The Carpathians as a Test of European Commitment: The Green Transition Cannot Begin with the Destruction of Nature

Author: Vitaliy Barvinenko, Doctor of Law, Director of the Institute of Danube Research

Following the 17th Meeting of the Carpathian Convention Implementation Committee — the working body in which the seven states of the Carpathian region prepare decisions for the Eighth Meeting of the Conference of the Parties to the Convention — held in Vienna on 7–8 September, several conclusions deserve particular attention.

This is precisely the kind of format in which, behind the general language of international documents, the actual substance of regional policy becomes visible: which projects are being planned, which environmental priorities are being defined, where funding will be directed and, most importantly, under what rules the Carpathian states intend to develop the region in the years ahead.

For Ukraine, this discussion is particularly significant. Following COP8, Ukraine will assume the presidency of the Carpathian Convention, while current materials of the Ukrainian diplomatic mission already define the forthcoming period as the 2026–2029 Ukrainian Presidency. This means not only an enhanced international status, but also responsibility for shaping the agenda of the entire Carpathian region.

At the December Conference of the Parties, a separate Ukrainian Carpathians Nature Recovery Dialogue is expected to be presented. Its purpose is to bring together Ukraine, partner states and international institutions around the recovery of the Ukrainian Carpathians. At the same time, the large-scale CARPATHIAN LIFE project is being discussed for implementation in 2027–2035, with an estimated budget of approximately EUR 34 million and the participation of 26 partners from the Carpathian countries.

This represents a move beyond the traditional understanding of environmental policy as a set of separate protected areas, forests or rivers. The European approach increasingly relies on the concept of ecological connectivity: natural areas should be regarded as a single system in which forests, river basins, wetlands, wildlife migration corridors, agricultural land and settlements are interconnected.

This logic is reflected, among other initiatives, in the NaturaConnect project. For the Danube-Carpathian region, it envisages the development of a network of green and blue infrastructure, the integration of ecological connectivity into spatial planning, closer coordination between the Carpathian Convention and the International Commission for the Protection of the Danube River, and the inclusion of biodiversity considerations in the future revision of the Danube River Basin Management Plan.

For Ukraine, this is fundamentally important because the Carpathians and the Danube cannot be regarded as two separate natural systems.

Water originating in the headwaters of Carpathian rivers reaches the Tisza within days and then flows into the Danube. The same applies to plastic waste, pollution, soil erosion products and the consequences of deforestation. Administrative borders between Ukraine, Hungary, Slovakia, Romania and Serbia do not exist for a river ecosystem.

This is why the Carpathian Biodiversity Framework specifically provides for measures to address transboundary plastic pollution in the Tisza basin, strengthen cooperation on wetland restoration and integrate ecological connectivity into river basin management, transport planning and spatial development.

This is what genuine regional integration means: not merely common declarations, but common governance of water, forests, waste, land and natural resources.

Polonyna Runa as a test for Ukraine

Against this background, the discussion that arose during the current meeting of the Carpathian Convention concerning developments in the Ukrainian Carpathians is particularly significant.

One of the most controversial examples is the construction of a wind power facility on Polonyna Runa in Zakarpattia Oblast.

The project envisages the installation of 30 wind turbines with a total capacity of up to 156 MW within the Turie-Remety territorial community. On 13 February 2026, the Ministry of Economy, Environment and Agriculture of Ukraine completed Environmental Impact Assessment procedure No. 8343 and issued a positive conclusion regarding implementation of the project.

In itself, this is not the problem. Ukraine urgently needs new generation capacity, decentralised energy production and reduced dependence on large power-generation facilities that Russia systematically attempts to destroy.

I support the development of wind energy.

However, green energy ceases to be genuinely “green” when its development results in the destruction of natural areas, the loss of old-growth forests, the fragmentation of habitats or practices that effectively circumvent environmental procedures.

This is precisely where questions arise regarding the way the Polonyna Runa project has been implemented.

EIA procedure No. 8343 began as early as June 2024. The EIA report was published in December of that year, while in January 2025 the administrative proceedings were temporarily suspended due to litigation concerning urban planning documentation. The positive environmental conclusion, as already noted, was issued only on 13 February 2026.

Yet construction activity in the area had been documented much earlier.

According to materials provided by environmental organisations and an inspection report of the State Environmental Inspectorate dated 23 June 2025, removal of the soil layer and construction of access roads had already taken place at certain sites. Publicly available materials also documented the construction of foundations intended for future wind turbines.

This raises a fundamental legal question.

By its very nature, an Environmental Impact Assessment is a preventive mechanism. Its purpose is not to assess an object that has already been constructed, but to identify the potential consequences of a proposed activity before implementation begins, examine alternatives, conduct public consultations and only then determine whether the project is environmentally acceptable.

Otherwise, the procedure itself loses its meaning.

Another issue concerns the fragmentation of the infrastructure required for operation of the wind farm.

Roads, foundations, power transmission lines and the generating facility itself may be legally treated as separate objects, but from an environmental perspective they constitute a single technological complex. A turbine cannot exist without a foundation, an access road, electrical infrastructure and the ability to transport large equipment to a mountain site.

Assessing the environmental impact of each of these components in isolation therefore creates a risk that the cumulative impact of the project as a whole will be underestimated.

The situation concerning forests is particularly illustrative.

