Oleksiy Vasyliuk
The environmental consequences of the war in Ukraine are typically discussed in the context of military action, explosions and mined areas. Yet there are just as many problems in the rear, well away from the frontlines. Large-scale extraction of natural resources, the destruction of forests, alterations to river courses and transfers of natural areas into private hands during wartime often escape the public eye. And activists’ and inspectors’ access to information and monitoring of violations is seriously limited, which exacerbates the situation. State registers are closed, movement in natural areas is complicated (in part due to the hazards of landmines), and public control is weak. What impact are these factors having on the environment in the context of the ongoing war?
The majority of studies, publications and expert talks on the environmental problems that have arisen in Ukraine as a result of the full-scale invasion are almost always concerned only with the direct consequences of military action, shelling and mining. Some of the biggest stories in the last three years have been the destruction of the dam at the Kakhovka hydropower plant, the threat of a “dirty bomb,” and soil and water contamination.
Read more:
- Military oil spill (2): Scale and consequences of the catastrophe for flora and fauna and the region’s ecosystems
- The toxic legacy of the Kakhovka Reservoir
- Danger! Mines! The terrible environmental and human cost of Ukraine’s minefields
- Pollution from the bed of the Kakhovka Reservoir could affect water quality in local settlements
Meanwhile, areas in the rear, often far from the frontline, face completely different environmental problems, typically unnoticed by journalists and officials. These issues may be rarely spoken of, but this doesn’t make them any less significant. While everyone’s attention is fixed on the consequences of shelling and military activity, as well as high-profile events in the geopolitical arena, in many regions of Ukraine, the extraction of building materials and minerals is developing at a frightening pace and scale. Forests are being cut down, river channels straightened, natural rivers and their banks dredged and denuded, and natural areas transferred to private ownership. While these activities are partly linked to servicing the needs of the army or the restoration of destroyed infrastructure, some of them (such as river dredging or riverbank reinforcement) are being used by local officials as a way of gaining access to budget funds.
The worse the consequences of military action at the front, the more unnoticed the violations in the rear. Although activity of this kind causes less environmental damage than direct military action, such cases are clearly harmful to Ukraine’s image as it pushes for closer European integration. And unlike the consequences of shelling, environmentally destructive projects well to the rear of Ukraine’s frontline could certainly have been avoided.
No entry for activists
Carrying out effective environmental monitoring in the rear has become a great challenge for public organizations since 2022, mainly as a result of mass restrictions on access to information and decision-making.
Before the full-scale invasion, Ukraine was making rapid progress toward providing the broadest possible access to open data for non-governmental organizations (NGOs) and citizens alike. Most state registers, maps, permits and other information were already in the public domain. One of the mottos of the current Ukrainian government is “the state on your smartphone.” Almost everyone in the country now uses a government mobile app called Diya, which not only holds digital copies of citizens’ most important documents, but also allows them to pay taxes, submit declarations, document damage to their homes, receive compensation for losses and much more. Most Ukrainians are therefore accustomed to having access to information online. The state has actively developed open-source data technologies and supported the development and implementation of electronic monitoring, creating numerous opportunities for activists devoted to unearthing environmental violations. In theory this has allowed any Ukrainian citizen to carry out environmental monitoring.
However, with the beginning of the full-scale invasion, access to many open registries was closed. For example, on the very first day of the invasion the public cadastral map became inaccessible, along with most databases on forests and minerals, as well as land development permits. The efforts of community organizations have made it possible to restore access, but only to individual registries, such as the environmental impact assessment registry. Movement restrictions are also substantial obstacles to independent monitoring. Some regions, closer to the frontline, were completely closed, and a nationwide ban on visiting forests was imposed across Ukraine. This complicated the work of activists, who were no longer able to record illegal logging or other violations.
These issues exist not only in the frontline zone, but also in regions up to 500-700 kilometers away. Essentially, foresters or poachers can now carry out illegal logging in forests, but activists cannot get into the forest to record these violations.
When Russia invaded, many activists and journalists joined the Ukrainian army and suspended their community work. Even more activists have switched their focus to helping their colleagues at the front. So there are now fewer community activists focusing on environmental protection, and those who remain have little opportunity to continue their activities.
In addition, the situation causes difficulties when it comes to sharing and exchanging experience with other countries. One example is restrictions on crossing borders for men of military age, which mean that some activists and NGO representatives have now lost the opportunity to attend conferences, training sessions and other events.
No inspecting for inspectors
Restrictions for regulatory authorities also hinder environmental protection work in the rear, since it is often even more difficult for inspectors of the State Environmental Inspectorate (Gosekoinspektsiya) or employees of the State Geographical Cadastre (Gosgeokadastr) to reach the site of a violation than it is for public activists.
Restrictions were first imposed on the work of Gosekoinspektsiya back in 2014, when inspectors were prohibited from traveling to conduct spot checks. Restrictions on inspections by environmental inspectorates and other regulatory bodies were introduced by Ukrainian Law № 76-VIII, adopted on December 28, 2014, which provided for a moratorium on small and mid-sized business inspections. It was this law that temporarily prohibited inspections by regulatory bodies such as the State Environmental Inspectorate without permission from the Cabinet of Ministers or an application from the business itself.
