Flawed legislation contains a loophole that allows local communities to use environmental tax funds for measures that are only nominally environmental. In the Lviv region, they are also taking advantage of this “golden ticket.” Landscaping instead of urban improvement becomes environmental protection, just as the maintenance of sewer systems or garbage collection suddenly “falls outside” the scope of housing and communal services.
EcoPolitic analyzed several environmental programs from this region and invites readers to find out how Lviv Oblast spends the funds collected from polluting enterprises.
A brief overview of the environmental tax
The environmental tax is a kind of penalty for environmental pollution, paid by businesses for their emissions into the air, water, and soil. These funds are distributed among environmental protection funds at various levels: 45% to the state fund, 30% to the regional fund, and 25% to local funds.
Lviv region cannot boast of significant environmental tax revenues. During 2025, its business entities paid UAH 52.2 million of this tax to the state fund. Slightly more was distributed among the regional and local ONPS funds.
Based on the results of the first seven months of 2025, the largest taxpayers were:
- JSC “DTEK Zakhidenergo” – UAH 44.4 million;
- Lvivvodokanal Municipal Enterprise – UAH 31.2 million;
- Lvivteploenergo Municipal Enterprise – UAH 7.5 million.
Environmental tax funds can be used exclusively for environmental protection measures. However, Cabinet of Ministers resolution No. 1147 from way back in 1996 gave communities quite a broad field for interpreting what is “environmental.”
Environmental protection at the regional level
To find out what the Lviv regional authorities consider environmental measures, EcoPolitic studied the passport for the environmental protection program for 2021–2027.
Is it possible to find measures here related to the reconstruction of sewer engineering networks and waste management? Of course. Note that these are described only in general terms. This is an important distinction from the eco-programs of most other regions previously analyzed by EcoPolitika, where you could usually see specific facility names and even installations slated for reconstruction.
Here, we just see such items as:
- construction, reconstruction, and arrangement of solid household waste landfills; implementation of measures for minimizing, utilizing, and recycling industrial, household, and hazardous waste;
- construction, reconstruction of wastewater treatment facilities, separate sewer systems, sewer networks, and structures associated with them;
- land reclamation of disturbed areas and territories of solid household waste landfills.
One of the funding sources for these measures is the environmental protection fund.
It is also worth noting that the environmental program of the Lviv region provides for the development and preservation of nature reserves, environmental education and awareness, and the development of air quality monitoring systems.
Eco-program of the regional center
Lviv’s environmental protection measures are outlined in the Comprehensive Environmental Program for 2024–2028. Funding sources include the budget of the Lviv City Community, as well as funds from other permissible sources. So, what does the city have planned?
Most of the measures are undeniably ecological in focus, though their "paper" expression ranges from passporting water bodies to creating a geospatial map on the open data portal. The wording of certain measures appears somewhat abstract, such as “Implementation of other measures in accordance with the annual priority funding plan” found in various sections of the program.
In Lviv’s eco-program, works related to the sewerage networks were ultimately not included, however, greening initiatives and waste management were not overlooked. Regarding waste, the corresponding section is mainly about hazardous waste requiring special handling. Nevertheless, the eco-program includes funding for a waste management system within the city community, as well as “other measures.”
Several landscaping initiatives have also been included in the eco-program under the heading “Maintenance of Green Spaces.” These involve the classic planting of saplings, flowerbed maintenance, removal of dead wood, as well as drafting projects for the maintenance and reconstruction of parks and squares.
Surprisingly, maintaining a land cadastre for Lviv is classified as an environmental measure. Similarly, installing bird protection on historical buildings is considered such a measure, even though, formally, this is the protection of architectural monuments.
Perceptions of ecology in smaller communities
In Velyki Mosty, the eco-program for 2025 was modest in size but consisted entirely of contentious measures. There was nothing listed apart from sewage and waste management, and there was no further detail provided for these activities.
Thus, within the framework of its Environmental Protection Action Program for 2025, the city planned to:
- construct, repair, or reconstruct treatment facilities, separate sewerage systems, and sewer networks in order to improve the condition of local rivers;
- arrange solid municipal waste landfills with reconstruction efforts and undertake reclamation of landfill sites.
Funds for these measures in Velyki Mosty were expected to come from specialized environmental protection funds – state, regional, and municipal.
In its list of environmental protection measures for 2025–2027, the Busk Urban Community referenced the government decree from 1996 for nearly every action. This decree serves as a basis for procuring waste containers and specialized vehicles for transporting household waste.
Other measures include extracurricular environmental education and the installation of pathways in the local park, which is recognized as an example of landscape garden art. To give this landscaping activity greater significance, its purpose was expressly stated as “preservation of the natural ecological system.”
Рreviously, EcoPolitic has already reviewed environmental programs in the Kirovohrad, Zaporizhia, Poltava, Odesa, Vinnytsia, Rivne, Zhytomyr, Ivano-Frankivsk, Cherkasy and other regions.
