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En v i r on m e n t an d S o c i a l De v e l opm en t—Ea s t A s i a an d pac i f i c R e g i on
Discussion Papers
Silent Steppe:
The Illegal Wildlife
Trade Crisis
July 2006
M O N G O L I A
MONGOLIA
Silent Steppe: The Illegal
Wildlife Trade Crisis
July 2006
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© 2006 e International Bank for Reconstruction and Development/THE WORLD BANK
1818 H Street, NW
Washington, DC 20433 USA
July 2006
All rights reserved.
is study was prepared by the Environment and Social Development Unit (EASES) of the East Asia and Pacifi c Region,
and was funded by e World Bank’s Netherlands-Mongolia Trust Fund for Environmental Reform.
Environment and social development issues are an integral part of the development challenge in the East Asia and Pacifi c
(EAP) Region. e World Bank’s Environment and Social Development Strategy for the region provides the conceptual
framework for setting priorities, strengthening the policy and institutional frameworks for sustainable development, and
addressing key environmental and social development challenges through projects, programs, policy dialogue, non-lend-
ing services, and partnerships. e EASES Discussion Paper series provides a forum for discussion on good practices and
policy issues within the development community and with client countries.
is publication is available online at www.worldbank.org/eapenvironment.
Suggested citation:
Wingard J.R. and P. Zahler. 2006. Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia. Mongolia Discussion Papers,
East Asia and Pacifi c Environment and Social Development Department. Washington D.C.: World Bank.
Cover image: Luke Distelhorst
Cover design by e Word Express
Contact information of the primary authors:
James R. Wingard Peter Zahler
Juris Doctor, Environmental Consultant Assistant Director, Asia Program
7015 Siesta Dr., Missoula, MT 59802 USA Wildlife Conservation Society
Email: jrwingard@envlaw.myrf.net 2300 Southern Blvd, Bronx, NY 10460 USA
Email: pzahler@wcs.org
is volume is a product of the staff of the International Bank for Reconstruction and Development / e World Bank.
e fi ndings, interpretations, and conclusions expressed in this paper do not necessarily refl ect the views of the Execu-
tive Directors of e World Bank or the governments they represent. e World Bank does not guarantee the accuracy
of the data included in this work. e boundaries, colors, denominations, and other information shown on any map in
this work do not imply any judgment on the part of e World Bank concerning the legal status of any territory or the
endorsement or acceptance of such boundaries.
e material in this publication is copyrighted. Copying and/or transmitting portions or all of this work without
permission may be a violation of applicable law. e International Bank for Reconstruction and Development / e
World Bank encourages dissemination of its work and will normally grant permission to reproduce portions of the work
promptly.
For permission to photocopy or reprint any part of this work, please send a request with complete information to the
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to the Offi ce of the Publisher, e World Bank, 1818 H Street NW, Washington, DC 20433, USA, fax 202-522-2422,
e-mail pubrights@worldbank.org.
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– iii –
Contents
F vii
A xi
A xiii
E S 1
I 9
C . W T S M 13
Offi cial Data Sources 13
Household and Market Survey Methods 14
Data Analysis Methods 17
C . H W T M 23
C . W T T T 27
Changes in Management 28
Changes in Take 29
Changes in Trade 31
Trade Chains, Markets, and Enforcement Opportunities 37
Known and Probable Impacts 40
C . E W M 49
Institutional Constraints 49
Economic Constraints 50
Wildlife-Related Revenues 50
Budgeting for Wildlife Conservation 51
Funding for Wildlife Research 53
Funding for Wildlife at the Local Level 54
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iv
Brief Overview of Wildlife Take and Trade Laws 55
Regulation of Wildlife Take 55
Regulation of Wildlife Trade 58
CITES Regulation 58
Regulation of Trophy Hunting 60
Regulation of Status and Conservation Measures 61
Community-Based Wildlife Management 61
Enabling Enforcement 62
C . R P A 65
Cross-Cutting Recommendations 66
International Trade Enforcement 72
Domestic Trade Enforcement 73
Hunting Management 75
Trophy and Sport Hunting Management 77
