Position on the call for feedback on EU Taxonomy

The Polish Electricity Association (PKEE) supports the idea of establishing a common language in order to ensure transparency and to provide a framework for investors and businesses. However, the main goal of the taxonomy must be to ensure the best investment framework allowing a cost-efficient transition. taxonomy must be to provide the best conditions for investment to enable transformation to take place in a cost-effective manner.

It is crucial to highlight that due to different starting points and energy mixes, the burdens resulting from the energy transition towards a sustainable economy will be unevenly distributed across the individual Member States. Therefore, countries that face more difficulties in the energy transition journey will need dedicated funding. In our opinion, the taxonomy should not only reward the current performance but also take transitional plans into account. In our view, the taxonomy should reward not only current achievements but also take into account transition plans.

Bridging technologies

A point of the utmost importance for the PKEE Members is that the list of environmentally sustainable investments should include all types of economic activities that can significantly reduce the negative impact on the climate. Transitional energy sources and bridging technologies such as generation sources based on conventional fuels - gas, nuclear energy – should be the important elements of energy transformation, as enablers of renewable energy sources integration, and thus as sustainable investments, however meeting the strict criteria of the emissions performance standard. These bridging technologies not only help to depart from coal mining and energy generation from coal but also to enable further development of renewable energy sources. Transitional energy sources and bridging technologies, such as sources using conventional fuels - gas, nuclear - should be important elements of the energy transition. Because they enable the integration of renewable energy sources, when they meet strict emission criteria - they can be considered as sustainable investments.

Bridging technologies will not only help to move away from coal mining and energy generation, but will also enable the further development of renewable energy sources.

Investments in gas networks should also be included in taxonomy if supplying high-efficiency natural gas-fired units required to ensure the security of supply to support a cost-efficient energy transition. All investments in electricity grid infrastructure (both at transmission and distribution levels) should be defined as sustainable to support further electrification and transition towards the carbon-neutral economy.nvestments in gas networks should also be included in the taxonomy - as long as they supply natural gas to high efficiency power units - necessary to ensure security of supply and support a cost effective energy transition. All investments in electrical network infrastructure (transmission and distribution) should be defined as sustainable to support further electrification and the transition towards a climate neutral economy.

No exemptions from the Life Cycle Evaluation exclusions from life cycle assessment (LCE)

The PKEE postulates that there should be no exemptions from the Life Cycle Evaluation (LCE) assessment for any kind of technology and that data is needed for each technology which requires to involve experts from relevant sectors in the Technical Expert Group (TEG) work. In our view, profound consideration of scientific evidence and further coordination within the Commission would be needed to establish the screening criteria that are well integrated into EU energy policy.

In our view, the creation of verification criteria that fit with EU energy policy will require in-depth consideration of scientific evidence and further coordination within the European Commission.

Although the PKEE endorses the Commission's approach of having technical screening criteria, in views of recent developments, PKEE Members call on the legislators to opt for a mixed system where delegated acts specify sectors and criteria while the implementing acts should include specific thresholds (qualitative and quantitative), measures and DNSH analyses. PKEE members recommend that legislators opt for a mixed system, in which delegated acts define sectors and criteria and implementing acts should include specific thresholds (qualitative and quantitative), actions and analyses not conflicting with other environmental objectives (DNSH).