The Polish Electricity Association's position on the recast of the Directive 2010/31/EU on the energy performance of buildings

Ensuring the right requirements for buildings is essential to meeting climate targets and reducing the European Union's dependence on fossil fuel imports. However, the Polish Electricity Association (PKEE) draws attention to the provisions concerning efficient district heating systems presented in the draft amendments to the Energy Performance of Buildings Directive (EPBD) and to certain inconsistencies with other documents of the "Fit for 55" package.

The PKEE has noticed serious inconsistencies in the detailed provisions:

  • Firstly, the EPBD must be coherent with the recast of the Energy Efficiency Directive (EED) and with the new definition of an efficient district heating and cooling system. It should be noted that the EED recast provides a schedule for tightening the requirements for efficient district heating and cooling systems. According to the above, the use of heat from high-efficiency gas cogeneration could provide the basis for meeting the criterion of efficient district heating systems. Yet, the revision of the EPBD according to the proposed criteria would significantly limit the connection of new users to these systems after 2030, as a result blocking the development of efficient district heating. In principle, the EPBD cannot exceed the requirements set out in the EED recast in terms of both energy sources and timing. Therefore, the PKEE encourages enabling connecting new buildings to all efficient district heating systems, not only those based on renewable energy and waste heat. Otherwise, a risk of degradation of district heating based on natural gas high-efficiency combined heat and power emerges, while this technology is important in terms of heat supply and to the national power system in Poland.
  • Secondly, it is not clear whether prohibiting the financial support to boilers using fossil fuels applies only to individual boilers or also to heat sources in district heating systems. A process of phasing out fossil fuels in district heating should be carried out carefully, taking into account the technical, social and economic possibilities as well as local conditions. In the opinion of PKEE, it should be possible to finance heat sources using natural gas in heating systems due to the high efficiency of combined generation and lower greenhouse gas emissions. We wish to strongly underline that a complete phase-out of fossil fuels (including natural gas) from heating by 2040 at the latest (as it was proposed by the Commission in the EPBD recast) will not be possible in case of Poland. The PKEE believes that any restrictions on financial support for the purchases of heat sources should primarily apply to other fossil fuels such as coal and oil.
  • Moreover, the EPBD proposes that the total annual primary energy consumption should be covered by, among others, energy from RES produced on-site. This eliminates electricity from national electricity grids, and the exceptions provided for in the EPBD proposal are significantly restrictive. In the opinion of the PKEE, supplying a building's primary energy demand with electricity from electricity grids, which are not dedicated ones, should be allowed as meeting the definition of a zero-emission building.

Furthermore, the PKEE believes that the role of the distribution system operators (DSOs) cannot be marginalised with regard to the sustainable mobility infrastructure (in and adjacent to buildings) as well as with regard to the smart readiness indicator, due to the fact that it involves the need for additional investments in the distribution grid infrastructure and also in relation to the possibility of using flexibility services by DSOs. DSOs should have the right to verify the availability of grid capacity in a given location.

Polish Electricity Committee's position regarding REPowerEU's plans to rebuild and increase resilience.

July 25, 2022

Polish Electricity Committee's position on the letter signed by Eurelectric relating to the issue of ensuring differentiation of entities participating in the EU ETS market

May 10, 2022

Stance of the Polish Electricity Committee on the amendment of Directive 2010/31/EU on the energy performance of buildings

April 1, 2022

Polish Electricity Committee's position on the draft Council Directive restructuring the EU framework for the taxation of energy products and electricity

November 19, 2021

Stance of the Polish Committee for Electricity (PKEE) on the draft Directive amending Directive (EU) 2018/2001 on the promotion of energy from renewable sources

November 8, 2021

Polish Electricity Committee's position on the European Commission's proposal to revise the EU Emissions Trading Scheme (ETS) and the operation of the Market Stability Reserve.

November 5, 2021

PKEE's position on the Social Climate Fund

November 2, 2021

PKEE's position on the Carbon Border Adjustment Mechanism .

October 28, 2021

Stance of the Polish Electricity Committee on the revision of Directive 2012/27/EU on energy efficiency

October 19, 2021

Polish Electricity Committee on "Fit for 55".

July 14, 2021

PKEE's position on the European Commission's delegated act establishing technical criteria for the assessment of activities in accordance with the principles of sustainable financing-taxonomy

December 16, 2020

PKEE's position on the preliminary assessment of the impact of the revision of Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the Union.

December 1, 2020