NATIONAL ECOLOGY PROJECT DRAFTED WITH VIOLATIONS OF LAW AND RUSSIAN CONSTITUTION
The most significant violations of the applicable Russian laws committed in drafting the National Ecology Project include non-observance of federal laws on the fundamentals of public control and on strategic planning; and the Federal Law "On Strategic Planning in the Russian Federation" (Article 13), which is an infringement of people's constitutional right to favorable environment as per Article 42 of the Russian Constitution.
Today, the Analytical Center of the Russian Government discussed the priorities and scope of the federal project for the Conservation of Biological Diversity and Development of Ecotourism as a component of the National Ecology Project. The discussion was held with the participation of leading experts in the field, including: Vyacheslav V. Rozhnov, Director of A. N. Severtsov Institute of Ecology and Evolution, Arkady A. Tishkov, Deputy Director for Research at the Institute of Geography of the RAS, Vsevolod B. Stepanitsky, Counsellor to General Director of ANO Amur Leopards, and others.
Key remarks to the Project tasks for the development of conservation areas
According to WWF Russia, increasing special protected areas, as planned in the Project, is not enough. Instead of creating new and expanding the existing protected areas, both tasks are combined in one. The expected increase in the areas will not ensure conservation of the most valuable land and marine ecosystems of Russia, which already should have received the conservation status in accordance with the Concept of Development of Special Protected Areas of Federal Significance for the Period to 2020 approved by Order of the Government of the Russian Federation No. 2322-r dated November 22, 2011. Moreover, in accordance with the Convention on Biological Diversity, by 2020, Russia's total protected areas should be at least 17% of land and 10% of water under national jurisdiction. This requires 50 million ha of water areas (10%). Now in Russia only 2.4% of water areas or about 18 million ha are protected. Approving the Project with the proposed indicators will make it impossible for our country to meet its obligations under the Convention, which are in fact quite attainable.
Moreover, ecologists concluded that the time schedule for creating new protected areas is unrealistic. For several months of 2018, eight new protected areas are to be created, which is impossible. At the same time, it is not quite correct to include the eight protected areas in the Republic of Crimea, which were given the federal status, in this plan (especially as it was done on September 13, that is before the approval of the Project Charter).
By 2024, it is planned to create only 11 conservation zones around the newly created protected areas, although today 68 nature reserves and national parks of the Ministry of Natural Resources and Environment of Russia do not have any conservation zones (while new ones will be created).
The task of conserving biodiversity is not envisaged in the Project
It is only about the reintroduction of 7 nameless species without determining their list or specific indicators of their population increase for each of them. There are no conservations tasks for the rare species that do not require reintroduction, but need urgent protection measures.
Ecologists are perplexed by the task of increasing the "population of seven key rare animals by at least 21,779 species in the aggregate." Using this aggregate indicator (for all species at once) with the accuracy to one does not make sense, as involved are both hoofed animals numbered in the thousands of species, and the Amur leopards, whose population is only about 100.
Protection of the environment, including valuable ecosystems and rare species, is the government's obligation. So, the fact that no budgetary funds are allocated in the National Project for this purpose is, in the opinion of Igor Chestin, Director of WWF Russia, an indicator that the government does not fulfill its obligation and thus violates the constitutional right of people to favorable environment as per Article 42 of the Russian Constitution.
Remarks to the plans of ecotourism development
The results of attaining this task, namely "increased number of visitors to the special protected areas" are given in kilometers (with the accuracy to 10 meters (!)) for the offered tourist routes and eco-paths, which is strange. First, now it is impossible to tell the exact "length" of these linear objects. Second, there is no direct relation between the length of ecological paths and the number of tourists in the national parks.
Questionable are also the expected growth indicators in the number of visitors to the protected areas.
According to official information, in 2017, the number of visitors to the state nature reserves and national parks of the Ministry of Natural Resources and Environment of Russia was 8,126,000, while in the document this figure corresponds to the intermediate indicator between the expected indicators for 2021 and 2022.
The Project budget is also far-fetched: the total amount of RUB 6,757,000,000, of which RUB 6,463,000,000 are the federal budget funds. Considering the 6-year period of the Project, its average annual budget appears to be RUB 1,077,000,000. It is even less than the budget allocated in 2018 (RUB 1,209,000,000) for 22 federal state budgetary institutions that protect such 7 rare species as the Persian and Amur leopards, snow leopard, bison, Przewalski's horse, argali, and dzeren. Since it is expected to create new and to expand the existing protected areas, the Project should also specify the costs required for cadastral registration of newly created protected areas. The task of promoting ecotourism will also require special capital investments.
Moreover, the budgeted financing out of extra-budgetary sources is underestimated. Only the World Wildlife Fund (WWF Russia) invests in the conservation of Russia's biodiversity at least RUB 450 million a year (data for 2017). Apart from WWF Russia, overlooked are the funds of ANO Amur Leopards and other non-commercial organizations, as well as the funds of Russian business (for example, RusHydro, Lukoil, etc.) investing annually much more in the attainment of tasks laid down in this Project.
"All these rather absurd mistakes were made because for some reasons the Project was not discussed with the professional community," Igor Chestin, Director of WWF, said. "It is obvious the Project cannot be adopted like this, it requires cardinal revision with the participation of environmental experts and the community."
WWF Russia delved into every section of the Project and provided its proposals and recommendations on correcting the existing shortcomings.
Photo in the announcement: (с) Vyacheslav Moroz / WWF Russia.