Community-Based Approaches 79
R 81
A A: S C S 89
Marmot (Marmota sibirica and Marmota baibacina) 90
Wol f (Canis lupus) 97
Corsac Fox (Vulpes corsac) 101
Red Fox (Vulpes vulpes) 103
Siberian Roe Deer (Capreolus pygargus) 105
Brown Bear (Ursus arctos) 107
Moose (Alces alces pfi zenmayeri and A. a. cameloides) 109
Snow Leopard (Uncia uncia) 111
Wild Boar (Sus scrofa) 113
Red Deer (Cervus elaphus) 115
Argali (Ovis ammon) 117
Saker Falcon (Falco cherrug) 120
Saiga antelope (Saiga tatarica mongolica) 122
Mongolian gazelle (Procapra gutturosa) 123
Musk Deer (Moschus moschiferus) 126
A B: A S I 129
A C: T 135
A D: H C S 145
Mongolia
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
v
F
1 Sampling results of males and hunters interviewed compared to Mongolian male population 18
2 Total annual legal wildlife trade in Mongolia, 1926–85 25
3 Average trade levels for selected species relative to historic peak trade volumes and compared to 2004 harvest
estimates 31
4 Diagram of trade chain types in Mongolia 40
5 Relative rates of decline for selected species in Mongolia 41
6 Public opinion poll—status of wildlife resources in Mongolia 42
7 Siberian marmot distribution 1970 91
8 Percentage coverage map for marmots in Mongolia 91
9 Marmot population declines, 1940–97 92
10 Offi cial marmot skin trade in Mongolia, 1892–97 93
11 O ffi cial wolf skin trade in Mongolia, 1927–85 99
12 Offi cial corsac fox fur trade in Mongolia, 1932–85 102
13 Offi cial red fox fur trade in Mongolia, 1932–85 104
14 O ffi cial roe deer trade in Mongolia, 1950–85 106
15 Historic wild boar trade in Mongolia, 1932–85 113
16 Red deer antler trade with China, 1965–74 116
17 Trade in Mongolian gazelle game meat in Mongolia, 1932–85 124
T
1 Ranking of species by estimated number of hunters that target the species 34
2 Ranking of species by reported mean annual harvest per hunter 34
3 Ranking of species by estimated total harvest volume in 2004 35
4 Ranking of species by domestic trade value per animal 35
5 Ranking of species by estimated potential total trade value in 2004 36
6 Ranking of species by trophy hunting permit and license fees 36
7 State revenues from natural resources, 1999–2003 51
8 Comparative ministry budgets, 2002– 03 52
9 Ministry of Nature and Environment budget, 2001–04 53
10 Conservation reinvestment percentages 53
11 Comparative research and development expenditures, 2001–03 54
12 Mongolian CITES exports for selected species, 1996–2004 59
A1 Export revenue from saker falcon in Mongolia, 1996–2003 121
C1 Legal and conservation status of harvested species 135
C2 International and domestic trade purpose of targeted species 138
C3 Wildlife product market values by species 139
C4 Estimate of total number of hunters weighted by age class 142
C5 Estimate of total number of hunters weighted by aimag 142
C6 Estimate of total number of hunters weighted by urban or rural residency classifi cation 143
C7 Comparison of Mongolia’s number of hunters and rate in population to selected countries 143
C8 Estimates of the total number of hunters and harvests by species in Mongolia 144
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– vii –
Foreword
Illegal wildlife trade is emerging as a serious
development issue which threatens the East Asia
region’s remarkable biodiversity and the welfare
of people who rely upon it. e region is a key
consumer of wildlife as derivatives such as food and
medicines, pets or live collections, as well as trophies or
decorations. In addition, East Asian countries supply the
international market with both legal and illegal goods.
Silent Steppe is the latest product of the Environment
and Social Development unit in the East Asia and
Pacifi c region of the World Bank in a series of activi-
ties by the Bank and our development partners to
understand the driving forces of wildlife trade, its scale
and operation, and to identify successful solutions to
address illegal trade. A previous publication—Going,
Going … Gone: e Illegal Trade in Wildlife in East
and Southeast Asia—summarized key concerns in the
region, and a recently launched sub-regional study—
coordinated by TR AFFIC International—is exploring
the economic and social drivers of illegal trade. More
broadly, this work is linked with the World Bank’s
concern about the adverse impacts of weak governance
on the management of natural resources, identifi ed as
a key issue in the Environment Strategy for the East
Asia and Pacifi c Region.
