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On November 5, 2020, the Cabinet of Ministers of Ukraine submitted to the Verkhovna Rada of Ukraine a draft law «On Amendments to Certain Laws of Ukraine Concerning the Regulation of Issues Related to Prisoners of War and Internees During a Special Period.»

Charitable Fund Right to Protection draws the attention of the subject of the legislative initiative and legislators to the fact that the provisions of this bill apply not only to prisoners of war, but also to foreign civilians who are on the territory of Ukraine, and therefore considers it necessary to provide analysis of the bill in this aspect.

The essence of the bill

The draft law was developed by the Ministry of Defense of Ukraine to ensure the implementation of Ukraine’s international obligations regarding the detention of prisoners of war and internees during a special period.

It implements changes and additions to the following laws of Ukraine: «On the Security Service of Ukraine»;  «On local self-government in Ukraine»;  «On local state administrations»;  «On the Armed Forces of Ukraine»;  «On the Defense of Ukraine»;  «On the Military Law Enforcement Service in the Armed Forces of Ukraine»;  «On the legal status of foreigners and stateless persons»;  «On the National Guard of Ukraine»;  «On the National Police».

According to the text of the draft, internees are persons who have been interned (forcibly settled in certain places by citizens of a state that threatens to attack or carry out aggression against Ukraine, who are on the territory of Ukraine, if it is absolutely necessary to ensure national security of Ukraine).

 «After the draft law №4327 was registered, our beneficiaries began to ask for explanations as to whether certain provisions of the bill violate their rights. In the process of analysis, we found that their fears are not unfounded, because the draft does not contain a clear internment procedure and possibility to appeal if such a decision wa made, »

– said Svitlana Butenko, senior lawyer for strategic litigation at Right to Protection CF.

Risks for refugees, persons in need of additional protection, asylum seekers

1. The Ministry of Defense states in the Explanatory Note to the draft law that the draft law does not contain provisions that could lead to  violation of the rights and freedoms guaranteed by the Convention for the Protection of Human Rights and Fundamental Freedoms (hereinafter – the European Convention), affect equal rights and opportunities for women and men, contain risks of committing corruption offenses and offenses related to corruption or create grounds for discrimination.

However, the Right to Protection CF considers it necessary to point out that certain provisions of this draft law that may violate the rights and freedoms guaranteed by the Constitution of Ukraine and the Convention for the Protection of Human Rights and Fundamental Freedoms.

In particular, it violates the right to liberty and security of person, guaranteed by The Constitution of Ukraine and Article 5 of the European Convention; the right to privacy provided for in Article 32 of the Constitution of Ukraine and Article 8 of the European Convention; the right to freedom of movement provided for in Article 33 of the Constitution of Ukraine and Article 2 of Protocol № 4 to the European Convention, and also violates the guarantees established in Articles 35, 43 and 44 of the IV Geneva Convention.

In addition, the provisions of the draft do not comply with the principle of legal certainty, i.e. are not clear, accessible and predictable for law enforcers, which contradicts the European Convention on Human Rights in its interpretation by the European Court of Human Rights.

 2. The draft significantly expands the powers of the Security Service of Ukraine, the National Police of Ukraine and the Armed Forces of Ukraine to identify citizens who pose a threat to Ukraine’s national security or threaten to attack or carry out aggression against Ukraine, as well as to make decisions on their internment. 

The unlimitedness of these powers in time, space, and the application of a sufficiently broad wording to the range of persons to whom it may be applied poses a threat of arbitrariness. This position is shared by UNHCR, as stated in the Thematic Legislative Update for November 2020, prepared on the basis of a legal analysis of laws and public policies concerning refugees, asylum seekers, stateless persons, internally displaced persons and victims of conflict in Ukraine.

The draft does not define a clear procedure for deciding on the internment of a person. In particular, it does not stipulate that such a decision is made for each person individually.  This is contrary to Article 75 of the Additional Protocol to the Geneva Conventions of 12 August 1949, relating to the Protection of Victims of International Armed Conflicts (Protocol I) of 8 June 1977, which prohibits collective punishment of persons under the authority of a party.

