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Genesis: Historical research
Reference:

Timber industry activity of the GULAG correctional labor camps of the OGPU-NKVD of the USSR in the late 1920s - 1937

Zykin Ivan

PhD in History

Associate Professor, Department of Social and Economic Disciplines, Institute of Technology (Branch) of the National Research Nuclear University "MIFI"

624200, Russia, Sverdlovskaya oblast', g. Lesnoi, pr. Kommunisticheskii, 36

zivverh@mail.ru
Other publications by this author
 

 

DOI:

10.25136/2409-868X.2022.7.36098

EDN:

JJPFYB

Received:

12-07-2021


Published:

18-07-2022


Abstract: The article examines the activity of correctional labor camps specializing in timber industry in the Soviet Union in the period from the late 1920s to 1937, singled out as the first stage of development of this group of camp complexes. The definition of the concept of "forest" correctional labor camps is given. For the first time, an analysis of the timber industry activity of the camps was undertaken. "Forest" camps functioned in the areas of the largest Soviet cities (Moscow and Leningrad), in the European North, the Urals and Siberia. Their main function was reduced to the development of woodlands, timber harvesting, mechanical processing of forest resources developed to a lesser extent. Conclusions are drawn about the gradual expansion of the scale of the timber industry activity of correctional labor camps in the period from the late 1920s to 1937. However, at this stage, the volumes of harvesting and mechanical processing of wood by "forest" camps were insignificant against the background of the development of the forest industry in the country. The first multiindustry "forest" camp appeared - the White Sea-Baltic Combine, which had a strong influence on the development of the timber industry in the autonomous Karelian Republic. With the help of prisoners' labor, the construction of a pulp and paper enterprise in the Urals was carried out. The experience of using prisoners in the timber industry in the period from the late 1920s to 1937 was a significant groundwork for further enhancing the role of the Main Directorate of Camps of the NKVD of the USSR in the industry.


Keywords:

timber industry complex, industrialization, GULAG, correctional labor camps, wood harvesting, mechanical processing of the forest, construction, prisoners, Belomorsko-Baltiysky Combine, Vishersky Combine

This article is automatically translated. You can find original text of the article here.

In the Soviet Union, in the process of planning and implementing the project of "socialist industrialization" (late 1920s - early 1940s), the timber industry was assigned a significant role. The growing needs of the country in the products of the industry actualized the need for the development of large forests, the construction of enterprises in the northern and eastern regions. Due to the fact that the timber industry was an industry with a low level of mechanization of production processes (especially in the field of timber harvesting) and required a large number of labor resources, the Soviet state resorted to various methods of attracting workers, including mobilization and coercive methods. First of all, it affected the districts of the largest cities of the country (Moscow and Leningrad), the European North, the Urals and Siberia. Having experience in mobilizing and forcing certain categories of the population to engage in forestry activities (for example, military personnel employed in labor armies in the early 1920s), party and state bodies, carrying out repressive and mobilization campaigns during the first five-year plans, directed significant labor resources to the forestry industry.

In the period from the second half of the 1920s to 1937, when the "socialist industrialization" began, including the development of forests, the construction of enterprises in the northern and eastern regions of the Soviet Union, correctional labor camps appeared, specializing in forestry activities. The mass repressions of 1937-1938 caused a significant increase in the number of camps that carried out timber industry activities, an increase in their importance in the production activities of the Main Directorate of Camps of the United State Political Directorate the People's Commissariat of Internal Affairs (GULAG OGPU-NKVD).

The work with sources and the study of the problems of the functioning of the GULAG have intensified in the country only since the late 1980s. For more than thirty years, a huge array of documents has been published, articles and monographs on the most diverse aspects of the activities of correctional labor camps have been published. The publications of V. A. Berdinsky and V. I. Veremyev [1], V. A. Berdinsky and V. I. Menkovsky [2]; G. M. Ivanova [5]; [6], L. P. Rasskazov [20], O. V. Khlevnyuk [27] analyzed the general trends and scales of forced labor in the USSR, economic activity GULAG, estimates of the repressive policy of the state are given, data on the timber industry activities of correctional labor camps are given. The reference book "The system of correctional labor camps in the USSR, 1923-1960" [21] contains, among other things, information about the Management of camps of the forest industry, camps specializing in timber industry activities, the time of their functioning and deployment, the number of prisoners, areas of production activity.

