Container ship at the Ukrainian port of Odessa

Ukraine’s water transport strategy documents under review

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Experts of the Save Polesia coalition believe that the recently released Strategic Environmental Assessment (SEA) of the “Strategy for the Development of Inland Water Transport of Ukraine until 2031 and the action plan for its implementation” contains a number of miscalculations.

On September 17, the Ministry of Infrastructure of Ukraine published the SEA report of this strategy on its website and invited all interested parties to comment. Thus, the ministry complied with the requirement of the national law to allow public consultations on important state documents that may have a significant impact on the environment. The author of the SEA report believes that the strategy as a whole is environmentally safe and adequate. However, environmental organizations raise concerns that the report is incomplete.

The National Ecological Center of Ukraine (NECU), a partner of the Save Polesia coalition, sent a letter to the Ministry of Infrastructure stating that the strategy and the corresponding SEA have significant shortcomings and can thus not be implemented.

‘ In particular, the SEA does not include an analysis of the impact of the strategy’s implementation on drinking water quality. This is extremely important to assess since – as the report itself states – 80% of the population of Ukraine uses water from surface sources (mostly rivers) for drinking. And more ships on our rivers significantly increase the risk of polluting our own drinking water and thus affecting our health, for example as a result of shipping accidents, sewage or garbage disposal.’, says
Heorhiy Veremiychyk NECU expert
Every ship, such as this cargo barge on the Dnieper river, is an additional source of pollution © Oleg Lystopad

Does the water transport strategy include the E40 waterway?
Veremiychyk notes that although the strategy does not specifically mention the E40 waterway project, it sets the task of connecting Ukraine’s river routes to the European inland waterway network TEN-T. It is impossible to fully fulfill this task without constructing the E40 waterway. However, the SEA does not mention any dangers and risks linked to this massive infrastructure project.

Strategy based on insufficient data
An important point is that the author of the SEA recognizes the fact that the strategy and its implementation plan do not have enough data to properly assess the impacts of the planned water transport on the environment. This is in line with the fact that in particular the impacts on protected areas are not thoroughly investigated.

Therefore, NECU warns that the current version of the SEA cannot be considered as a final conclusion. Additional data are needed to obtain an objective assessment of the strategy and its implementation plan.

Unfortunately, the legislation of Ukraine does not provide for mandatory consideration of comments to the SEA. “But we hope that the Ministry of Infrastructure and the Ministry of Environment will take our comments for the further work with the Strategy into account,” stresses Veremiychyk.

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Top photo shows a container ship at the Ukrainian port of Odessa by Dimitry Anikin from Unsplash.