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Friday, October 07, 2016

EU Set to Tighten Financial Support Allowed for New Coal Plants

The reform of the Emission Trading Scheme that basically taxes carbon dioxide emissions has been controversial. Now a compromise appears nearly certain to pass. It continues some free allowances (which have crippled the price support for allowances to date), but it tightens the rules on financial support for new coal projects. It will be interesting to see the effects on Poland. I doubt anything but major brownouts and the huge increase in imported electricity from our neighbors will move the government to look at reality.

Tuesday, July 26, 2016

European Renewable Energy Investment Flattening Out Despite Calls for More Capacity

     While the European Governments are pushing for ever higher renewable energy quotas, the total rate of renewable energy investment in Europe has flattened out.   "Experts said that investors did not have confidence in European policymakers’ support systems for renewables." EuroActive (2015). "Low-carbon energy" investment in Europe in 2015 dropped by more than half. The Guardian, March 23, 2016. European countries are in transition to support for renewable energy by reverse auctions. Renewable Energy Policy Network, "Global Stats Report: Renewable Energy 2016." Auctions in practice have always been problematic, producing an unpredictable amount of capacity due to limited bids and/or limited build-outs by winning bids. See Mott, "The European Commission's Mismanagementof State Aid Rules for Renewable Energy," PowerGen Europe 2015. A group monitoring the achievement of the Eu 2020 RES targets noted when the guidelines on support were released by the European Commission concern was already evident: “Since the announcement of new state aid guidelines, many potential investors fear less stable conditions. In case the guidelines are implemented as announced, investments will drop to a much lower level.” Keep on Track (2014)(website). This has predictably occurred in 2015-2016.

     Pressure from large utilities in Europe has been effective in pushing the EU towards a policy that rewards the big players in energy, whose cost of capital is lower and whose profit expectations are lower. Auctions for RES support have been a way to allow continued market  dominance of the traditional energy players. See Mott, supra.

     As levels of support go down in many cases in auctions, the percent of projects actually getting built goes down as well.  The "bid in" mechanism is common and precludes this process from creating a stable and predictable supply of RES capacity. This is showing up in the total EU investment results and will grow worse in my opinion until it is corrected.

Thursday, July 21, 2016


Poland has brought a lawsuit to try to get the EU to make the emissions policies subject to the unanimous consent provisions of the European Treaty. No one outside of Poland gives this lawsuit much chance. The new Polish Government also has pushed for loopholes in the climate provisions for EU CO2 reductions by 2030.

The creative use of the forestry provisions threatened to allow Member States to create paper credits for CO2 reduction that basically scammed the system. The use of planting trees to create credits under the Kyoto Protocol was widely criticized by the Left. LINK. New EU earlier proposals have also drawn criticism: "But Kyoto’s accounting rules and its use of a ‘business as usual’ baseline have left it open to abuse. By overstating their “business as usual” logging, governments can scoop up millions of euros worth of carbon credits by simply not hitting their timber-felling targets." Studies have also shown that, for Poland, the cost of re-forestation is likely to be higher that the cost of switching the energy production to cleaner technologies.

The latest proposal from the European Commission, however, seems to have caught the game in advance and may frustrate this effort, by both the terms of the provisions defining when forests can count and by a cap on the use of this form of credits to mean 2030 numbers. "The Commission will introduce tougher accounting rules and will not allow forest management to be taken into account in a bid to head off abuse." EuroActiv, supra.

The lack of a clear understanding of the economics of energy as well as a certain naivety about its leverage in Brussels has continued to plague the new government's initiatives.

Thursday, July 07, 2016

Poland Posed to Have Major Water Problem

The Polish coal sector uses an astounding 70% of all of the water annually used in Poland, according to a new report.  Massive amounts of water are used for cooling at coal-fired energy plants. So when there is a period of low water levels in our rivers and lakes, as we have experienced for the last two summers, there is a huge risk of power outages. Polish electricity is "down" about ten times more each year than Germany (where Polish politicians love to assert that the system is unreliable).

The level of water consumption by energy in Poland is five times the average level in Europe and ten times the global number. Id. This is a very unsustainable situation:

"Water absorption coal-based energy is one of its biggest drawbacks. In terms of the abundance of water, we are in the European Union on the fifth place from the end, before the Czech Republic, Denmark, Cyprus and Malta. Moreover, Poland has one of the lowest of renewable water resources in the world per capita. They are smaller even than some countries in desert zones ... such as Niger, Chad and Sudan," according to Dr. Sylwester Kraśnicki, hydrogeologist with the University of Jan Wyżykowskiego in Polkowice.

