Overall assessment

The Polish National Recovery and Resilience Plan complemented by the
REPowerEU chapter consists of 55 reforms and 56 investments. They
will be supported by an estimated €25.27 billion in grants and
€34.54 billion in loans. 46.6% of the plan will support the green
transition (increased from 42.7% before the REPowerEU revision) and
21.36% of the plan will support the digital transition.

Reform "B3.6 Improving the conditions for the development of renewable
energy sources" foresees amendments to the Renewable Energy Act
(“RES Act”), with the goal of creating a better enabling framework for
prosumers, clusters, and energy communities. A new reform G1.1.1 in the
REPowerEU chapter aims to improve the regulatory framework for energy
communities - consists of an analysis with recommendations.

Detailed assessment

General: allocation, definition, transposition

Specific allocation for energy communities

The fund mentions a pre-investment and investment support for existing communities energy companies or entities intending to establish such communities (EUR 189 mln).

Definition of energy communities in line with EU legislation

The fund refers directly to the definition from the Act on Renewable Energy Sources (2015), which, after numerous amendments, provides a relatively good definition of energy communities, in line with the EU's definition. There is also a link to the implementation of the RED II Directive: "Development of local renewable energy sources implemented by energy communities (including energy clusters, energy cooperatives and other energy communities resulting from the implementation of the RED II Directive), group prosumers (collective and virtual prosumers) with particular emphasis on the role of local government units (in particular municipalities and associations of municipalities) ) forming such local communities".

Proportionality of share of total fund allocated to energy communities

Only 20 energy communities (cooperatives, clusters and local
governments’ initiatives) are to be supported in the investment phase.

The allocation of EUR 189 million makes only 0,75% of the grant part.
The support of only PLN 400 k (EUR 84 k) for one energy cooperative
compared to PLN 1.5 million (EUR 315 k) for clusters and local
goverments’ investments, is considered inadequate.

Allocation for the first call for proposals for pre-investment support for 139 entities is PLN 186.9 million (over EUR 42 million)

Availability of tailored financing tools

Only grants are available.

Link to a wider scope of activities and objectives

Link between energy communities, building renovation and energy efficiency

The scheme does not mention a link between energy communities, building renovation and energy efficiency. Only in regard to clusters - extra points will be given to applications with experience of cooperation with scientific units in the field of RES or energy efficiency.

Recognition of energy communities under multiple objectives

In the revised Polish NRRP energy communities are recognised under multiple objectives, including 1) promoting renewable energy and accelerating the phase out of fossil fuels, 2) building energy security, 3) tackling energy poverty.

Transparency and inclusiveness

Holistic strategy to provide financing across different levels of project development

Grids investments supporting the further integration of renewable energy are planned in the Recovery and Resilience Plan, but they not linked to energy communities directly. Pre-investment support is foreseen for 200 energy communities, clusters, and local government initiatives.

The pre-investment support programme shall consist in "developing a legal and organisational format and business model for launching or developing an energy community, and in preparing the necessary analyses and documentation for the investment. This programme shall support, inter alia, local energy market development strategies; analyses of local energy demand and supply; inventories of local energy resources (infrastructures) and their potential (such as capacity to provide energy connections); feasibility studies, business plans, due diligence documents; technical documentation and construction projects."

Transparency of the design and communication of the schemes and measures

The process was rather problematic. The RRP underwent a public consultation process, but two calls for proposals were announced without a proper advertisement. The lack of monitoring committee meetings in this period prevented members from influencing the selection criteria, and the calls eventually launched in Q4 2023. The call for pre-investment support was open until 31.12.2023 and for investment support until 28.03.2024.

Selection criteria and the prioritisation of various social components

The selection criteria are not bad but clearly prioritise clusters over energy cooperatives, the social component is fully missing. There are also concerns regarding the application of the Do No Significant Harm principle.

Decentralised tender process

It is a Centralised call. However, regional and local authorities are represented in the Monitoring Committee, and are able to influence (on a general level) the implementation of the RRP

Existence of procedures to facilitate the participation of energy communities in open calls

The Ministry of Development and Technology issued a number of guiding documents and organised webinars to advertise the call and explain the application procedures. The call for energy cooperatives was prolonged due to small number of applications.

Stability and predictability of the programme through time

Timeframe, budget and number of entities to support are described in the RRP itself, and support conditions in the call. However, changes are planned under the REPowerEU chapter (increase of support), and the details will be announced after the negotiations between Poland and the Commission.

REPowerEU

Inclusion of energy communities in national REPowerEU chapter

In the REPowerEU chapter and the revision of the RRP, support for energy communities was entirely moved to the new part of the recovery plan (as G1.1.2) and upscaled, with the allocation almost doubling (from EUR 97 million to EUR 189 million). Instead of 139, now 200 entities should receive pre-investment support and 20 instead of 10 - investment support.