Our strategy

Thus, the first pillar of the strategy is ICT security – business continuity as availability and resilience of systems as well as data integrity and confidentiality in IT solutions. The ICT strategy defines the following areas as priorities:

• Network segmentation. The projects implemented in this area are aimed at ensuring adequate separation of resources with various sensitivity levels, both through infrastructural actions and through appropriate shaping of business projects.
• Workstation. Involves projects which ensure secure work tools necessary to maintain efficiency and functionality in accordance with business requirements, while protecting against malicious software and ensuring control over privileges and data transfers.
• Internet interface. Our external perimeter that provides a functional and unified Internet access (also through a secure WiFi network deployed in 2017 in the Konstancin-Jeziorna Head Office) to the employees and our guests, and secure access, as required, subject to the guidelines arising out of the rule of separation and privilege management.
• Detection and response. To ensure an up-to-date ICT security, a deducted Security Operations Centre (SOC) team runs a 24h threat monitoring. For IT or OT incidents, the team takes actions and measures as required. Another line of support is the Computer Emergency Response Team (CERT). CERT was established in 2016, and in 2017 became an accredited member of Trusted Introducer. It is involved in raising employee awareness by publishing alerts and threat warnings, publishing bulletins on the ICT security and reporting incident information, as well as cooperation with third parties in the field of co-ordination of incident handling, and exchange of information about threats with third parties (e.g. CERT NASK, Government Centre for Security, cert.gov.pl).

In order to ensure efficient implementation of the PSE CG Cyber Security Programme, in September 2018 the Management Board of PSE established the Cyber Security Committee which is tasked with the coordination in the PSE CG of ICT and cyber security measures, especially those requiring decisions that exceed the powers of the heads of PSE’s organisational units.

In collaboration with our stakeholders, we carry on activities aimed at ensuring an appropriate level of ICT security and strategic harmonisation of the efforts made. We also closely cooperate with entities responsible for cyber security of the country and the power sector.

To enhance the cooperation, build awareness of threats to cyber security and approach to counteracting such threats, we actively participate in numerous conferences, seminars, as well as national and international industry cooperation forums.

PSE updated and agreed critical infrastructure protection plans with Police voivodeship commanders, State Fire Service voivodeship commanders, voivodeship building inspectors and voivodeship governors, as well as with the Minister of Energy. Plans were also analysed by the Government Centre for Security.

The Konstancin offices of the company were visited by the representatives of the Task Force on anti-terrorist measures and standards and co-operation rules relating to critical infrastructure, as appointed by the Minister of the Interior and Administration. Representatives of the Team (among others the ABW (Internal Security Agency), the Ministry of the Interior and Administration, the Police, the Government Centre for Security) became familiar with selected solutions in the field of physical, cybernetic and personal security implemented in the company.

PSE also takes active part in projects organised by third parties. In September 2017 a representative of our company spoke at joint conference on disinformation organised by the Ministry of National Defence and the Government Centre for Security.

As part of cooperation with the Police Academy in Szczytno, in February 2018 PSE co-hosted an international conference entitled “Participation of the Police and other services and institutions in protection of the critical infrastructure of the state at the age of asymmetrical threats”. Representatives of our company participated in discussion panels and delivered individual lectures at the conference.

In May 2018 workshops entitled “Cooperation between the Operator and the Police on the protection of the critical infrastructure” took place at the Konstancin head office. The workshops were attended by representatives of the Police (regional and poviat headquarters from the Mazowieckie voivodeship, Warsaw Capital Headquarters, Mazowieckie Voivodeship Headquarters and the General Headquarters), the Office of the Government Plenipotentiary for Strategic Energy Infrastructure, the Ministry of Energy, the Government Centre for Security and the Internal Security Agency.

PSE also participated in TETRYL 2017 anti-terrorist exercise organised by the Ministry of the Interior and Administration and prepared by the Central Bureau of Investigation, aimed at testing the response and cooperation between the services in the event of a terrorist act with a hidden element of a radioactive threat in a facility that requires mandatory protection. The Company provided its offices and the background for the event scenario.

