For several months, the speed of obtaining integrated environmental permits (IEPs) may be slower due to the transfer of powers from the liquidated Ministry of Environmental Protection and Natural Resources of Ukraine to the merged Ministry of Economy.
This was stated in a comment to EcoPolitic by Andriy Gunko, coordinator of the project "Best Available Technologies and Management Methods (BAT/BAM) for Ukraine," which is being implemented by GIZ on behalf of the German government.
According to the expert, the reorganization of structural units, the reassignment of officials, and the transfer and unification of document management and electronic services systems, which are currently underway at the Ministry of Economy, could potentially affect the speed of the IEPs procedure. However, these factors should lose their relevance in a few months.
According to Andriy Gunko, operators of existing facilities should start planning their transition to IEPs now to avoid complications. He warned that in the last of the three years provided for by law, when all operators will simultaneously begin to submit applications, there will indeed be a risk of not meeting the deadline, as the licensing authority may be overloaded.
“At the same time, since the permitting procedure is new to all participants, the first operators to submit applications may receive more attention and support from the permitting authority with regard to the statutory consultations,” the expert emphasized.
Andrii Hunko believes that, in terms of the deadlines specified by law, delays should not occur. He cited several arguments to support his opinion:
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the procedure for obtaining an IEP is well known and has been proven in EU countries;
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it is effectively integrated into Ukrainian legislation and is consistent with the principles of Directive 2010/75/EU;
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the text of the law and subordinate acts have undergone thorough examination during interdepartmental coordination, public hearings, and consultations with businesses;
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the new legislation contains no logical contradictions, inaccuracies, or ambiguous interpretations;
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the BAT project, together with the Ministry of Economy and competent authorities, conducted a series of training sessions for business representatives, civil servants, and the public on implementing the IEP issuance procedure regarding application form completion, application submission, use of the IT system, legislative foundations, international experience, and best modernization practices in accordance with BAT.
The expert also reported that a new module of the “EcoSystem” online platform, through which the IEP procedure will be implemented, is currently being finalized.
“Currently, some parts of the module are still in the final stages of development (for example, permit form generation), but they will be implemented shortly, before the procedure for obtaining IEPs reaches its final stages,” he assured.
We would like to remind you that EcoPolitic previously published an article by another expert, Vladislav Antipov, CEO of the Center for Ecology and New Technologies Development (CEN), about the difficulties and pitfalls that companies may encounter when obtaining integrated permits. In it, the expert provided detailed explanations of both the procedure and the time required to prepare high-quality documentation for obtaining an IDD.
