Federalism and the integration of minorities

By Doris Wydra

 

Since the end of the 20th century more and more federal structures are developing in Europe, especially in Eastern Europe and also within the Russian Federation the structure and possible development of federalism are still under discussion (Münch 1996). Within the European Union the key word of a “Europe of the regions” started an academic debate on possible models for the “federalisation” of the European integration. The challenges for the member states are characterized in concepts of “multi-level governance” (decision making competencies are shared by actors at different levels rather than monopolized by national governments) and the “joint decision trap” (characterizing the inter-linkages and decision blockades in a multi-layered system). This problem becomes more and more evident, as more and more members of the European Union create some federalist structures or regional autonomies (Scharpf 1994; Hooghe/ Marks 2000; Kohler-Koch/ Jachenfuchs 1996).

Federalism is seen as an essential element for democracy and integration, especially in countries with a variety of different regions and minority constellations. This article tries to give an overview of different approaches to federalism in Western European States and the European Union and puts this in relation to Russian federalism. The central focus will rest on the different relations between federalism and minority protection and the different approaches of different states to solve problems of ethnic and language conflicts within heterogeneous societies according to their peculiar situation. This will lead us to varying implementations of federalist concepts. A special problem with regard to ethnic tensions and the cohabitation of different linguistic groups within one state or one region is the question of education, especially in relation to language learning and education in the mother tongue. Therefore this article will also show some of the regulations of educational issues within different federal systems.

 

General aspects of federalism and minority integration

 

One of the main aspects of federalism is the distribution of the state territory and authority between the federal state and the federal subjects. Also the federal subjects enjoy state quality. This delimitation of competencies and powers is reflected by the institutional setup of the state, like parliament, government, administration and the judicial system. The subjects dispose of genuine competencies, which are not derived from the central state and a set of instruments to allow for their participation in the policy formation of the federal state (Laufer 1996). As a prerogative federalism includes three essential components, the federal, regional and municipal component. Local self-government is therefore an indispensable element of federalism (Rykin 1998). Mayntz states, that “federalism does not simply signify decentralization, but denotes a multi-level structure, the interdependent concurrence of central and regional levels of decision-making. It is not the element of decentralization within federalism but exactly the concurrence of various levels of decisions-making which represent a decisive evolutionary advantage (Mayntz 1990)”.

 

Today, federalism is more and more discussed as a means of minority protection in heterogeneous societies. To protect minorities multicultural societies have developed two main concepts: on the one hand the concept of individual freedom and equality, leading to the individualisation of minority rights and on the other hand the principle of territorial autonomy, basing rather on the rights of a group of persons living in a common territory (Fleiner-Gerster 1995). But within poly-ethnic societies territorial autonomy may not as such lead to an adequate protection of minorities. Although the model case of Switzerland mainly rests on the territorial principle, this cannot simply be transferred to other heterogeneous societies, as the Swiss system rests on a historically grown republican and democratic self-understanding of the Cantons. This is not per se given in other societies, where the simple application of the territorial principle for minority protection may lead to deficits for minorities without a specific territory (Heinemann-Grüder 2004).

Although most modern theories on democracy build on a more or less homogenous and closed society and on a basic consensus of the people living in a democratic state,  this is rarely the case, especially in countries with heterogeneous minority structures (Fleiner 1995). In literature it is therefore quite often argued, that pluralistic nations call for a federal state structure. It is based on the presumption that in multicultural states the principle of consensus has to be superior to the majority principle (Saladin 1995; Fleiner-Gerster 1995). This implies that federalism and democracy can in some way be seen as contradictory principles, as they are basing on differing values. It can be said, that the “nation of persons” is incompatible with a “union of places”. This argumentation assumes, that democracy necessarily depends on the rule of simple majority votes. In fact federalism can be a method to increase the majority necessary for state decisions. This does not imply the search for a “super-majority” for decisions but whenever issues are touched that bother the essential interests of one or another group, this group has a right to protest, that cannot or only under more difficult conditions be annulled (Abromeit 1997).

 

 

Different concepts of federalism and minority protection: Switzerland, Germany, Belgium and Austria

 

State concepts

 

Switzerland is a pluralistic nation without ethnic, linguistic or cultural homogeneity. Quite often the Swiss system is portrayed as the model case of a federal system. Switzerland is called a “nation of will”. This includes the commitment to similar basic values. The Swiss form of federalism is mainly based on collective rights (in contrast to ideas like the French “social contract” or liberal basic rights). The central constitutional parts of the Swiss state are the cantons and the municipalities. The Swiss state understanding bases on a community that is defined and formed by politics (Basta 1995). Swiss federalism is often characterized as solving the contradiction between democracy and federalism by controlling federal power by democratic means and democratic decisions by federal power sharing. In contrast to federal states basing on the principles of liberal democracy (like the USA or Canada), where federalism is an instrument to bring together different groups and overarching particular interests by state unity, and federalism is regarded a supplement to democracy and as a principle of power control, in Switzerland federalism is a structural principle of democracy, that also includes participatory elements as part of federalism. This leads to a constant search for consensus, a democracy of negotiation (Basta 1995).

