. Additionally the CSRD proposal should take into account not only the development of the EU Sustainable Finance framework but also the ongoing legislative process with regard to legislation related to this framework.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

The PGE Group would like to highlight the following issues with regard to the draft Delegated Regulation: 1.The definitions of the economic activities listed in Table 1, Table 2 and Table 3 in Annex II of the draft Delegated Regulation should be aligned with definitions of economic activities used in Article 2 of the draft Delegated Regulation, as at the moment, there are inconsistencies between these definitions. The definitions in Article 2 distinguish between “Taxonomy-aligned”, “Taxonomy-eligible” and “Taxonomy-non-eligible” activities. On the other hand in Table 1, Table 2 and Table 3 in Annex II the category of “Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)” is introduced, which is not explicitly defined in Article 2 of the draft Delegated Regulation. 2.The reporting obligation mentioned in Article 11 of the draft Delegated Regulation which concerns reporting in the year 2022 for the year 2021 should not cover the four remaining environmental objectives (Article 9 of the Taxonomy Regulation). This should be explicitly stated in the draft Delegated Regulation. The reporting obligation should cover these environmental objectives only after the Delegated Regulation covering technical screening criteria for these objectives will be published. 3.The reporting requirements under Article 9, paragraph 3 should not be applied retrospectively in the sense that the obligation to report KPIs covering previous five reporting periods should not apply to reporting periods before the year 2022. The Delegated Regulation should clearly state the starting date of this obligation. 4. In our view Introducing in the CapEX plan (Annex I, point 1.1.2.2) a limit of 5 years (which in some circumstances can be extended to 7 years) with regard to the expansion of the undertaking's Taxonomy-aligned economic activities is not justifiable and does not fit with the investment horizon of many companies, whose planning and investment horizon is much longer - especially those one which will transition themselves to climate neutral ones. Additionally the CapEX should not be disclosed as it may contain strategically sensitive projects and confidential aspects that cannot be disclosed prematurely. 5. In our opinion the requirement of reporting KPIs for each economic activity (Annex I, point 2, (b)) is very hard to fulfil in case of energy utilities as for some of their activities e.g. Combined Heat and Power production a disaggregation of economic activities is very difficult if not impossible. Therefore flexibility should be granted to each individual company when assessing whether such a disaggregation is fully possible, and thus, in some cases, the disclosure of KPIs per economy activity should not be mandatory. 6. Furthermore the requirement of reporting KPIs for each environmental objective as well as total at undertakings or group level (Annex I, point 2, (c)) adds additional administrative burden and is not justified by the purpose of the Taxonomy regulation. In our opinion investors are predominantly interested whether or not an activity is Taxonomy-aligned or not and to a much lesser extent to which of the environmental objectives the activity is contributing. Therefore reporting of KPIs for a total of the environmental objectives should be sufficient. 7. The requirement of identifying, in case of Taxonomy-eligible economic activity, the proportion of that activity that is Taxonomy-aligned (Annex I, point 2, (d)) only adds additional burden and is not justified by the purpose of the Taxonomy regulation. It will be very hard for companies to understand and apply the EU Taxonomy and any additional obligation will only add more burden. Therefore demanding from companies that, besides the obligations imposed on them by the Delegated Regulation, they should identify how much of their Taxonomy-eligible activities is Taxonomy-aligned is unnecessary and undesirable.
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Response to Guidance on REDII forest biomass sustainability criteria