We also cooperated with international partners, such as the NATO Energy Security Centre of Excellence in Vilnius and the European Centre of Excellence for Countering Hybrid Threats in Helsinki. Representatives of the company participated, as speakers, among others in ATC Critical Energy Infrastructure Security and TTX CORE 2017 workshops and exercise in Kiev and Critical Energy Infrastructure Protection: the Importance of the Public-Private Partnership workshops in Vilnius.

GRI 103-2 Integration of the Technical Protection Systems

In 2017, PSE’s Security Department began work on the integration of the Technical Protection System at PSE facilities. The idea to build alarm centres based on the existing Regional Supervision Centres is aimed at ensuring an appropriate protection level (through elimination of false signals and reduction of necessary interventions to actual incidents). 

Another initiative is the development of the “Integrated Protection System in PSE”, i.e. development of a model where a specialised security division supports security within the company by preparing standards for physical and technical protection, standards of fencing and facility access, and supervision and assistance in preparation of investment and upgrading tasks, acceptance of security related works, co-ordination of maintenance, repair and replacement of equipment and fencing.

Development of the domestic market

Our organisation, as an entity responsible for the national power system (Polish Power System, PPS), is one of the developers of the future market solutions. In this context, the Advisory Team for Changes in the Operations of the Electricity Market (ZDREE) established by the Ministry of Economy has been a major platform for dialogue with market participants. The Team was tasked with preparing a new wholesale model of the electricity market. In addition to PSE’s participation, works of the ZDREE were performed with the involvement of representatives of the Energy Regulatory Office, Economic Society Polish Power Plants, Polish Society of Combined Heat and Power Plants, Polish Power Transmission and Distribution Association, Association of Energy Trading, Polish Power Exchange, Polish Academy of Sciences and NSZZ Solidarność Trade Union.

On 17 October 2012 the team approved the final report with recommendations on the modification of the model of the electricity market in Poland. The report accounts for the premises and the European context of the proposed changes.

The process of modifying the architecture of the national electricity market was divided into two stages: the first aimed at improving the effectiveness of the balancing market and the method of managing the generating units, and the other aimed at the architecture of the wholesale market.

Based on the prepared recommendations and external conditions arising out of network codes, in 2017 PSE began to implement the Market Management System, MMS, in Poland, which will deploy new solutions in the field of operation of the generating units and loads, with the use of the complete model of the transmission network. One of the requirements to be met by the new system is support for the integration with the cross-border balancing market.

The process of modification of the domestic electricity market is inscribed within the wider context of development of the European electricity market and the European legal framework. As part of the changes in the national market, European solutions for the day-ahead market and the intra-day market will be implemented. Any delays in the implementation of the internal energy market, in particular in the Core region (continental Europe) will affect the schedule of implementation of such solutions in Poland.

PSE participation in development of the concept of the Community energy market

Since the very beginning, PSE has actively participated in the development of the EU integrated electricity market. We have been participating in the works of the working groups of industry organisations from the power sector. Our representative have participated in works of the Ad-Hoc Advisory Group on the most important assumptions for the final model of the electricity market and development of the European codes on the forward market (Forward Capacity Allocation, FCA), day-ahead market and intra-day market (Capacity Allocation and Congestion Management – CACM), and the cross-border balancing market (Electricity Balancing Guideline, EBGL), i.e. of Commission Regulation (EU) 2017/2195 of 23 November 2017 establishing a guideline on electricity balancing.

From the TSO view, the most important organisation is the European Network of Transmission System Operators for Electricity (ENTSO-E). It was established in accordance with the requirement of the Third Energy Package and has been implementing the tasks defined therein. 43 TSOs from 36 countries belong to ENTSO-E.

More than 80 PSE specialists are directly engaged in ENTSO-E work. They have been actively participating, at various levels, in all major tasks carried out by the organisation, which encompass, among others, the process of developing the European network codes. PSE is represented in the main bodies of the association. At the General Meeting, the company is represented by the President of the Management Board, and a member of PSE Management Board is a member of the ENTSO-E Board. The main components of the ENTSO-E structure are committees. We are represented in all of the committees: the System Operations Committee; System Development Committee; Market Committee, Research, Development and Innovation Committee; Digital Committee and the Legal and Regulatory Group which acts as a committee. The Market Committee is particularly important as regards development of the energy market. PSE has standing representatives in all the working groups reporting to the committee, and the Market Committee is chaired by PSE’s representative, Deputy Director of the International Cooperation Department, heading the European Integration Strategy Section.  

