Ukrainian National Environmental NGO (UNENGO) «Мама-86» had prepared comparative analyses of the Draft National Environment Action Plan for 2011-2015 (NEAP), submitted to the Cabinet of the Ministers of Ukraine (CMU) by the Ministry of Environment and Natural Resources of Ukraine (MoE) after agreement with the all central governmental authorities (CGA) and discussion with the public and the final version of the NEAP approved by the Decree of the Cabinet of Ministers of Ukraine.

Besides the approval by the Cabinet of Ministers should take place before the 31 of March 2011, the dates of the preparation were extended due to multi sectoral consultations with central governmental authorities, representatives of science and NGOs organized by the Ministry of Environment. Such consultations required additional time. At the end of April the Ministry of the Environment submitted publicly agreed version of NEAP    to the Cabinet of Ministers. However the NEAP was approved only on 25^th of May (by the Decree of the CMU # 577-р). Moreover, approved text was published on the Website of Verkhovna Rada even later – at the end of July 2011. It became clear that CMU Secretariat has changed the structure of the document and deleted the dozen of key provisions from the discussed draft. Some other provisions of the NEAP were edited and resulted in the change of the context and correspondent misrepresentation of planned implementation results.

In particular, the deleted provisions included: inventory of environmental information, pollution release and transfer registry (PRTR) pilot projects and PRTR Protocol to the Aarhus Convention ratification, Interagency working group on monitoring of Decisions of Parties to the Aarhus Conventions, National Action Plan on Climate Change adaptation, measures on developing economic incentives for pollution decrease; ratification, methodology and reatification of the Protocol on Strategic environemntal assessment to the Espoo Convention; measures for «greening» of the development policy and improvement of environmental accounting; methodology of environmental risk assessment, actions for national environmental network formation, criminal responsibility for living resources use and many others. Legally binding environmental policy integration provision required in accordance with the Law on State Environmental Policy Strategy obtained new shortened edition, which drastically reduces scope of action referring only to the one of integration instruments – Strategic Environmental Assessment (SEA). Since the development and approval of SEA methodology was completely excluded from the activities, the approved edition has no sense. The above mentioned activities were traditionally implemented in a nontransparent way not only for the public but for the Members of NEAP Working group as well.

Ukrainian National Environmental NGO «Mama-86» expressed deep concern on the changes imposed by the CMU Secretariat to the NEAP and also applied to the MoE with proposal to initiate the process of changes and amendments to the approved NEAP in the letter addressed to the Ministry of Environment and Natural Resources of Ukraine. “Mama-86” plans to conduct public monitoring of State Environmental Policy Strategy and the NEAP implementation, as well as the EU Budget support use.