The Swiss constitution bases on the principle of shared sovereignty between the federal state and the Cantons (Art. 3 Constitution) and a strong emphasis on pluralism within the whole political system of Switzerland (Fleiner 1995).

The main identification point within Switzerland is the Canton. The Swiss constitution (Art. 37) stipulates for a Canton citizenship, but all citizens of the Cantons have to be treated equally all over the Swiss territory.  According to Article 42 of the Swiss constitution the federation assumes all tasks requiring uniform regulation. The Cantons define the tasks, which they shall accomplish within the framework of their powers (Art. 43). Disputes between Cantons, or between Cantons, and the Federation shall be resolved, if possible, by negotiation or mediation (Art. 44 (3)) and the Cantons shall also participate in the decision-making process on the federal level, in particular in federal legislation (Art. 45).

Conflict solving between the Cantons and the federal state is mainly a duty of the state authorities. According to Section 4 of the Constitution (Federal Guarantees) the Federation guarantees the constitutions and the territory of the Cantons (this is a duty of the Federal Parliament, Art. 172 Constitution). The Constitutional Court decides on conflicts between the Cantons and the federation (Art. 189 (4)).

 

Like the Swiss federal system the German federalism is the result of a historic development, but was also enforced by the Allied Powers after World War II. The German Basic Law provides for the delimitation of competencies between the Federation and the federal States (Länder). According to Article 30 of the Basic Law all competencies, not explicitly assigned to the federal state lie within the range of competences of the federal States, but federal law overrides Land law (Art. 31). In the area of administration the German federalism shows a strong prevalence of the Länder, as Article 83 stipulates that “the Länder execute Federal laws as matters of their own concern insofar as this Basic Law does not otherwise provide or permit“(Kilper/Lhotta, 1996).  The constitutional orders of the Länder have to conform to the principles of a republican, democratice and social state governed by the rule of law. Municipalities must be guaranteed the right to regulate all local affairs on their own responsibility, also concerning financial autonomy. The Federation has to guarantee, that the constitutional order of the Länder confirms to the basic rights (Art. 28).

Because of the strong co-operation between the federal state and the Länder, but also because of the continuous co-ordination between the Länder in areas, where they are assigned single competence, the German model of federalism is often termed as “cooperative federalism”, but is also seen as “executive” federalism, as the federal system is very much dominated by the governments (of the federal state as well as of the Länder) (Münch 1996). According to the “eternity”-clause in Article 79 (3) the federal structure of Germany can not be changed (“An amendment of this Basic Law affecting the division of the Federation into Länder, the participation in principle of the Länder in legislation, or the basic principles laid down in Articles 1 and 20, is inadmissible“) (Arndt 1999). It has to be noted, that this only guarantees the federal structure of the German state, but is no guarantee for the continued existence of the Länder as they exist at the moment[1].

Like the Swiss federalism within the German model the affiliation to the federal subject is a strong reference point, although it is not institutionalised like in Switzerland. A special test for German federalism was the re-unification in 1990. Article 72 of the Basic Law stipulates that the Federation has the right to legislate in matters of concurring legislation if and to the extent that the establishment of equal living conditions throughout the federal territory or the maintainance of legal or economic unity renders federal regulation necessary and in the national interest. Clearly the new Länder had no equal living conditions, which called for assistance of the “old” Länder. The new subjects of the Federation were also stronger influenced by the central state which started discussions about possible tendencies to unitarism (Münch 1996)

 

An example for a relatively new federal system in Western Europe, also as a reaction to tensions between linguistic groups, is Belgium. In contrast to Germany and Switzerland this federalism is not the result of a historic development.

The new constitution of Belgium (adopted in 1993) set up a very complex federal system, which aims at transforming a unitary state into a federal state. The constitution divides the Belgian territory into three federal entities but recognises also a personal autonomy for linguistic communities. It combines three models for minority protection: individual human rights, territorial federalism and personal federalism (Fleiner-Gerster 1995). Constitutional amendments that pertain to regional interests, like expanding the catalogue of regional competencies, require not only a two-thirds majority within the Belgian parliament, but also a majority within both linguistic groups in each of the legislative chambers. Belgian federalism is insofar peculiar, that it not only uses “territory” as the basis of its federal structure, but it also comprises a non-territorial component. The territorial component is mainly structured around the two largest linguistic communities, the French community and the Dutch-speaking community. Separate regional and Community parliaments and governments continue to exist, although within the French regions these tend to be unified. But still differences exist. Brussels for instance is a Region and not a Community, while the small number of German-speakers are a Community and not a Region. The fact, that Belgium was formerly a unitary state lead to a different solution than in Germany and Switzerland: while in these countries all competencies not explicitly assigned to the federal state remain within the competence of the subject, in Belgium all powers which have not been assigned to either level of government remain in federal hands. Belgian federalism also features a lot of characteristics of “intra-state” federalism, securing that the regions can contribute to federal policy-making. It also includes several provisions to prevent the federal government from proposing legislation that violates the interest of the French-speakers, as those are the largest minority at the federal level (Swenden 2003).

