Blind restoration: What lessons do other countries have for Ukraine’s green recovery? – Ukraine War Environmental Consequences Work Group

Oleksiy Vasyliuk

The issue of Ukraine’s postwar recovery has shadowed military events since the first months of Russia’s full-scale invasion. And the more destruction is inflicted, the greater in scale and extent, and the longer and more costly recovery work will be.

Despite the absence of a convincing vision for when and how exactly Russia’s war on Ukraine will end, preparations for postwar recovery have been underway since the first months of the all-out invasion. Unfortunately, big business is taking the lead, concentrating immense efforts on lobbying for more beneficial conditions. In reality, this means weakening environmental norms and simplifying processes for obtaining permits and undergoing environmental assessments for projects—something that has concerned environmental experts for several years now.

Indeed, Ukraine’s business community is abuzz in anticipation of an inpouring of international aid for reconstruction and post-war investment. Ukraine itself, as a state, is clearly ill-equipped to keep track of this business activity, preoccupied as it is with achieving its defensive goals, maintaining diplomatic activity and addressing wartime operational challenges.

It will be impossible to rebuild the country without comprehensive planning, and this will require a new approach to territorial planning in Ukraine, involving thorough consideration of what exactly to rebuild, whether destroyed infrastructure and housing can be reconstructed in situ or whether it will need to be built anew elsewhere. Unfortunately, this is hindered by a lack of understanding of where, when and under what conditions the war will end. As a result, all of the excitement around recovery and the initial decisions on its implementation is somewhat premature: it is taking place long before a comprehensive vision has begun to emerge.

This kind of approach carries serious risks: important natural areas may be destroyed by the implementation of “restoration” projects in areas that have not actually been damaged, while restoration funds may be misallocated to areas in safe parts of Ukraine, meaning they may run out before areas that have actually been affected become accessible.

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Wolf in sheep’s clothing

One of the most interesting aspects of the issue of Ukraine’s postwar recovery is that it is being described exclusively as a “green recovery,” and even referred to officially as such, for example on Ukraine’s state digital services portal Diya.

Yet in reality, there is currently no central executive body in Ukraine charged with oversight of a green recovery policy. The Ministry of the Environment and Natural Resources of Ukraine played this role for a while. Since financing from the European Union was nominally contingent on compliance with the principles of the European Green Deal, this ministry should have been the key state body responsible for coordinating issues linked to funding for Ukraine’s recovery from EU countries. But in 2025 the ministry was liquidated just two weeks after a bill on green recovery was presented, and little was heard on the subject thereafter.

Tensions over the issue of postwar recovery were brewing among the environmental community as far back as July 2022, when the Ukrainian government presented a plan for the “restoration of Ukraine during and after the war” at a specially organized international conference in Lugano, Switzerland. Ruslan Strelets, then Ukraine’s minister of natural resources, identified a number of “priority” projects for Ukraine—but while ostensibly related to environmental protection, they were PR initiatives aimed solely at painting a pretty picture for foreign visitors, rather than preserving wildlife. Even at that early stage (four months after Russia’s full-scale invasion began), lists of business projects competing for the opportunity to participate in restoration funding were publicly available (for example, here and here).

None of these projects, however, have anything to do with restoring the environment after the losses sustained during the war. Most of them, in fact, are actually harmful to the environment. They include expanding natural resource extraction and facilitating access to subsoil resources, constructing a 1 million-hectare irrigation system and developing drainage systems, constructing 3.5 GW hydropower plants, and even developing the E40 waterway, a plan to link the Baltic and the Black Sea with a navigable water route, which is being actively opposed by environmentalists in at least three countries. Environmentalists, riffing on the similarity between the name of the city where the forum was held—Lugano—and the Russian-occupied Donbas city of Luhansk, branded this “restoration” project for Ukraine the “Luhansk Shame” and, alongside their European colleagues, called on senior EU officials to provide financing to Ukraine only on the condition that a number of key environmental reforms be implemented. However, their appeal fell on deaf ears.

A year later, in 2023, the Recovery Plan 2.0 on environmental security was formally unveiled at another recovery conference in London. However, the plan was never mentioned again, and its text was not even made public. Like the Lugano conference, the event was more reminiscent of a business forum than an environmental summit.

In 2024, a third conference on Ukraine’s recovery was held in Berlin. Although a large number of environmental topics featured on the program, they consisted primarily of general reports and no longer extended to detailed discussions in dedicated groups. The Ministry of the Environment and Natural Resources of Ukraine’s position on environmental recovery was limited to concerns about the forestry sector and “wildlife resources.” Nonetheless, the conference did result in the announcement of plans to create a “Platform for the Green Recovery of Ukraine.”

