On November 10, 2023, the Ministry of Environmental Protection and Natural Resources refused the Mokryany Forestry Enterprise to issue a conclusion regarding clearcutting and clearcut sanitary logging.
The notification on the planned activity regarding the use of forest resources appeared in the Unified Register of Environmental Impact Assessment as early as June 30, 2023. On September 28, 2023, the EIA report was released.
EPL analyzed the report in detail and identified a number of significant violations. As a result, we sent comments to the report with a request to declare the planned activity inadmissible and not to issue the EIA conclusion to the Mokryany Forestry Enterprise.
Based on the results of the review of EIA documentation, the Ministry of Environmental Protection concluded that the provided documents do not make it possible to fully investigate the impact on the environment in the course of implementation of the planned activity, to determine the admissibility or justify the inadmissibility of implementation of the planned activity, as well as to determine environmental conditions of its implementation. Having a number of reservations, the Ministry refused to issue the EIA conclusion to the Mokryany Forestry Enterprise.
Importantly, 7 out of 10 comments from EPL were taken into account in the text of the refusal. In particular, the Ministry of Environmental Proteciton agreed that the report should include materials from forest pathology surveys, materials on the division of forests into categories, a quarterly list of tree-stands older than 120 years, as well as a proper assessment of the impact on flora and fauna. In addition, we drew their attention to the prohibition of wood harvesting in virgin forests and quasi-virgin forests, as well as to the observance of the Rules for clearcutting in the mountain forests of the Carpathians approved by Resolution of the Cabinet of Ministers of Ukraine No. 929 of October 22, 2008.
We consider the refusal justified as it takes into account public, civil and private interests, meets the purpose of environmental impact assessment aimed at preventing damage to the environment and ensuring rational use and reproduction of natural resources, in the process of decision-making on implementation of economic activities that may have significant impact on the environment.
More details can be found in EPL’s comments and the decision of the Ministry of Environmental Protection.
