Polish Electricity Association

PKEE calls on the European Commission to introduce a sectoral exemption for energysector activities from Directive 2014/25/EU. The energy sector operates today in fully competitive markets, is subject to extensive EU regulation, and plays a central role in delivering the EUs strategic objectives on energy security, decarbonisation and competitiveness.

District heating and cooling The PKEE members have made and continue to make numerous investments to replace existing coal-fired heating sources with highly efficient cogeneration ones based on natural gas because the use of renewables in large-scale district heating systems is limited.

Polish Electricity Association position on the Inception Impact Assessment of the revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources Members of the Polish Electricity Association (PKEE) are actively involved in reduction of greenhouse gas emissions and further development of renewables.

Providing adequate requirements for buildings is essential to meet climate goals and to reduce the EU's dependency on fossil fuels imports. However, the Polish Electricity Association (PKEE) wishes to draw attention to the provisions on efficient district heating systems presented in the proposal for a recast of the Energy Performance of Buildings Directive (EPBD) as well as to some inconsistencies with other…

In January 2020, the European Commission presented the European Climate Law roadmap, which was acknowledged in the “The European Green Deal” communication outlining the goal to drive Europe towards becoming the first climate-neutral continent by 2050. The European Climate Law proposal will be presented in March 2020 and its adoption is expected to take place before the COP26 summit in Glasgow (November 2020).

The Polish Electricity Association (PKEE) appreciates the European Commission proposal to establish the Carbon Border Adjustment Mechanism (CBAM) to reduce the risk of carbon leakage and ensure that the price of imports more accurately reflects their carbon content.

The PKEE, representing leading companies in the Polish power and heat sector, emphasizes that district heating (DH) is a SOCIALLY SENSITIVE SECTOR providing an essential public service. I. CONCERNS REGARDING THE HEAT BENCHMARK The proposed heat benchmark of 31.2 allowances/TJ (a 34.1% reduction) is considered structurally flawed because: FALLBACK NATURE: As a cross-sectoral fallback, its reference sample is "pulled…

The Polish Electricity Association (PKEE) believes that improvements in energy efficiency are necessary to achieve more ambitious EU climate targets. However, the recast of Directive (EU) 2012/27/EU on energy efficiency (EED) must acknowledge different starting points of individual Member States, especially regarding district heating and high-efficiency cogeneration.

Polish Electricity Association's comments on the review of the Directive 2012/27/EU on energy efficiency Polish Electricity Association (PKEE) believes that energy efficiency might play a role in achieving the European Green Deal objectives, yet it should not undermine the long-term perspective of EU economy electrification.

PKEE members are committed to achieve climate neutrality and 55% emissions reduction target. As pointed out by i.a. Eurelectric, if carbon neutrality in entire economy is to be achieved by 2050, hard-to-abate sectors need to be electrified, which cannot be implemented with skyrocketing power prices, observed nowadays in Europe.

The Polish Electricity Association welcomes the opportunity to participate in the Commission’s public consultation for the amendment of the EU ETS Directive and would like to point the Commission’s attention to the following aspects.

The Polish Electricity Association (PKEE) supports aligning taxation of energy products and electricity with the EU climate policy, to contribute to the 2030 targets and climate neutrality by 2050. However, the revision of the Energy Taxation Directive (ETD) must not result in additional increase in energy prices for consumers.

The Polish Electricity Association (PKEE) agrees that the achievement of objectives set out in the European Green Deal may require a broader discussion about the possible amendments to the existing energy taxation rules.

Setting an appropriate renewable energy framework for the decade ahead is critical to ensure predictability of the energy transition pathway while safeguarding Europes competitiveness. The Polish Electricity Association (PKEE) would like to draw the European Commissions attention to the following key issues: renewable energy targets, regulatory complexity, financing of the energy transition, energy storage…

The attached document contains the contribution of the Polish Electricity Association (PKEE), outlining key considerations for ensuring that the revised Climate Delegated Act remains coherent, technologyneutral and operational for market participants across the Union.

Please find attached PKEE's feedback. Key messages: PKEE represents major investors in Polands energy transition and over 18 million energy consumers. We support a just, responsible, and transparent transition that ensures citizens' trust. Achieving climate goals cannot jeopardise EU energy security or competitiveness, especially in todays unstable geopolitical and economic environment.

