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Figure 19: The virtuous circle: profound change in the commercial and regulatory ecosystem for nuclear energy around the world is needed to support rapid scale-up Together, the solutions discussed below represent profound system change and disruption of the existing commercial and regulatory ecosystem for nuclear energy. Scaling nuclear energy to levels that are relevant for advancing climate management and human development goals can’t be accomplished through incremental moves. Each of the proposed solutions entails a significant departure from business as usual; together they amount to a fundamental reset of a 70-year-old industry. Poland is in a unique position, owing to the variety of nuclear energy projects and technologies being proposed, to explore how these solutions could benefit its economy-wide decarbonisation. Furthermore, Poland has the opportunity to collaborate with its CEE neighbors, who are also advancing large GWe and SMR programs, to mutually benefit from these initiatives. Figure 20: Levers for reducing overnight construction cost (OCC) from a first-of-a-kind reactor to the Nth-of-a-kind reactor.90 91 92 Figure 21. The six solutions for the New Pathway for Nuclear Energy The six solutions for the New Pathway for Nuclear Energy CATF proposes a suite of solutions that together provide a new pathway for realising nuclear energy’s potential to meet growing demand for zero-carbon electricity, industrial heat, clean fuels, and other applications: Move from a delivery model that relies on slow and expensive mega-projects to focus on commoditised, standardised and manufactured “products” supplying large orderbooks Currently nuclear plants are built in the same manner as large, bespoke, one-at-a-time infrastructure projects like hydroelectric power plants, bridges, high-speed rail lines, highways, and airports. Such projects take decades to plan, finance and construct. Radical overhaul is required to reimagine how nuclear plants are built and delivered. This means learning from analogous industries, such as the industries that supply ships, aerospace technologies, and gas turbines, and designing for modular manufacturing, efficient assembly of standardised parts, and the ability to ship as much of a fully designed and finished product to a site as possible, rather than requiring complex on-site construction. Use demand aggregation to develop large orderbooks and promote repeat builds of the same design Scale matters. Historical experience shows that repeat builds of the same standardised design, especially at a single site, can produce substantial cost reductions, approaching as much as 25%, between the first unit and the Nth unit. Learning by doing on this kind of scale will require firm commitment for dozens of units of the same design. In the context of demand aggregation this could take the form of aggregating the demand from utilities and commercial organisations within Poland and or working with its CEE neighbors or the wider EU to aggregate the demand for one or more nuclear power station designs. Demand aggregation is relevant to all sizes of nuclear power plants. However, it is especially relevant to Small Modular Reactors where the concept of factory built modular construction of multiple units combined with an aggregated demand should provide an appropriate environment for supply chain investment and the cost reductions envisaged for multiple deployment. Integrate plant delivery The industry that currently delivers nuclear power plants is highly fragmented as it is split between vendors; component manufacturers; engineering, procurement, and construction firms; and off-takers such as utilities. This leads to very large inefficiencies, as risk and management are often unequally distributed without a single point of accountability. It also results in unnecessary costs and delays as various parties argue about risk, and sometimes litigate against each other when things go wrong. Harmonize global licensing In the last two decades, licensing nuclear projects has been a significant hurdle to deployment, even in markets with decades of experience in nuclear regulation and oversight. A significant issue for many vendors and potential customers is the lack of harmonisation between and across national nuclear licensing regimes. This often means that vendors need to undergo repetitive licensing processes in jurisdictions with different laws and requirements and varying technical standards. Provide technical support for first-time nuclear nations Licensing a nuclear reactor project in a country that is just embarking on the use of this technology is an order of magnitude more challenging than doing the same in a mature market. To eliminate licensing barriers in embarking countries it will be important to (1) minimise human resource and financial constraints and (2) create a framework that further enables nuclear licensing across these countries. Expand access to financing for nuclear projects Nuclear energy has received only a small fraction of total global annual investment in the energy transition, for reasons that include the multi-billion-dollar size of capital investment necessary to deploy nuclear projects, lengthy development and construction terms, the unique regulatory demands of nuclear projects, and a lack of familiarity with nuclear technologies in the financial community, which has frequently translated to a lack of acceptance of nuclear financing proposals. Small Modular Reactors and Advanced reactors as a potential pathway for electricity and energy decarbonisation While Poland has been developing its nuclear program and recently announced the development of