/ PRELIMINARY OPINION ABOUT THE NECP AND THE ENVIRONMENTAL REPORT IN PUBLIC CONSULTATION

PRELIMINARY OPINION ABOUT THE NECP AND THE ENVIRONMENTAL REPORT IN PUBLIC CONSULTATION

The HSE Group had expected that the National Energy and Climate Plan (NECP) would recognise the need to implement all planned key projects of the HSE Group, which are, in our opinion, essential for achieving the national climate and energy objectives, both from the aspect of increasing the share of renewable energy sources (RES) in the final energy consumption and reducing greenhouse gas emissions. Unfortunately, we have to establish the following facts:

1. The NECP does not provide for further planning and construction of new hydro power plants and pumped-storage plants, which negatively affects both the level of energy self-sufficiency and the competitive position of companies that possess concessions for the energy utilisation of water resources, and the profession and brain drain from this field.

2. It is unacceptable that as early as at the strategic level we are giving up on potentially important projects, whose environmental impact will be assessed on the level of siting of an individual concrete project, while Slovenia is, according to the latest data, in the group of countries that lag the most behind the REC objective until 2020.

3. By excluding hydro power plants on the middle Sava until 2030 and by making further development of RES and hydro power plants conditional on the drafting of additional vulnerability studies and legislative amendments, the NECP measures actually paralyse investments in RES at least until 2023
when it will be time to prepare a new draft of the NECP in accordance with EU law. The NECP, in the form in which it was last presented, maintains the status quo in the field of development of RES in the next 34 years. 

4. At the same time, by failing to specify concrete projects for attaining the objectives, which is also incompatible with Regulation 2018/1999 on the governance of the energy union, the NECP does not allow the principle of the prevailing public interest to be implemented
the Energy Act, namely, stipulates that the projects and measures specified in the NECP are in the public interest from the aspect of energy and climate policies. 

5. It is also necessary to specify projects in order to obtain more favourable financial resources, as one of the requirements to obtain funds is that the projects are part of the NECP – support for the implementation of the projects which will be part of national climate and energy plans is also one of the guidelines of the recently adopted lending policy of the European Investment Bank (EIB) for the field of energy.

6. Considering the current development, experience with siting and capacity of the electricity network, the planned growth in the production of electricity by solar power plants and wind farms is completely unrealistic. What is more, the manner in which the transmission and distribution network will be developed to compensate for such growth in production capacity is not presented in the NECP. Development of pumped-storage hydro power plants as environmentally friendly reservoirs is not envisaged either.

7. Although the role of natural gas as a transitional resource is also clear and recognised at the EU level, the NECP does not envisage natural gas-fired thermal power plants which would compensate for electricity from coal-fired generators due to the objective of decarbonisation already before 2030. Production of synthetic gas as its partial replacement is not fully presented. Such definition in the NECP does not provide for further utilisation of the existing energy facilities, which are equipped infrastructure-wise both from the aspect of the network and the supply of energy and consumption of thermal energy. The guideline of the NECP in the field of natural gas for the production of electricity threatens the supply of the entire Šalek Valley with thermal energy, which is currently fully reliant on the supply of thermal energy from the Šoštanj Thermal Power Plant (TEŠ) and needs replacement production facilities already before 2030.

8. Finally, the NECP also has many shortcomings in the key Chapter 5, which does not contain breakdown by individual measures of financing both from public and private funds, nor does it envisage sources of financing of the abolition of the use of domestic coal.

Let us emphasise at the end that the pressure to meet the deadlines set by the EU, which have been known for a long time, must not be an excuse for drafting an empty document on the level of measures and projects, which will be intended only for finding the lowest possible common denominator and meeting the deadlines, and not for actual strategic reflection on further development of the energy and climate policies in Slovenia, which will enable an economically sustainable transition to a low-carbon society.

In the opposite case, it may happen that, considering the complexity of siting of new production facilities and their construction, the supply of Slovenia with electricity at a competitive price after 2040 will be threatened, which will have catastrophic consequences to the development and competitiveness of the Slovenian economy and society as a whole.