EU Tracker – Local heating and cooling plans in Poland
Summary
What is the status of the transposition of Art 25.6(EDD) and its implementation ?
Poland is currently not well-prepared for the transposition of EED article 25.6. Regulatory changes, targeted support mechanisms and substantial capacity building will be needed.
Polish municipalities are obliged to draft energy supply plans, but these are generally carried out in separation from their overall activities related to climate, energy and spatial planning, and have a low compliancy rate. The key role of energy planning for reaching air quality and low-emission objectives has however been recognised nationally. Technical support to municipalities is limited and organisational support framework for municipalities is weak. Good practices for technical guidance and support to municipalities to support their heat transition exist but have not yet been deployed at scale nationally. Local administrations face a severe staffing shortage and are greatly constrained in their capacity to undertake energy and climate planning. To make a transposition of EED article 25.6 feasible and to properly align local efforts to national and European targets, regulatory adjustments, substantial investment in human resources and local governance capabilities, improved alignment between energy planning, spatial planning and emission reduction targets, and enhanced multi-level coordination will be needed.
Detailed assessment
The legal framework and the obligations
An obligation to provide a local energy supply plan exists, but is not well integrated in local spatial planning and governance practices
Overview of the legal frameworks per governance level
| National | Poland’s Energy law (Dz.U. 1997 nr 54 poz. 348) defines the overall regulatory framework for energy related issues in Poland, including the competencies for subnational and local governments. Poland’s overarching climate and energy policy objectives are stated in the strategic document Energy Policy of Poland until 2040 published in 2021. One of its main objectives, Specific Objective 7, is to increase the efficiency and renewable and waste heat share in District heating and to expand it to an additional 1.5 million households by 2030. The document stresses the critically important role of energy planning at the level of municipalities and regions for rational energy management, improved air quality and increased use of local energy sources, with an aim to increase the number of municipalities with energy plans. Targets in terms of GHG emission reductions, renewable or waste heat share or allocation of funding for such measures are not stated, but a target to meet heating demand for all households in a zero- or low-emission manner by 2040 has been indicated. Poland’s national Energy and Climate Plan (NECP) submitted in 2019 has no targeted measures and objectives for heating and cooling. Public consultation for a 2030 heat strategy was conducted in 2022, but a date for its publication has not yet been announced. |
| Regional | Polish Regional authorities (voivodships and powiat) are responsible according to the Energy Law for ensuring the security of supply of heating in their region, which includes a responsibility to coordinate and assess heating supply plans conducted at the local level. |
| Local | All Polish Municipalities are legally obliged to prepare municipal heat, electricity and gas supply plans of 15 years once every three years as stated in article 19 and 20 of the Energy Law. These plans mainly address the security of supply for heating and are often drafted by or in close collaboration with energy companies and utility providers. They do not specifically address energy use for cooling and do not offer a strategic and spatially targeted vision to decarbonize the heating and cooling across its entire territory. Only around 20 % of Polish municipalities had provided such plan by 2020. Those drafted are often insufficiently detailed, and generally not aligned with other municipal policy and planning documents, despite legal calls for alignment. |
Content of local heating and cooling plans according to the law
The main elements of the energy supply plan as defined in article 19 of the Energy Law include:
- An assessment of the current supply for the supply of heat, energy electricity and gaseous fuels and make assumptions for future supply and demand for at least a period of 15 years ahead, which should cover the entire area of the municipality.
- An assessment of using existing surpluses and local resources of fuels and energy, taking into account electricity and heat produced in renewable energy source installations, electricity and usable heat generated in cogeneration, and development of waste heat from industrial installations.
The plan should be the subject of public scrutiny and review in the drafting phase for 21 days, and should include citizens, energy utilities and other stakeholders that may be targeted. The plan should be carried out in alignment with local zoning plans and local air quality programmes.