26 Apr 2021

PGE Polska Grupa Energetyczna S.A. (hereinafter: PGE) welcomes the opportunity to provide feedback on the draft Implementing Regulation on establishing operational guidance on the evidence for demonstrating compliance with the sustainability criteria for forest biomass (hereinafter: draft regulation) laid down in Article 29 of Directive (EU) 2018/2001 of the European Parliament and of the Council (hereinafter: REDII). PGE is the leading utility operating in the Polish electricity and heat sector. Thanks to the combination of its own fuel resources, energy generation and distribution grids, PGE guarantees a safe and reliable power supply to over 5 million households, businesses and institutions as well as heat supply to ca. 2 million customers. PGE perceives biomass, accounting for 60% of renewable generation in the EU, to be still a relevant element in the energy transition and decarbonisaton of heat supply, if proving sustainability as stated under Article 29 of REDII to ensure compliance with environmental protection of the most valuable sourcing areas. In our opinion, detailed provisions of the draft regulation go beyond elements of the REDII. When considering specific rules to ensure compliance with sustainability criteria, some requirements proposed in draft regulation tackle issues not addressed in REDII. In our opinion, the final regulation should strike a balance between taking into account the necessary REDII provisions and ensuring that economic operators do not bear excessive financial, organizational and administrative risks. The draft regulation should not aim at introducing a very restrictive criteria on national level. REDII provides for a set of measures that need to be included in order to prove necessary compliance with sustainability criteria. According to REDII, if some criteria are established in the national legislation, further evidence is not required. On the other hand, if some criteria are not established in specific Member State, more detailed evidence must be provided by economic operators. The same pertains to relevant level of monitoring to be established under national legislation. We believe that it is not an economic operator who should be responsible for carrying out this assessment. At the same time, the draft regulation does not fulfill provisions established in Article 30(8) of REDII, since it does not set any possible timeframe for the voluntary or national schemes. Furthermore, in our view, there are no proposals intending to minimize administrative burdens which inevitably is to increase significantly. On the contrary, Recital 8 and Article 6 of the draft regulation, obliges economic operators to provide additional evidence of the existence of management systems at the sourcing area level where compliance with the LULUCF criteria cannot be demonstrated. According to Recital 6 and Article 4 of the draft regulation, if a specific Member State does not present measures and solutions applied in the form of national schemes, it is the responsibility and obligation of economic operators to use international voluntary schemes. They are also to provide a robust audited documentation regarding forest biomass. PGE would like to highlight that abovementioned issues lead to taking a very high risk by economic operators since they are dependent on measures taken by external actors. At the same time, multiple assessment schemes of the sourcing areas threatens the compliance certainty and stability. What also should be stated in the final regulation are the responsibilities and task-sharing when developing the wide risk-based assessment of forest management legislation. According to Recital 5 and Article 3(1) this assessment is on economic operators. In our view this task should be carried out in cooperation with national authorities.
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

2 Apr 2021

PGE Polska Grupa Energetyczna S.A. position on the proposal of roadmap to revision of Commission Regulation No 651/2014 (GBER) 1. In general we believe that the Regulation has performed its role well and we welcome the proposal to amend it to reflect technological progress, market changes and the new political priorities of the European Union. To achieve these priorities, it is necessary to create favorable conditions for the energy transformation, especially in regions that are currently heavily dependent on coal. 2. Experience with the application of the Regulation shows, that there’s a need for increasing notification thresholds for: o types of aid specified in Article 4 : (i) operating aid for the production of electricity from renewable sources; (ii) investment aid for energy infrastructure; (iii) investment aid for energy efficiency projects; (iv) investment aid for the district heating or cooling distribution network; (v) investment aid for environmental protection; o large aid schemes for renewable energy exceeding €150 million per year and granted on competitive bidding process basis. It is also necessary to increase the limit of the average annual budget of the schemes falling under GBER in the Member State concerned. The current level of financial thresholds for those activities is outdated and does not reflect the increased cost of the new investments. 3. When aid cannot be granted under the GBER and it needs to be notified, we consider it necessary to set up a fast-track procedure. 4. Moreover, we propose specifying in GBER operating aid for the production of heat from renewable sources as a new type of state aid within section 7: Aid for environmental protection, which would help to better address the goals of the Green Deal. 5. Additional aid intensity bonuses should be offered for carbon-dependent regions defined in accordance with NUTS-2 classification. The aid intensity may be increased by additional 5 percentage points (on top of regional bonus) for investments located in coal-reliant areas. Many investments in transition regions are already eligible for financing and state aid under normal conditions, but have not been undertaken since regular state aid conditions are intended for investments regardless of their location, and therefore are not satisfactory in regions under structural pressure. 6. The definition of "energy infrastructure" should be changed so that it reflects the current technical solutions and is consistent with the approach proposed in the Green Deal and the rapid development of energy storage. The obligation to notify the granting of aid in this respect should be removed and the definition of energy infrastructure has to be amended by removing provisions requiring storage facilities to be directly connected to high-voltage transmission grid. Since pumped storage hydroelectricity will play an important role in stabilizing the power systems, it requires favorable financing conditions. 7. We propose to remove the exemption from the provisions of section 1 of the GBER for regional aid for energy production, distribution and infrastructure (Art 13 (b) of GBER). We propose to resign from a similar exemption in the draft RAG guidelines. Alternatively we propose to change the way the costs eligible for environmental and energy aid are calculated – by allowing to qualify all investment costs without subtracting costs of counterfactual scenario. Energy sector is on the path of unprecedented transition. To speed up the process of transformation, in particular to replace plants fuelled with fossils with RES we find it crucial to loosen the State aid eligibility criteria – the main difference of regional aid and environmental one is the way the eligible costs are settled: for RAG – full investment costs and for EEAG by comparison with counterfactual scenario. We suggest enabling simpler calculation of costs for environmental/energy investment for the time of transformation.
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Response to Revision of the guidelines for trans-European Energy infrastructure

