Vienna Programme Office Secretariat of the Carpathian Convention UN Environment Vienna International Centre Mr. Harald Egerer harald.egerer@un.org, klaudia.kuras@un.org , info@carpathianconvention.org Copy to: Ministry of Ecology and Natural Resources of Ukraine Mr. Ostap Semerak gr_priem@menr.gov.ua, nastiaparks@menr.gov.ua
Ukraine focal Point Mr. Serhij Gubar s_gubar@yahoo.co.uk 17th of December, 2018
Dear Mr. Egerer, With the regret we have to inform you, that Ukraine is violating provisions of the Framework Convention on the Protection and Sustainable Development of the Carpathians On behalf of Initiative Group Free Svydovets let me officially inform you that one of the a unique massifs of the Ukrainian Carpathian Mountains called Svydovets is now under threat. And consequently, Ukraine is violating provisions of the Framework Convention on the Protection and Sustainable Development of the Carpathians the articles 12 Environmental assessment/information system, monitoring and early warning and 12 bis Climate Change. Breaking the articles 21 (part 1, 3, 4) and 22 (part 1, 3, 4) and 23 (1, 3).of Protocol on Sustainable Tourism to the Framework Convention on the Protection and Sustainable Development of the Carpathians. Breaking the article 6 of Protocol on Conservation and Sustainable Use of Biological and Landscape Diversity to the Framework Convention on the Protection and Sustainable Development of the Carpathians done in Kiev on 22 May 2003. On May 2017, Rakhivska and Tyachivska Region State Administration take the decisions that allow to plan construction of a new ski resort on the territory of Svydovets without environmental impact assessment of such decision for the Carpathian region. On March 18th, 2018 Zakarpatska Oblast State Administration started the Ecological Impact Assessment for the creation of the new mega vacation-touristic complex “Svydovets” (hereafter “recreational complex”) on the Svydovets mountain range with a planned network of cableways, skiing piste, hotel infrastructure. This process is registered in the Unified Register of Ecological Impact Assessment (Registration number 2018314288). Documents are available here [6]. . Accordingly, Svydovets massif in the Ukrainian Carpathian is now a subject of a proposed megarecreational complex, offering recreation for more than 22 000 visitors per day. The total area of the recreational complex will cover 1430 hectares. 23 ropeways, 120 restaurants, 60 hotels, 390 cottages, 10 shopping centers, 17 rental equipment items, 2 bank branches, 3 fitness centers, 5
multi-storeyed parking spaces for 6000 cars, 230 km of ski tracks and 89.9 km of highways are planned to be built. That will destroy the biodiversity and ecosystems of this unique area. Nature conservation value of Svydovets The Svydovets massif is a home to wild mixed spruce and beech forests rich in flora and fauna. Three natural lakes are located within the massif. The massif is known for its high precipitation, about 1 400 mm per year. The source of the Tisza river, one of the region’s most important rivers and tributary of the Danube, is located here as well. As a consequence, the massif is of great importance for the hydrological regime of the Carpathians.