Many experts have been cautioning of global water problems in the coming decades. As it now stands, Poland - besides having an unreliable energy system that is starting to cost more than all of our neighbors using a more diverse energy mix - may now face a serious water crisis in the coming years.

Tuesday, July 05, 2016

Poland: It is Not Your Atmosphere.

The last two governments in Poland have echoed a nationalistic theme on energy policy to the effect that Poland should be free to make its own choices on its energy mix. Coal is historically the overwhelmingly dominant source of power and should remain so as a national prerogative. If all of our neighbors want to have green energy as a big part of their mix, that is their choice, but not Poland's.  This is basically and fundamentally flawed logic.

A new NGO study by HEAL, however, brings all of this rhetoric into focus: Poland does not own the atmosphere and has no legal, moral and philosophical right to poison its neighbors. If the shoe was on the other foot and Poland's neighbors were doing this to Poland, we can imagine the outrage of the more nationalistic Polish political voices.

Unfortunately, the Polish power plants excel in emissions to the whole of Europe, causing each year more than 5,800 premature deaths, including 4690 overseas. The deterioration of health caused by breathing polluted air also generates health costs charged to the whole of society - says Veronica Piestrzyńska of the Polish branch of the Health and Environment Alliance (HEAL Poland).

Lignite-fired power plant in Belchatow (PGE) emits far the most polluting of all classified plants, causing annually approx. 1,270 premature deaths. The top five most poisonous plants were also plants in Kozienice (Enea) and Rybnik (EDF), causing each year respectively 650 and 480 premature deaths.

- The transformation towards cleaner sources of energy should be a joint effort of all European countries, but the specific task of standing here in front of Polish, which is the largest in the energy emitter of pollutants - says Marek Józefiak the Polish Green Network.

Poland uses coal for 83% of its energy. It has successfully applied for extra time to meet all EU obligations to reduce emissions from coal-fired power plants. Polish politicians have extracted billions of Euro of EU funding to transition away from a coal-based economy, close mines, and promote renewable energy. But this money has almost entirely been spent to sustain the old energy infrastructure, extending the life of old-fashioned and obsolete coal mines and power plants past their useful life. 

Poland has so far successfully used other people's money to keep its ancient and uneconomic energy infrastructure on life support, while simultaneously dumping the pollutants into the air shared by all of its neighbors. This is done in the name of providing cheap energy, but Polish electricity is more expensive than most of our neighbors, despite the EU and Polish subsidies.  

Obviously Poland cannot continue to defy the laws of economics, even if it can avoid any moral accountability for its energy policies. The time is finally running out for the old obsolete coal-fired plants built in the Soviet era. Modernizing them is prohibitively expensive and financing new coal-fired plants is quite problematic in Europe at this point. Polish politicians can coerce the state-owned companies to stay the course, but this source of financial support is now waning.

Unfortunately at the moment, most Poles want ever more control over their national destiny, seemingly preferring an energy catastrophic failure as long as it is driven off the cliff by a Polish driver. 

From "Thelma and Louise."                             LINK to full report.

Friday, June 24, 2016

Lack of Energy Diversity Cripples Polish Electricity Supply

With 85% of the electricity in Poland supplied by coal, the country is in a unique position of vulnerability in Europe. While the use of coal throughout Europe is declining sharply, it is not changing significantly in Poland. Couple this fact with the steady decline in the profitability of operating coal plants,(1) and you can see nothing to suggest a very bright energy future in Poland under this policy. Recent changes in Poland also seem to clearly have stopped major new wind and PV energy capacity.

What we now see in the interim in Poland are the consequences of a lack of energy diversity in the supply.  For the second summer in a row, the coal plants are struggling due to schedule maintenance in the warm weather but also due to low water levels. While the wind can also be lower in these hot and dry months, our neighbors with extensive PV capacity are seeing a nice natural balancing with the hot and clear weather. Poland does not have that asset.

Even the long-term strategy of meeting the EU renewable energy targets in 2020 and 2030 is linked now strongly to co-firing biomass in coal plants. This could be as much as 75% of the total RES in 2020 planned by the new government.  Except if the coal plants themselves fail, then the co-firing as a RES source fails as well. Given so many old coal plants must be closed by the final deadline for meeting EU emission requirements, this is a very poor long-term gamble for RES capacity. In the short-term, it also means that disruption of the coal-fired plants like we have seen due to water problems, will also stop production of co-fired biomass energy. New coal plants hoped for construction in the near-term are also having difficulty securing financing from private equity and all forms of debt funding.