The Belgian Court of Arbitration (Constitutional Court) up to now plays only a limited role, as he cannot control the compliance of federal and regional laws with all articles of the constitution, but only with some of its principles (principle of equality, freedom of education and ideology and the distribution of competences according to the constitution or in special majority laws) (Swenden 2003).

Although Belgian federalism comprises three regions and three communities, Belgian politics is in essence bipolar, as the German speaking population is very small in number. In contrast to the Swiss system, where political parties play a rather secondary role, in Belgium they are of mayor importance (Swenden 2003).

 

The Austrian system of federalism bases on the principle of the hierarchy of legal norms and the concept that all sub-national power devolves from the federal constitution. The constitutions of the provinces are delegated law. But according to Article 99 of the Austrian constitution (Marko 2004)[2] the provinces have “relative autonomy”, which means, that they are free to regulate all organisational affairs as long as these provisions do not directly contradict any provision of the constitution (Marko 2004). In contrast to already presented federal systems like Switzerland or Germany, the Austrian federal constitution provides for a detailed regulation of the structure and the operation of the provinces. For instance Article 95 of the Austrian Constitution stipulates, that the legislative power of the province has to be exercised by a unicameral parliament, all representatives have to be elected on the basis of proportional representation. Further detailed provisions regulate the status of parliamentary representatives of the federal subjects as well as the procedure of law making in the provinces. Sub-national constitutions can authoritatively only be interpreted by the Austrian Constitutional Court. This creates a very tight framework for the institutional set-up of the provinces.

 

This brief overview about different federal systems showed that federalism is a legal and political term, but has no fixed substance. As diverse as federal systems in themselves are the provisions for minority protection within federal systems, as the next paragraph will show.

 

Minority and language protection in different federal systems

 

Different federal and constitutional systems also lead to different mechanisms of minority protection and integration of different ethnic and linguistic communities. Within Swiss federalism terms like “minority” or “majority” do not have any real significance. There is a common participation in power by the different linguistic and religious communities. The linguistic groups for instance have to be reflected by the composition of the government (art. 175 (4)). Those communities are the constitutive element of the Swiss federal state. Minorities are seen as an essential value in relation to the independence of the Cantons, the linguistic authority of the Cantons and the municipal autonomy. This leads to an inter-linkage of minorities, as the minorities are overlapping and to a democracy of institutionalised (linguistic and religious) diversity (Basta 1995).

Switzerland knows three official languages and four national languages (art. 4 Constitution). But although French, German or Italian Swiss do feel a cultural proximity to the respective nation states, they do not lean towards them in a political sense. In literature Switzerland is often called an “a-national” state. There are also no “national” minorities in Switzerland, as people talking different languages belong to a certain “language community”, but not to different “nations” (Fleiner 1995).  The central provision of the Swiss constitution for the protection of linguistic rights is article 18 guaranteeing the freedom of language. Article 62 of the Swiss constitution transfers the competencies for education, and with this also language education, to the Cantons. There are four multi-lingual cantons, but only in Grisons three languages are spoken. Within these Cantons the linguistic groups are protected by delegating nearly all competences regarding culture and education to the municipalities, who are also deciding about the school languages (because of the factual role of the German language in the canton Grisons, at all schools German is taught as complementary language. To enhance bilingualism in German schools Italian and the Romansh language have been introduced as second languages (Fleiner 1995). This provision is for instance in contrast to Canada, where each individual has an extensive language rights, while in Switzerland the freedom of language is mostly connected to the principle of territory. This can only diminish conflicts between linguistic groups if it is applied rather variable in mixed territories (Fleiner in Samardzic). Article 70 stipulates that the official languages of the Federation are German, French and Italian. Romansh shall be an official language for communicating with persons of Romansh language. The cantons also have the right to designate the official languages. In order to preserve harmony between linguistic communities, they have to respect the traditional territorial distribution of languages, and take into account the indigenous linguistic minorities. The Federation shall also encourage multilingual cantons in the fulfilment of their particular tasks, especially the measures taken by the Cantons of Grisons and Ticino to maintain and to promote Romansh and Italian.

There are two essential problems that may challenge the Swiss model of federalism and minority integration: the first is, that this system is not adopted to non-Swiss nationals (immigrants), who are not a structural part of the system. For taking part in decision procedures within the Cantons and municipalities, they only have the chance of voluntary assimilation. The other challenge is the increasing difference of the economic development of the Cantons, as this may as a consequence also dissolve the consensus between the linguistic groups. Another development can become an increasing problem of legitimacy of the Swiss form of federalism, rather basing on direct democracy than on representative elements, as the participation in votes is diminishing (Basta in Samardzic).

 

The Swiss model, although in literature often presented as ideal model of federalism, cannot be easily transferred to other states and systems, although some basic principles can be derived from it. One essential element is, that it shows, that federalism may be an instrument of identification building, by strengthening the identification of various groups with the federal state through identification with a subject of the state. This is especially important for minorities and for their relation with the overarching state, as they are more easily building a loyalty with a state where they have the possibility to articulate their interests.

