Position of Ukrainian Climate Network on the priorities of the climate policy of Ukraine with regard to COP 26 conference

This year the conference of UNFCCC aims to encourage countries to make ambitious commitments on the reduction of greenhouse gases emissions until 2030 in order to ensure reaching carbon neutrality by 2050, providing for adaptation of vulnerable communities and natural habitats to climate change, mobilizing climate finance and uniting countries for the fulfillment of reached agreements. However, the most anticipated and the most difficult part of the conference is the consensus on the market and non-market mechanisms of the Paris Agreement.


Position of the official delegation of Ukraine at COP26

In July 2021, Ukraine submitted to the UNFCC secretariat the updated National Contribution to the Paris Agreement (hereinafter – the updated NDC), which aims for the reduction of 65% in GHG emissions by 2030 compared to 1990, which means the reduction of 7% if compared to 2019.[1] One of the priority objectives of the official delegation of Ukraine at the conferences is to present the updated NDC.

As for the position of Ukraine on the other conference agenda items, civil society has been presented the following priorities:

  • Implementation of Article 6 of the Paris Agreement. Ukraine does not appreciate the transfer of unused emission reduction units from the Kyoto to the Paris regime. At the same time, the recognition of the need for certain compromises has been let known.
  • Transparency of the Paris Agreement. Ukraine supports the position that demands different countries to report in the same way, without taking into account their level of economic development.
  • Contributions to the Adaptation fund. Ukraine supports the position that such contributions under Article 6 of the Paris Agreement shall be voluntary.
  • Issues of territorial integrity and national sovereignty of Ukraine. The official delegation will stand firmly in the position to decline the reporting submitted by the Russian Federation to the UNFCCC secretariat that includes emissions of temporarily occupied territories of Ukraine in Donetsk and Luhansk oblasts, and Crimea. If the Ukrainian position on this issue receives no support, the Ukrainian delegation will be determined to block the conference decisions.


The assessment given by Ukrainian Climate Network to the position of the official delegation of Ukraine at COP26.

Ukrainian Climate Network (hereinafter – UCN) supports the position against the use of old credits from the Kyoto protocol under the market mechanisms of the Paris Agreement. At the same time, it emphasizes the need to avoid double counting of emission reductions and adhere to the additionality principle.

The application of Article 6 mechanisms should always lead to real and additional emission reductions. Robust criteria are necessary to ensure that “incidental” emission reduction units are not generated by the projects implemented under Art. 6 of the Paris Agreement. Incidental – i.e. those that arise as a by-product of economic projects that have not been aimed at reduction of emissions in the first place. For all credits to be used under the Article 6 mechanisms, their “additionality” to the emission reductions that would have occurred without the application of these mechanisms must be demonstrated.

Regarding the voluntary nature of contributions to the Adaptation Fund, UCN emphasizes the importance of climate change adaptation. Therefore, it is necessary to provide alternative ways to support adaptation measures in addition to the allocation of funds (e.g., training, exchange of experience and technology).

Ukrainian Climate Network supports Ukraine’s efforts to protect its territorial integrity, and at the same time expresses concerns regarding the prudence of using the mentioned methods. The importance of this year’s climate talks for reaching agreements that allow the Paris Agreement to fulfill its goal of preventing global temperatures from rising is difficult to overestimate. We are therefore concerned about the possible blocking of decisions. Moreover, UCN emphasizes that Ukraine is the one who should report on the occupied territories, highlighting the problems with obtaining the necessary information and development of data monitoring technologies.


Ukrainian Climate Network believes that Ukraine’s climate policy should be developed following the next priorities:


Priority 1. Reduction of GHG emissions into the atmosphere, acceleration of the large-scale implementation of energy efficiency measures and strategic transition to renewable energy sources.

In order to achieve the goal of reducing GHG emissions by 65% in 2030 compared to 1990 levels, the government is developing a detailed plan for implementation of the updated NDC, and it is important to involve all stakeholders, including public and local governments, in the process.

Particular attention should be dedicated to involving communities and municipalities with the process of development and implementation of climate plans, which will help to align national and local climate policies and develop the practice of effective community participation in the preparation of the next nationally determined contribution of Ukraine, which we have to prepare already by 2025.

