How can you have a non-transparent National Environmental Policy?


Seven leading Ukrainian environmental organizations have addressed an open letter to the Prime Minister, the Head of the parliamentary profile committee and the Head of the EU Representative Office in Ukraine asking them to take the process for drawing up and passing a Strategy for National Environmental Policy under their personal control.

The environmentalists express concern that the draft law on approving just such a Strategy which had been carefully prepared with the participation of civic society, scientists and Verkhovna Rada Deputies, was recalled because of the change in government. The amendments are now taking place in an extremely secretive and non-transparent manner.

The letter points out that the preparation and adoption by the end of 2010 of the Law on a Strategy for National Environmental Policy up till 2020 was the main condition for Ukraine’s 35 million Euro support from the EU.  The Strategy should be accompanied by an action plan containing specific projects for which European funding is allocated. Both Strategy and Action Plan are to be aimed at creating a contemporary and efficient system of environmental protection in Ukraine close to the European system to stop the degradation of Ukraine’s environment.

The authors explain that the draft Strategy was begun in 2008 and that throughout a large part of 2009 it was posted on the website of the Ministry for Environmental Protection. The process was transparent and coordinated by an inter-departmental working group with the participation of members of the public, scientists and Verkhovna Rada Deputies.

“After the change of government in 2010 the draft law was returned to the Ministry for reworking and to be agreed again. Under the new minister the process of working on the Strategy has become closed, the inter-departmental working group which prepared the previous version of the Strategy has ceased to exist, while a new one has not been created. The wider public have been totally cut off from participation in this work. At present the process of agreeing the draft with interesting central executive bodies is coming to an end and in two days the draft law is to be submitted to the Cabinet of Ministers. It has still not been published on the website of the Ministry, not to mention any broad public discussion”.

The letter explains that the initiative for preparing  European model Strategy and Action Plan for National Environmental Policy came from environmental NGOs which from 2005-2007 ran a nationwide campaign “On Prioritizing Environmental Policy”.

“The lack of transparency and elimination of public participation in the process of drawing up the most important document for the strategic development of the country in the environmental field are not only a flagrant violation of national legislation including the requirements of the Aarhus Convention. They also provide clear indication of the likely fate of millions of UAH of budgetary funding which the new Minister is preparing to “deal with” in swift manner.

We are outraged by the inadequate style of cooperation with the public of the new head of the Ministry, while we feel strong concern at the same time that non-transparent use of the huge amounts from the EU which should serve to improve the state of the environment in Ukraine could lead to yet another corruption scandal and damage to Ukraine’s reputation in is relations with the EU.

We call for:

Reinstatement of the inter-departmental working group on preparing a Strategy for National Environmental Policy with the involvement of the public and of scientists;

Deferment of review of the draft Strategy by the Cabinet of Ministers until a public discussion has been held with the procedure and mechanisms for this set out in Ukrainian legislation.

Full public discussion of the draft law “On a Strategy for National Environmental Policy fro the period up to 2020”;

We call on the Cabinet of Ministers and the profile committee of the Verkhovna Rada to take personal control over the review and adoption of a Strategy for National Environmental Policy and Action Plan.


The letter is signed by:


The Ukrainian Environmental League

The Ukrainian Society for the Protection of Nature

“Environment – People – Law” [EPL]

 “Zeleny Svit” [“Green World”]

“Chysta Khvylya” [“Clean Wave”]

The National Ecological Centre [NECU]

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