Implementation status of particular tasks necessary to implement the new economic policy based on inclusion of environmental costs of high-emission sectors of the economy shall be deemed very unsatisfactory. Development and implementation of a fundamental document – the National Renewable Energy Action Plan – was significantly delayed. Implementation of legal solutions necessary to streamline development of renewable energy sources is subject to much more critical assessment. The RES Act, which was to implement directives of the climate and energy package, has not been passed to date; never-ending discussions between particular ministries regarding its form delay implementation of the required regulations by a number of years. The removal of barriers to green economy development notified by commercial circles and public organisations is equally slow. For 10 years we have not developed effective procedures for connecting renewable energy sources to the grid; we have not passed the so-called Transmission Corridors Act, which prevents grid extension – whose poor condition is still the most significant barrier to RES development. Attempts to adapt statutory regulations and administrative procedures to rapidly changing and transforming energy sector made by the administration are delayed and fragmentary. An example is the attempt to implement solutions necessary to allow for development of offshore wind farms to the Polish law, which after many months of discussions halted on spatial planning issues, without even discussing such key issues as power engineering or the environment.

Bearing the above in mind, as well as the fact that competences in the area of development of the climate and energy policy of Poland, including development of renewable energy sources, are dispersed among a number of ministries, we find it legitimate to appoint a Governmental Plenipotentiary for Renewable Energy Sources.

Currently most of these tasks are performed by Ministry of Economy and Ministries of the Environment, Agriculture or Infrastructure, and subordinate institutions. Special RES sections or teams are established in each of these ministries. However, the specificity of renewable energy sources development is related to the need to integrate and synchronise actions of these teams and institutions to achieve a desired effect – effective transformation of the economy towards low-emission one.

Within the past few years the environmental and energy targets of Poland became significantly integrated. EU commitments as well as renewable energy issues gained in priority (the importance of these issues will certainly increase in long term). Therefore, it is legitimate to already today develop a complex programme for institutional and legislative changes necessary to implement the tasks laid down in the National Renewable Energy Action Plan and EU Directives, including Directive 2009/28/EC and many others.

Furthermore, it is also legitimate to specify new general tasks for the development of the renewable energy sector, including implementation of tasks in the area of promotion of and education in renewable energy sources, simplification of procedures related to development and implementation of renewable energy investments, specification of sources and directions for financial aid to investments, and many others.

It is also necessary to specify new detailed tasks for the development of the renewable energy sector, including implementation of tasks related to particular RES technologies, inter alia in the area of the abovementioned offshore wind power (development of separate regulations for offshore wind farms, coordination of these regulations with provisions on construction and operation of offshore facilities, etc.). Certainly, the increasing importance and complexity of particular energy subsectors determines the need for coordinating at least some of them at the level of at least undersecretary of state, in particular with regard to new energy sectors, i.e. nuclear power and renewables.

The main arguments for appointment of the Governmental Plenipotentiary for Renewable Energy Sources and establishment of a RES Department:
1. Insufficient production of energy from RES, in particular from technologically modern sources yielding predictable results in long time.
2. Lack of long-term and stable strategy including a support scheme for new renewable energy sources that would also stimulate industrial development in areas such as production of components, technological development, creation of jobs, etc. These issues shall fit into the comprehensive development of the Polish economy.
3. Lack of educational and promotional actions related to social acceptance for common use of RES as an alternative energy source and the fundamental tool to reduce CO2 emissions, what is a fundamental element of transformation of the Polish economy towards a low-emission one.
4. Lack of actions related to development of infrastructure allowing for common development and application of RES.
5. Lack of a comprehensive strategy specifying the vision of sustainable development to reduce CO2 emissions with regard to environmental requirements for investments.
6. Ineffective use of funds supporting the sector’s development, including funds from the substitution fee.
7. The need for better understanding of the needs of the dispersed energy sector by representatives of the state administration and decision-makers.

With regard to the above it is necessary to appoint a Governmental Plenipotentiary for Renewable Energy Sources, whose actions could consist in initiating governmental works in the area of RES development and coordinating all legislative works pertaining to RES development, carried out by the central state administration institutions. Certainly, the works of the Governmental Plenipotentiary for Renewable Energy Sources would require expert and organisational aid. Therefore, it would be necessary to establish a substantive base – for instance within the structures of Ministry of Economy – and establish a new Renewable Energy Sources Department. Currently there is a RES section in the Ministry’s of Economy Energy Department; however, it would be incapable of performing these tasks, if only due to insufficient number of personnel. Therefore, a RES Department shall be established similarly to the Nuclear Energy Department, which would be responsible for the substantive, organisational and office service of the Plenipotentiary. Regardless of the works of the RES Department the Plenipotentiary would be obligated to cooperate with representatives of the RES sector, including non-governmental organisations. Attached please find a potential regulation appointing the Governmental Plenipotentiary for Renewable Energy Sources (developed on the basis of a regulation appointing the Governmental Plenipotentiary for Nuclear Energy).

I hope that our appeal will gain your support.

Krzysztof Prasałek
President of the Polish Wind Energy Association