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Assessment for Poland (Silesia)

Status: Draft Plan
Date of plan: 01.03.2021
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Overall Plan Rating

There are also some indicators rated as not consistent with the just transition. These are marked as red on the traffic light system and should be the foremost priorities to address and improve on. The indicators are organised under their corresponding principles in the Annex to this report.

Principle 1

The TJTP should be sustainable and deliver on long-term, international and EU climate commitments such as the Paris Agreement and EU 2030 and 2050 climate objectives.
Indicates a commitment to reduce GHG emissions but by < 55% emissions reduction versus 1990 levels by 2030 OR it does not indicate a need to reduce emissions at all
Identifies the opportunities to increase renewable energy in the region and specific actions, projects or targets are proposed
Identifies the opportunities to increase energy efficiency or reduce energy use in the region or nationally, but no specific actions, projects or targets are proposed

Principle 2

The TJTP should not lead to prolonged fossil fuel use or promote false solutions to the transition to climate neutrality. As a guide, coal should be phased out by 2030.
A phase-out of coal is planned or implied (the fossil fuel is recognised as in terminal decline), but the end date is after 2030 or undefined
No phase-out of fossil gas is planned or implied
Not enough information available or fossil fuel subsidies not discussed

Principle 3

The TJTP should lead to sustainable economic diversification at the local, regional and national level.
Promotes economic diversification, and explicitly recognises (e.g. in the assessment of the transition challenges) that all sectors of the economy must become sustainable
Recognises the value of SMEs and start-ups, setting out a clear plan for their support and incentivisation e.g. through dedicated incubators
Includes programme specific indicators (section 2.5) to measure support to, or success in supporting, SMEs and start-ups.
Indicates a link to and a need for consistency with the NECP's objectives. Provides a clear prioritisation of funding and investment needs into different sectors, labour market adjustments and for relevant reskilling and upskilling in line with - or going further than - the most up to date NECP for sustainable economic diversification and to create decent, sustainable and resilient jobs

Principle 4

The TJTP should address social inequalities, improve interregional solidarity, decrease inequalities and tackle injustices.
Justifies why certain regions should receive support with reference to the underlying economic and employment impacts of the transition, and justifies the choice objective criteria or comparative data
Prioritises employment support and job search assistance for workers directly losing their jobs as a result of the transition AND other worker groups, including those who may be indirectly affected
Identifies the existing and future skills, training and education gaps for all workers and sectors, including future generations, at regional level on the basis of objective and quality skills forecasts or clearly sets out a process to identify them
Foresees targeted investments sufficient to remedy these gaps and create decent, sustainable and resilient jobs for all current (and future) workers in the region
Does not consider the quality of new jobs or include measures to address the issue
Recognises some inequalities and identifies some measures to address those arising from the transition, such as a minimum income support, energy poverty reduction or early pensions. But the TJTP does not consider existing inequalities or address all inequalities identified with planned measures
Identifies the potential changes to quality of life arising from the transition and includes some targeted measures to address residual negative factors, such as air and water quality issues
Includes programme specific indicators (section 2.5) to assess change in quality of life or project selection criteria to prioritise quality of life improvements
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Principle 5

The TJTP should not harm EU environmental and climate objectives and values.
Does not include activities which would negatively impact environmental and biodiversity indicators relating to:
- Biodiversity
- Air pollution
- Accessible greenspace (land take)
- Water quality

AND neither does it include significantly harmful activities as defined by the EU Taxonomy or which would lead to unsustainable use of natural resources or which would lead to ecosystem harm
Foresees investment in new fossil fuel infrastructure, including for example for power generation, heating, fossil fuel-based chemicals manufacture or aviation capacity. A red rating is also given if the TJTP foresees investments which would prolong the life of existing fossil-based infrastructure, for example retrofits in existing EU ETS installations
Identifies actions or activities to improve a wide range of environment and biodiversity indicators in the regions concerned. It includes, as a minimum, actions or activities relating to at least 3 of the following categories:
- Biodiversity
- Air pollution
- Accessible greenspace (land take)
- Water quality
Includes programme specific indicators (section 2.5) to measure biodiversity or environmental quality
Includes investment in waste incineration or new landfill capacity

Principle 6

The TJTP should respect the polluter pays principle.
The TJTP does not identify the entities responsible for existing environmental damage.

AND/OR the TJTP recommends to use JTF resources to pay for land restoration without an analysis - or commitment to an analysis - of the possibility and applicability of the Polluter Pays Principle

Principle 7

The TJTP should be supported by adequate, coordinated and long-term public and private funding sources.
Relies on EU funds only to deliver the just transition (although not limited to the Just Transition Fund and the Pillar III of the Just Transition Mechanism)
AND/OR there is no clear targeting of funds for the most appropriate activities or to address funding gaps
Private funding sources are not identified and public funding appears to be the sole source of funding identified for the activities and the investments outlined in the TJTP

Principle 8

The TJTP should be designed, monitored and evaluated through meaningful partnerships which engage all stakeholders in an open, inclusive and ongoing process, especially at local level. Social dialogue and collective bargaining should be central pillars of the transition when it comes to the labour market and enterprises.
A coordination body is established but membership of the coordination body requirements and composition may be unclear.

AND / OR

Details on procedures are vague without transparency on timing and schedules for such meetings, or on how, when or where information on process and relevant documents will be published in an accessible place. Alternatively the majority of information must be directly requested from the institution responsible rather than openly available.
Clearly and comprehensively identifies stakeholders to be involved in the process, consistent with the groups identified in Article 3 of the European Code of Conduct on Partnership and a clear and justified description of their roles and status in the process
Limited detail on how stakeholder views and consultation inputs were integrated into the final plan, or how they will be (beyond a commitment to a consultation, for example).  Detail on stakeholder engagement plans for the preparation, implementation, monitoring and evaluation of the TJTP is also limited.
The plan recognises the need to support capacity building of some stakeholders, particularly those with limited resources, to enhance their engagement
Public consultation and engagement of all relevant stakeholders while all options are open is provided for, the period of consultation and engagement is launched with at least 4 weeks prior notice, the period for consultation and engagement lasts for at least 12 weeks and there are at least 4 weeks to comment on the final draft
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Principle 9

The TJTP should take a place-based, local approach to strategy design and implementation.
Identifies NUTS 3 regions which will require targeted action and prioritises measures for the specific NUTS 3 regions concerned
Takes into account the need for community engagement, indicates how existing and planned community initiatives may be integrated into the TJTP and makes clear provision to engage and inform the local community

Principle 10

The TJTP should be developed based on high quality, independent and objective analysis of the challenges and opportunities of the transition for regions.
The indicators and/or data included in the TJTP are focused at the regional level and are high quality, appropriate to the goals of the fund to address the socioeconomic challenges arising from the transition to climate neutrality and they are comprehensive, encompassing both quantitative and qualitative measures
The TJTP foresees a revision process by the Member State regularly, following the update of its NECP or following the mid-term review of programmes. The revision process includes an evaluation of implementation so far and is to be carried out in consultation with stakeholders and partners as identified in the European Code of Conduct on Partnership

Comments

In question 12 all requirements are met, except of addressign women as defavorised group. Also I strongly recommend to separate engagement of stakeholders in the preparation phase and in implementation phase. We can assess only first one at this point. I would put it in 2 separate question, as Silesia had a very thorough consultation process in the preparation phase but does the plan for involvement in implemenation are too vague (so no answer really fits in question 29).