large GWe nuclear power plants93 that would help to diversify its energy mix and reduce carbon emissions, there is a growing recognition of the potential benefits offered by Small Modular Reactors94 and Advanced reactors. As the nation pursues its ambitions in the nuclear energy sector, these smaller and more flexible reactor designs are emerging as a compelling alternative. Small Modular Reactors and Advanced reactors have been developed over the last decade that range from less than 5 MWe up to 300 MWe per unit, which is about one-third of the generating capacity of traditional nuclear power reactors (we will refer to these two types as SMRs). As with existing nuclear reactors, SMRs use energy from a controlled nuclear chain reaction to create steam that can either power a turbine to produce electricity or use that steam for a wide range of industrial applications including clean hydrogen production and district heating to list a few uses. These designs span a range of technology options. Some as with existing large reactors use light water as a coolant while others, the Advanced Reactors, utilise a gas, liquid metal or molten salt to transfer heat to a secondary purpose, e.g., steam generation or molten salt storage facility. The light water reactors use similar fuel to existing reactors, while the Advanced Reactors use new and different types of fuels. Advantages of SMRs Many of the benefits of SMRs are inherently linked to the nature of their design – small and modular. Given their smaller footprint, SMRs can be sited on locations not suitable for larger nuclear power plants. Another benefit of SMRs is their MWe power density in respect of land use. A typical 300 MWe SMR site will occupy less than 100 hectares. In a Member State where land use is constrained by urbanisation, agriculture and other factors, SMRs are considerably more land efficient than other clean energy technologies. This benefit is not recognised in any financial cost comparison between clean energy technologies but should be recognised as a societal benefit. Figure 22. The Footprint of Large-Scale NPPs, SMRs and Microreactors Figure 23. Land Use by Energy Source Prefabricated units of SMRs can be manufactured, transported to site and installed quickly, making them more affordable and quicker to build than large GWe reactors, which are often custom designed for a particular location, are complex and these factors sometimes lead to construction delays. Additionally, SMRs offer a smaller initial investment and potential savings in cost and construction time and can be deployed incrementally to match increasing energy demand. In comparison to traditional gigawatt reactors, proposed SMR designs are generally simpler, and the safety concept for them often relies more on passive systems and inherent safety characteristics of the nuclear reactor. This means that in such cases no human intervention or external electrical power is required to shut down systems, because passive systems rely on physical phenomena, such as natural circulation, convection, gravity and self-pressurisation. These increased safety attributes, in some cases, eliminate or significantly lower the potential for unsafe releases of radioactivity to the environment and the public in case of an accident. SMRs offer a lower initial capital investment, greater scalability, and siting flexibility for locations unable to accommodate more traditional larger reactors. They also have the potential for enhanced safety and security compared to earlier designs. Deployment of advanced SMRs can help drive economic growth. The term “modular” in the context of SMRs refers to the ability to fabricate major components of the nuclear reactor in a factory environment, ship to the point of use and then assemble the modules, reducing construction time, direct costs and interest on cost of capital. Even though current large nuclear power plant projects incorporate factory-fabricated components (or modules) into their designs, a substantial amount of on-site work is still required to assemble components into an operational power plant. SMRs are envisioned to require limited on-site preparation and substantially reduce the lengthy construction times that are typical of the larger units. SMRs can reduce a nuclear plant owner’s capital investment due to the lower plant capital cost. SMRs can provide energy and power for applications where large plants are too large for the demand or sites lack the infrastructure to support a large unit. This would include smaller electrical markets, isolated areas, smaller grids, sites with limited water and acreage, or industrial applications. SMRs are expected to be attractive options for the replacement or repowering of aging/retiring fossil plants, or to provide an option for complementing existing industrial processes or power plants with an energy source that does not emit greenhouse gases. In addition, SMRs can be coupled with other energy sources, including renewables and fossil energy, to leverage resources and produce higher efficiencies and multiple energy end-products while increasing grid stability and security. Some advanced SMR designs can produce a higher temperature process heat for either more efficient electricity generation or industrial applications. SMR designs have the distinct advantage of factoring in current IAEA safeguards and security requirements. Facility protection systems, including barriers that can withstand design basis aircraft crash scenarios and other specific threats, are part of the engineering process being applied to SMR designs. Most SMRs will be built below ground level for safety and security enhancements, addressing vulnerabilities to both sabotage and