The surest way to drown in the ocean is to try to consistently swim against the current. The force of nature is just bigger than you are and it is a contest that you cannot win.

In the same way, fighting against the long-term economic and technological trends in energy seems like a likely way to end up dead in the water.


(1) The UBS study in 2015 pointed to massive closures of coal-fired plants in Europe and very limited profitability of plants still operating. Bloomberg has reported a general trend to phase out coal plants in Europe.

UPDATE: Monday, June 27, 2016: The peak power load was even greater on Friday. The cooling water problem limited coal-fired power plants operations. All of Poland's neighbors did not have the problem and their prices were much lower, since they all have much higher penetration of PV in their energy mix.

Wednesday, June 15, 2016

Poland Used Up Its Energy Transformation Funding to Prolong Dependence on Coal

A new report from the very credible Client Earth group answers the question "why can't Poland get money from the EU to fund the transition away from coal to cleaner technologies?"

"As many as 70 per cent. projects implemented by energy companies in exchange for the free allocation of emission of greenhouse gases include carbon infrastructure, and only 10 in renewable energy sources.However, the purpose negotiated by the Polish government called "derogation" .... was to be the modernization of the outdated energy sector and diversification of sources of supply. Investment in the coal could be affected by serious problems after 2020, when the price of allowances will begin to grow - comments by ClientEarth Foundation, Lawyers for the Earth."

The total funding up to 2020 was 4.5 billion EURO! Instead of spending the support, as intended by the EU, on de-carbonization, Poland spent it mostly on projects to support the existing coal energy infrastructure. Poland is still left with a bunch of very old coal-fired power plants (30 years old plus) that cannot produce economical electricity or meet EU mandatory emissions standards. No intelligent business would have made the same decisions.

Now that Poland is getting into a corner on carbon emissions, the EU Industrial Emissions Directive, and the Renewable energy Directive (all of which now involve billions of Euro is penalties and costs to the Polish economy due to the continued heavy use of coal), Poles are screaming to change the rules. The morality and equity of this position is very dubious after taking billions of Euro to make the changes and blowing the money. Poland's behavior toward coal is pretty much that of an alcoholic.... a substance abuser that cannot stop and will use everything around them to feed the habit.

Monday, June 13, 2016

RES Market in Poland: Biomass and Biogas New Favorites - Wind and PV Seem Doomed

The biggest development in the renewable energy prospective market in Poland is the new amendment in the Sejm, which has passed the committee and appears to be sailing for rapid rubber-stamping by the rest of the government in Warsaw.

The single biggest characteristic of the law is the emergence of separate technology "baskets" for renewable energy auctions. The Polish Government figured out that it can control the mix of technologies by setting the size of the baskets as well as the reference prices (maximum allowed support in the form of a contract for the difference). Regardless of any other developments, it appears that this procedure will be used to skew the support away from PV and wind to biogas and biomass.

The characteristic being used to "make the cut" is the stability and reliability of the renewable energy source. The intermittent nature of PV and wind have led the Polish Government to put them into a less desirable category in baskets which can be limited by size and level of support in any future auctions. The amended bill is not available yet as this is written, but the basic approach is set out in the draft proposal introduced a few weeks ago. The net reason has been referred to by Grzegorz Wiśniewski from the Polish Institute for Renewable Energy as the end of PV and wind energy in Poland ("ustawa o OZE i ustawa „antywiatrakowa” zamykają możliwości realizacji programów inwestycyjnych w fotowoltaice i energetykę wiatrową"). 

While there are objectionable provision to the new laws that will likely be reversed by the European Commission if they are not taken out in subsequent proceedings in Poland, the basic matrix of using separate technology baskets and references prices has been approved by the Commission for auctions in other countries. I do not believe that this mechanism really does anything to satisfy the competition provisions of the European Treaty, but the Commission has pushed it, 

In Poland, the effects will be widespread. Wind and PV investors that have been quite active are starting to fold up their tents. The under current here is that these are mainly foreign firms and the new government has made no secret of its skepticism about encouraging foreign investment in Polish energy. The allegations that a 15% or even 25% RES share of electricity that relied mainly upon wind and PV will introduce really serious grid instability has been taken as a truism and not critically evaluated. Even the experience in Germany where the share is over 40% does not necessarily provide support for this assumption. 