The support framework
Poland has no proper support framework in place for local energy planning
Polish municipalities receive very limited support to prepare strategic and spatial energy planning documents, making them largely unprepared for the EED provision. Technical guidance and organisational support are not comprehensively developed, while financial schemes available to municipalities are rarely targeted towards planning related activities. Polish local administrations are also hampered by a lack of financial and staffing resources and dedication needed to carry out these tasks and have issues to access energy-related geodata. Substantial efforts are needed to strengthen the administrative capacity in Polish local administrations to properly and strategically use planning as a tool to decarbonise heat.
Provided Support
| Technical and organisational | 2/5 | There is no comprehensive technical support framework for energy planning at place accessible to Polish local authorities. Some regions have issued more detailed guidance for municipalities to draft energy supply plans. The Silesian Voivodeship’s guidance document, for instance, includes guidance on how to assess the local potential to meet energy need through the identification of local energy resources, including RES and waste heat sources. Municipalities may be provided with external support for identifying heating sources, but rarely for spatial planning related activities. Technical and organisational support for local authorities to improve their capacity of shifting to cleaner and more efficient heat is currently being developed within the framework of the LeadAir Programme, coordinated by ForumEnergii, a Polish energy think-tank. The programme has also supported the development of energy transition maps focused on district heating on the basis of a local transition modelling tool, which may serve as a useful base for building a more comprehensive technical support framework for heat planning in the Polish context. |
| Financial | 2/5 | There is no financial framework for drafting local heat planning or mapping provided to local authorities. Funding may however be used for planning related activities within specific projects, mainly from the national Thermo-modernisation and Renovation Fund. This has been the case for Municipalities participating in the Stop Smog Program, aimed at tackling energy poverty through low-emission projects, which has been recognised as a good practice by the EU Interreg programme. These actions have however not been integrated with the overall energy planning activities undertaken by municipalities. Funding from the Clean Air Programme, established to support the phase-out of individual coal-fired heating in households to reduce the release of harmful Particulate Matter (PM), has mainly targeted private households directly (and mainly to individual gas or biomass boilers).The allocation of energy-related funding sources from the National Recovery and Resilience Plan (RRP) to Municipalities for energy projects have been delayed as a result of disputes over the rule of law between the European Commission and the Polish Central Government. |
| Staff & skills | 1/5 | The lack of staff in local administrations is a key constraint for the development of energy supply plans, and for energy and climate planning in general. Most local administrations have no dedicated staff with competence in energy efficiency or planning. Heating supply plans and climate and energy-related documents are thus prepared by external contractors. A national support scheme to train energy experts in local and regional administrations, mainly funded by the EU, was operational between 2014 and 2020. A large number of Polish local authorities have nevertheless used funds to strengthen their competences and capacities on areas related to the heat transition, either from EU funding (ELENA and LIFE) or from their own budgets. Regulatory changes in the tax regime, the COVID-19 pandemic, Russia’s full-scale invasion of Ukraine and the energy crisis have put substantial budgetary pressure on Polish Municipalities. Providing basic services has in this context become the utmost priority, including covering the cost of heating. Combined with a lack of administrative capacity and know-how, this has in many cases constrained the ability for Polish local administrations to devote the necessary time, resources and attention to strategically and structurally address energy efficiency, emission reduction, air quality and the cost of energy for end consumers, without adequate support mechanisms at place to build up the competence and capacity needed. This may in part explain the low compliancy rate of energy supply plans, and their lack of alignment to other energy, climate and spatial development documents and dedicated investment schemes. |
| Access to data | 2/5 | District Heating supply data to municipalities can be provided by the distribution network operators on a voluntary basis. This access is often dependent on the relationship between local governments and the operators, often owned by one of the four state-controlled energy companies PGE, TAURON, Enea and PKN Orlen. Heating demand data is only accessible from public buildings and multi-family housing and rarely digitized and harmonized, which makes it costly to collect. Additional data-related constraints include lack of digital tools and databases to store, manage and visualize spatial and other heating related data. The Central Emission Register of Buildings (CEEB), a database, was launched in 2021, to which property owners are obliged to submit data on heat sources and fuel combustion of buildings for both the residential and non-residential sectors. Local administrations have recently had access to these data, key for heating and cooling planning purposes. |
