Comments and proposals on Draft Order by Ukraine’s Cabinet of Ministers «On National Plan of development of renewable energy sector till 2030»

Ukrainian climate network has supported the claim submitted to Ukraine’s Agency on Energy Efficiency and Energy Saving, concerning Ukraine’s Cabinet of Ministers Draft Order «On National Action Plan of development of renewable energy sector till 2030».

We, men and women, members of Ukrainian civil society, representatives from 11 non-government organizations and associations, fairly welcome the completion of «National Action Plan of development of renewable energy sector till 2030» (NAP RES). This important document, once well elaborated and implemented, helps us to counteract climate crisis and contribute to development of Ukraine. At the same time, in order to promote renovation and decarbonization of real economics sector, to attract investments and stay aware of country’s real potential to move to renewables, we propose to consider the following proposals and comments obtained by NGOs together with local self-government bodies as a result of discussion with 90 participants.

Proceeding from above-said, we ask for your attention to consider the following proposals during the public debates on National Plan:

  1. Renewables share in end-user consumption

On 30th of November, Energy Community Secretariate, by Resolution 2021/14/MC-EnC, has approved and adapted Regulations 2018/1999 on governance. The document sets general rules of planning, reporting and monitoring related to energy and climate policies and objectives. We consider it necessary to update the national goal on renewable energy to guidelines from the 4th Energy Package and reach 30% renewables in end-user consumption by 2030, on condition that renewables in electricity sector shouldn’t make up less than 30%.

  1. Strategic environmental assessment

Action Plan is a document of state planning, therefore under the Law of Ukraine «On strategic environmental assessment», this assessment must be applied to the consequences of execution of this document. Strategic environmental assessment allows to assess long-run outcomes and tendencies that will emerge after this document is passed. It is important to know the prognosed impact on air quality influenced by use of biomass, land use, increase of demand for certain resources etc. At the moment, neither the report on strategic environmental assessment, nor any information on assessment of NAP RES was published.

  1. Support for new strategies of RES development

Draft «National Action Plan on renewable energy sector till 2030» says that decentralized production of renewable energy makes up only 2,5% of all national renewables facilities. At the same time, EC’s 4th Energy Package, which is soon to be implemented in Ukrainian legislation within obligations on EU association, defines partitioned generation among the basic components of European Green Deal.

For now, the only way to support renewables power stations under 1 MW of capacity is «green» fee, which expires in 2030. But this is insufficient to strengthen private producers of clean electricity, especially when stable purchasers remain in debts for produced electricity.

We should support the development and implementation of guarantees for “green” electricity through establishing corporate РРА (power purchase agreement) and net energy billing. These tools are often used worldwide.

3.1 Solar energy sector: NAP RES till 2030 as a tool for discrimination, not a tool for developing solar energy sector

​​It is worth pointing out that draft National Action Plan till 2030 says nothing about ambitious growth of solar renewables share. A sharp difference when compared to policies that encourage to involve solar facilities in energy systems in the EU, the USA, China, Middle East, and Latin America. Energy transition without rapid development of solar energy sector turns out impossible.

For example, in countries of the EU, in 2021 alone there has been added 25,9 GW new solar facilities, and Poland alone in 2021 has built over 3,7 GW new solar power stations. China in 2021 has added about 53 GW solar power stations, and it is expected to reach 60 GW in 2022. These data prove that despite well-known myths and gossip it is absolutely technically possible to integrate large renewable facilities in power networks.

The proposed objectives for renewables in Ukraine by 2030 (+3 GW in solar sector), seem too insignificant when compared to above-mentioned figures, and so constitute rather an obstacle, not a stimulus to development. The actual refusal from developing solar energy sector will cause construction of decentralized facilities to stop, and prosumers will disappear. The seven-fold decrease in solar power stations construction in 2020-2021 in Ukraine has led to termination of high-tech branch and over 6 thousand vacancies, while state budget lost considerable income in form of taxes and fees.

It is important to emphasize that nowadays investments in green energy sector are the most justified ones. Investors’ behaviour proves this clause. Over 500 billion U.S. dollars yearly invested worldwide in renewables – number one among kinds of generation. Efforts to emphasize on other energy sources in NAP will worsen the condition of Ukrainian energy facilities, which are already critical, with obsolete generation capacities constructed mostly over forty years ago. Therefore, in the context of refusal from coal in electricity production by 2030-2035, development of green hydrogen capacities, reduction of dependence upon fossils import, we see it economically and technically justified to bring general net capacity of industrial and household solar power stations to at least 18 GW by 2030 (instead of 10 GW mentioned in NAP). They will be exploited on competitive basis and produce ecologically clean, climate neutral, decarbonized, renewable grid electricity, bearing no risks to emit pollutants into the air and provoke anthropogenic disasters like Chornobyl, which has resulted in diseases and deaths of 600 000 people.

It is good to stress that these very 18 GW solar power by 2030 are stipulated by plan of energy transition, proposed in a report on assessment of generating capacities, by distribution provider Ukrenerho.