We nevertheless are where we are. Until 2020 arrives and the RES target is missed, it is unlikely that there will be a major change in the support for new projects. The existing system will inevitably see changes with the EC decision in SA 37244, the pending state aid case on green certificates. But that system will cut off July 1, 2016, unless a dramatic political change occurs and it is extended. The extension of that law is probably the only viable means to assure Poland meets its 2020 commitment. The auctions will be delay construction until the last minute and seem to clearly not portend enough RES capacity to satisfy the requirement.

Biogas will do well under the new rules and will remain one of the few technologies that has enough support to justify new projects. The auction mechanism itself will restrict biogas development to some extent, knocking out the smaller developers and speculators. Small farm projects will also struggle with the proposed reference price (550 PLN/MWhr), especially with their limited co-generation potential. Biogas will also become more critical as the Circular Economy package gets approved and implemented, pushing organic wastes into biogas and away from landfills and incinerators. See presentations from Waste Management in the Circular Economy 2016, European Academy Conference, May 12-13, 2016, Berlin.

UPDATE: As of June 23, 2016, the new amendments are headed to the President of Poland for signature. I still expect something from the European Commission on green certificates. The net results will be a sharp decline in interest in wind and PV in Poland. Some complicated issues on co-firing including, not only the state aid issue, but the technically costs of going to higher biomass percentages of fuel as well as legal issues on burning waste. I am speculating that the inclusion of waste wood by the government may be a sign that they got feedback from the Commission that the reference price for co-firing in an auction will be lower than they wanted. I have no doubt whatsoever that the Polish Government is trying to push as much co-firing as possible, but there are limits that may impede this from going the way they want. Among other items mentioned above, some of the old plants that have been the biggest co-firers will be closed after 2020. The local biomass rule will likely be challenged by someone and could continue uncertainty over co-firing well past 2020.

Wednesday, June 08, 2016

Major German Grid Operator Shoots Down Argument that Renewables Cannot be Integrated into the Grid

This is heresy in the utility business and they are supposed to keep exaggerating the adverse effects of renewable energy on the grid. But Boris Schucht, CEO of 50Hertz Transmission GmbH since 2010, is remarkably candid in his interview this week: "There are a certain number of myths in the energy industry. One of them is that we need more flexibility in the system to integrate renewables, like energy storage, interruptible loads or backup power plants. That’s a myth. We have a lot more flexibility than we need and a huge amount of potential."

He advocates some changes but is not repeating the doomsday scenarios echoed by Eurolectric's lobbyists. On days of excess energy, he says Germany can just export to Poland. If Poland is below the renewable energy target in 2020, it will have no choice but to take German wind electricity, even if that means replacing Polish coal plant electricity output. The decision for Poland is not whether we have renewable energy or not, but whether it will be Polish or German.  Few politicians here understand this.

Tuesday, June 07, 2016

Where is that Reliable Coal Energy When We Need it? Poland faces Energy Shortage

We are constantly lectured in Poland about how reliable the conventional energy system is and how unreliable renewable energy is.  Reality, however, suggests that our neighboring countries with diversified energy supplies are much more secure, much more reliable and now actually cheaper.

While Poland struggles with a 30-year old energy infrastructure, built by the communists who seemed incapable of building a reliable automobile, our neighbors have shifted to a large mix of renewable energy technologies that add alternative sources of power that generally compliment each other.

As energy storage is also deployed all around us, the future of electricity supply seems to be alluding Poland. The government seems locked into 1960s thinking about these issues.

Now a new report indicates that energy shortages may again appear in Poland in the late summer. Because, guess what, coal is unreliable under certain weather conditions (hot weather, high demand, and low water levels).

Not only are we seeing the cost of new coal plants grow larger than onshore wind, but without the line of investors and banks willing to fund them, but now we seem to be experiencing the negative side of a lack of energy diversification.

Tuesday, May 31, 2016

"Market power": Capacity Markets Are Not Cost Effective

We are often told in Poland by advocates of coal that renewable energy is too expensive. They ignore the fact that onshore wind is cheaper than new coal plants right now and that PV will be cheaper during the investment life of any new coal plant planned today.

