Latest unambitious domino falls as Poland publishes plan for EU recovery fund

With public hearings on the plan kicking off this week, it is crucial for the Polish government to heed the proposals of civil society groups for more ambitious projects and to avoid potentially harmful investments.

Harmful projects for energy efficiency

The lack of vision is on display in the recovery plan when it comes to energy efficiency. Although this component is supposed to consume a significant part of the funds, the draft does not present reforms that would make an effective and sustainable reduction of greenhouse gas emissions in line with the EU’s Renovation Wave strategy objectives.  Moreover, some of the planned spending will feed the Clean Air programme that financially supports the installation of new coal and pellet boilers. Since Poland has no formal pellet quality or sustainability standards, the pellets can be made from harmful materials, such as waste furniture boards. That kind of policy is clearly incompatible with the EU’s ‘do no significant harm’ (DNSH) rule because of the potential risk of rising CO2 emissions. The draft does not get any better in terms of renewable energy sources. Apart from the fact that the funds allocated for this purpose are relatively small, the draft plans list investments in municipal waste incineration, most of which are plastic. 

This type of incineration will lead to CO2 emissions per unit of energy production comparable to coal-fired installations.

In this context, the draft’s focus on hydrogen is surprising. There are no credible prospects of Poland’s imminent achievement of surpluses of clean energy from renewables, which could be utilised to produce clean hydrogen. Investing money in research and development potential for pure hydrogen is desired as long as a solid renewable energy impulse would accompany it. On the other hand, investing in gas pipelines or ‘hydrogen’ storage facilities right now is only strengthening dependence on fossil gas. There are good reasons to believe that this pro-gas policy, conceived in the recovery plan, will lead to a powerful lock-in of natural gas to the electricity and heating grid.  Poland plans to replace most of the coal that is removed from the energy mix with gas, producing 56 TWh of energy from gas in 2030, or approximately one third of all current production. The idea that gas is not a transition fuel but will stay with Poland to the end is not that far-fetched.    

Biodiversity protection neglected in the plan

The Polish plan’s most bitter defeat so far is its virtually non-existent focus on biodiversity, similarly to other national plans. The lack of adherence to the DNSH principle is clearly visible. The Polish plan does not include improvements to the poor management of Natura 2000 sites.  Although measures like establishing flower meadows and similar nature-based solutions for cities, these are pushed somewhere to the margin. The authors seem to ignore the main factors of the loss of biodiversity in Poland, the disappearance of habitats and ecological corridors and the overexploitation of natural resources. 

Biodiversity and the DNSH principle are mentioned in the document as abstractions.

The plan assumes that all the reforms and investments contribute to protecting biodiversity and do not cause severe damage to nature.  Such a lawmaking philosophy does not comply with the EU’s regulations on drawing up the recovery plans. A plan should explain how none of the proposed measures and investments seriously damage nature. The Polish plan does not include any activities aimed at protecting species, ecosystems, ecological corridors, or any ideas for strengthening the protection or enlargement of protected areas.  On the contrary, some of the proposed solutions undermine environmental legislation. The program includes, for example, the adoption of a special law on anti-drought investments. It contains new regulations that threaten Poland’s biodiversity and water resources. This proposed act simplifies investment procedures for the building of concrete water facilities. Its core is to make it easier for Polish Waters (national regulator of water investments) to obtain permits for new dams and artificial reservoirs in Niepołomice on the Vistula, in Ścinawa and Lubiąż on the Oder and in Pisz on the Pisa. The draft assumes the priority of the special act’s provisions over nature protection bills. This makes it much easier to intervene in protected areas, for example by enabling water installations in nature reserves. The small hydropower plants encouraged by the project are mostly incompatible with the EU Water Framework Directive. They do immense harm to biodiversity by blocking wildlife corridors while making a disproportionately small contribution to renewable energy production. Moreover, the proposed anti-drought regulation deprives society of democratic and effective participation in investment consent proceedings. It severely interferes with the competences of local governments as well.

Possible improvements

The silver lining is that all of these misguided plans are possible to fix before it is too late. The plan should strengthen forests and river valleys by restoring them to their natural state. Such measures have been proposed by a group of civic organisations in a document with programmes and reform directions that can be easily incorporated into the recovery plan.  This includes legislative changes to the bill on forests, water law, or the EU directive’s application on environmental impact assessment. Those proposals remove from Polish law non-compliance with the EU acquis and upgrade the environment and biodiversity protection.  Civil society is also proposing to initiate a national river restoration programme and modify the draft programme to combat drought, shifting the focus from extending concrete hydropower infrastructure to nature-based solutions.  In addition to tackling biodiversity loss in Poland, these two programs would help the country adapt to climate change by mitigating the effects of droughts and countering climate change by protecting and restoring natural carbon sinks such as forests and wetlands.