3. The draft does not provide a definition of persons who “pose a threat to the national security of Ukraine” and does not guarantee that a person is informed of the reasons for his or her internment, as expressly provided in Article 75 of Protocol I. This significantly limits ability to appeal for  such a person.

Failure to comply with the principle of legal certainty in the project may lead to the fact that the above exclusive powers of public authorities may be applied to an unlimited number of citizens of the Russian Federation who are in Ukraine, including refugees, persons in need of additional protection, asylum seekers.

The draft law does not contain any safeguards against the internment of civilians who are refugees or persons in need of additional protection or seekers of protection, which is directly contrary to the provisions of Article 44 of the Convention for the Protection of Civilian Persons in Time of War of 12 August  1949 (IV Geneva Convention).

Persons who may be interned under the requirements of this draft law, contrary to the safeguards and guarantees provided for in Article 35 and Article 43 of the IV Geneva Convention, are not protected by the right to leave the country at the beginning and during the armed conflict or by immediate judicial review (and subsequent  review at least twice a year).

At the same time, the draft proposes to supplement the grounds for banning the departure of foreigners or stateless persons from Ukraine, provided for in part two of Article 22 of the Law of Ukraine «On Legal Status of Foreigners and Stateless Persons» with the paragraph “on internment decision – until revocation of internment decision”.

 4. The draft law provides for amendments to Article 11 of the Law of Ukraine “On Defense of Ukraine”, according to which an internee has the right to appeal the decision on his / her internment in the manner prescribed by law.

Given that internment is a special procedure, the appeal of the decision should also have certain features, such as a reduced period of consideration of such cases and their appellate review, compared to other categories of cases.  

Therefore, the bill should contain relevant provisions on the procedure for appealing such a decision. However, those provisions are absent in the text of the draft law. Given this, such an approach may contradict the provisions of Articles 55 and 124 of the Constitution of Ukraine, which guarantees the right to appeal in court against decisions, actions or omissions of the authorities, as well as to extend the jurisdiction of the courts to any legal dispute.  

Despite the general rules on the right to appeal contained in the text of the bill, the law in this case should provide for an appropriate appeal procedure with its features if necessary, which in turn will guarantee the realization of the internee’s right to a fair trial.

However, the final and transitional provisions of the bill also do not contain relevant proposals for legislative changes. Therefore, even if the internee has the right to appeal, he or she will not be able to use it in the absence of the necessary simplified procedure.

The absence of relevant provisions in the text of the bill does not allow for judicial control over the decisions of public authorities – the General Staff of the Armed Forces of Ukraine and the Security Service of Ukraine, even if decisions are made in a special period. This contradicts Article 64 of the Constitution of Ukraine, the constitutional right of a person and a citizen to appeal provided for in Article 55 of the Constitution of Ukraine may not be restricted in a state of war or emergency.


Given the risks outlined above, the purpose of the project is to implement the Geneva Convention on the Protection of Civilian Persons in Time of War, which seeks to protect a certain group of persons and begins when, in the event of a conflict or occupation, a person finds himself under the authority of a party to the conflict or of an occupying State of which he or she is not a national. This purpose is not reached in this draft law.

In this regard, we empasize that the draft must be brought in line with Ukraine’s international obligations under the Geneva Convention concerning to the Protection of Civilian Persons in Time of War. Based on this, the Right to Protection CF provides the following recommendations for finalizing the draft law № 4327:

1. Refugees, persons in need of additional or temporary protection, asylum seekers should be excluded from the scope of regulation of this draft law.

2. The draft law should be supplemented by the guarantee to be able to freely leave the territory of Ukraine by the persons who are subject to internment at the beginning and during the armed conflict as an alternative to internment.