natural external hazards. Some SMRs will be designed to operate for extended periods without refuelling. These SMRs could be manufactured and fuelled in a factory, sealed and transported to sites for power generation or process heat, and then returned to the factory for defueling at the end of their life cycle. This approach could help to reduce the international transportation and handling of nuclear fuel. In many countries, SMRs are being considered as potential replacements for fossil-fuelled power stations, such as coal-fired power plants. In this approach, the nuclear project can take advantage of the existing infrastructure such as access to water supply, power grid connection, switchyard and other surrounding assets to its benefit. Due to their smaller power size and modular approach, a coal-fired power plant may be replaced by several nuclear modules which can be constructed gradually to offer the flexibility of deployment. Advanced SMRs are being actively proposed to provide the energy to produce clean hydrogen at scale to meet the growing demand and forecast for clean hydrogen. In fact, nuclear technology offers many pathways to produce clean hydrogen via low temperature electrolysis (LTE), high temperature electrolysis (HTE) as well as thermo-chemical water splitting. These hydrogen generation technologies should provide Member States with options to meet their hydrogen strategies and policies. CATF in collaboration with Romanian partner Energy Policy Group95 has launched a report focusing on technical and economic assessment of SMRs96. Policy recommendations distilled from this report can be also helpful for developing Polish SMR projects. Improving the licensing process for SMRs National Level Enhance internal expertise and capacity of the national nuclear regulator for assessing specific Light Water Reactor (LWR) and Non-Light Water Reactors designs. Address potential challenges related to advanced SMR designs using new types of highly enriched fuel. EU Level Promote international cooperation for harmonisation of licensing regimes, with a focus on standardisation and efficiency. Consider the creation of joint pre-licensing reviews, guidelines, or best practices for SMRs among interested EU member states. Explore the establishment of a license-by-testing system (“sandbox”) to streamline and expedite the licensing process. Establish a European technical body for SMRs to provide support and expertise to national regulators. International Level Utilise existing frameworks of international cooperation for large-scale Nuclear Power Plants (NPPs) to exchange know-how and practical experience among national regulators. Consider the formation of an International Technical Support Organization (ITSO) to conduct and review license applications, assist with inspections, and provide training services. Improving Public Policy in the Nuclear Sector National Level Support First-of-a-Kind (FOAK) demonstration units for SMRs and allocate funding for this purpose. Create a Contract for Difference (CfD) scheme for SMRs to provide financial support and de- risking. Assess the necessary workforce for SMR development and support reskilling/upskilling through funding for a just transition. Support R&D and nuclear manufacturing capabilities through state aid instruments. EU Level Support nuclear R&D, especially focusing on advanced manufacturing processes for SMRs. Collaborate with the European Commission and member states to create Centers of Excellence for Advanced Manufacturing on Nuclear Research. Improve transparency in planning and decision- making processes. Develop and implement public engagement programs to address public acceptance of nuclear projects. Reducing the Costs of New Nuclear Power Plants Emphasize proven project/construction management practices for increased probability of success. Shift towards serial manufacturing of standardised SMR plants with inherent and passive safety measures. Establish a Joint Platform for SMR Procurements at the EU level to address fragmented demand and to help build the orderbook, consolidate requirements, and negotiate common SMR designs. Coordinate technology acquisition to support standardisation, factory-based manufacturing, and reduce costs. Explore participation in off-take agreements (PPAs), build-own-transfer models, or joint equity participation through the joint platform. Fast action for emissions reductions Reducing methane emissions Why methane emissions? Climate benefits: Methane is the second greatest contributor to climate change and over 80 times more potent than CO₂ for global warming over a period of 20 years. Methane mitigation is the most cost-effective climate action for reducing the impact of global warming in our lifetimes, and avoiding irreversible tipping points. It is also one of the only low-hanging fruits remaining in the climate fight, a measure that has very limited to no cost and can have a major beneficial impact for climate. The Sixth IPCC Assessment Report97 identified methane mitigation as a priority and stressed the need for rapidly reducing methane emissions. Energy security benefits: In the context of the energy crisis, cutting methane emissions would ensure that all the gas in the pipeline arrives to the consumers. Indeed, methane saved from leaks within the EU could amount to 600 kt of methane per year. This wasted gas represents the annual consumption of gas in almost 1 million French homes. Economic benefits: As the prices of energy rose, cutting methane emissions also became more economically beneficial. Addressing methane leaks could already be done at low or no cost before the crisis but, with the rise in energy costs, the benefits are higher for companies