Preamble
The UN Climate Conference is an annual conference held within the framework of the UN Framework Convention on Climate Change (hereinafter referred to as the Convention) and the meeting of the parties to the Kyoto Protocol. This conference is the main international event focused on climate, where not only environmental but also political interests of countries are discussed. It is important for Ukraine to show itself as an active participant in the global climate policy process, to contribute to the formation of international partnerships and to strengthen support for our sovereignty and climate strategy.
We are convinced that at COP29 Ukraine should have a position that will take into account global climate commitments, and particularly challenges caused by the war, as well as the country’s strategic interests. Ukraine should emphasize the importance of sustainable recovery and international support to overcome environmental and climate consequences of the war.
Because of the military aggression of the Russian Federation against Ukraine, the occupation of a large part of its internationally recognized territory, which includes the Autonomous Republic of Crimea, part of the Donetsk, Luhansk, Zaporizhzhia, Kherson, Kharkiv and Mykolaiv regions, massive missile and artillery strikes on the territory of all regions of Ukraine, our country has experienced unprecedented difficulties in implementing provisions of the Convention.
In particular, the Russian aggressor destroyed huge areas of forests, destructed or partially seized the greenhouse gas emission monitoring system, destroyed numerous mines – both those that were in operation and those that were in a state of conservation. The energy infrastructure, in particular, the electric power infrastructure, is constantly under attack, which makes it impossible to fulfill the obligations regarding the reduction of greenhouse gas emissions. Acts of ecocide were recorded, in particular, through the destruction by the Russian occupiers of the dam, reservoir and economic complex of the Kakhovka hydro power plant. Zaporizhzhia nuclear power plant, the largest in Europe, was captured, which stopped the production and supply of electricity to the energy system of Ukraine. A number of renewable energy facilities were seized or destroyed, in particular, the largest wind energy parks on the coast of the Sea of Azov, a large number of solar power plants in the south of Ukraine. The aggressive war of the Russian Federation against Ukraine adversely affected the investment climate, which significantly complicated the “green transition” due to a sharp drop in Ukraine’s investment attractiveness for foreign capital.
The Russian Federation, which is a Party to the Paris Agreement, with the direct support of the Republic of Belarus and North Korea, violated a number of fundamental provisions of the Paris Agreement by waging war against Ukraine, in particular:
the right to access to sustainable development of Ukraine and to eradication of poverty is violated;
food security of humanity, especially of the poorest countries, which are traditional consumers of Ukrainian food, is at risk; looting of food stocks is happening in the occupied territories, Ukrainian infrastructure for storing and transporting grain is targeted by missile strikes;
intentional and indirect destruction of absorbers and accumulators of greenhouse gases (for example, forest and steppe ecosystems);
the infrastructure for monitoring greenhouse gas emissions, recording climate indicators, etc., is destroyed.
In connection with the ongoing aggression and partial occupation of the territory of Ukraine by the aggressor country, the Russian Federation, Ukraine has no possibility to fully fulfill the obligations in accordance with paragraphs 8, 9, 13, 17, paragraphs 1, Art. 5, paragraph a, point 7 of Art. 13 of the Paris Agreement.
At the same time, despite the objective obstacles in the implementation of this Agreement, caused by the aggressive actions of the Russian Federation, as well as its allies, which directly support aggression against Ukraine, there are internal and international opportunities and mechanisms in Ukraine for fulfilling the goals of this Agreement in the territory controlled by the Ukrainian government.
At the conference, Ukraine should raise the issue of effective implementation of the obligations of the state in accordance with Ukraine Facility Plan. One of the blocks of this plan is “Green transition and environmental protection”. According to the Plan, the green transition is a key priority for economy modernization aimed at increasing energy efficiency and reducing emissions. Achieving climate neutrality involves the following: combating industrial pollution, a course towards climate neutrality, emission allowance market, combating illegal logging, waste recyclng and moving away from the resource-based economy.
Particular attention should be paid to the fulfillment of the goals and tasks that Ukraine undertook within the framework of the Paris Climate Agreement. In order to implement Ukraine’s contribution to the Paris Agreement, it is necessary to implement innovations and best global practices in all key sectors of the economy. In addition, by 2030, it is planned to take steps in such area as electricity, heat supply, industry, forestry, housing and communal sector, transport, agriculture, and waste management.
Block of recommendations
In our opinion, in order for Ukraine to fulfill its obligations under the Paris Climate Agreement and Ukraine Facility Plan, to achieve climate goals, authorities must take the following measures:
Verkhovna Rada of Ukraine
Measures should be taken to integrate climate policy into other policies at all levels, in accordance with the Law of Ukraine “On the Basic Principles of State Climate Policy”.
Create legislative conditions for improving the system of monitoring, reporting and verification (hereinafter referred to as MRV) of greenhouse gas emissions. To intensify the implementation of EU standards for MRV, in particular regarding mandatory reporting at the level of installations, in order to increase the accuracy of data and compliance with European norms.
In order to fulfill obligations to the Energy Community and harmonize Ukraine’s carbon policy with the EU policy, it is important to continue the development and adoption of legislation on legal regulation of the national system of emission quota trading.
It is necessary to ensure legislative basis for implementation of waste management reform, which should include implementation of the European waste hierarchy and systems of extended producer responsibility, transition to a circular economy, creation of effective financial instruments for such a reform and overcoming corruption risks.
It is important to amend the legislation with the aim of minimizing the impact of martial law on climate policy implementation, to enact climate legislation, in particular on MRV and mandatory reporting. This will contribute to ensuring the continuity of work and introducing high standards of climate policy in the conditions of war.