3. The draft law should be accompanied by a clear definition of «a person who poses a threat to the national security of Ukraine» and guarantee the individuality of the decision to intern persons and properly inform such a person about the reasons for his or her internment.

4. The draft law should be supplemented by the procedure of urgent judicial control on the legality of the application of internment of persons (to be performed at least once every six months) with the possibility of appeal.

UNHCR Ukraine – Aгентство ООН у справах біженців в Україні

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The Mentoring Program of the Centre for Democracy and Rule of Law (CEDEM) had just recently ended, but no one said it won’t start again! Today, on February 25th CEDEM launches it’s Mentoring Program 2.0. Anastasia Odintsova, advocacy lawyer at R2P was a mentor in the first program and will participate in the second one. Here is what she says about her first mentees from the NGO «Women’s Initiative Foundation»:

Анастасія Одінцова: про менторський досвід, навчання інших та маленькі кроки для великих змін Anastasia Odintsova tells about her mentoring experience, teaching others and small steps for big changes

«During my participation in the first program, I got extraordinary mentees – Halyna Tatarenko and Olena Arsentieva, who are not only members of the NGO, but are also internally displaced persons. They work and teach at Volodymyr Dahl East Ukrainian National University (this university moved from Luhansk to Severodonetsk). They both have a common goal: to provide access to higher education to the people with disabilities and limited mobility in the Luhansk region in the shortest term possible, and later – implement it throughout Ukraine.»

«The program has been a great start for this.  During its implementation goals were identified and most importantly, the steps to achieve these goals were drawn. At the moment, I have joined my former mentees in developing a National Strategy for Creating a Barrier-Free Space in Ukraine, and we are already working there as equal partners and changing our country for the better,» – says Anastasia Odintsova.

Halyna Tatarenko is also optimistic on this matter:

 «After the program, we have already participated in the All-Ukrainian scientific-practical conference «Interaction of international and national law through the prism of globalization and integration» where the results of the mentoring program were presented. In the spring we will present an Analytical Report on ensuring the rights of people with disabilities and low mobility groups to access higher quality and professional higher education in the Luhansk region, which will contain recommendations to overcome the existing problems.»

In the near future, new cooperation with new mentees will begin and it will be no less interesting and socially useful.  You can find more information on our Facebook page and on the CEDEM page.

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In Ukraine, it is forbidden to deport, extradite, or forcibly return not only refugees, but also persons who have applied for international protection (asylum seekers)!

It is a safeguard to protect against threats to life, liberty or torture in the country of affiliation.

«In legal consultations we share with lawyers and attorneys our vast experience in protecting asylum seekers who have faced the extradition check in Ukraine. We emphasize that everyone should have access to the migration procedure in Ukraine, and extradition checks should be carried out exclusively in accordance with law,»

– said Svitlana Butenko, strategic lawyer at Right to Protection CF.

More information on how to prevent the extradition of asylum seekers can now be found on the legal consultations platform WikiLegalAid. In the new material, our lawyers described in detail the legal regulation and practical aspects of the extradition of asylum seekers in Ukraine.

We offer lawyers and human rights activists to use this material in their practice as well!

UNHCR Ukraine – Aгентство ООН у справах біженців в Україні



Statelessness is a multifaceted problem. Even people who are legally citizens of Ukraine have no opportunity to practically exercise most of their rights without documents.

We have repeatedly told the stories of people who failed to replace Soviet passports, or were simply not issued a passport for some other reason. The story below is about the importance of timely updating the documents, because a passport with outdated information is not considered valid. Sometimes however as in such a situation, it is simply not possible to timely update the documents.

Our beneficiary Natalia was born in Shakhtarsk, Donetsk region of Ukraine. There she married and had a child. After marriage, she changed her last name, but she never managed to get a passport with a new last name. The conflict in eastern Ukraine, which began shortly thereafter shifted all the plans. Despite her young age (Natalia was only 22 at the time), she had to move to Russian Federation.

