Mr. Arnulf Müller-Helmbrecht
Executive Secretary

Secretariat of the Convention
on the Conservation of Migratory Species
of Wild Animals

Martin-Luther-King Str. 8

53175 Bonn, Germany

Ref. 1-12/9132
05.12.2003

Subject: MoU concerning Conservation, Restoration and Sustainable Use of the Saiga Antelope

Dear Mr. Müller-Helmbrecht,

The Ministry of Agriculture of Russia has sent twice its proposals (letters of 24.01.03 No. 12-02-17/103 and of 08.05.03 No. 3-12/3715) on Memorandum of Understanding concerning Conservation, Restoration and Sustainable Use of the Saiga Antelope (MoU) and the Action Plan concerning Conservation, Restoration and Sustainable Use of the Saiga Antelope, which is integral part of MoU, to the Secretariat of the Convention on the Conservation of Migratory Species of Wild Animals (CMS). However, none of the proposals and remarks was taken into account neither in MoU nor in Action Plan.

In spite the fact that the Ministry of Agriculture of Russia has undertaken all main activities on monitoring and protection of the Saiga Antelope in Russia, as appears from the National Report of Russia on International Meeting in Elista in May 2002, its role in collecting and accumulating data on dynamics of the Saiga population state as a whole as well as in protection of nominal subspecies of this animal in Russia is not mentioned.

Having possessed the information collected in recent years as well as the multiyear factual data, on basis of which the cyclical fluctuations of the Saiga population in the North-West Caspian area be tracked, we believe that the analysis of the current state of the Saiga in Russia given in the Action Plan is not represented the facts and the parameters of the population changes being compared are not actually comparable to produce objective appraisal of these changes.

Incomplete knowledge on current population state, inaccurate analysis of influence of complex of limiting factors, denial of the regularities of population trends and ignoring of existing system of the Saiga monitoring and protection in the Russia prevented the authors from developing the Action Plan that ensure enhancement of effectiveness of the practical measures currently undertaken to protect and increase the Saiga stock.

In many respects the Action Plan is already out of date. The main tasks on monitoring of the state and protection of the Saiga population, which only, according to the authors, are planned to be implemented, have already been undertaken in Russia for many decades. The efforts taken give positive results. For example, by the year 2001 the annual decline in the Saiga stock in Russia had decreased by 1.5 times, and since 2001 the Saiga numbers has been stabilised. At the same time, the monitoring and protection measures have constantly being improved; additional measures for the Saiga stock reproduction have being elaborated and applied including captive breeding activities.

The Action Plan proposed is declarative and is not working actually. The Action Plan should clearly identify the most important, really achievable, and priority tasks; terms and methods of their implementation; indicate the concrete, qualified and responsible actors; specify the size and source of financing, both on the whole and for particular tasks; identify the results expected and reporting requirements.

The Ministry confirms its readiness to consider again the MoU and the Action Plan and how to implement them after having the documents properly amended by the CMS Secretariat.

Please accept, Mr. MГјller-Helmbrecht, the assurances of my highest consideration.

A.V.Gordeyev
Minister