“ENVIRONMENT for EUROPE” process
ENVIRONMENT DIVISION
United Nations Economic Commission for Europe
Palais des Nations, 8-14, avenue de la Paix
CY-1211 Geneva 10, Switzeland
Email: efe@un.org
Appeal
Dear Ministers,
The Ninth Environment for Europe Ministerial Conference is an important platform to raise the most pressing environmental problems in Europe and discuss potential solutions. A group of environmental NGOs from Ukraine would like to take this opportunity to draw your attention to the environmental problem described below.
We found out about the intention to build a National Memorial Military Cemetery on the territory of the “Lysa Hora” in Kyiv. The local government announced this intention directly and posted a draft decision on the website of the city council (URL: https://kmr.gov.ua/sites/default/files/1375_6.pdf)
The explanatory note to this decision points out to the urgency and relevance of honor burials of the fallen defenders of our country at the National Military Memorial Cemetery in Kyiv. Undoubtedly, adequate burial and commemoration of the defender heroes is an urgent task. At the same time, the problem of protecting the objects of the nature reserve fund does not recede into the background. In the current situation, it becomes even more important.
Lysa Hora is the location of the largest earthen fort in Europe. Тhe territory of the nature reserve fund was declared here on February 17, 1994. We are talking about regional landscape park “Lysa Hora”, a separate territory of the nature reserve fund is the “Natural channel of the Lybid River”.
In accordance with the Ukrainian legislation, any construction, change of boundaries, damage to trees, shrubs, grass cover, and the passage of all types of transport are prohibited on this territory. Violation of these prohibitions is subject to criminal liability.
Despite belonging to the nature reserve fund, archaeological value, unique landscape, complexity of the relief and active erosion processes, Lysa Hora often becomes the subject of illegal encroachments by Ukrainian officials and developers.
The recently published decision is noteworthy mainly for the following reasons:
1. The draft decision ignores the fact that the entire territory belongs to the Nature Reserve Fund of Ukraine.
2. The draft decision does not take into account the natural and territorial features of this park. The construction of any complexes on the territory of the RLP “Lysa Hora” is impractical because of the natural and territorial features of this park.
3. Such a project does not take into account the circumstances that actually became the purpose of its development. А flat area within transport accessibility with an established waste disposal system is required for burial. In our case, all these factors are absent.
4. The draft decision allocates 140 hectares for the memorial, despite the fact that technically only 11 hectares can be used for burial.
In connection with the above, it seems that officials are once again covering up the topic of war and manipulating with respect for fallen soldiers for their own selfish purposes.
The Ministry of Environmental Protection and Natural Resources of Ukraine plays one of the leading roles in the process of transferring the territory of the Lysa Hora regional landscape park for development, and consequently in the process of the complete destruction of the existing natural and archaeological values there. The position of the Minister of Environmental Protection and Natural Resources of Ukraine – Ruslan Oleksandrovych Strilets and his assistants – is particularly important. Unfortunately, as of now, the relevant ministry does not protect the natural wealth of Lysa Hora and supports its destruction.
We believe that no Ukrainian soldier fights for the destruction of Ukrainian nature and history.
Expressing our deep respect and honor to the participants of the Ninth Environment for Europe Ministerial Conference,
WE ASK YOU:
1. To draw attention of the Ukrainian Ministry of Environmental Protection and Natural Resources to adverse environmental impacts of the construction works planned in Lysa Hora RLP.
2. To express concern regarding the actions taken by the Ukrainian authorities with the aim of performing construction works in the Lysa Hora regional landscape park, destroying its unique nature and archaeological value.
3. To respond to the arbitrary actions of the Kyiv City Council regarding the development of the Lysa Hora regional landscape park and the support of such actions by the Ministry of Environmental Protection and Natural Resources of Ukraine and its employees by proposing solutions that can accommodate both the purposes of commemoration of Ukrainian heroes and preservation of valuable natural territories.
ICO “Environment – People – Law”
NGO Ukrainian Nature Conservation Group
NGO Ecozahin (eco-squad)