In 2020, the girl was finally able to return to Ukraine. She really wanted to see her family. However, updates to the passport were needed in order to be able to enter Non-Government Controlled Areas. 

After applying to the State Migration Service of Ukraine to exchange her passport in connection with the change of surname, Natalia was refused due to lack of documents. In fact, the only passport she left with was marked as «subject to exchange».

Not having the confidence and understanding how to solve such a difficult issue, Natalia turned to the Right to Protection CF for help. The time was short. Back then the girl lived with people who were not indifferent to her situation and helped her out of pity. But the problem was that at any moment she could have been asked to leave the house where she temporarily lived. There was a risk of being left without housing and livelihood at all.

«Above all, I dream to see my family!»

– said Natalia.

The Fund’s lawyers analyzed the documents which the beneficiary had and made appropriate requests for additional information. Subsequently, a birth certificate and a marriage certificate were obtained. Eventually, Natalia replaced her passport. Her dream to see the family has finally come true!

паспорт щоб побачити рідних passport to see family

UNHCR Ukraine

United Nations High Commissioner for Refugees in Ukraine

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On the February of 18th and 19th Right to Protection CF team held two online webinars on Protection Mainstreaming Bakhmut district public servants. 

Відбулись онлайн семінари зі зменшення ризику катастроф для чиновників Бахмутського району R2P held webinars on risk vulnerability reduction for Bakhmut district officials

Representatives of Intensive Care Hospitals, Social Protection Service, Child Protection Departments participated in these webinars. In addition, representatives of amalgamated hromadas (Zvanivka and Siversk) attended the webinars. 

Main focus of discussions was set on improvement of coordination in order to protect and prepare the most vulnerable groups in the communities for the potential natural and industrial disasters risks in the region. The key feature of these webinars is that those are focused not only on talks but to find actual solutions to the existing problems.

During the webinars such question were raised and discussed:

  • How to protect schoolchildren during an emergency? 
  • How school psychologists might be integrated in emergency response activities?
  • What might be the role of starostas (village leaders) in an emergency context?
  • How interaction between humanitarian actors and health workers might be improved?

«Reducing Risk Vulnerability in Eastern Ukraine» Project is funded by USAID – US Agency for International Development (in particular, by its USAID’s Bureau for Humanitarian Assistance, BHA), and has been implemented since 2019 by 3P Consortium led by ACTED Ukraine.

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In December 2020, the Verkhovna Rada of Ukraine adopted in the second reading and as a whole the draft Law of Ukraine «On the State Budget of Ukraine for 2021». This law has already entered into force. 

So, what exactly changed in the context of protection of the rights of internally displaced persons (IDPs) and victims of an armed conflict? 

Here are the key differences:

  • Funding for the state program for the payment of monetary compensation to victims whose houses (apartments) were destroyed as a result of a military emergency caused by the armed aggression of the Russian Federation has been increased to UAH 114 million.
  • Subventions from the state budget to local budgets for the implementation of measures to support the territories affected by the armed conflict in eastern Ukraine have been increased to UAH 125 million.
  • A new state program has been introduced to ensure proper conditions for entry and exit of persons to the temporarily occupied territories of Ukraine – UAH 267 million.
  • A new state program has been introduced to ensure the reintegration of young people from the temporarily occupied territories of Donetsk and Luhansk oblasts, the temporarily occupied territory of the Autonomous Republic of Crimea and the city of Sevastopol – UAH 130 million (although such a program appeared only between the first and second readings).
  • There is no funding for the state program «Affordable Housing» (it was reduced by the April changes to the state budget for 2020 and will not be renewed in 2021).
  • There is no funding for subventions from the state budget to local budgets for the implementation of the project «Housing for Internally Displaced Persons».
  • There is no funding for a program to provide mortgage loans to internally displaced persons.

Full details – in the table.

UNHCR Ukraine – Aгентство ООН у справах біженців в Україні

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On February 17, within the conference «Bridge the Gap: Environmental and Industrial Risks in eastern Ukraine», representatives of the Right to Protection CF held thematic panel discussion «Environmental Monitoring for national risk-oriented approach».

