Subsoil user checklist: what data should be provided by the end of the year

Subsoil users must systematically update their data to avoid suspension of the special permit.

It is often the case  when subsoil users do not pay much attention to documentation. Instead, it is not enough to obtain a permit for subsoil use once, some data must be systematically updated and provided to government agencies. What are the risks of delay?

If a subsoil user fails to submit reports and documents to the relevant government agencies on time, they may be unknowingly suspended from having a special permit for subsoil use. It will take many months to renew it. As a result, the company will lose time, as it will not be able to continue its activity without a special permit. Failure to comply with certain procedures may even result in a criminal case.

The following list of documents should be updated by subsoil users in the near future.

Water intake passports. Subsoil users must submit copies of water intake passports to the State Service of Geology and Mineral Resources every year. And according to the new resolution of the State Service of Geology and Subsoil (SSGSU), the passports must also be registered in the automated system.

Moreover, in October, the SSGSU issued an order warning subsoil users that if they failed to provide information within the specified timeframe, the issue of further validity of special permits for subsoil use would be considered.

Passport of oil and gas wells. The SSGSU is updating the data on the oil and gas well stock, so it is necessary to fill out and submit a well passport for each special permit by December 1 this year. The records are kept in the Register of oil and gas wells, which is administered by the State Research and Development Enterprise “State Informational Geological Fund of Ukraine” – SRDE “GeoInform of Ukraine”.

Correct coordinates of corner points of boundaries and water intakes in the special permit. All subsoil users should pay attention to this, regardless of the type of minerals and whether they extract oil, gas or water. The SSGSU is switching to a new coordinate system, so the accuracy of these coordinates may be very low. If they do not match the actual boundaries of the fields, law enforcement officers may be interested. Even a 100-meter difference with the boundaries specified in the permit is already a criminal case. If the coordinates do not match, you need to apply to the SSGSU with a request to amend the special permit.

Annual report on the accounting of reserves of each type of minerals. It should be made in the form of 5-gr, 6-gr (to be submitted by February 5) and 7-gr (to be submitted by January 20).

To do so, subsoil users can use the reporting form for mineral reserves accounting and instructions to fill out the form correctly.

In addition to the order “On granting special permits for subsoil use,” reporting on the implementation of the work program is also provided for in the subsoil use agreement.

Annual plan. It is necessary not to forget about the annual plan of groundwater extraction and consumption and the annual plan of mining development for 2022. They must be submitted to the State Labor Service of Ukraine for approval. With an already approved plan for the year, you can continue using subsoil.

Meter verification. Who is involved in water extraction needs to control the verification of meters. After all, unaccounted-for extraction is considered a loss to the state.

Post-project monitoring of planned activities. It is necessary to review the environmental requirements in the EIA (environmental impact assessment) conclusion, as such monitoring can be either quarterly or annual. Such monitoring can be conducted by the organization that performed the EIA or by another company.

Thus, the minimum program for subsoil users is to remember to periodically monitor the obtained permits and update the data and ideally, to monitor changes in legislation and trends in the field of subsoil use in order to adapt to them quickly.

Oleksandr Hnevush, Chief geologist of the Geological Investment Group, for GMK.center.