Volyn Regional Council Appeals to the Government and Law Enforcement Authorities Regarding the Blocking of the Activities

On March 31, 2026, during the 35th regular session of the Volyn Regional Council, the issue of the actual obstruction of amber extraction activities of the municipal enterprise Volynpryrodresurs of the Volyn Regional Council by the State Enterprise Forests of Ukraine was raised.

The Volyn Regional Council has appealed to the Prime Minister of Ukraine, the Head of the State Forest Resources Agency of Ukraine, the Prosecutor General, and the Director of the State Bureau of Investigation in connection with interference in the lawful economic activities of ME Volynpryrodresurs in the field of amber extraction by officials of SE Forests of Ukraine, allegedly carried out through abuse of office. These actions have caused significant losses to budgets at all levels.

The Council requested to ensure an effective and impartial investigation within the framework of the criminal proceedings registered in the Unified Register of Pre-trial Investigations under No. 42026030000000015 dated February 4, 2026, with legal qualification under Part 3 of Article 206 of the Criminal Code of Ukraine (Obstruction of lawful economic activity committed by an organized group or by an official abusing their authority, which caused substantial damage or other grave consequences — punishable by imprisonment for a term of 6 to 10 years, with deprivation of the right to hold certain positions or engage in certain activities for up to 3 years or without such, and with confiscation of property), as well as to bring those responsible to justice.

In the appeal, the deputies express concern over the prolonged, deliberate, and unjustified obstruction of the enterprise’s activities, despite it operating on the basis of valid special permits for subsoil use. This situation causes outrage and may indicate inaction or improper performance of duties by officials of SE Forests of Ukraine, resulting in significant losses of revenue for budgets at various levels.

The Regional Council emphasizes that continued disregard of the issue is unacceptable and undermines public trust in state institutions.

Following the amendments to legislation that have entered into force, and the introduction of a new type of logging — “for subsoil use purposes” — within the scope of special permits No. 6172 and No. 6173 dated February 2, 2017, on June 30, 2025, the municipal enterprise Volynpryrodresurs of the Volyn Regional Council submitted a request to the State Enterprise Forests of Ukraine seeking approval for the clearing of trees and shrubs across seven land plots with a total area of 13.26 hectares.

These territories are covered by an Agreement between ME Volynpryrodresurs and the landowner — the Volyn Regional Military Administration — dated March 21, 2022 (as amended by the Supplementary Agreement of August 19, 2022).

The works were initiated in accordance with Part 5 of Article 58 of the Forest Code of Ukraine and Resolution of the Cabinet of Ministers of Ukraine No. 105 dated February 4, 2023 (as amended by Resolution No. 721 dated June 18, 2025).

Chronology of Events and Description of the Violation:

1. On June 30, 2025, the municipal enterprise Volynpryrodresurs of the Volyn Regional Council sent an official letter to the State Enterprise Forests of Ukraine and its branch Polissia Forestry Office requesting approval for logging activities for subsoil use purposes.

2. On July 10, 2025, a response was received from SE Forests of Ukraine indicating readiness to carry out a preliminary calculation of damages. However, according to the procedure, the Kamin-Kashyrskyi District State Administration (DSA) must formally request such calculation, after which the enterprise must pay the assessed damages. Only then would a logging permit be issued and logging activities commenced.

3. On July 15, 2025, the Kamin-Kashyrskyi DSA sent a letter to SE Forests of Ukraine requesting the calculation of damages.

4. On July 17, 2025, SE Forests of Ukraine sent a letter to the Polissia Forestry Office regarding the allocation of forest stands for logging, the execution of a preliminary damage assessment, and submission of the results to the Kamin-Kashyrskyi DSA.

5. On July 24, 2025, SE Forests of Ukraine repeatedly addressed the Polissia Forestry Office, instructing it to calculate damages within the term by July 31, 2025.

