«CURRENT EVENTS»
THE FLIGHT OF BEUROCRATIC THOUGHT:
NEW MNR DECREE
WWF comments to the Decree issued of the Russian Ministry
of Natural Resources #1107 dd. September 15, 2003,
“On amendments in the list of national park and nature reserve staff”
(the Decree is available at the MNR site: http://www.mnr.gov.ru/part/?act=more&id=1269&pid=194)
It follows from the preamble to the Decree that the document was issued
“to amplify the efficiency of work of the state nature reserves and
national parks”, although after getting acknowledged with the Decree
it is obvious for a director of a national park or nature reserve that
the result of its implementation will be reverse — the worsening
of work efficiency.
Today the standard list of staff includes the following deputy directors:
- in nature reserves: for territorial protection, for research,
for environmental education, for general administrative issues;
- in national parks: for territorial protection, chief forester
(in a number of cases chief forester fulfils tasks of deputy director
for territorial protection as well), for research, for environmental
education, tourism, and recreation, for general administrative issues.
The Decree throws into confusion the settled list of staff for the
state nature reserves and national parks, which had already proved
itself to good advantage (in nature reserves it was effective for
11 years, in national parks — for 3 years).
The Decree artificially complicates the structure of administrative
personnel in nature reserves by introducing the position
of chief forester for 95 Russian nature reserves of the MNR. (The
position of chief forester who was in charge of protection service
existed in nature reserves until 1992. Since 1992, due to the creation
of a special state inspection for reserve protection the position
was abolished; instead the position of deputy director for protection
was introduced. Deputy director for protection was in charge of forestry
issues as well. He managed to cope with these responsibilities successfully
so far).
The Decree, artificially and absurdly, granulates functions related
to territorial protection between the chief forester (“forest protection
against fires and forest violations” as it follows from the Decree
in a tongue-tied manner) and the deputy director for environmental
conservation and ecological security (issues related to biological
resources and biodiversity conservation).
In contradiction with the time-tested practice, the Decree imposes
responsibilities for ecological monitoring, including monitoring of
flora and fauna, on the deputy director for environmental protection
and ecological security – while in all nature reserves it was
a responsibility of the deputy director for research. Thus, ecological
monitoring – the sole objective indicator of territorial protection
effectiveness – is now transferred from the deputy director for research
to the deputy director for protection. Perhaps, its was done to completely
prevent objective evaluation of protection measures or the degree
of destruction in the protection system.
The Decree also refers nature conservation to the scope of
key responsibilities of deputy director for management, environmental
education, and tourism. At the same time, the Decree refers protection
of natural heritage to the key responsibilities of the deputy
director for general issues. If we take into account the fact
that chief forester and deputy director for environmental protection
have almost same responsibilities, we’ll see the real danger of disorganisation
of the nature conservation process in nature reserves and national
parks.
According to the Decree, the liaison with law enforcement agencies
should be a responsibility of the deputy director for general issues
– while these things were always in charge of the deputy director
for protection.
The Decree calls the position of deputy director for scientific work
in nature reserves "deputy director for science", which contradicts
with the current Statement on State Nature Reserves in the Russian Federation
approved by the RF Government Decree (edition #527 dd. 23.04.1996),
according to which the position should be called "deputy director
for scientific work". So, the possible liquidation of the deputy
director on scientific work position due to this Decree (and consequent
staff rearrangements) are believed to be inadmissible
The Decree also means great bureaucratisation of the PA deputy director
assignment process. Until now, only the assignment of deputy
directors for research required co-ordination with the relevant Department
in charge of the PA (whose stuff members knew experts in science involved
into the system very well). Now directors of nature reserves and national
parks are bereaved of independence when choosing all their deputies;
they will have to run protracted correspondence or even conduct direct
negotiations with the Russian Ministry of Natural Resources (notorious
procedures of document circulation in the MNR are known by everybody
in Russia). The candidature of deputy director for research must be
discussed with the deputy minister, who had never been in charge of
PAs and has no idea of the situation in nature reserves and national
parks. The candidature of deputy director for administration, environmental
education and eco-tourism must be agreed with the deputy minister
in charge of finance and economic issues (hopelessly abstracted from
environmental education and eco-tourism issues).
The Decree requires nature reserve and national park directors not
only to introduce amendments into their lists of staff, but also to
withdraw from the staff list a number of leading specialists whose
status will remain uncertain for a long period of time due to the
procedure of “re-concordance”. It is easy to foresee how all these
things would complicate the psychological atmosphere in nature reserves
and national parks: searching for a new job is often very problematic
for such specialists.
The Decree requires nature reserve and national park directors to
introduce these amendments into the staff list for 2004 by December
26, 2003. The procedure of staff approval had already been made more
complicated in this year by a minister’s Decree (currently directors
have to get a visa in the Staff Department, while the list itself
should be approved by the deputy minister in charge of PAs). Most
of the directors had already approved these lists for 2004, which
means that they will have to do it once again.
We would like to note that the Decree was developed out of consideration
of the Department of Protected Natural Areas, Objects and Biodiversity
Conservation, directors of nature reserves and national parks, or
any other experts. It is evident that this is the next move of the
MNR aimed at the destabilisation of the federal network of nature
reserves and national parks.
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