In Mongolia, the World Bank is supporting the Gov-
ernment in its eff orts to ensure sustainable exploitation
of the country’s considerable natural resources. In
addition to this study on illegal wildlife trade, research
is underway on the illegal timber trade, on the success
of tree planting projects, and on other issues of
concern. is report, as well as many other projects,
has been supported through the Netherlands-Mongo-
lia Trust Fund for Environmental Reform (NEMO), a
wide-reaching initiative which has touched almost all
aspects of environmental management in Mongolia in
2005–06.
Silent Steppe is a good example of exploring poverty-en-
vironment connections and the impacts of weak natural
resources management on poor people’s livelihoods.
Since the economic dislocation of the post-Soviet
era, hundreds of thousands of Mongolians turned to
hunting wildlife as one of the few alternative income
generating activities available. Expanding illegal wildlife
trade, however, is becoming unsustainable, providing
less and less support to livelihoods while contributing to
the extinction of rare species. Addressing this prob-
lem—providing alternative livelihoods and incentives
for protecting rather than destroying a valuable resource
base—will require a concerted eff ort by Government,
civil society, and the development community.
In cooperation with several other NGOs, Wildlife
Conservation Society (WCS) took the lead in
conducting this in-depth study based on their global
experience and strong local presence in Mongolia. We
encourage those in government and civil society to
read this report and to consider its recommendations.
Magda Lovei
Environment Sector Manager
East Asia and Pacifi c Region, e World Bank
Saha Dhevan Meyanathan
Mongolia Country Manager, e World Bank
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– ix –
Foreword
The single greatest threat facing many species
of wildlife across the world today is hunting
for commercial wildlife trade. Such trade
is escalating in scale across the globe, from
the vast, multimillion-dollar trade in animals or their
parts across Asia for their meat, skins, as pets, and as
medicines, to the notorious “bushmeat trade” across
Africa. e rise in the trade is due to a wide range
of factors, including growing access to increasingly
small and fragmented natural habitats, a change from
traditional to effi cient modern hunting technologies,
loss of traditional hunting controls, and the addition
of big business into what had been predominantly a
local-scale subsistence activity. e loss is accelerated
by demand from a growing middle class in urban areas
with the cash to buy wildlife and wildlife products,
and globalization that facilitates long-distance inter-
national trade, even if illegal. Many wildlife products
used for food, medicine or clothing have crossed
the boundary between “tradition” and “fashion,” so
demand is high and growing.
Examples of the scale of global wildlife trade are
numerous: 25 tons of turtles exported every week in
2000 from Sumatra to China; 1,500 restaurants in
Ho Chi Minh City, Vietnam selling wildlife meat;
90,000 wild mammals sold per year for meat in a
single market in North Sulawesi; 1.5 million live birds
per year sold in one Javan market; and on any one
occasion, more than 90,000 snakes and 24,000 turtles
being sold in markets in Guangzhou and Shenzhen in
southern China. In Malabo, Equatorial Guinea, about
13,000 wild mammal carcasses are sold every year;
and in Gabon, about 12,000 tons of wild meat is sold
annually. e problem is not confi ned to developing
nations; between 1992 and 2002, United States trade
in wildlife and wildlife products increased by 75
percent, and in 2002, legally declared shipments of live
wild animals into the U.S. included more than 38,000
mammals, 365,000 birds, 2 million reptiles, and 49
million amphibians.
Increased hunting, primarily for commercial wildlife
trade, is causing species declines, local extinctions,
and threatening global extinctions across the tropics.
In Vietnam, 12 species of large animals have become
extinct, or virtually extinct, in the past 50 years,
mainly due to hunting. Every major protected area
in Southeast Asia has lost at least one species of
large mammal due to hunting, and most have lost
many more. In Bioko, Equatorial Guinea, hunting
has reduced primate populations by 90 percent in
Commerciall y harvested gazell e fi eld dres sed and ready for trans port to
market. Ima ge: Henry Mix / Natu re Conservation Inte rnational.
