On August 26, 2010, the Government of Ukraine submitted the outdated text of the Draft National Environmental Strategy which did not incorporate public comments for consideration of the Verchovna Rada. On August 27, the Verchovna Rada registered draft  Law of Ukraine on approval of the National Environmental Strategy. These illegal steps  made useless both the constructive dialogue between the Ministry of Environment and NGOs involved in the process of preparing the Strategy since 2007 and the results of long-expected public discussion of experts' written comments on the Draft Strategy (conducted on August, 26).

Actually CMU violated its own regulations (Paragraph 53, part 2) and the requirements of Ukrainian legislation (Resolution №10 2010 by CMU, Paragraph 27) in the context of following the procedure of the public expertise and taking into account public opinion when it concerns such important documents

NGOs experts noted that almost for the first time in three years, those in the Department of Environmental Policy of the Ministry of Environment who are responsible for developing the Strategy followed almost the all procedures of preparing and carrying out the public discussion of a Draft Strategy. The text of the Draft Strategy and information about public hearings were published on the web-site of Ministry on June, 23. Throughout two months public experts sent comments. On August, 26, the Public Discussion of the comments and proposals took place, the report on their consideration was made, and the new draft Strategy with changes and additions was composed. As of August, 27^th, the NEW Draft was ready to be submitted to the Government of Ukraine. Still there was some time till September, 7 (the opening of the Seventh session of the Verkhovna Rada of Ukraine) to endorse this document by CMU in a simplified procedure.

MAMA-86 NGO, National Environmental Centre of Ukraine and All-Ukrainian Environmental League, whose leaders took part in developing the draft Strategy from the beginning, sent letters to the Prime Minister of Ukraine Mykola Azarov (http://mama-86.org.ua/images/stories/000194/Azarov.PDF)  and  the Minister of Environment Mykola Zlochevsky (http://mama-86.org.ua/images/stories/000194/Zlochevskiy.PDF) with the statement of their position and requirements to take necessary measures.

«We consider that the haste of the Government concerning the submission of Draft Strategy on August, 26, is groundless, - is written in the letter. – It has done much harm to the cooperation between Ministry of Environment and the public and undermined reputation of the Cabinet of Ministers. It is not clear to us why the Ministry did not inform CMU about the scheduled public discussions and preparing of upgrade Draft Strategy with incorporated results of public consultation.

We realise that preparation and adoption by the end of 2010 Law of Ukraine on adoption of the of National Environmental Strategy is a major commitment in the environmental sector in the framework of implementation of the Ukraine-EU Agenda of the Association  in 2010 and the main prerequisite for Ukraine to receive budgetary support. But European Commission considers that public participation in developing the Draft strategy is the necessary condition of financial support too, and expects that the Draft will be discussed by public and takes into account the improving proposals».

Signatories expect to get the answers on such questions as: why did the Government violate the requirements of the Ukrainian legislation and its own regulations in context of following the procedure of public expertise, on what grounds did it ignore the process of public discussion of the Draft Strategy and what way is it going to consider the public suggestions.

Now, the experts - members of the Working Group on preparing of National Action Plan for Environmental Protection and Public Council under the Ministry of Environment  are developing the updated Draft Strategy in order to submit it for Hearings in the Committee on Environmental Policy, Use of Natural Resources and Elimination of Consequences of Chornobyl Disaster. The date of  the hearings is to be agreed.

Contact person:

Anna Golubovska-Onisimova, the President of the All-Ukrainian Environmental NGO “MAMA-86”, the coordinator of project “Strengthening Participation of Environmental Organizations of Ukraine in the Development of EU-Ukraine Relationship”,

This e-mail address is being protected from spambots. You need JavaScript enabled to view it
tel. (044) 465-70-46

This material was prepared in the framework of the public monitoring of Ukraine’s implementation of its commitments to the European Union in environmental policy, which is also part of project “Strengthening Participation of Environmental Organizations of Ukraine in the Development of EU-Ukraine Relationship”, supported by the European Program of the International Renaissance Foundation.