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Ukraine’s dangerous air pollution problem in desperate need of solutions

The air in Ukraine is worse than anywhere else in Europe. The World Health Organisation ranks Ukraine as the country with the highest health impact from air pollution in Europe. With almost one third of the air pollution produced by energy generation, cutting emissions from power plants has to be the first step in dealing with this health hazard.

With 70% of Ukraine’s primary energy consumption coming from various fossil fuels, which in turn emit an enormous volume of pollutants into the air, it is safe to say that fossil fuels are the main culprit of the country’s air pollution. Coal-fired power plants lead the way: the massive fleet of 20 plants constantly pumps sulphur dioxide, dust and nitrous oxides into the air.

To put the problem into perspective, the reported sulphur dioxide emissions of the Ukrainian coal power plants for 2019 are 589,557 tonnes. This is strikingly close to the 617,281 tonnes emitted in 2019 by the 16 Western Balkans power plants, which in recent years have become famous for emitting more sulphur dioxide than all of the EU power plants combined. A recent report from the Centre for Research on Energy and Clean Air concluded that Ukraine is the single biggest emitter of sulphur dioxide in Europe, with most of the emissions coming from coal-fired power plants. 

Ukrainian coal power plants also reported emissions of 104,809 tonnes of nitrous oxides, twice as much as the notorious 16 Western Balkans power plants, and 155,891 tonnes of dust, which completely dwarfs the 17,556 tonnes from the Western Balkan plants.

According to the World Health Organisation’s information on mortality and the burden of disease from ambient air pollution for 2016, Ukraine has 2,538 disability-adjusted life years (DALYs) lost annually per 100,000 people. This is the highest number in Europe and is mostly driven by Ukraine’s fossil fuel addiction.

As a European Union accession candidate and a signatory to the Energy Community Treaty, Ukraine has a long list of obligations whose implementation would lead to a significant reduction in emissions. However, Ukraine has done a terrible job upholding these obligations so far, even with seemingly simple tasks such as reporting emissions to the Energy Community and the European Environment Agency.

In the emissions reports made under the Large Combustion Plants Directive, which has been in force in Energy Community contracting parties since January 2018, Ukraine’s data have several inconsistencies. The report for 2018 is missing emissions data for 15 of the stacks that were operating during that year and should have reported emissions. Both 2018 and 2019 reports include plants, such as the Burshtynska power plant (which exports electricity to the EU), whose reported emissions match the limits set in the National Emissions Reduction Plan down to the exact figure. This raises suspicion that the numbers reported may be incorrect.

These inconsistencies in the reporting make the accuracy of the data questionable, to say the least, and in reality the emissions figures might be even higher. Also, due to the country’s old and degraded air quality monitoring system, the plants’ impact on ambient air quality is also not properly measured. 

Ukrainian citizens have taken it upon themselves to fill this information void with a wide network of citizen-installed particulate matter (PM) monitoring stations. However, indicative citizen monitoring is not a replacement for official monitoring with data available in real-time, and it certainly cannot replace continuous monitoring of emissions at the stationary sources of pollution.

It is high time for Ukraine’s government to take the air pollution problem seriously and to take concrete measures to reduce emissions at the source. This is a long and expensive process, regardless of whether it includes bringing the emissions from the power plants down to legal limits or replacing them with renewable capacities. However, further delays must not be tolerated by any party involved, including the international community. As long as Ukraine’s dangerous emissions continue unabated, people will continue to pay the cost with their lives.

Bankwatch published a publication covering the impacts of Ukraine’s energy sector on air quality and recommendations to protect human health and the environment from air pollution in Ukraine.

Publication in English, in Ukrainian. 

A Green Agenda for the Western Balkans: Where are the teeth?

Click here to view NGO recommendations from April 2020 vs this week’s Green Agenda proposal

Back in early April this year, 18 environmental organisations working in the Western Balkans put forward a set of recommendations on the EU’s Green Agenda, covering the five areas set out by the European Commission. 

While the devil lies in the numerous details that are yet to be hammered out, what sticks out overall is that the Green Agenda has plenty of good ideas, but a conspicuous absence of enforcement mechanisms.

Anyone dealing with governments in the Western Balkans must be aware that they are not really overachievers in environmental issues. Commitments made back in 2005 under the Energy Community Treaty  to cut pollution in coal plants remain woefully unfulfilled, two countries still plan new coal plants, and the whole region is suffering from a tsunami of destructive and unnecessary hydropower plants. Recycling and waste prevention are at miserable levels, while energy wastage is rampant. Rail and other public transport is being neglected, while overpriced and oversized motorways inflate the countries’ debts.