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Mongolia
x
some areas and caused local extinction in others, and
in Kilum-Ijim, Cameroon, hunting has wiped out
chimpanzees, elephants, sitatunga, and many other
species. As populations of a desired species in one area
decline, markets seek their supplies from other species
or other areas, causing ever-increasing circles of loss.
e problem of vast and unsustainable trade in wildlife
is a global one, but it is most acute in Asia. Asia has,
on average, higher human population densities and less
remaining forest than other parts of the tropics. It also
has a long tradition of consuming wildlife products
for medicinal use, and has some of the most rapidly
growing economies in the world. Domestic trade is
signifi cant across the region, but a major proportion
of the trade is international, with massive demands for
wildlife from the core consuming nations of East Asia.
In recent years, the core focus of conservation concern
has been the devastating impacts of commercial wild-
life trade on tropical forest wildlife. Productivity of
tropical forests for wildlife is extremely low, so species
here are especially vulnerable to any commercial levels
of hunting. In such habitats, a further problem is that
forest peoples still depend on wildlife as a vital source
of protein and income. Loss of wildlife to markets
tens or hundreds of kilometers away means that a vital
resource is lost. Remote rural peoples who have few or
no alternatives are driven even further into poverty.
e current study in Mongolia is truly groundbreak-
ing, in that it shows that the problem of commercial
wildlife trade is also vast, unsustainable, and a
major threat to wildlife populations in other areas.
is trade is not coming from tropical forests, but
temperate steppes and woodlands; it is not heading
north into the core consuming nations, but south.
It is not linked to the tropical timber trade, but to a
wide range of other factors, from Mongolia’s recent
sociopolitical history to its geographical position in
the world. e eff ect of commercial trade on wildlife
populations is dramatic, however, and a cause for
major conservation concern. e data presented here
by Jim Wingard, Peter Zahler and their colleagues is
eye-opening because it shows us that we need to think
much more widely about the problem of wildlife trade:
that it aff ects countries sometimes off the radar of the
global conservation community, and it is doing so at
a dramatic scale. Of most immediate importance, this
study is a major step in addressing the wildlife trade
in and from Mongolia, and in seeking solutions to
conserve Mongolia’s unique and wonderful wildlife
community, as well as ensuring that rural livelihoods
are sustainable for people in the long term, rather than
being tied to a dwindling resource base.
Elizabeth L. Bennett, M.B.E.
Director, Hunting and Wildlife Trade Program
Wildlife Conservation Society
Head of a tai men, a large salmoni d which is under pressure f rom sports fi shin g for trophies and can al so be
found on sa le in Ulaanbaatar’s res taurants. Image : K. Olson.
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– xi –
Acronyms
a.s.l. Above sea level
CBNRM Community-based natural resource
management
CITES Convention on International Trade in
Endangered Species of Wild Flora and
Fauna
CMS Convention on Migratory Species
CR Critically Endangered (IUCN Red List
category)
DD Data Defi cient (IUCN Red List category)
EN Endangered (IUCN Red List category)
GDP Gross Domestic Product
GEF Global Environment Facility
GIS Geographic Information Systems
GOM Governement of Mongolia
GTZ Deutsche Gesellschaft für Technische
Zusammenarbeit (German Agency for
Technic a l C o o p e r a t i o n)
IUCN e World Conservation Union ( e
International Union for the Conservation of
Nature and Natural Resources)
LC Least Concern (IUCN Red List category)
LR Lower Risk (old IUCN Red List category)
MLF Mongolian Law on Fauna
MLH Mongolian Law on Hunting
MNE Ministry of Nature and the Environment
MNT Mongolian tugrik
MOSTEC Ministry of Science, Technology, Education
and Culture
NGO Non-governmental organization
NE Not Evaluated (IUCN Red List category)
NT Near reatened (IUCN Red List category)
NSO National Statistical Offi ce of Mongolia
PPP Purchasing Power Parity
SPA Strictly Protected Area
SPSS Statistical Package for the Social Sciences
SSIA State Specialized Inspection Agency
TCM Traditional Chinese Medicine
UNDP United Nations Development Program
UNEP-WCMC United Nations Environment Program—
World Conservation Monitoring Centre
USSR Union of Soviet Socialist Republics
VU Vulnerable (IUCN Red List category)
WCS Wildlife Conservation Society
WW F World Wide Fund for Nature
Notes:
All dollars are U.S. dollars; all tons are metric tons
Aimag (= province) is the largest sub-national administrative
unit; below the aimag is the soum (= district), which is divided
into bag (= sub-district). In the capital city districts are called
duureg and sub-districts khoroo.