The Svydovets is a mountain range located in Western Ukraine. It is one of the highest ranges of the Eastern Carpathians, with 4 peaks higher than 1700 m a.s.l. and one peak higher than 1800 m a.s.l. More than half of all glacier lakes in the Ukrainian Carpathians (9 out of 17) are located there as well as one of the key components of the transnational UNESCO World Heritage site “Ancient and Primeval Beech Forests of the Carpathians and Other Regions of Europe.� The whole mountain range is a unique part of the Ukrainian Carpathians due to the high concentration of rare, red-listed, relict and endemic plant, animal and fungi species. The central part of the Svydovets mountain range and the upper part of the Chorna Tysa River are important for both the Ukrainian Carpathians and the entire Carpathian mountain system because they ensure the ecological stability of the region. 1. The territory of the massif is home for 42 plant species and 51 animal species listed in the Red Data Book of Ukraine [1, 2]. 2. In general, according to the minimum estimates, more than 500 hectares of highaltitude spruce, fir and beech old and virgin forests are concentrated on the territory of the recreational complex, which are especially valuable for conservation and are subject to protection in accordance by the Law of Ukraine about "Amendments to Certain Legislative Acts of Ukraine on the Protection of old-growth Forests". 3. On the territory of the "Central Svydovets", there are leaks of the transboundary Tisa River, which flows through the territory of 5 countries and is protected within EU Water Framework Directive and the Water Code of Ukraine. Natural objects of national (1) and international importance (2) 1. There is a number of protected areas on the territory of the Svydovets massif. In particular, the southwestern part of the massif belongs to the Carpathian Biosphere Reserve. 4 objects are nature protected areas of local and national importance: Smerekovi Carpaty forest reserve, Apshynetsky hydrological reserve, Bila ta Chorna Tysa ichthyological reserve and Stanislav botanical reserve. 3 more objects are natural monuments: Vorozheska hydrological natural monument, Gerezhaska hydrological natural monument, and Andromeda botanical natural monument. 2. The Svydovets is also a part of the Emerald Network, which is protected by international environmental treaties, including the Berne Convention [3] that is also ratified in Ukraine. As of November 2016, the Standing Committee of the Berne Convention approved 271 objects of the Emerald Network on the territory of Ukraine. In particular, there are 2 objects on the territory of the planned resort: Skhidnyi Svydovets [4] and Marmaroski ta Chyvchyno-Hryniavski Hory [5].
Threats 1. National level About 800 hectares have been earmarked for housing, commercial, economic and recreational infrastructure, including the area for engineering communications. It is planned to build several reservoirs with the total volume of 1,260,000 m³ to provide the necessary amount of water both for tourists and for the artificial snow production. Since the one-time snowfall of all ski runs will require at least 787 000 m³ of water, it can be assumed that these figures are significantly underestimated. According to the construction plan, up to 850 ha are earmarked for deforestation in the area. More than 300 ha of the planned clearcuts are located in the water protection zone and about 330 ha is at altitude above 1,100 meters, which should be protected by the Law of Ukraine “Moratoria for Clearcuts on Mountain Slopes in Fir-Beech Forests of the Carpathian Region”. Deforestation will increase the risk of soil erosion, flooding, and avalanche, land-slides, decreased water table and increased water pollution. 93 species listed in the Red Data Book of Ukraine and dozens of species of regional and international red lists will be threatened as a result of the project implementation. Building recreational complex will violate the requirements of national laws. Apshynetsky, Bila ta Chorna Tysa, Vorozheska and Gerezhaska protected areas are located directly on the territory of the potential resort. 2. International level Building of the recreational complex will have impact on the neighboursing countries. According to the research, about 6000 m³ of waste water will flow into the river Tysa daily, which flows through the territory of 5 countries and is protected within EU Water Framework Directive and the Water Code of Ukraine. Up to 5,800 m³ of sewage waters will be produced by the recreational complex daily, which will directly affect Bila and Chorna Tysa ichthyological reserve, which is also a part of "Marmaroski ta Chyvchyno-Hryniavski Hory" Emerald site. Building of the recreational complex will violate the requirements of international laws. Skhidnyy Svydovets and Marmaroski and Chyvchyno-Hryniavski Hory Emerald sites are located directly on the territory of the potential recreational complex. This complex will have direct impact on all protected territories mentioned above. There is already a statement from the government of Hungary, which demands inclusion of the European scientists to the group which will conduct an Environment Impact Assessment of the Recreational complex Project. The message that the area is the subject of a proposed mega-recreational complex has been also passed to the European Parliament. Numerous foreign organizations already officially expressed their concerns regarding threats of the future recreational complex to the Government of Ukraine. Climate Change The area is already suffering from climate change impacts (floods, intensive precipitation, droughts, etc.), therefore building of the recreational complex and accompanying infrastructure will further influence the frequency and strength of these disasters.
