“A Sapling Can’t Replace a Tree”: Ministry Rejects Tree Bank Plan

Uzbekistan’s Ministry of Ecology has reviewed the proposal from entrepreneur Murad Nazarov, presented during an open dialogue hosted by the Chamber of Commerce and Industry. The proposal suggested replacing the nationwide moratorium on tree-felling with compensatory planting and the creation of a «tree bank». In response, the ministry issued a statement stressing several key points.

Uzbekistan, lacking access to seas and oceans — vital natural sources of oxygen and carbon dioxide absorption — is over 60% desert and semi-desert. This makes the country particularly vulnerable to climate change.

It is important to consider the impact of regional climate change. In Central Asia, warming trends are occurring at twice the global average. Over the past 30 years, average temperatures in the region have risen by 1.5°C compared to the global average of 0.7°C. Under these conditions, green spaces are essential to ecological balance, which the moratorium aims to preserve.

Global Examples Underscore the Need for Strict Tree Protection

Experience from developed countries shows that strict limits on tree removal are effective tools for environmental protection and sustainable urban development.

• In Germany, the law protects both forests and urban greenery. Illegal felling, especially in public areas, can result in fines of up to €50,000 per tree. Compensatory measures are strictly monitored.
• In the United Kingdom, breaching a Tree Preservation Order (TPO) can lead to fines of up to £20,000 in magistrates’ court or unlimited fines and imprisonment in Crown Court. In 2023, the destruction of the iconic Sycamore Gap tree resulted in a prison sentence of over four years for the perpetrator.
• In Kazakhstan, Article 340 of the Criminal Code stipulates fines of up to 160 monthly calculation indices (approximately $1,181) or arrest for up to 40 days, with possible confiscation of property.
• In Russia, Article 260 of the Criminal Code provides for fines of up to 1 mln roubles (about $12,770) or imprisonment for up to four years for illegal cutting in large volumes, along with possible equipment confiscation and restitution for damages.

These examples demonstrate that even in countries with more favourable climates, stringent measures are in place to protect green spaces.

By comparison, Article 79 of Uzbekistan’s Administrative Liability Code provides fines ranging from 25 to 50 basic calculation values (about $738–$1,470) for individuals, and 50 to 75 BCVs (about $1,470–$2,210) for officials. Given the intensifying climate pressure, maintaining and strengthening the moratorium is seen as a crucial measure for environmental resilience.

No Substitute for Mature Trees: Risks of Corruption and Irreversible Loss

The proposed mechanisms of compensatory planting and a «tree bank» cannot replace the current moratorium for several reasons:

1. A mature tree cannot be fully replaced by a sapling in terms of carbon dioxide absorption, microclimate regulation or biodiversity. According to the European Environment Agency, one mature tree can absorb up to 21 kg of CO₂ annually — a function no sapling can replicate for decades.
2. The practice of creating a «tree bank» carries risks of speculation and corruption, which state policy seeks to avoid. As noted in the Human Rights Watch report Wild Money, compensatory planting in several countries has been used to cover up illegal cutting. In Uzbekistan, such planting is intended as a supplement, not an alternative, to administrative or criminal accountability.

Regrettably, some construction industry representatives have shown cynical creativity in circumventing environmental regulations. One striking example is the use of chemicals to artificially dry out trees in order to legally justify their removal.

A genuinely progressive approach would be to channel this level of creativity not towards bypassing ecological standards, but towards meaningful contribution to environmental sustainability.

Moratorium Reinforced by Law and Presidential Decrees

Despite such challenges, the Ministry of Ecology is making every effort to respond symmetrically to emerging threats and prevent ecological offences.

In 2024, amendments were introduced to Article 79 of the Administrative Liability Code, increasing penalties for the destruction of green spaces.

It is also worth noting that the President of Uzbekistan, in his electoral platform, called for the introduction of a permanent ban on tree-cutting. Presidential decrees have placed special emphasis on creating green zones, particularly during construction, affirming the state’s commitment to environmental policy and strategic development aimed at conserving natural resources and improving quality of life.

Specifically, Presidential Decree No. 199 of 23 November 2023 states that newly constructed buildings and facilities will not be approved by state commissions unless at least 25% of the adjacent land area is allocated for greenery and landscaping is carried out.

Call for Investigation and Dialogue Without Compromise

This attempt at revision is especially disappointing in light of growing efforts to implement ESG principles and the declaration of 2025 as the Year of Environmental Protection and the Green Economy.

In his remarks, Mr Nazarov also mentioned using various «methods» to remove trees at any cost. In this regard, the Ministry believes law enforcement agencies must conduct a thorough review of the approaches he has used in the past. It is hoped that the results will shed light on the legality of his previous actions.

Global practice shows that sustainable construction is based on preserving existing green areas, not destroying them with promises of compensation. The ministry remains open to constructive dialogue, but not to revisiting the foundational principles of state environmental policy.

Earlier, Murad Nazarov, founder of Murad Buildings, has proposed a review of Uzbekistan’s current moratorium on tree cutting.