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Acknowledgments
– xiii –
This report was prepared in partnership
with the Wildlife Conservation Society.
We thank the primary authors, James
R. Wingard and Peter Zahler, for their
hard work in creating an excellent product. e work
was managed by Tony Whitten, Senior Biodiversity
Specialist, East Asia and Pacifi c Region of the World
Bank. e study was funded by the Government of the
Netherlands through the Netherlands-Mongolia Trust
Fund for Environmental Reform (NEMO).
Every study must recognize the various individuals
that have contributed to its success, for no study is the
result of one person’s eff orts. However, the authors
would be remiss if they did not express a special thank
you to a particular group of researchers. Much of
the information contained in this report represents
nothing less than their sheer determination and
persistence. Given the task of interviewing thousands
of people spread across one of the largest and least
populated countries in the world, in a single summer,
they did not (as they easily could have) buckle under
the enormity of the job. Day after day, for weeks on
end, they grabbed their stacks of interview sheets and
headed out the door to endure endless drives across hot
and dusty landscapes, reaching in the end virtually all
corners of Mongolia. is acknowledgment is in large
part dedicated to all of them, especially: B. Arunbileg,
S. Oronchimeg, E. Sodmaa, D. Monkhbayar, M.
Norjmaa, Ts. Mu n khjargal, Ts. Tsog tsolmaa, M.
Azjargal, S. Altantsetseg, C. Purevsuren, B. Ankhtset-
seg, N. Ankhtsetseg, Kh. Otgondorj, S. Buyandelger,
T. Chingel, Ts. Altangerel, Ts Basanjargal, Tsogtjargal,
Ch. Ariunzaya, and D. Oyuntuya. We were also
fortunate enough to have two tough characters to lead
our more challenging market surveys, J. Ochirkhuyag
and Otgontumur. Not to be forgotten in this list is
a young foreign exchange student from the United
States, Luke Distelhorst, whose constant presence,
Mongolian language skills, and dedication to the
eff ort contributed in uncountable ways to the fi nal
product. e fi nal analysis came into focus with help
from Charles Yackulic, a master’s student at Columbia
University in wildlife biology, who helped wade through
the mountains of data and make sense of it all.
In an extraordinary show of cooperation, this study
also benefi ted enormously from the contributions of
several organizations. Without their willingness to
provide data, photographs, and conduct surveys in
their project areas, this study would still have signifi -
cant gaps. ese include numerous individuals at the
Mongolian Academy of Sciences, Institute of Biology
(Dr. Tsendjav, Dr. L. Amgalan, Dr. Mandakh, Amga-
laanbaatar, Dr. Lkhagvasuren, and Dr. Dulamtseren),
National Police Agency (Boldbaatar), State Specialized
Inspection Agency (Dr. Ts. Banzragch), Ministry of
Nature and Environment (J. Batsukh and Ganzorig),
Scientifi c and Environmental Cinematographic Soci-
ety of Mongolia (D. Sumkhuu), Taimen Conservation
Fund (Dr. E. Erdenbat and E. Batsuren), Mongolian
Conservation Coalition (Dr. Richard Reading, Zolaa),
Community Conservation Network (G. Gansukh), In-
ternational Takhi Group (Petra Kacenzcky and Chris
Walzer), GEF/World Bank Khuvsgul Project (Sh.