In 2025, the Ministry of Environmental Protection and Natural Resources was dissolved, and its functions were transferred to the new Ministry of Economy, Environment and Agriculture, a body that lacks a principled public position on many issues, including compliance with the European Green Deal in Ukraine. Curiously, the former ministry was dissolved just 10 days after the conclusion of the largest conference to date on Ukraine’s recovery, held in Rome on July 10–11. For the first time, however, environmental issues were only nominally represented, and the event itself barely featured any specialists or officials from the Ministry of Natural Resources.

Green issues aside, the government agencies chiefly tasked with Ukraine’s post-war reconstruction are those responsible for infrastructure development. From mid-December 2022 to September 2024, the Ministry for Development of Communities and Territories of Ukraine bore the title of Ministry of Reconstruction of Ukraine. During this time, the minister of Development of Communities and Territories of Ukraine simultaneously held the position of Deputy Minister of Reconstruction of Ukraine and a separate government agency, the State Agency for Reconstruction of Ukraine, reported to that minister as well. In other words, the former Ministry of Infrastructure bears full legal responsibility for Ukraine’s recovery, though under the EU’s Green Deal it should theoretically have been overseen by the Ministry of Natural Resources.

In July 2025, in cooperation with partners in Sweden, the Ministry of Natural Resources and Environment developed and submitted a draft law “On the Fundamentals of Green Recovery in Ukraine,” the primary goal of which was to ensure that the reconstruction of Ukraine would be carried out in a sustainable way. However, just a few weeks later, the ministry itself was liquidated and nominally merged with the Ministry of Economy of Ukraine. Although the word “environment” appears in the name of the new Ministry of Economy, Environment and Agriculture of Ukraine, it is primarily oriented toward economic priorities and even makes public statements declaring that it is putting those interests first. The new ministry had no interest in passing the bill on green recovery—in fact, the first bill it drew up with any connection to the environment was aimed at abolishing the vast majority of important environmental permits and assessments. This would seem to indicate that no supporters of the green recovery agenda remain in power in Ukraine.

What exactly is a ‘green recovery’?

The term “green recovery” lacks a clear definition: it was first used in specific reference to Ukraine and recovery after Russia’s full-scale invasion. Globally, a different concept is commonly used—“ecological restoration,” which refers exclusively to the restoration of ecosystems in the wake of anthropogenic impacts. The concept is regulated at UN level; the organization itself has designated 2021–2030 as the Decade on Global Ecosystem Restoration. Representatives of Ukraine should therefore take care when making statements about “green recovery,” as its international partners may interpret them to be a reference to the current UN global goals.

Global trends

In 2021, just months before the full-scale invasion of Ukraine, the International Union for Conservation of Nature (IUCN) published one of the most fundamental documents to date on the impact of armed conflict on the environment—an analytical report titled “Conflict and Conservation: Nature in a Globalized World.” The report’s authors reach a seemingly paradoxical yet crucial conclusion: the greatest threats to nature arise not during hostilities, but after they come to an end.

“… [W]aves of unconstrained development that often follow warfare quickly overwhelm any short-term reduction in pressures on nature. Natural resources such as wildlife and timber can often be the most easily available sources of revenue for reconstruction efforts, and so pressures on nature can be extremely high in post-conﬂict situations”, the document states.

The mass resettlement of people, the construction of housing and infrastructure, the restoration of agricultural, and uncontrolled use of resources within protected areas—according to the IUCN, all of these factors remain systemically underestimated in post-conflict planning.

Basing its conclusions on examples from Africa, the Middle East, Asia and Latin America, the report shows that “fast-track” restoration without due regard for biodiversity often leads to irreversible damage to ecosystems. The report is an excellent summary and also analyzes global lessons, but Ukraine is failing to capitalize on this experience, as it lacks the necessary government oversight.

Delving a little deeper into this report, its authors conclude that wars do not so much directly destroy nature as lead to the loss of a state’s capacity for effective conservation: scientists and rangers are forced to leave positions they have occupied for many years; institutions collapse; and conservationists often become victims of persecution. States themselves often cease to exist or have their borders altered. In the long term, strategic changes in institutional capacity are more destructive to conservation systems than actual military action itself. It goes without saying that events in Ukraine are not reflected in the global report. Of all the wars in the last century, World War II would appear to be the most similar to the Russian-Ukrainian War in terms of the destruction it inflicted.

Some historical examples show that war temporarily restricts human access to land and reduces pressure on nature (agriculture, the use of pesticides on arable land and forests, land reclamation, and hunting all come to a halt), which creates short-term “benefits.” However, such benefits quickly vanish after a war ends, when a wave of uncontrolled development typically begins.