25 Feb 2021

PGE Polska Grupa Energetyczna S.A. (PGE) welcomes the opportunity to provide feedback on the draft Regulation on guidelines for trans-European energy infrastructure (TEN-E Regulation). We perceive the proposal as an opening to a discussion on adjusting the current provisions to better reflect new EU energy policy. Yet, new rules should focus more on facilitating projects already in place contributing to the EU climate agenda. We welcome the proposal of a coordinated approach to planning of the transmission network for each sea basin with a perspective until 2050 and new priority offshore grid corridors including the BEMIP offshore. Nevertheless, the draft TEN-E Regulation does not recognise as potential projects of common interest (PCIs) the investments related to the development of electricity transmission infrastructure from offshore wind farms connected radially, thus not creating a direct interconnection between the Member States. We believe that prioritizing only offshore grids for renewable energy having dual functionality of transmission and interconnection as well as traditional electricity interconnectors contradicts the ambitious objectives of the EU Offshore Renewable Energy Strategy since the majority of infrastructure will still base on radial connection. Acknowledging the key role of offshore electricity in decarbonisation of the EU, it seems justified that incentives should be directed to radial connection infrastructure as well. The draft TEN-E Regulation introduces some improvements for smart electricity grids projects. By now, only a few have been granted the PCI status. This aspect is of particular importance for projects developed by DSOs. New market conditions, energy sector decentralization and rapid increase of distributed energy sources (DER) should encourage local projects having positive system effects. Thus, cross-border criteria enabling smart distribution grid projects should be accompanied with suitable opportunities of data exchange. Grid bottlenecks due to local congestion and consequences of extreme weather increase as the EU systems and networks, even local ones, become more interconnected. Effective cooperation seems therefore crucial. Thus, we welcome the proposal to better balance the interests of ENTSO-E and to increase the role of ACER and the Commission while also acknowledging the role of the EU DSO Entity. However, in the context of smart electricity grids projects and those integrating DER as well as improving grid operations and system stability, PGE sees the possibility of increasing the role of DSOs engagement, which in the current proposal is still insufficiently reflected. Sector decentralization urges the need to relax the criteria in Annex IV which should also cover low- voltage as well as to remove the mandatory participation of TSOs with regard to DSOs projects. With a view of new challenges, both should be treated on equal footing. We would like to also point out the specific situation of pumped hydroelectricity storage (PHES). Storage projects in general are allowed to become PCIs, yet the proposal includes an explicit exemption of PHES projects from applying to CEF funding. PHES is a proven technology and may contribute to development of storage in next years. In our view, PHES as a source of flexibility should be brought to a larger context also with a view of revising the State aid package to provide for support for projects in line with environmental requirements but not profitable without support. While we welcome sustainability as a criterion for PCIs, we argue that sustainability and do no significant harm (DNHS) criteria should not undermine other objectives such as security of supply. Taking into account future developments of sustainable finance policy as well as technical screening criteria supplementing Art. 17 of Regulation (EU) 2020/852, this aspect may undermine the stability of a given PCI in terms of future compliance with DNSH condition.
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Response to State aid rules for Research, Development and Innovation