Brussels, 20.04.2020 PKEE position on the IIA to the Industrial Emissions Directive revision 1. Polish Electricity Association (PKEE) acknowledges Commission’s attempt to review IED which is setting emissions caps for industrial activities.

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

Warsaw, 23 July 2018 The position on financing sustainable growth The European Commission has on 08.03.2018 presented the action plan for financing sustainable growth 1 and on 24.05.2018 the proposals for the relevant legislative acts. Both the action plan and the aforementioned legislative proposals are based on the recommendations from the High-Level Expert Group on Sustainable Finance2.

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

Position paper of the Polish Electricity Association (PKEE) submitted in response to the consultation on the guidance for applying the do no significant harm (DNSH) principle under the 20282034 Multiannual Financial Framework. The document presents key recommendations aimed at simplifying, harmonising and ensuring a proportionate application of DNSH requirements.

The Polish Electricity Association (PKEE) welcomes the opportunity to contribute to the consultation on the design of the legal framework for the possible use of high quality international carbon credits (ICC) towards the 2040 climate target under the European Climate Law. The detailed position is set out in the ATTACHED DOCUMENT.

Targets and Overall Approach: PKEE believes that improvements in energy efficiency are necessary to achieve the EUs ambitious 2040 climate target. The revised framework should prioritise cost-effective solutions and reflect the diverse starting points of Member States. In this context, additional binding targets are not necessary.

Polish Electricity Association position on Renewable energy - guidance on designating renewables acceleration areas Given that Member States have to designate renewables acceleration areas for renewable energy technologies by 21 February 2026, Polish Electricity Association (PKEE) welcomes the Commission initiative to issue guidance on this matter.

Polish Electricity Association position on Proposal for a regulation amending Regulations (EU) 2019/943 and (EU) 2019/942 as well as Directives (EU) 2018/2001 and (EU) 2019/944 to improve the Unions electricity market design The root of current energy crisis first and foremost is the energy fuel markets crisis not the wrong architecture of the energy market.

Appropriate governance will be crucial for building a genuine Energy Union and achieving climate goals. PKEE draws the Commissions attention to the following issues: - Consistency and flexibility of the framework; - Targets and indicators; - EU funds and conditionality; - Energy security. Please find attached the position paper.

The Polish Electricity Association (PKEE) recognises the strategic importance of revising the EUs energy security framework in light of evolving geopolitical risks, accelerating electrification, and energy transition challenges. A robust framework must balance decarbonisation and competitiveness with secure, stable, and affordable energy supply.

The Polish Electricity Association (PKEE) welcomes the opportunity to contribute to the consultation on the revision of national targets and flexibilities in the EU climate policy framework after 20301. As highlighted in the Commissions Call for Evidence, the forthcoming revision must support the achievement of the provisionally agreed 2040 climate target while ensuring fairness, cost-efficiency and resilience…

The Polish Electricity Association (PKEE) welcomes the proposal of the European Commission on the Regulation establishing the Just Transition Fund (JTF), which is essential for the Polish energy transition. The investments in the Polish energy sector needed to achieve this transition amount to EUR 179-206 billion . This would, therefore, require more adequate measures tailored to the actual transition needs.

The implementation of the new Regulation concerning data reporting under REMIT raises several practical issues that require further clarification to ensure consistent and accurate compliance across market participants. In our response, we draw attention to the following issues: 1. Lack of standardised data formats; 2. Timeline for implementation and final guidance; 3. Clarification of definitions (Article 2); 4.

Position of the Polish Electricity Association (PKEE) in response to ECs proposal for a regulation of the EP and of the Council amending Regulations (EU) No 1227/2011 and (EU) 2019/942 to improve the Unions protection against market manipulation in the wholesale energy market.

The exceptional situation in energy markets caused by Russia’s invasion of Ukraine requires Europe to revise its energy transition plans. We need to be better prepared to meet new challenges while building energy security for the entire EU and its individual regions.

PKEE welcomes draft EC proposal on Implementing Regulation on interoperability requirements and non-discriminatory and transparent procedures for access to data required for customer switching. Poland is developing in practice its country-wide power data exchange digital system CSIRE and new model of electricity supplier switching with the aim of ensuring that market participants share a clear and mutual…

The Polish Electricity Association (PKEE) welcomes the idea of creating the Social Climate Fund (“the Fund”) and believes that it might be a helpful tool in ensuring a just transition and reducing energy poverty. However, the cost of increasing energy prices for households may be only partially mitigated by the Fund.