Devil in the climate details as Slovakia finalises plan for EU recovery fund

Components of the Slovak national recovery and resilience plan

Outdated plans and no regional capacities

One of the key problems with the Slovak recovery plan is that it is based on outdated documents. There is no appropriate carbon neutrality decarbonisation model finalised for aligning the measures with 2030 and 2050 EU climate targets. The Slovak National Energy and Climate Plan was outdated even in 2020 when it was published. There was not enough political will to update the decarbonisation models, and Slovak ministries did not have sufficient capacities. The Ministry of Environment prepares the model for carbon neutrality since 2019, but only general information about measures is available – no clear pathway.   Moreover, Slovakia will probably review its reports on renewable energy shares starting from 2010 due to incorrect reporting of data from households and small sources in the last decade. The current government’s Programme from April 2020 stated that it would review the NECP and Low Carbon strategy. The draft plan has not so far built in NGO recommendations for supporting preparation of capacities in the Regional Centres, which would help orchestrate the planned decarbonisation at the regional level. One-stop shops in the regions assisting households in applying for funding is a measure in good direction, but it shouldn´t subsitute real decarbonisation planning and implementation and much wider and deeper focus of the Regional Centres.

Slovak ministries should include a component for  ‘Preparation of regional capacities for decarbonisation’ with EUR 3 million.

Renovation of buildings

Reforms include integrating various public support measures, increasing transparency, complex assessment of historical buildings, and dealing with construction waste. The last reform is the only circular economy initiative in the whole recovery plan. The renovation of public historical buildings should incentivise deep renovation and preserving historical values – not only pragmatic utilisation of these buildings. It is hardly possible to assess if it’s an appropriate use of funding to contribute to carbon neutrality by 2050 at the latest.  Moreover, the regional decarbonisation strategies and capacities for preparing them are almost non-existent.

The relevant ministries should double-check the support for historical and listed buildings with the decarbonisation model.

Fossil gas boilers a false solution to tackle energy poverty

Investment package for improving the energy efficiency of 40 000 family houses investments package includes a EUR 50 million allocation for fossil gas boilers. Although the Ministry of Environment conditioned this programme on other energy efficiency measures, it comes with a false presumption that low-income households will be schooled into using fossil gas boilers to avoid air quality infringement. Low-income families would hardly switch from cheaper fuels, such as wood (and unfortunately waste), to fossil gas. This is problematic because Slovakia already has one of the worst ratios of energy-related spending compared to income in the whole EU and opting for the more expensive fossil fuel would only make it worse.  Fossil gas boilers in the plan should be replaced by more sustainable solutions. The Slovak Academy of Sciences recommends examples of good practice in tackling energy poverty, such as supporting homes’ renovation in other member states.  There is mention of solar systems and heat pumps, but they are not yet properly integrated into the component.

The Ministry of Environment should replace support for fossil gas boilers with renewable energy sources (RES) systems.

The renewable energy sources and energy infrastructure

Reforms from the renewable energy sources and energy infrastructure component primarily focus on transposing the Clean Energy for all Europeans package into Slovak legislation.

Ministry of Economy should add sustainability criteria for renewable energy sources and set municipalities, energy communities and prosumers into the eligible recipients of public finance support for building new RES – not only support entrepreneurs.  

Decarbonisation of industry

This component’s reforms include a phase out of subsidies for electricity from domestic coal, which was approved in 2018 and won’t be financed from the Recovery and Resilience Facility. Streamlining controls and improving integrated permitting for industry is another reform that raises attention from the environmental and access to justice points of view. The cost-efficiency is the main principle for investments in the EUR 350 million decarbonisation of industry component of the plan.

The Ministry of Environment should check if the projects listed there are in line with the carbon neutrality model, which their department finalised.

Railway and cycling infrastructure, but also highway hydrogen infrastructure

Reforms in sustainable transport are focused on preparing investment projects and other public passenger transport and intermodal freight transport measures. The new policies for the long-term support of alternative fuels seem problematic as the RRP supports highway infrastructure. Through EUR 700 million, the plan includes spending on a number of positives, including the development of low carbon transport infrastructure and environmental freight transport, as well as promotion of ecological passenger transport. Unfortunately, it also plans to support problematic construction of infrastructure for alternative fuels (e-mobility and hydrogen). Pedestrian, cycling and public transport infrastructure were strongly neglected for decades as overpriced highways have been financed as a state priority. Individual automobile transport is much less efficient, socially accessible and environmentally sustainable than public transport systems.  

This is why the EUR 50 million allocation for 1000 new electric and hydrogen recharge stations on highways should be switched from grants to loans. 

The partnership principle and participation

The Slovak Ministry of Finance sent the first draft of Slovakia’s recovery plan to the European Commission on 23 December 2020. However, the Ministry published the complete draft of Slovakia’s plan for public consultation on 8 March 2021. With the tight deadline for submitting plans to the European, this three month delay made the public participation in the planing process mostly a formal exercise.  Moreover, the Slovak government massaged the legislative process by publishing a draft version of the plan for the official consultation on 8 March 2021 in order to reach agreement among political coalitions, discuss with the Commission and finalise by 30 April 2021. This is a dangerous precedent as the legislative process allows this consultation only in its final stage.

The Ministry of Finance should incorporate the partnership principle into the implementation structure of the recovery plan.