Impact Assessment and Project Appraisal

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Environmental assessment in the Russian

Federation: evolution through capacity building

Aleg Cherp & Svetlana Golubeva

To cite this article: Aleg Cherp & Svetlana Golubeva (2004) Environmental assessment in
the Russian Federation: evolution through capacity building, Impact Assessment and Project
Appraisal, 22:2, 121-130, DOI: 10.3152/147154604781766030

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 Impact Assessment and Project Appraisal, volume 22, number 2, June 2004, pages 121–130, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK
Russian Federation
Environmental assessment in the Russian
Federation: evolution through capacity building
Aleg Cherp and Svetlana Golubeva
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The Russian Federation environmental assess-
ment (EA) system comprises state environmental
review (SER) undertaken by state authorities and
assessment of environmental impacts (OVOS)
undertaken by the developers. Despite significant
progress in the 1990s, integration between SER
and OVOS, screening and scoping provisions
and alignment with international approaches
were often seen as problematic. These issues
were addressed in the EIA Regulations issued in
2000. However, the system immediately came
under a major threat resulting from the closure
of the Ministry of Environment. Supported by
capacity-building efforts and strong networking,
the Russian EA community has largely deflected
this threat and enrolled various stakeholders into
supporting EA, which now encompasses SER
and OVOS components. Activities at regional
level and critical evaluation of the existing sys-
tem were key elements in these efforts.
Keywords: environmental assessment; Russia; state
environmental review; capacity building
Aleg Cherp (corresponding author) is at the Department of Envi-
ronmental Sciences and Policy, Central European University,
Nádor u. 9, 1051, Budapest, Hungary, E-mail: cherpa@ceu.hu;
Website: www.ceu.hu/envsci/. Svetlana Golubeva is Business
Development Manager, ICF/EKO, Tverskaya zastava, 3, off.
240, Moscow, Russia; E-mail: sgolubeva@icfeko.ru; Website:
www.icfeko.ru.
The authors are grateful to numerous Russian EA practitio-
ners for discussing ideas presented in this paper and to the
World Bank and Ecoline in Russia for providing forums for
such discussions. All the opinions expressed are the authors’
who bear full responsibility for possible errors and omissions.
Impact Assessment and Project Appraisal June 2004
T
HE RUSSIAN FEDERATION (RF) is one of
the largest emerging democracies. For centu-
ries, it has exercised a profound cultural, po-
litical and economic influence on both immediate
and more distant neighbours. The newly independent
states (NIS) of the former USSR still look up to
Russia in many matters of environmental policy,
including environmental assessment (EA).1 That is
why understanding the Russian EA system is espe-
cially important.
Several internationally published studies of EA in
RF and its context (for instance, Cherp and Lee,
1997; Govorushko, 1991; Khotulyova et al, 1998)
identified and explored specific challenges facing
the Russian EA system in the 1990s. However, it
had always been obvious that both the system and its
political and economic context were undergoing a
rapid transition, while the knowledge about its func-
tioning was accumulating. The authors thus felt it
necessary both to update the reader on the most re-
cent changes in the Russian EA system and to show
it from an angle that should help to understand its
‘dynamic’ as well as its ‘static’ features.
The observations and analysis reported in this ar-
ticle have been accumulated in the course of several
EA studies and capacity-building projects under-
taken over the last five years. The most important
have been the World Bank study on the effective-
ness of the EA system in Russia (von Ritter and
Tsirkunov, 2002), the project on strengthening EIA
in Russia conducted by the University of Manchester
and Ecoline (EIA Centre, 2001), as well as research
by Volostnov (1999), Prokopets (2001), Verzhbit-
skaya (2001) and additional information gathered for
the national State of the Environment Reports 1997–
2002.
1461-5517/04/020121-10 US$08.00  IAIA 2004 121
 EA in the Russian Federation
The authors sought to analyse the Russian EA
system as a “dynamic policy system” as suggested
by Cherp and Antypas (2003). This means exploring
the ways in which EA policies are formulated, im-
plemented and adjusted, including through ‘policy
networks’ that are able to bring together diverse
forms of knowledge, perspectives and experiences.
To achieve this objective, instead of giving a snap-
shot of the Russian EA system, we first discuss its
context and the main driving forces and challenges
as they existed at the end of the 1990s. We then ex-
amine the evolution of the system paying special at-
tention to the capacity of networks of EA actors to
deal with the most pressing issues. Finally, we out-
line the future challenges facing EA in Russia and
the most promising ways of dealing with these.
EA in Russia and context at turn of century
Overview of the EA system in the 1990s
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Although, certain elements of EA have existed in the
USSR since the 1960s, a coherent EA system
emerged only in the late 1980s in response to the ris-
ing awareness of environmental problems, the in-
creasing interest in international approaches to
environmental regulation, and the emerging policy
of glasnost (openness and transparency). The Soviet
Government of that time was especially attracted by
the possibility of incorporating the US National En-
vironmental Policy Act and other western experi-
ence in the existing system of socialist expertizas
(expert reviews of planned economic activities). Es-
sentially, this was an attempt to achieve ‘western’
results by socialist means, typical for many envi-
ronmental policies of the perestroika (see Larin et
al, 2003). Thus, the system of ‘ecological experti-
zas’ was rapidly institutionalised and became the
central pillar of the Soviet and then Russian envi-
ronmental protection system (Cherp and Lee, 1997).