Executive authorities
In order to ensure the possibility of effective implementation of the Law of Ukraine “On the Basic Principles of State Climate Policy”, it is worth updating the 2030 Strategy of Environmental Security and Adaptation to Climate Change and the 2035 Strategy for Developing and Implementing State Climate Change Policy and adopting the operational plan of measures for its implementation in 2024-2026, in accordance with the Paris Agreement and the principles and ideas embedded in the Law of Ukraine “On the Basic Principles of State Climate Policy”.
It is necessary to develop and present an updated nationally determined contribution under the Paris Agreement, taking into account current situation in Ukraine and impact of the war on climate.
It is vital to ensure a dynamic review of the 2030 National Energy and Climate Plan (hereinafter – the NECP): ensure regular monitoring and a dynamic process of reviewing the goals and indicators of the NPEC, adopted in June 2024, in order to update it and prepare for the next review by the European Commission until December 2025. It is necessary to take into account both national and international changes in the field of climate policy and energy, especially changes in the EU within the framework of the “Fit for 55” package.
Ensuring implementation activation of the system of monitoring, reporting and verification (hereinafter – MRV) of greenhouse gas emissions, EU standards for MRV, in particular for introducing mandatory reporting at the installation level.
In order to gradually converge with the European Emissions Trading System (EU ETS) and increase the competitiveness of the Ukrainian economy on the international market, it is worth taking measures to implement the national emission quota trading system.
Initiating measures to minimize the impact of martial law on the implementation of climate policy, enacting climate legislation, particularly on MRV and mandatory reporting.
As part of the reform of the system of integrated environmental permit, it is necessary to adopt relevant by-laws so that the provisions of the Law of Ukraine “On Integrated Prevention and Control of Industrial Pollution” could be effectively implemented.
Ensuring implementation of waste management reform, which should include implementation of the European waste hierarchy and extended producer responsibility systems, transition to a circular economy, creation of effective financial instruments for the reform and overcoming corruption risks.
Taking measures for the greening of agriculture, which will include ensuring working mechanisms for monitoring and controlling compliance with the current legislation of Ukraine on the prohibition of plowing coastal protective strips and slopes, nature conservation areas, optimizing the structure of agricultural land and the land fund in general by reducing the area of arable land, preserving hayfields and grasslands as lands that support the existence of valuable ecosystems, phasing out prohibited pesticides and chemical fertilizers, fighting against smuggling of pesticides, reducing use of permitted pesticides and chemical fertilizers, expanding organic farming.
In the period of 2024-2030, measures should be taken to change focus of the forest industry towards ensuring environmental role of forests, to approve a comprehensive plan for implementation of the 2035 State Forest Management Strategy, to phase out continuous felling in all forests of natural origin that do not have nature conservation status. Preservation of self-seeded forests should be carried out through active promotion of their inclusion into the forest fund, creation of communal and private forests on degraded arable lands, and permanent state control. When planning forestry activities, it is necessary to aim to preserve biodiversity and ecosystem services it provides.
Local self-government bodies
To support the updating and implementation of the 2030 Strategy for Environmental Security and Adaptation to Climate Change and the 2035 Strategy for State Climate Policy. To develop and adopt local operational action plans to meet national climate commitments.
To ensure comprehensive integration of climate policy into local strategies and programs in the areas of transport, urban planning, health care, education, energy and infrastructure, which will contribute to the achievement of the goals of the Law of Ukraine “On the Basic Principles of State Climate Policy” at the community level.
To consider supporting and involving local businesses into the national emissions trading system once it is properly implemented.
To supervise implementation of the requirements of the Law of Ukraine “On Integrated Prevention and Control of Industrial Pollution” and provide consulting support for the proper processing of integrated permits within the scope of powers under the Law of Ukraine “On Local Self-Government in Ukraine”.
To implement the European waste hierarchy at the local level, promote creation of conditions for extended producer responsibility and support the community’s transition to a circular economy. To provide local control over waste management, taking into account prevention of corruption risks.
To support measures to optimize the land fund by reducing the area of arable land, preserving hayfields and pastures, and encouraging organic farming.
To develop local programs for preservation of natural forests, to implement measures to stop continuous felling in forests of natural origin, especially those that do not have nature conservation status. To stimulate creation of communal and private forests on degraded lands and ensure protection of self-seeded forests through their inclusion into the local forest fund.
Conclusions
We believe that Ukraine needs to draw attention of the world community to the issue of compensation for environmental damage caused by the war, use of green technologies for reconstruction and attraction of international funds for climate projects, adaptation to climate change in the conditions of post-war recovery.
We are convinced that the right approach should be immediate launch of negotiations on Ukraine’s EU accession under Chapter 27 “Environment and Climate Change” or the Green Cluster in general. This is necessary for the post-war reconstruction and recovery of Ukraine. Active and effective implementation of EU acts in the field of environment and climate will contribute to truly green reconstruction of Ukraine. This will enable implementation of the principle “building back better” and Ukraine’s international climate obligations.
We call on the authorized authorities to take into account the recommendations of this appeal and activate legislative initiatives to harmonize Ukraine’s environmental and climate legislation with the EU standards. The Ukrainian delegation at the 2024 UN Climate Conference (COP29) should comprehensively present Ukraine’s position regarding the urgent need for “green” recovery, strengthened with climate policy and supported by international partners. Ukraine’s main strategy at COP29 should combine global efforts to combat climate change with sustainable recovery initiatives. This will enable Ukraine not only to make a significant contribution to reducing global emissions, but also to consolidate its position on the world stage, emphasizing that the aggression of the Russian Federation is a global threat that hinders the achievement of the goals of the Paris Agreement and requires elimination of the environmental consequences of the war. In order to reduce the global climate threat caused by the actions of the Russian Federation, we suggest that the international community introduce a complete ban on investments and equipment supplies for Russia’s new energy projects in the Arctic.