In the scientific and educational institutions of the regions where the GULAG played an important role in socio-political and socio-economic development, scientific centers and schools for the study of the repressive policy of the Soviet Union have developed. Information about the timber industry activities of the OGPU-NKVD GULAG in the late 1920s - early 1940s is available in the studies of: N. M. Ignatova [7], A. N. Kustysheva [12], L. A. Maksimova [13]; [14], V. G. Makurova [15], N. A. Morozova [16], L. A. Obukhov [17]; [18], A. B. Suslova [23], N. V. Upadysheva [24], S. N. Filimonchik [25], R. A. Khantalina [26], S. A. Shevyrina [28], V. K. Shmyrova [29], S. I. Shubina [30], M. V. Shulgina [31], R. V. Yurchenkova [32]. In most of the works, the problems of labor use, living conditions of a "special agent" in the timber industry are considered in fragments, in the context of the topics studied. However, some correctional labor camps specializing in timber industry activities have become objects of research. Thus, L. A. Obukhov reviewed the construction of the Vishersky Pulp and Paper Mill and its further functioning in the context of the relationship between the civil trust and the special purpose camp [17], S. N. Filimonchik devoted an article to the White Sea-Baltic Combine [25], M. V. Shulgin Solovetsky special purpose camps [31]. Camps that specialized in forestry activities have not yet become an independent subject of study.

Despite a large number of various works on the history of the GULAG of the OGPU-NKVD of the USSR, both generalizing and concerning individual regions, correctional labor camps, an analysis of the timber industry activities of this department has not been carried out, a conceptual idea of its role in the country's economy during the period of "socialist industrialization" has not been formed. Solid collections of documents have been published in recent years [3]; [8]; [9]; [10]; [22], in which the timber industry activity of correctional labor camps is quite widely represented. The analysis of published documents and research on this problem has been undertaken for the first time.

It becomes relevant to identify a group of camps for which the timber industry was the main activity. The "forest" correctional labor camps should include camp complexes, the key production tasks of which were the harvesting and mechanical processing of wood, the construction of timber enterprises. The construction is also included due to the continued use of part of the prisoners after the start-up of enterprises in the main production.

Addressing the problems of the functioning of camps that carried out timber industry activities is also relevant from the perspective of the modern period, since it allows taking into account the historical experience of developing the central, northern and eastern regions of the country, attracting labor resources, including through coercion, when determining the prospects for the development of the timber industry in Russia.

The beginning of the forced labor economy dates back to the first years of Soviet power. However, the formation of this phenomenon as a system dates back to the late 1920s. In the conditions of industrialization, the use of forced labor of special settlers and prisoners had an important impact on the development of the timber industry. It was caused by the increased demand for wood and the inability to form stable production teams. As A. B. Suslov noted, "the mobilization possibilities of using the labor of prisoners and special settlers allowed regional party and economic leaders to perform economic tasks that were lowered from above, which would have been difficult under other circumstances" [23, p. 27].

The 1920s were a period of discussion and determination of the strategy for the formation and functioning of the forced labor economy. Although the first proposals on the participation of prisoners in the timber industry and the beginning of their labor use in the industry were separated by several years [3, p. 22, 23, 29-30, 297]; [20, S. 272, 273, 274]; [31, p. 130]. The first correctional labor camps, which began to carry out timber industry activities and the construction of enterprises, were formed during the 1920s. These include the Solovetsky special purpose camps in Karelia (operated from 1923 to 1933), the Northern camps in the Northern Territory (from 1929 to 1931), Vishersky in the Ural Region (from 1928 to 1934) and the Siberian ITL in the West Siberian Region (organized in 1929 and operated for several decades) [21]. These camps were multi-industry complexes, where forest management and the construction of timber industries were among the areas of work.

Prior to 1929, the participation of prisoners in the timber industry was not of a mass nature. In April 1930, a fiveyear plan for the development of the forestry industry of the European North of the RSFSR was adopted, and the government set the task before the Supreme Council of the National Economy, the People's Commissariats of Internal Affairs, Labor and the organizing Committee of the Northern Territory to attract prisoners to ensure high rates of timber harvesting [20, pp. 273, 274]. At the end of the 1920s, the following situation developed in the participation of OGPU camps in timber industry activities. The northern camps carried out large-scale cutting and loading of timber export materials in the Arkhangelsk port. The Far Eastern camps harvested wood both for their own exports and for the export operations of the Dalles Trust. Vishera camps were engaged in the construction of chemical and pulp and paper enterprises in the Urals, logging in the Northern Urals. Siberian camps conducted, among other things, logging for the Komsomol, and Solovetsky camps performed, among other things, work for forest exports [9, p. 67].

