EcoPolitic analyzed the ex-minister's farewell post on Facebook, in which he listed his own achievements during his tenure. The official's text is very long, so we focused our attention on those peripheral reforms that must be implemented for Ukraine to join the European Union.
1. Waste management reform
What does the minister write?
"We have launched a waste management reform." And lists the following achievements in detail:
- laid the foundation for the creation of a modern garbage processing infrastructure in Ukraine.
- agreements with investors.
- a new market for hazardous waste management has been formed.
What is the real situation
Yes, indeed, in the Ministry of Environment made up the plan for placing new waste processing plants in Ukraine, which includes several priority projects, but Ruslan Strilets, presenting the developed plan, did not provide any information about the availability of investors. Therefore, their existence remains in question.
And about "the formed new market of hazardous waste management" is a complete mockery. About the impending collapse in this sector, experts in the environmental sphere and business are simple cried out to the ministry last year.
Due to the inconsistency of the actions of the Cabinet of Ministers and the Ministry of Environment with the requirements of Law No. 2320-IX "On Waste Management" as of January 9, 2024, there was no none licensed company, and businesses and medical institutions could not legally dispose of this type of waste.
Currently, licenses for the management of hazardous waste are issued by the Ministry extremely slowly. EcoPolitic calculated that at such rates as now, this the process will be delayed for another 5 (!) years.
In addition, specialists stated, that 90% of the norms of the waste law are dead.
2. Course on climate neutrality
What does the minister write?
"A new Ukrainian climate track has been launched – not in words, but with concrete actions and results." Among the results he names:
- the presence of pavilions (!) at international climate conferences, attracting the attention of hundreds of international partners. And isn't this a routine day-to-day job, which is a little incorrect to present as an achievement?
- signed declarations and agreements, negotiations and agreements. In our subjective opinion, declarations and negotiations in themselves are not yet a real result.
- fully prepared projects of the main climate law of Ukraine and the Strategy for the implementation of state policy in the field of climate change.
- "developed climate architecture" – to be honest, they did not understand at all what Mr. StrIlets means by this wording.
- steps have been taken to be a participant in the carbon market and the foundation has been prepared so that next year the emissions trading system will be operational in Ukraine in pilot mode.
What is the real situation
Yes, indeed, July 16 deputies approved the draft Law on the Basics of State Climate Policy, the adoption of which is provided for in the Ukraine Facility Plan. Regarding the Strategy, it is also true: its project is for the period until 2035 already approved by the government
But all other points have very general wording and do not contain any specifics. That is, the minister is boasting about prepared papers, and not real visible results that can be evaluated by KPI. Apparently, in the eyes of bureaucrats, this is the only real achievement – new strategies, concepts, road maps that no one needs.
It is worth saying that specialized specialists and public activists also reproached Ruslan Strilets for the complete lack of a plan of real steps to implement the strategies and concepts developed by his department, which look so rosy on paper.
Ludmila Tsyganok was the president of the Association of Environmental Professionals forced to state, that the minister and his subordinates are very far from understanding how reforms are generally implemented. We can assume that it is precisely because of this that things usually did not go beyond good "concepts and strategies".
3. Reform of the field of industrial pollution
What does the minister write?
"We have launched a reform to reduce and control industrial pollution." By this the official understands:
- adopted framework legislation.
- developed and ready for approval European Best Available Technologies and Management Methods (BTM) in a number of industries.
- Ukraine has official observer status in the Seville process.
What is the real situation
The European integration law on integrated prevention and control of industrial pollution has indeed already been adopted. But it has received such a flurry of criticism from stakeholders and environmentalists that it is very, very questionable to consider it an achievement.
Experts expressed 3 critical reservations regarding draft law No. 11355: unrealistically short deadlines for enterprises to carry out eco-modernization, lack of tools and sources of financing for industrial modernization, as well as complete detachment from the realities of wartime and the state of the economy after 2.5 years of war.
In addition, they indicated to the fact that without a sub-legal regulatory framework and specialists who will be able to ensure the implementation of the reform, the law on industrial pollution will never work.
