What does the Ministry of Natural Resources say about the draft law on clear-cutting Russia’s mountain forests?

Recently, we thoroughly examined the official response from the Ministry of Economic Development of Russia regarding the draft law on clear-cutting mountain forests of protected category. It was certainly a very strange letter from the representatives of the department, and the arguments they provide cannot stand up to any criticism.

In one sentence: the number of “skiers” in the country increased by 22%, and therefore we need to cut down protected forests and build ski resorts — which are the last refuges of wildlife — for more than 300 billion rubles.

Meanwhile, for some reason, they mentioned in their response the “growing forest fund of the country,” which, according to them, has increased by about 4.5 million hectares since 2010. However, the scientific studies we submitted in response indicate the opposite: since 2010, the area of forests in Russia has DECREASED by 4.6 million hectares.

A link to the detailed analysis of the Ministry of Economic Development's response will be at the bottom of this material.

Now let’s examine the next response, this time from another agency — the Ministry of Natural Resources of the Russian Federation.

It should be noted right away that the Ministry of Economic Development is the author of the draft law, but they cannot “develop” natural territories, especially protected ones, without the approval of the Ministry of Natural Resources.

So! They send out the letter “to the mailing list,” the exact same copies are sent to everyone who tries to contact the Ministry of Natural Resources to find out the details of the draft law. Therefore, if you, together with us, have sent inquiries to the agencies, you probably have the same response in hand.

File Response from the Ministry of Natural Resources (PDF) 111 КБ

I would say: “let’s remove all the fluff from the document,” but forgive me, comrades — I can’t. It’s all just “fluff” with no facts or explanations!

Let’s look at it in detail!

THE MINISTRY OF NATURAL RESOURCES OF RUSSIA WRITES

“Forest legislation and others... are based, among other things, on the principles of ensuring the multiple-purpose, rational, continuous, and sustainable use of forests...” (p. 1 of the letter).

Here, the Ministry of Natural Resources points to the principles of the Russian Federation’s Forest Code to immediately confirm that any project must comply with the idea of “sustainable use.” The paradox is that in the letter itself, for some reason, the agency does not provide an analysis of how the new draft law on clear-cutting protected forests meets these very principles.

Why mention this if you don’t provide any clarifications? They just cited excerpts from the laws, pointing to them blindly? Or what?

“In accordance with Article 41 of the Forest Code, the use of forests for recreational activities is associated with... the organization of recreation and promotion of public health...” (p. 1).

Here, the Ministry of Natural Resources reiterates the norms of the Forest Code, and they are correct: we do have Article 41, which permits some infrastructure in the forests for recreational purposes, but on condition that the natural landscape is preserved and WITHOUT CLEAR-CUTTING.

Why did they even write this if the question is about legalizing precisely the clear-cutting of protected forests?

“In accordance with Part 2 of Article 41 of the Forest Code... construction... of capital structures... in the field of tourism... is allowed on part of the area not exceeding 20 percent of the area... not occupied by forest stands...” (p. 2 of the letter).

Here, the Ministry of Natural Resources points to current limits: no more than 20% of the forest plot’s area and no more than 1 hectare, and on land NOT OCCUPIED BY FOREST. This is a basic provision of existing legislation designed to limit construction within the framework of recreational use of the forest.

Actually, it is these very norms that they want to change with the new draft law.

“According to Article 21 of the Forest Code, clear-cutting of forest stands... for recreational purposes is not allowed” (p. 2).

Here, the representatives of the agency confirm that the current legislation explicitly prohibits clear-cutting when using forests for recreation. This is important, because the proposed draft law precisely removes these restrictions in the event of constructing ski resorts on mountain forest plots.

“In accordance with Part 1 of Article 111 of the Forest Code, protective forests include forests... of special value...” (p. 3).

Here, it is emphasized that there are categories of forests (the very protective forests) where even stricter bans apply.

“...it is prohibited to carry out activities incompatible with their intended purpose and beneficial functions” (Article 111 of the Forest Code, Part 6, p. 3 of the letter).

Essentially, that’s all! There’s nothing else in there. They quoted excerpts from the Forest Code of the Russian Federation and finally added that, despite the existing legislation, the Ministry of Natural Resources itself approved the new version of the draft law.

“At the same time, the draft law has been revised based on the comments of the Ministry of Natural Resources of Russia in terms of excluding the possibility of placing an unlimited number of facilities on forest fund lands in protective forests...” (p. 3).

We were literally told: “Yes, clear-cutting of mountain forests is prohibited! But we approved the draft law, and now clear-cutting will be legal.” That’s it.

There is an interesting point in the official response from the Ministry of Natural Resources: initially, they intended to give the authors of the draft law even broader powers, but after “certain comments from the Ministry of Natural Resources,” the scope of construction was “reduced.”

However, for some reason, the agency does not specify in its response any details, i.e., what exact limits or strict norms have now been established!

I did not find them in the text of the proposed draft law either. I assume that in this way, employees of the Ministry of Natural Resources simply tried to “whitewash” the duplication of the draft law on the government initiatives website! And let me remind you that officials failed to pass the first version of the project due to public outrage, after which they simply abandoned the old project and duplicated it under a different number, intending to “pass it quickly.”

But we noticed it too. After that, on the last day of the public discussion, within just a few hours, “suddenly” thousands of votes “For” the draft law started to appear. We recorded all this and sent a statement to the Investigative Committee of the Russian Federation, as well as to the General Prosecutor’s Office for further investigation.

The chances that they will really prevent possible manipulations with the draft law and hold someone accountable are almost zero. But we must use all the mechanisms available to civil society.

Essentially, that’s the entire “official answer” from the Ministry of Natural Resources of Russia. Just “fluff,” no facts, arguments, or reasoning. At least we saw some attempts to justify their position in the letter from the Ministry of Economic Development — they at least tried to find excuses (though they didn’t succeed), but the Ministry of Natural Resources sent people “fluff,” filled with terminology and beautiful phrases from the laws.

Really, this paper not only fails to answer the questions asked but completely ignores the public. It feels like they themselves do not know what they need to say or do.

Judging by everything, nobody there is really responsible for anything. They pour out “fluff” and unquestioningly lobby the momentary interests of big business!

Be sure to check out: 

• A complete analysis of the official response from the Ministry of Economic Development of Russia
• Take part in the public initiative against the destruction of mountain forests

© PAVEL PASHKOV