The regions of the country where correctional labor camps were stationed tried to involve them more actively in economic activities. The works with which the enterprises of the forestry departments and trusts of the Supreme Council of the National Economy of the USSR, which had serious personnel, organizational, housing and other problems, could not cope, were transferred to the camps. If an emergency situation arose in any area of forestry activity, one of the mobilization measures was to send prisoners there. Such a situation occurred, for example, in the port of Arkhangelsk in the second half of 1929, when, at the request of the Bureau of the Northern Territory, prisoners were urgently sent to work on cutting up the timber rafted along the Severnaya Dvina River and loading operations. As a result, "a breakdown in the timber export program was avoided and the downtime of a dozen foreign steamships that took place was eliminated" [8, p. 76].

In 1930, the OGPU plenipotentiary representative for the Northern Territory, R. I. Austrin, proposed to transfer to the camps of the region the work on mechanization of wood removal, operation of the sawmill No. 48 of the Severoles trust, one of the largest built in these years, organization of logging along the southern and eastern shores of the White Sea. It turned out that the Management of the Northern Special Purpose camps had a sufficient number of workers and specialists, unlike the enterprises of the trust, and, according to R. I. Austrin, "could not only successfully fulfill the production program of the plant, but also produce their own lumber for export" [9, pp. 64-65]. The mobilization and personnel potential of the Northern camps exceeded the capabilities of the timber enterprises of the Northern Territory, and gradually they increased their share in the economy of the region.

Since 1930, the gradual switching of the work of the Solovetsky special purpose camp, which was mainly of a contract nature, to their own household work began. Two forest areas were assigned to the camp. At the same time, the Solovetsky camp, which was "an organization whose business reputation is impeccable" [9, p. 58], was expected to fulfill both its timber export program and work for other organizations. Active exploitation on the Solovetsky Islands has led to the disappearance of forests, despite the introduction of fuel economy and the closure of a number of enterprises. In 1930, at a meeting of the camp party cell, it was openly admitted about the cutting of logging sites for ten years ahead, which could "ruin the island." In 1931, the narrow-gauge railway was dismantled, logging began to be episodic and completely stopped by 1937 [31, p. 131].

Despite this optimism, many problematic circumstances were noted that accompanied the timber industry: massive local diseases (scurvy, colds, frostbite); remoteness of work sites from settlements; lack of possibility of providing normal and timely medical care; unsatisfactory living conditions due to the short duration of work (logging - four winter months, rafting twothree months); extended working day; constant transfer of labor to new places of work (two or three times during the year) [9, pp. 59-60]. Under such conditions of forest exploitation, it was unreasonable to count on the successful implementation of the production program. In addition, there were examples of unsatisfactory timber industry among the GULAG camps. Thus, the logging program by the Northern special-purpose camps was not carried out at the beginning of 1930, and the camps of the Far Eastern Region fulfilled the timber export program, according to data on March 10, 1930, only by 8% [9, pp. 60-62].

The implementation of production programs by correctional labor camps was carried out, as a rule, due to overexploitation of prisoners, whose condition worsened also for reasons of unsatisfactory food and clothing provision, housing and consumer services, harsh natural and climatic conditions. The systemic problems of the labor use and maintenance of the "special agent" manifested themselves with all acuteness at the stage of the formation of the forced labor economy, in the late 1920s - early 1930s. At the same time, the camp system was not always ready to recognize and correct violations of the rule of law against prisoners. This is evidenced by appeals to the heads of the highest party and state bodies and inspections of correctional labor camps (see, for example: [8, pp. 70, 71-75]; [10, pp. 140-141]). The leadership of the camps, the OGPU, knew about the violations, but could "ignore" them while ambitious tasks of industrialization and an active struggle against the "enemies" of the Soviet government were on the agenda.