Saruul, B. Mendsaikhan, and Dr. Clyde Goulden),
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UNDP Eastern Steppe Biodiversity Project, UNDP/
GEF Conservation of the Great Gobi and its Umbrella
Species Project (Ts. Dashzeveg and Enkhbat), Argali
Project (Ganchimeg Wingard), Denver Zoological
Foundation (Jed Murdoch), USAID Economic Policy
Reform and Competitiveness Project (B. Indraa), GTZ
Conservation and Sustainable Management of Natural
Resources Project (P. Suvd and Galragchaa), and the
Khustai National Park Trust (Ts. Sukhtulga).
e authors also thank the WWF Mongolia Program
Offi ce, in particular Chimgee (former director),
Chimed-Ochir (director), Onon (biodiversity special-
ist), and Batnasan (project leader) for their integral
partnership in this endeavor and their assistance in
numerous aspects of the study, including assistance
in the development of the survey questionnaires,
methods, analysis, wildlife trade conference, and
follow-up work. WWF Mongolia has been actively
involved in assessing wildlife trade issues and pursuing
actions to stem the increasing tide of trade. eir
expertise and knowledge, particularly in Mongolia’s
western provinces, helped shape this study’s approach
and provided critical data for the analysis.
e fi nal text benefi ted from the comments of several
expert reviewers whose professional insights improved
the discussion and eliminated oversights. For this, a
debt of gratitude is expressed to various staff of the
World Bank: Chris Finch (Senior Country Offi cer,
EACCO), Richard Damania (Senior Environmental
Economist, SASES), Sudarshan Gooptu, Lead
Economist EASPR, Magda Lovei (Sector Manager,
EASEN), Yoko Watanabe (Biodiversity Specialist,
GEF), and to other specialists, including Dr. Richard
Reading (Director of Conservation, Denver Zoological
Foundation), Axel Braunlich (Birdlife International),
and Tom McCarthy (Director of Science and Conser-
vation, ISLT). Bryony Morgan handled the complex
fi nal stages of report production and incorporated
details from recent taxonomic reviews and conserva-
tion assessments for Mongolia. Desktop and design of
the publication was by e Word Express.
Finally, great thanks are due to the thousands of
participants in this study for their candor and patience
in answering more questions in one sitting than
any interviewee should have to endure. e results
contained in these pages belong to them.
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– 1 –
Executive Summary
Although never a part of the Soviet Union,
Mongolia’s long status as a satellite state
guaranteed that it would suff er from the
collapse of that world power. Along with
many other countries, and seemingly overnight,
Mongolia was cut adrift from the government that had
dominated its political and economic life for almost
70 years. Mongolia was understandably unprepared to
negotiate the forced transition which happened when
its level of development was substantial compared to
what it was in the 1920s, but it was still very much a
dependent nation, living in large part off Soviet subsi-
dies. Investment in the country by its former mentor
had given Mongolia a well-regulated capacity to
harvest, but little ability to produce or add value to its
resources; and wildlife trade was always a part of what
it supplied. From 1926 to 1985, Mongolia delivered
to its northern neighbor a total of 119 million furs, 13
million kilograms of game meat, and 1.5 million tons
of elk antlers, trading as many as 3.5 million animals
in a single year. Recently, the opening of borders with
China, with its dominant economy and enormous
capacity to absorb resources, has resulted in a shift in
trade routes but a rapid re-escalation in wildlife trade,
with concomitant declines in economically important
wildlife species.
Five examples highlight the recent, rapid decline in
economically important species in Mongolia.
Within fi ve years, the population of Mongolia’s
subspecies of saiga antelope (Saiga tatarica mongo-
licus) catastrophically declined from over 5,000 to
less than 800, an 85 percent drop (WWF 2004).
e decline in Mongolia follows shortly after a
similar collapse in the major populations of saiga
in Kazakhstan and Russia, where populations
have crashed from over 1 million in the early
1990s to perhaps as low as 31,000 in recent years;
the driver in this collapse is the lucrative Chinese
medicinal market for saiga horn (Millner-Gulland
et al. 2001, Flora and Fauna International 2004).
Red deer (Cervus elaphus) have also declined
catastrophically across Mongolia. According to
a 1986 government assessment, the population
size at that time was approximately 130,000 deer
inhabiting 115,000 square km. e most recent
population assessment in 2004 showed that only
about 8,000 to 10,000 red deer now inhabit 15
aimags (provinces) of Mongolia. is is a 92
percent decline in only 18 years.