12 Jan 2021

PGE Capital Group welcomes the European Commission’s initiative to revise the existing State aid rules for research, development and innovation (RDI). In general, we consider the scope of revision initially indicated in the Roadmap as justified. However, we believe that current revision scope under RDI State aid framework should be extended to cover the specificities of RDI projects as indicated below. 1) Increasing the basic aid intensities for industrial research and experimental development to better and faster implement technologies and solutions crucial for delivering the European Green Deal goals or allowing an additional bonus for RDI projects dedicated to such technologies and solutions. The basic aid intensity is insufficient due to the fact that a significant part of the research results will not be used commercially in the future. Research projects therefore entail a high risk for the beneficiaries. In our opinion, increased aid intensity in terms of experimental development as well as industrial research for projects contributing to achieving climate targets is a cornerstone for the implementation of measures supporting energy transformation across the European Union. These projects remain crucial for the implementation of the European Green Deal objectives in order to reduce greenhouse gas emission and to provide more integration of electricity generated in renewable energy sources to the power system. 2) Correction of compatibility condition for research infrastructure regarding its accessibility –granting aid should be allowed also for infrastructure that pursues economic activities which is not publicly accessible and giving open access to such infrastructure should not be obligatory. We would like to highlight that a commercial enterprises make their laboratories available to others very rarely. In many cases, it would involve the disclosure of a company’s secret. Thus, we believe it is understandable that entities investing in the development of technology are reluctant to do so. The equipment itself and research materials reveal the scope and nature of a research, so enterprises are not willing to make their infrastructure available to other entities on market terms. As a result, they do not invest in research infrastructure due to the lack of resources. Therefore, the requirement to make infrastructure available should be abolished. Alternatively, the possibility of granting a specific aid intensity for each infrastructure and the aid of a higher intensity for infrastructure made available to others may be considered to possibly provide further incentives in this area.
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PGE urges EU to ease emission benchmark cuts for district heating

4 Jan 2021
Topic — EU benchmark values for free emission allowances for district heating 2021-2025.
Message — The company requests a heat benchmark close to 60.4 allowances per terajoule instead of the proposed 47.3, arguing the stricter value ignores technological and economic realities in district heating. They emphasize gas cogeneration as a vital transition technology from coal, delivering major emission reductions while maintaining heat security.123
Why — This would reduce their compliance costs and maintain profitability of district heating operations.45
Impact — Individual households face higher heating bills and increased energy poverty affecting millions of Poles.67
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Response to Climate change mitigation and adaptation taxonomy