An important achievement in the works pursued on the ENTSO-E platform was the development of Capacity Calculation Regions, CCR, in accordance with requirements of the CACM Regulation (Capacity Allocation and Congestion Management).
In the CCR proposal, approved by all the TSOs, the Germany-Austria border was incorporated, which is the first step towards a coordinated allocation of transmission capacities on that border. The proposal was sustained by ACER, which ultimately decided on the shape of regions for calculation of transmission capacities in Europe. Incorporation of the Germany-Austria border in the process of coordinated allocation of capacities in the Central and Eastern Europe will support the systemic solution of the lack of import capacities on the Germany-Poland border.

Designation of CCR regions supported commencement of the works on the implementation of the final day-ahead market and intra-day market mechanisms, which, in accordance with requirements of the CACM and FCA regulations, are maintained in individual CCRs. Representatives of PSE have actively participated in the steering committees and working groups in all three regions within the PPS borders:

• Core – Continental Europe with synchronous borders of the PPS,
• Baltic – the Baltic States with the LitPol interconnection,
• Hansa – DC interconnections in the Baltic Sea region, with the SwePol interconnection.

Regardless of the works carried out in the CCR regions, PSE representatives participate in projects that implement requirements of Commission Regulation (EU) 2017/2195 of 23 November 2017 establishing a guideline on electricity balancing (hereinafter: EBGL).

As part of the works in CCR regions and EBGL implementation projects, our representatives try to secure the optimum representation of interests of the national energy market in solutions which are being deployed at the European and regional levels.

PSE is also an active participant of:

• the Central Eastern European Forum for Electricity Market Integration – a forum aimed at providing political support in the process of electricity market integration;
• CIGRE - an international association of experts dealing with the issues of power generation, transmission and distribution. The aim of the association is to promote innovations and new solutions in the power sector through cooperation between the worlds of business and academia;
• Central Europe Energy Partners (CEEP) – an international non-profit association which represents the energy sector of the Central Europe. The goal of the association is to support the integration of the Central European energy sector within the framework of the EU common energy and security policy in the area, where the Board of Directors is led by the director of PSE’s International Cooperation Department.

The market solutions that are developed and their effectiveness translates to the operating conditions of the interconnected power systems. PSE actively cooperates with other European operators under the TSO Security Cooperation (TSC) initiative. A total of 13 operators are TSC members. On 1 September 2014 a dedicated company, TSCNET, was established. The company supports operators by performing tasks involved in day-ahead and intra-day operational planning, mid-term coordination of integration of network elements, and coordination of redispatching remedial actions between operators. These tasks fall within the remit of the Regional Security Coordination Initiatives (RSCIs), i.e. regional coordination and supervision centres. The most important issues relating to the TSC initiative, such as the strategy and development directions, are decided on by the TSC Cooperation Board, which is vice-chaired by PSE’s President of the Management Board (whose deputy is the Adviser to the Management Board of PSE). TSC Operational Board is responsible for technical issues; the vice-chairman of this Board is a representative of our company. A total of more than a dozen PSE employees work in the TSC working groups.

At the beginning of 2017, all legislative proposals included in the package were directed for further work in the EU institutions, i.e. to the relevant commissions of the European Parliament and of the EU Council, where the positions of individual Member States are represented. Intensive work in both institutions was carried out throughout 2017. The package proposals which, from the viewpoint of PSE’s role as the transmission system operator in Poland, could pose particularly negative regulatory risks included areas such as:

• preventing the differentiation of real electricity prices (price in the balancing market) within a single zone resulting in the inability to individually coordinate the operation of electricity sources and loads in a given zone according to the condition prevailing in the zone;
• imposition of the requirement to procure electricity and reserve power within separate market processes, resulting in an inefficient use of system resources designed to supply electricity to consumers;
• implementation of inefficient and ineffective procedure of changing the price zone configuration;
• introduction of a minimum percentage threshold for transmission capacities made available for cross-border exchange that ignored the technical capabilities of the systems and resulted in an increase in the costs of remedial measures;
• retaining provisions that promote the energy only market, with stringent restrictions for the dual-commodity market;
• transfer of the decision-making powers to regional coordination centres in areas important for the security of the power system operation.