to address their leaks. According to the IEA’s Methane Tracker, 71% of leaks in the EU could be mitigated at low cost and 41% at no-net cost before the energy crisis.98 Globally, flaring, venting, and leaking amount to $47 billion in lost revenue per year. Implementation of the Methane Regulation and Import Standard In November 2023, the EU agreed to its first-ever rules on reducing methane emissions in the energy sector, which include the bloc’s first rules for domestic producers on leak detection and repair (LDAR), venting and flaring of methane, emissions from abandoned and inactive wells, as well as annual monitoring and reporting of emissions, which are subject to verification by independent verifiers. The regulation also includes landmark obligations on importers of fossil fuels, which will be implemented in a phased approach, with data and reporting obligations starting first, just nine months after the Regulation’s entry into force. Starting in 2027, importers will be required to demonstrate that they meet the same MRV standards as those adopted in the EU’s methane regulation. The Commission will set forth a methodology for a methane intensity standard, which will be adopted by 2027 and fully implemented by 2030.99 CATF’s analysis with Rystad100 showed that a phased import standard would have demonstrable emissions reduction benefits, with few negative impacts on EU energy security and the price of oil and gas. This is due to the evolving oil and gas market and the low marginal costs for compliance, combined with the increased potential for expansion of clean energy resources. With new energy supplies expected to drastically shift world markets starting in 2025, the import standard is expected to have a minimal cost for suppliers of gas, and even less impact on consumers, because many suppliers will be able to sufficiently reduce emissions enough to avoid paying a fee – leaving those that do need to pay the fee with little pricing power to pass the fee on to consumers. In CATF and Rystad’s model, prices will therefore rise about 1% – at most – due to the import standard. Figure 24. Incremental costs to gas exporters to the EU resulting from the implementation of MIPS, 2031 Recommendations: What can Poland do to cut methane emissions? 1. Ensure consistent application of the EU’s Methane Regulation 1.1. Legal: Ensure future energy contracts meet the standards adopted in the EU’s Methane Regulation Member States should develop a firm understanding of how these new obligations affect different types of energy contracts. When many obligations go into effect between 2027 and 2030, importers will be required to show that all contracts concluded or renewed after the EU’s Methane Regulation’s entry into force comply with the obligations.101 From 2027 importers will be required to show compliance with MRV obligations, from 2028 they will begin reporting methane intensity according to the forthcoming methodology, and by 2030 they must demonstrate that methane intensity is below the maximum values set. Long-term contracts extending past these dates must therefore include provisions to comply with the obligations set forth, either immediately or at a later date. The Polish government should therefore immediately develop a future-orientated procurement strategy that takes these legal considerations into account and encourages compliance with all provisions in the Methane Regulation. This should include a strong legal foundation for other entities within Poland purchasing oil and gas. 1.2. Economic incentives: setting proportionate and dissuasive fees Effective implementation of the Methane Regulation, including the new import standard, will require EU Member States to establish dissuasive fees on operators and importers to incentivise abatement throughout the value chain. Article 30 of the Regulation stipulates that Member States must implement fines proportionate to the environmental damage and impact on human safety and public health, and therefore the Polish government should consider establishing fees on methane that take into account the significantly higher GWP of methane over CO₂. According to the IPCC’s Working Group 1 contribution to the Sixth Assessment Report, fossil-sourced methane has a GWP of 82.5 over 20 years and a GWP of 29.8 over 100 years, while non- fossil source methane has a GWP of 79.7 over 20 years and a GWP of 27.0 over 100 years.102 While the import standards costs will ultimately depend on the European Commission’s forthcoming methodology, a joint CATF-Rystad baseline impact assessment showed that fees could be levied as high as €1500 / MMBTU without significant adverse effects on gas prices.103 1.3. Building regulatory competences The Methane Regulation is a first of its kind in Europe, meaning that regulatory authorities may have little to no experience executing verification of key provisions on LDAR, MRV, and venting and flaring. When Poland appoints a competent authority to ensure compliance with the Methane Regulation, the entity should work in lock-step with other competent authorities within the EU, to build necessary capacities, potentially with support from jurisdictions outside the EU with significant experience, to ensure consistent application of the Methane Regulation. 