4 Dec 2020

PGE Group’s comments on draft Delegated Regulation establishing the technical screening criteria 1.The proposed technical screening criteria for climate change mitigation in case of electricity generation from gaseous and liquid fuels are unfeasible for existing technologies in gas-fired power generation. 2.An unfeasible limit is also being established in case of cogeneration of heat/cool and power from gaseous and liquid fuels. According to the proposal the life-cycle GHG emissions from the co-generation of heat/cool and power from gaseous and liquid fuels have to be lower than 100gCO2e per 1 kWh of energy input to the co-generation for such an activity to be regarded as environmentally sustainable. Additionally there is a lack of clarity how to calculate this threshold as it is not clear whether it should be applied to the input or output of CHP units. For CHP units, a more feasible limit seems to be the proposed 270gCO2e/kWh of electricity and heat/cool generated in the climate change adaptation activities, provided that a fair method is used to allocate emissions partly to heat and partly to electricity outputs. 3.When calculating the emissions of a cogeneration of heat/cool from gaseous and liquid fuels, an appropriate methodology is needed. The method used by the European Investment Bank (”heat bonus”) is a credible methodology and should be applied. 4.Alternatively to the higher threshold and EIB’s heat bonus, the proposed technical screening criteria in case of climate change mitigation for electricity generation from gaseous and liquid fuels and for cogeneration of heat/cool and power from gaseous and liquid fuels could be based on the ones listed for energy generation from bioenergy in points 5 and 6 part 4.8 of Annex I, e.g. to attain electrical efficiency of at least 36 % or generate highly efficient CHP. 5.The proposed technical screening criteria for climate change adaption introduce, in case of electricity generation from gaseous and liquid fuels and for cogeneration of heat/cool and power from gaseous and liquid fuels an emission limit for direct GHG emissions of less than 270g CO2e/kWh, which is unfeasible for gas-fired power plants. It is not clear if and how gas-fired CHP plants could contribute to climate change adaptation and as a result be regarded as an environmentally sustainable activity. The draft delegated act itself does not specify this issue and should be clarified. 6.Gas cogeneration is an important technological solution which will have to play a significant role in reducing emissions, where alternative individual green energy sources are unavailable, especially in regions transforming away from coal and densely inhabited urban areas. Switch from coal to gas helps to save over 70% of CO2 emissions. It provides security of heat supplies and can improve air quality in cities across EU. Additionally, in a fully decarbonised system, gas cogeneration will continue to deliver important primary energy savings by combining electricity and heat generation. 7.It should be also emphasized that it is not always possible to build a large biomass-fired heat source (due to the sustainability criteria for biomass) or a thermal waste treatment installation, and there is Importance of gas cogeneration in reducing emissions of other harmful substances: replacing a typical WR-25 coal-fired heat only boiler with a gas-fired CHP unit results in: 820 times lower dust emission, 465 times lower NOx emission and almost 3 times lower SOx emission. 8.Introducing technical screening criteria which will rule out gas-fired power generation and cogeneration by setting unfeasible limits, will not only increase significantly the overall costs of coal replacement but will also harm the most vulnerable customers. 9.All investments in electricity grid infrastructure should be defined as sustainable to support further electrification and carbon-neutral transition, even in systems which are not fully decarbonised yet.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

7 Oct 2020 · IA2030

Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

11 Sept 2020 · Outcome of the vote on Climate Law

Response to Offshore renewable energy strategy

31 Jul 2020

PGE Capital Group is actively engaged in development of offshore wind projects in Poland. With offshore wind farms projects being currently carried out, PGE Capital Group will have up to 2,5 GW of installed capacity in the Baltic Sea by the end of 2030. Transmission grid upgrade as well as new grid investments to facilitate the offshore sector development are the first action to focus on. Offshore wind farms generate large amounts of clean energy that may be subject to structural limitations if the internal onshore grid is not developed sufficiently. For this reason, TSOs and DSOs should be more incentivized to develop the internal grid for connecting offshore wind farms and in result to minimize the level of generation curtailments. These incentives may be introduced through providing additional grants and facilities for grid development, but also forbidding the TSOs to conclude connection agreements with offshore wind farms developers not guaranteeing power evacuation and at the same time providing compensation for potential curtailments. We believe that this approach may result in the financial pressure for the TSOs to develop their internal grid to make it available to be fed with renewable electricity generated in offshore wind farms. From the perspective of building up a common grid to efficiently transmit electricity generated in offshore wind farms, PGE Capital Group identifies also the need to provide new, additional financial instruments to scale up development of the offshore renewable energy. Therefore, we appreciate the foreseen revision of the EU rules on trans-European energy infrastructure (TEN-E Regulation) as the very core element of the EU Offshore Strategy. We believe that one of the most important amendments to current wording would be to enable classifying offshore wind grid connection as the project of common interest (PCI) even if there is no direct impact on the level of cross-border flows. New Regulation should follow the approach that offshore renewable electricity is considered itself as a common interest of all European citizens. We believe that large-scale offshore wind farms implemented in cooperation with local suppliers will play an inevitable role to the post-COVID economic recovery of the European Union. However, the latest European Council conclusions referring to the Recovery and Resilience Facility establish a strict and short timeline of the proposed measure (legal commitment concluded by the end of 2023 and payments made before the end of 2026). In our opinion it may be considered as an obstacle for offshore wind farms projects and this strict timeline should be relaxed. We agree that cooperation between Member States will be one of the key enablers for offshore wind sector development. Therefore, we believe that funding under Connecting Europe Facility-Energy for common renewable energy projects should also be made available for projects developed under international consortia and joint ventures. Nowadays, this is the most common model for implementation of offshore wind projects. We would like to highlight the need for a comprehensive approach in the EU legal framework. We encourage the Commission to propose measure strengthening the EU industrial and technological global leadership in offshore sector based on EU-production across the entire value chain. We believe that positive environmental effects of the offshore wind development should not be jeopardized by emissions resulting from the shipping of contents for offshore wind farms construction from other continents. Further collaboration should continue to reconcile the interests of other maritime activities as well as biodiversity aspects whilst the priority should be given to scaling up large offshore wind farms.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

