BULGARIA’S HYBRID ENERGY MODEL: LEGAL ASPECTS OF SYSTEMIC SUSTAINABILITY

Abstract

This study analyzes the critical interaction between centralized nuclear power capacities and emerging decentralized energy communities within the context of the full liberalization of the Bulgarian energy market by 2026. The primary focus is directed toward the regulatory dichotomy between the Energy Act, which ensures systemic security through base-load capacities, and the Energy from Renewable Sources Act, which introduces decentralized entities and derogates the traditional "vertical" energy model. The analysis establishes that the transition to a free market fundamentally alters the status of the Kozloduy Nuclear Power Plant—moving it from a strategic asset with administrative quotas to an active market participant exposed to price volatility and in need of new financial instruments, such as Contracts for Difference. In parallel, the Energy from Renewable Sources Act legitimizes the figures of the "active consumer," the "citizen energy community," and the "independent aggregator," providing them with streamlined administrative regimes and energy-sharing rights. The research identifies a significant regulatory vacuum regarding pecuniary liability for imbalances and the allocation of systemic sustainability costs. It highlights the legal antinomy between the priority grid access granted to renewable energy sources communities and the technological inertia of nuclear capacities, which often leads to the improper socialization of individual costs within the overall system price. In conclusion, specific legislative measures are proposed to achieve regulatory synergy, including the introduction of "flexible grid contracts," the transformation of network services toward capacity-based fees (per kW), and the integration of decentralized sources under the direct operational control of the system operator. The author substantiates the thesis that the sector's sustainability depends on transitioning from a model of parallel existence toward the legally regulated functional integration of generating capacities.