6. On August 1, 2025, ME Volynpryrodresurs provided additional materials upon request of the Polissia Forestry Office of SE Forests of Ukraine, including:

• site location schemes on forest management maps with coordinates of corner points,
• site location scheme on the public cadastral map,
• Annex 3 to the Agreement with the Regional State Administration containing planning and cartographic materials for the entire Agreement.

These materials were requested despite not being necessary for damage calculation, as the enterprise had already provided in its initial letter:

• the Agreement with the Regional State Administration,
• the land transfer acceptance act with cadastral numbers and plot areas,
• site location schemes on forest management maps.

7. On September 17, 2025, ME Volynpryrodresurs received a letter from the Kamin-Kashyrskyi RSA, including attachments: a letter from SE Forests of Ukraine and a response from the Polissia Forestry Office dated August 1, 2025 No. 2523/34.4.4-ВЛ, which failed to take into account the documents submitted by the enterprise on August 1, 2025, and stated the following:

In response to the letter of the Forestry Department of SE Forests of Ukraine dated July 24, 2025 No. 5918/3.1-ВІ regarding the calculation of damages to be incurred by SE Forests of Ukraine as a result of the temporary occupation of a land plot of approximately 13.26 hectares by ME Volynpryrodresurs, the Polissia Forestry Office reports as follows:

According to Clause 3 of the Agreement on exploration and extraction works on amber-bearing subsoil plots dated March 21, 2022, the location of geological exploration and pilot-industrial development, including subsequent amber extraction, is determined based on topographic, geodetic, and cartographic materials, as well as documents confirming ownership or use rights to the land plot, which were allegedly not provided in the attachments.

Without the above-mentioned documents, the Polissia Forestry Office claims it is unable to carry out the preliminary calculation of damages resulting from the temporary occupation of the land plot by ME Volynpryrodresurs.

8. Due to unlawful actions by officials of the Polissia Forestry Office, involving abuse of authority, and the inaction of SE “Forests of Ukraine,” despite having all necessary documents to calculate damages and clear the land plots of forest vegetation for subsoil use purposes, the lawful economic activities of ME Volynpryrodresurs were obstructed, resulting in losses to budgets at all levels. Accordingly, the enterprise filed a complaint with the Volyn Regional Prosecutor’s Office. Based on the review of submitted materials, criminal proceedings No. 42026030000000015 dated February 4, 2026 were registered in the Unified Register of Pre-trial Investigations under Part 3 of Article 206 of the Criminal Code of Ukraine. The case materials were subsequently transferred to the State Bureau of Investigation.

9. As of today, in violation of the law, the Polissia Forestry Office of SE Forests of Ukraine has neither calculated the damages nor cleared the land plots of forest vegetation, despite having all necessary documentation. As a result, the activities of ME Volynpryrodresurs related to the development of new plots are effectively blocked, and planned revenues are not being received by the budgets, causing losses on a particularly large scale.

Facts of Illegal Extraction and Budget Losses

As of today, legal amber extraction by the municipal enterprise on the above-mentioned land plots has not yet commenced. The last time land plots with a total area of 11.1834 hectares were cleared of forest vegetation by SE Forests of Ukraine for the activities of ME Volynpryrodresurs was in August 2024. This illustrates the absurdity of the situation and further confirms the deliberate nature of the obstruction.

Moreover, by a striking coincidence, it is precisely on the land plots totaling 13.26 hectares — for which ME Volynpryrodresurs had requested damage assessment and forest clearing — that incidents of attempted illegal amber extraction at night by diggers from the neighboring Rivne region have begun to be recorded. Such attempts have been repeatedly stopped both by the enterprise’s personnel and by law enforcement authorities.

It cannot be ruled out that the actions of officials of the Polissia Forestry Office branch of SE Forests of Ukraine may have contributed to the resurgence of illegal extraction activities in the Volyn region. While the lawful activities of ME Volynpryrodresurs are being systematically obstructed, cases of illegal extraction are either not met with an adequate response or are ignored altogether.

This situation directly impacts the regional and local budgets, which are not receiving the planned revenues from the municipal enterprise’s activities. Funds that were intended to support regional development are not being generated due to unjustified and deliberate obstruction.