The concept of ecological expertizas, deeply
rooted in the hierarchical and technocratic manage-
ment of the centrally planned economy, was initially
translated as EIA (see, for instance, Govorushko,
1991). However, its fundamental differences from
western EA were soon realised, so the term state
environmental review (SER) was coined in inter-
national publications.2
The formal SER procedure, stipulated by key en-
vironmental laws (Federal Law on Environmental
Protection (1991; 2002), Federal Environmental Re-
view Law (1995)) has not changed much over the last
eight years. It has been centred on the review of the
design or planning documentation for proposed pro-
jects (or other planned activities) by state-appointed
special expert committees, and issuing a mandatory
‘resolution’ on whether, and under what conditions,
the proposed development can go ahead. Hundreds
of thousands of SERs have been conducted in Russia
since 1989 (see, for instance, Table 1).
122
Table 1. Number of SERs conducted at the federal and
regional level in Russia, 1991–1994 and 1997–2003
Year Number of SERs
Federal level Regional level
1991a 50,000
1992a 56,000
1993a 78,200
1994a 80,800
1997b 402 57,600
1998b 873 60,700
1999b 568 75,000
2000b 430 61,000
2001b 165 53,000
2002b 173 36,000
2003c 250 48,000
a
Sources: Lopatin (1995)
b
von Ritter and Tsirkunov (2002) and State of the
Environment Reports (1998–-2003)
c
Ministry of Natural Resources (2003)
However, by the early 1990s, the Russian practi-
tioners familiar with international EA experience
pointed out that the procedure of environmental
impact assessments by which developers prepare
part of the documentation to be reviewed by SER,
called OVOS,3 is, in fact, more similar to the west-
ern EIA than SER. Unfortunately, the concept of
OVOS, a ‘soft’ environmental policy tool, was much
harder to sell to politicians, officials and the public.
Therefore, it was hardly mentioned in the legal acts of
the 1990s, except the OVOS Regulations (1994)
which were largely ignored by both developers and
officials.
In the mid-1990s, progress was slower than it
could have been, partially because of somewhat
different views within the Russian EA community
regarding the best approach for strengthening the
system. There was the SER group of experts in key
positions in the Ministry, who relied on well-
established institutions, laws and practices, and ex-
tensive bureaucracy. They maintained that SER is
the most appropriate preventive environmental pol-
icy tool for Russia. In their view, improvements
could only be achieved through gradually strength-
ening SER provisions and institutions.
Many such developments in regulations, guide-
lines, technical capacities and institutions have been
made over more than a decade of a functioning SER
system resulting in conceptual and procedural de-
velopments of EA. However, these improvements
arguably came at a slow pace, partially because there
were no obvious ‘benchmarks’ (either domestically
or internationally) for ‘best practice’ of SER, and
innovations were difficult to introduce and dissemi-
nate, given the scale of the country and the constant
administrative reform.
Another factor slowing the development of the
SER approach was that it was not obviously com-
patible with western EA, so that lessons from inter-
national EA experience could not directly be
Impact Assessment and Project Appraisal June 2004

Improvements to the state
environmental review came slowly,
partly because there were no obvious
benchmarks for best practice, and
innovations were difficult to introduce
and disseminate, given the scale of the
country and the constant
administrative reform
incorporated into SER practice. For much the same
reason, alignment of the SER approach to that of in-
ternational investors and international development
agencies (such as European Bank for Reconstruction
and Development (EBRD) and the World Bank) was
complicated.4 The public, though generally suppor-
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tive of the clear-cut and strict nature of SER resolu-
tions, often demanded a degree of access to
information, transparency and participation, which
was difficult for the technocratic and bureaucratised
SER system to grant.
Finally (and, perhaps, most importantly), the
growing business community was increasingly irri-
tated by SER provisions (particularly by their indis-
criminate application to almost all types of activity),
which they considered as yet another bureaucratic
obstacle to investment. In times of declining econ-
omy, low investment and populist governmental
policies, this was not such a significant factor;
however, it proved to be decisive when the economy
turned around at the end of the 1990s.
The second, OVOS, group of Russian EA practi-
tioners held the view that the SER system had to be
radically reformed, if not dismantled, to give way to
EA provisions modelled after best international
practice and centred on the OVOS procedure. The
investor/developer and the public should be the main
actors in this process, with state authorities playing
an auxiliary role. Not surprisingly, this position was
not enthusiastically supported by SER bureaucrats.
Moreover, many environmental non-governmental
organisations (NGOs) were also extremely suspi-
cious about any proposals to reform the SER system,
which they viewed as the only real safeguard
whereby environmentally dangerous developments
could be stopped.
