However, since the beginning of 2022, all processes of reforming the forestry sector have been in limbo. And with the beginning of the full-scale Russian invasion of Ukraine, in general, a number of achievements of past years have been lost.
Thus, the Open Register of Logging Tickets, the Unified Register of Internal Affairs, including materials of already closed cases, and forest maps, including in regions where there were no hostilities, are again inaccessible to the general public. Despite the fact that the Presidential Decree on the introduction of martial law in Ukraine of 24.02.2022 did not include the suspension of Article 50 of the Constitution of Ukraine, according to which everyone is guaranteed the right to free access to information about the state of the environment.
In a number of regions remote from the territories of hostilities, unjustified bans on visiting forests were introduced, which, together with the closure of registers, greatly complicated public control over forestry management. And against this background, it is proposed to simplify the felling of a number of species during martial law.
In our opinion, temporary changes to the felling rules should only concern ensuring the prompt implementation of tasks for the defense of Ukraine and forest protection. At the same time, it is unacceptable to cancel the Sanitary Rules in the forests of Ukraine, which include a number of restrictions on felling in various categories of forests, as well as the removal of current restrictions on continuous sanitary felling in the Carpathian region.
We also insist on the earliest possible restoration of public access to registers in the field of forestry and the timely filling of these registers:
An open register of felling tickets of the State Enterprise “LIAC”, including maps of quarterly and separate divisions.
Public cadastral map (excluding information on lands of the Ministry of Defense and the Ministry of Internal Affairs).
Layers with the boundaries of forests and objects of the nature reserve fund on the Ecosystem portal.
A single register for environmental impact assessment – at a minimum, open case files related to forest logging, since the information in them does not pose a threat to national security.
A single inspection portal, which contains the results of inspections of business entities by regulatory authorities, in particular the State Environmental Inspectorate.
As experience shows, transferring the consideration of environmental issues during the war to the “untimely issue” section only worsens the situation, and in the forestry sector – it also leads to an increase in the level of corruption and a decrease in management efficiency.
We would like to separately emphasize the need to take into account the principles of the European Green Deal, in particular regarding forest management, during the post-war economic recovery. Considering which, we present below the following fundamental positions that should become mandatory in the process of post-war reconstruction and European integration of Ukraine:
– ensuring the interests of the woodworking industry of Ukraine can only be achieved by intensifying the use of artificial forests (increasing the volume of maintenance felling, selective and gradual main use felling, re-forming felling instead of continuous felling), while reducing the operational load on forests of natural origin and strengthening their protection.
– it is necessary to develop the integrated use of forest resources, in particular, expanding the use of non-timber forest resources, including stimulating tourism.
– an increase in the forest cover index of Ukraine can be ensured only by preserving and balanced use of self-seeding forests and creating private forests on degraded arable lands, while completely abandoning the afforestation of steppe and meadow ecosystems.
– to reduce corruption during the sale of timber, it is necessary to adopt as soon as possible the draft law 4197-d “On the Timber Market”, which proposes to transfer the sale of timber exclusively to electronic auctions.
– high-quality planning and implementation of measures to manage mined forest areas is necessary, based on the experience of other countries.
– one of the key sources of financing for the forestry sector of Ukraine should be the monetization of forest ecosystem services, including carbon removal from the atmosphere and conservation, as well as adaptation to climate change. In addition to timber, forests provide a large number of ecosystem functions, the users of which are all citizens of Ukraine. In order to ensure financing for the implementation of climate-forming, water-conserving, soil-protective and other functions by forests, and to increase resilience to climate change, it is necessary to develop a regulatory framework for the assessment and monetization of ecosystem services.
We look forward to fruitful cooperation with representatives of the forest sector and state authorities to implement the above tasks and prevent restrictions on the possibilities of public control and public participation in forest management processes.
Sincerely,
МБО “Екологія – Право – Людина”
ГО “Українська природоохоронна група”
ГО “Дунайсько-Карпатська Програма”
ГО “Екоклуб”
ГС “Всесвітній фонд природи Україна” (WWF-Україна)
ГО “ВЕА “Зелений світ”
Сєвєродонецька міська екологічна асоціація “Зелений світ”