In our opinion, the consent for introduction of such solutions and adoption of the market model that took into account such proposals would have prevented secure and effective operation of the European power systems. The reason is that this model in inadequate for challenges faced by such systems where such challenges result from the ever-increasing variability of electricity generation and the required flexibility on the side of electricity consumption.

For this reason, our organisation was actively involved in the works on the package, presenting its position on the solutions being developed and presenting productive proposals of changes to such solutions to the state administration, at the ENTSO-E forum, in the messages addressed to MEPs, by taking the floor at conferences and other events concerning the package, and by publishing its opinions in the Polish and European media.  

Considering the regulatory risks arising out of the Clean Energy for All Europeans package, from the very beginning of package proceedings, PSE presented the position that in order to meet the challenges faced by the power systems, first it was necessary to effectively coordinate operation of generation sources and electric loads, using price signals. Such a coordination has to maximise economic benefits of using limited transmission capacities of electricity networks to supply consumers with electricity on one hand, and on the other it should provide support for meeting criteria of secure electricity supply. In connection with development of distributed forms of electricity generation and the distributed nature of demand flexibility, to ensure effective impact being exerted on resources located in various system locations, they must be stimulated accordingly to the prevailing conditions. To this end, it is necessary to properly price electricity at these locations which in turn requires proper representation of resources found in the system (networks and sources) in market processes and correct organization of such processes.

In addition, at the domestic and international forums, we have stressed that the proposed package solution that consisted in separate acquisition of electricity and power reserves stands in conflict with the operational effectiveness of the electricity markets. In combination with the tighter integration of the system balancing process and congestion management leading to generation of localisation pricing signals, integrated acquisition of resources necessary to balance the system will trigger maximum possible system flexibility that is required for the effective management of the operation of interconnected power systems, with a high share of RES.

PSE also provided technical support to the state administration in the discussion on the zone configuration change and review procedure. We drew attention to the fact that the energy market in the zonal market operated properly only with correctly designated bidding zones, where there are minimal or no network constraints. Therefore, the procedure of review and change of the zones should be transparent, comprehensible and feasible, and competences of entities should match their systemic role in the EU.

During works on package legislative proposals in the European Parliament and the EU Council, arbitrary minimum percent thresholds were adopted for cross-zonal capacities to be shared, referenced to the thermal capacities of cross-border connections. In PSE’s opinion, establishment of such thresholds lacks the economic rationale and poses a threat to the operational security of interconnected systems as it leads to providing access to such capacities above the level arising out of technical conditions and possibilities for ensuring secure network operation. The need to fulfil this obligation would lead to a drastic increase in the costs of remedial measures taken by the TSOs, which would ultimately be borne by the final recipients.

The restrictive provisions on the introduction of capacity mechanisms proposed in the package are of major importance to the entire power sector in Poland and to our organisation. The analyses which are carried out suggest that Poland may soon lack generating capacities necessary to cover consumers’ demand. The issue calls for structural solutions, such as transformation of the energy market from the single commodity model to the dual commodity market, through introduction of a structural, technologically neutral capacity mechanism.

The provisions of the package also provide that the so-called regional coordination centres are to issue binding instructions to the national TSOs on issues of key importance to the operational security of systems such as the coordinated designation of cross-border transmission capacities and the implementation of coordinated system security analyses. PSE, just like other transmission system operators who are members of ENTSO-E, presented a position that granting the right to the regional coordination centres to issue binding decisions in these areas would reduce the scope of actions that the TSOs may take to fulfil the obligation to guarantee system operation security. Separation of decisions affecting system operation security from responsibility for the security would lead to unavoidable competence conflicts and non-optimal operational decisions.

In December 2017, the EU Council agreed a common position on legislative proposals regarding the shape of the electricity market, which dropped the introduction of the requirement to obtain electricity and capacity reserves in separate market processes; as regards differentiation of actual electricity prices within a single zone, a relevant exclusion for centrally available systems was introduced. The EU Council also approved provisions that are favourable for Poland and which pertain to the conditions for the participation of coal generating units in power mechanisms.