1.4. Mapping of wells with no ownership The oil and gas industry in Europe dates back to the 1850s.104 Since then, many wells have been abandoned for a wide range of reasons, including production declines and business migration to more productive oil fields. The issue of abandoned wells105 is complicated by the difficulty in identifying which companies own them or are responsible for them. In some cases, due to the way these wells were decommissioned, no owner can be identified and held accountable for the emissions and the measures needed to address them. While the total number of abandoned wells in Europe is unknown, it is estimated that Poland has tens of thousands of abandoned and orphaned wells. With a long history of oil and gas commercial operations, most European countries lack complete inventories of all wells drilled in their territories. And many of these abandoned wells are unplugged or improperly plugged, permitting harmful chemicals and gases to escape the wells.106 Unplugged wells present safety and environmental hazards today, and if unaddressed, will continue to pose issues as new wells are drilled and former drilling lands are repurposed. Mapping these wells and the status (i.e. effectively sealed or not) could be the first step to engage in plugging and sealing programs and would be crucial to provide good basis to gather accurate estimates of methane emissions, and to mobilise proper funding and resources for abandoned well management programs at national and European level. Italy completed a project to comprehensively map old oil and gas wells, finishing the project in 2017. Poland should establish a separate program on methane mitigation for abandoned wells to ensure all these wells are identified, sealed, and monitored. The mapping should accompany the development of national databases of all wells in each country. These databases can aggregate information from a variety of sources, including: National public and company archives. Bottom-up reporting of wells by landowners and other members of the public; and scientific surveys, notably those using magnetic surveys to detect wells in dense vegetation and buried wells beneath the surface. Such a program if coupled with funds or financial mechanisms could lead to substantial reductions in methane emissions from abandoned wells and create new employment opportunities. In parallel, Poland should work to understand the legal status of wells and put in place protocols and adequate funding to properly plug and monitor them. Figure 25. Global LNG demand and supply forecast to 2040 2. Encourage national oil and gas companies to join OGMP 2.0 The Oil and Gas Methane Partnership (OGMP) 2.0 is a global initiative of public and private entities, led by the United Nations Environment Programme (UNEP), and founded by the Climate and Clean Air Coalition in 2014. The initiative aims to reduce methane emissions in the oil and gas sector, whereby members commit to using a measurement-based reporting framework. So far over 120 companies operating in over 70 countries have joined OGMP 2.0, which covers 80% of global LNG flows, 25% of natural gas transmission and distribution pipelines, and 38% of global oil and gas production. Members of OGMP 2.0 include multiple companies that are state-owned, or partially state-owned, such as Romania’s ROMGAZ, which joined OGMP 2.0 in July 2023. OGMP 2.0 provides a comprehensive methodology to improve the accuracy of methane emissions reporting over time, using a 5-tier reporting level system. This ranges from Level 1 reporting, which requires a single consolidated emissions number, up to Level 5 Reporting, which integrates specific source level reporting with independent site level measurements for reconciliation. All OGMP 2.0 member companies are required to establish a company-wide methane reduction target, and develop an implementation plan as well as a pathway to improve reporting towards the Gold Standard. The OGMP 2.0 reporting system has been defined, in interim, by Article 12 of the EU Methane Regulation as the basis for technical guidance and reporting templates for upstream, midstream, and downstream operations.107 This guidance remains in effect until the European Commission lays down a reporting template. Given the central role of OGMP 2.0 in reducing methane emissions, Poland should consider encouraging oil and gas companies that are state- owned or partially state-owned, to join the framework. This should include Poland’s national gas company, Polskie Górnictwo Naftowe i Gazownictwo, as well as PKN Orlen, of which Poland is the largest shareholder. Such a move would help facilitate robust and strategic plans to reduce methane emissions, and proactively improve the accuracy of reporting to meet the forthcoming MRV obligations of the Methane Regulation. Innovation in clean technology Superhot rock energy Geothermal energy currently plays a modest role in Poland’s clean transition and is primarily used for district heating. However, in the country’s search for alternative clean energy sources, we see that geothermal energy is starting to gain more attention from public and private stakeholders. The country has increased108 the total installed geothermal energy capacity from 74 megawatts (MW) in 2020 to 129 megawatts (MW) today and has 7 wells in operation. Additionally, recent support schemes reflect Poland’s increasing interest in geothermal energy. For instance, the Long-term Program for the Development of the Use of Geothermal Resources in Poland, issued by the Ministry of Climate and Environment in May 2022, along with programs like Polska Geotermia Plus109 (Polish Geothermal Energy Plus), which has a budget of PLN 600 million (EUR 129.7 million), and the financing of geothermal wells constructions in 15 towns across the country, with a budget of PLN 229.2 million (EUR 49.5 million). Technology-wise, there is an emerging breakthrough in the country, as the Szaflary well110 aims to reach a depth of 7km and more than 180 degrees Celsius. Moreover, during the December 2023 Polish Geothermal Congress in Krakow, public and private investors expressed interest111 in exploring