PGNiG SA

GENERAL COMMENTS: • Natural gas is a bridge from coal to renewables and hydrogen. Especially in MS like Poland whose economy is to a large extent based on coal, role of gas is crucial in the process of energy transformation toward clean sources of energy. • It is of key importance to ensure that any possible increase of RES target is set only after a thorough impact assessment and in a technology neutral manner.

General comments: 1) Climate neutrality target for 2050 should remain at EU level [art. 2(1)]. 2) A thorough impact assessment is needed to address the real impact of increasing reduction targets for 2030 up to 50-55%, especially in the context of COVID19 outbreak and its repercussions on EU economy [art. 2(3)].

GENERAL COMMENTS: • Carbon leakage is already a reality and the risk is likely to increase in the view of the raising of the EU climate ambition. • Taking into account the increased EU climate ambition, there is a strong need to appropriately address carbon leakage in order to maintain level playing field for EU producers when competing domestically and on global markets.

Warsaw, 1st April 2020 PGNIG POSITION ON INCEPTION IMPACT ASSESSMENT CONCERNING CARBON BORDER ADJUSTMENT MECHANISM PGNiG welcomes the opportunity to comment on the inception impact assessment concerning Carbon Border Adjustment Mechanism.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

GENERAL COMMENTS: • PGNiG highlights that some Member States due to national circumstances (e.g. Poland) still rely heavily on coal. PGNiG is actively involved in transformation of district heating by replacing coal plants with natural gas-fired high efficiency cogeneration units.

GENERAL COMMENTS: • The effects of raising the contribution of the ETS towards a higher emissions reduction target will not be felt equally across the EU. Some MS will be more affected than others. • Required investment in Polish energy sector in the years 2021-2040 (according to the Polish government), are estimated at over PLN 560 bln (about EUR 125 bln). • PGNiG is concerned whether additional resources (2,5 p.p.

GENERAL COMMENTS: • Extension of EU ETS should not be considered as most effective solution across all sectors. Individual approach in specific sectors should be applied in order to maximize environmental benefits. • As regards waste sector, one of the main identified sources of methane are uncontrolled emissions of landfill gas in landfill sites.

GENERAL COMMENTS: - In the view of the current international situation, in particular Russia's aggression against Ukraine and the resulting reduction in gas supplies to the EU, as well as the experience of the COVID-19 pandemic which generates the risk of a lack of sufficient generation capacity in the energy sector due to delays in investments, a system solution is needed to guarantee security of energy supply to…

Warsaw, 21st April 2020 PGNiG POSITION ON INCEPTION IMPACT ASSESSMENT CONCERNING REVISION OF THE INDUSTRIAL EMISSIONS DIRECTIVE PGNiG welcomes the opportunity to comment on the inception impact assessment concerning revision of Industrial Emissions Directive 2010/75/EU (IED).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PGNiG welcomes the possibility to comment on the proposal for a regulation amending Regulation 2019/631 as regards strengthening the CO2 emission performance standards for new passenger cars and new light commercial vehicles in line with the Union’s increased climate ambition (Cars Regulation).

• TEN-E should continue to support development of natural gas transmission infrastructure as natural gas could play an important role in delivering clean and affordable energy in the transitional period; • The significant development of clean gases influences future role of the existing natural gas infrastructure as it may be used to transport renewable gases and hydrogen and back-up the variable power generation; •…

General comments: • The Council of the European Union recognised the need to support the development of different alternative fuels (including LNG as a transitional fuel). • As stated in the Impact Assessment accompanying the proposal for regulation, LNG provides a good solution to air pollution issues, allowing reductions in SOx and NOx emissions.

Polskie Górnictwo Naftowe i Gazownictwo S.A. (Polish Oil and Gas Company; hereafter: PGNiG) welcomes the opportunity to comment on the proposal for a directive on the protection of the environment through criminal law (COM (2021) 851 final). PGNiG recommends extending the scope of Article 9 so that it includes additional circumstances that may be regarded as mitigating circumstances.