Government fi gures estimated 50,000 argali (Ovis
ammon) in Mongolia in 1975, but only 13,000 to
15,000 in 2001 (Amgalanbaatar et al. 2002). is
is a 75 percent decline in just 16 years.
Marmot (Marmota sibirica) once numbered more
than 40 million, dropping to around 20 million
by 1990 and were last tallied in 2002 at around 5
million; a decline of 75 percent in only 12 years
(Batbold 2002).
Finally, saker falcons (Falco cherrug) have started
a similarly precipitous decline, dropping from an
estimated 3,000 breeding pairs in 1999 to 2,200
pairs, losing 30 percent of the population in just 5
years (Shagdarsuren 2001).
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Mongolia
2
Anecdotal evidence suggests the same is happening
to other wildlife species for which either limited or
no direct population data are available. is is a trend
that, however unstudied, is fully acknowledged by
Mongolians across the country. During the course of
this survey, hunters frequently commented that red
squirrels have all but disappeared from many forests.
ey complained that red and corsac fox are becoming
harder to fi nd, and roe deer, brown bear, moose, black-
tailed gazelle, and musk deer are all vanishing, leaving
only silence in a landscape once fi lled with the sights
and sounds of wildlife. When asked to characterize
the wildlife resource, both hunters and non-hunters
expressed concern that unbridled hunting around the
country is creating an empty landscape.
Wildlife trade in Mongolia
Trading millions of animals every year, Mongolia’s
overall wildlife trade economy is estimated by this
study at more than $100 million annually. is is a
conservative estimate that relies primarily on fur trade
values and to a lesser degree on medicinal and game
meat trade.
Six species comprise the core of Mongolia’s wildlife
trade. In order of importance, they are 1) Siberian
marmot, 2) corsac fox, 3) red fox, 4) Mongolian
gazelle, 5) roe deer, and 6) red squirrel. Although low
in value compared to some traded species (e.g., snow
leopard), these species are all hunted in large volumes
by thousands of hunters across the country. By
comparison, species with the highest domestic values
represent signifi cant income levels only for trophy
hunting operators and a few hunters/traders. In other
words, the least valuable are in fact the most valuable.
e gray wolf also fi gures prominently in Mongolia’s
trade equation because of the high number of hunters,
moderately high market values, and harvest levels all
combining to make it one of the more lucrative trade
species. However, exaggerated harvest fi gures made it
diffi cult to accurately estimate total trade.
Much of Mongolia’s wildlife trade is for the interna-
tional fur market, but a growing international and
domestic market for wild game and medicinal parts
plays a signifi cant role that should not be ignored.
Fur trade
e largest portion of wildlife trade, both in terms
of volume and value, consists of furs sold on the
international market, primarily to China, with some
trade going to Russia and a limited amount sold on the
domestic market.
e primary fur trade targets are Siberian and Altai
marmot (Marmota sibirica and M. altaica), wolf (Canis
lupus), red fox (Vulpes vulpes), corsac fox (Vulpes
corsac), red squirrel (Sciurus vulgarus), snow leopard
(Uncia uncia), brown bear (Ursus arctos), lynx (Lynx
lynx), and Pallas’ cat (Otocolobus manul). Limited fur
trade exists for sable (Martes zibellina), badger (Meles
meles), mink (Mustela vison), weasels (Mustela altaica
and M. erminea), steppe polecat (Mustela eversmanni),
hare (Lepus spp.), muskrat (Odontra zibethicus), pika
(Ochotona spp.), chipmunk (Tami a s s ibiricu s ), and roe
deer (Capreolus pygargus) skins.
e single largest volume of fur trade is for Sibe-
rian marmot. An estimated 3 million animals were
harvested in 2004 alone, at an estimated market value
of $30 to $40 million.
Although not traded in large volumes, rare and highly
threatened species such as snow leopard are also
traded. is trade is extremely diffi cult to track and
quantify. Project investigators discovered 13 fresh
snow leopard skins in a small western border town in
China during this study, reportedly poached in Mon-
golia. Also during the same summer of 2005, Russian
border guards confi scated another 15 Mongolian snow
leopard skins on Mongolia’s northwestern border.
