Review of the draft law on the shooting of endangered animals listed in the Red Book.

Within the Russian state system there is a powerful bloc of lobbyists for sport and recreational hunting — they have their own “elite clubs,” travel around the world, kill the rarest animals, and collect trophies. They compete, keep rankings, boast about their weapons, and about who can kill more animals and do it more spectacularly. At the same time, the country’s forest sector has long been pushed toward the hunting industry, attracting “clients” from all over the world who are willing to pay enormous sums to kill animals in the Russian Taiga.

This hunting lobby, which includes high-ranking officials and representatives of big business, has repeatedly tried to undermine the system of wildlife protection by allowing trophy hunting of endangered animal species. In other words, of those animals that are listed in the Red Book and stand on the brink of extinction.

The logic is simple: trophy hunting has one goal — to find and kill the rarest, largest, most impressive, and most unique animal. That is why wealthy people are willing to pay enormous amounts for the killing of, for example, an endangered mountain sheep, a Siberian tiger, or any other rare animal. And where such demand exists, a corresponding “supply” inevitably appears.

But there is a fundamental problem: trophy hunting of rare animals must not become an acceptable legal practice. Animals are listed in the Red Book precisely because so few remain, and the duty of the state is to protect the remaining populations, not to build more convenient mechanisms for their destruction.

THE KILLING OF RED BOOK ANIMALS

We have already defeated similar initiatives in the past, when society was stronger and there were more opportunities to influence such processes. Now the situation has changed: society is exhausted and distracted, so lobbying groups within the state are once again trying to push through the legalization of the shooting of the rarest animals.

Unfortunately, several years ago we were unable to stop one of the legislative changes through which the list of exceptional cases for the harvesting of Red Book animals was expanded. This was done carefully, without openly legalizing trophy hunting, because direct legalization could not be forced through at that time — society was defending these animals too fiercely.

The authorities pushed through changes that expanded the space for the permitted lethal removal of rare animals: for monitoring population status, protecting public health, protecting domestic animals from mass disease, eliminating threats to human life, and also under the pretext of “preventing suffering.” A separate category was the “preservation of the traditional way of life of Indigenous small-numbered peoples.” These are precisely the types of legal formulas that later make it possible to use exceptions more and more broadly, creating a dangerous legal basis for abuse.

Even so, that stage remained limited and did not openly allow direct trophy hunting. Now, with society weakened, they have launched the next project in order to build a broader, more convenient, and more scalable administrative mechanism for the harvesting of rare animals.

The next draft regulation, No. 165677, was published on the Federal Portal of Draft Normative Legal Acts, and the likelihood that they will try to push it through this time is extremely high.

1. Before reading this analysis, I strongly recommend reviewing the chronology of events: who exactly has been lobbying for the killing of rare animals, and where all of this began.

   
   
2. I also recommend a separate article on the officials’ response to public outrage over the new draft: what exactly they said, and why the proposed changes are dangerous.

On our side, a Public Initiative against this madness has already been launched, and every possible resource is being used to raise public attention. We are preparing appeals to government agencies and institutions, and we will look for mechanisms of resistance through the media and through our allies within the Government. But honestly, the chances are small, because the main force — mass public attention and the demand to leave wildlife alone — is now weakened. People are tired, their attention is scattered by political and social collapse, and many are also intimidated by constant pressure, blocking, and restrictions.

ANALYSIS OF THE DRAFT

The draft itself is accompanied by the core document that amends the current rules and would have to be signed if the draft is adopted. Below, I will break it down quotation by quotation and explain what the actual problem is.

“On the approval of the Rules for the harvesting of wildlife objects listed in the Red Book of the Russian Federation and the red books of the constituent entities of the Russian Federation (except for the harvesting (catch) of aquatic biological resources)”

This is one of the key formulations in the draft. The term “harvesting” in relation to Red Book animals has already existed in the legal field before, but now they are trying to embed it into a broader and more technologically formalized permitting system that will apply not only to the federal Red Book, but also to the regional red books. In practice, a unified framework is being created for the authorized harvesting of rare animals across the entire country.

From a scientific perspective, regional populations are often the most vulnerable: they are small, fragmented, dependent on specific reproductive individuals, and reliant on movement corridors. Even a single removal can inflict serious demographic damage: a collapse in reproduction, the loss of dominant males, the destruction of social structure, and accelerated extinction of a local population.

“2. Compliance with the Rules approved by this Resolution shall be monitored by the Federal Service for Supervision of Natural Resource Use and its territorial bodies… and by the authorized state authorities of the constituent entities of the Russian Federation…”

Here it is directly visible that a significant portion of permitting and control powers is being distributed between the federal and regional levels. That means that in a substantial number of cases, decisions will no longer be made solely within a unified federal framework, but also at the level of the regions. The more decision-making points there are, the greater the room for bureaucratic discretion and the higher the risk of pressure from local interests.

Under the new draft, the regions are in practice being given a substantial share of the authority to approve the harvesting of animals listed in the regional red books. At the same time, the text does not establish any полноценный independent external scientific oversight.

“3. This Resolution shall remain in force until September 1, 2032.”

This is a typical bureaucratic tactic of recent years. When a permanent rule is difficult to push through because of public backlash, it is framed as a temporary arrangement, as though it were something limited and reversible. In practice, such measures are later extended or become part of the permanent legal system.

There is no scientifically justified urgency requiring the creation of a new six-year permitting model for the harvesting of Red Book animals.