In the history of forced labor in the USSR, there is a unique case when in 1930-1931 trading companies of Great Britain, France and the USA opposed the import of forest resources and materials from the Soviet Union on the basis of dumping and information about the large-scale use of prisoners' labor, including logging. In general, the attention of the countries of Western Europe and North America to the problem of the use of forced labor in the USSR, including in the timber industry, was manifested periodically. Therefore, data on the use of prisoners in various jobs were carefully hidden: it was forbidden to put camp stamps on export goods, references to prisoners disappeared from the documentation of economic organizations. In this regard, the letter of the secretary of the Northern Regional Committee of the CPSU (b) S. A. Bergavinov to I. V. Stalin after the publication in the newspaper Pravda dated November 13, 1930 in one of the materials of the phrase "no prizes are given to labor prisoners" is indicative. The head of the regional committee reported that the Soviet government officially denies the facts of forced labor of prisoners in the field of timber harvesting, for which it concentrates a "special contingent" in remote woodlands [22, p. 183].

The campaign of the countries of Western Europe and North America against the import of forest resources and materials from the Soviet Union was actively launched in early 1931. In February 1931, a group of American workers engaged in logging in Karelia wrote that "they have been working for the third month, but they have not seen forced labor anywhere." Workers from Canada who worked at the Sailor's mekhlesopoint noted in a letter that "they work voluntarily, stay in the forest for eight hours, get a good salary, have hearty food, live in a spacious, clean and bright room ..." [22, p. 196]. In March of the same year, the American engineer P. M. Valon, who worked in the Severoles Trust, in his letter to the Embassy of the United States of America described in rainbow colors the work and life in logging in the Northern Territory [30, pp. 202, 203, 204]. Such statements were made, most likely, under pressure from local and regional authorities and business organizations. And naturally, for foreign workers, especially skilled ones, they sought to create more attractive working and living conditions compared to local residents or special settlers and prisoners.

On March 8, 1931, the head of the Council of People's Commissars of the USSR, V. M. Molotov, in his speech at the VI Congress of Soviets of the USSR, spoke "about the lies of the bourgeois press about working conditions in the northern regions in logging." As proof, he invited representatives of foreign states and foreign journalists who lived in Moscow and enjoyed freedom of movement to make a trip to the areas of timber harvesting and make sure that "work on export goods, at least on the same export forest, has nothing to do with the work of prisoners ..." [5, p. 230]. In the camp complexes and economic organizations that used forced labor, work was intensified on the resettlement of special settlers and prisoners from places where foreigners could visit. In Karelia, prisoners employed in the timber industry complex were removed from work within a day. On March 9, the second secretary of the Karelian Regional Committee of the CPSU(b) A.M. Apolonik reported to S. M. Kirov, a member of the Politburo of the Central Committee of the CPSU (b) and the Presidium of the Central Executive Committee of the USSR, that in the region "all traces of the former work of prisoners are outwardly hidden" [11, p. 40]. Due to the transfer of the "special agent", the autonomy lost one of the significant sources of labor resources.

In April 1931, the Northern Regional Committee decided to "clear the sawmills No. 3, 4 on Bakaritsa, 8, 15 and 23, forest exchanges No. 2 and Bakaritsa, Kholmogorsky, Primorsky, Vozhegodsky, Kotlas and Gryazovets timber farms from the administratively expelled" [30, p. 205]. When a message came to the Northern Special Purpose camps that the verification commission was heading to Kotlas, the GULAG ordered the urgent liquidation of the transit point located there. This "relocation" was reflected in the memoirs of a prisoner of the Northern camps V. Ya. Dvorzhetsky [4]. So the inspection commission on arrival could not confirm the information about the harvesting of timber for export by prisoners. And a hastily organized operation to transfer the "special agent" could only be possible thanks to the extensive mobilization capabilities of the OGPU.

The second wave of the appearance of correctional labor camps that carried out forest management occurred in the early 1930s. In 1931, the Ukhta-Pechora camp in the Komi region (operated until 1938), Temnikovsky in Mordovia (until 1948), Svirsky in the Leningrad region (until 1937), the White Sea-Baltic in Karelia (before 1941) [21]. Of these camps, only Temnikovsky and Svirsky specialized in timber industry activities mainly in the harvesting of wood for Moscow and Leningrad. Thus, the Svir camp was obliged to prepare, export and load 1.09 million m3 of firewood in the area of the Svir River by October 1, 1931, and the Temnikovsky camp was to prepare 1.45 million m3 of firewood, 350 thousand m3 of business wood, export and load 1.2 million m3 of firewood to Moscow by January 1, 1932 [9, p. 75]. For the Ukhta-Pechora and the White Sea-Baltic (until 1933) ITL, logging was of a subsidiary nature. In particular, for 1931-1938. The Ukhta-Pechora camp, in addition to performing the main tasks of developing coal, oil, radium deposits, processing minerals, prepared 854 thousand m3 of drill and fastening timber for its own needs [13, p. 175].