Against this background, change can be made, but usually only if politicians see clear consequences of not doing so. This has been proven again and again by the Energy Community Treaty. The Treaty has been in force since 2006 and has seen some progress with applying EU energy and environmental legislation in the region, but enforcement is seriously lagging due to the lack of penalties. A discussion is currently ongoing about introducing monetary penalties, which could finally speed up implementation as long as they are set at a dissuasive, effective and proportionate level.

But the Green Agenda has not taken this lesson on board. It is full of support, promotion, facilitation, and assisting, but short on binding measures. 

The only clear sign of extending the countries’ binding commitments is to “facilitate their swift alignment with the EU Climate Law”. This is certainly a very welcome move, but only covers one of the five Agenda areas, and still doesn’t mention how it will be enforced.

Another issue is a lack of coherence between the Green Agenda and the Economic and Investment Plan for the Western Balkans. 

While the Green Agenda promotes decarbonisation by 2050, the Investment Plan’s flagship on “Transition from coal” promotes four fossil gas pipelines presented as “future-proof” on the basis of no evidence whatsoever. 

It is hard to overstate how unreasonable this is in a region which does not have a tradition of widespread gas use. The European Commission is knowingly encouraging a set of not particularly rich countries to waste their limited resources on complex network infrastructure that will be obsolete in a couple of decades’ time and would call for yet another “transition”.

Another contradiction is on hydropower. The Green Agenda highlights the need to diversify away from hydropower and bioenergy, while the Investment Plan’s renewable flagship projects consist entirely of hydropower – except for in North Macedonia.

And while the Green Agenda mainly promotes rail and urban transport, half the Investment Plan’s transport projects are motorways.

People are sick and tired of words without deeds, and of contradictory messages. If the European Commission is serious about its Green Agenda, it has to stand behind it and find a way to make it enforceable. 

Whether this is through existing mechanisms like the Energy and Transport Communities or by changes in the Stabilisation and Association Agreements with the accession countries doesn’t matter much – the important thing is to make it stick. This way, the Western Balkans’ environment wins but the EU wins too, by finally convincing people that it means business.

Click here to view NGO recommendations from April 2020 vs this week’s Green Agenda proposal

Groundhog day: Third public consultation for Belgrade incinerator environmental studies and still no circular economy in sight

Around two years ago, the European Bank for Reconstruction and Development (EBRD) opened a public consultation on an environmental and social assessment for the Vinča waste incinerator, landfill rehabilitation, landfill gas facility and new landfill. The bank was considering financing the project and wanted to make sure that an environmental and social assessment meeting its own standards was carried out. So far, so good.

Ne Davimo Beograd and A11 from Belgrade, together with Bankwatch, submitted 92 pages of comments on the study, reflecting major deficiencies, for example a lack of data on waste projections, a lack of non-incineration alternatives, a failure to commit to the new EU Waste Incineration BREF standards being developed at the time, and the project’s negative impact on Serbia’s ability to meet EU circular economy targets.

When the responses came, they were clearly written by the project sponsor, Beo Clean Energy, without any additional input from the bank. As a result, our most important comments – eg. on the potential clashes with EU recycling targets, and the lack of recycling/prevention elements within the project – were put aside on the grounds that they were not the company’s responsibility. Yet its public-private partnership contract would clearly dictate Belgrade’s whole waste management system, locking the city into long-term incineration. 

This was already in conflict with the Aarhus Convention requirement that public participation must take place at an early stage when all options are still open, and things have only got worse since then.

Further attempts to clarify with the EBRD raised more questions than they answered. Tiny snippets of contradictory information were accompanied by bland assurances that the bank was satisfied with the Serbian authorities’ answers to its questions – presumably implying that we ought to be satisfied too. Clearly, we weren’t. We lodged an official complaint to the bank’s recourse mechanism.

Meanwhile in late June 2019, the Serbian Ministry of Environment opened a national level consultation on two environmental impact studies – one for the incinerator and landfill gas plant, and one for the new landfill. 

The national-level studies were more or less a rehashed version of the study presented to the EBRD, with the same factual mistakes, old data, missing waste projections and missing non-incineration alternatives. Despite the fact that the EU had earlier in June approved new pollution control standards called the Waste Incineration BREF, the national-level environmental study for the incinerator failed to demonstrate that the plant would adhere to the new rules.

