Ukraine is currently building a system of minimum stocks of oil and petroleum products. But under wartime conditions, the issue is not just how much fuel is contracted or accounted for in the system. The key question is how much of this resource will actually survive a massive attack.
As Tetiana Dumenkova, Deputy Head of the Fuel and Energy Business Association (FEBA), notes, in the era of drones, a large open oil terminal ceases to be a symbol of reliability and becomes a potential target. Ukraine is building its minimum stock system not during a classic energy crisis, as EU countries did, but under the constant threat of missiles, UAVs, and enemy reconnaissance.
The legislative framework is already in place: the Law of Ukraine “On Minimum Stocks of Oil and Petroleum Products” is in effect, alongside government regulations governing the system. The model envisages a gradual increase in market participant obligations—from 3% in the first year to 24% by the eighth year. There is also a provision to store a portion of these stocks in EU countries.
However, for Ukraine, this is not enough. Stocks held abroad may be an important insurance mechanism, but in a crisis, the fuel still needs to be delivered. And in wartime, time is often as valuable as the resource itself.
According to FEBA, Ukraine must shift from the logic of large, open tank farms to a multi-level and dispersed storage system. This is not about one large “fuel bunker,” but rather a network of different levels: strategic underground or semi-underground hubs, protected regional depots, local stocks for critical infrastructure, a portion of reserves held abroad, and mobile logistics.
Local reserves for communities, hospitals, water utilities, heating plants, emergency services, the agricultural sector, and military logistics are especially important. These should not be open tanks or temporary containers, but protected, dispersed, and fire-safety-equipped solutions.
Global experience confirms that underground storage can be an effective element of energy security. The U.S. uses salt caverns for its Strategic Petroleum Reserve; Germany stores a portion of its crude oil in underground salt formations; and India is developing underground rock caverns. Ukraine also possesses engineering experience in large-scale underground energy storage thanks to its system of underground gas storage facilities.
At the same time, we emphasize that underground storage does not make fuel absolutely invulnerable. Surface nodes, power supply systems, pumping stations, loading racks, and logistical access roads remain vulnerable. However, going underground changes the nature of the risk: instead of the total loss of a resource, the country gains a chance for repairs, route rerouting, and the preservation of the stock itself.
For Ukraine, the optimal path is not a choice between a “just-in-time” delivery model and protected reserves, but a combination of both. Current logistics must ensure the daily flow, while underground and protected reserves must provide the country with time at a critical moment.
We believe that Ukraine should not start with massive megaprojects, but with pilot solutions that can be tested, scaled, and adapted to real wartime risks. The principle should be simple: less conspicuous infrastructure, more dispersal, protection, invisibility, and practical survivability.
You can read the full column by FEBA Deputy Head Tetiana Dumenkova at the following link:
