Автор: MSha – Власна робота, Суспільне надбання (Public Domain), https://commons.wikimedia.org/w/index.php?curid=27420134

The Ministry of Economy, Environment and Agriculture of Ukraine has, for the second time, refused to issue an Environmental Impact Assessment (EIA) conclusion to Kosivhidroenergo LLC for the construction of a small run-of-river hydropower plant No. 3 of the dam-adjacent type on the Cheremosh River near the village of Roztoky, Kosiv District, Ivano-Frankivsk Region.
The relevant Order of the Ministry of Economy No. 7115, dated 30 June 2026, has been published on the Ministry’s official website. The case registration number in the Unified EIA Register is 12321.

Why was the application rejected?
This is the second refusal concerning the project. The previous refusal was issued under Ministry of Economy Order No. 1324 dated 28 January 2026. The new decision states that some of the previously identified deficiencies had not been addressed.

The key grounds for the new refusal include:
1. Inaccurate information regarding the potential impact on the Cheremoskyi Ichthyological Reserve.
The EIA report stated that the planned activity site was not located within the reserve and that no impact on it was expected. However, the Ministry’s materials cite official information from the Chernivtsi Regional State Administration confirming the existence of the Cheremoskyi Ichthyological Reserve, a protected area, within the planned activity area.

2. Possible overlap with Hutsulshchyna National Nature Park.
The annex to the Order states that, based on the cartographic materials, the planned activity site may be partially located within Hutsulshchyna National Nature Park. However, this was not properly reflected in the EIA report.

3. Contradictory cartographic data.
The report contains inconsistent information regarding the administrative boundary between Ivano-Frankivsk and Chernivtsi regions.

4. Insufficient assessment of impacts on natural habitats.
The Ministry noted that the conclusion regarding the absence of protected natural habitats was based on literature sources. This provided grounds to consider that adequate field surveys had not been conducted in the area potentially affected by the planned activity.

5. Failure to take into account comments from competent authorities.
The decision materials refer to the position of fisheries authorities, which warned that the construction of hydropower plants on the Bilyi Cheremosh and Cheremosh rivers could pose an environmental threat to the hydrological regime of mountain rivers and to the conservation of rare fish species listed in the Red Data Book of Ukraine.

6. Incomplete consideration of public comments.
The annex to the Order states that comments and proposals submitted by the Ukrainian Nature Conservation Group during the EIA procedure were not properly reflected in the report.

Why is the Cheremosh River important?
The Cheremosh is not only a mountain river and a natural administrative boundary between Ivano-Frankivsk and Chernivtsi regions. It is an important part of the living ecosystems of the Ukrainian Carpathians.
According to the materials cited in the Ministry of Economy’s justification, the Cheremoskyi Ichthyological Reserve covers a section of the Cheremosh River and its tributaries upstream from the city of Vyzhnytsia within Chernivtsi Region. The river channel and its tributaries serve as spawning grounds for valuable fish species, including brown trout and Carpathian barbel.
Of particular importance, the upper reaches of the Cheremosh are identified as the only place in the region where the Danube salmon, an endemic species of the Ukrainian Carpathians, has survived.
The construction of small run-of-river hydropower plants on mountain rivers may pose risks to the natural flow regime, fish migration, spawning grounds, rare fish species, and the overall integrity of river ecosystems.

We thank local residents, elected representatives, environmental and human rights organisations — including the Ukrainian Nature Conservation Group, which systematically submitted expert comments within the EIA procedure — for their participation in efforts to protect the Cheremosh River.
The Ministry of Economy’s decision once again demonstrates that public participation, transparency in EIA procedures, the reliability of environmental data, and expert attention to the condition of mountain rivers play a meaningful role in environmental protection.
The rivers of the Carpathians should remain living, free-flowing, and accessible to future generations.

Source: Ministry of Economy Order No. 7115 of 30 June 2026, “On Refusal to Issue an Environmental Impact Assessment Conclusion to KOSIVHIDROENERGO LLC”, and its annex setting out the grounds for refusal.