Comments and Responses Table
Pipeline entry – FP Concept
Conservation of Virgin Forest Biodiversity in the Pechora River Headwaters Region, Republic of Komi, PIMS # 2496
1. GEF Secretariat comments on Pipeline entry
Comment /Response
/ Reference to the FP Concept1. / Project was first supported with a PDF A that was approved in October 2003. The Operational Program was OP 12, OP 2 and OP 3. Please explain the rationale behind the shift of Operational Programs and the move away from integrated ecosystem management as the primary means to achieve the project objective. / The decision was taken based on the PDF A analysis of threats to the Komi biodiversity and potential solutions, as well as on the assessment and prioritization of the overall UNDP/GEF portfolio.
2. / Please provide an explanation of what would happen without GEF (baseline) and with GEF (alternative). / Amendment has been done in the revised Concept / See p. 4 of the Concept
3. / The GEF is currently supporting a
number of projects in the Russian
Federation (Kamchatka, Altai-Sayan,
Volga, etc) that are addressing similar issues related to weak capacity, limited funding for protected areas, and threats
from private sector actors (forestry, oil, mining, infrastructure). All of these initiatives are promoting their ease of replicability to other regions in the RF, however, there appears to be little in the way of lesson learning and replication between the projects under implementation by UNDP and the design of this project. / 1. Added value of this project to the strengthening of the national PA system:
- political and institutional framework which wasn’t targeted by UNDP/GEF projects before: Komi Republic has it’s own republic-level political system, legislation and the government (the highest level of sovereignty in the Federation and set of republic-level institutions). Opportunity to look at the harmonization and coordination between federal and republic-level PAs;
- unique ecosystem (virgin boreal forests were not targeted by other UNDP/GEF projects in Russia);
- types of land use (logging) and development activities surrounding PAs offer new opportunities for UNDP/GEF to work out new models for sustainable land use and cooperation with businesses/local population
2. Leveraging upon the lessons from other GEF projects in Russia will happen for sure in the areas of:
- PA management planning;
- Capacity building models;
- Financial instruments;
- Information management;
- Partially, the project will use the legal/regulatory analysis prepared in the framework of the Kamchatka project
3. Tools for exchange of lessons between projects:
- joint PA management workshops;
- study tours (Altay-Sayan project more relevant)
- direct networking between the project teams;
- exchange of reports, research products and other information materials developed by projects. / See p. 12 of the Concept
4. / The description of the project's
sustainability strategy is very
optimistic and inconsistent with other
project implementation experiences in the Russian Federation both GEF and non-GEF and does not reflect the
current very large gap in public
funding in the Russian Federation. / There is some evidence that the state funding for protected areas management and conservation has been gradually increasing over the last few years. There is also evidence in the on-going legislative reform that the government intends to exercise a more strict ownership and control over the protected areas system. Experience of other UNDP/GEF projects in Russia (e.g. Kamchatka) shows that the presence of GEF project in the area helps to lobby the interest of the protected areas and conservation and ensure an increased attention of the government to these globally important protected areas. In addition to the state funding, the project will help generate alternative revenues to the PA management. Cooperation with the businesses operating around the protected areas is another sustainability factor: on the one hand the project will motivate the businesses to provide direct support to the conservation activities; on the other hand a more sustainable land use practices in the long term will reduce the costs of conservation in the buffer zones and the need for rehabilitation measures. / See p. 12 of the Concept
5. / Please outline the potential for
replication for repeating the project
lessons elsewhere. / The project lessons and models will be relevant to:
- Russian regions with the similar political/institutional systems: Republics within the Russian Federation (eg. Republic of Karelia, etc.). The project will generate models for cooperation and harmonization of nature resource and PA management between federal and republic-level authorities and sectoral agencies;
- other forested regions/protected areas with the active logging operations around the PAs (Republic of Karelia, Arkhangelsk oblast; Siberian regions, etc.). The project will generate models for sustainable conservation-friendly land use practices and cooperation with/incentives to businesses working in the PA buffer zones and around the PAs. / See p. 12 of the Concept
6. / Please clarify why the original
proponent of the PDF A (Economic
Development Program of the Republic of Komi) is no longer a stakeholder and the proposal is being presented by the State Department for Natural Resources and Environment Protection, Republic of Komi / Economic Development Programme of the Republic of Komi (EDP RK) used to be a targeted programme owned by the Government of the Komi Republic and was completed in 2001. Originally the GEF project idea was developed as one of the outputs of the EDP RK. Once the programme has been completed, the Government of the Komi Republic decided to transfer the leadership over the GEF project to the federal level – the regional branch of the Ministry of Natural Resources of the Russian Federation, given that the key PAs included into the GEF project are of the federal jurisdiction, as well as in order to facilitate future replication of the project results throughout the country. However, the Government of the Komi Republic remains a key stakeholder for this project; it has co-financed project development and continues to support the project very strongly.