In 2016, a federal law “On temporary aspects of the implementation of state oversight (control) measures in the sphere of economic activity” was approved. As a result the earlier moratorium was extended to 2017 and, following changes in the law, again until 2018. In 2018, however, the moratorium was canceled.
As a result, public organizations have virtually lost the opportunity to contact the state environmental inspectorate when they discover a violation. Essentially, this means that until 2022 only local residents had the right to contact the Gosekoinspektsiya to report violations occurring near their place of residence.
Government oversight (control) and state market oversight under martial law were terminated by a Cabinet of Ministers of Ukraine resolution dated March 13, 2022. Resolution No. 303 “On the termination of government oversight (control) measures during the period of martial law” was introduced by a presidential decree dated February 24, 2022.
Prior to 2022 only local residents retained the right to contact Gosekoinspektsiya to report violations that occur near their place of residence. During the full-scale war, these restrictions were expanded and now the environmental inspectorate and State Geographical Cadastre may only conduct onsite violation inspections if they are instructed to do so by the Ministry of Environmental Protection and Natural Resources.
In fairness, these clearly unjustified restrictions are partially offset by new opportunities that have appeared since the full-scale invasion. For example, the state platform EcoZagroza, which collects information on the environmental harm inflicted on Ukraine by the Russian invasion, now features a function allowing users — identified via a digital signature — to submit a report on environmental violations they have discovered. Within two weeks of the report being filed, the State Environmental Inspectorate travels to the site and documents the violations that have been reported. If the information is confirmed, a report is drawn up and the State Environmental Inspectorate makes a request to the authorities to conduct a full inspection.
So activists still have some ways of protecting the environment. In fact, “the state on your smartphone” works quite effectively here, since any individual making an online application receives scanned copies of all documents associated with the inspection — including photographs of the procedure.
Environmental impact assessments
The state registry of environmental impact assessments (EIA) is another important database affected by restrictions in the last three years. Ukraine began implementing European directives on environmental impact assessment and strategic environmental assessment in 2017. This should mean that the EIA procedure is transparent and open and all documentation regarding projects is available online.
After the invasion, however, the registry was temporarily closed, making public scrutiny of environmentally destructive projects impossible. A number of new projects were approved without due consideration as a result. The registry was eventually reopened under public pressure, but officials tried to hide the locations of planned facilities for some time, citing safety concerns. They literally obscured the names of settlements and coordinates on project documents, as well as maps and diagrams. It is hard to see how the environmental risks of a project can be evaluated in such conditions.
It has become clear to the Ukrainian Nature Conservation Group that one in every four environmentally harmful projects has received a negative environmental impact assessment (EIA) following comments from public organizations. The implication is that community participation was restricted in the interests of unscrupulous businesses — and to the detriment of Ukraine as a whole. Attempts to restrict access to this information come across as a deliberate effort to deprive the public of an important tool for influencing the environmental situation.
The projects that have undergone EIA assessment during the full-scale invasion include the reconstruction of sensitive facilities such as nuclear power stations and hydropower plants. Information about such projects can be used by the Russian army, so it is hardly surprising that they have been classified. However, the vast majority of projects, such as the development of quarries, planned logging in forests, the construction of new facilities at enterprises or the clearing of river beds (and hundreds of such projects are submitted for EIA every month) are unlikely to be of any strategic significance for the Russian army.
The registry is now up and running again. However, the Ministry of Environment and Natural Resources has created a new registry requiring even more complex user identification. The old registry, containing thousands of completed cases, remains inaccessible.
The inability to review old cases is also a serious limitation: investors eager to bring their plans to fruition at any cost repeatedly apply for assessment, even after receiving several negative EIA conclusions. For activists, members of the public and journalists who learn about a harmful new project (for example, about digging a quarry in a nature reserve), it is vital to know whether negative EIA conclusions for this or a similar project have previously been issued.
Unscrupulous investors may also be counting on exploiting the rotation of officials making decisions on the EIA procedure to help them obtain permission for the project they have planned, on the principle that “if this one doesn’t approve it, the next one will.” In such cases, it is essential that the public point out to the “next” official that their predecessors have already assessed this project and drawn negative conclusions. Today, however, this has become much more difficult to do. The majority of the most environmentally harmful projects “approved” in Ukraine since the full-scale invasion are just like this — previously unapproved or even prohibited.
Here are several examples of projects that represent a particularly serious threat to nature, yet have officially received positive EIA assessment since the full-scale invasion began.
- Mining of granite from the Markivetske deposit in the Khmelnytsky region. The EIA conclusion was published on July 18, 2022, despite resistance from local residents. The granite deposit is located within a national nature park listed as a site belonging to Europe’s Emerald Network.