At present, Ukraine’s target for reduction of GHG emissions by 2030 is the lowest acceptable from possible options, but it is also insufficient to keep global temperature growth below 1,5°C or even below 2°C, so Ukraine’s next targets should be more ambitious and meet the objective of reaching climate neutrality by the middle of the century. According to Climate Action Tracker, the updated target of Ukraine is critically insufficient.[2]

Ukrainian Climate Network welcomes the start of work of the Ministry of Environmental Protection and Natural Resources of Ukraine on the framework law “On the Strategy of Low Carbon Development of Ukraine by 2050” and is ready for active participation in its development.

According to the updated NDC, the share of renewable energy sources by 2030 will grow from 17% to 30%. The declared goal of achieving a 30% share of RES in the power sector by 2030 is a positive signal for change in government policy in reforming the energy sector. At the same time, it is not sufficient to lead Ukraine to climate neutrality and energy independence. Furthermore, the system for sustainable utilization of the decommissioned wind turbines and solar panels should be developed.

UCN unequivocally states that Ukraine shall stop state funding of the coal extraction and re-direct the funds to the just transition of the sector.

It is necessary to establish a time-frame (deadlines) for the phase out of coal in Ukraine, in particular a specific end date for the curtailment of coal production and the closure of the last coal-fired power plant.

An important aspect of decarbonization in the future should be the development of hydrogen energy. However, Ukrainian Climate Network warns against confusing targets for emission reductions in the next decade with targets for the development of hydrogen energy. The transition to hydrogen as an energy source will happen in some industries only if energy efficiency is improved and a much higher share of renewable energy capacity is reached. The state plans for the production of hydrogen with nuclear power are unacceptable, as are the plans to export renewable hydrogen to the EU, while the share of RES generation within the country remains low and GHG emissions from the energy sector account for the largest share in the overall balance.

In UCN’s opinion, for Ukraine as an agrarian country, the development of bioenergy seems more feasible and reasonable. It will help regional clusters to emerge, develop small and medium-sized businesses and utilize the existing potential in this sector.

The energy transition requires broad involvement of society. Most Ukrainians are largely unable to invest in renewable energy, and without the state support of municipal building stock insulation, the average Ukrainian cannot afford the service. Therefore, a set of policies and tools (for example, the creation of energy cooperatives and revolving funds), which provide for simple and reliable investments in sustainable energy and energy efficiency by citizens, their associations and local governments is much needed. Such a set of instruments will not only attract significant resources but also foster communities’ participation in the energy transition.

The Global Methane Initiative, launched by the EU and the US, should evolve into a legally binding document containing requirements and standards for preventing and eliminating methane emissions. Ukraine should join this initiative, as well as establish the cooperation with the European Commission in the framework of the EU Methane Strategy, in particular, to participate in the establishment and commissioning of the International Methane Emissions Observatory (IMEO).


Priority 2. Increase absorption of greenhouse gases by restoring natural ecosystems

Carbon neutrality implies that greenhouse gas emissions do not exceed what plants and soils are capable to absorb from the atmosphere. Therefore, the support and restoration of natural ecosystems is as important as the reduction of GHG emissions. Measures such as increasing the absorption and retention of greenhouse gases by forests and ecosystems, reducing peat extraction and restoring peatlands, reducing emissions from agricultural land use, and retirement of degraded land, together with reducing greenhouse gases emissions will help Ukraine achieve its goals.

Ukraine needs to focus on the development of non-aggressive, sustainable agriculture, taking into account the principle of the European Green Deal “from field to table”, which will significantly reduce the destructive impact of this sector on natural ecosystems.

It is necessary to stop the plowing of steppe meadows, floodplains, drainage of peatlands and destruction of wetland ecosystems as soon as possible and to develop a long-term action plan to restore these ecosystems in the near future. These measures will not only increase the absorption of greenhouse gases by natural ecosystems but also preserve biodiversity.

Forest belts play an important role in reducing greenhouse gases emissions in Ukraine, namely their preservation and restoration. They are a key element in soil protection, biodiversity conservation and greenhouse gases absorption in the country’s forest-steppe zone. In addition, forest belts play a significant role in the food security of both Ukraine and other countries that import agricultural products.

In addition, Ukraine should not rely on carbon capture and storage technologies. It is neither economically feasible nor a reliable measure, which, moreover, requires additional energy consumption causing further negative impacts on climate.

Therefore, neither increased carbon absorption by natural ecosystems nor artificial carbon capture and storage technologies can replace measures to reduce greenhouse gases emissions – abandoning fossil fuels, energy efficiency and the transition to renewable energy sources.


