Unscheduled Inspections of Strategic and Critical Mineral Resources Have Begun

In accordance with the instruction of the Prime Minister of Ukraine and the relevant decision of the Cabinet of Ministers of Ukraine regarding the implementation of state geological control, unscheduled inspections of 38 valid mineral extraction permits have been initiated. These permits were issued for the development of strategically important and critical mineral resources, as well as for the use of oil- and gas-bearing subsoil.

The purpose of the inspections is to verify compliance with legislation in the field of geological exploration and the rational use of mineral resources, fulfilment of the conditions of mineral extraction permits, implementation of approved work programmes, completeness and timeliness of mandatory payments, and the protection of the state’s economic interests in the field of mineral resource use.

The first subject of the unscheduled inspection among subsoil users, according to the approved list, was Special Permit No. 6189 dated 13 March 2017, issued for the extraction of copper ore and associated minerals — silver and gold — at the Zhyrychi copper deposit, which belongs to ME Volynpryrodresurs of the Volyn Regional Council.

The Western Interregional Department of the State Geological Control Department of the State Service of Geology and Subsoil of Ukraine conducted an unscheduled inspection regarding compliance with the conditions of the mineral extraction permit for the development of the Zhyrychi copper deposit.

As a result of the inspection, an Inspection Act was prepared containing remarks regarding the non-fulfilment of certain provisions of the work programme, and a Directive was issued requiring their elimination.

ME Volynpryrodresurs considers it necessary to officially state that the remarks indicated in the Inspection Act and Directive should be assessed taking into account the actual circumstances of wartime, which prevented the full implementation of the approved work programme.

An evaluation of compliance with the permit conditions without taking into account the presence of mine-explosive barriers and the fact that the territory has been mined, as well as the legal regime of martial law and the legislation regulating mine action activities, does not reflect the real situation.

Following the introduction of martial law on 24 February 2022, in accordance with Presidential Decree No. 64/2022 “On the Introduction of Martial Law in Ukraine”, as well as subsequent decrees extending the period of martial law, and due to the construction of fortification structures and mine-explosive barriers within the territory of the Zhyrychi copper deposit, located in the Ratne territorial community near the border with the Republic of Belarus, the extraction of copper ore and associated minerals (silver and gold) under Special Permit No. 6189 dated 13 March 2017 is currently prohibited.

Martial law has a direct impact on the enterprise’s ability to implement the work programme and comply with the conditions of the mineral extraction permit.

According to the legislation in the field of national security, defence and civil protection, as well as decisions of state authorities regarding the defence of the territory of Ukraine, mine-explosive barriers and other defensive engineering structures are elements of defence infrastructure and constitute high-risk facilities.

Under the Law of Ukraine “On Mine Action in Ukraine” No. 2642-VIII, access to such facilities and the performance of any activities within the relevant territories are prohibited until the termination of martial law and the completion of full demining of these areas.

ME Volynpryrodresurs hopes that the explanations and evidence provided in response to the Inspection Act and Directive will be duly taken into account by the State Geological Control Department of the State Service of Geology and Subsoil of Ukraine, and that restrictive measures regarding the validity of the mineral extraction permit will not be applied.

The enterprise is currently unable to carry out the planned activities under the work programme due to circumstances beyond its control.

ME Volynpryrodresurs also expects that a reasonable timeframe will be established to address the remarks, taking into account the uncertainty regarding the duration of martial law and the time required for the demining of the territory of the Zhyrychi deposit, in order to avoid the need for repeated requests for extensions.

The copper ore extraction project remains strategically important for both the region and the state. However, its implementation will only be possible after the end of martial law and the completion of full demining of the territory.

The development of the Zhyrychi copper deposit is a long-term investment project requiring substantial capital investment, the involvement of technological partners and investors, and a stable security environment. At present, all activities at the deposit are prohibited, which delays the implementation of the project, as the territory is located within a border security zone and is currently used for defence purposes.

ME Volynpryrodresurs of the Volyn Regional Council is a public and transparent enterprise that conducts its activities strictly in accordance with current legislation.