In 1932, logging operations were carried out by six camps. The volumes of logging amounted to 9376 thousand m3 of wood (99.1% of the plan), haulage 7536 thousand m3 (87.5%) and were comparable with the results of the work of the largest trusts of the People's Commissariat of the USSR. Only one trust of the department, Sevles, harvested and exported more wood than camps in 1932. By this time, the camps began to conduct complex logging activities, to produce, approximately in the volumes of a large combine, products of mechanical processing of wood [9, p. 100]. In 1933, the camps were supposed to harvest 8.5 million. m3 and export 7.8 million m3 of forest (9.4% and 7.7%, respectively, to the volume of work of the People's Commissariat of the USSR), produce 300-340 thousand m3 of lumber. It was planned to involve about 140 thousand people in logging operations, three times more than two years earlier. In 1933, logging, construction and operation of enterprises of the timber industry complex were carried out by the Ukhta-Pechora, Temnikovsky, Svirsky, Siberian, Solovetsky, Vishersky camps [9, pp. 100, 108].

In August 1933, the Council of People's Commissars of the USSR adopted resolutions "On the White Sea-Baltic Combine" and "On measures in connection with the organization of the White Sea-Baltic Combine". One of the main tasks of the new enterprise was the development of the timber industry. On October 1, 1933, the transfer of the forests of the Karelles and Sevzaptranles trusts began under the jurisdiction of the White Sea-Baltic Combine. The combine was supposed to supply the Murmansk Railway with firewood, sleepers and logs, Leningrad with firewood, supply balances for the Syas pulp and paper Mill, and conduct logging. In July 1935, the forest territory of the White Sea-Baltic Combine was defined as part of the Povenetsky, Vygozersky, Medvezhyegorsky, Padansky timber farms and parts of the Rugozersky, Soroksky, Tungudsky timber farms with a total area of 2.8 million hectares [22, pp. 237, 245, 266]. The territory occupied by the forest was 1.68 million hectares with a reserve of overstuffed wood in the amount of about 200 million m3 (without Chirk-Kemsky district) [19, p. 63].

The volumes of the timber industry activity of the White Sea-Baltic Combine were comparable to the work of large trusts of the People's Commissariat of the USSR and played an important role in the development of the economy of Karelia. The combine had a multi-industry orientation, developed mechanical processing of wood and forest chemistry. From the results of his work for 8 months, from August 1933 to March 1934, the unfolding scale of timber industry activity is visible: 700 thousand festmeters of wood were harvested, 67 thousand m3 of boards and beams, 12.8 tons of resin, 31.6 tons of turpentine, 233.5 tons of coal and 56 tons of tar were produced. The combine included five sawmills, two furniture factories, 10 single-frame mobile type sawmills and 19 trellis cutters [15, pp. 87-88, 90].

In 1932-1936, there was a Lokchim (Pezmog) combine in the Komi region, which used the labor of prisoners, in 1933 harvested 40 thousand m3 of wood and produced 85 tons of forest chemical raw materials (turpentine and other products of forest chemistry) [14, p. 276]. Initially, the management of the Komi region had big plans for the development of the timber chemical industry associated with this enterprise. The construction of the Lokchimsky (Pezmogsky) combine was included in the program of the second five-year plan. Until 1940 , it was planned to harvest about 3 million m3 of pine forest and 2 million m3 in the basin of the Lokchim River . m3 of spruce wood. Despite the fact that the regional leadership supported the Lokchimsky Combine in the issue of providing timber industry enterprises of Syktyvkar with wood, already in the spring of 1934, a gradual curtailment of work in the area of the Lokchim river began. From the spring of 1936 to the summer of 1937, the mechanized forestry enterprise of the Komiles trust and the Pezmog logging farm of the Nizhnechovskaya correctional labor colony functioned on the basis of the combine [16, pp. 148, 149, 150, 151].

