Discussion of the "blind" TV broadcast: what (wasn't) shown to stakeholders

Discussion of the "blind" TV broadcast: what (wasn't) shown to stakeholders Shutterstock
Hanna Velyka

The business community and environmental groups are still waiting for the bill to be made public

On April 16, the Ministry of Economy, Environment, and Agriculture of Ukraine organized another meeting with stakeholders and the public, during which it promised to discuss the approaches and key parameters of the National Greenhouse Gas Emission Trading System (NGGETS).

EcoPolitiс journalists attended the event and gathered participants’ impressions afterward. Despite the fact that this topic is of great interest to industrialists and has generated significant attention both in the business community and among experts, there was very little feedback following the meeting.

The draft law that was never presented

In our opinion, the main reason for the low engagement among experts was that none of the stakeholders had actually seen the prepared draft Law of Ukraine “On the Principles of Operation of the National Greenhouse Gas Emission Allowance Trading System” at the time of the meeting. It simply hadn’t been made public yet, so the experts were unable to provide an assessment.

During the meeting, officials promised to do so “any day now” after coordinating with the ministry’s legal department. As of the morning of April 22, the document is still not available on the Ministry of Economy’s website. Perhaps the ministry’s legal team had many questions about the draft law, and it will be published retroactively later, as has happened before.

What was discussed

The main speaker was Bohdan Semenenko, Head of the Department of Environmental Protection and Industrial Pollution Prevention at the Ministry of Economy. Active interaction also came from Oleksandr Krasnolutskyi, Deputy Minister of Economy, Environment and Agriculture, and Oleh Bondarenko, Head of the Verkhovna Rada Committee on Environmental Policy and Nature Management.

Despite the absence of the draft law text in the public domain, this meeting can hardly be called a waste of time:

  1. Those present were shown a brief overview video on the main principles and parameters of the future NGGETS. However, only those who attended the meeting offline were able to fully watch it. Due to a technical flaw, participants who joined via Zoom could not hear the audio. The images in the video changed very quickly, so it was very difficult even to grasp the essence. The Ministry of Economy promised to publish the video on its website – we are still waiting.
  2. Those present were acquainted with a list of eight comments from the Federation of Employers of Ukraine (FEU) that had been submitted to the ministry. Seven of them were accepted, and one was rejected.
  3. The ministry clarified the timeframe in which it plans to submit the draft law to parliament.
  4. Particular attention was given to the highly relevant CBAM issue: officials reported on the steps the Ukrainian authorities have already taken and still plan to take to assist domestic businesses whose goods fall under this mechanism.
  5. Stakeholders were able to ask questions regarding one of the most problematic aspects – funding for decarbonisation measures. Officials described a mechanism provided in the draft law under which enterprises will be able to allocate 90% of their financial commitments within NGGETS to their own eco-modernisation projects.

According to the Ministry of Economy, the event’s outcome was that “further steps for the implementation of the National Emissions Trading System (NETS) were discussed.” This is accurate. However, the claim that “participants considered the key aspects of shaping the system, in particular the draft Law of Ukraine 'On the Fundamentals of Functioning of the National System for Trading Greenhouse Gas Emission Allowances,'” is not correct. Here, officials presented wishful thinking as reality because there was only a brief video presentation instead of the actual document, which cannot substitute for familiarization with over 130 pages of the draft law.

Participants’ impressions

We thoroughly monitored the social media pages of experts and stakeholders. Indeed, feedback is scarce. For example, Olga Kulyk, Director of the Ecology, Energy, and Green Economy Department at the Federation of Employers of Ukraine (FEU), noted that representatives of the Ministry presented the key features of the NETS reflected in the draft law, as well as the timeline for implementing the system.

“One of the important and sensitive aspects of implementing this system is ensuring real funding for projects to be carried out by Ukrainian companies to reduce greenhouse gas emissions,” she emphasized.

The expert also noted that officials did not overlook the issue of CBAM.

Active meeting participant, Member of Parliament Serhii Mahera, also declared his involvement in the process of NETS implementation. He considers it crucial not to wait for EU accession, but to build a national system now that will be compatible with the European one from the start.

“The entire logic should change: the funds collected should not simply go to the state budget, but be returned to enterprises for specific modernization projects and emissions reduction. So, this is not about punishment, but about investment in renewal,” the parliamentarian is convinced.

Meanwhile, Liudmyla Tsyhanok, President of the Professional Association of Environmentalists of Ukraine (PAEW), began her post with the main point:
“We are waiting for the publication of the draft Law of Ukraine 'On the Fundamentals of Functioning of the National System for Trading Greenhouse Gas Emission Allowances',” she wrote.
The expert also highlighted the financial aspect of the draft law. She expressed hope that NETS will not be constructed merely as a fiscal tool without a clear connection between carbon fee revenue and financing the decarbonization of payers, as in such a case, according to Liudmyla Tsyhanok, Ukraine risks imposing a double burden on businesses.
The expert called for preventing a situation where businesses will pay yet will lack access to capital for decarbonization. She warned that, with such a configuration, the system would not deliver any real environmental effect.
“The principle of targeted use of carbon revenues for decarbonizing payers is not a matter of policy design but a fundamental condition for its effectiveness,” the PAEW president is convinced.
The question of whether to introduce an emissions trading system for greenhouse gases in Ukraine has long been irrelevant – this is a binding commitment of our country to the European Union.
The main challenge, given the war, CBAM pressure, and the risk of losing markets, is to design the system so that it simultaneously promotes environmental goals, protects domestic producers, and ensures long-term economic resilience. That is why, together with other stakeholders, we are waiting for the text of the draft law to be published for public discussion.
Earlier, EcoPolitic reported that the Ministry of Economy announced the readiness of the draft Law on the National ETS.
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