Public hearings without the public, payment for discussions and experts without discussions and experts, conclusions without verification of their implementation. As it turned out, despite the availability of tools for implementing transparent environmental impact assessment (EIA) and strategic environmental assessment (SEA) procedures, these processes are not very effective in practice.
The Professional Association of Environmentalists (PAEW) analyzed the report "Environmental Impact Assessment and Strategic Environmental Assessment – Towards a Green Transition" conducted by the Accounting Chamber of Ukraine.
"Ukraine has established an adequate legal and institutional framework for EIA and SEA and has made significant progress in bringing national legislation into line with European standards, but has not ensured the proper implementation of these standards," the organization summarizes.
Registers not adapted for analytics
The unified EIA and SEA registers formally serve as open sources of environmental information, but in fact remain only data repositories. They do not have the tools to analyze the collected information, combine it with other state databases, or work with it in analytical mode.
Users are unable to quickly filter, systematize, or export data by territory, stage of procedure, or type of activity.
A separate problem is the lack of an option to download post-project monitoring (PPM) reports, which significantly limits public access to the full environmental picture.
As a result, such registries do not ensure either real transparency of processes or effective use of information for analysis and decision-making.
Low public engagement
Currently, public discussions are not a real tool for Ukrainians' participation in environmental processes. Audit results have revealed the following trends:
- there are usually very few participants in discussions-up to ten people, and only if they show up at all. In 80% of public hearings, records were drawn up noting the absence of community representatives;
- no people means no comments. Overall, suggestions regarding the procedure are rarely submitted.
Therefore, the report emphasizes the lack of effective discussion with communities, even though the EIA system does provide for their involvement.
The PAEW does not entirely agree with this. The organization states that such minimal public engagement does not meet the level required by law. At the same time, the reason lies not with the people.
“Low public activity – this is not a problem of the citizens but an indicator of poor communication and a lack of trust in the procedures. Genuine engagement starts where the public sees a link between their participation and real decisions,” the expert community writes.
Unjustified expenses for discussions and experts
In just a year and a half (2024–Q1 2025), the state received UAH 216.6 million for conducting public discussions. Of this amount, UAH 93.4 million (45.8%) was used by authorized territorial bodies. It is noteworthy that most of the funds were spent not on expert opinions, but on organizational costs for holding the hearings.
There is an important nuance: during a full-scale war, discussions take place online. This did not affect the cost paid by business entities, although video conferencing is cheaper in terms of organizational costs than a live meeting with the community.
Here is the structure of the costs of public discussions using the example of a second-category public discussion. This refers to activities whose impact does not extend beyond the region.
The total cost is UAH 15,900. It consists of payments for the following activities:
- 6,300 UAH (39.7%) – expert services for the EIA;
- 4,300 UAH (27%) – other direct costs. This includes document archiving, business travel, and electronic media;
- 3,400 UAH (21.4%) – organization and holding of public hearings. This covers expenses for premises rental, multimedia equipment, report and protocol preparation;
- 1,400 UAH (8.8%) – information support. This category includes paper and office supplies, document copying and mailing;
- 500 UAH (3.1%) – indirect expenses. This refers to utilities, internet, and facility maintenance.
Expert services account for the largest share, though their actual provision is rather questionable. By law, the Ministry of Economy and authorized bodies may establish expert commissions for the EIA procedure. These experts may be appointed from the official register that the Ministry of Economy is required to maintain.
The report found that neither an expert register nor advisory boards based on it were created during the reporting period.
“In fact, under martial law, business entities pay over 70% more for holding public hearings (as shown by the cost of public hearings of the second category) than the expenses incurred by the Ministry or the authorized territorial body for their organization,” – emphasizes PAEW.
Monitoring – Formal or Absent
According to the report, the procedures do not allow determination of whether the conclusions of the EIA and SEA had any impact on the environment. The reason lies in the inefficiency of monitoring the enforcement of these conclusions.
Only a small number of businesses reported the results of post-project EIA monitoring. The same situation applies to the monitoring of the SEA procedure – executive authorities, as SEA program clients, simply do not publish them.
EcoPolitic previously reported that bypassing legal procedures, the government plans to cancel the EIA for clear sanitary logging. The National Agency on Corruption Prevention (NACP) has already identified potential corruption risks in the text of the document.
