|March 14, 2018, Kyiv||Ukrainian version|
ON THE REVISION OF THE GOVERNMENTAL POLICY
IN THE HYDROPOWER SECTOR
to Volodymyr Groysman, the Prime Minister of СMU of Ukraine
from the Working Group 3 of Ukrainian National Platform of the Eastern Partnership Civil Society Forum
(WG-3 UNP EaP CSF)
and the Working Group 5 of EU-UA Civil Society Platform (WG-5 EU-UA CSP)
Dear Mr. Prime Minister
We, the members of WG-3 UNP EaP CSF and WG-5 EU-UA CSP, request You to suspend the implementation of the State Program of Hydropower Development Until 2026, approved by the CMU Resolution on July 13, 2016, No. 552-p (hereinafter – the Program).
We request to carry out a national public hearing on the feasibility of this program in compliance with Ukrainian legislation.
This appeal is caused by:
- a rush approval of the Program without the consent of the Ministry of Ecology and Natural Resources of Ukraine and consultations with the public of Ukraine;
- triggered by this Program, wave of protests of scientists and the environmentally concerned public, inter alia local communities, expected to be heavily affected by inevitable forced displacement of people;
- intentional ignoring by the Program developers of climate change problems, globally rising threats of drinking water shortages, obvious losses of valuable nature-protected areas, arable lands, objects of historical and cultural heritage of Ukraine, and the need to resettle the local population.
The projects, provisioned in this Program, cause particular concern for society of Ukraine, namely:
- a cascade of 6 hydropower stations on the Dniester River that will result the irreversible loss of the unique canyon of the river in its natural state; flooding the objects of the Nature Reserve Fund of Ukraine and settlements, thus causing irreparable damage to the tourist and recreational potential of the region; transboundary impact on the territory of the Republic Moldova by decreased river flow;
- If built on geologically unstable deposits, the planned Kaniv Pumped-storage hydropower station (PSHPS) will create a permanent threat of the large-scale technogenic disaster. The impact of this station on re-sedimentation and migratory mobility of radionuclide contaminated sediments will cause the irreversible damage to the unique objects of the Nature Reserve Fund – «Trakhtemirovsky regional landscape park» and «Zmiinyi islands»;
- completion of the construction of the Tashlyk Pumping Hydropower Station, accompanied by elevation of water level to a mark +20,7 m, in the Oleksandrivsky reservoir on the river Pivdeniy Bug, will mean the destruction of the unique cultural-historical heritage of the Cossack era; the flooding of the Bug rapids and the territory of the Nature Reserve Fund of Ukraine; the increase of irreversible water losses, water; irreparable impact on the ichthyofauna, etc.
The Program contradicts the state policy of Ukraine aimed at the European integration and disregards Ukraine’s commitments under the Association Agreement with the EU in the harmonization of the Ukrainian legislation with energy and environmental legislation of European Union.
The program has not undergone a Strategic Environmental Assessment, consultation with environmental authorities, exchange of information with neighbouring countries (Directive 2001/42/EU); public access to environmental information has not been not ensured (Directive 2003/4/EU). Public informing and public consultation have not been held (Directive 2003/35/EU); the river basin conditions and the basin water management principles (Directive 2000/60/EU) have not been taken into account. No consultations have been held with the Republic of Moldova about implementation of the Program that violates the Kiev Protocol on Strategic Environmental Assessment to Espoo Convention.
Implementation of the Program will complicate compliance with standards for drinking water from surface sources (Directive 98/83/EU); will lead to the destruction of natural habitats of wild birds (Directive 2009/147/EU); will cause the destruction of the natural riverbeds, which are the natural corridors of the migration of wildlife and birds, as well as the habitat of their existence (Directive 92/43/EU).
In connection with the above, we would like to draw your attention to the transition of hydropower generation to the principles of balanced development at the international level. In particular, the International Hydropower Association has developed a document: the Protocol for Assessing the Sustainable Development of Hydropower, which is used in many countries around the world and aimed at improving the quality of hydropower projects.
Adoption and implementation of the Protocol in Ukraine can become an important tool for an objective assessment of hydropower projects and decision-making on their construction. The application of the Protocol will promote the publicity and transparency in hydropower development, accelerate the approach to European standards in Ukraine, increase the level of trust of civil society to decision making, establish constructive dialogue between the Government and the public, thus making possible comparison of national projects with projects, implemented by member-states of the European Union and assimilation of best practices. Application of the Protocol will create a favourable investment climate in hydropower sector; will open the possibility of attracting funds from world financial institutions, provisioned in the Hydropower Development Program, without which it is impossible to implement any large-scale project in the current economic conditions of Ukraine.
We request the Ministry of Fuel and Energy of Ukraine with the involvement of the Ministry Ecology and Natural Resources of Ukraine to ensure the preparation of a new version of the Hydropower Development Program Until 2026, based on the methodology set forth in the Protocol, and to hold a nation-wide public consultations and the Strategic Environmental Assessment of the revised Program.
The experts of the Platform are ready to extend a consultative support on the application of the Protocol.
This appeal is supported by the resolutions (see attached) of seminars that presents public opinions about the Program in Kyiv, Chernivtsi and Mykolayiv, carried out in the framework of the project «Hydropower Development in Ukraine – Public Analysis in the Context of European Integration Processes», which is being implemented by the National Ecological Centre of Ukraine under the auspices of the Ukrainian party of the Civil Platform the Ukraine-EU community and the Ukrainian National Platform for the Eastern Partnership Forum
Ukrainian National Platform for the Eastern Partnership Forum, funded by the European Union and the International Renaissance Foundation in frame program «Public Synergy”.
|Coordinator of the Working Group № 3 UNP EaP CSF
|Coordinator of the Working Group № 5 EU-UA CSP