Environmental groups are urging Ukraine to step up its climate ambition as a way out of its energy crisis, after the government circulated a draft INDC that would allow its emissions to soar from current levels.

The nation’s environment ministry last week circulated draft plans to other ministries, businesses and NGOs, intending to get views on which of four options to put forward as the country’s contribution to a global climate pact. Final government approval is expected before the end of the month.

Ukraine is considering 2030 greenhouse gas emission targets ranging from reductions of between 40% and 55% below its 1990 levels of 944.4 million tonnes of CO2e, according to the draft INDC dated Aug. 12 seen by Carbon Pulse.

But because the country’s emissions fell sharply in the 1990s along with the collapse of its Soviet-era industry, the goals would allow Ukraine’s emissions to rise by between 6% and 41% above 2012 levels of 402.7 million tonnes, according to calculations that exclude LULUCF.

Any emission goal resulting in 2030 emissions above 370 million tonnes (excluding LULUCF) would comfortably rate Ukraine’s INDC as “inadequate” under scenarios by Climate Action Tracker, which provides scientific analysis of national climate action from four European research groups.

“All the four options are unacceptable in terms of ambition,” added Iryna Stavchuk, of environmental group National Ecological Centre of Ukraine (NECU).

It’s unclear whether UN negotiations on a global climate pact due in December would agree rules on sharing the burden of emission cuts worldwide, though a UN panel of scientists have said that cuts of 40-70% below 2010 levels are needed by mid-century to stave off runaway warming.

Ukraine’s environment ministry had not responded to emails seeking comment at time of press.

DEFENSIVE PRIORITIES

The INDC draft said Russia’s 2014 annexation of Crimea and a pro-Russian rebellion in the country’s east had radically changed Ukraine’s development course, with 20% of its economic potential destroyed and a need to up its heavy industrial output to help fortify its border zones and increase weapons production, amongst other things.

The government said the INDC will need to be revised after Ukraine regains the lost territory, and the country will need to undergo a substantial programme to reconstruct ruined infrastructure.

“It should be noted that Ukraine has already reduced its allowed GHG emissions by more than 10.2 billion tonnes since 1990, a result that no other country of the world has achieved. The national price of this contribution to maintenance of the global climate system is also very high: 30% GDP decline and a population decrease of 8 million people. Under these conditions, no one may deprive Ukraine of its right to restore its economy and resume growth within the allowed GHG emissions volume,” the INDC said.

“Considering what’s happened to the country, if they do anything (on climate) I would be surprised,” said one veteran Ukraine climate policy observer, who asked not to be named due to the sensitivity of the INDC process.

The conflict has even hampered more practical aspects of drafting the INDC.

“The projections for INDC should be based on solid underlying data, a complete set of which is available only for 2013. Since the annexation of Crimea and military activities in the east of Ukraine, both data and previously used assumptions on country’s GHG emissions will need to be revisited, as soon as peace and order within Ukraine’s territory has been restored, and damage to natural habitats, industry and infrastructure has been properly assessed, said Ganna Korniyenko, a Kiev-based climate policy analyst at Thomson Reuters.

The country’s capacity to act is also very limited without external financial support, she added, pointing out that besides severely worsened economic conditions and ongoing military activities, the country has some 1.5 million internal refugees from the east and Crimea.

NECU’s Stavchuk recognises that the conflict has drastically shifted Ukraine’s priorities but argues that a more ambitious INDC would help the country rebuild.

“Climate change is not on the political agenda at all in Ukraine, there are huge issues the government faces but it doesn’t seem to grasp that taking action on climate can contribute in overcoming them,” she said.

“There is a huge potential for climate action to help overcome the economic crisis and to reduce the dependency on Russian gas,” she added, referring to Ukraine’s ageing, inefficient industrial facilities and leaky building stock.

ENERGY MIX

The draft INDC references “next steps” including implementation of a 2014 EU Association Agreement and the EU ETS Directive governing the bloc’s emissions trading system. It refers to requiring the design and implementation of long-term mitigation actions including market mechanisms.

But NECU’s Stavchuk said the draft failed to take into account the policies Ukraine is currently developing and, rather than being written to reflect future plans, seemed to be based on existing policies that date back to 2006.

Ukraine is a member of Europe’s energy community, which includes the EU and southeast European and Black Sea nations seeking to more closely link their energy markets. Ukraine is also seeking to diversify from its almost total dependence on Russian gas.

As part of its membership, Ukraine has undertaken an action plan for renewables to supply 11% of energy use by 2020 and has a draft plan for a 9% cut in domestic energy consumption over 2012 to 2020.

Neither of these goals seems to be taken into account in the INDC paper, nor does a 2013 update to Ukraine’s energy strategy that included a goal to cut GHG emissions by 15% under 2010 levels by 2030.

INTERNATIONAL SUPPORT

Although each country is responsible for the content of its INDC, Ukraine received technical support from the EU via its Clima East project, UNDP and the US development agency USAID.

But the EU’s support in the climate sector has been limited since the bloc in 2013 banned Ukrainian JI carbon credits for use in its ETS unless they underwent further validity checks amid concerns about the environmental integrity of any ERUs not subject to international oversight.

The ban came too late to prevent hundreds of millions of offsets from flowing into the EU – units which a recent study found had undermined the EU’s own climate efforts due to nearly 75% of the ERUs not representing actual emission reductions.

By Ben Garside – ben@carbon-pulse.com