At the beginning of 2018, the position on the proposal was also adopted by the European Parliament. This position differs significantly from the position of the EU Council regarding the most important regulatory risks for PSE. In particular, the European Parliament proposed introduction of strict time constraints for the functioning of capacity mechanisms and the tightening of the criteria the fulfilment of which enables coal generating units to participate in these mechanisms. In addition, the EP’s position did not accept postulates not to introduce the requirement of procuring electricity and capacity reserves using separate market processes.

Areas in which the position of both institutions is similar is the introduction of minimum percentage thresholds for cross-border capacities that are made available and the proposal of the procedure of review and change of the zone configuration that is intricate and difficult to be effectively implemented. In addition, both the EU Council and the EP expressed support that at least two functions essential for the secure operation of the system - the results of the coordinated calculation of transmission capacities and the coordinated security analyses - determined by the regional operational centres were binding for national TSOs.

GRI 103-2 In 2018 the “Clean Energy for All Europeans” package entered the final phase of approval by the EU institutions, the so-called trilogue. The result of this process will determine the final wording of legal acts that will determine the directions of development of the power sector after 2020.
In 2018 organisation continues to provide technical support to the governmental administration as regards arguments for the aforementioned regulatory risks. We also present, at the national and international forums, our position and proposals of solutions to issues relevant for the effective operation of the European electricity market.

We participate in international innovative projects, such as EU-SysFlex. This way, PSE are becoming the leader in advanced solutions in the field of energy, with a team of highly competent and committed employees and managers. We undertake a series of actions aimed at developing competences of employees and we are an active creator of projects in the field of R&D works which are part of our strategic goals.

In 2017, as part of the concept of innovations ecosystem being developed in the company, the Duets Programme was launched. This competition is aimed at generating an impulse to educate human resources to respond to the contemporary issues faced by an electricity transmission system operator. As part of the programme, the key grant holder, such as the doctoral student or student, gets the opportunity to work on an actual TSO issue. We finance the work of both the doctoral student and their scientific tutor. Most of the works is performed by the duet in the home unit, with extensive consultations with the PSE Innowacje team.

What is the DSR?

The DSR service consists in a voluntary and temporary reduction of electricity consumption by the consumer at the request of our company, i.e. the transmission system operator, in the hours of peak demand for electricity, in return for an appropriate remuneration.

Between September 2016 and July 2017, we developed and introduced new DSR service mechanisms, called DSR Intervention Programmes (DSR IP). The new mechanisms started the activation of the demand side on the electricity market based on the new rules, adapted to the capacities of consumers and the PPS requirements. The work resulted in contracting increased capacity volumes. The first DSR contracts concluded under the new rules came into effect on 1 July 2017 and were valid until the end of June 2018. The DSR contracts under the Guaranteed Programme cover in total the guaranteed volume of capacity reduction volume of 361 MW in summer and 315 MW in winter. The additional, non-guaranteed reduction volume was obtained by entering into contracts under the Current Programme.

The electricity market is characterised by a continuous development which, combined with the changes in the generation structure of the PPS and in the European interconnected systems, increases the probability of a situation occurring in the PPS, where it will not be possible to ensure operational security during peak demand hours, including the security of electricity supply to consumers. Thus, the process of expanding the range of active consumers in the electricity market requires further development of the DSR service, in particular through the elimination of the existing participation barriers for potential contractors. It is necessary to continue work to modify the current DSR service mechanism in order to optimise the effects for the PPS, and, at the same time, develop the rules that would implement the DSR service as one of the elements of the new electricity market and capacity market, in accordance with the expected adoption of the new legal regulations in the forthcoming years.

Plans for the future

The concept of new DSR IPs

A team of PSE experts, with the support of PSE Innowacje and the National Centre for Energy Analysis, has been working on the development of the DSR service through modification of the concept and operating rules of two new DSR intervention programmes. Changes in the rules of the programmes – both the guaranteed programme (with payment for readiness to provide the DSR service and for reduction) and the current programme (with payment for reduction) – developed on the basis of existing experience will allow us to maximise the utilisation of the reduction potential of consumers. At the same time, work will be carried out to design rules that would support the implementation of the DSR services as one of the elements of the new model of the electricity market (including the capacity market).