the use of geothermal energy for electricity production. While these are significant developments on the geothermal front that should be further supported, the only way for Poland to move away from fossil fuel dependencies and shift towards a more self- reliant and energy-secure decarbonised future, is by considering a diverse set of clean firm energy sources. This is why it is critical that the Polish government also explores the opportunity of Superhot Rock Energy112 – a technological innovation that has the potential to meet long-term demands for zero-carbon, always-on power, and can generate hydrogen for transportation fuel and other applications. What is Superhot Rock Energy? Superhot rock energy falls under the category of “engineered” or “enhanced” geothermal systems or “EGS”. These technologies involve the injection of water directly into the ground at exceptionally high pressures. This process creates fractures within the rocks, allowing the water to circulate and absorb the surrounding heat. The resulting hot water is subsequently brought to the surface, where it drives electricity generation in a power plant. The difference between the EGS technologies commercially available today and superhot rock energy, is that the latter aims to achieve deeper and hotter conditions. superhot rock energy is produced with temperatures of 400C and above. More on the technical aspects of SHR can be found here113. Figure 26: Superhot rock energy system Water is injected (through an injection well) into superhot dry rock (rock at temperatures above 400°C) and is circulated through fractures (or drilled conduits) to a production well that provides thermal energy to produce power, heat, or fuels. What’s the state of SHR in Europe? Although the technology is still in early stages of development, Europe is a leader in engineered geothermal systems, with projects in the upper Rhine valley and work investigating superhot geothermal systems in Italy, Iceland and Greece. See here our Superhot Rock Projects Map114. Several projects funded by the EU Horizon 2020 programme (DEEPEGS115, DESCRAMBLE116, GEMex117) have already reached supercritical conditions118 and have made notable advancements in researching technologies for superhot geothermal. However, for the technology to be commercially available in the 2040s, it still needs further research efforts to demonstrate the promise of superhot rock energy and deploy this energy source at scale in Europe and beyond. What are some of the main benefits of SHR? Clean always-on renewable power source: Superhot rock is not reliant on fluctuating external factors, which means it ican be a consistent, always-on, 24/7 carbon-free energy source of electricity generation that can meet the continuous power demands of homes, industries, and communities, serving as a baseload power source. Energy security benefits: Successful superhot rock technology could access geothermal resources potentially almost everywhere well beyond traditional geothermal systems which rely on geographically limited natural hot springs. Consequently, superhot rock systems could provide substantial amounts of local energy. Given the energy security challenges in Europe, superhot rock energy is an endeavour that, with vision and robust funding, could provide terawatts of “local” zero carbon baseload energy within a couple of decades. Cost-competitiveness: CATF analysis119 suggests that superhot rock energy could be cost-competitive because of the far greater amounts of heat that can be delivered from one well. This energy density could allow superhot rock to provide energy that is competitive with fossil power. Furthermore, drilling and reservoir development costs—combining labour, equipment, and materials costs—are expected to be higher for first-of-a-kind projects but to progressively decline through continuous improvement, similar to the deep cost reductions and productivity improvements that occurred in large-scale unconventional shale oil and gas development. Once it reaches commercial scale, superhot rock is expected to be competitive with both fossil and renewable energy resources. Limited land use: Superhot rock systems have minimal land use and above-ground structure requirements. While many clean energy sources require extensive onshore or offshore space to meet the energy demand, the amount of energy delivered by superhot rock systems per unit of surface area will be very high, and superhot rock systems would therefore require less land to meet the energy demand. What are some the overall challenges for its commercialisation? Lack of financial support: Focused research and innovation funding is essential for emerging technologies at low Technology Readiness Levels (TRLs), as is the case of superhot rock energy. It is crucial that these technologies advance toward feasibility studies, broader pilot projects, and eventually, full-scale development. Strong legislation and regulation, and easy permitting: The success of SHR Energy in Europe also relies on establishing comprehensive legislative and regulatory frameworks, and easy permitting, as this would create an encouraging environment for investors and other industry stakeholders and superhot rock energy could be developed safely and efficiently. Further technological innovation: By allocating sufficient funding, significant technological progress would be made. For instance, super-deep drilling technologies, such as the one being developed by GA Drilling (a Slovakia-based company that aims to “make the idea of geothermal energy anywhere and for anyone in the world to happen”), would be further developed, enabling SHR projects to be conducted in regions where high temperatures are