The cost of renewable energy support in Poland is about 7 PLN per month on an average consumer bill of 153 PLN. Most of this has gone to electricity producers who would have generated the electricity without support (old hydro and co-firing). Had new capacity in RES been supported, the impact on consumers is normally cut in half by pressure of prices due to increased supply.

Now we are told that consumers must pay to have old coal-plants standing by on the few days a year when extra power is needed. Studies in the United States have demonstrated that this is the most expensive way possible to meet peak demand. See U.S. Electric Power Research Institute (2013).*

Now, however, the cost impact on consumers is being finally discussed in Poland. Consumers will face an increase in bills of 18-50% to allow the big utilities to keep old coal plants on stand-by for peak demand. This is many times the impact of RES support on consumers and one would have hoped that the government would have carefully evaluated alternative schemes to deal with peak demand.  But I cannot seem to find the studies or reports or references generated during this major policy development.


* Germany is reporting to have saved billions of Euro on electricity transmission costs by its moves into energy storage. This savings is not even factored into most analysis of energy storage vs "peaker" plants.

UPDATE: The cost of storage in 2015 is generally quoted as $.20 per kWhr. This price is falling rapidly (about 15% a year). The comparison should be between the peak rate of electricity and the lowest demand period. Poland has already hit this level last summer for a period. The next comparison should be the cost of the peak energy  from a "capacity market" system. I believe that this will exceed the storage cost in the near term. See Energy Strategies paper. It is hard to find data that is transparent, i.e. it is mostly reported as a surcharge on the rate per kWhr in monthly bills. The impact on monthly bills is huge! The DG Competition will require that all technologies compete in "capacity markets." This includes energy storage which competed unsuccessfully in the UK auction last year.  By next year, I expect that energy storage in many places will be competitive in this auctions, which is why Eurolectric successfully lobbied to get stored energy to lose its renewable energy support under the guidelines from the European Commission. This is not a law and will likely be challenged - most Member States have not adopted this stupid rule.

UPDATE 2: In the UK, about one billion GB a year will be passed on to consumers by 2019 for a "capacity market."  Despite the real need for a peak power reserve, only 1% of the capacity market will be linked to demand response.   This is an outrageous waste of the public's money!

Tuesday, May 24, 2016


We live in a strange time and place. Electricity in Poland is much cheaper than it was a few years ago, but the experts are projecting power shortages in the near future. The rules of supply and demand seem suspended by the regulatory and political situation. The low price of electricity in Poland is stopping new construction and investment for multiple possible sources.

Polish government officials do not want us to follow the road of Germany and develop a higher percent of renewables. They say it is too expensive and unreliable. Yet German electricity is cheaper than Polish power and has far, far fewer outages.

The Polish Government objects to adding too much to the price of electricity to support renewable energy, but proposes to continue to use most of the support for the existing production of electricity with only a small partial switch to biomass to make it "green." This does not create any new electricity and detailed studies show that it is 100% transferred to end-users [where support for new RES production ends up increasing all the supply of electricity and has only a fractional impact on end-user prices]. Let's use the most expensive option in the name of saving money!

Irrational policies founded on half-truths and misrepresentations are not unique in politics throughout the world, but they seem to be a well-developed specialty in Poland.

Wednesday, May 18, 2016

Reality Hits Polish Government Plans for Renewable Energy

The Polish law on renewable energy has been a moving target for years. Originally, the law was deliberately delayed to allow the state-owned energy companies to keep receiving support which the European Commission would have stopped if the new law had been notified under the treaty. Now the delays are being triggered by the new government's efforts to amend the program on the fly.

The government has convinced itself that what RES capacity is already done and more co-firing will be all that we need. Some additional biogas plant construction (actually a lot in real terms) is strongly supported in their mix. But the classic RES technologies are on their black list. They have been completely persuaded by the coal lobby that these technologies are too unreliable to be major parts of the energy mix.

The factual basis for their assumptions is being broadly challenged by the RES sector. Poland will not meet the 2020 target without a serious program that includes the full mix of RES technologies. The need to start addressing the 2030 goal is also closer than it looks. The need to expand the energy production sector by any means to avoid black-outs in next few years also strongly suggests that new electricity generation supported by investors (RES) should be promoted, while the government remains free to consider its fantasy of major new coal blocks filling the void.

Many of the old coal-fired plants that have been co-firing will be offline in 2017-2020. A lot of these are the biggest co-firers. Unless they are operating in 2020, nothing that has been done will count toward the target. A lot of the new coal-fired plant construction is a bit delusional - the financing is just not there for this technology when coal plants are closing all over Europe. The debt and equity markets obviously know this, even if the Polish Government pretends not to notice. Expansion of co-firing will be quite problematic, even assuming that the support scheme to do it gets by the European Commission state aid review.