Representatives of the State Emergency Service of Ukraine, Members of Environmental Committees and Departments, ecologists and experts, as well as the elected representatives took part in the event.*

During the discussion, current problems in the field of environmental monitoring and the issues of legislative regulation of this area were actively discussed. The event also presented the results of a study conducted by the Right to Protection CF regarding the level of awareness of the population in the settlements of Donetsk region (Government-Controlled Areas) about environmental and industrial risks that exist in their places of residence.

The topic of environmental monitoring was chosen as a starting point for the second day of the conference and included discussions on environmental and disaster risks prevention. 

After all, monitoring is the basis of a risk-oriented approach, it is a chance to predict and prevent serious environmental disasters.

«As my colleague Artem Krenbok remarked, in medical terms, monitoring is a diagnosis of the disease. If we do not have the data on the condition of the whole organism, we can not prescribe proper treatment,»

– said the moderator of the event, legal analyst at R2P Anastasia Bondarenko. 
«Bridge the Gap: Environmental and Industrial Risks in eastern Ukraine» conference. Day 2. Panel disussion Anastasia Bondarenko

The lack of a nationwide industrial and environmental risk monitoring system means complete lack of information on the general state of the ecosystem, thus making it impossible to fully and effectively use a risk-oriented approach.

According to Anastasia Bondarenko, back in 1998 Ukraine launched an environmental monitoring system which then should have been implemented, but as of now only some of its elements are functioning.  

«We monitor surface waters, in some cities – air monitoring is available, but these elements do not allow us to create a broad picture of what is happening to our environment. We do not monitor industrial risks. Common knowledge is that Donetsk and Luhansk regions have the biggest concentration of industrial objects, and we can only guess what is happening there because of the moratorium on inspections of the enterprises.»

– said Anastasia Bondarenko. 

This thesis was confirmed by Lesya Vasylenko, MP, head of sub-committee of climate changes, and Air Protection of the Committee of the Verkhovna Rada of Ukraine on Environmental Policy and Nature Management

«Risk assessment system in Ukraine is somewhat outdated, and a risk-oriented approach is not the basis for implementation of the concept of “environmental safety”. According to the current law, environmental safety is interpreted as a factor that affects the well-being and human life, and this is true.  But we must keep in mind that the world is moving forward and we, together with the whole world, are experiencing the consequences of climate change, so it is not enough to think of the environment as a space consisting only of humans and everything necessary for their life & well-being»

– commented Ms. Vasylenko. 

Currently, there are discussions at the level of the Ministry of Environmental Protection and Natural Resources of Ukraine on the development of a state concept of adaptation to climate change.  According to Ms. Vasylenko, this concept includes a risk-oriented approach to how environmental safety will be determined through the prism of risk reduction.  

«We discussed with you last year on this matter and I can already say that we will recommend the government and the Verkhovna Rada to consider amending the law, which will remove restrictions on monitoring in areas where hostilities are taking place,»

– said Lesya Vasylenko. 

Petro Kropotov, Chief Specialist of the Department of Emergency Prevention of the State Emergency Service (SES) of Ukraine also stressed the need to make changes to the state system of environmental monitoring.

«Bridge the Gap: Environmental and Industrial Risks in eastern Ukraine» conference. Day 2. Panel disussion Petro Kropotov

He noted that in accordance with the Code of Civil Protection, there is a single state system of civil protection that exists and operates in Ukraine. One of its subsystems is called “Environmental Monitoring”, and the Ministry of Environment Protection and Natural Resources is responsible for it. It is its representatives who carry out hydrological and atmospheric air monitoring, but this current mechanism has long been in need of revision.

