The merger of the Ministry of Environmental Protection and Natural Resources of Ukraine, the Ministry of Economy and the Ministry of Agrarian Policy and Food into the new Ministry of Resources will be an institutional disaster for the environment, national security and the state's strategic course towards European integration.
This was emphasised by more than 20 civil society organisations in a joint statement posted on Facebook. They called for comments to join the statement. It now has more than 200 additional signatories: representatives of environmental organisations, scientists, lawyers, and active citizens.
The activists believe that the Ministry of Environmental Protection should be a key government agency that serves as an ‘independent regulator, controller, and representative of environmental and public health interests’.
‘Integrating this ministry into a structure that is simultaneously responsible for the economy, agricultural policy and environmental protection means levelling environmental priorities and a constant conflict of interest at the very centre of decision-making,’ they warned.
The main warning
The NGOs are particularly concerned about the prospect of considering natural resources solely through the prism of economic or agricultural expediency. They reasonably believe that combining the management of such resources with economic or agricultural interests can lead to a loss of control over their conservation. Therefore, environmental protection issues risk becoming less of a priority compared to profit and production.
‘Under such conditions, natural resources are beginning to be seen as a tool for achieving economic goals, which contradicts the very essence of environmental protection,’ the activists say.
A step backwards
Representatives of environmental organisations believe that the planned merger of the ministries is a regressive trend. They cited the following arguments to justify this assessment:
1. To integrate environmental policy into all areas of public administration, which is a requirement of national and European legislation, Ukraine needs a strong, independent, professional ministry with adequate institutional capacity.
2. The challenges posed by a full-scale war require strengthening rather than reducing environmental institutions and ensuring their sustainability.
3. Ukraine has committed to adopt and implement EU environmental legislation. The Habitats and Birds Directives, the Water Framework Directive, regulation of industrial emissions, waste management, climate change, etc. all require clear environmental governance.
4. Environmental protection should not be subordinated to bodies or structures whose priority is economic or agricultural development, as in such a configuration, in practice, priority is always given to economic expediency rather than nature conservation.
The activists stressed that, according to EU law, the environmental protection system is equivalent to the economic sector in the structure of public administration and cannot be weakened or simplified through deregulation.
5. A separate environmental ministry should not only protect nature, but also act as a guarantor of the constitutional right of citizens to a safe environment.
‘This right, enshrined in Articles 16 and 50 of the Constitution of Ukraine, cannot be cancelled for the sake of “optimisation” or managerial populism,’ the environmentalists stressed.
6. In the period of post-war recovery, Ukraine cannot risk the trust of international partners and donors, as international assistance depends on transparency, professionalism and accountability of institutions. According to experts, the merger of the Ministry of Ecology with other agencies could undermine this trust and call into question the effectiveness of environmental policy.
7. CSO representatives also recalled the unsuccessful previous experience of merging the Ministry of Ecology with the Ministry of Energy, which resulted in the environmental sector being set back in environmental reforms by 9 months.
Therefore, civil society representatives called on the Cabinet of Ministers of Ukraine to abandon plans to liquidate the Ministry of Environment and ensure its institutional independence. They also appealed to the President of Ukraine to publicly support the preservation of a separate Ministry of Environmental Protection and Natural Resources of Ukraine as a critical institution on Ukraine's path to the EU and future sustainable development.
"Nature has no political orientation, social status or military rank. It is the basis of our life. Anyone who ignores its protection endangers the future of themselves, their children and our country," the activists summed up.
Recently, EcoPolitic reported that the Ministry of Environment, the Ministry of Economy and the Ministry of Agrarian Policy and Food will be merged into a new Ministry of Resources under the leadership of Oleksiy Sobolev, who is currently the First Deputy Minister of Economy.
