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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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