Why current recovery plans are not sustainable

Certain animal groups and individual species in Ukraine are growing in number, according to observations. Satellite data shows a significant increase in the number of steppe marmots (Marmota bobak) in occupied territories. Ungulate populations have increased in all regions of Ukraine, as hunting is temporarily prohibited under martial law. And the common polecat (Vormela peregusna), a rodent-feeding species, has seen increased abundance thanks to a significant increase in its prey base (small rodents). It is clear, however, that the end of the war will lead to renewed rodent control measures in fields and populated areas, and only land that is yet to be demined and undeveloped natural areas will remain the last refuges for rare species. Furthermore, some chemicals used to control rodents can also kill the predators that feed on them. Thus species including the polecat now have a temporary window of opportunity to restore their numbers before the next “difficult period”.

Unfortunately, Ukraine lacks global assessments and environmental conservation experience in mined areas. Prior to Russia’s full-scale invasion of Ukraine, the world had no experience of working with such vast mined territories, which makes the conflict a unique historical example in terms of the impact of war on wildlife. The mining of large areas will make any meaningful environmental management (especially combating the widespread spread of invasive species) impossible for decades, and perhaps even centuries, which practically excludes not only the possibility of recovery planning but also the study and assessment of the consequences of military action.

At the same time, wildlife doesn’t wait for human decisions or take our capabilities into account, and spontaneous vegetation restoration occurs anywhere free from anthropogenic pressure, including the presence of humans themselves. In only a few cases are native plant species the main driver of restoration (the best-known example in Ukraine is the restoration of natural forests on the site of the former Kakhovka Reservoir); in the vast majority of cases, abandoned areas are overgrown with invasive species instead. This is also related to the fact that most damaged and subsequently abandoned areas are arable land and settlements, i.e., not natural ecosystems, which suffer from constant landscape fires, which, in the case of Ukraine, result in an increase in the proportion of species in pyrogenic landscapes that originate in North America. In the context of wildlife, therefore, “green recovery” in Ukraine will be limited by the physical inaccessibility of large areas of territory for both research and restoration. Unfortunately, important protected areas—national parks, nature reserves and biosphere reserves—will also count among these inaccessible areas, at least temporarily. It remains unclear for now what should be done with these potentially valuable natural sites amid a mass of abandoned and inaccessible territories. Recognizing this circumstance should be a key component of future strategy for the recovery of Ukraine.

Why the Ukrainian case is different

Empirical analysis by the IUCN has shown that areas with high biodiversity—and especially non-protected areas with concentrations of rare species—are more likely to become war zones. Protected areas, however, are statistically less likely to be the target of military action, as strategic military targets are rarely found in wilderness areas. In Ukraine, however, the fiercest fighting unfolded along the Siverskyi Donets and Dnipro river valleys, resulting in the large-scale destruction of natural areas that had a high percentage of protected areas. The lower Dnipro region, where the southern front of the Russian-Ukrainian War took shape and where active hostilities have continued for over three years, contains the largest concentration of important protected areas in the country. The Black Sea Biosphere Reserve and four national parks are located here, entirely within the war zone.

Resettlement, recovery and ‘postwar threats’

The IUCN report notes that two of the main sources of environmental problems after conflicts are mass resettlement and uncontrolled attempts at “reconstruction.” The forced displacement of millions of people leads to natural resources being overused in temporary settlements, as well as deforestation, depletion of water resources and land degradation. Examples cited in the report include an increase in consumption of water from the Yarmouk River following the mass influx of Syrian refugees into Jordan since 2011, which has led to water imbalances and social tensions.

A peculiar aspect of Ukrainian “recovery” in this context is that in many cases, resettlement from dangerous regions is not characteristic of typical refugee migration (although the scale and tragedy of this should in no way be understated), since it does not involve the establishment of refugee camps or the like. Instead, people are settling in safe regions and actively rebuilding their businesses, playing an active role in social and political life, supporting the army and volunteering. More importantly, the country is witnessing a systematic relocation of businesses, particularly agricultural producers and mining companies seeking new areas for their operations.