Nevertheless, the proponents of OVOS managed
to develop its discourse and practice, the latter in
connection with the activities of international lend-
ing institutions, especially as facilitated by the Cen-
tre for Project Preparation linked to the Russian
Pollution Abatement Facility operated by the World
Bank, EBRD and other international funding institu-
tions (Maximenko and Gorkina, 1999). Within this
context, EIAs were prepared with regard to the 1994
Impact Assessment and Project Appraisal June 2004
EA in the Russian Federation
OVOS Regulations but mostly according to the
international (such as the World Bank) procedures.
The dialogue between the two ‘camps’ was com-
plicated by their institutional affiliations and inter-
ests and, in some cases, became deadlocked. It was
also framed by such endemic Russia’s questions as:
finding its own way vs adopting western experience;
autocratic regulation by enlightened bureaucracy vs
a self-regulating democracy; and so on. These were
spiced up by more modern discussions of environ-
ment vs development, and federal vs decentralised
government. It should also be noted that the forma-
tion of Russian environmental policy, especially the
tools for mainstreaming environment in develop-
ment planning, environmental policy integration,
and other tools characteristic of ‘ecological
modernisation’ proceeded very slowly in Russia in
the 1990s (Larin et al, 2003).
All these circumstances had unfortunate conse-
quences in the lack of integration of SER and
OVOS. In particular, it was frequently noted that
OVOS reports (‘volumes’) often did not focus on
the core environmental issues, did not meet the
expectations of the SER, and did not influence deci-
sion-making on proposed activities (Cherp and Lee,
1997; von Ritter and Tsirkunov, 2002).
As already mentioned, very large numbers of
SERs have been conducted in Russia (see Table 1).
The overwhelming majority of them have focused
on project-level activities, with only 1% or 2% ad-
dressing regional plans or development schemes.
Moreover, according to Volostnov (1999), up to
three-quarters of developments reviewed by SER
have not been environmentally significant.
According to von Ritter and Tsirkunov (2002), the
decline in the number of SERs between 1999 and
2001 reflected a worrying combination of two nega-
tive trends: declining capacity within the SER
institutions and increased focus on cases with low
environmental impact at the expense of coverage of
cases with significant impact. Moreover, a sample re-
view of SER cases reported by these authors shows
that SER resolutions were becoming shorter and in-
creasingly focused on procedural issues rather than on
substantive recommendations of mitigation measures.
Nevertheless, those cases submitted to SER typi-
cally complied, at least formally, with the SER
requirements. On the other hand, compliance with
OVOS Regulations (1994) and the EIA Regulations
(2000), has been very low particularly with regard to
public participation and preparation of terms of
reference.5 Thus, meaningful OVOS practice was
mainly limited to large projects with foreign partici-
pation and much of it occurred within the framework
of the Russian pollution abatement facility (Maxi-
menko and Gorkina, 1999).
Thus, the broad critical issues facing the Russian
EA system at the end of the 1990s included:
• finding the way to incorporate international best-
practice experience of integrating the environment
123
 EA in the Russian Federation
into decision-making into the Russian system
without compromising its capacity and ability to
integrate with existing institutions;
• ensuring the effectiveness of the system in the
face of the rapidly changing political and eco-
nomic context of its application;
• ensuring constructive co-operation and dialogue
between OVOS and SER professionals that could
lead to integration and mutual enhancement of
both instruments;
• ensuring consistent implementation of EA provi-
sions by all relevant actors. This could only be
achieved through gaining support from the public,
the business community, various government
agencies and international organisations.
All these issues largely related to individual and sys-
temic capacities of various actors and institutions in-
volved in the development and implementation of EA
policies. Some capacity-building projects were initi-
ated throughout the 1990s (for example, the operation
of the Public Environmental Review Centre from
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1995 to 1998 (Ecoline, 2001)), and their collective ef-
fects were becoming evident by the end of the decade.
However, the unexpected changes in the political and
economic context at the end of the last decade
suddenly, and profoundly, affected these priorities.
Economic, political, environmental policy context
If the development of the EA system in the 1990s
was taking place in a declining or stagnating econ-
omy, the situation of the last five years has been
dramatically different. Following the financial crisis
of 1998, the Russian economy has been rapidly re-
covering, bringing about an increase in investment
and a rise of industrial production. Most of the in-
crease has occurred in the raw materials and energy
sector associated with significant environmental
impacts (see for instance, Cherp et al, 2003). This
recovery resulted, inter alia, in increasing foreign
business presence, strengthened business lobbies
and, at the same time, increasing attention of busi-
nesses (especially foreign-owned) to environmental
risks and liabilities and the rise of Russian domestic
environmental services (consultants).
The political situation in Russia has also changed
in connection with Vladimir Putin becoming the
President in 2000. Many administrative structures
and laws were consolidated and the political and
economic instability of the 1990s has all but gone.