With warming temperatures and shifting precipitation patterns, building a new recreational complex, offering skiing in such a low altitude (1700m) is neither a sustainable nor profitable effort. Even Austrian ski resorts, mostly located in altitudes between 1500m and 3000m, increasingly struggle. The irregular and decreasing snowfalls make artificial snow production necessary for most ski resorts to operate. However, the high amounts of water necessary to guarantee operational resorts all winter often lead to empty water reservoirs already in January. As a result local water shortages happen more often. Soil compaction causing erosion and a change of vegetation are other consequences of the preparation of slopes. Regional development Of course the economic situation of the region should also be considered, as the local population is currently experience high unemployment rates. However the recreational complex will not solve the problem of unemployment, and the majority of profits will go to a few investors rather than the local community. Instead, small family businesses and local traditional economy, including green tourism should be supported. Ministry of Environment and Natural Resources of Ukraine approved the Scientific substantiation of creation of protected area on the territory of Svydovets massif, called Landscape Reserve (zakaznik) of National importance “Central Svydovets” [1]. But for several month no further steps were taken for creation of the protected area. We insist that such large-scale anthropogenic impact on these territories that include unique habitats of rare, endemic, relict and arctic-alpine species of flora and fauna is inappropriate. In accordance with Article 8 (paragraph 2), Article 12 (paragraph 2) and Article 9 (paragraph 2) of the "Protocol on the Conservation and Sustainable Use of Biological and Landscape Diversity to the Framework Convention for the Protection and Sustainable Development of the Carpathians (dated May 22, 2003)", we suggest that the territory of the central part of Svydovets mountain range should become a protected area, which will ensure the сonservation of endangered species and habitats here. There are three scenarios that we support: either create here a Landscape Reserve (zakaznik) of National importance “Central Svydovets” (IUCN category IV), as suggested by Kagalo et al (2018) [1], include this territory to the Carpathian biosphere reserve (IUCN category II), or create here National nature park (IUCN category II). A less desirable scenario would be creating a regional landscape park on this territory. This status gives only formal or “paper” protection for the ecosystems and species, and therefore may be used by the investor as a trick to build a recreational complex or ski resort and to formally comply with the request of the nature conservationists.
Resolution Considering all abovementioned, we would like to ask the Secretariat of the Carpathian Convention and its Parties to consider and communicate an issue of Svydovets threats and to: -
Consult Ukraine on non-admission of further violence of the Carpathian Convention Protocols.
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Support establishing of the conditions and criteria, including relevant remedial and compensatory measures, under which projects of new ski resorts and similar recreational complexes may be authorized for construction in Carpathians, particularly at the territory of Svydovets.
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Support proper conduction of the Environment Impact Assessment of the recreational complex “Svydovets�.
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Make recommendations about conditions of ski resorts or recreational complexes building in the Carpathians in accordance to the Protocols of Carpathian Convention.
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Recommend and support further development, with the support of the TRANSGREEN project and possible other on-going or future projects, the Carpathian Countries Integrated Biodiversity Information System (hereinafter CCIBIS), as an information system accessible to all the Parties, collecting vailable data sets, information on local and regional administrations, outcomes of projects and other relevant data esspecialy at Svydovets isseus.
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Support, initiate and advice alternative to huge recreational complex sustainable regional development projects on the territory of Rakhiv and Tyachiv regions.
For further information please contact us: +38 067 320 19 69 or free.svydovets@gmail.com Initiative group FREE Svydovets
References [1] Kagalo A., Kanarsky Y., Mykitchak T., Kovtoniuk O., et al. Nature conservation value of the central Svydovets Mountains (Ukrainian Carpathians) // Bulletin of the Taras Shevchenko National University of Kyiv. Geography 1 (70). 2018. - P. 35-48.Available here: https://wildernesssociety.org/wp-content/uploads/2018/04/Svydovets_Application.pdf [2] Red Data Book of Ukraine: Plant Kingdom (2009) ed. by Y. P. Didukh [in Ukrainian], Globalkonsalting, Kyiv, pp. 900 [3] Council of Europe (2014) Convention on the Conservation of European Wildlife and Natural Habitats – Resolution No. 4 (1996) listing endangered natural habitats requiring specific conservation measures (Adopted by the Standing Committee on 6 December 1996) and Revised Annex I of Resolution No. 4 (1996) (1996) (Adopted by the Standing Committee on 5 December 2014) [4] http://natura2000.eea.europa.eu/Emerald/SDF.aspx?site=UA0000259 [5] http://natura2000.eea.europa.eu/Emerald/SDF.aspx?site=UA0000117 [6] http://eia.menr.gov.ua/places/view/288