On December 21, 2011 the Ministry of ecology and natural resources of Ukraine published on its web-site in the section “Draft regulations” published the revised draft of the Concept of the National Program of waste management considering proposals and comments from central and local authorities, public and scientific organizations, enterprises and institutions.

Developers of the draft Concept have received and processed more than 100 letters with suggestions and comments to the above project concept. In particular, the draft concept included the part of the comments submitted by the UNENGO “МАМА-86”:

• On allocation of medical waste in a separate group of waste;
• On establishing a modern system of management of electrical and electronic waste, which already works efficiently in most European countries;
• On Elimination of “hot” points;
• On the effective application of modern economic tools and economic leverage;
• On rehabilitation of contaminated territories;
• On conducting educational outreach;
• On consultations with the public and NGOs.

Unfortunately, in the Part 1, dedicated to definition of the problem, in spite of the recommendations of “MAMA-86” to include the data about the real amount of obsolete pesticides (OP) in Ukraine, the information about amount of OP remained unchanged. According to it the amount of OP in 2010 was 20,528 thousand, placed in 4075 warehouses of different forms of ownership, where conditions of storage do not correspond to environmental safety.

According to the results of international partnership project “Elimination of acute risks from obsolete pesticides in Ukraine” (2008–2010), implemented by the UNENGO “МАМА-86” in cooperation with Millieukontakt International Dutch non-governmental organization and financially supported by MATRA Programme of the Royal Dutch Ministry of Foreign Affairs , the quantity of OP in Ukraine can amount to not less than 40 thousand t., and these estimates were proofed by the specialists of the Ministry of ecology and natural resources in the course of practical work of repacking OP.

The draft Concept of the National Program also did not include the suggestions provided by “MAMA-86” on the National Plan of implementation of the Stockholm Convention and POPs-containing wastes, as well as mercury containing wastes.

In addition, the Concept does not clearly define the work with general public, especially in the part concerning handling of solid wastes.

Unfortunately, the Part 5 of the Concept, which includes future solutions of the problems of wastes, provides plans of creation the infrastructure, which unfortunately can include mobile units for burning wastes.

The next step in work on the project of the National program of waste management in Ukraine has to become specific proposals of tasks and activities.

Execution of tasks of the National Program of waste management in Ukraine is planned to perform in two stages during 2013–2020, which is in the framework of “General Principles (strategy) of national environmental policy for the period till 2020”. The first stage: 2013–2015, the second stage: 2016–2020.

Financing of Program is planned for the expense:

• State budget of Ukraine (including its general and special funds);
• local budgets, including budgets of the Autonomous Republic of Crimea, Kyiv and Sevastopil;
• the private sector;
• businesses, including housing and communal services involved in the system of waste management;
• international financial institutions and grants;
• other sources not prohibited by law.

The approximate funding of the Program is 23.9 billion uah, including the first stage — 5.5 bln. II — 18.4 billion uah. The volume of work for the first stage includes the cost of relevant measures in the National Action Plan on Environmental Protection for 2011–2015.