7. World Bank comments
Comment / ResponseIn Section A "Summary", the project rationale is laid out as based on the status of sector issues as of late 2003 and fails to reflect the critical-path issues that came to the forefront of the forest biodiversity agenda in Russia as a result of administrative and legislative changes that occurred in 2004 and early 2005 (i.e. implementation of the land reform, changes in the forest law that lead to a substantial increase in the role and responsibility of the private sector over forest management outside PA's including their buffer zones, divestiture of responsibilities to regional authorities on fire management, agricultural forests etc., major organizational changes/disruptions in government agencies in charge of protected areas management as a result of the ongoing administrative reform). / Although the project concept may not be completely specific or explicit on those issues, the project proponents and UNDP have been closely following those regulatory and institutional changes in the country and project outcomes remain fully relevant in the new Russia’s legal and regulatory framework. Some relevant studies and analysis were undertaken in the framework of the on-going UNDP/GEF projects in Russia.
It should be also noted, that following the recent revisions of the Russian legislation mentioned by WB reviewer and also in view of the new reforms to come (forest code etc.), there is a certain level of uncertainty of the implications and the final shape of these reforms at the regional level. While these reforms are indeed very recent it was not possible to conduct a comprehensive analysis of these issues at the PDF A stage - additional analysis and assessments are to be conducted at the PDF B stage. These issues, specifically division of responsibilities between the federal level and the regions, are still work in progress and will naturally become clearer for Russia itself during 2005. However, this uncertainty shouldn’t be considered as an increased risk for the project, as non of the reforms put in question the scale/size or existence of the current PA system or any specific PAs. On the contrary, the latest changes in federal legislation move towards a stronger ownership of the government over the protected areas system and towards overall strengthening of environment protection legislation and enforcement. At the regional level in the Komi republic, all republic-level nature resources and environmental management institutions remain at their place. Some institutional restructuring is going on within the regional branches of the federal Ministries, however, all the key people – UNDP/GEF project stakeholders – remain at their posts and responsibilities. This allows to speak of staff and management continuity and stability for our project. While the general analysis of threats and expected outcomes remain relevant in a new situation, the detailed analysis and design of outputs/activities will be carried out during PDF B. These changes could be also considered as an opportunity for the GEF project to impact and strengthen the legal/regulatory framework while it is currently emerging.
The project plans to work intensively with the private sector (see Concept) / See p. 3 of the Concept
The magnitude of all these latest changes makes the presented project concept and its proposed outcomes a generic boilerplate lacking substantive relevance. E.g. without such details it is unclear which institutions should be the key target of the project's institutional strengthening outcomes, what are the main issues to be harmonized between the federal and regional regulations, etc. Examples of regional 'baseline' activities, programs, and budgets are primarily related to the pre-reform situation which is no longer relevant.
Forest fire and poaching data are provided only for 1999-2000, without
assessment of the more recent and important dynamics. The description (esp. Section B.2 "Country Drivenness") clearly warrants a substantive update on key issues. / See above
The threats to Komi forest biodiversity remain relevant.
Basic institutions targeted by the project remain the same: (1) the federal Ministry of Natural Resources of the Russian Federation and its branch in the Komi Republic responsible for the management of federal PAs (Department of Rosprirodnadzor for the Komi Republic – former Komi Department of Federal Service for Nature Use Control; Forestry Agency for the Komi Republic); (2) regional authorities within the Government of the Komi republic (Ministry for nature resources and environment protection of the Komi Republic and others) responsible for the land use management in the republic. These two are the key project stakeholders and beneficiaries.
Besides, among regional stakeholders are Rosnedra of the Komi Republic and Water Board (under the auspices of the RF Ministry of Nature resources), and also the regional Directorate of Fish and Game control, plant quarantine and veterinary medicine (belongs to the Ministry of RF Agriculture) / The Concept has been amended with more recent data about poaching and forest fires until 2003, see pp. 8-9.
Updated information on project stakeholders is given on p.14 if the Concept.
On proposed impact indicators - the proposal does not give a clear justification why 100% of production forests around the target PA's should be subject to international certification. Certification is a market-driven tool and cannot be imposed on areas where there is no such market requirement (these are mostly non-economically accessible forests, as clearly and correctly stated in section "Socio-economic history"). In fact, one of the major issues that this project should aim to address is exactly how to promote sustainable forest management in areas that are outside of direct 'green market' influence. / The Komi Republic has been always a leader in promotion of the forest certification. While it is not formally imposed by any federal or regional legislation, forest certification as an important marketing and conservation-oriented tool is being promoted/advocated by the Government of the Republic. Local logging businesses fully understand the benefits and share the concept. Now, the businesses themselves are the driving force behind the forest certification in the region. Forest certification is considered by the project as a market tool. The project will try to increase the benefits for conservation from this tool rather than unreasonably impose it. /