Hydroenergy development program until 2026, approved by the government on July 13, 2016, poses serious risks to the environment, especially the Dnister River. In addition, it was adopted in a very non-transparent way and in violation of regulations. This was stressed by experts-environmentalists at a press briefing held at Ukraine Crisis Media Center. “This program is extremely dangerous to water resources, the main resource of our planet. We encourage the government to impose a moratorium on its implementation, and secondly, to conduct an expert discussion about the development of this industry both among environmentalists and energy workers,” said Ruslan Havryliuk, member of the Council, National Ecological Center of Ukraine.
Procedural violations
Ruslan Havryliuk noted that such programs involve developing the concept, its expert and public discussion and approval of the government first and only then a program may be created on this basis. This was not done. “The draft program was not published on the website, the public was not involved, and most importantly, there was no environmental assessment. It’s a violation of the procedure for the adoption of such projects and a violation of our right to participate in decision-making. We were able to analyze the text of the program only after its adoption,” said Marta Pankevych, legal advisor to the International charity organization “Ecology-Human-Law”. The program violates some international environmental commitments of Ukraine, including under the Association Agreement.
“[Regarding risks to the environment] the main thesis of project implementers is that they still do not know anything, but plan to spend tens if not hundreds of million on a feasibility study and then find out the possible consequences,” said Ostap Yednak, MP (independent).
The protest of local authorities and expert institutions on the construction of hydropower plants in the upper reaches of the Dnister was ignored. “The appeals to regional councils and administrations get a formal reply saying ‘we will consider your proposals, but we decided to build’,” noted Petro Tiestov, ecologist of the International charity organization “Ecology-Human-Law”. “And despite the fact that there are official findings of the National Park “Dnister Canyon”, Institute of Ecology of the Carpathians, Ivano-Frankivsk University of Oil and Gas – scientists working in the region, at a recent round table in the Parliament Ukrhydroenergo stated that these were wrong conclusions.”
Environmental risks
The program involves the construction of “hydromonsters”, which in Soviet times were rejected because they were too dangerous. Ruslan Havryliuk noted that today the Ukrainian rivers are too congested with dams, which almost violates the Water Code of Ukraine. Under these conditions, the normal functioning of river ecosystem is impossible. “The dam of Olexandrivka Reservoir of Tashlyk PSPS prevented sturgeons from migrating along the Buh, and we lost the last living river in its lower course,” he reminded. It would be appropriate to find a way to restore natural riverbeds because further construction of dams can result in lowering the water level, worsening water quality and mortality of some fish species. This even endangers the water supply for the population, because about 70% of the population consumes water from surface sources.
The main argument of energy experts is that large pumped storage units are needed to regulate the system. However, it would be appropriate to focus on more environmentally friendly green energy.
Construction of new hydropower plants in the upper course of the Dnister affects the interests of not only Ukraine, but also Moldova. “We are very offended by the fact that though the Dnister is the cross-border river, the Ukrainian government did not consider it necessary to consult experts before the adoption of this program. This contradicts the principles of the Espoo Convention and the principles of the strategic environmental impact assessment. European countries should not do so,” noted Illia Tombitskyi, director of the International association of Dnister river keepers. He noted that the Dnister is very special for Europe in terms of biodiversity and landscape diversity. That is why Moldova would like to keep it at least just as it is.
Negligence or corruption cover-up?
The experts suspect that the interests of construction companies may be behind the ultra-fast and non-transparent decision-making. “The quick adoption of some unclear document by the Cabinet of Ministries has violated internal regulations, environmental legislation and international conventions. Perhaps, some of them explain this by the fact that construction of such major infrastructure projects is linked to the multibillion injections and loans received from international financial institutions,” noted Ostap Yednak. The mere development of the HPP construction project in the upper course of the Dnister costs 155 million UAH.
“Formally, most hydroenergy subjects are operated by the state company ‘Ukrhidroenergo’, while most design works for them are conducted by private organization ‘Ukrhidrotekhproekt’ in Kharkiv and the consortium ‘Ukrhidroenergobud’ in Kyiv. In fact, the hydroenergy development program is a program of earnings for ‘Ukrhidroenergo’ and two private companies,” informed Petro Tiestov. According to him, this future construction has been already included in the investment component of the electricity tariffs.
Strategic decisions should be made transparently
Serhii Vykhryst, expert of EU Project, emphasized that it is necessary to change the situation where important strategic decisions become known to the public post factum when nothing can be changed. In such cases both public participation and environmental assessment should be real processes affecting the final decision and not a formality. The public should become aware of any such projects and decisions in advance.
Ostap Yednak noted that due to the procedural violations, the program can be put on hold by court. He added that MPs again have registered the draft law on strategic environmental assessment of similar programs in the Verkhovna Rada. This will help avoid similar cases in the future. Last time it was vetoed by the President. “I hope that we will adopt it in the coming weeks, and the President will stand on the side of the public and environment,” noted Ostap Yednak.