Moscow has sought to concentrate power through
extensive administrative reform and cutting down on
non-essential bureaucracy. At the same time, the
Putin Government has shown signs of intolerance
towards political, including environmental, dissent.
This all took place in the context of a continued tug-
of-war between the federal centre and the regions.
Public interest in environmental matters has sub-
stantially declined from its high point in the early
1990s; this has resulted in the environment all but
124
vanishing from the political agenda. However,
where such interest has remained (for instance, in
environmental health in some local groups or in bio-
diversity in nation-wide NGOs), the opportunities,
the mechanisms and the skills for translating it into
specific policy action have arguably increased.
An important contextual factor has been the change
in the foreign policies of the Russian Federation. This
can be best summarised as doing away with the ‘new
thinking’ of the Yeltsin and Gorbachev eras and
replacing it by ‘real politik’ where Russian national
interests take the highest priority. While discussing
rapprochement with the European Union (EU), even
to the point of harmonising Russian and EU legisla-
tion and access to the World Trade Organisation, Rus-
sia has grown increasingly critical of foreign aid and
meddling in its internal affairs by western powers.
All these factors heavily reflected on both exter-
nal and internal environmental policy. Externally,
the most noticeable phenomenon was the recent
Russian scepticism towards the Kyoto treaty, which,
as high officials emphasise, would only be signed if
it corresponded to “Russian national interests”. Sur-
prising to many, such an approach has long been
evident in Russia’s dealing with other environmental
treaties. For example, although a signatory to the
Espoo Convention, Russia has still not ratified it,
apparently because of foreign policy considerations.
The Aarhus Convention, signed and ratified by most
of its neighbours, also lacks the Russian signature.
The new political and economic situation has had
even more profound impact on Russian domestic
environmental policy. The Russian EA system be-
came the focus of international attention when in
May 2000 the Government abolished the State
Committee for Environmental Protection (SCEP)
and merged environmental management, including
the EA function, into the Ministry of Natural Re-
sources (MNR). Many environmentalists have con-
sidered this the most significant setback to
environmental policy in the last 15 years (see for in-
stance, Larin et al, 2003).
Von Ritter and Tsirkunov (2002) refer to two
main explanations of this event, one is that it was
part of a broader Government effort to reduce the
number of ministries and independent authorities,
another that environmental protection policies (first
of all SER) were perceived as an obstacle to eco-
nomic growth. Whatever the rationale, the Russian
EA system was dealt a major blow. The next section
describes how and why the EA community was able
to organise and ensure the survival of the system.
Recent evolution of the EA system
Evolution of EA capacity
Since the formal introduction of the main elements of
the SER/OVOS system in the late 1980s, the capacity
of the Russian EA community has developed
Impact Assessment and Project Appraisal June 2004

significantly. It is possible to note the rise in aware-
ness of developers, authorities and the public, tech-
nical skills and experience of consultants, and the
number of guidelines, textbooks, university courses,
and other resources. However, this section will focus
on two aspects of the EA system’s capacity that are
less frequently noted: the ability of the system for
critical self-reflection; and the emergence of net-
works of EA actors.
During the late 1990s and early 2000s, there has
been a gradual evolution in the manner in which
Russian EA policy is formulated and implemented.
Arguably, the policy process has become more in-
clusive, participatory, knowledge-intensive and sys-
tematic. The first steps in this direction were made
during the formulation of what would become the
2000 EIA Regulations. The process of drafting the
regulations took more than three years and involved
many individuals and organisations. It provided a fo-
rum for the discussion of the strengths and weak-
nesses of the existing system, as well as its
relationship with international best practice. This
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debate proved to be very important for finding the
right balance between institutional reality and ideal
expectations.
In particular, the EIA Regulations formally coined
the notion of the “Russian EA system” as including
both SER and OVOS. This development has proved
to be critical in bridging, in legal terms, the two pre-
viously disparate approaches to EA in Russia. On a
conceptual level, this bridge was justified in a book
entitled Environmental Assessment and Environ-
mental Review (Cherp et al, 2000), several editions
of which were published and widely disseminated by
the NGO Ecoline approximately at the same time as
the EIA Regulations were formulated and issued.
It was both a textbook on the common elements
of EA international practice, and a detailed analysis
of the Russian EA system, including the interpreta-
tion of the emerging EIA Regulations (2000). The
authors sought to interpret the features of the spe-
cific Russian EIA system in western terms, thus both
making its experience available to the international
EA community and increasing the availability of
international experience to the Russian EA commu-
nity. The book played an important role in establish-
ing a common language among EA professionals,
thus contributing to the cohesiveness of the Russian
EA community, which would play a key role during
the crisis of 2000.
