On December 24, 2020, the Ukrainian Nature Conservation Group (UNCG) published its in-depth comments on the ‘Maritime Environmental Strategy of Ukraine’ draft . It will be recalled that this project was promulgated by the Ministry of Environmental Protection and Natural Resources of Ukraine on November 27, 2020  and after that it was criticized by ‘ARC’ experts who sent relevant system proposals to the authorities . It is noteworthy that the remarks of UNCG and of the Association are similar in direction.
In particular, the Ukrainian Nature Conservation Group notes that the draft strategy does not sufficiently address the issue of the attempted annexation of Crimea, the occupation of part of the Donetsk region and the obstacles created by Russia in Ukraine’s exploitation of the Azov and Black Seas. UNCG points out that the text of the strategy “positions Ukraine at the international level as a state that recognizes its helplessness” regarding Crimea and Donbas.
This leads, experts emphasize, to the fact that the Russian Federation conducts unauthorized economic activity in Ukrainian waters. Ukrainian scientists have also published research on the consequences of the construction of the Crimean Bridge, which could cause significant hydrological changes in the Sea of Azov and the subsequent extinction of its biodiversity. But the draft strategy does not take into account or describe these risks, so it cannot be implemented, UNCG scientists emphasize.
Therefore, the Ukrainian Nature Conservation Group emphasizes, that this document should analyze in detail all these risks and contain a description of Ukraine’s actions to overcome them, and not recognize the attempt to annex Crimea. UNCG also aptly states that the draft strategy avoids mentioning a number of Ukraine’s obligations under the Association Agreement with the EU, as well as a number of environmental agreements directly related to the Black and Azov Seas.
It should be noted that the Ukrainian Nature Conservation Group was established in 2014 as a team of specialists working on issues of practical nature protection. Since 2018, the environmental group has acquired the official status of a non-profit public organization. Currently, 6 doctors of sciences and 25 candidates of sciences are involved in the work of UNCG. The total assets of this organization’s members of are 35 own publications of the Ukrainian Nature Conservation Group and at least 1000 published articles in the field of protection and monitoring of biodiversity and protected areas.