«In January 2014, the government approved the concept of managing the risks of emergencies of industrial and natural kind and later adopted the plan for its implementation. SES of Ukraine together with other governmental bodies and the National Academy of Sciences carried out these measures. We have developed a basic document that should be approved – “Regulations on the organization of risk management”, but first the amendments to the Code of Civil Protection are needed. At the same time, SES is being reformed and we are moving to a risk-oriented approach to state supervision and control.»

– said Mr. Kropotov.

The same measures aimed at enterprises that may pose a potential environmental threat are implemented by other supervisory authorities.  And this is right, because according to the representative of the SES, the risk should be paid by the person who creates it. In fact, if an entity creates a risk, it should pay to minimize it, and the state should control it.

«The SES has also developed a draft resolution “On the functioning of the system of monitoring and forecasting of emergencies of industrial and natural kind”. We have also been working on the establishment of the Emergency Monitoring Center, but the events in the east have reshaped all government spending.  So now we are considering the possibility of monitoring and forecasting by the State Center for Emergency Management.  However, it also needs modernization.»

– said Petro Kropotov.

According to Vladyslav Alekseev, Head of the Office of Regulatory Policy and Ecological Expertise of the Agency of Nature Reserves, Forestry and Regulatory Policy of the Department of Ecology and Natural Resources of the Donetsk Regional State Administration of Ukraine, the current environmental monitoring system in the Donetsk region is an open information system. The priorities of its functioning are the protection of vital ecological interests of man and society.

«System includes 7 stationary posts and 2 mobile laboratories for monitoring and control of atmospheric air, 50 compact air quality stations on the border of sanitary protection zones,»

– said Mr. Alekseev.

Ganna Cherkasova, Main Ecologist of Toretsk city, also spoke about improvements in the field of environmental monitoring in the Donetsk region.

«There was a big step forward in this direction. We received sensors that work online. Therefore, the population now has wide access to all monitoring data, which has never been the case before. Previously, there were only a few inquiries and appeals, but now people can go to the site at any time of day and see the real time picture. In addition, the Smart City application was recently developed in Toretsk, thanks to which everyone can access information that is constantly updated and ask questions to the specialists.»

«At the same time, we have serious problems that prevent us from implementing the necessary environmental protection. This includes the inconsistency of legislation (because regulations may contradict each other or exclude each other, or be very general) and the intersection of powers of different bodies and services,»

Ms. Cherkasova said.

In addition, the issue of regional environmental funds remains unresolved, making it impossible to compensate for environmental damage. The lack of specialists also remains a problem.

«Monitoring is a big step for me as an ecologist, but I would like to understand: if there is monitoring, then we must have tools to respond to certain situations, if there are programs, then funding should be provided, if there are accidents and there is damage to the environment, we must determine guilty and reimburse damages, if the inspection can not come to us, then the authorization to perform such an inspection must be transferred to the local state representatives,»

– said Anna Cherkasova.

* Panelists: Petro KropotovState Emergency Service of Ukraine, Chief Specialist, Department of Emergency Prevention; Lesya Vasylenko – MP, head of sub-committee of climate changes, and Air Protection of the Committee of the Verkhovna Rada of Ukraine on Environmental Policy and Nature Management; Serhii Natrus – Donetsk Oblast Administration (Environmental Department), Director of Environmental Policy Directorate; Ganna Cherkasova – Main Ecologist of Toretsk city; Serhii TretyakovAnastasia Bondarenko – Legal Analyst at R2P (Event facilitator).

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Experts of the Right to Protection CF (R2P), within the framework of the Prepare Prevent Protect (3P) Consortium (ACTED, IMPACT Initiatives, R2P, the Danish, Austrian and Ukrainian Red Cross Societies) prepared a report on phone-based survey of the population on the awareness of disaster risks in Donetsk and Luhansk regions.

Survey was conducted from December 2020 till January 2021 on the Government Controlled Areas of Ukraine (GCA) as a part of the project «Reducing Disaster Risk Vulnerability in eastern Ukraine». The main purpose was to screen the population’s awareness on environmental/industrial risks that exist in Donbas. Respondents living in Popasna, Yasynuvata, Volnovakha, Bakhmut districts and in the city of Toretsk were involved in the study.