The construction of the access road to Polonyna Runa involved logging that affected areas of old-growth forest. On 14 July 2026, the Eighth Administrative Court of Appeal annulled a logging permit issued for clear-cutting primeval forest in the Shypot tract. By the time the court delivered its judgment, some of the trees had already been felled.

Another major infrastructure component is the electricity transmission line. According to the State Enterprise Forests of Ukraine and environmental organisations, its route requires a multi-kilometre corridor through forest areas; on one section alone, approximately 40 hectares of forest were involved. Surveys identified species included in Ukraine's Red Book, while in June 2026 logging along part of the route was suspended following the discovery of a population of fire salamanders.

The subject of the discussion, therefore, extends far beyond the installation of thirty turbines. It concerns roads, transmission lines, forest clearance, the movement of large volumes of soil, intervention in a high-altitude landscape and the potential fragmentation of natural habitats.

Renewable energy and nature should not be competitors

We need to abandon the false choice between renewable-energy development and nature conservation.

European policy is not based on such an opposition.

The European Commission explicitly recognises that wind power and nature protection can be compatible, provided that projects undergo appropriate environmental assessment and that significant negative impacts are prevented, minimised or compensated for. In particularly valuable natural areas, the necessity and acceptability of specific projects must be assessed individually.

Moreover, studies of Ukraine's wind-energy potential indicate that Zakarpattia Oblast is not among the regions with the highest overall technical potential. The highest indicators are found primarily in southern and coastal regions, while western regions have considerably lower potential when the amount of land actually available for construction is taken into account.

This does not mean that wind farms should not be developed in Zakarpattia.

It means something else: the selection of specific sites must be particularly careful.

A unique high-altitude landscape should not automatically become a construction site merely because it is technically possible to install a generator there.

The central issue is institutional quality

The Polonyna Runa case matters not only as a local environmental conflict.

It raises a much broader question about the quality of public administration in Ukraine.

We are preparing to preside over the Carpathian Convention. We are asking European partners to finance the restoration of the Ukrainian Carpathians. We expect tens of millions of euros in international environmental assistance. We speak about ecological corridors, restoration of primeval forests and wetlands, integrated river-basin management and the future Trans-European Nature Network.

At the same time, we have to explain to our partners why work could begin in environmentally valuable areas before completion of the full environmental procedure and why the infrastructure of one major project is being considered through a series of separate legal and administrative decisions.

It is this contradiction that creates the greatest concern.

Trust in a state's environmental policy is not built through international presentations. It is built through specific administrative decisions.

It is difficult to credibly defend the need to preserve the Carpathians in Vienna, Brussels or Belgrade if, inside Ukraine, environmental legislation is treated as a procedure that can be adjusted to accommodate an investment decision that has effectively already been taken.

From the Carpathians to the Danube

For me, as Director of the Institute of Danube Research, this issue has another fundamental dimension.

The Carpathians are, to a large extent, the water tower of the Danube region. A significant share of the flow feeding Danube tributaries originates here. The condition of mountain forests determines the capacity of landscapes to retain water, the speed of surface runoff, the scale of soil erosion, flood risks and the ecological status of rivers further downstream.

Deforestation in the headwaters and water quality hundreds of kilometres downstream are therefore elements of the same process.

This is exactly how contemporary European environmental policy approaches the issue. NaturaConnect regards the Carpathians and the Danube basin as an interconnected transboundary region and explicitly seeks to integrate terrestrial and aquatic ecological corridors into a single planning system.

This should become one of the priorities of the Ukrainian Presidency.

The recovery of the Ukrainian Carpathians should not be reduced to planting new trees after natural areas have been destroyed. It is significantly cheaper, more effective and more responsible to prevent their destruction in the first place.

European integration is measured by practice, not declarations

The Carpathians are not a renewable resource in the political sense of the term.

A two-hundred-year-old forest cannot be compensated for by planting seedlings during the next budget year. A high-altitude natural habitat cannot simply be relocated to a neighbouring plot of land. Destroyed ecological connectivity cannot be restored by a Cabinet of Ministers resolution.

This is why Ukraine's European integration in the environmental sphere is not only about transposing EU directives into national legislation. The far more difficult task is to create a system in which these rules genuinely influence investment and administrative decisions.

The European Parliament has already called on Ukraine to strengthen efforts to combat illegal logging, including in the Carpathian primeval forests, and to ensure proper development of the Emerald Network — the pan-European system of areas of special conservation interest established to protect rare species of flora and fauna and their natural habitats.

The situation on Polonyna Runa is therefore not a dispute between “environmentalists” and “energy developers”.

It is a test of Ukraine's ability to move from a model in which environmental procedures follow construction to a European model in which environmentally acceptable areas are identified first, the cumulative impact of the entire infrastructure is assessed, genuine public consultation takes place and only then does an investor arrive and construction begin.

Ukraine has every opportunity to develop renewable energy while preserving the Carpathians. But this requires abandoning the assumption that any project labelled “green” is automatically environmentally sustainable.

In a few months, Ukraine will assume a leadership role within the Carpathian Convention and will have an opportunity to shape the regional agenda. This is a major chance to transform the Ukrainian Carpathians into a space for international investment, nature restoration, community development, modern infrastructure and transboundary cooperation.

But it is also a major responsibility.

We cannot demand that our neighbours clean up the Tisza, protect wildlife migration corridors, restore wetlands and preserve Carpathian forests if we ourselves allow practices that call those very principles into question.

European integration does not begin in Brussels. In this case, it begins on Polonyna Runa.