Apart from wasting our time by having to comment on hundreds of pages of similar text twice in different formats, it was far from clear what either of these processes achieved. None of our substantial comments were taken into account – only a few minor details – and in September 2019 the Ministry of Environment approved the environmental impact assessment while the EBRD approved financing for the project.

The project promoters were clearly in a hurry, as the Ministry of Construction, Transport and Infrastructure issued the construction permit for the project on 16 August 2019 – more than a month before the environmental impact assessment process was complete, thus undermining the outcome of the process and rendering it largely pointless. 

Even an initial approval for the project to receive renewable energy incentives was issued by the Ministry of Mining and Energy on 27 September before the environmental assessment was approved, and before the final construction confirmation was issued by the Ministry of Construction on 8 October. This rendered it illegal both in terms of Serbian law and under the EU Renewable Energy Directive, which is binding on Serbia under the Energy Community Treaty. 

Under Serbian law, the approval for incentives should only have been issued once construction could legally start, while under the Renewable Energy Directive, only the biodegradable fraction of the waste can count as renewable, but the subsidies were granted for electricity from the whole plant.

Fast forward to summer 2020: Suddenly the Ministry of Environment started a new scoping process for an updated environmental assessment. 

The stated reason was that the study needed to be brought into line with the EU Waste Incineration BREF – yes, the same one that had been approved in June 2019, before the previous environmental impact assessment consultation, and the same one that we’d been highlighting in our communication with the EBRD for two years already.

So here we are again, on Groundhog Day, stuck in a never-ending cycle of submitting comments on environmental assessments of the Vinča incinerator, still with no basic data justifying the project. 

In fact, in the meantime, we found data which proves the project will conflict with EU circular economy targets, and the EIB and EC agree with us. But the EBRD, the World Bank’s International Finance Corporation and the Austrian Development Bank are sticking stubbornly with the project.

But this time it’s even weirder, as the Ministry has not made it clear whether it has annulled the previous permits and approvals for the project or not, and it is not clear whether construction on the actual incinerator has started.

Clearly this process has absolutely no integrity unless it can actually impact on the project and unless all options – including not building the incinerator – are still open.

In fact, given the fact that several appeals, lawsuits and legal complaints are pending against the project and the topsy-turvy permitting process, the most logical thing for the competent Serbian Ministries to do now would be to annul all the previous approvals and permits, and treat this environmental impact assessment as a new one starting from scratch. They will surely be reluctant, but the alternative might take even longer.

Any increase in renewable energy targets must exclude environmentally destructive projects

Last week, Bankwatch responded to the European Commission’s public roadmap consultation on the Renewable Energy Directive (RED II), aimed at assessing how EU renewable energy rules can contribute to higher EU climate ambition. We highlighted the need to raise the level of ambition of the Directive’s targets and sub-targets. However, we emphasised that this must also include the strengthening of its sustainability criteria.

Renewable energy will need to play a crucial role if the EU is to achieve its key target to reduce GHG emissions by 55% by 2030. Yet so far, hydropower and biomass have made up a significant proportion of renewables in the EU and accession countries, despite the serious environmental damage they entail.

Bankwatch has documented the harmful impacts of hydropower projects – small and large – on both people and the environment. Within the EU, no fewer than 60% of rivers have failed to reach good health, among others as a result of hydropower construction. In recent years, their trail of destruction has been particularly felt in biodiversity-rich southeast Europe, where nearly a third of all hydropower projects planned or built since 2005 are in protected areas or internationally recognised areas of high biodiversity value. 

This overdevelopment of small hydropower projects has been driven by disproportionate support from feed-in tariffs – a form of subsidies that are no longer allowed in the EU except for the smallest projects. In 2018, 70% of renewable energy incentives in the Western Balkans benefitted small hydropower. This is despite small hydropower only generating 3.6% of total electricity.

In the EU, hydropower can in theory only be subsidised if it is in line with the Water Framework Directive. But in practice, there are insufficient mechanisms to ensure this condition works. By the time any breaches of the Directive have been established, subsidies have usually long since been approved. 

As a result, Bankwatch is calling for tighter conditions, allowing hydropower to be counted as renewable energy only in countries which have complied with the Water Framework Directive and ensured their rivers are in good health – at least for the river basin in question. 

Compliance with the Habitats Directive to prevent damage to protected areas and species also needs to be a condition for labelling energy projects as renewable – and not only be on the project level: no potentially damaging projects in Natura 2000 areas should be counted as renewable energy in any Member State failing to implement the Habitats Directive correctly. This would both prevent unsustainable renewable projects and incentivise better application of the Habitats Directive.

