Dear Brett The press has taken up the issue and there are quite a few reports along these lines. At a civil soceity meeting I addressed at the Open Society Forum a few months ago I asked the participants exatly your question. Some said there was no point, and some said they were scared (though that was based on experience a few uears ago). It is only in the last 6 years or so that the relevant legislation has been interpreted to permit the developments now seen. When I read Articles 8, 11 and 12 of the Protected Areas Law, my unqualifed interpretation would be that almost all of the current construction activities in Bogd Khan are illegal. i.e. ... Article 8. Strictly Protected Areas Zones 1. Upon consideration of the natural features, characteristics, unique soil, water, flora and fauna, and the human activities involved, Strictly Protected Areas shall be divided into the following zones: 1/ Pristine Zones; 2/ Conservation Zones, and; 3/ Limited Use Zones;, Article 11. Limited Use Zone Regime Pursuant to the appropriate permit, the following activities may be conducted in Limited Use Zones using environmentally safe technology: 1/ activities described in Articles 9 and 10 of this Law; 2/ soil and plant cover restoration; 3/ forest maintenance and cleaning;; 4/ pursuant to an approved program and method, conduct animal surveys and regulate the number, age, sex and structure of animal populations; 5/ use mineral water and other treatment and sanitation resources; 6/pursuant to the appropriate procedure, organize eco-travel and tourism according to designated routes and directions 7/ use accommodations constructed pursuant to appropriate procedures and designated for temporary residence, camping, observation, research and investigation by travelers and other people with permission (see 12(5)); 8/ take photographs, make audio and video recordings and use them for commercial purposes; 9/ conduct mountain and ovoo workshop and other traditional ceremonies; 10/ pursuant to the appropriate procedures, local residents may collect and use side-line natural resources and medicinal and food plants for their household needs. Article 12. Activities Prohibited in Strictly Protected Areas 1. If its prohibited to conduct the following activities in Strictly Protected Areas for purposes other than those described in Articles 10 and 11 of this Law: 1/ to change natural characteristics by plowing, digging, use of explosives, > exploration of natural resources, mining, extracting sand or stone, harvesting wood and reeds, or constructing roads in areas other than in Limited Use Zones; 2/ to collect and prepare secondary natural resources or medicinal, food, and technical plants for commercial purposes; 3/ to hunt, trap, or startle animals or destroy their nets, hibernation or burrows for purposes other than those described in the paragraph 4 of Article 11 of this Law; 4/ to use methods, techniques or substances with have negative environmental impacts in order to combat or prevent hazardous insects, rodents, or fire; 5/ to construct buildings other than those described in paragraph 7 of Article 11 of this law; 6/ to conduct any activities which pollute the soil, water and air; 7/ to enter a Special Protected Area with a dog and gun without permission from local protected area administration; 8/ to land aircraft or fly at low altitude without prior permission from the local protected area administration; 9/ to building winter, spring, autumn, and summer settlements or graze cattle without the appropriate permit; 10/ to using open water sources such as lakes, rivers, steams, springs or ponds for commercial purposes; 11/ to conduct other activities prohibited by law, or protection regime which have negative environmental impacts However, if Article 33 (below) is read alone, without the above, then any "environmentally safe" land use could be justified. But I am not a lawyer. Also, if Article 36.3 is not read together with Article 11.7. then tourism sector developments could be justified as long as they "have attained international standards". Article 33. Land Use in Special Protected Areas 1. Land within Limited Use Zones of Strict Protected Areas, National Conservation Parks Natural Reserves, and Monuments may be used by citizens, economic entities and organizations through the use of environmentally safe methods pursuant to a contract designating the purpose, terms, and conditions. Article 36. Land Use Decision 1. The State Administrative Central Organization shall make a decision on land use by citizens, economic entities and organizations within the Limited Use Zones of Strictly Protected Areas, National Conservation Parks, Nature Reserves and Monuments based on the recommendations from the Protected Area Administration and Soum or Duureg Governors. 2. Where two or more persons request to use the same land, the decision shall be based on land use designation, environmental impacts and the expenses for environmental conservation measures. 3. Where citizens, economic entities or organizations requests to use the same land for travel and tourism business, the decision shall be based on whether the facilities for those activities have attained international standards. 4. The decision set out in paragraph 1 of this Article shall clearly state the land use designation, the location of the zone, the location of the land, its boundary, size and whether the land shall be used solely or jointly. 5. In case of objection on land use then the reason and justification of it shall be set out in the decision of state administrative central organization. I am pleased to say that the Ministry of Nature, Environment and Tourism has used some of our funds provided by the Netherlands Government to hire one of IUCN's best environmental lawyers to help find ways to modify the Protected Areas Law and remove the ambiguities. In due course the final version will go before Parliament for approval.