The PGE Capital Group is the biggest Polish energy utility with a total 56,03 TWh of electricity and 50,33 PJ of heat generated in 2019, which guarantees a safe and reliable power supply to ca. 5.27 million of electricity consumers. Nearly all of our units need to hold a relevant permit within the meaning of the Article 4 of the Industrial Emissions Directive (“IED”). The PGE CG is conducting numerous investments dedicated to comply with the Commission Implementing Decision (EU) 2017/1442 of 31 July 2017 establishing best available techniques (BAT) conclusions, under Directive 2010/75/EU of the European Parliament and of the Council, for large combustion plants. Furthermore, the waste incineration BAT conclusions are also relevant for our business activity, with a special regard to operating and developing thermal waste treatment installations. We would like to point out the following key aspects developed further in our response: We do not see the economic and legal reasons to add to the IED permitting additional component reflecting the GHG abatement measures. In fact, CO2 emission reduction potential is determined by the primary energy source – except for CCS, which has not been applied to large-scale power generation, there is no technically feasible option to significantly reduce CO2 emissions from fossil fuels, like it is possible with pollutants such as NOx, SO2, PM2.5 or mercury (Hg). CO2 emissions are governed by the EU ETS based on the cap and trade principle, not by the IED based on the command and control approach. The GHG abatement measures with the IED/BAT framework would result in additional business uncertainty. The factual impact of the BAT-AELs on the total level of emission reduction, may be finally assessed only after the BAT for LCP adaptation period, which expires on August 17, 2021. Therefore, we consider that the potential revision of the substantial emission standards for Large Combustion Plants would be definitely premature. It should be underlined that 4-year modernisation period in case of power plants, as set out in the Article 21(3) of the IED, is considerably too short. It should be acknowledged that not all power plants may be simultaneously disconnected from the grid. General timeline for the modernisation process should be more adjusted to the different industrial sectors and preferably extended where appropriate. The Sevilla process should be based on the objective and verified data, therefore the referential installations should be located in the Europe, non-European countries such as Japan and USA should be excluded. Moreover, only the environmental performance of the installations in operation should be accounted. Norms should not be derived from demonstration installations, not operating commercially. Final text of the BAT Conclusions should not undermine conclusion undertaken and the technical level, therefore setting any far-reaching political amendments should be strictly avoided. Formal impact assessment concerning the relevant BAT Conclusions should be carried out before the final Article 75 Committee meeting. As far as the BAT Conclusions are adopted in an implementing act, their scope of application should not extend the scope of the IED itself. Construction process of the new district heating plants replacing the old ones can be expected to be delayed due to the COVID-19 outbreak. There is a risk that several cities and urban areas would not be fully supplied with heat in the heating season of 2022/2023 because existing installations with derogations would have to be phased-out prior to new ones becoming operational. Due to these extraordinary circumstances, it is necessary to extend the district heating derogation for 12 months and this probably requires an amendment to the IED. The possibility to apply for derogations under Article 15(4) of the IED should be preserved.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

15 Apr 2020 · Power sector decarbonisation

PGE seeks more funding and specific climate impact assessments

9 Apr 2020
Topic — A consultation on the European Climate Law establishing a binding 2050 climate neutrality objective.
Message — PGE requests individual impact assessments and a five-fold increase in the Modernisation Fund. They suggest delaying timelines to account for the economic impact of COVID-19.123
Why — This would prevent bankruptcy and ensure capital is available for new green investments.45
Impact — Environmental goals may suffer if the regulation and impact assessments are postponed.6
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Response to Commission Implementing Regulation on the Modernisation Fund