When talking about minority protection in Germany one has to keep in mind that the overall number of persons belonging to national minorities is very small and only limited to specific territories (the term excludes so called “new” minorities, like Turks, comprising a far larger number of people and living all over the German territory. When signing the European Framework Convention for the protection of National Minorities Germany declared that, as the Convention contains no definition of the notion of national minorities, its provisions will be applied to the Danes, the Sorbian people, the Frisian and the Sinti and Roma. The federal constitution does not contain any specific provisions on minority protection, but the constitutions of the Länder where national minorities live, do. The constitutions of Brandenburg (Art. 25) and Saxony (Art. 6) contain provisions on the Sorbian minority (e.g. Article 6 Constituton Saxony: (1) The citizens of Sorbian nationality who live in the State constitute an inherent part of the people of the State and enjoy equal rights with the remaining people of the State. The State guarantees and protects their right to preserve their identity and to preserve and develop their traditional language, culture and customs, in particular by way of schools, pre-school and cultural establishments. (2) The necessities of the Sorbian people are to be taken into consideration in regional and local planning. The German-Sorbian character of the Sorbian ethnic group's area of settlement is to be maintained. (3) The cooperation between Sorbs beyond the State boundaries, particularly in Upper and Lower Lausitz, is in the interests of the State). Article 5 of the constitution of Schleswig-Holstein provides for the cultural autonomy and political participation of the Friesian and the Danish minority. Constitution of Sachsen Anhalt (Art. 37) and Constitution of Mecklenburg-Vorpommern (Art. 18). The common basis of these provisions is, that they guarantee minority rights only to German citizens.

In Germany education falls within the competences of the Länder. As there is the demand for certain homogeneity the Länder have coordinated their educational politics and policies, which leads to a high level of conformity in the educational systems between the federal subjects of Germany. This is done mainly institutions like the Conference of Ministers on Education (Schade 2000). Länder, on whose territory national minorities live also have adopted special provisions for the language education of those minorities. For instance the Law on Schools of Saxony stipulates in Article 2, that within the german-sorbian territory all children have to have access to learning the Sorbian language or to be taught certain subjects in the Sorbian language. The ministry of culture is responsible for setting up provisions with regard to the status of the Sorbian language as foreign language or as mother tongue within the schooling system. This is added by the provision that in all schools in Saxony basic knowledge on the history and culture of the Sorbian people has to be taught. Like in Switzerland the strong territorial connection to the realisation of linguistic rights gets evident.

The German system of federalism shows a lot of differences regarding the integration of immigrants in different subjects, as the Länder have extensive powers regarding integration policy (Thränhardt 2001). An analysis of the German educational system shows, that the achievements of pupils from immigrant families, vary from federal subject to federal subject. This can be attributed on the one hand to a phenomenon called “institutionalised discrimination” which is a form of discrimination that is inherent in the institutional system of education but also to different forms of education of pupils from minority groups in different federal subjects and if the educational tends towards segregation (e.g. by creating separate classes for foreign pupils) or integration (e.g. comprehensive schools). This analysis also shows that there is a direct connection between educational policy and the overall policy on foreigners of the subject (Hunger 2001).

 

In Austria minority protection mainly concerns the Slovene and Croat national minority, having their traditional territories in three of the Austrian provinces (Carinthia, Styria and Burgenland). According to Article 7 (paragraph 2, 3 and 4, all being part of Austrian constitutional law) of the Austrian State Treaty 1955 between the Allied Powers and Austria, they enjoy equal protection before the law and are guaranteed elementary education in their mother tongue. They also have special rights to use their language before the courts and administrative authorities (Marko 2004). For other, so called “autochthonous” minorities like Hungarians, Czechs, Slovaks, Roma and Siniti the provisions of the Peace Treaty of St. Germain 1919 are still in force. In Austria the education laws of Carinthia and the Burgenland contain provisions for bilingual elementary education. In Carinthia secondary education in the mother tongue is guaranteed by the educational law, bilingual secondary education in Burgenland (Marko 2004).

 

Until the year 2000 minority protection was an exclusively federal competence, in 2000 Article 8 of the Constitution of Austria was added up by paragraph 2 making linguistic and cultural pluralism a state goal with regard to the autochthonous ethnic groups. It is the task of the federation, the subjects and the municipalities to respect and protect ethnic groups, their language and culture. By this the provinces will be able to adopt minority protection law, but still only in the form of complementary law to the legislation passed by the federation (Marko 2004). Because of the federal prevalence the constitutions of the provinces in question (Carinthia, Styria, Burgenland or Vienna) do not contain any provisions regarding minority protection. They also follow the federal constitution providing that German is the official language, unless otherwise is provided for in national laws on the use of minority languages, like in the Law on Ethnic Groups) (Matscher 1994).

 

In Belgian the smallest linguistic group is the German speaking minority, that is not protected by a territorial autonomy but has full jurisdiction within the areas of culture, social matters and education within the German linguistic region. But it is almost totally excluded from the relevant mechanisms, which are designed to ensure a balance between Flemings and French speakers. They enjoy linguistic and cultural rights, but are only hardly included in the workings of the federal state (Scholsem 1994).

