UPD. On September 19, the Ministry of Environment published the final version of the Concept Note. The final document clarifies the transboundary assessment. The document also describes the principles that Ukraine should be guided by (the principle of exclusivity, controllability, reversibility). The Ministry of Environment noted that under the conditions of war, Ukraine did not have the opportunity to develop a comprehensive framework for granting derogations from the EIA and SEA rules.
Most of the public comments in the document were not taken into account, and the content of the note remained unspecified, thus not complying with the rules of Reform 6.
The Ministry of Environment has published a draft Concept Note, a document outlining the scope of exemptions from Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) regulations. Ecoclub, along with other civil society organizations, has reviewed the document and identified several shortcomings. The content of the draft does not fully align with the requirements outlined in Ukraine’s Recovery Plan. If the Ministry does not address public feedback and approves the document in its current form, many reconstruction projects and programs may proceed without proper environmental impact assessments, and public opinion will be disregarded. There is also a risk of slowing down European integration due to misinterpretations of EU regulations.
The Concept Note does not specify particular projects or establish clear criteria for their implementation. This poses a risk that reconstruction projects dangerous to public health and the environment may be approved.
Read the public position:
Position of civil society organizations on the possible narrowing of EIA and SEA in Ukraine (171 downloads )EIA and SEA are procedures designed to assess the environmental impact of projects and plans, ensuring public awareness and participation in the decision-making process. Currently, these procedures are flawed: permits for factories and enterprises are often issued without thorough analysis, following the principle of ‘economy first’ (read in Ukrainian).
We thank the organizations that supported the joint position:
- NGO ‘Center for Environmental Initiatives ‘Ecoaction’
- NGO ‘Plato’
- NGO ‘Environmental and Humanitarian Association Green World’
- NGO ‘Ekoltava’
- NGO ‘SaveDnipro’
- Civil Society Organizations of Working Group 3 of the Ukrainian National Platform of the Eastern Partnership Civil Society Forum
- Civil Society Organizations of Working Group 5 of the Ukrainian Side of the EU-Ukraine Civil Society Platform”