**Specifying the issue.** The policy continuum for the mining transparency issue included a series of cumulative steps (Figure 8), building from the current _ad hoc_ , discretionary, under-regulated, and politicized process for granting mining licenses (0) to the implementation of a clear legal framework and automated cadastre system, complete with internet-based query capabilities (100). In between, preliminary measures included decreasing the number of steps in the application process, supporting a cadastre website, and clarifying the status of land. The next stage of reform involved enacting increasingly stringent exploration requirements for license holders, rolling out the automated cadastre system, and holding public consultations on mining costs and benefits. The final stage of reform included establishing an interagency commission to oversee and ratify cadastre recommendations, fully deploying the automated cadastre system, and applying a clear regulatory framework for granting and renewing exploration licenses.

**Figure 8:  Policy Steps to Improve Mining Transparency in Mongolia**

<!-- Start of picture text --> 100 – Regulatory framework applied in granting & renewing licenses;<br>automated mining cadastre system fully developed, with web query enabled<br>87 – Clear regulatory framework applied, with publicly disclosed regulations<br>above the ministerial level, preferably through cabinet or presidential decree<br>70 – Interagency commission established to oversee & ratify cadastre<br>recommendations; automated system deployed; quarterly reports published<br>65 – Public consultation supported on mining costs and benefits as part of<br>license granting process<br>50 – Mining leases granted only when economic feasibility is established;<br>automated cadastre system deployed but not fully operational<br>40 – Provisions in place for exploration continuation until economic<br>viability is established<br>30 – Minimum expenditure required on exploration licenses to minimize<br>speculation; automated system partially deployed, with only geodetic data<br>20 – Status of land clarified via Ministry of Nature & Environment for<br>reserves, protected areas, and special use lands<br>15 – Computerized cadastre and license records website supported<br>10 – Streamlining begun by decreasing the number of process steps through<br>detailed operational procedures<br>0 – Ad hoc , discretionary, under-regulated, and politicized process for<br>granting mining licenses<br><!-- End of picture text -->

**Collecting data.** The team discussed mining issues with about a dozen experts in government, parliament, civil society, mining companies, and donor organizations, including within the Bank. Although these experts were broadly willing to talk openly about mining issues, many of them had only superficial information on the specifics of mining license and cadastre system reforms; access to those on the inside of the reform debate was constrained due to the pre-election timing.

The data showed that, at the time of the pilot exercise, stakeholder positions varied widely across the spectrum of possible reforms (Figure 9). Many executive stakeholders and political parties supported mid-level reforms such as granting mining leases only after economic feasibility is established, deploying an automated cadastre system even if not fully operational, and supporting public 13