Service contracting – additional capacity

The DSR IP service will be contracted as a result of entering into and implementation of contracts with contractors selected in the open tender procedure. The plans are to acquire up to 500 MW of reduction capacity – offered by the existing contractors and new contractors selected in the tender procedure, the Guaranteed Programme, and additional reduction capacities arising out of the sale offers placed by contractors on a dynamic basis, through the sales portal in the Current Programme.

Expansion of information systems

New functionalities of information systems are designed to support the system of DSR IP services. The functionalities will be implemented in stages.

DSR Concept Simplified Current Programme

PSE plans continued development of the DSR service by creating a new voluntary programme addressed to consumers with the contracted capacity of over 300 kW; Simplified Current Programme (DSR PBU). This programme will be addressed to all consumers subject to restrictions on the consumption and supply of electricity.

Effects of the NMRI implementation:

• optimisation of the investment process and enhancing its effectiveness with a particular focus placed on methodical management of projects and portfolio. In 2017 PSE considerably reduced project delays and re-aligned the completion dates for investment projects;
• an increase in the investment process transparency and assurance of key stakeholders as far as management of the risk in projects and monitoring of activities of contractors are concerned;
• implementation of uniform qualitative and quantitative parameters for the evaluation of the investment processes;
• implementation of modern technologies and processes and product innovations (the new tools improve investment project management in terms of lead time, quality and costs);
• development of the adaptation and innovative organisation ready to face the most difficult challenges found in the investment process.

Selected action plans as part of the NMRI initiative in 2018:

• implementation of the new investment project management methodology,
• implementation of the new tool for handling and supporting the investment process,
• implementation of improvement designs in the areas of organisation and processes, tools and competences and motivation,
• adaptation of the Building Information Modelling technology in the project being implemented,
• standardisation of the data collection and recalculation systems.

01. Guarantor of energy security
Objective: Maintain a proper level of energy security in a manner that is responsible towards the society and environment

Our core, regulated activity is the fulfilment of the duties of a national transmission system operator. We manage the Polish Power System, balancing electricity demand with electricity production by generating sources available in the PPS.

We take part in creating the European electricity market and actively participate in developing global initiatives taken by operators, members of ENTSO-E.

The power transmission network must allow for changing power generation technologies and the location of generating sources both in Poland and in Europe. We are aware of the challenges of climate, environmental and social changes, and the need to adjust all our activities to face up to them.

02. Exemplary investor
Objective: Win favourable attitude of the investment environment

We plan and implement transmission network investment projects throughout the country. It is an essential condition for ensuring the continuous and reliable operation of the transmission system and maintenance of the country's energy security. Irrespective of the impact of our activities on the environment, we always listen intently to the needs and expectations of all interested parties.

Utmost care and diligence in performing investment tasks is to ensure that the values of the natural environment will remain available for future generations, and investments will be implemented with the acceptance of local communities in a manner that does not conflict with their broadly defined social interest.

03. Responsible employer
Objective: Provide employees with an opportunity for professional development and build a corporate culture based on the supported values

PSE employees – their knowledge and commitment – are at the core of the company's success and its sustainable development. We focus of providing high-class specialists to our company, who will build its high market value by pursuing the mission and strategic objectives of the company. We offer a secure and friendly working environment. We focus on responsibility, professionalism and commitment.

04. Reliable partner
Objective: Support transparency of activities and ethical conduct in relation to partners

We attach significant importance to how we build relations with our partners. We play a leading role in the power sector, which translated into taking responsible decisions and measures concerning other participants of the electricity market in Poland.

We seek to create a sustainable future for all our internal and external stakeholders. What we find very important are transparency and reliability, equal treatment of all market participants, preventing corruption in the context of transparent and effective rules of conduct, as well as our internal procedures and processes followed in relations with other participants of the electricity market.

05. Industry expert
Objective: Build and maintain the TSO’s image as an expert on key legislative and opinion-forming forums.

Owing to our employees' competence and experience, we are perceived as a partner for cooperation with legislative bodies, central and local administration units, and with scientific establishments and industry organisations.

We are actively involved in the law-making process. We take care of the development and transparency of the electricity market.