 

This introduction to different federal systems, most of them members of the European Union allows for a brief look on the regionalisation tendencies within the European Union itself, but also on the commitment to diversity since the Maastricht treaty (1992). On the second conference of the European Parliament in 1991 it was decided, that the future of the community asks for a framework, where each institution of the community, the national state and the regions can play an active role according to its competencies (Wittkämper 1997). The Treaty of the European Union declares the commitment of the Union to protect the cultures of the member states by securing their national and regional diversity, besides the emphasis of the common cultural heritage. The subsidiarity principle (Art. 5 of the treaty of the European Union)[3] aims at enhancing federalism and democratisation (Ridola 1995; Fleiner-Gerster 1995). Within the framework of the European Union the “Committee of the Regions” was created but up to now this institution has only limited functions. This tendency of the European Union also asks for some new definitions of the cooperation between the state and its federal subjects. For Germany this is regulated by Articles 23, 24 of the German Basic Law and the Law on the Co-operation between the Federations and the Federal States in matters concerning the European Union (1993) (Wittkämper 1997). The interlinked duties within the framework of the European Union contribute to an augmented dependence of the Länder from the federal state, also in areas where they have a single competence (Laufer 1996).

 

Federalism in the Russian Federation

 

While according to the soviet perception the government of a multi-ethnic state with the dimension of the Soviet Union was only possible by setting up a rather tight centralist concept, since 1991 the Russian Federation is the only successor state of the Soviet Union that opted for a federalist structure (Hickmann 1996). This federalism is of special importance as the cultural differences are an essential aspect of the Russian system. Especially the regions may therefore provide a basis for building identities (Hickmann 1996). Federalism in Russia combines elements of a constitutional federalism with treaties between the centre and the subjects.

 

Russian Federalism is mainly characterized as asymmetric federalism, although in principle the equal representation of the subjects is fixed within the Russian constitution[4]. This asymmetry is based on the federal treaties as the constitutional equality of the subjects is not fostered by the treaties, clearly putting a higher priority on the republics. Three forms of asymmetry exist: differences in the status of the subjects, that is provided for in the constitution, different executive powers, fixed by the bilateral treaties and variations of regional political regimes, that are mostly in contradiction with the constitution (Heinemann-Grüder, 2002). While the titular nations realise the right of self-determination the status of other non-Russian nations follow a certain hierarchy (Roesler 1997). Another term used for the Russian form of federalism is “ethno-federalism”. This refers to a system giving certain groups a privileged access to power within the subjects de jure and de facto and also comprises an ethnic component within the representation of the subjects at the federal level (Heinemann-Grüder 2004). The territorial borders of the Russian subjects do not follow the ethnic borders. Both, simple territorial or ethno-federalism would have had disadvantages for the Russian Federation. While full-fledged ethno-federalism could have led to disadvantages for Russian dominated regions, territorial federalism may lead to assimilation pressures on non-titular nations (Heinemann-Grüder GUS).

 

The Constitutional Court of the Russian Federation stated, that the sovereignty of the Russian Federation is primary and not derived from the sovereignty of its subjects. This is based on Articles 3 (1) and 4 (1) of the Russian Constitution. The carrier of the sovereignty of the Russian Federation is the multinational people and this sovereignty covers the whole territory of the Russian Federation. From the state quality of the subjects no sovereignty can be derived (Uebe 2004).

 

In contrast to other federal systems the delimitation of powers between the federal state and the subjects (Art. 71-73) is not adapted to the respective state power, but the competences of legislative and executive powers rather follow the general distribution of competencies. The subjects may issue legal acts in all areas that do not explicitly fall within the competence of the federal state. The Russian constitution only very generally mentions the delimitation of powers, but it does not clearly state if these are exclusive or concurring competencies. Especially difficult is the delimitation in the area of shared competencies. According to the constitution the subjects are competent, as long as the state has not issued any regulation. There is also no exact definition of the limits of the legislative powers of the subjects. Those limits are solely defined by the authority issuing the provision. The hierarchy of norms is not abstractly provided for in the basic law, but this hierarchy is rather determined by the competences to issue legal acts. In the case of collision the overriding legal act is not only prior with regard to the application but also with regard to validity, the lower-ranking provision is treated as non-existent (Hartwig 2004).

But the delimitation of competencies is not only fixed within the Russian constitution but also within federal treaties between the centre and a whole range of the federal subjects. These treaties vary from subject to subject and foster the asymmetry of the Russian federalism. Another problem is, that these treaties are not always in line with the requirements of the constitutional provisions, as single competencies of the centre became shared competencies or single competencies of the subjects and shared competencies were also provided for as exclusive competencies of the subject (Schneider 2004).

The principle organ of representation of the federal subjects of the Russian Federation is the federation council (Chapter 5 of the Constitution: Federal Assembly) consisting of two representatives from each subject, one from the legislative and one from the executive branch of the subject. But also in relation to the Federation Council some questions remain open, as the question for the representational role is not fully solved. It is not provided for, that both members in the Council represent the same subject. By this conflicts between the legislative and the executive branch of the subjects can be transferred to the Federation Council. In theory the members of the Council have a free mandate but in practice, according to Article 9 of the Law on the Federation Council, the mandate can be revoked at any time, as the reasons for this revocation are not mentioned (Awakjan 2004).

