To V.V. Putin
President of the Russian Federation
On the improvement of state management
of the federal system of specially protected natural areas
Dear Vladimir Vladimirovich,
Please, let us bring to your attention our concern of an alarming situation
evolving in the field of state management of the federal system of specially
protected natural areas.
The ecological doctrine of the Russian Federation includes the task
of establishment and development of a network of specially protected
natural areas among the main priorities of the national policy in the
field of ecology.
These areas are of particular significance for biological and landscape
diversity conservation as the cornerstone of biosphere protection. Moreover,
the most important natural complexes and entities are represented within
the framework of the federal system consisting of state natural reserves
and national parks.
Until recently the Ministry of Natural Resources of the Russian Federation
exercised control of 95 state natural reserves, 35 national parks and
11 federal reservations.
In accordance with the legislation in force natural reserves and national
parks have a status of federal state institutions (consisting of more
than 10 thousand employees) and implement their activities in the field
of nature protection, scientific research and ecological education.
Meanwhile, in the evolving structure of state management in the field
of environment the future of the system of natural reserves and national
parks is uncertain.
As established in Resolution No. 400 of the Russian Government of July
30, 2004, “pending the adoption of a relevant legal act by the Government
of the Russian Federation state management in the field of organization
and functioning of specially protected natural areas of federal significance
shall be entrusted to the Federal Service of Nature Use Oversight”
(these areas, first and foremost, consist of natural reserves and national
parks).
Thus, the issue of state management in this field remains unsettled.
At the same time provision of the Federal Service of Nature Use Oversight
with a mandate to exercise control of the federal system of specially
protected natural areas seems unfeasible due to the following reasons:
1. The established management model contradicts the concept and objectives
of the current administrative reform.
According to Decree No. 314 of the President of the Russian Federation
of March 9, 2004 federal services exercise control and oversight functions
as well as some specific functions in particular fields of activity.
However, the list of these functions does not refer to state management
in the field of specially protected natural areas organization and functioning.
Under Decree No. 314 of March 9, 2004 and Decree No. 649 of May 20,
2004 of the President of the Russian Federation federal oversight services
are not entitled to manage state property or to render paid services,
inter alia through state institutions under their control. Meanwhile,
implementation of natural reserves and national parks’ state management
functions is indivisible from relevant state property management.
In addition, natural reserves and national parks being state institutions
render paid services within the context of their main activities in
accordance with the legislation in force.
Under the existing regulation the Federal Service of Nature Use Oversight
maintains a cadastre of specially protected natural areas, although
this field of activity should fall under the competence of federal agencies
in accordance with Decree No. 314 of the President of the Russian Federation
of March 9, 2004.
2. The function of state management of the system of natural reserves
and national parks is alien to the Federal Service of Nature Use Oversight
and therefore is not prioritized in its activities.
The structure of this federal service instead of providing for the
establishment of a single specialized Administration on specially protected
natural areas contains only a small division consisting of just five
staff-members (meanwhile earlier the Ministry of Natural Resources had
a special department for this purpose). And at such strength it is supposed
to ensure professional management of specially protected natural areas
(which include 130 natural reserves and national parks), including organization
of nature protection, research and ecological education activities on
a Russian-wide scale!
At the same time as a result of a personnel policy pursued by the authorities
of the Federal Service of Nature Use Oversight the most experienced,
qualified and well-known staff-members of the former Department on specially
protected natural areas of the MNR of Russia did not find their niche
within the new structure. All this creates a real threat of degradation
of the federal system of natural reserves and national parks state management
as well as that of loss of nature conservation experience accumulated
in the field of domestic nature conservation activities.
3. The current model of specially protected natural areas state management
system ignores well-established practice of territorial nature protection
tested for many decades throughout the world.
The world has accumulated extensive experience in efficient management
of national systems of natural reserves In the United States, Australia,
New Zealand, South Africa and other nations well-known for their nature
conservation activities protected natural areas fall in the competence
of specialized public services (US Natural Parks Service, Canadian Natural
Parks Service, South African Natural Parks Service, etc.) which are
counterparts of modern federal agencies in Russia.
This practice is well-established throughout the world. Implementation
of a successful management model tested in many foreign countries contributes
to considerable improvement of efficiency of state management in the
field of nature conservation.
Apparently, the most feasible solution lies in the establishment
of a specialized Federal agency on specially protected natural areas
authorized to ensure state management in this field and operating under
direct control of the Government of the Russian Federation. This
idea is in full compliance with the relevant paragraph of the Third
Russian-Wide Congress on Nature Protection (held on November 21, 2003)
and is supported by leading domestic experts in the field of nature
protection and nature conservation.
Time dictates the need to establish a system of efficient state management
of specially protected natural areas in modern Russia. This in turn
will not only ensure sound use of our national natural heritage but
will also improve the image of this country at the international level
as of a nation implementing progressive ecological policy.
In view of the above, we urge you, Vladimir Vladimirovich, to consider
our proposal and to facilitate its practical implementation.