13 Mar 2020

The PGE Capital Group remarks concerning the Modernisation Fund Implementing Act According to the recent CAKE analysis, CAPEX needed to reach carbon neutrality in Polish energy sector varies between EUR 179-206 billion. We believe that the Modernisation Fund resources may play a significant role in triggering low- and zero-emission investments in energy generation. Unfortunately, a few concerns regarding Modernisation Fund operationalisation may limit its effectiveness. Need to set more business-oriented timelines for relevant decisions In case of priority investment proposals put forward there is no need to conduct a complex assessment by the Investment Committee. Therefore, there is no reason to postpone the simplified assessment required for investments on priority list only to confirm that an investment falls into the areas listed in Article 10d (2) of the EU ETS Directive. We propose that investment proposals submitted by the beneficiary Member States as priority investments shall be assessed by the EIB no later than within four weeks from submission of the proposal. Moreover, there is no time-limits for adoption of disbursement decisions. According to the Article 10d of the EU ETS Directive: „The Commission shall adopt its decision in a timely manner”. We propose that the Commission shall adopt disbursement decision no later than four weeks from the adoption of opinion by the Investment Committee. Need to ensure more predictability for the support dedicated to the large-scale projects It should be possible to bank all necessary investment resources including the future revenues from the auctioning of allowances, which have not been monetised prior to the decision date in a single decision. The Modernisation Fund’s design should facilitate the financing of large-scale projects with a single disbursement decision that would guarantee required financial resources for the project. The actual payments will be made after obtaining relevant CO2 revenues in the forthcoming years, however, the next disbursement decision should be issued on the basis of a simplified procedure – similar to the support dedicated to the multiannual programs. Member States should not be discouraged from supporting non-priority investments The proportion between the financial resources dedicated to priority investments (at least 70%) and non-priority investments (maximum 30%) should be checked only at the end of the 4th EU ETS phase. The European Commission would like to verify in each disbursement decision that the overall target of at least 70% of funding dedicated to priority investments is met at all times. Thus, the eligible Member States are limited with respect to the financing of non-priority projects upfront. The beneficiary Member States’ competences should be preserved The beneficiary Member States should not be discriminated in the process of nomination of Investment Committee members. All Member States should be empowered to select three non-beneficiary members of the Investment Committee. State aid cumulating rules should be clarified to avoid any doubt Modernisation Fund would be probably only an auxiliary source of the project financing. Therefore, it is of the utmost importance to clarify State aid cumulating rules to allow a combination of different sources of support up to the highest aid intensity according to the applicable State aid rules. Additional comments Moreover, several terms such as “financial statement” referred to in Article 13 (2) of the Implementing Act or “undue delay” should be clarified to avoid any doubt regarding the implementation of the Modernisation Fund. It should be also clarified if the Modernisation Fund will support investments implemented beyond 2030, e.g. via amounts disbursed to discontinued investments. The European Investment Bank should conduct its task related to the Modernisation Fund at reasonable cost. Please find our specific proposals in the table attached below.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

11 Mar 2020 · Green Deal priorities: Just transition, offshore wind

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

18 Feb 2020 · European Green Deal

PGE Urges EU Compensation for High Climate Transition Costs

6 Feb 2020
Topic — A legislative proposal to legally mandate EU climate neutrality by the year 2050.
Message — PGE calls for increased financial compensation and funding to support the power sector's transition. They request realistic intermediate targets and green funding for gas and nuclear technologies.123
Why — Increased subsidies and green status for gas would lower their compliance costs.4
Impact — Wealthier EU Member States lose auction revenue to fund the transition in coal-reliant countries.5
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

28 Jan 2020 · Decarbonisation in Poland and climate neutrality

Meeting with Francisco Barros Castro (Cabinet of Commissioner Elisa Ferreira)

16 Jan 2020 · Preparatory meeting PGE

Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič)

13 Jun 2019 · State of the Energy Union