Other capacity-development efforts recently car-
ried out in Russia include the development of Guide-
lines on EIA for the NIS by the Centre for
International Projects (supported by UNEP). This
facilitated unification of Russian-language EA ter-
minology in the NIS and is likely to further increase
the influence of the Russian experience on the EA
systems of neighbouring countries. The international
EA experience was made more widely available to
the Russian EA community as a result of translating
to Russian the UNEP’s EIA Training Resource
Impact Assessment and Project Appraisal June 2004
EA in the Russian Federation
The World Bank decided not to sign
two operations without Government
assurance that it had restored a
working environmental assessment
system that could ensure the
environmental safety of new
investments
Manual (UNEP, 2000) and Ecoline publishing it on
the Internet.
As the majority of EIAs in the Russian Federation
are undertaken at regional level (see, for instance,
Table 1), many capacity building efforts of the late
1990s focused on regional capacity. For example,
the capacity-building project by Manchester Univer-
sity and Ecoline (supported by the British Govern-
ment) included training and creation of EA centres
in the Tomsk, Chita and Irkutsk oblast (EIA Centre,
2001). These and other regional capacity-building
efforts were associated with the increasing number
of regional EA regulations further described below.
Disbanding the SCEP came literally the day after
the new EIA (OVOS) Regulations were issued in
2000. In response to local and international protests
(Larin et al, 2003), the MNR invoked a working
group, which comprised academics, experts and the
public, to elaborate a new concept of the EA system,
but soon discontinued it because it failed to arrive at
a common vision regarding the future of SER,
though all participants agreed that it had to be pre-
served (see Golubeva, 2001).
In 2001, the SER staff at the federal headquarters
of MNR was reduced from 33 to 15, while the total
number of SER officials in Russia declined from
about 700 in early 2000 to about 400 in 2001 result-
ing in sharply rising case-loads despite the reduction
in the overall number of SERs (von Ritter and
Tsirkunov, 2002). However, the Russian EA com-
munity was able to organise itself even under these
circumstances.
World Bank study of the effectiveness of Russian EA
The main ally in protecting the Russian EA system
from complete destruction turned out to be the
World Bank, which expressed its concerns about the
viability of the reorganised Russian system soon af-
ter the disbanding of the SCEP. The World Bank de-
cided to hold off on the signing of two operations
until it received assurance from the Government that
it had restored a working EA system that could en-
sure the environmental safety of new investments.
Under the threat of lending to Russia being
suspended, the SER Department was reinstalled in
125
 EA in the Russian Federation
Box 1. World Bank study “How effective is EA in
Russia?”
The study stated that the EA system had been a key
element of the Russian environmental policy. It challenged
the assumption that EA is an obstacle to business by
proving that the delays and costs associated with
compliance to EA provisions are generally low to moderate
(though disproportionately greater burdens fall on small and
medium-sized projects with no significant environmental
risks). A business survey quoted by the study demonstrated
that environmental regulations were ranked the 23rd out of
30 other obstacles to business.
The study evaluated the context for the operation of the
EA system, the legal and institutional framework, the
practical implementation, the impact and the institutional
capacity for EA in Russia. Of all these aspects, only the
legal framework was found satisfactory, whereas the
institutional capacity was considered to be under the
greatest threat. The following critical deficiencies of the
system were identified:
● Lack of integration of the OVOS and SER subcomponent
of the system. This was especially evident in the limited
role that SER authorities played in determining the scope
and reviewing the quality and relevance of OVOS.
● Lack of effective screening provisions resulting in
‘dispersing’ scarce financial resources and wasting time
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while analysing impacts of low-risk projects to comply
with complicated assessment procedures.
● A limited impact of EIA on decision making, except in
selected cases of highly visible and internationally
financed projects. This is the result of excessive focus on
meeting formal requirements to attain a formal SER
approval and is exacerbated by the declining capacity to
monitor and enforce EA conclusions.
● Declining institutional capacity, which has been brought
about by the ongoing restructuring, the lack of, or
misleading, guidance from the centre, and the shrinking
of Russia’s environmental management system.
● Unclear relationship between federal and regional
functions in EA.
Source: von Ritter and Tsirkunov (2002)
the MNR. At the same time, the World Bank, par-
tially supported by the Ministry, initiated a study of
effectiveness of the Russian EA system in 2001.
This study (reported by von Ritter and Tsirkunov
(2002)) capitalised on the capacity-building efforts
undertaken previously and the existence of EA net-
works extending to various geographic regions and
various stakeholder groups. In particular, it involved
experts from the Government, academia, NGOs, in-
dustry, consultancies, and the federal and regional
levels. Several international experts were also asked
to review the methodology and the findings of the
study, which are summarised in Box 1.
Although most of the World Bank’s findings were
well known to Russian EA professionals, the study
was really important in its ability to pronounce these
conclusions at a relatively high level. Another im-
portant outcome of this study was that it provided a
forum for discussion and critical self-reflection for
the Russian EA community. In comparison with
similar debates taking place in the 1990s, this one
was more systematic, as it sought to rely on objec-
tive evidence. In this case, the participants in the
debate also had more incentive to co-operate, as they
126
had to prove to policy-makers the value of the EA
system.