Priority 3. Adaptation to climate change with the use of nature-based solutions and ensuring funding for climate change adaptation

According to the updated NDC, Ukraine “plans to create a solid foundation” for adaptation to climate change by 2030. Following the approval of the Strategy for Environmental Safety and Climate Change Adaptation until 2030, it is necessary to develop sectoral strategies for climate change adaptation.

The implementation of adaptation measures should be preceded by climate change vulnerability assessment of the entire territory of Ukraine with detailed information on the vulnerability of each region / oblast, as well as a subsequent commitment of communities to develop and approve action plans for climate change adaptation with nature-based solutions.

Without systematic funding for adaptation to and mitigation of climate change impacts measures, their implementation remains impossible. This area should not entirely depend on foreign aid and private investment. Therefore, from 2021 in Ukraine, it is necessary to include in the state budget mandatory articles for the implementation of measures to mitigate and adapt to climate change. Ukrainian Climate Network supports the initiative to create the Ukrainian Climate Fund.

These costs can be in part financed by increasing the price of CO2 emissions to at least UAH 30 per ton, followed by a gradual increase to align with carbon emissions costs in the EU, and the related expansion of the scope of the tax. Also, the Tax Code of Ukraine, along with the CO2 tax rate, should directly define a tax rate of methane emissions, which in a span of 20 years is 86 times more potent GHG than CO2, at a level not lower than the current rates for pollutants of 1-st hazard class.

Tax rates should be high enough to compensate for the damage caused to the environment by emissions, as well as to reflect the cost of adaptation measures, which became necessary because of such emissions. The amount of fines for unaccounted emissions or inaccurate reporting should be high enough to perform its main, i.e. preventive, function. Funds received from environmental taxes should be earmarked for measures to reduce air pollution, adapt to climate change and environmental protection.


Priority 4. The rules for Article 6 should not undermine the social and environmental integrity of the Paris Agreement.

Any transfer of emission reduction units between countries should lead to higher ambitions of national targets and help keep temperatures increase below 1,5°C. The flexible mechanisms of the Kyoto Protocol have proved ineffective and have led to increased emissions, through the trade of excessive credits generated by overestimation and fraud, and not through the implementation of concrete emission reduction projects. This negative experience shall not be repeated in the framework of the Paris Agreement. Therefore, it is necessary to prevent the transfer of old emission reduction units to the period after 2020.

Flexible mechanisms of the Kyoto Protocol should be put to an end, and no credits arisen from them should be counted towards other than Kyoto Protocol commitments. Existing projects and methodologies should be robustly re-evaluated before they may transition to Article 6 mechanisms.

Thus, civil society does not support the transfer of emission reduction units from previous periods. Ukraine’s position on bilateral market instruments under Article 6 of the Paris Agreement must meet the additionality and avoidance of double counting criteria.

Appropriate control tools should accompany market mechanisms of Article 6. These tools should provide sufficient detail to track the origin of emission reduction units to avoid double counting, i.e. when several countries can count the same credits towards their national climate targets.


Priority 5: Development of institutional capacity to implement climate policy and integration of climate policy into all sectors of the economy

Integration of climate policy into various sectors of economy and building institutional capacity to ensure adequate coordination of public authorities and distribution of legislative, administrative and control functions between different authorities and branches of power is a necessary prerequisite for effective implementation of climate policy in Ukraine.

It is necessary to form approaches and basics (principles) for taking into account climate change in policy-making in all sectors of the economy. First of all, this should be demonstrated when drafting the action plan for the implementation of the updated NDC of Ukraine.

In the reports on SEIA and EIA the part on the assessment of climate change impacts should be expanded, and the methodology for these two procedures regarding certain sectors of the economy, which are associated with climate change and carbon footprint, should be developed.



Ukrainian Climate Network hopes that COP26 in Glasgow will be a turning point in climate policy, where all previous commitments will be put to work and countries will finally move to reduce their emissions.

Ukraine is one of the most vulnerable to climate change countries in Europe and is already facing negative impacts, which will only aggravate in the future. Therefore, we expect that Ukraine will begin actively implement the taken commitments and will make every effort to achieve carbon neutrality in 2050 together with the rest of the world. This could be facilitated by a long-term vision for the development of the energy sector, including the date for the abandonment of coal in Ukraine set no later than 2035, modernization of industry, protection and restoration of ecosystems, and development of energy efficiency in the housing sector.

[1] https://unfccc.int/ghg-inventories-annex-i-parties/2021

[2] https://climateactiontracker.org/countries/ukraine/

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