- Development of the Dvorovychi deposit for construction sand in the Rivne region. The EIA conclusion was issued on June 26, 2023, despite the area’s status as a nature reserve. The project had already received a negative EIA conclusion twice, but during the war it was approved nonetheless.
- Mining operations by Bukovinsky Budyvelny Materialy LLC in the Chernivtsi region. The conclusion was issued on January 30, 2024. This project was twice issued with previous negative EIA assessments on the grounds that it involves mining within the boundaries of a nature reserve.
- Construction of a 999 kW diversion mini-hydropower plant on the Stogovets River and the construction of a diversion mini-hydropower plant on the Baltsatul River in the Zakarpattia region. Both conclusions were received on August 2, 2023. The project had already been given a negative assessment in the past because it is located in an area with Emerald Network status, created partly to protect rare species of migratory fish. In addition, building a power line through continuous forest areas requires logging, which divides wildlife populations. The construction of one of the hydroelectric power plants may also damage nature reserve fund land, an area that is a hydrological natural monument.
- Construction of a 999 kW mini-hydropower plant on the Teresva River in the village of Neresnitsa in the Zakarpattia region. The conclusion was issued on July 17, 2023, although the project was previously rejected in one EIA report and completely banned in another. The site has Emerald Network status.
- Clearing of the Kolomak riverbed in the village of Kolomak in the Poltava region. Permission was granted on January 2, 2025, after a previous refusal. The project involves large-scale excavation of the river channel, which is part of the Emerald Network and along which several nature reserves are located.
- Clearing the bed of the Ingulets River along a stretch of approximately 46 km in the Kirovohrad region. The project, which was approved on December 18, 2024, involves excavating a riverbed along a section with a fully preserved natural river channel. The area is protected as part of the Emerald Network.
There are other projects that have been given the green light during the full-scale war yet whose implementation completely contradicts Ukraine’s environmental legislation. In addition, most of the environmentally harmful projects approved during this period are located in areas that are part of Europe’s Emerald Network, the preservation of which is a mandatory condition for Ukraine’s accession to the European Union.
What about rare earth metals?
The issue of public access to tools for monitoring the environmental situation in Ukraine has acquired particular importance in the light of negotiations between Washington and Kyiv on giving American companies access to Ukrainian minerals. It is abundantly clear that this question is not being discussed in the context of environmental protection, and the environmental aspect is not being considered whatsoever during the talks. A significant share of these minerals are not located in “sterile” space and will not be extracted from already existing mines. On the contrary, most rare earth metals are found in natural areas with protected national and international status.
For instance, Ukraine’s beryllium deposits are located under the swamps of the Polissia Nature Reserve and the Hutsulshchyna National Park, its titanium and zirconium fields extend beneath Sviati Hory National Park, niobium and tantalum are found under the Gomolshansky Forests National Park, while thorium deposits lie beneath the Male Polissia National Park. In addition, phosphorites containing lanthanides are found under the Podilski Tovtry National Park, while the Buzkyi Gard National Park contains controversial rare earth metals and even uranium ores.
Without public monitoring, it is difficult to imagine that Ukraine will be able to simultaneously prepare for accession to the European Union (with its strict environmental standards) and provide foreign companies with access to minerals located in nature conservation areas of pan-European significance. It is obvious that some of the most valuable minerals cannot be extracted in Ukraine without destroying the most valuable nature reserves and sites of European significance.
Back in 2012, when power in Ukraine was in the hands of the former president Viktor Yanukovych and his team, the government signed shale gas contracts with Shell and Chevron, deals which were environmentally dangerous and not in Ukraine’s interest. But the Revolution of Dignity, Yanukovych’s flight and Ukraine’s subsequent democratic course of development brought these projects to a halt. Nevertheless, Ukrainians learned that harmful agreements with foreign companies for the extraction of minerals in Ukraine can be signed without consideration of environmental standards and public opinion. That lesson gives hope that history will not repeat itself this time.
Vital community monitoring significantly reduced
Opportunities for experts and community organizations to monitor and counteract environmental violations occurring away from the frontlines have become severely limited. The risks of new environmentally harmful projects have only increased.
While the full-scale invasion continues and a significant part of Ukraine has been captured by Russian troops, nature is suffering in all regions of the country, even in areas far from the frontlines. For this reason, it is important for community organizations to continue their activities and monitor environmental violations throughout Ukraine.
Given the current scale of destruction, when hundreds of thousands of Ukrainians are defending Ukraine at the front, a few cannot be permitted to quietly plunder the country’s natural heritage in the rear. It is also worth remembering that Ukraine’s recovery will also require resources, and pressure on nature conservation areas will only increase. This is already evident today, when de facto bargaining over rare earth metals and other minerals is underway even before a truce has been reached.
This author urges Ukrainian and especially foreign journalists to take an interest in events in Ukraine not only in the combat zone, but also in areas far from the frontline. It must not be forgotten that the war’s consequences extend throughout Ukraine and must be understood. Environmental damage should be minimized in all regions.
Translated by Alastair Gill
Main image source: EcoHubMap
