Over the last few years, many changes have taken place in the forestry and forest management sector in Ukraine, which have improved the opportunities for public involvement in sustainable forest management.
In particular, during 2018-2021 afforestation plans were opened, an electronic register of tree logging tickets was created (on the website of the state enterprise “LIAC”), changes in legislation were adopted to reduce felling within the nature reserve fund and alpine forests, developed with broad participation. Also, the 2035 State Forest Management Strategy of Ukraine and the Forest Management Procedure were approved, the concept of protective areas for biodiversity conservation in forests was introduced into legislation, and a number of draft by–laws were developed to modernize the current rules of felling. At the same time, the procedure of environmental impact assessment of continuous and gradual felling on an area of more than 1 ha was actively implemented, which repeatedly resulted in denials of permits for felling that potentially could cause substantial adverse impact on forest ecosystems.
However, from early 2022, all processes within the forest sector reform have been suspended. and with the beginning of the full-scale russian invasion of Ukraine a number of achievements of previous years have been lost.
The open register of tree logging tickets, the Unified register of EIA, including materials of already closed cases, and maps of forests, including in areas where no hostilities took place, are again inaccessible to the general public. This happened despite the fact that the Presidential Decree on martial law in Ukraine of 24.02.2022 did not include the suspension of Article 50 of the Constitution of Ukraine, that guarantees to everyone the right to free access to information about the state of the environment.
In a number of areas that are far away from the hostilities, unjustified bans on visiting forests were introduced, which, together with the closure of registers, made public control over forestry very difficult. Alongside with this, simplification of felling of a number of species during martial law is proposed.
In our opinion, temporary changes to the rules of felling should relate only to ensuring the prompt implementation of tasks for the defense of Ukraine and forest protection. At the same time, it is unacceptable to abolish the Sanitary Rules in the Forests of Ukraine, which include a number of restrictions on felling in various categories of forests, as well as to remove existing restrictions on continuous sanitary felling in the Carpathian region.
We also insist on the restoration of public access to the following forestry registers as soon as possible and on timely uploading of information into these registers:
Open register of logging tickets of the State Enterprise “LIAC”, including quarters allotment maps.
Public cadastral map (excluding information about the lands of the Ministry of Defense and the Ministry of Internal Affairs).
Layers with boundaries of forests and objects of the nature reserve fund on the Ecosystem portal.
The unified register of environmental impact assessment – at least open the case files related to deforestation, as disclosure of this information does not pose a threat to national security.
The unified inspection portal that contains the results of inspections of economic entities by regulatory authorities, in particular the State Environmental Inspectorate.
Experience has shown that shifting environmental issues during the war to the category “not the right time” only worsens the situation, and in the forest sector also leads to increased corruption and reduced management efficiency.
We would like to emphasize the need to take into account the principles of the European Green Deal, in particular on forest management, during the post-war economic recovery. According to these principles, the following are the basic positions that should become mandatory in the process of postwar reconstruction and European integration of Ukraine:
1. Ensuring the interests of Ukraine’s woodworking industry can be achieved only by intensifying the use of artificial forests (increasing the volume of forest thinning, selective and gradual clearcut logging, reforming felling instead of continuous felling), while reducing the operational load on forests and strengthening their protection.
2. It is necessary to develop the integrated use of forest resources, in particular to expand the use of non-timber forest resources, including the promotion of tourism.
3. Increasing the forest cover of Ukraine can be ensured only by preserving and balancing the use of self-seeding forests and creating private forests on degraded arable land, while completely abandoning the afforestation of steppe and meadow ecosystems.
4. In order to reduce corruption during the sale of timber, it is necessary to adopt as soon as possible the draft law 4197-д “On the Timber Market”, which proposes to transfer the sale of timber exclusively to electronic auctions.
5. It is necessary to introduce good quality planning and implementation of measures for the management of mined forest areas, based on the experience of other countries.
6. One of the key sources of funding for Ukraine’s forestry sector should be the monetization of forest ecosystem services, including carbon dioxide removal and sequestration, as well as adaptation to climate change. In addition to wood, forests provide a large number of ecosystem functions, the users of which are all citizens of Ukraine.In order to ensure funding for forests to perform climate regulative, water protective, soil protective and other functions, increase resilience to climate change, it is necessary to develop a regulatory framework for the assessment and monetization of ecosystem services.
We hope for fruitful cooperation with representatives of the forest sector and public authorities to implement the above tasks and prevent restrictions on public control and public participation in forest management processes.
Sincerely,
International charitable organization “Environment-People-Law”
Ukrainian Nature Conservation Group
Danube-Carpathian Program
“Ecoclub” NGO
All-Ukrainian Environmental Association “Green World”
Severodonetsk City Ecological Association “Green World”