‘Blind restoration’

Ukraine could now, however, be threatened by a more dangerous trend that has been observed in the aftermath of other military conflicts. “Blind restoration” is a situation in which the state prioritizes the deployment of restoration funds without regard for the environmental consequences. The authors of the IUCN report note that natural ecosystems typically suffer significantly more after the end of wars than those directly affected by fighting, leading to even greater degradation than that already experienced during the war. The reason for this is simple: the scale of damaged landscapes is far greater. Roughly speaking, the area of clearcuts and quarries created as a result of intensive restoration is added to the total area of conservation zones and wilderness damaged by military action. Not only is nature itself degraded, but also the nature conservation system itself, along with environmental legislation and institutional and management systems. Legislative restrictions that are “temporarily” lifted during the “restoration” period typically remain in effect for the long term, meaning that restoration essentially becomes a process of maximizing donor funds while simultaneously lifting environmental regulations and restrictions for an extended period. In view of the current realities in Ukraine, it is almost impossible to imagine “suspended” environmental regulations being easily reinstated.

The post-war period therefore poses a serious threat to biodiversity, and the success of its recovery depends on whether the state successfully integrates an environmental component into restoration planning processes. In Ukraine’s case, however, comprehensive spatial planning is not yet even being discussed, while lists of business projects are already being approved.

Unfortunately, it is common for governments or donors to fast-track restoration efforts without considering environmental aspects or even community interests. The Restoration Opportunities Assessment Methodology (ROAM), also developed by the IUCN and focused primarily on forests, can partially counteract the “blind” approach of making environmentally significant decisions without considering the actual state of natural systems or social contexts. This methodology is quite similar to the European Environmental Impact Assessment and Strategic Environmental Assessment procedures, which allow environmental NGOs and communities to monitor projects at all stages. For now, however, most changes continue to follow the global “blind” trend in Ukraine: certain provisions of the EIA law and a ban on logging in nature reserve areas have been repealed, and the procedure for granting short-term leases to farmers has been significantly simplified. Furthermore, in 2024, the Ministry of the Environment and Natural Resources of Ukraine issued a concept note recommended derogations from SEA and EIA procedures, intended to allow certain projects (including the construction of the new Kakhovka hydropower plant and the deforestation of 90 hectares of the Emerald Network for the construction of a military cemetery) to go ahead without environmental assessments.

Why does this matter for Ukraine?

As the site of the largest military conflict of the 21st century, taking place in a European country that is actively implementing selected European environmental standards, the situation in Ukraine today is a unique opportunity to test whether the predictions made in the IUCN report are justified. Ukraine is becoming the largest example in history of a global focus on “nature in war,” with approaches to assessing the consequences of war in the context of the environment being actively created and developed.

So what lessons can Ukraine learn before fatal mistakes are made? First, there must be an understanding that war does not negate the need for environmental conservation—environmental protection must continue even in combat zones, taking human safety and the needs of ecosystems into consideration. And in the face of such large-scale threats, urgent attention to environmental protection and restrictions on any development of untouched natural areas is required. After the war ends, special attention must be paid to environmentally-oriented restoration to avoid a “second wave” of destruction, when restoration takes place without regard for environmental criteria. Such restoration, in turn, will be impossible without comprehensive planning for a new, modern vision of Ukraine.

To date, there is no indication of any centralized initiatives for a new general plan for Ukraine at state level, a plan which should be based on a coordinated system of national, regional and local planning documents. This approach is notably absent from “green recovery” plans that are more akin to a business tender. However, it does feature in the Ukraine Facility initiative. This is a €50 billion financial support program for Ukraine from the European Union for 2024–2027, which will be used to finance the state budget, stimulate investment and provide technical support for the implementation of the program. The final point of the program outlines a “green transition,” focused primarily on achieving climate neutrality goals in industry, energy and forestry.

On a more strategic level, the Ukrainian government is preparing a unified system of state documents that must be synchronized: state strategy and reforms at national level; regional development strategies and comprehensive recovery programs; and local community development plans. Spatial planning is viewed as a framework linking state programs, regional strategies and local initiatives, ensuring a balance between urbanized and natural zones and the integration of environmental and climate principles into all stages of recovery. Comprehensive regional and community recovery programs should include proposals for environmental restoration, the development of protected areas and general approaches to spatial use, taking into account urban planning regulations, environmental protection and the rational use of resources. In reality, however, planning is not based on a top-down model from a general to local scale, but is limited to individual projects and competitive bidding, with fragmented support measures focused almost exclusively on safe areas of Ukraine.

The overall conclusion is that Ukraine’s partners and donors are the most reliable guarantors that Ukraine will shift its priorities toward the European Green Deal. National taxpayer funds and the contributions of environmentally responsible donors should potentially be used only in compliance with the donors’ own “green” standards. This approach should also apply to international banks.

The role of international partners

It is clear that the World Bank, the EBRD and other international financial institutions will direct a significant portion of their funding to rebuilding Ukraine, and will therefore largely determine whether recovery plans are environmentally sound, sustainable and consistent with environmental principles.