As for BTM, the process of their preparation is very, very slow. Out of almost 40 necessary documents, units are currently adapted and prepared for approval.
But the minister told the truth about Ukraine receiving official observer status in the Seville process. It happened on June 5, 2023. After full accession to the EU, our country will have the "right to vote" in the development of new European BTM.
4. Forestry reform
What does the minister write?
"Forestry reform has been brought to the finish line". Here is the evidence he provides:
- the forest industry in Ukraine is no longer subsidized – it pays heavy taxes to the state budget. The profit of SE "Lisa Ukrainy" for the first half of 2024 is UAH 11.14 billion.
- the flow of wood is tracked online from harvest to sale for export.
- at the end of 2023, the ministry launched an electronic certificate of wood origin, which is the final document in the chain of control over the circulation of wood.
Mr. Strelets also adds that "this is an irreversible path to the transparency of the industry, which has been corrupt for many years."
What is the real situation
Numerous materials of scientists, ecologists, investigators and public organizations prove the exact opposite: the changes introduced by the Ministry of Environment during the leadership of Strelits only increased the volume of illegal logging, and corruption in the industry was centralized and firmly cemented.
It became the most resonant investigation of the BlackBox OSINT project regarding Yuri Bolokhovets, who was brought to the position by Ruslan Strilets. According to the investigators, the former head of the State Forestry Agency, and now the general director of the state enterprise "Forests of Ukraine", Bolokhovets, who now reports to all the country's forestry enterprises, "covers" corrupt people on the ground and "crushes" illegal logging. He also lobbies the Cabinet to cancel environmental restrictions on sanitary logging.
If you are interested in the topic, we highly recommend reading the full investigation.
Dmytro Karabchuk, forester, chairman of the board of the NGO "Forest Initiatives and Society" says that according to expert research, as well as his own analysis, third wood in Ukraine is being prepared illegal. He also talked about the scheme used by foresters to avoid conducting EIA and mass "sanitary" felling of actually healthy trees.
According to MP Yaroslav Zheleznyak, the State Enterprise "Forests of Ukraine" purchases the most cars among all state-owned enterprises. And the appetites for transport at "Lisiv" only increase every year. Yes, in August DP conducted tender for a batch of electric bicycles.
5. Reform of state environmental control
What does the minister write?
"Revived the reform of state environmental control".
"We have presented a strategy on how to change the system – so that there are no more discussions about the high-quality or not so good work of the inspectors, as well as taking into account the new emphasis – the need to record Russia's crimes against the environment and calculate the damages," Mr. Strelets assures.
What is the real situation
In May, the EU made another attempt to force the Ministry of Environment to carry out the DEI reform, which has been going on for 7 long years. In order for this to finally happen, the European Commission in its recommendations to Ukraine noted the reform of the State Environmental Inspection of Ukraine among the 5 priority tasks in the field of environmental protection for 2024.
After all, instead of taking concrete steps to create a conceptually new body based on the European model, the Ministry of the Environment spread empty chatter and repeatedly made amendments to draft law No. 3091 "On State Environmental Control", the only real change in which was a change in the name of the control body without any transformations in approaches and principles of its work.
Instead of rolling up its sleeves and finally taking on the construction of a fundamentally new structure, the Ministry of Environment under the leadership of Sagittarius generally demonstrated only decorative changes, such as, for example, in the form of "EcoZagroza".
And this platform publicized by the ex-minister is public activists criticized as senseless, since the Ministry of Environment simply does not respond to citizens' appeals that were submitted through it.
It should be noted that non-governmental organizations of nature protection also sent a collective letter to the ex-minister with a proposal to report to the public.
"Such a step will correspond to the European spirit of government accountability, and will demonstrate our progress towards EU membership not only on a formal level, but also on a value level. We sincerely hope that Mr. Ruslan will agree to our proposal and create a precedent for reporting to interested parties," they expressed their hope.
We hope that the next minister will not get carried away with PR, narcissism and "resuscitation of reforms", but will focus on the protection of forest resources, water resources and biodiversity in Ukraine.