  1. Bioenergy sector: the unsustainability of energy crops

Sustainability criterion is prior in development of new energy technologies. In other words, bioenergy sector should improve, not worsen the environment. State support for the branch must first and foremost stimulate recycling of agricultural and municipal organic waste (to biogas). In last year October European Environment Agency has presented guidelines[1] concerning ecological standards of energy technologies. According to these guidelines, energy crops are expected to have the highest pressure on land-use (surpassed only by some hydropower stations). We consider this branch non-privileged within development of bioenergy sector. Wood-working wastes will considerably decrease the pressure on arable lands, used for growing biomass.

Besides, solid biomass belongs to filthy energy technologies because of high sulphur oxides emissions, and sometimes shows even higher emissions of particulare matter than coal. This emphasizes the necessity of high-quality monitoring of environment and control over compliance with environmental legislation, either while designing and exploiting power stations.

  1. Waste incineration is not renewable

Wastes, unlike wind, sun or waves, do not emerge from continuous natural processes. They, on the contrary, result from finite resources like minerals, fossil fuels and forests unsustainably cut down. Incineration (even under brand new technologies) emits high-toxic substances like lead, mercury, dioxines, furans, into environment – if not into the air, then into water and soils after burial of ashes and unburned fractions.

Combustion plants waste a lot of multiple-used materials to produce only small amount of energy. Investments may be placed more effectively in environmentally clean and energy saving practices like prevention, reuse, recycling, and composting (according to Waste management ranking by Directive 2008/98/EU from European parliament and EU Council dated November 19, 2008). For example, Denmark has recently revealed that its waste combustion facilities emit twice as much CO₂, than it was anticipated. This is why the country has failed to achieve objectives of Kioto protocol on decrease of greenhouse gases emissions.

  1. Green hydrogen

We stand for development of purely “green” hydrogen energy sector (that is, production of hydrogen with help of renewable electricity only), after 2030, in the long run, on condition that renewable energy first and foremost comes into Ukrainian united energy system so as to decarbonize it. At the same time, criteria of sustainable water use must be set in order to avoid aggravation of water crisis.

Taking into account the fact that Ukrainian liabilities related to feed-in-tariff for green energy investors expires in 2030, it is reasonable to turn to active phase of green hydrogen production afterwards. In other conditions, the development of new energy branch that operates green electricity is economically non-viable and irrelevant.

  1. Sustainability criteria for small hydropower stations, updated procedure of assessment of environmental impact

In order to secure sustainable and safe environment we need to refuse from planning and construction of large hydropower stations and storage plants. In contrast to that we should exploit demand management and brand new technologies related to energy accumulation and transformation – electrochemical batteries, crane or shaft gravity power stations etc. Small hydropower stations, when needed, must be built only if they comply with sustainability criteria for energy facilities.

Construction of small hydropower station is possible in case of need, but only if it meets sustainability criteria for energy facilities, and particularly:

  • does not affect severely the existing ecosystem;
  • project life of a small hydropower station is at least 30 years;
  • there is developed program of environmental monitoring for small hydropower stations.
  1. Function of municipalities and flow of funds

The composers of NAP RES believe that it has nothing to do with functioning of local self-government, rights and interests of amalgamated hromadas, local and regional development, labour sphere, rights of handicapped, functioning and use of Ukrainian language. Yet local self-government bodies, population of cities, towns and villages play determining role in development of decentralized generation, use of renewables for heating and general understanding of significant role of renewables for the country.

Decentralization has brought municipalities the resources and obligations, and it is not to be neglected while planning the development of renewable energy sources. The following approaches help to unite efforts of national government and hromadas for developing renewables and have to be included in National Action Plan:

  • establishing criteria and stimuli for support of renewables while giving government subvensions to hromadas;
  • higher competence of local self-government bodies in renewables;
  • support of hromadas’ partnerships for shared development of renewable sector (supplies of sustainable biomass for heating, uniting municipal financial instruments, state-private partnership);
  • implementing efficient ways of involving hromadas and local self-government in composition of normative legal documents.
  1. Monitoring and reporting on NAP RES

Regular control upon implementation of plan and achievement of desired indicators allows to react to challenges in time and effectively, and adjust activity and plans. Public presentation on implementation process may help, if it is published every two years by April 1 of the year after report period. It must contain information about measures taken, anticipated and achieved results, detailed plans for the next report period.

  1. Harmonization with adopted normative legal documents

In Ukraine, there exists a number of normative legal documents, completed and under completion, that directly affect the development of renewables. They are Energy strategy, Action Plan on compliance with National contribution to Paris agreement, Integrated plan on climate and energy sector, branch plans and strategies. These documents have to conform to NAP RES.

We ask you to send your response to the mentioned facts in terms defined by Law of Ukraine «On claims from citizens» to address: 33014, Rivne, S. Bandery str., 41, room 95, and to e-mail:

Appeal supported by:

  1. NGO «Ekoklub»
  2. NGO «Center of environmental initiatives «Ecoaction»
  3. NGC «Ukrainian solar energy association»
  4. Coalition of NGOs and municipalities «Energy transition»
  5. NGO «Solar City»
  6. NGO «Pravopolis»
  7. NGO «Khmel’nyts’ky energy cluster»
  8. NGO «United Planet»
  9. NGO «SaveDnipro»
  10. NGO «Environmental office»
  11. Ukrainian climate network (35 nature protection NGOs from all over Ukraine).
  12. NGO «Ekosense»

Download letter>> Outg. №10 dated Feb 19, 2021_NGO Ekoklub (1)

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