“1. These Rules establish the procedure for the harvesting of wildlife objects listed in the Red Book of the Russian Federation and the red books of the constituent entities of the Russian Federation… and are mandatory for legal entities and individuals, including individual entrepreneurs, on the territory, continental shelf, and exclusive economic zone of the Russian Federation.”

Here it is directly закрепляется that the new permitting model involves not only individuals, but also legal entities and individual entrepreneurs. The main danger lies in the fact that this structure creates an administrative infrastructure around which the commercialization of the harvesting of rare animals may later develop.

If one approaches the issue scientifically, then in the protection of rare animals it is unacceptable for regimes capable of leading to the death of individuals to be built into a procedure accessible to a broad range of applicants.

“3. The harvesting of wildlife objects shall be carried out only on the basis of a permit… …If a wildlife object is listed both in the Red Book of the Russian Federation and in the red books of the constituent entities of the Russian Federation, then the permit shall be granted by the Federal Service for Supervision of Natural Resource Use.”

This means that the decision on whether harvesting is permissible will be made by an administrative authority. The text says nothing about independent conservation science, external population expertise, or public scientific review being the mandatory basis for such a decision.

Where is the scientific justification for removal? Where is the population viability model? Where is the assessment of permissible selection by sex and age, the analysis of cumulative mortality, and the evaluation of uncertainty? None of this is established in the draft.

In practical terms, the central role is given not to scientific verification, but to the administrative decision of an official.

The next point is especially important: this is where the draft moves the permitting model into digital form.

“4. …shall be carried out by entering a record into the permit registry… which is formed and maintained in electronic form… Applicants shall be notified of the granting or refusal of a permit… through the unified portal of state and municipal services… …permits… in relation to objects… listed in the red books of the constituent entities… shall be issued in accordance with the procedure established by… the constituent entity of the Russian Federation.”

If the issuance of permits is tied to an electronic registry and digital notification, then the state is building not a one-time emergency measure, but a permanent and scalable administrative mechanism. For truly isolated and extraordinary cases, this level of procedural digitization would simply not be necessary.

What is being created here is an infrastructure through which permits for the harvesting of rare Red Book species can be processed in a standard administrative way.

“5. For each harvesting event, the person who received the permit shall draw up an act on site indicating the number of wildlife objects harvested, the time, place, means of harvesting, and the names of the persons responsible for and involved in the harvesting.”

Here we see that the death of a rare animal is being integrated into an ordinary bureaucratic procedure: harvesting, an act, formal recording, and further reporting. In essence, the draft describes a production process in an area where the matter should concern an extraordinary and strictly controlled exception.

Pay particular attention to the phrase “persons involved in the harvesting.” This means that additional participants may be drawn into the actual execution, and therefore the space for abuse and opaque distribution of roles expands.

“6. Upon completion of the harvesting… within a two-month period, a report shall be submitted… …The report shall indicate the number of individuals actually harvested… the date and place… as well as the registry entry number… The report forms… and the procedure for their submission shall be approved by the authorized bodies…”

Reporting is submitted only after the harvesting has already taken place, and within two months. This creates obvious problems for immediate independent verification. The most dangerous aspect is that the report forms and the procedure for their submission are approved by the authorized bodies themselves. In other words, critically important control parameters are moved out of the norm itself and into the ведомственная sphere, where they can be changed administratively.

If the real goal were the protection of rare species, the draft would have to establish concrete reporting requirements directly in the rules themselves, including mandatory independent expert review.

“The permit shall specify its validity period. The time limits shall be determined by the authorized body… in accordance with the purposes of harvesting wildlife objects.”

Here once again it is emphasized that the project prioritizes the logic of harvesting. Meanwhile, in the case of Red Book species, non-lethal methods must be the first option by default: rescue and rehabilitation, relocation in case of immediate threat, scientific monitoring only where it is proven impossible to obtain data non-invasively, veterinary intervention, and other forms of action that do not destroy the animal.

Any economic and especially commercial motives in relation to Red Book animals should be expressly excluded. The text of the draft does not do this.

The rest of the document’s logic works in one direction only: toward the further expansion of a permitting practice in a field where, by definition, there should be a regime of maximum caution and strict protection.

I also studied the explanatory memorandum attached to the draft. One quotation is enough:

“The implementation of the proposed decisions… shall not entail negative socio-economic, financial, or other consequences.” “...there are no mandatory requirements… information on the type of permitting activity… responsibility…”

It is difficult even to imagine how such a thing can be written about a draft that concerns rare and endangered animals.

The formula “will not entail negative consequences” sounds especially cynical in this context. We are talking about a document that constructs a permitting model for the harvesting of Red Book animals. Any management error here may lead to irreversible consequences: local extinctions, degradation of genetic diversity, and the destruction of socio-spatial structure in large predators and ungulates.

This is the situation, friends. Everything is extremely serious, and this draft may indeed be pushed through. We will try to stop it, but we cannot succeed without your support. A sharp drop in public activity is already visible, and the struggle is becoming extremely difficult.

Study the draft on the official government website. This is the direct link, and there you can also download the documents on which this analysis is based.

Review the draft regulation

Also take part in our Public Initiative — sign it and receive a certificate of participation. Spread the information, monitor the status of appeals being sent to government agencies and authorities, and wait for further instructions. The initiative serves as our coordination center on this issue, and it is critically important now to bring together as many people as possible.

  Public initiative

These are hard times. Even inside the federal agencies responsible for protecting nature, deep gaps in the understanding of biological processes are evident. At the leadership level, the influence of groups focused on immediate gain and administrative convenience is growing stronger. The scientific community, meanwhile, is being pushed to the margins of decision-making.

Let us try to stop this. There is very little time left.

© PAVEL PASHKOV