Unfortunately, biomass is no better than hydropower, and brings additional issues regarding carbon emissions. Energy production from forest biomass leads to both CO2 emissions during combustion and reduces the capacity for carbon capture and storage by forests. Yet it is not clear that current EU sustainability criteria take account of this. 

In a previous analysis of the National Energy and Climate Plans (NECPs) , Bankwatch found that central and eastern European (CEE) countries plan logging and the use of biomass far above sustainable levels. Estonia, for example, cuts down 30% more forests than grow back for biomass use, and in Slovakia, logging grew by at least 75% from 1990 to 2015, leading to a 6% loss of forest cover. 

These concerns were conveyed in our response to the Commission’s roadmap consultation on the Directive. We highlighted that increasing the level of renewable energy will only be part of the solution, and to be truly effective, stricter provisions need to ensure the sustainability of renewable energy projects. 

We welcomed the Biodiversity Strategy 2030 released in May this year, which introduced stricter enforcement mechanisms for protecting sustainability. The revised Renewable Energy Directive needs to follow this positive direction. It has the potential to really drive forward renewable energy and act as a catalyst for achieving GHG emission targets. But it must ensure that increasing the EU’s ambitions for renewable energy does not exacerbate environmental and social destruction. 

The (Un)Just Transition Fund: the European Parliament shows how green it really is

On Wednesday, 16 September, MEPs cast a final vote on the Just Transition Fund (JTF) to establish Parliament’s final position for negotiations with the European Council. First proposed in January this year, the JTF is designed to mitigate the social impacts of those in coal regions most affected by the transition from fossil fuels to clean, sustainable energy sources.

The JTF’s legislative journey has been far from smooth. The Fund’s amount has been revised three times, from EUR 7.5bn, to 40bn and now 17.5bn. In July, the Committee on Regional Development-first responsible for this file, voted in favour of reintroducing gas to the list of possible investments that can be supported by the Fund. Unfortunately, last Wednesday the Parliament followed suit and voted for the JTF not to fully exclude fossil fuels from the scope of the Fund. This comes less than a year after the same Parliament gave its full support to the climate objectives outlined by the Commission’s European Green Deal. 

In a further sense of bitter irony, Commission President Ursula Von de Leyen announced the very same day the decision to increase the European target for GHG emissions reductions to 55% by 2030 (a proposal that was initially put forward by Parliament, who wanted the Commission to increase the target from 50% to 55%).

But how ‘just’ can this Fund still be, given that public money may now be used to support the fossil fuel industry – those responsible for creating the need for a just transition in the first place? Can it still be deemed ‘just’ if these much needed funds are diverted away from those citizens who require the most support for dealing with the economic and social burden of the transition? 

Bankwatch published our position outlining the lack of safeguards in the JTF in March this year, where we highlighted that fossil fuels, in particular natural gas, will have a nonexistent role in energy production after 2035. This was further reiterated during Bankwatch’s submission to the JTF public consultation, where we noted that in less than 15 years, natural gas will become a stranded asset in energy production if the objectives of the Paris Agreement are respected. These concerns have been validated by a  CAN Europe report, which revealed that more than 10% of the Fund will go to the four countries that plan to phase out coal by 2030 via a significant increase in fossil gas use. 

A truly ‘Just’ Transition Fund would instead focus on investing entirely in sustainable technologies that also create long-lasting jobs, something that will be severely hindered by Parliament’s latest decision. 

Looking ahead, this now sets a precarious course for ongoing negotiations on the next EU long term 2021-2027 budget and recovery measures, especially given an unprecedented 30% of this will now be allocated to climate related spending. In particular, the Recovery and Resilience Facility and Cohesion policy regulations which are worth EUR 900 billion will also see heated debate over excluding fossil fuels from their supported activities. The spotlight will now turn to whether Parliament will repeat the same mistake again.

Regardless of the outcome of these negotiations, Parliament now finds itself in the awkward position of being the least green EU institution, and risks being held responsible for failing to deliver on the Green New Deal objectives and the Paris agreement that it vowed to support. 

Georgia’s precious Khada Valley at risk due to a new road to Russia

‘This is not only the struggle of the locals. If we lose the Khada Valley, the entire country will lose it. So we hope that everyone will bond to save the historic heritage and wealthy biodiversity of Khada,’ said Giga Chokheli, a local of Georgia’s Khada Valley. Khada is known among Georgians and foreigners for many reasons: it is among tourists’ favorite hiking destinations, with breathtaking mountainous landscapes, and its precious cultural legacy is unique. 

