The Ministry of Environmental Protection and Natural Resources of Ukraine refuses to issue a license for hazardous waste management on grounds that did not exist under Ruslan Strilts's leadership. The date of the last license issued by the Ministry is August 28, 2024.
The PAEW Association of Environmental Professionals was outraged by this fact.
Experts said that among the reasons for the refusal to issue a permit in the field of hazardous waste management by the Ministry of Environment, in particular, was “the incompatibility of the terminology of waste management operations and waste management specified in the conclusions of the state environmental assessment and conclusions on environmental impact assessment (EIA) received before 09.07.2022, as well as the list of wastes of the State Waste Classifier and the National Waste List”. The same reason can be a justification for not granting a permit for waste treatment, PAEW says.
Environmentalists reminded the ministry officials that on July 14, 2023, to simplify the definition of waste classes and the transition to a new classification procedure, the Ministry of Ecology prepared a table with an approximate ratio of waste codes DK 005-96 and a draft National Waste List.
“That is, the issue of “incompatibility” between the list of wastes of the State Waste Classifier, approved and put into effect by the Order of the State Standard of Ukraine dated 29.02.1996 No. 89, and the National Waste List, approved by the Resolution of the Cabinet of Ministers of Ukraine dated 20.10.2023 No. 1102, was resolved by the Ministry of Environment,” the experts state.
Therefore, they speak of different interpretations of legislative norms by the past and current leadership of the Ministry.
PAEW experts had several questions about the current licensees:
- How did the entities obtain licenses based on the conclusions of the state environmental expertise and EIA conclusions received before 09.07.2022?
- How do the waste codes, names of operations specified in the conclusions of the state environmental assessment and EIA conclusions obtained before 09.07.2022 of the current licensees relate to the Law of Ukraine “On Waste Management”?
- Is the information contained in the conclusions of the state environmental assessment and EIA conclusions obtained before 09.07.2022 of the current licensees unreliable? Is this a ground for license revocation?
- What is the status of licensees who did not receive a permit for waste treatment operations after October 09, 2024?
- If the National Waste List is revised every three years, do entities need to undergo another EIA?
Experts noted that each market operator essentially has the same facility and the same technological process, “the essence of which will not change by rewriting their name.”
“So what is the Ministry of Environment doing during the war, how long will each successive minister shift the blame for violating the law to their predecessors, and who will break this vicious circle?” they ask.
The Association of Environmental Professionals has already drawn the attention of the Ministry of Ecology to the illegality of the requirements for potential recipients of hazardous waste management licenses and waste treatment permits. Read more about why it is illegal to require existing companies to undergo an EIA to obtain new permits in our article.