Since the onset of the full-scale invasion, the World Bank has launched over 20 investment projects in Ukraine aimed at restoring various types of infrastructure: transport, energy, agriculture, urban development, etc. The European Investment Bank (EIB) is focusing its activities on municipal infrastructure and supporting Ukraine’s path to EU accession. The European Bank for Reconstruction and Development (EBRD) occupies a niche in promoting green investments, particularly in the municipal and corporate sectors. The World Bank also has the greatest influence over recovery policy, since it manages the finances provided by many countries through the Ukraine Relief, Recovery, Reconstruction and Reform Trust Fund (URTF), and coordinating the preparation of the annual Rapid Damage and Needs Assessment (RDNA), which oversees the allocation of recovery funds.

As the Ukrainian government, pressured by the war and lobby groups, slackens environmental assessment requirements and effectively dismantles key environmental institutions, the role of international development partners is becoming decisive in maintaining and improving environmental safeguards in strategic planning and project implementation.

The EU accession process is generally seen as the best hope for improving environmental policies and practices, but since the full-scale invasion, EU countries and European institutions have often weakened or delayed environmental requirements themselves.

The next important line of defense is the environmental and social policies and standards of leading international financial institutions. The World Bank’s approach to rebuilding Ukraine is based on its fundamental Environmental and Social Framework (ESF), which is mandatory for all Bank-financed investment projects. This framework helps borrowers manage environmental and social risks and improve development outcomes. It emphasizes a proportionate, risk-based approach, with particular attention paid to complex projects. The ESF is based on ten environmental and social standards (ESS), covering a wide range of issues essential for a sustainable recovery.

Although the ESF is applicable at any stage of the project cycle, in practice the World Bank uses it only in the later stages of planning. Consequently, key decisions—project type and location—are typically made without due consideration of environmental requirements and public participation. As a result, many strategically important aspects remain unaddressed.

For example, according to an analysis by researchers Andrii Bahinskyi and Nina Potarska, published in the journal Humanitarian Alternatives, only one of the many infrastructure projects supported by the World Bank in Ukraine explicitly takes climate resilience into account.

The EIB’s standards are closely tied to the EU legal framework, making it a key driver of Ukraine’s alignment with European environmental standards. The EBRD’s environmental and social policy focuses on supporting “green transformation” and actively engages the private sector. Yet these banks also have a tendency to leave consideration of environmental issues and engagement with stakeholders until very late in the planning process.

The most problematic aspect of international development banks’ current operations in Ukraine is that they are suspending most environmental assessment and monitoring procedures under the pretext of martial law and security concerns, thereby undermining the ability of both the Ukrainian government and the banks themselves to ensure oversight of projects. In the case of the World Bank and EBRD, this occurs even when the state-owned companies implementing the projects lack experience in complying with ESF requirements or have a negative track record of compliance. There are almost no cases of full-fledged environmental impact assessments (ESIAs) having been carried out in the World Bank’s recent investments in Ukraine. Banks also use the same arguments about martial law to justify the suspension of public consultations and public participation.

What next?

After all that Ukraine has been through, rebuilding the country seems a natural and urgent task. But historical and global experience shows clearly that it is precisely after a war that nature suffers the most. Not from explosions and fires, but from human haste—from a desire to “restore” without due consideration for what exactly should be restored and how.

Ukraine is already heading down the same path that in many countries ended in environmental degradation and losses far greater than those caused by military action. The weakening of environmental procedures, the abolition of impact assessments and the dismantling of institutions that should guarantee environmental responsibility collectively put Ukraine at risk of repeating the mistakes made by others.

The greatest responsibility today lies not only with the Ukrainian government, but also with the international financial institutions and partner countries that are funding Ukraine’s recovery. It is they who will determine what that recovery actually means—whether it will be a short-sighted process aimed primarily at securing funds or a genuine transformation toward sustainability.

The World Bank, EBRD, EIB and donor governments should be expected not just to provide funding, but also to implement specific policies for Ukraine that will exclude support for projects lacking environmental assessment, public oversight and strategic planning. Their own environmental standards should be applied not at later stages, when everything has already been decided, but from day one of the project cycle.

Ukraine, for its part, must be able to make decisions based on more than just military or economic considerations. Rebuilding the state is impossible without rebuilding environmental policy. And until Ukraine has an effective environmental ministry, responsibility for upholding environmental principles must fall on the donors, international banks and civil society organizations that have the right to demand it.

The solution to “blind restoration” is not more money, but more time, caution and honesty. After all, genuine restoration is not a return to the status quo. It is a chance to build a system in which nature will no longer be the victim of any crisis—even war.

Translated by Alastair Gill

Main image source: dream.gov.ua