A group of NGOs has addressed the Ministry for Development of Communities and Territories of Ukraine with a number of comments on the State Target Program for the Just Transition of Coal Regions of Ukraine until 2030. Activists emphasised the need to align the Program with European standards and avoid investments in fossil fuels.
According to the appeal, the Program lacks clear criteria for determining which projects genuinely relate to just transition. In their opinion, this creates the risk that any project in a coal region could be considered a transition project merely based on its location.
“This should not be just a set of infrastructure projects but a real tool for economic recovery and a just future for communities that have depended on coal for decades. We understand that working on the Program is not easy, especially in the conditions of a full-scale war, which is precisely why we want the document to be of the highest quality and genuinely effective,” said Anastasiia Bushovska, energy policy expert at Ecoaction.
The activists also emphasise that the Program allows for projects involving fossil gas, which contradicts EU requirements for just transition projects. Furthermore, the document lacks clear mechanisms for harmonisation with local just transition plans, does not foresee the stocktaking of closed mines, and does not outline measures for addressing the infrastructure after the closure of coal enterprises.
NGOs call for the development of a new mine closure procedure to replace the current standard, which they argue is outdated and does not meet environmental requirements.
The appeal was signed by NGOs Ecoaction, Luhansk Human Rights Center “Alternatyva”, Razom We Stand, Center for Anti-Crisis Research, Shield, Dobropillia Youth Centre “DOBRO”, and Ecoclub.
After the conclusion of public consultations, the Ministry is reviewing the submitted proposals, after which the Cabinet of Ministers of Ukraine is expected to consider the Program.
Background
Just Transition is a model of regional development that ensures a decent life and fair income for all workers and communities affected by the phase-out of fossil fuels (closure of production facilities, coal mines, and related enterprises).
The Ukrainian government plans to phase out coal use in electricity generation by 2035. Once this happens, challenges will arise in terms of employment, retraining of laid-off workers, and the broader future of coal communities. This is why it is important to have a state program at the national level that clearly defines how the just transition of coal regions should take place.
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Translated from Ukrainian by Ecoaction volunteer Elizabeth Kostiana.

