The Polish Electricity Association supports establishing technical screening criteria (TSC) for the Taxonomy Regulation to allow a sustainable transition towards low-carbon economy. However, we are deeply concerned that some of the TSC may pose a huge challenge for the energy sector in Poland.
Electricity generation – gaseous and liquid fuels
We are strongly against putting a 100 g CO2/kWh threshold on emission for electricity generation using gaseous and liquid fuels as it excludes this activity from being regarded as sustainable.
The list of sustainable activities should cover all types of economic activities that can significantly reduce the negative impact on the environment, including enabling and transitional technologies, like electricity generation from natural gas, which in our opinion were not sufficiently addressed in the delegated act.
Evolutionary and cost-efficient shift from solid fossil fuel to gas-fired plants is of key importance to ensure the necessary back up for balancing of RES and to maintain the security of supply in Member States heavily dependent on coal.
The TSC presented in section 4.7 for climate change mitigation could be based on the ones listed for energy generation from bioenergy in points 5 and 6 part 4.8 of Annex I to allow gas-fired power plants to be regarded as sustainable.
TSC applying to climate change adaptation introduce an emission threshold of 270 g CO2e/kWh for electricity generation from gaseous and liquid fuels, which is unfeasible for gas-fired power plants. However, why and how these power plants could contribute to climate change adaptation and as a result be regarded as sustainable is not clear because the draft delegated act does not specify this issue.
Transmission and distribution of electricity
All investments in electricity grid infrastructure, even in systems which are not fully decarbonised, should be defined as sustainable to support further electrification and transition. The proposed classification based on the emissivity of connected generators does not seem relevant. Instead, the improvement of reliability and efficiency of the network should be assessed.
Cogeneration of heat/cool and power from gaseous and liquid fuels and production of heat/cool from gaseous and liquid fuels
We are strongly against putting a 100 g CO2/kWh threshold on emission for a production and
cogeneration of heat/cool from gaseous and liquid fuels as it excludes this activity from being regarded as sustainable.
All activities should be evaluated based on their overall contribution to climate goals and their influence on maintaining security of supply. This may require a flexible setup for transitional technologies such as gas-fired heat and CHP plants, which in our opinion were not sufficiently addressed in the delegated act.
TSC do not specify clearly what kind of methodology should be used to calculate emissions from CHP plants and whether the threshold should be applied to the input or output of CHP units. When calculating the emission threshold for a cogeneration of heat/cool and power from gaseous and liquid fuels an appropriate methodology is needed. The method used by the European Investment Bank (”heat bonus”) is a credible methodology and should be applied.
Alternatively, the TSC presented in section 4.19 for climate change mitigation in case of cogeneration could be based on the ones listed for energy generation from bioenergy in points 5 and 6 part 4.8 of Annex I to allow gas-fired CHP plants to be regarded as environmentally sustainable.
Climate change adaptation TSC for cogeneration of heat/cool and power introduce an emission threshold of 270 g CO2e/kWh. However, why and how gas-fired CHP plants could contribute to climate change adaptation and as a result be regarded as sustainable is not clear because the draft delegated act does not specify this issue.