Now we are seeing the deadlines for the PiS amendment to the law start to drag out. A big part o this is undoubtedly feedback from the Commission looking at the new law. The gap between installations covered by the current law (green certificates) and facilities that will be constructed based on the auctions is growing. This is the period when facilities cannot qualify under the old law and cannot get support under the new law. I predicted that it would be 24 months or more and that may be charitable. Continuation of a modified green certificate program approved by the Commission is probably the only viable alternative remaining to meet the 2020 target. This would have to be tweaked to add correction coefficients by technology to reflect their actual cost of production. See prior posts on Mott's Blog. This RES deficit will be especially true when the accumulated green certificates are largely voided by the Commission's action in the enforcement case SA 37244.

The whole situation is made much, much more difficult by the lack of transparency surrounding the legislative process. This has been endemic from the start of the RES legal changes in 2010. Rather than incorporate a bit of reality testing into the internal process, the Polish politicians run into the back office and create their plan. When it hits the streets, they are confronted with all of the realities that they avoided, ignored or were ignorant of when they made their clandestine plan. Real world economics and compliance with European and Polish law apparently only get any attention after the proposal is made in public. Since these twin pillars dictate almost everything that happens in the RES market, the plans seldom bear any relationship to what can actually happen.

The growing bunker mentality of the government, especially vis-a-vis Brussels will only make the problem more acute. While life creates the opportunity of experience, it only promotes forward progress when the right lessons are learned. Transparency and open discussion to flush out the facts is not obviously one of the lessons that is being learned here.

Monday, April 25, 2016

PiS Changes in RES Law Will Promote Co-firing, Biomass and Biogas

Leaked information published in Poland today suggests that the PiS Government will fundamentally change the nature of renewable energy support contained in the prior government's version of the new law.
 'State support in the form of a contract does not have to get the source of the most cost-effective, but the disposition by the greatest number of hours per year. Among the defined limit at the auction they would have been performed in a specific order: the renewable energy sources for power exhibiting the best stability, but not necessarily the cheapest, and finally to the least controllable and disposable.... This means opening up  co-firing  [eg. coal and biomass from wood], will take precedence. Then the next blocks will be biomass and biogas, as well as clusters, also considered self-sufficient and stable systems - indicates our source close to the government sources, and knowing the draft amendment. - If a designated pool of energy ordered by the government will be something else, only they will be held auctions for wind power and solar." Rzeczpospolita, April 25, 2016.
This is serve several purposes that are important for the new government's policies. (1) It will effectively control the technology mix of new RES construction by setting up technology baskets for the auctions that can regulate how much of each technology receives support. This will effectively control wind energy development, even if the land use law gets reversed or tied up in EC proceedings. (2) Technology baskets have been approved by the European Commission for other Member States, so this bypasses the state aid obstacle in theory. However, the maximum price of the co-firing auction will be controversial if it exceeds the real cost of production and results in over-compensation for co-firing (the historical situation). Presumably, the Polish Government will clear the price with the Commission in the course of the current DG Competition review.  (3) The revenue from the new support for co-firing may be an effective offset to the refunds of illegal aid for co-firing since 2005 when it was over-compensated. See pending case SA 37244. It is also speculated that it is a reward for the state-owned energy companies supporting the insolvent state coal mines.  See Grzegorz Wisniewski comments in Rzeczpospolita. (4) The policy can arguably be supported by the need to limit intermittent RES sources that have caused problems in other countries. The issue will only be if the government interest in stability of the system is sufficient to pass muster with the European Commission. The fact that other Member States have been able to conduct approved auctions that are technology-specific and basically ration technologies by basket size seems to indicate that this is possible.
The implications for biogas are probably good. A  separate technology basket will greatly help projects win support. The issue will be the reference price and whether the unnecessary restrictions on projects (size below 1 MW and organic waste substrate restrictions) are removed in the new proposal.  
Another change will be the shift to allow wood to be used in co-firing, not just biomass from agriculture. This is expected to raise wood prices in the Polish market with some adverse effects on smaller users of biomass.
Controversies will still exists with the changes. The major issue remaining will be how the auction reference prices are set and whether doing these changes "on the fly" will result in killing many projects except for co-firing.