It is worth noting that the Polish RRP is no longer a programme to combat the effects of the COVID pandemic. It appeared after episodes of the energy crisis and Russia's invasion of Ukraine. It should be used to solve current problems. The document doesn't address many of them, but the government strives to continue the current course of action and the ambitions contained therein are mostly moderate.  

The delayed implementation of the RRF creates a window of opportunity in Poland for projects that lacked political determination so far. By reducing energy demand, limiting support for gas projects and increasing the role of RES, Poland can build sustainable resilience from an environmental, economic (energy prices, new industries) and social (reduced health risks, energy poverty, social participation due to accessible public transport) perspective. Full mobilisation today is an opportunity for a safe winter for many Polish households. 

The directions set out in the RRP are correct, but out-of-date. Now they need to be adjusted to the current situation. In the Green Energy and Energy-Intensity Reduction component we pay attention to several issues.  

Energy efficiency and heating 

• in current conditions, reducing energy demand should have the highest priority - a national energy efficiency target of 13% by 2030 in line with RePowerEU is necessary, moreover, progress towards it should be monitored on annual basis; 

• the electrification of heating should be significantly accelerated - the NAP does not specify its share in the replacement of heat sources in buildings. Instead, it sets an unambitious demand for the maximum share of gas boilers in the replaced heat sources to be below 40%, although in recent months this share has fallen below 30%; 

• synchronising measures in the Clean Air Programme with the long-term renovation strategy is a pro. However, there is a lack of minimum energy performance standards for buildings, which after renovation should have an annual energy consumption in line with the standard for new buildings (WT21) or lower; 

• focus on high building standards for low-income housing, which will reduce future running costs, deserves a positive assessment; 

• plans regarding district heating set out in the RRP are insufficient. They should be shifted towards renewables even more, i.e. instead of natural gas, low-temperature networks powered by RES should be considered, even if initially in the form of local pilot programmes;  

• although provisions on heat sources in single- and multi-family buildings go in the right direction, the underlying indicators (e.g. minimum heat power requirements for the source), determining effective transformation, should be verified; 

• top priority should be given to implementation of the regulation on quality standards for biomass solid fuels and the ban from misleading branding; 

• when improving energy efficiency of public buildings, gas projects should be eliminated as they have poor prospects and will be more expensive to operate in the life cycle; 

• businesses must be involved more in reducing energy demand. Either the Polish system of white certificates becomes more effective – which will lead to a rapid and sustained reduction in energy demand - the process of doing so must be speeded up, or other mechanisms should be considered, with a premium depending on long-term energy reduction. 

Hydrogen 

• goals reflect the minimum efforts expected in the 4th Gas Package and the EU hydrogen strategy – not particularly ambitious, although the direction is fine. Poland - as #3 producer in the EU - should benefit from their implementation; 

• It should be emphasized that priority use of hydrogen will be in industry (and not in transport) - replacing fossil fuels is most difficult there. While creating a favourable legal framework for the development of hydrogen transport is justified, spending money on the development of hydrogen mobility not; 

• spending public money on low-carbon hydrogen production makes no sense. All interventions in hydrogen should be for the production, storage and industrial use of green hydrogen; 

• late delivery of milestones means joining the hydrogen economy late, risking missed opportunities to develop market niches. 

Renewables 

• targets for photovoltaics and onshore wind energy should be clearly raised, as figures are already significantly underestimated: PV capacity (including micro-installations) exceeds 10 GW, onshore wind capacity is about 7 GW, while the target for both for mid-2026 is a mere 23.5 GW. Raising the goals will primarily require publicly financed investments in distribution networks (not financed by the RRF), rather than support for the construction of new generation sources; 

• abolishment of the distance rule (so-called 10H rule) should have highest legislative priority – it will unlock the new onshore capacity relatively soon and in a cost-efficient manner; 

• subsidising individual energy storage facilities is controversial - larger, local lithium-ion storage facilities are more cost-efficient. 

Green transformation of cities 

• support should be firstly given to local authorities who are determined and ready to implement ambitious goals, also with innovative tools; 

• instruments should include a comprehensive range of measures (energy efficiency of buildings, reduction of energy poverty, strategies to reduce GHG emissions, accelerated phase-out of fossil fuels in heating and cooling) and, importantly, the development of good practices that can be applied nationally. 

In the above-mentioned areas investments will amount to about EUR 9.2 bn (of which EUR 3.7 bn in loans). The final result will be determined by how well RRP and RePowerEU are implemented. Leaving most of the milestones for mid-2026 seems to be quite risky. Changes have to happen earlier, for the sake of the competitiveness of firms and households’ financial standing. Institutional capacity to proceed applications from beneficiaries is crucial - even the authors of the Plan emphasise streamlining the procedures.    

The available document (annex to the Proposal for a Council implementation decision) has little information on financing and action plans. Based on the milestones, one can expect a significant role of state-owned companies and a relatively large number of investments carried out in a non-competitive mode, which requires the highest level of scrutiny. In order to ensure optimum implementation, the RRP Monitoring Committee should regularly analyse the progress, access full information on its implementation and give early warning signals, as time for implementation is very limited. In the Polish context, involving NGOs is a must, as they have the necessary expertise in climate and environmental issues and are discussion partner for the government in the area.  

The RRP does not offer a comprehensive picture of the energy transformation in Poland, but it is a good starting point. We hope that other pieces of decision-making process will be developed with similar determination. In particular: update of strategic documents, reforms in other areas, as well as decisions on what should be supported with taxpayers' money (and to what extent) and what should not. In the short run, the Commission’s endorsement gives the government a powerful tool to prepare Poland for the coming winter and the multi-month struggle with the energy and climate crisis.