This valley will be bulldozed to build the Kvesheti Kobi road to Russia. An EUR 558 million project envisages digging five tunnels and building six bridges in a tiny valley. Two international financial institutions, the European Bank for Reconstruction and Development (EBRD) and the Asian Development Bank (ADB), have already allocated loans to support this initiative. 

But some members of the local community, scientists and human rights activists refuse to let the road be built. Campaigners said that they are particularly concerned because the project has violated some of the international banks’ standards. 

They have started a petition to protect the valley, as the project threatens traditional forms of livelihood, unique biodiversity (some species in the valley are on the IUCN Red List of Threatened Species), a number of cultural monuments and unique towers that date back to the tenth and eleventh centuries, unexplored archaeological treasures that confirm traces of life from the Eneolithic period, and tourism opportunities. 

The petition addresses the Government of Georgia, the EBRD and the ADB. It calls on the project promoters to choose an alternative route for the new road that does not go  through Khada because of the valley’s special value. Campaigners also request that the government establish a Protected Landscape (IUCN category V) in the Khada Valley (see all requests here).

‘Khada Valley has an amazing…diversity of cultural heritage monuments in a small area. This clearly confirms how unique the valley is and, to be fully discovered, it needs thorough scientific explorations. Some of the patterns here are unique, including the three monuments of national importance that date back to the IX-X centuries… All together, they form a cultural phenomenon that embraces considerable scientific, educational and touristic potential and its importance goes beyond local. We consider it inadmissible to have the highway in the valley. An alternative route should be selected,’ said Manana Suramelashvili, an art and cultural heritage expert who is one of the authors of the petition.

‘The project’s ESIA [Environmental and Social Impact Assessment] Report and other mandatory documentation related to the project do not comply with the EBRD’s 2014 Environmental and Social Policy and the ADB’s 2009 Safeguard Policy,’ reads a new report about the potential socio-economic and gender impact of the Kvesheti-Kobi road on the local population, produced by Green Alternative, a Bankwatch member organisation in Georgia. 

According to the report, the project does not comply with the EBRD’s standards for the following performance requirements: assessment and management of environmental and social impacts and issues, land acquisition, involuntary resettlement and economic displacement, cultural heritage, and information disclosure and stakeholder engagement. 

‘The project will go through a critical habitat, as defined by the ADB’s policy.It will endanger physical cultural resources as well as fail to bring poverty alleviation and benefits to the region’s inhabitants,’ states Green Alternative’s assessment. 

The petition was launched after recent controversial developments in the valley. Despite one year of struggle, the locals’ protests and highly critical reactions from cultural, environmental and human rights defenders about the project’s impact, the preliminary construction still began.   

The very first steps of those works already threatened a historic monument and violated Georgian law: the preliminary construction took place only 70 metres from a significant historic monument in Mtiuleti, the Nagvarevi church. According to Georgian law, construction must take place at least 300 metres away from any significant historical or cultural site. 

In addition to this, archaeologists said, the construction of a secondary road for the Kvesheti-Kobi project posed serious risks to archeologically important yet unstudied spots in the village of Zakatkari. Only after the public outrage in response to these activities did the National Agency for Cultural Heritage Preservation in Georgia say that the activities were illegal. None of the project’s international funders have made any public comment about the violations. 

‘The Naghvarevi and Zakatkari cases are the first examples of the kinds of dangers this project could bring,’ said Manana Kochladze, founder of Green Alternative. ‘The development of the Kvesheti-Kobi project began without properly exploring the area. The social and environmental impacts of the road project are practically unstudied, and the construction is more dangerous than stated in official project documents. Unfortunately, in Georgia, the participation of international financial institutions in a project does not necessarily guarantee that the project will be developed according to international standards.’ 

‘For one year we used all official methods to save the valley. As a result, instead of listening to our concerns, the government kicked off the construction,’ said Giga Chokheli from Khada, who is one of the complainants who filed a lawsuit alongside Green Alternative against the Georgian government. The lawsuit requests that the government revoke the permission for the preliminary construction of the Kvesheti-Kobi road project obtained by the Ministry of Environmental Protection and Agriculture. Other attempts to save Khada also included letters to the ADB and EBRD, who the local population particularly relied on due to their international standards. However, their expectations were not quite fulfilled: 

‘Instead of the support of international financial institutions, the response I got at one of the meetings from a representative of the Asian Development Bank was the following: “Do you really believe that project is being done for Khada?!”’ Chokheli recalled. He added:

‘The project ignores the needs of villagers and intends to sacrifice the entire Khada Valley, which we will not allow.’

Sign the petition here.