Can Ukraine’s EU-backed recovery plan deliver on its green promises?

EUR 50 billion in EU funding has been earmarked for Ukraine to implement the reforms detailed in the Ukraine Plan. These measures must align with the Ukraine Facility Regulation and the goals and policies of the EU, ensuring not only a return to pre-war conditions but also contributing to a more sustainable approach to the development of Ukraine and its integration within the EU. Although the plan was endorsed by the European Commission in April and approved by the Council of the European Union in May, future periodic evaluations will determine whether or not these criteria have been met.  

It’s particularly important that the Ukraine Plan adheres to the provisions of the regulation on meaningful stakeholder engagement, the allocation of funds to subnational authorities, as well as the principles of ‘do no significant harm’ and ‘leave no one behind’. Additionally, the plan and overall financial framework within Ukraine Facility must ensure that at least 20 per cent of the overall proposed investment budget is allocated to climate, environmental, and green transition measures, including biodiversity conservation. For this reason, adherence to these requirements is essential if Ukraine is to receive further financial support.  

We’ve taken a close look at the environmental aspects of the plan, particularly the measures outlined for safeguarding the environment during reconstruction efforts.  

Green shoots of recovery?  

The Ukraine Plan takes several positive approaches to the reconstruction of the country, such as emphasising energy and resource efficiency during the construction and renovation of buildings. Additionally, it prioritises the restoration and modernisation of municipal infrastructure, such as heating, water supply and drainage systems, while supporting the production of green building materials in line with EU standards.  

Ukraine’s planned energy sector reforms aim to improve the legal framework for the development of renewable energy sources, increase the efficiency of centralised heat supply systems, enhance energy efficiency in public buildings, and promote the domestic production of energy equipment.  

These measures are vital, particularly given the findings of a recent study on the climate impacts of the first 18 months of Russia’s war in Ukraine. It reveals that the prospective national rebuild could potentially increase greenhouse gas emissions by over 50 million tonnes of carbon dioxide equivalent (CO2e). However, a more sustainable approach to reconstruction involving energy-efficient technologies would reduce this figure significantly over the long term. 

Ukrainian non-governmental organisations Ecoaction and Ecoclub have been actively involved in shaping the government’s reconstruction plan from the outset, offering valuable recommendations, particularly for the energy sector. Encouragingly, some of their suggestions have already been incorporated into the plan, which bodes well for a future collaborative approach. 

The plan also signals positive developments for the agricultural sector, with a strong emphasis on sustainability and green initiatives. Notably, the plan prioritises small and medium-sized farms, representing a significant shift from previous policies, which disproportionately favoured large agricultural enterprises. This focus on smaller farms, known for their less environmentally harmful practices, is a welcome change.  

The planned reforms also include developing advisory services and promoting the transition to products with higher added value. If implemented effectively, these measures have the potential to foster more sustainable farming practices and contribute to a greener, more resilient agricultural sector in Ukraine.  

While the Ukraine Plan addresses the issue of climate change with a focus on state and international climate policy, including the establishment of a Scientific Expert Council on Climate Change and a commitment to preserving the ozone layer, its lack of emphasis on carbon pricing mechanisms, particularly the EU Emissions Trading System, is a cause for concern.  

Although adaptation to climate change is mentioned in the agriculture section of the plan and in relation to national legislation, it lacks a dedicated chapter. This is a crucial oversight, as communities are already developing and implementing recovery plans. To support their efforts, national policy must seamlessly integrate with local policies, providing a clear framework that prioritises climate adaptation.  

Contradictions and inconsistencies 

Although the Ukraine Plan acknowledges the importance of biodiversity conservation, the focus is limited to forest management at the expense of a more comprehensive approach. It’s encouraging to see that the plan outlines the development of a National Biodiversity Strategy and Action Plan aimed at increasing the protection of nature conservation areas and restoring ecosystems damaged as a result of the war. However, there is no mention of the biodiversity strategy in the list of reforms, and specific targets for increasing the size of these protected areas are notably lacking. 

The plan proposes legislative changes to preserve forests and combat deforestation and degradation. However, it also aims to increase wood production significantly over the next decade from 15 to 25 million cubic metres, which is hard to reconcile with a commitment to preserving forests and the EU’s stern measures on deforestation-free products. The Ukraine Plan’s forest management strategy should focus on addressing environmental concerns, particularly the prevention of forest degradation, as outlined in the EU Deforestation Regulation.  

Another contradiction arises in the energy sector. The plan’s stated goals of decarbonisation, decentralisation, and efficiency are completely at odds with its hopes for a ‘nuclear energy renaissance’. The development of nuclear energy is neither financially stable nor economically profitable. Over the past 30 years, new nuclear power plants have consistently encountered cost overruns and significant delays worldwide. Nuclear generation directly opposes energy decentralisation by contributing to even greater centralisation of the energy system, jeopardising energy security for decades to come.  

Considering the recent loss of almost all of the country’s coal generation due to Russian shelling, cheaper and faster energy solutions are now desperately required. Instead, distributed generation from renewable energy sources offers an immediate and cost-effective solution that can empower individual communities and consumers. Ukraine has no time to wait for nuclear units. 

Fertile ground for improvement 

With global and domestic temperatures continuing to rise each year, the plan fails to incorporate measures that target the impacts of the climate crisis on communities. While the plan addresses climate adaption at the national level, it omits any strategy for tackling the consequences of climate change at the local level.  

Agriculture is a sector acutely vulnerable to the effects of the climate crisis. But the only adaptation solution mentioned in the plan is irrigation, with reference to its positive impacts on the environment. Yet, this sole measure is nowhere near enough. The plan needs to adopt a joined-up, holistic approach to climate change adaptation that meets the diverse challenges posed by droughts, floods, and other climate-related events. 

Surprisingly, for all its focus on small and medium-sized farms and adopting a green approach to agriculture, the plan fails to address the fundamental issue of Ukraine’s extensive arable land. While acknowledging that 70 per cent of Ukrainian territory is arable, the plan neglects the long-term risks associated with this pattern of land use. Reducing arable land and increasing productivity in cultivable areas are crucial for sustainable agriculture.  

However, this should not be misinterpreted as a justification for rejecting green measures. Enhanced productivity should be achieved through sustainable practices, not by intensifying the use of pesticides and fertilisers. The goal is to optimise production efficiency on existing arable land, not to expand it. 

Sustainable future within reach  

In conclusion, while the Ukrainian government’s recovery plan offers many positive steps, a closer look reveals contradictions and inconsistencies that conflict with the principles of a green recovery. The Council of the European Union already approved the plan, the monitoring and assessment of the plan’s implementation and its adherence to  the Ukraine Facility Regulation and the EU’s climate and energy goals would be key in the next period.  

The recommendations provided by advocacy organisations like Ecoaction, Ecoclub, CEE Bankwatch Network, and Transport & Environment – now in the hands of the Council and the European Commission – have the potential to put the plan on a more sustainable footing. Upon approval by the Council, vital financing and investments are expected to flow, allowing Ukraine to receive regular tranches for implementing the plan.

The original article in Ukrainian is available here.