In basic Russian federalism shows three principal conflict lines: between the centre and the autonomies (especially the republics), between certain autonomies concerning economic privileges and between titular nations and other ethnic groups within the autonomies. Although in principle this may hint towards a possible intensification of conflicts within Russian ethno-federalism, this does not have to be the case. Ethno-federalism in itself may also lead to a de-escalation as no influential interest group puts the system under question and it also takes pressure from the centre. On the other hand as long as non-titular nations within Russia are not seen as constitutive for the state, but are characterized as minorities, ethno-federalism may also contribute to protect from assimilation and centralism (Heinemann-Grüder 2004).

 

One of the essential deficits of the Russian federalism is the missing institutionalised communication mechanism between the subjects of the federation (Hickmann 1996). Another problem are the contradictions between regional legislation and federal legislation. In part this dates back to the time before the Russian constitution was issued, as the subjects had already begun with working out their own systems of sovereignty, but is also a result of the lacking and imprecise delimitation of competencies within the Russian legislation (Heinemann-Grüder 2004).

 

Within Russia the Constitutional Court has gained power as authoritative instance for deciding on disputes between the centre and the subjects (Art. 125, 128). Still the execution of decisions of the Constitutional Court remains a problem (Keber 2004). Statutory courts have meanwhile become an essential element of the constitutional control within the subjects (those courts are not explicitly provided for in the Russian Constitution but are basing on Art. 1(1), 10, 11 (2), 18 (2) and 46) and the Constitution also includes specific provisions about the possibility of setting up a regional constitutional judiciary). The subjects also have the right to set up their own constitutional courts (according to Art. 71, 72, 73, 118, 125). Also the federal law on the judicial system (1996) includes general provisions on constitutional and statutory courts within the subjects. The laws now issued by a series of subjects do more or less follow the federal law “On the Constitutional Court of the Russian Federation”. The Constitutional Court of the Russian Federation assumes, that the regional court have the exclusive competency to scrutinize the normative acts of the federal subject, if such competencies are fixed in the respective constitution. The standard for the examination of the normative control of the regional courts is in principle only the constitution or statute of the subject, but in practice they also draws on the federal constitution (Kražkov 2004). 

 

In comparison to other federal systems Russia has chosen a rather centrist form of federalism and the primacy of legislation is not contrasted by a subject friendly structure of the executive branch. In the area of federal duties the administration of the subjects are more or less elongated arm of the centre because of the subordination to instructions (Hartwig 2004).

 

Conclusion

 

When talking about minority protection and integration within federalist systems, the shortcomings of federalism also have to be mentioned. „Regionalism“ can only safeguard certain minorities, namely those with territorial ties (Kulow/Steuer-Flieser 1995). Without adding features of personal autonomy, it does not protect dispersed minorities and can by this create primary and secondary minorities. Most of the federal structures all over Europe, including Russian federalism, do not aim at protecting so called “new minorities”, which means immigrants, like the Turkish minority in Germany.

In general it can be said, that within federalist systems political processes can be quite productive, if the federal state creates the right framework and the subjects cooperate in kind of an competition for optimisation. On the other hand federalism can also lead to a blockade between federation and subjects (Thränhardt 2001).

The role of traditional administrative entities is no longer only defined in relation to the national state but also in relation to international developments, especially concerning economic interests[5]. Globalisation and its effects on national political systems has been heavily discussed in recent years in political science. This of course also effects federal systems. Clearly the national state is, while still playing an important role, loosing its role as single nodal point.

 

Bibliography:

 

Abromeit Heidrun (1997), Direkte Demokratie und Föderalismus in der Europäischen Union, in: Eugen Antalovsky, Josef Melchior, Sonja Puntscher-Riekmann (Hrsg.), Integration durch Demokratie. Neue Impulse für die Europäische Union. Marburg: Metropolis Verlag für Ökonomie, Gesellschaft und Politik GmbH, 207-222.

 

Arndt Hans-Wolfgang (1999), Aktuelle Probleme, Entwicklungstendenzen und Perspektiven des Föderalismus in der Bundesrepublik Deutschland, in: Reinhard C. Meier-Walser, Gerhard Hirscher (Hrsg.), Krise und Reform des Föderalismus. Analyse zur Theorie und Praxis bundesstaatlicher Ordnungen, München: Olzog, 27-35.

 

Awakjan Suren (2004), Struktur und Funktion des Föderalismus im Wandeln von Jelzin zu Putin, in: Brunner Georg (Hrsg.), Der russische Föderalismus. Bilanz eines Jahrzehnts. Münster: LIT Verlag, 127-146.

 

Basta Lidija (1995), Minderheiten und ihre Legitimation des Bundesstaates, in: Slobodan Samardzic, Fleiner Thomas (Hrsg.), Föderalismus und Minderheitenprobleme in multiethnischen Gemeinschaften. Eine vergleichende Analyse über die Schweiz und Jugoslawien, Publications de l’Institut du Fédéralisme, Fribourg Suisse, 3-40.