In 1934, four correctional labor camps specializing in timber industry (the White Sea-Baltic, Temnikovsky, Svirsky, Sarovsky) harvested about 6.9 million m3, exported about 6.5 million m3 of wood, produced almost 250 thousand m3 of lumber. The largest volume of forest resources (business and woodwood) it was harvested by Svirsky (more than 3.6 million m3, or almost half of the volume for "forest" camps) and Temnikovsky (more than 2 million m3). m3) camps. The White Sea-Baltic Combine harvested a little more than 1 million m3 of forest, since it had just begun the development of woodlands [9, pp. 119, 122, 123]. The largest output of lumber was at the Temnikovsky camp (70% of the total volume for "forest" camps), and in the White Sea-Baltic Combine, sawmilling and woodworking had not yet been organized on an industrial scale.

The execution of the plan took place only at the Temnikovsky camp. The Svir and Sarov camps experienced a shortage of able-bodied labor, which is why they could not achieve the planned indicators. A significant part of the harvested forest resources was used as fuel. Thus, the Svir camp delivered 75 thousand wagons of firewood to Leningrad in a year (43% of the total supply), the Temnikovsky camp delivered 44 thousand wagons of firewood to Moscow (30% of the total supply) [9, pp. 122, 123]. The success of the camps in the timber industry was followed by an increase in planned indicators. For example, in 1935, the Temnikovsky camp was given an even greater task: for the harvesting of business wood 950 thousand festmeters, for the export of business wood 900 thousand festmeters, for the harvesting of firewood 2200 thousand raummeters. At the same time, a railway line was still being built for the development of the new Unzhe-Vetluzhsky forest [9, p. 123].

It should be noted that with the increase in the volume of timber industry activity by "forest" correctional labor camps, the number of prisoners in them increased. So, at the beginning of 1930, there were 85 thousand people in four camp complexes, a year later about 183 thousand, and at the beginning of 1934, about 197 thousand prisoners were serving their sentences in six camps. As of January 1, 1937, about 159 thousand prisoners were serving their sentences in four "forest" ITL (White Sea-Baltic, Svir, Siberian and Temnikovsky). In 1934-1937 in the White Sea-Baltic camp there were in different years from 59 thousand to 90 thousand people, in Svirsky from 23 thousand to 44 thousand, Siberian from 45 thousand to 65 thousand, Temnikovsky from 21 thousand to 31 thousand prisoners (calculated by: [21]).

In the late 1920s and early 1930s, the labor of several thousand prisoners was used in the construction of a deep wood processing enterprise - the Vishersky Pulp and Paper Mill. Despite the very fast construction time (according to official data from April 1930 to October 1931, although preparatory work was carried out since 1925, and the use of prisoners began a year later), serious problems of labor use of the "special agent" were already noted at the level of the construction administration: "It will be much cheaper to build with freelance labor than with prisoners, whose labor productivity is too low, and the salary that the factory pays to the camp for the imprisoned labor is the same" [18, p. 38]. However, the attractiveness of using special settlers and prisoners due to their mobilization capabilities and overexploitation led to the expansion of the GULAG's construction activities in the field of deep processing of wood. On July 29, 1935, the Council of People's Commissars of the USSR by its decree obliged the NKVD to build a pulp mill of the Segezha Lumber and Chemical Combine [27, p. 70]. However, the expansion of the construction of timber enterprises by the GULAG occurred in the late 1930s - early 1940s.

Thus, in the period from the late 1920s to 1937, which can be distinguished as the first stage in the development of the timber industry of the GULAG camps of the OGPU NKVD of the USSR, camp complexes arose to solve limited tasks in the field of forest management: harvesting wood for industrial and export purposes, firewood for Moscow and Leningrad. It was only in 1933 that the first multi-industry "forest" correctional labor camp appeared the White Sea-Baltic Combine, which carried out harvesting, mechanical processing, deep processing of forest resources, as well as the construction of enterprises of the timber industry complex. By the mid-1930s, the development of the field of mechanical wood processing intensified in the camps, which was due to the need to provide them with building materials and woodworking products. On the contrary, pulp and paper production did not play a special role in the activities of the GULAG, since the agency acted in most cases as a contractor for the construction of facilities in this industry.

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