The representatives of Silver Taiga Foundation have prepared and submitted a letter to the Head of the Komi Republic Sergei Gaplikov with regard to his decision about combination of the Ministry of Nature and the Ministry of Industry under the umbrella of the Ministry of Industry taken on October 17.
«In our opinion such combination of two Ministries is wrong and it goes against the functional use of the both Ministries», – said in the letter.
According to the mass media, the main arguments «FOR» the combination of the Ministries are a simplification of a paperwork for the investment projects and for the business as a whole and also a slimming down the bureaucracy. At the same time, the arguments «against» have not been considered as there are no such arguments at all. However, there are enough of them, and not to consider these arguments means to take intentionally a wrong decision, which will lead to the mandatory negative consequences.
The main but not the exhaustive arguments «AGAINST» of the combination of the two Ministries under the umbrella of the Ministry of Industry are pointed out in the letter.
The first argument – it is necessary to separate the functions of natural resources management and control of their use (Ministry of Nature objectives) from the industry development functions (Ministry of Industry objectives). The combination of these functions will necessarily lead to the domination of the industry development objectives over the control of the natural resources use. At the same time, as it is said in the letter «the functions of control over the resources use and natural environment protection and the functions of industry development are separated in the majority of the regions of Russia».
The second argument «AGAINST»: «Total disappearance of «natural environment protection» from the name of the integrated Ministry can lead to the serious image-building and reputational losses for both the Government and the Parliament of the Komi Republic, especially in the coming 2017 announced as the Year of Ecology by the President of the Russian Federation».
One more argument «AGAINST» is connected to the structure of the integrated Ministry as it does not correspond with the structure of the executive authorities in the Parliament of the Russian Federation and this «lack of correspondence can lead to the difficulties in receiving and distribution of subvention from the federal budget, in particular, for the purpose of organization of the forest management, conservation and protection of forests and to the cutbacks to funding of the environmental actions».
In the case of combination of the two Ministries under the umbrella of the Ministry of Industry many international responsibilities and the projects carried out in the Komi Republic under the Ministry of Nature of the Komi Republic supervision will be «hung up». In particular, BEAR projects in relation to the natural environment protection, reduction of the hot spots in the Arctic Region, SPNA Network of the Barents region, UNDP/GEF Project with the focus on SPNA Network of Komi restructuring and on carbon stocks management and climate change in the Komi Republic and the Nenets Autonomous Area. All this is a one more argument AGAINST such combination.
Finally, the decision about this combination of the Ministries has already drawn «an active protest of the regional environmental society and the disapproval of the local population (according to mass media)», who not without a reason «take up the proposed combination under the umbrella of the Ministry of Industry as the preferences for the industrial lobby concerning the access to the natural resources when the level and quality of the ecological monitoring of the natural resources are reducing».
Summing up all these arguments «AGAINST» of the combination of the two Ministries under the umbrella of the Ministry of Industry of the Komi Republic Silver Taiga Foundation asks the Head of the Republic «to suspend the decision in relation to the combination of the two Ministries» and «to consult all the interested parties about the advantages of such combination on the basis of the possible positive and negative consequences analysis».
The copies of the letter have been forwarded to the Chairman of the State Council of the Komi Republic Nadezhda Dorofeeva, to the Minister of Industry of the Komi Republic Nikolai Gerasimov and to the Minister of Nature of the Komi Republic Roman Polshvedkin.