The debate within the framework of the World
Bank study arguably resulted in strengthening the
cohesion and political power of the Russian EA
community. Much of this improvement has resulted
from the fact that different EA actors identified
common language, interests and agendas. For in-
stance, the difference between the proponents of the
OVOS and SER approach has all but vanished, as
the former realised the need to protect the SER insti-
tutional structure from being demolished and the lat-
ter embraced the idea of a more flexible process
meeting the need of the developers and the public.
The concept of the ‘Russian EA system’ (including
both SER and OVOS) that needs strengthening and
protection in its entirety became the common cur-
rency of the discourse associated with the study.
The World Bank study recommended the creation
of a professional association for EA in Russia that
could institutionalise the networks formed as a result
of the study and other capacity-building activities.
The objectives of the Association, endorsed at the
national EA workshop in Cherepovets at the end of
2003, included (Vologda Environmental Protection
Committee, 2003):
• developing capacity in EA through education, re-
search and information dissemination;
• maintaining professional and ethical standards in
EA; and
• strengthening contacts between EA actors in Rus-
sia and abroad.
Regulatory developments
In addition to the Federal Law on Environmental
Review (1995) and the Federal Environmental Pro-
tection Law (1991, updated in 2002), there are three
currently active federal regulations on SER and one
on OVOS/EIA.6 In addition, a number of regulatory
acts were issued by the regions, which have a consti-
tutional authority to legislate within the framework
provided by federal laws (see, for instance, Box 2
and note similar EA regulations in Perm,
Box 2. Draft EIA regulations and guidelines in the
Arkhangelsk oblast
The draft EIA regulations prepared in 2002 are aligned with
the federal EIA Regulations (2000). However, they proposed
a specific screening system. For category A projects, the full
EIA procedure, as envisioned at the federal level is con-
ducted. There is a screening list to assign activities to these
categories. For category B projects a simplified EIA proce-
dure is conducted (largely limited to a preliminary EIA).
However, if there are significant public concerns, as identi-
fied at the stage of preliminary EIA, the project may be as-
signed to category C where additional public consultations
are required. The draft EIA guidelines were prepared to in-
terpret, explain and clarify both the federal EIA procedure
and the regional EIA Regulations (Khotulyova, 2002).
Impact Assessment and Project Appraisal June 2004

Sverdlovsk, Tomsk, Vologda and other Russian re-
gions (Ecoline, 2003)).
Of all the federal documents, the 2000 EIA Regu-
lations are undoubtedly the most important. They
define, for the first time, in legal terms the steps of
the project-level EA procedure in Russia and its re-
lationship to the traditional instrument of SER.
These regulations are in line with international prac-
tice, including most requirements of the Espoo Con-
vention, Aarhus Convention and the EU EIA
Directives.7 The following are the most important
elements introduced by the regulations:
• the two-stage EIA procedure with scoping (pre-
paring terms of reference) taking place after the
first stage;
• explicit requirement to produce a publicly available
environmental impact statement with a specified
content;
• requirements for public notification, public hear-
ings and provision for public participation in
scoping.
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The 2000 EIA Regulations also tackle the issue of
screening, which has proved to be a matter of bitter
debate and division within the Russian EA com-
munity for years. According to the framework
environmental legislation and the 1995 Environ-
mental Review Law, all economic activities and
other activities that may result in direct or indirect
environmental impacts are subject to SER, which
should review “materials on the assessment of envi-
ronmental impacts”.
Some stakeholders had interpreted this as the
requirement to conduct EA for all activities, how-
ever small and insignificant. At the same time, the
majority agreed that such an approach would be
ineffective and unsustainable, because it over-
whelms SER authorities, leads to procedural defi-
ciencies, opportunities for corruption, and lower
effectiveness, and puts a disproportionate burden on
small and medium-size projects with no significant
environmental impact.
There have been numerous attempts, including the
1994 OVOS Regulations, to introduce lists of envi-
ronmentally significant activities for which EIA
would be mandatory, but such attempts were criti-
cised on a variety of grounds, and even challenged
by prosecutors’ offices on the grounds that they
violate federal legislation.
The 2000 EIA Regulations took an intelligent step
towards resolving the screening issue by a) estab-
lishing a screening step within the EA procedure and
b) delegating to the regions the authority to “sim-
plify the EIA procedure” for certain “environmen-
tally insignificant categories of activities”. Such
regional screening regulations, which should be
approved by the federal authorities, were to reduce
the number of EIAs conducted at the regional level
to manageable size.
This solution has opened the door to experiments
Impact Assessment and Project Appraisal June 2004
EA in the Russian Federation
with regional screening regulations (for instance, in
Arkhangelsk (Box 2), Moscow, Tomsk and Vologda
oblast), which in a number of cases has been success-
ful. However, taking into account the insufficient ca-
pacity in many Russian regions, the most realistic
approach to establishing screening provisions is to is-
sue framework federal guidance and enforce its trans-
lation into regional regulations, at the same time,
building the awareness and skills of regional officials.
Such guidelines will be drafted in the near future with
the participation of regional representatives (Vologda
Environmental Protection Committee, 2003).