 

Conference on Challenges of Federal Governance in the Russian and Canadian Federations, Ottawa 2000, problemy federativnogo stroitel’stva, www.forumfed.org

 

Fleiner Thomas (1995), Föderalistische und demokratische Institutionen und Verfahren zu Lösung ethnischer Konflikte in: Samardzic S., Fleiner T. (Hrsg.), Föderalismus und Minderheitenproblem in multiethnischen Gemeinschaften. Eine vergleichende Analyse über die Schweiz und Jugoslawien, Publications de l’Institut du Fédéralisme, Fribourg Suisse, 41-96.

 

Fleiner-Gerster Thomas (1995), Multikulturelle Gesellschaft und verfassungsgebende Gewalt. Staatslegitimation und Minderheitenschutz. Die Grenzen des Nationalstaatsmodells. In: Thomas Fleiner Gerster (Hrsg), Die multikulturelle und multi-ethnische Gesellschaft. Eine neue Herausforederung an die europäische Verfassung. Publications de l’institut du fédéralisme, Fribourg, Suisse, 49-68.

 

Gäßner Barbara (2004), Die Verfassungsgerichtsbarkeit in den Subjekten der Russländischen Föderation: Verfahrens- und Entscheidungsarten, Prüfungsgegenstände, Prüfungsmaßstäbe, in

Hartwig Matthias, Die Kompetenzverteilung zwischen der Russländischen Föderation und ihren Subjekten nach der föderalen Verfassung, in: Brunner Georg (Hrsg.), Der russische Föderalismus. Bilanz eines Jahrzehnts. Münster: LIT Verlag,  227-240.

 

Heinemann-Grüder Andreas (2002), Föderale Autonomie in Russland und in der GUS, Zentrum für angewandte Poliforschung zur Eigenverantwortung und Autonomie der Regionen.

 

Heinemann-Grüder Andreas (2004), Ethnischer Föderalismus in Russland – konfliktreduzierend oder-eskalierend?  in: Brunner Georg (Hrsg.), Der russische Föderalismus. Bilanz eines Jahrzehnts. Münster: LIT Verlag, 19-42.

 

Hickmann Thorsten (1996), Föderalismus und Transformation in Russland: Siamesische Zwillinge?, in: Ammon G., Fischer M., Hickmann T., Stemmermann K. (Hrsg.), Föderalismus und Zentralismus: Europeas Zukunft zwischen dem deutschen und dem französischen Modell., Baden-Baden: Nomos Verlagsgesellschaft, 158-174.

 

Hoohge Lisleth, Gary Marks (2000), Multi-level Governance and European Integration. Lanham, Boulder, New York, Oxford: Rowman & Littlefield Publishers Inc.

 

Hunger Uwe (2001), Bildungspolitik und „institutionalisierte Diskriminierung“ auf Ebene der Bundesländer. Ein Vergleich zwischen Baden-Württemberg, Bayern, Hessen und Nordrhein-Westfalen, in: Thränhardt Dietrich (Hrsg.), Integrationspolitik in föderalistischen Systemen, Jahrbuch für Migration 2000/2001, Münster: LIT Verlag, 119-137.

 

Jachtenfuchs Markus, Kohler-Koch Beate (1996), Regieren in der Europäischen Union. Fragestellungen für eine interdisziplinäre Europaforschung, in: Politische Vierteljahresschrift, 1996, 537-556.

 

Keber Tillmann (2004), Konfliktlösungsmechanismen zwischen Föderation und Föderationssubjekten, in Brunner Georg(Hrsg.), Brunner Georg (Hrsg.), Der russische Föderalismus. Bilanz eines Jahrzehnts. Münster: LIT Verlag, 281-300.

 

Kilper Heiderose, Lhotta Roland (Hrsg.) (1996), Föderalismus in der Bundesrepublik Deutschland. Opladen: Leske+ Buderich.

 

Kražkov Vladimir A. (2004), Die Verfassungs- und Statutengerichte der Subjekte der Russländischen Föderation, in: Brunner Georg (Hrsg.), Der russische Föderalismus. Bilanz eines Jahrzehnts. Münster: LIT Verlag, 207-226.

 

Kulow A.-C., Steuer-Flieser D. (1995) , Zusammenfassung und Aussprache, in: Thomas Fleiner-Gerstner (Hrsg.), Die multikulturelle und multi-ethnische Gesellschaft. Eine neue Herausforderung an die europäische Verfassung. Publications de l’institut du Fédéralisme. Fribourg Suisse, 29-36.

 

Laufer Heinz (1996), Zur Situation des deutschen Föderalismus, in: Ammon G., Fischer M., Hickmann T., Stemmermann K. (Hrsg.), Föderalismus und Zentralismus: Europas Zukunft zwischen dem deutschen und dem französischen Modell. Baden-Baden: Nomos Verlagsgesellschaft, 45-53.

 

Marko Jospeh (2004), Federalism, Sub-national Constitutionalism, and the Protection of Minorities.

 

Matscher Franz (1994), Federalism and protection of minorities. Constitutional aspects in Austria, in: Protection of Minorities in Federal and Regional States, Venice Commission, 1994, CDL-MIN (1994) 007e-prov-restr

 

Mayntz Renate (1990), Föderalismus und die Gesellschaft der Gegenwart, in Archiv für öffentliches Recht, 1990.

