In the Khmelnytskyi region, the State Agency for Geology and Mineral Resources has put up for sale a plot within the Lisova section of the Burtynske graphite ore deposit. However, the land is situated within the boundaries of the nature reserve fund — the ‘Malovanka’ Regional Landscape Park. Consequently, the buyer will either acquire an illiquid asset or pose corruption and environmental risks to the region.
Petro Testov, head of the analytical department at the Ukrainian Nature Conservation Group (UNCG), spoke about this on his Telegram channel.
According to a report from NADRA.info, the sale concerns a 20-year licence to extract graphite ore. The 51.31-hectare plot is situated in the Shepetivka district of the Khmelnytskyi region. The auction is scheduled for 20 October, and the starting bid is nearly 8.5 million UAH.
Extraction in protected areas
The environmentalist stated that he had checked the original documents relating to the establishment of the ‘Malovanka’ Park, and that the plot of land put up for sale therefore lies entirely within the boundaries of the nature conservation area. He also pointed out that, on occasion, the boundaries of nature conservation areas on cadastral maps can be sufficiently irregular to allow for some margin of error.
However, the auction documentation pack includes a letter from the Ministry of Economy and the Environment. Citing data from forestry officials and the Khmelnytskyi Regional State Administration, the letter states that the plot forms part of a landscape park.

However, even in 2019, when the protected area had already been established, a preliminary geological and economic assessment was carried out there on the basis of desk research. The reserves were verified by Protocol No. 4756 of the State Commission for Mineral Resources of Ukraine, dated 12 April 2019.
Petro Testov emphasised that this was not the first mistake made by the State Agency for Geology and Mineral Resources, and also pointed out that all plots put up for auction must be approved by the Ministry of Economy.
"Geonadra has an official letter from the ministry stating that the plot is situated within the Nature Reserve Fund. Geonadra has lost court cases concerning the Makove Marsh. Yet they are still putting the plot, which lies within the Nature Reserve Fund, up for auction," the environmentalist emphasised.
Risk factors
The sale of a plot of land carries risks for either the investor or the environment. An investor ‘without connections’ will simply end up buying land where development will be impossible due to environmental restrictions. At the same time, the environmentalist suggests another possibility — that the auction is being organised with a specific bidder in mind, who may be able to ‘come to an arrangement’ with both the Regional State Administration and the state-owned enterprise ‘Forests of Ukraine’.
"Such actions are, at best, evidence of a glaring lack of professional competence on the part of officials at the State Agency for Geology and Mineral Resources. At worst, they pose a serious risk of corruption and raise the suspicion that the auction may have been tailored to a specific bidder, for whom the location of the plot within the boundaries of the Regional Landscape Park is not an issue," writes Petro Testov.
EcoPolitic previously reported that, in the same Khmelnytskyi region, within the Podilski Tovtry National Park, a wind farm is already under construction. It is worth noting that the environmental impact assessment procedure has not yet been completed, and the operation of the wind turbines poses a threat to birds and bats.