Our opinion on the draft amendment aiming to abolish the stockpiling obligation for power plants over 50 MW
According to Energiaklub Climate Policy Institute, lifting the fuel stockpiling requirement poses significant energy security risks - especially as the proposal is not supported by any calculations or technical analysis. We believe the amendment should only be adopted following a comprehensive impact assessment and the development of appropriate risk mitigation measures.
The Ministry of Energy proposes to amend Government Decree 44/2002 (XII.28.) GKM by eliminating the obligation for power plants over 50 MW, running on hydrocarbon fuels, to maintain a fuel oil stockpile. The aim is for such plants to rely instead on the strategic gas reserves stored at the Szőreg-1 facility during disruptions in natural gas supply.
In our view, this approach lacks adequate justification. The explanatory note offers no meaningful calculations regarding either the economic burden of the current system or the risks of the proposed alternative. Existing power plants already have the necessary infrastructure in place, and the one-time cost of stockpiling fuel amounts to only about 2% of annual consumption.
We find it particularly concerning that the regulatory reference to a remote gas storage facility does not provide a technically secure solution in the event of pipeline disruptions or other operational failures. Current regulations still require that the delivery of the liquid fuel stock to the power plant must not depend on long transport routes - an essential safeguard that would be lost under the proposed amendment.
In its current form, the proposal does not guarantee the continuous operation of power plants in emergency situations and leaves key questions of responsibility unanswered. Therefore, we recommend that the amendment only be adopted following a robust impact assessment and the inclusion of concrete measures to ensure energy supply security.
You can read our full policy opinion here in Hungarian: Véleményünk az 50 MW feletti erőművek készletezési kötelezettségének eltörlését célzó rendeletmódosításról (PDF)
