The Open Letter
ABOUT THE CHANGING THE FUNCTIONAL ZONING OF THE DANUBE BIOSPHERIC RESERVE BY THE
GOVERNMENT OF UKRAINE
It has become known, that on October 25 the Ukrainian government is going to present
UNESCO the new zoning plan and the Project of the territory organization and
protection to the natural complexes of Danube biospheric reserve.
The given changes in the functional zoning of the Danube biospheric reserve was
conducted pursuant to the Council Of National Safety And Defense of Ukraine decision
of June 6, 2003 and to fixed it the Decree of the Ukraine President of June 10, 2003
"About the Council Of National Safety And Defense of Ukraine decision of June 6, 2003
"About a condition of fulfilment of the Decree of the Ukraine President of August 10,
1998 N 861 "About creation of the Danube biospheric reserve " and prospect of the
shipping way Danube-Black Sea construction". It was called by The Ukraine Transport
Ministry aspiration to build the navigation channel Danube-Black Sea just through the
Bystre estuary, Danube biospheric reserve.
On a moment of the set forth above documents acceptance the Bystre estuary was
entered in the absolutely reserved zone of the Danube Reserve, it was transferred in
the zone of anthropogenous landscapes by the Ukraine Prezident Decree of February 2,
2004 "About expansion of the Danube Reserve territory with out of necessary
The development of new zoning plan and Project of the territory organization was
conducted by the Ukrainian research institute of ecological problems, which is
subordinated to the Ukrainian ministry of ecology and natural resources.
October 6 - 8 this year the Ukrainian Government promised to the Official delegation
of the European commission to conduct with a public the dialogue concerning a
building of a channel Danube- Black sea pursuant to the national legislation and
rules of the Aarhus Convention. The Ukrainian government has infringed this promise:
the changing of the Danube reservation zoning was conducted secretly, with out of the
Characteristically, the deputy of the State reservation service (Ukrainian
Ministry of ecology and natural resources) chief mr. S. Komarchuk gave these promises
such as other authorities. This man should present the Project of the territory
organization of the Danube Reservation in Paris.
Our organization sent 4 letters concerning granting to the representative of
ecological group Pechenegy of an opportunity to take part in consideration of this
documentation: 3 letters was sent to Ukrainian research institute of ecological
problems, 1 to the Ukrainian ministry of ecology and natural resources. First letter
was sent on July 12, 2004. The answer was dated by July 23, 2004, in the letter the
acting as director of institute mr. G.D. Kovalenko asked us to give clarifications
concerning the "documentation we wanted to be acquainted.
Such clarifications was sent by us to the Institute on July 31, 2004. But it was
not answered. September 11, 2004 we had repeat the letter, and write that having not
answered on our reference the officials from the Institute have infringed the
legislation about the citizens references. We have warned, that in a case of ignore
the further our letters, we shall be compelled to protect rights in the judicial
order. As a reply to this reference we have received the letter from mr. G.D.
Kovalenko (wrote on September 20, 2004), there was specified, that, pursuant to the
agreement, using of the materials required by us (we requested it, to participate in
preparation of the Project of territory organization) is possible only by the
Customer consent. The letter s author has suggested to address in the appropriate
territorial bodies of the Ukrainian Ministry of ecology and natural resources. So we
did not take an answer on our questions.
Taking into account a modern general orientation of this Ministry activity, and the
available information on the Project of the territory organization and the natural
complexes protection of the Danube reserve, developed by Ukrainian research institute
of ecological problems, we have great basis to suspect that such changes will be
introduced in the new zoning plan:
1) All internal reservoirs and (or) channels will be withdrawn or transferred in
a zone of the anthropogenous landscapes.
2) Zhebryanskaya bay (now it is a part of the anthropogenous landscapes zone)
and island Ermakov (referred now to a buffer zone and zone anthropogenous landscapes)
will be transferred in the absolutely reserved zone.
3) The coast sites of Starostanbulsk branch and Potapov branch (now it is the
absolutely protected territory of the Danube Reservation), will be transferred in a
anthropogenous landscapes zone.
This changes are dangerous because:
1) The base of this decision is only authorities instructions; their scientific
and ecological solvency causes serious doubt.
2) The expert conclusions of Ukrainian National ACADEMY of Sciences (this
organization is very famous in the world scientific community) was not is taken into
3) The extraction of reservoirs and channels from a Reservation structure or
their transferring to the anthropogenous landscapes zone антропогенных of landscapes,
as well as anreserving of the Starostanbulsk branch and Potapov branch coasts will
ease a protection mode of natural complexes in Danube Biospheric Reserve. It will
actually make impossible maintenance of a Reservation, this situation will entail the
catastrophic deterioration of a delta s natural complexes.
4) The reserving of Zhebryanskaya bay and island Ermakov will aggravate
attitudes of Danube Reserve and local residents and will lead to a social intensity
The NGO of Ukraine are against this changes of a zoning, this point was
reflected in the Resolution created by the Forum of river basin Danube
nongovernmental organizations ""Let's save the Danube biosphere reserve". This
document was handed to the Official delegation of the European commission in Ukraine
on October 8, 2004.
Proceeding from above-stated we ask:
1. UNESCO and European Union: to take into account an actual situation at the
statement of the new Project of territory organization and natural complexes
protection in Danube Biospherical Reservation.
2. UNESCO: to take into account the communities opinion (the Resolution of the
Forum of river basin Danube nongovernmental organizations "Let's save the Danube
biosphere reserve") at the statement of the new Project of territory organization and
natural complexes protection in Danube Biospherical Reservation.
3. European Union: to take into account the ignoring the promises to Official
delegation of the European commission as well as the continued infringements of
Aarhus convention by the Ukrainian authorities.
Yours faithfully, Chairman Of Council
Environmental group Pechenegy Sergey Shaparenko
more about the problem