The leading Ukrainian environmental and anti-corruption organizations including National Interests Advocacy Network (ANTS), International charitable organization “Environment-People-Law” (EPL), Anti-corruption Action Center (AntAC), SaveDnipro NGO that have been working together to promote the rule of law for environmental protection in Ukraine, strengthen environmental democracy principles and foster key environmental reforms are unanimous in their position regarding the plans to merge the Ministry of Ecology and Natural Resources of Ukraine and the Ministry of Energy of Ukraine.
Recently, a message about the rejoining of the Ministry of Ecology and Natural Resources of Ukraine to the Ministry of Energy of Ukraine appeared in the mass media. А similar experiment was conducted in 2019-2020 and was unsuccessful. As we know, such changes did not lead to the improvement of the implementation of reforms in the area of environmental protection. Ministry of Energy of Ukraine was mainly aimed at solving energy issues paying no or very little attention to pressing environmental problems and the need to implement environmental reforms.
The lack of effective creative leaders in the government indicates that they can repeat “shooting into their feet” and not reach a higher level of management.
A separate Ministry of Environment and Natural Resources cannot be effective if it stews in its own juice and does not promote and prioritize green policies in the areas of jurisdiction of other ministries.
Currently, the Ministry of Energy and others continue to ignore the need for green transformation in favor of the economic interests of some groups and their economic selfishness. The attempt to liquidate the Ministry of Environment again or to merge it with the Ministry of Energy is also an attempt to indulge economic interests. Therefore, the key is a conceptual change in priorities and approaches with an emphasis on the greening of all spheres of life and activation of the country’s eco-transformation, rather than eco-amputation.
Reasons that make effective work of the merged ministry impossible:
A direct conflict of interests between the energy sector, which is the main polluter of the environment, and the interests of environmental protection and public health.
For example, the ministry’s functions to sign product sharing agreements can limit or even cancel measures to reduce greenhouse gas emissions.
Non-compliance with the practice of European states.
Тhe international charitable organization «Environment-People-Law» has repeatedly analyzed the organization of ministries in various European countries. 12 of the 28 EU countries have a separate ministry for the environment. We are talking about Bulgaria, Estonia, Italy, Lithuania, Germany, Poland, Romania, Slovakia, Slovenia, Finland, Czech Republic, Sweden. 11 countries have an environment ministry linked to climate change, energy, agriculture, nuclear safety, etc., but the environment is a priority issue there. In these 11 states, the united ministry was created to environmentalize other industries. These countries are Austria, Belgium, Great Britain, Denmark, Ireland, Spain, Cyprus, Malta, Latvia, Luxembourg, the Netherlands, Portugal, France, Croatia.
In 7 countries, energy is combined with the environment. It should be said that energy is usually added to the powers of environmental departments in the context of climate change and greening. At the same time, environmental powers are not being reduced, but are being increased.
EU leaders approved an integrated approach to climate and energy policy aimed at combating climate change and improving energy security in 2007. Therefore, the environmental part of energy was added to the powers of other departments. That’s the way things stand.
Тhe need to provide national funding for nature protection.
Development of a network of nature reserve funds requires constant financial support, appropriate institutional development and seeking international environmental protection assistance. That is why there is a need for high-quality specialists and close cooperation with relevant donors and environmental protection institutions. The creation of a united ministry will aggravate the lack of funding problem.
Strategic environmental assessment and assessment of the impact on the environment of the most important plans and programs must be carried out by an independent ministry.
Otherwise, in this part, the government will have a direct conflict of interest and will not comply with anti-corruption principles.
The urgency of implementing European norms and standards.
The environmental block of EU legislation consists of a number of waste management directives, and climate directives, etc. Approximation of Ukrainian environmental legislation to European standards requires reforms and strong institution capable of carrying out these reforms. It is also impossible to implement the European Green Deal (EGD) in the absence of a powerful authority in the environmental sector.
On the other hand, Ukraine fail to fulfill a number of environmental protection obligations stipulated by the EU-Ukraine Association Agreement and a strong Ministry of Environment is needed to promote the process of Ukraine’s European integration in the environmental sector.
Full-scale russian aggression against Ukraine.
Full-scale russian aggression against Ukraine aggravated the existing problems and caused new ones. One of them is assessment of the damage caused to the Ukrainian environment as a result of the war. Currently we have the possibility to calculate the damage caused to the environment by russian aggression in different directions thanks to functioning of a separate ministry. Тhe merging of the Ministry of Ecology and Natural Resources of Ukraine and the Ministry of Energy of Ukraine will have fatal consequences for these processes.
Because Ukraine declared its goals towards green transition and strives to integrate into the European Union in the environmental sector and because environmental aspects should get due attention in the overall social agenda as they are related to protecting human health and life, we strongly disagree to the plans to merge the Ministry of Ecology and Natural Resources of Ukraine and the Ministry of Energy of Ukraine and call on the government not take actions that will have adverse impact on lives of Ukrainian for decades, if not centuries.
Anti-corruption Action Center (AntAC)
International charitable organization “Environment-People-Law” (EPL)
National Interests Advocacy Network (ANTS)
Ukrainian Nature Conservation Group (UNCG)
NGO “Osokorky Wetland park”
Donetsk regional organization of All-Ukrainian Environmental League
NGO “GOVERNMENTAL ORGANIZATION «PUBLIC HEADQUARTERS RESCUE KAMYANETS-PODILSKYI»
All-Ukrainian Youth Movement “National Alliance”
“Volyn Foundation” NGO“
“Free people Volyn“ NGO
“Eco-Severedonetsk“ civil society initiative
Petro Hryniuk, ornithologist
Eremurus Ecological Club
Oleh Tsaruk, expert of the UNCCD, expert of LEAD program of FAO
Environmental Bureau of the Ukrainian Greek-Catholic Church
All-Ukrainian Environmental Association “Green ark”
Zaporizhzhia Regional Division of All-Ukrainian Environmental League
Nataliya Vyshnevska, “Save Pikuy” initiative
Yulia Krasnova, Doctor of Law, docent
Donetsk Regional Organization of All-Ukrainian Environmental League