How Mayor Serhiy Khrustovskyi “plans” Odesa’s suburbs: development strategy through a scandal-plagued tender and dozens of complaints to the AMCU

How Mayor Serhiy Khrustovskyi “plans” Odesa’s suburbs: development strategy through a scandal-plagued tender and dozens of complaints to the AMCU

The Avanhard Settlement Council of the Odesa District has announced a tender for the development of a comprehensive spatial development plan for the community’s territory. Formally, this is about a strategic document that should define the future of Avanhard and the surrounding settlements.

In fact, this story has turned into a vivid example of how one document can reshape the land in the suburbs of Odesa, and the procurement procedure itself is accompanied by complaints, decisions of the Antimonopoly Committee, and questionable actions by the customer.

The political responsibility for this story lies with the head of the Avanhard community, Serhiy Khrustovskyi.

7 million on the «strategy» for the suburbs of Odesa

This concerns the open bidding procurement procedure under number UA-2025-11-17-014260-a.

According to the tender conditions, the contractor must develop a comprehensive spatial development plan for the community and general plans for the settlements:

1.Avanhard

2.Khlibodarske

3.Prylymanske

4.Nova Dolyna

5.Radisne

This community also includes the nationally famous “Seventh Kilometer”.

This very document will determine: where housing will be built, where industrial and logistics zones will appear, where roads will pass, which territories will become recreational, and which lands can be developed.

In other words, this is a document through which the fate of all the land in the suburbs of Odesa is actually decided.

That is why a huge number of questions arose immediately regarding the tender.

Complaints from participants: the tender is written «for their own»

Immediately after the announcement of the procedure, several complaints from market participants were submitted to the Antimonopoly Committee of Ukraine.

The companies stated that the tender documentation contains discriminatory requirements that restrict the participation of most potential performers.

AMCU confirmed: the conditions restrict competition

The AMCU Commission reviewed the complaint from the «ZemArchConsult» consortium and issued decision No. 17919-r/pk-pz dated 03.12.2025.

The Commission found that the customer prescribed requirements in the documentation that effectively exclude a significant portion of participants.

In particular, it required the submission of:

- a geodata base from a similar contract;

- formatted in accordance with Order of the Ministry of Regional Development No. 56 dated 22.02.2022;

- with validation confirmed in the public validator of the urban cadastre.

This means that only companies that had performed similar work after 2022 could participate.

The Antimonopoly Committee explicitly stated that such requirements restrict competition and are discriminatory.

Decision dated 03.12.2025 No. 17919

The customer was obliged to make changes to the tender documentation.

Failure to comply with the Antimonopoly Committee’s decision

And this is not the only complaint about the actions of Khrustovskyi’s Avanhard Settlement Council. There are as many as 7 such appeals regarding discriminatory norms.

On December 18, 2025, a request was sent to the customer regarding the failure to comply with the decision of the Antimonopoly Committee of Ukraine Commission No. 17918-r/pk-pz dated 03.12.2025, adopted as a result of reviewing the complaint in the procurement procedure.

The AMCU decision established that the tender documentation contains requirements that restrict competition and are discriminatory towards potential participants.

In particular, in the task for developing the comprehensive spatial development plan for the Avanhard Settlement Territorial Community, it is stated that the Protocol of the strategic session of public discussions dated October 21, 2025, is attached to the documentation.

However, this document was not actually attached to the tender documentation, despite being explicitly listed as «attached».

The absence of this document hinders participants from properly forming their proposals, as it contains materials from the working group’s developments and public proposals that must be taken into account in developing the comprehensive plan.

The AMCU Commission established that the documentation does not contain documents listed as attached, which violates the principles of:

- openness and transparency of procurement procedures;

- non-discrimination of participants;

- equal access to information.

In accordance with the AMCU decision, the customer was obliged to eliminate these violations by making changes to the tender documentation.

However, as of the time of the request, the relevant changes had not been made.

In accordance with Article 164-14 of the Code of Ukraine on Administrative Offenses, failure to comply with the decision of the Antimonopoly Committee of Ukraine as the body for complaints may result in a fine imposed on the customer’s manager from 34,000 to 85,000 UAH.

In this regard, the customer was once again obliged to make changes to the tender documentation and add the missing document — the Protocol of the strategic session of public discussions dated 21.10.2025.

Strange arithmetic: tender for 7 million — winner with a price under a million

After the auction, the winner of the bidding was declared to be the «ZemArchConsult» consortium.

The price of its proposal is 998,000 UAH including VAT.

That is, with an expected value of 7 million hryvnias, the winner offers to perform the work for less than one million.

Such a difference between the expected price and the actual proposal raises serious questions about real competition in the bidding.

Khrustovskyi chose a strange method. The winner did not submit the documents, so the tender was simply canceled. Such a clever move.

After determining the winner, the company informed the customer that it could not upload part of the documents confirming the absence of grounds for rejection.

According to the law, in such a situation, the customer must reject the winner’s tender proposal.

But instead, the Avanhard Settlement Council canceled the entire procurement procedure.

This decision was again challenged to the AMCU.

The applicants’ explanations state that the law explicitly provides for a different procedure: if the winner did not provide the necessary documents, the customer is obliged to reject the proposal, not cancel the bidding.

Thus, the customer effectively chose the most convenient option for itself — to completely stop the procurement procedure.

Development strategy or land redistribution scheme?

The comprehensive spatial development plan is not just a technical document.

It determines:

- where residential complexes can be built;

- where logistics and industrial parks will appear;

- which lands will receive new designated purposes;

- which territories will be subject to development.

That is, this document actually determines the fate of huge land areas in the suburbs of Odesa.

That is why the story with the tender for this plan looks not like an ordinary procurement, but like a struggle for control over the future of all adjacent territories of the city.

And while the community awaits a real development strategy, the procedure for ordering it looks like a typical example of how, under the guise of «development planning», issues of land redistribution around Odesa can be resolved.