The Ministry of Environmental Protection and Natural Resources of Ukraine (Min dovkillia) has once again issued a refusal for the Environmental Impact Assessment (EIA) conclusion regarding the plan to raise the water level of the Oleksandrivske Reservoir for the completion of the Tashlyk Pumped-Storage Hydroelectric Power Plant (HPP). The refusal was based on a significant list of violations found in the EIA Report.
This is a major victory for conservation, as the Buzkyi Hard National Nature Park – a site of unique biodiversity and cultural heritage – was again under threat of significant flooding and destruction.
Key Reasons for the Ministry’s Refusal
The primary grounds for the Ministry’s decision highlight fundamental failures to comply with environmental legislation:
- Violation of Public Notice Deadlines and Content: The official notification of the planned activity in printed media was published late, and the information provided was incomplete.
- Ignoring Public Comments: The report failed to address and provide proper justification for rejecting the comments submitted by NGOs and individual citizens, a direct violation of the EIA procedure.
- Lack of Cumulative Impact Assessment: The report did not fully describe the cumulative environmental impact of integrating the Tashlyk HPP into the energy complex alongside the South Ukraine Nuclear Power Plant (Yuzhnoukrainska NPP).
- Unreliable Data on Protected Species: The report contained inaccurate or outdated data regarding plant species and communities listed in the Red Data Book of Ukraine and the Green Data Book of Ukraine (which lists rare natural plant habitats), which would be destroyed by the flooding.
- Violations of Protected Areas Legislation: Raising the water level would lead to the flooding of territories within the Protected Areas Fund (Pryrodno-Zapovidnyi Fond, PZF), which are subject to special protection.
- Failure to Account for Water Scarcity: The report did not consider the risks to water supply for the Mykolaiv region under existing water deficits, nor did it account for the projected severe worsening of this deficit due to the project.
- Other Deficiencies: The report lacked a site map, presented incomplete data on noise and air pollution, and offered an insufficient analysis of alternatives to the planned activity.
The volume of violations, inaccuracies, and contradictory information was so substantial that UNCG’s formal objections alone spanned 52 pages.
The Ministry emphasized that the identified violations are incompatible with the requirements of environmental protection legislation and prevent a positive decision on the activity.
We are grateful to the Ministry of Environmental Protection and Natural Resources for its consistent position in defending this critically valuable territory. Buzkyi Hard is a habitat for a number of globally unique species that could disappear forever if this outdated Soviet-era project were to be approved.