Conclusions and recommendations
This paper provides an overview of the recent evolu-
tion of the EA system in the Russian Federation. It
demonstrates how various contextual factors af-
fected developments in EA regulations and practice.
The EA system emerged in the late 1980s and the
early 1990s as a result of growing public and politi-
cal awareness of environmental issues, pressures for
transparency in decision-making and increasing
interest to environmental policy tools used in devel-
oped countries.
In the mid-1990s, the EA institutions operated
under conditions of economic decline, political in-
stability, relatively weak government and businesses
rather indifferent to regulations. At present, they
have to adapt to rapidly expanding economic activi-
ties, the low political profile of environmental
matters, consolidating executive power, more
sophisticated politics and businesses intensely lob-
bying for their interests.
Such a change provides both a threat and an
opportunity for an EA system. For example, the
growing political influence of private business may
threaten EA institutions. This is partly what hap-
pened in Russia when SER provisions were inter-
preted as an “obstacle to investment” and were all
but revoked in 2000. At the same time, as businesses
evolve and consolidate they are increasingly inter-
ested in playing by clear, transparent and universal
rules, thus they may support rule-based, transparent
and clear EA provisions.
Despite many difficulties, the Russian EA com-
munity has managed to avoid several threats and
utilise some opportunities arising from the change in
its societal context. The paper demonstrates that
such an ability to respond to change, a characteristic
of an ‘adaptive policy system’, is linked to the
capacity of EA actors to form cross-sectoral net-
works, to critically evaluate and reflect on existing
experience, to experiment with various approaches,
and to be open to diverse forms of domestic and in-
ternational knowledge.
The networks of EA actors in Russia described
in this paper, show a distinct characteristic of ‘trans-
lating’ various ideas and interests.8 Perhaps the
most remarkable translation occurred between the
127
 EA in the Russian Federation
advocates of SER and OVOS. The poor ability of
the two groups to co-operate had slowed the devel-
opment of the system in the mid-1990s. However,
when the SCEP was abolished in 2000, both camps
felt sufficiently threatened to initiate meaningful co-
operation. They tacitly agreed on a concept of the
“Russian EA system” that included both SER and
OVOS and needed strengthening in its entirety.
Moreover, the Russian EA community success-
fully enrolled the World Bank, some large indus-
tries, environmental consultancies and NGOs, as
well as regional environmental bureaucracies,
willing to experiment with pilot approaches, into this
project of strengthening the Russian EA system.
Much of this ‘translation’ and ‘enrolment’ occurred
in the course of the World Bank’s study of the effec-
tiveness of EA in Russia.
For example, during the World Bank’s study, the
traditional barrier between the officials and the
NGOs was lowered, because the former clearly
needed public support for the EA system. The indus-
try and the regulators could both argue for a trans-
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parent rule-based internationally benchmarked
approach that would stimulate, rather than hinder,
investment. The regions and the centre could also
co-operate in piloting regionally specific solutions
and in mobilising both bottom-up and top-down
support for the system. Facing the destruction of the
Russian EA system, the international community be-
came keen to learn how it functions and how it can
be protected, whereas Russian EA professionals be-
came very interested in collecting evidence on the
value of EA systems internationally.
The paper highlights an important lesson from
Russia, potentially relevant to larger countries with
semi-autonomous regional administrations. Many
regulatory and practical developments have proven
to be easier to implement at the regional level than
national level, because political commitment can, in
many cases, be easier to secure and the institutional
structures are more flexible. “The diversity of Rus-
sia’s eighty-nine regions is a fertile ground for pilot
testing new approaches” conclude von Ritter and
Tsirkunov (2002). Regional-level policies are also
easier to implement since they are often formulated
by those directly involved in implementation.
However, a bottom-up approach, where pilot EA
policies are formulated and tested at the regional
level can be successful only if there is a vigorous
‘horizontal’ dialogue between the regions supple-
mented by a ‘vertical’ dialogue with the central
government.
The Russian EA community shares the opinion
that the overarching goal, at present, is to have the
EIA Regulations (2000) consistently and effectively
implemented, while retaining the capacity and
increasing efficiency of the SER institutions. Estab-
lishing a coherent screening system is a pre-
condition for attaining this goal. Retaining the
capacity of the SER institutions, can be achieved if
the division of responsibilities in this sphere between
128
Moscow and the regions is adequately resolved.
During the debates on the World Bank study, this
was flagged as a contentious issue, which attracted
significant controversy.
Many observers maintain that, in view of dramatic
cuts of federal bureaucracy planned by Putin, it
would be sensible to delegate some EA responsibili-
ties to the regions, which have significant legal and
executive autonomy. Opponents point out that any
such dramatic changes in administration are likely to
result in collapse of the vulnerable SER institutions,
that regions do not have adequate capacity for im-
plementing EIA provisions and that, last but not
least, the present politics at the regional level is
unlikely to favour national and global environmental
goals.
