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 scientific substantiations.

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 communities participation.

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 account.

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 in region.

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