Звіт про телефонне опитування «Зменшення вразливості до ризику катастроф у Східній Україні» «Reducing Disaster Risk Vulnerability in eastern Ukraine». Report on phone-based survey

During the project implementation, significant gaps in the disaster risk management system at all levels in Donetsk and Luhansk regions were identified, namely:

  • Lack of a national environmental monitoring system, including a system covering regular monitoring of groundwater, chemical composition of mine water, water level in mines and soil pollution;
  • Low level of public awareness of risks and, as a consequence the low level of risk resilience. In communities along the line of contact, the population remains poorly informed about the main industrial and natural risks in the region.

Survey is available in .pdf format:

The survey was made possible with the final support of the European Union through its Directorate-General for Civil Protection and Humanitarian Aid (ECHO). Document covers humanitarian aid activities funded by the European Union.

The views expressed in this document should in no way be taken as an official opinion of the European Union, and the European Commission is not responsible for any use of the information contained therein.

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What’s the quality of the water we use? How safe is it for our health? These questions should be answered with the use of data from the state water quality monitoring, the procedure of which was approved by the Cabinet of Ministers of Ukraine back in 2018. However, there’s still no state monitoring program.

Anastasia Bondarenko, legal analyst at the Right to Protection CF, commented on this

Анастасія Бондаренко якість води water quality

«Ukraine is actively developing a water quality monitoring system. Surface waters are the main source of drinking water in many regions of Ukraine (for example, in Donetsk and Luhansk regions, where its sources are the Siverskyy Donets and groundwater). Surface water monitoring programs in accordance with European standards are successfully implemented by the Siversko-Donetsk Basin Administration. But as the workers themselves admit, not all water sources have enough equipment and funding is provided mainly through international support programs. But the situation with groundwater monitoring is much worse.»

According to the State Ecological Academy of Postgraduate Education and Management and the implementing organization OpenAccess Environment, which was responsible for the implementation of the «Open Environment» program of the on-site water quality and level of groundwater monitoring. In November 2019 the submission of information must have started as a part of the water quality monitoring system but as of now it is still in development.

Significant percentage of the water supply in both regions was damaged by hostilities. According to the expert, wells remain the only source of water supply for many locals. Most mining towns and villages are located directly above the clearing. Therefore, the chemical composition of water in wells is affected not only by the composition of mine water but also by their level.

Якість води на Донбасі Water quality Donbas

Unfortunately, we have to state that systematic monitoring of mine waters is not carried out at the moment. The situation is particularly difficult in cities associated with mines that are flooded in Non-Government Controlled Areas of Ukraine, such as Zolote and Toretsk. 

Enterprises located in the controlled territory, according to the state account of water use, only in Donetsk region in 2019 carried out dumping of mine and quarry waters to surface water objects of the Kazeny Torets river basin (Siverskyy Donets river basin) in volume of 17.05 million square meters without quality category. And this is only the data on 10 coal industry enterprises.

water quality якість води

According to the State Institution «Donetsk Regional Laboratory Center of the Ministry of Health of Ukraine» in 2019 they have conducted 11860 studies of drinking water quality from the decentralized water supply for sanitary and chemical indicators. Deviations from sanitary norms – 16.7% (against 12.6.0% for the same period last year) out of more than 11828 studies of drinking water of decentralized water supply for nitrate content. Deviations from sanitary norms – 46.1% (against 11.6% for the same period of the last year) due to decrease in research against last year’s level.

«The consequences of the lack of water quality control, the inability to promptly and adequately inform the public about the state of technical and drinking water as well as the threats to the use of such water for health violate the rules of Art. 50 of the Constitution of Ukraine, which stipulates that everyone has the right to a safe environment for life and health and guarantees everyone the right to free access to the information on the state of the environment, the quality of food and household items,»

– sums up Anastasia Bondarenko.

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