Although hydrogen will have a small role in complimenting the country’s fuel mix, it will be key in achieving climate neutrality. It will replace fossil fuels where electrification, based on renewables (RES), will not be enough, such as in aviation and heavy industry, as well as in long-distance transport and power generation. However, for hydrogen to fulfil its role in decarbonizing the economy and building Poland’s energy independence, it will have to be green - that is, produced domestically using renewable energy. Which is why the main shortcoming of the document is that it foresees an initial role for hydrogen production from natural gas or coal.

Solid foundations

The draft Strategy is a good basis for further discussion about the development of the Polish economy, because it:

• sets a clear, ambitious, but realistic quantitative target of installing 2 GW of electrolyzers by 2030, an assumption compatible to those of other European countries;
• supports the EU’s goal to achieve climate neutrality by 2050,
• aims to build Poland's energy independence.

Key development areas

The Hydrogen Strategy gives key directions for the development of this new sector in Poland. The Strategy:

• comprehensively identifies the sectors in which hydrogen may have an important role in the future, i.e. heavy industry, transport, power and heating,
• recognizes the key role of green hydrogen, produced from RES, which is closely related to the development of renewable energy,
• indicates specific technologies, where hydrogen can be used: buses, polygeneration systems (production of electricity and heat) in buildings, energy storage for use in the electrical grid;
• identifies the need for legislative changes in the form of a new Hydrogen Law.

To be improved

However, the Hydrogen Strategy should be amended in the following areas:

1. Quantitative targets for hydrogen use in the medium (2030) and long-term (2040 and 2050) are missing, which prevents the Strategy from being a solid guide for the development of this market[1]. 
2. The Strategy does not preclude support for emission-intensive hydrogen production from fossil fuels, which contradicts the goal of the Hydrogen Strategy itself, i.e. minimizing dependence on fossil fuels that contribute to greenhouse gas emissions[2]. Currently, the gray hydrogen produced in Poland is highly emissive and based on natural gas. Supporting the production of such hydrogen, even with CCS technology, would indirectly subsidize the Poland’s dependence on natural gas imports[3]. 
3. The Strategy does not give enough information on the "Carbon Contract for Difference" support scheme. The contract for difference can be a key incentive for industry to purchase green hydrogen while encouraging investment in its production. The Strategy lacks a definition of this support system, scope of application, and implementation pathway in Polish law.
4. In anticipation that the domestic supply of green hydrogen may not be sufficient to meet the future demand for hydrogen, the Strategy should encourage the participation of Polish companies in hydrogen generation projects outside Poland for the purpose of meeting this demand.
5. The Hydrogen Strategy is not reflected in other very important strategic documents - the recently adopted Polish Energy Policy (PEP) [4] and the National Energy and Climate Plan (KPEiK) [5]. As a next step, these documents need to be updated.

Conclusions

Producing green hydrogen for the Polish economy will require a new approach to renewable energy forecasting and development. Government documents such as KPEiK and the recently adopted PEP will need to be updated.

The draft Hydrogen Strategy sets a target of installing 2 GW of electrolyzers by 2030, which will produce nearly 200,000 tons of hydrogen per year[6]. Approximately 9.4 TWh of renewable electricity will be required to produce this amount of green hydrogen[7]. KPEiK forecasts a total electricity generation of 200 TWh in 2030[8] (in PEP - 181 TWh[9]). The additional demand from renewable sources alone will thus account for as much as ca. 5% of the total projected electricity generation[10]. This means that RES development targets in these documents are insufficient to ensure green hydrogen development.

To enable a dynamic development of the hydrogen industry it will be necessary, among other things, to revise the distance regulation[11] which limits onshore wind investments and continue the development of photovoltaic installations. Enabling the production of hydrogen from wind and photovoltaic sources will make it low-cost, resulting in measurable benefits for the Polish economy. 

Poland is moving away from coal and low-carbon alternatives are urgently needed. Green hydrogen development creates opportunities to reduce emissions and replace natural gas in many sectors. It also provides an opportunity to maintain energy security - as green hydrogen complements an energy mix based on renewable sources. The Hydrogen Strategy is an important first step in this direction. However, specific numerical targets must be written into it and the Strategy should also include more concrete proposals for a support system for green hydrogen.

At the same time, the Hydrogen Strategy cannot be detached from the reality of Poland's climate and energy policy and documents such as PEP and KPEiK. When planning electrolizer capacities and sectoral demand for hydrogen, it is important to plan its production from, as much as possible, domestic renewable sources. The alternative would lead to increased dependence on electricity imports, not necessarily based on RES. In such a scenario, the Hydrogen Strategy would neither contribute to building Poland's energy security nor guarantee that the subsidized hydrogen would be green.