found at greater depths, beyond the reach of existing drilling techniques. Also, with sufficient funding, more locations for early demonstration projects could be identified. These technical advancements are essential for expanding the geographic scope of SHR energy production, and, as a result, costs could be reduced and efficiency can be improved, bringing superhot rock energy closer to large-scale commercialisation. Collaboration and workforce development: As SHR technology expands, there will be an increasing demand for well-trained professionals proficient in project design, computer modelling, ultra-deep drilling techniques, advanced downhole remote sensing, and the operation of surface power plants, among other essential skills. Recommendations: What can Poland do to support superhot rock energy? Develop a strategy for geothermal energy that considers superhot rock energy The Ministry of Climate and Environment published in May 2022 The Long-Term Development Program for the Utilization of Geothermal Resources in Poland120 (Geothermal Development Roadmap in Poland), which is a first-of-a-kind roadmap for the development of geothermal energy in the country until 2040 (until 2050 in some areas). This is a step in the right direction as the document contains action plans for the development of shallow, low, medium, and high-temperature geothermal energy, and it also includes mentions of other geothermal uses such as energy storage. However, there is no mention of considering supercritical conditions. The country can benefit from including SHR in key policy documents – not only in the Geothermal Development Roadmap, but also in the country’s NECP and PEP2040, which already include the development of geothermal energy as a goal. The documents should include an assessment of resources, existing infrastructure and supply chains, siting plans, and policy frameworks needed to support the uptake of SHR and to create a pathway for its development and eventually full deployment at scale. Support an ambitious and focused research agenda, enabled by robust public funding and collaboration with other member states On November 24th, 2023, Climate and Environment Ministry announced121 the financing of the construction of 30 new geothermal wells with PLN 428 million (99 million EUR) from the National Fund for Environmental Protection and Water Management. These fundings are steps in the right direction to expand geothermal energy, which consists of technology that is already commercially available. However, the government of Poland (and other European governments) should also allocate funding to technologies in early stages of development, such as superhot rock, as public funding for pilot demonstrations and technology innovation is needed in order to prove the capacity of the technology. This will lower the risk and increase private investment, which has been limited so far. Note that, according to the findings from the public polling carried out in August 2023, 70% of respondents in Poland were in favour of government investment into superhot rock energy development. Investing in cutting-edge, next-gen clean energy solutions at an early stage can yield substantial returns, especially in the context of the green transition The demonstration and commercialisation of superhot rock energy in Poland and beyond will require stakeholder collaboration, both at national level and across different member states. Knowledge-sharing and creation of consortia should play a big role in the development of superhot rock energy. Drive public awareness to enhance acceptance According to findings from CATF’s public perception polling122, there are notable public knowledge gaps about superhot rock energy, which can provoke understandable scepticism among the population. The national government and other organizations play a key role in shaping public opinion and fostering acceptance of clean energy solutions. Which is why to alleviate public concerns and boost awareness, it is essential for governments to actively engage with the population and work to close these knowledge gaps. This, in turn, will empower individuals to make well-informed decisions. Carry out a heat reservoir assessment and map to understand the national deep geothermal and superhot rock potential – and keep an open data repository Through the mapping of superhot geothermal reservoirs, Polish policymakers can better evaluate the national potential of superhot rock energy. This evaluation can serve as a foundation for determining whether additional public or private resources are needed. Additionally, as superhot rock is at early stages of development, all reliable data is a valuable resource and key for further development. Therefore, it is recommended to keep an open data repository on all subsurface information. Create a national platform for stakeholder collaboration on superhot rock energy The country counts with the Polish Geothermal Association123, which is the main non-political and non- governmental geothermal organisation in the country and is a member of the International Geothermal Association and of EGEC – European Geothermal Energy Council. This serves as a national platform for stakeholder collaboration on geothermal matters. Such efforts of collaboration within the scientific community as well as among other industry players, policymakers, and at the NGO level are also needed for superhot rock energy. By sharing lessons learned and best practices, stakeholders can collectively advance the understanding and implementation of this technology, helping accelerate the progress of SHR energy on a larger scale. This knowledge sharing should happen at national level and with other Member States.