On February 10, 2021, the State Reserves Commission of Ukraine held a scientific and technical meeting to discuss the preliminary draft of “Methodological approaches to compatibility (comparison) of the Classification System template of the Committee for Mineral Reserves International Reporting Standards (CRIRSCO) to geological and economic assessment of reserves and resources of deposits of solid combustible and ore minerals submitted for state examination and evaluation”.
Kislotoupor, as a subsoil user with 25 years of experience, was involved in the discussion of the document and provided its suggestions and recommendations. In our opinion, the methodological provisions can become an effective tool for the domestic subsoil user to interpret and adapt certain provisions of the current Classification of Reserves and Resources in Ukraine to other international systems, in particular the CRIRSCO System of Codes.
Our proposals for the "Methodological approaches" project:
1. Indicate in the explanatory note, in the preamble, in the annotation or in separate sections of the document, clear and unambiguous definitions, namely:
– that the approval of these guidelines (methodological provisions) is not an attempt to change, replace or distort the current requirements and norms of Ukrainian standards for the classification of resources and reserves of minerals, in accordance with the regulations of the State Reserves Committee of Ukraine;
– that this document, its separate provisions or the consequences of any of its interpretation are not intended and do not provide for the replacement or duplication of functions of the “Qualified Person”, which operate in additional (voluntary at the initiative of the subsoil user) assessment of reserves and resources of minerals requirements of separate national codes of the CRIRSCO system.
– The provisions of these methodological approaches and their use for any purpose are not in the nature of unappealable and direct transfer of reserves and resources, according to the current classification of the State Reserves Committee to the definitions and requirements of the classification of codes within the CRIRSCO system.
2. It is necessary to indicate that the use of these approaches does not affect the final decisions of the “Qualified Person” and does not affect the current classification norms in Ukraine.
3. Add notes (conditions, warnings or clarifications) that the presence or absence of primary geological information (core arbitration samples, primary day books, test reports, etc.) may affect the interpretation and final decision of the “Qualified Person” and the actual allocation of resources and reserves specific object of assessment to certain categories. That is, when considering the materials of geological exploration works, the State Reserves Committee of Ukraine is guided by the available geological information to the extent that it is sufficient for assessment and classification in accordance with Ukrainian requirements, and the requirements of the CRIRSCO system codes may require additional materials to determine the category of resources and reserves. That is why, a decision in each case remains within the competence and authority of the relevant evaluation institution.
4. Indicate that the allocation of certain reserves and resources in case of availability of the additional / parallel assessment (in accordance with the requirements of certain codes of the CRIRSCO system) may differ from the conclusions of the State Reserves Committee of Ukraine and “Qualified Person” on the requirements, completeness and detail of separate information according to modifying factors of each separate category (according to the level of technological, laboratory, social, commercial, marketing and economic study, and according to the industrial significance of the object subsequently), in the presence of additional requirements of each separate country and the relevant code of the CRIRSCO system.
5. Separately indicate the practical significance of this document after its approval, namely: the practical possibility at the initiative of any subsoil user or other interested person (unless it contradicts current legislation or regulations on access to commercial information) to obtain additional expertise of the State Reserves Committee of Ukraine on the interpretation of balance or off-balance reserves and resources of a particular subsoil use facility (calculated in accordance with current national classification standards of Ukraine), according to their approximate value of classification according to specific codes of the CRIRSCO system (with recommendations and references, which will be competent but still advisory in nature). Such expertise with preliminary translation / interpretation can be used by the subsoil user for the generalized presentation of the object (facility), for conducting substantive negotiations with foreign investors, funds, etc.
6. The provisions of a separate competent expertise of the State Reserves Committee of Ukraine should not be aimed at the unappealable classification of CRIRSCO in order to avoid a false impression of the investor about the prospects for the development of the mining project.
We hope that the approval of the project, taking into account all constructive suggestions, comments and feedback, will promote investment and development of subsoil use in Ukraine.