Logging During the “Silence Season”: Between Environmental Necessity and Economic Expediency

Every year from April 1 to June 15, Ukraine enters the so-called “silence season” — a period when wild animals reproduce, birds nest, and ecosystems become particularly vulnerable to any human disturbance. For this reason, legislation provides for restrictions on activities that generate noise and disruption, including forestry operations.

However, for more than four years, this provision has effectively not been in force.

What Is the “Silence Season” and Why It Matters

The legal basis of the “silence season” is Part 5 of Article 39 of the Law of Ukraine “On the Animal World.” It explicitly prohibits, during the period of mass reproduction of wildlife, the conduct of noisy activities as well as all types of logging in certain categories of forest areas. This prohibition has a clear biological rationale: in spring, even minimal disturbance — machinery operation, tree felling, increased noise — can lead to the death of offspring or the abandonment of nests. During this period, environmental damage is disproportionately high. The law defines a list of territories where the prohibition applies. These include high-mountain forests, riparian protection zones, forests in ravines and on slopes, wetlands, and protected natural areas.

However, particular importance is attached to reproduction areas within hunting grounds. These are specially designated territories where economic activity is restricted in order to restore wildlife populations. Their area must constitute at least 15% of hunting grounds, and they are most often located in forested areas. Unlike other categories, which cover relatively narrow types of terrain, reproduction areas may include virtually any forest tracts identified as important for wildlife reproduction. Reproduction areas are designated through the process of hunting land management planning — a comprehensive procedure that includes inventorying territories, assessing their quality, identifying breeding habitats, and planning their protection. These materials determine exactly where the logging prohibition applies. This means that a violation can be clearly established by comparing a logging permit with hunting management documentation.

What Changed During the War

In March 2022, the provision on the “silence season” was suspended for the duration of martial law. This decision had objective reasons: the need for timber for defense, heating, and infrastructure in the context of the full-scale invasion.

However, as of 2026, the situation has changed. A significant part of Ukraine’s territory is far from active hostilities, yet the restrictions have not been reinstated. This means that logging — including in reproduction areas — can take place without seasonal limitations even during the wildlife breeding period.

The Problem of Sanitary Logging

Sanitary logging deserves particular attention. Formally, it is intended to improve forest health by removing diseased or damaged trees. In practice, however, it accounts for around half of all timber harvesting in Ukraine. This creates risks of abuse, where commercial logging is effectively carried out under the guise of sanitary cuts. During the “silence season,” such logging is especially harmful, as it destroys wildlife habitats at the most critical stage of their life cycle.

Are Restrictions Really Unnecessary?

The State Forest Resources Agency notes that many of these areas are already subject to other restrictions. This is partly true: for example, in protected areas or high-mountain forests, economic activity is already significantly limited. However, in reproduction areas there is a fundamental difference. Currently, only a coordination regime applies to forestry operations, whereas the “silence season” imposed a complete ban on logging. This is a far more effective protection tool.

Notably, Ukraine’s “silence season” model was even more progressive than in many EU countries, where such restrictions are often absent or merely advisory. Against this backdrop, the suspension of the provision appears to be a step backward, particularly in light of Ukraine’s European integration commitments and new requirements for environmentally sustainable forest products.

A full return to the pre-war “silence season” may be difficult. However, a more balanced approach exists — restoring restrictions at least in relatively safe regions. Priority should be given to reproduction areas. A ban on logging in these zones from April 1 to June 15 would be a minimally necessary step to preserve biodiversity.

Conclusion

The temporary suspension of the “silence season” in 2022 was justified. However, its prolonged non-restoration creates risks for ecosystems and opens the door to abuses, particularly through sanitary logging. Reproduction areas are territories specifically designated for the conservation and restoration of wildlife. They are the ones that require priority protection today. Restoring the “silence season” — even in a partially reinstated, differentiated form — is a logical step for a state that seeks to balance economic needs with environmental responsibility and move toward European standards of sustainable development.

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The publication is produced by NGO «ForestCom» with the support of the Askold and Dir Fund as a part of the Strong Civil Society of Ukraine –  a Driver towards Reforms and Democracy project, implemented by ISAR Ednannia, funded by Norway and Sweden. The contents of this publication are the sole responsibility of NGO «ForestCom» and can in no way be taken to reflect the views of the Government of Norway, the Government of Sweden and ISAR Ednannia.