The World Bank recommendations envision a
gradual process for developing a vision and studying
options for the division of responsibilities between
the centre and the regions, taking the experience of
other federal states (Canada, Germany and the USA)
into account.
Finally, the issue of the integration of OVOS and
SER, haunting the Russian EA system for more than
a decade, should be resolved. This is one of the three
principal recommendations of the World Bank study
(the other two are improving screening and scoping,
and strengthening SER institutional capacity). For
example, involvement of SER in approving terms of
reference for OVOS is a logical step to facilitate
such integration. Tighter integration of OVOS, SER
and environmental permission can also be achieved
relatively easily by strengthening the integration of
‘new’ and ‘traditional’ environmental policy tools
(see OECD, 2003).
A number of other issues are widely discussed
within the Russian EA community. The most promi-
nent one is probably strategic environmental as-
sessment (SEA). The existing SER and OVOS
regulations do not have any specific requirements
for strategic-level activities, which are presumed to
be assessed in the same way as project-level devel-
opments. In practice, the number of SEAs is very
small and they are almost entirely limited to plans
and programmes rather than policies (see the section
“Overview of the EA system in the 1990s”). At the
same time, there are several mechanisms, beyond the
SER system, for incorporating environmental con-
siderations into strategic documents such as urban
and territorial development plans.
How effective these mechanisms are and how
they might be linked with the SER and OVOS re-
quirements is not very well understood. SEA was
explicitly excluded from the World Bank study and
the awareness of this issue is only just starting to
emerge (Vologda Environmental Protection Com-
mittee, 2003). The first steps in strengthening the
Russian SEA systems are currently underway within
the joint project between Ecoline EA Centre and the
Regional Environmental Centre (REC) for Central
and Eastern Europe funded by the EU. This project
Impact Assessment and Project Appraisal June 2004

will involve, not only the existing networks of EA
professionals, but also economic planners and re-
gional-level politicians to explore and pilot various
options for implementing SEA (Ecoline EA Centre,
2004).
Thus, the Russian EA system still faces many
challenges related to both regulation and practice.
Some of these are fairly trivial (such as screening),
while others are difficult even for more mature EA
systems (such as SEA). The risk of the collapse of
the system is still a real threat, though less so than
three or four years ago. The World Bank proposes
four sensible “guiding principles” for dealing with
these challenges (von Ritter and Tsirkunov, 2002):
• assured basic implementation capacity;
• efficiency and business friendliness;
• effectiveness, by focusing limited institutional,
analytical and financial resources on the most sig-
nificant environmental impacts;
• long-term impact by evolving the EA system from
a ‘do-no-harm’ tool to an instrument supporting
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sustainable development decision making.
The first of these principles deserves further com-
ment. While “basic implementation capacity” (in
terms, first of all, of the number and resources of
SER employees) is a precondition for the survival of
the system, it is certainly not sufficient for its effec-
tiveness and development. To explain the ability of
the system to develop, such a notion should be sup-
plemented by that of ‘advanced capacity’, related,
inter alia, to the ability to learn and network as
described above.
The domestic and international EA communities
may help to develop such a capacity in Russia, based
on systematic evaluation of capacity needs and de-
veloping capacity-building strategies. Provided that
such strategies are well formulated, implemented
and effective, we can expect new dynamic develop-
ments in the Russian EA system.
Notes
1. See for example, Khusnutdinova’s discussion of the influence
of the Russian system on EA in Uzbekistan (pages 167–172 of
this issue). See also Bektashi and Cherp (2002); Cherp
(2000); and Galstyan (2002) for examples from Azerbaijan,
Armenia and Belarus respectively.
2. The first usage of the English term was in Cherp and Lee
(1997). ‘State ecological (or environmental) examination’, ‘eco-
logical expertise’ and other translations have also been
common.
3. OVOS is the Russian abbreviation for the assessment of im-
pacts on the environment.
4. It was not uncommon for developers to undertake two EIAs:
one to satisfy an international lender or investor; and one to
meet the Russian SER requirement (see, for instance, Proko-
pets, 2001). The main problem was often that western devel-
opers could not easily submit to SER the project
documentation prepared by the strict and formal project design
rules.
5. These were not widely familiar to proponents and authorities
and often were deemed too complex, especially for smaller
Impact Assessment and Project Appraisal June 2004
EA in the Russian Federation
activities. A similar situation was earlier observed in relation to
the OVOS Regulations 1994.
6. The full updated list of Russian EA regulations can be found at
the Internet site of the Network for Environmental Assessment
in Countries in Transition (see CEU, 2004).
7. With the notable exception of screening — see below.
8. The terms ‘translation’ and ‘enrolment’ are used in the author-
network theory to describe “interaction within networks … as a
continuous process of ‘translation’ and ‘enrolment’ in which ac-
tors negotiate the definition of each others’ interests, and try to
link the interests of others to projects they themselves want to
carry out” (Latour, 1987 and Callon, 1986 quoted in Cherp and
Antypas, 2003)
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