 

Münch Ursula (1996), Ergebnis deutscher Geschichte und mögliches Modell für Europa: Der bundesrepublikanische Föderalismus, in: Ammon G., Fischer M., Hickmann T., Stemmermann K. (Hrsg.), Föderalismus und Zentralismus: Europas Zukunft zwischen dem deutschen und dem französischen Modell. Baden-Baden: Nomos Verlagsgesellschaft, 54-75.

 

Ridola Paola (1995), Minderheitenschutz durch Regionalismus und Autonomie. Eine neue verfassungsrechtliche Herausforderung, in: Thomas Fleiner-Gerstner (Hrsg.), Die multikulturelle und multi-ethnische Gesellschaft. Eine neue Herausforderung an die europäische Verfassung. Publications de l’institut du Fédéralisme. Fribourg Suisse, 83-98.

 

Roesler Karsten (1997), Föderalismus als conditio sine qua non? Die Russische Föderation zwischen territorialer Integrität und nationaler Selbstbestimmung, in: Kellermann Kerstin, Nitschke Peter (Hrsg.), Zur Natur des Föderalen. Beiträge aus Theorie und Praxis. Münster: Waxmann Verlag GmbH, 101-116.

 

Rykin Victor (1998), Föderalismus in Rusßland von heute und Probleme der Nationalitätenbeziehungen, in: Maßnahmen zur Internationalen Friedenssicherung, Bd. 3, 1998.

 

Saladin Peter (1995), Verfassung und Grundrecht auf Kultur, in Thomas Fleiner-Gerstner (Hrsg.), Die multikulturelle und multi-ethnische Gesellschaft. Eine neue Herausforderung an die europäische Verfassung. Publications de l’institut du Fédérlisme. Fribourg Suisse, 7-20.

 

Schade Angelika (2000), A research topic in education law and policy: The development of regionalism and federalism in Europe and their impact on educational policy and administration, in European Journal for Eduation Law and Policy 4, 2000.

 

Scharpf Fritz W. (1994), Optionen des Föderalismus in Deutschland und Europa, Frankfurt: Campus Verlag.

 

Schneider Eberhard (2004), Die Kompetenzabgrenzungsverträge zwischen der Föderation und den Föderationssubjekten: Dynamik und Asymmetrie, in: Brunner Georg (Hrsg.), Der russische Föderalismus. Bilanz eines Jahrzehnts. Münster: LIT Verlag, 61-76.

 

Scholsem Jean-Claude (1994), Federalism and Protection of Minorities: Belgium, in Protection of Minorities in Federal and Regional States, Venice Commission, 1994, CDL-MIN (1994) 007e-prov-restr

 

Swenden Wilfried (2003), Belgian Federalism. Basic Instituttional Features and Potential as a Model for the European Union, Paper prepared for „Governing together in a new Europe“ Conference, 2003.

 

Thränhard Dietrich (2001), Zuwanderungs- und Integrationspolitik in föderalistischen Ländern, in: Thränhardt Dietrich (Hrsg.), Integrationspolitik in föderalistischen Systemen, Jahrbuch Migration 2000/2001, Münster: LIT Verlag, 15-34.

 

Uebe Franz (2004), Tendenzen der Rechtsprechung des Verfassungsgericht Russlands zu föderalen Problemen, in: Brunner Georg (Hrsg.), Der russische Föderalismus. Bilanz eines Jahrzehnts. Münster: LIT Verlag, 301-324.

 

Wittkämper G.W. (1997), Neue Vernetzungen: Transnationale und globale Politiken als Herausforderung an die „alten“ Kooperationsformen der Bundesländer, in: Kellermann Kerstin, Nitschke Peter (Hrsg.), Zur Natur des Föderalen. Beiträge aus Theorie und Praxis. Münster: Waxmann Verlag GmbH, 11-20.

 



[1]     This is also provided for in Art. 29 of the German Basic Law: The division of the federal territory into

Länder may be revised to ensure that each Land be of a size and capacity to perform its functions effectively, but with regard to regional, historical and cultural ties, economic efficiency, and , the requirements of local and regional planning. Thoses revisions have to be confirmed by a referendum of the respective Länder.

[2]     The difference between the Austrian and German constitutional law lies mainly in the fact, that while the

German Basic Law stipulates that all federal constitutional law has to be part of the constitutional document (Basic Law), the Austrian constitution does not contain such a provision. In Austria a whole range of laws and provisions exist, having constitutional ranking. This also results in quite frequent amendments of federal constitutional law.

[3]     The European Parliament, the Council, the Commission, the Court of Justice and the Court of Auditors

shall exercise their powers under the conditions and for the purposes provided for, on the one hand, by the provisions of the Treaties establishing the European Communities and of the subsequent Treaties and Acts modifying and supplementing them and, on the other hand, by the other provisions of this Treaty“

[4]     The Russian Federation shall consist of republics, territories, regions, federal cities, an autonomous region

      and autonomous areas, which shall be equal subjects of the Russian Federation (Art. 5 (1).

[5]     Conference on Challenges of Federal Governance in the Russian and Canadian Federations, Ottawa 2000,

      problemy federativnogo stroitel’stva, www.forumfed.org