Medicinal trade
Trade in medicinal products has increased both on
the domestic and international market. e primary
trading partner is China, but several interviewees
reported selling large volumes to Koreans as well.
International buyers are looking primarily for brown
bear gall bladder, saiga antelope horns, wolf parts of
all types (including tongue, spleen, ankle bones, and
teeth), musk deer (Moschus moschiferus) glands, red
deer shed and blood antlers, genitals, tails, and fetuses,
and snow leopard bones.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
3
e domestic medicinal market includes marmot,
wolf, corsac fox, badger, sable, brown bear, muskrat,
roe deer, musk deer, snow leopard, Pallas’ cat, Daurian
hedgehog, Daurian partridge, Altai snowcock, and
northern raven.
Game Meat Trade
Trade in game meat, other than fi sh, appears to be
limited to the domestic market for the moment.
Mongolian gazelle (Procapra gutturosa) meat was once
traded to China, but that trade has apparently stopped
with the recent banning of commercial harvests in
Mongolia and the closure of game processing plants in
China.
Mongolia also supplied large quantities of fi sh to
markets in Russia in the early 1990s, but a change in
supply routes and higher prices paid in China have
caused trade to shift primarily to China, although
trade continues to some degree with Russia.
Even though international game meat trade has slowed
or even stopped, the domestic market is thriving and
by itself represents a signifi cant and continuing threat
to wildlife populations. e domestic market therefore
deserves serious management and regulatory attention.
Game meat available in local markets includes Siberian
and Altai marmot, Mongolian gazelle, roe deer, moose
(Alces alces), Altai snowcock (Tetraogallus altaicus),
several species of fi sh, and, in some areas, Asiatic wild
ass (Equus hemionus).
A number of restaurants in Ulaanbaatar and around
the country have started to off er fresh fi sh on the
menu. Species include the endangered taimen (Hucho
taimen), lenok (Brachymystax lenok), river perch (Perca
fl u v i a t i l i s ), northern pike (Esox lucius), Siberian gray-
ling ( ymallus arcticus), Siberian whitefi sh (Coregonus
spp.), Potanin’s osman (Oreoleuciscus potanini), the
(introduced) common wild carp (Cyprinus carpio),
catfi sh (Silurus asotus), and a species of lamprey
(Lethenteron reissneri).
Trophy and Sport Hunting
Trophy and sport hunting have become increas-
ingly popular in Mongolia and have the potential to
contribute to wildlife management by providing much
needed funding. Many large mammals, some raptors,
and one fi sh found in Mongolia are advertised by
hunting companies around the globe. ese include
gray wolf, brown bear, red deer, Siberian ibex (Capra
sibirica), argali (Ovis ammon), wild boar (Sus scrofa),
Mongolian gazelle, black-tailed gazelle (Gazella
subgutturosa), Ussurian and Yakut moose (Alces alces
cameloides and A. a. pfi zenmayeri), and roe deer.
e Ministry of Nature and Environment actively
promotes trophy hunting and has set special rates
ranging from $100 for red fox to as much as $25,000
for Altai argali. Reinvesting a percentage of these fees
in the conservation of the resource (required by the
Law on Reinvestment of Natural Resource Use Fees)
has the potential to provide signifi cant funding for
wildlife management.
However, government fi nance regulations and a lack
of community benefi t from trophy hunting prevent
this market from achieving the desired outcome of
supporting hunting management and local economies.
As a result, trophy hunting represents yet another
competing use of a dwindling resource.
Trade Chains and Markets
is study identifi ed fi ve diff erent wildlife trade
chains active in Mongolia: (1) hunters to domestic end
users; (2) hunters to domestic markets; (3) hunters
to domestic processors; (4) hunters to cross-border
markets, and (5) hunters to international trade chains.
In general, Mongolia’s wildlife trade chains involve
individual hunters, both professionals and amateurs,
harvesting wildlife in remote areas and bringing it
to collecting points in urban centers and settlements
located throughout the country. Almost every soum
center has at least one individual acting as a collection
point, making this a truly national problem.
Products not sold locally are typically transported to a
larger market such as Ulaanbaatar, sold to an interna-
tional buyer, packaged, and shipped across the border,
typically concealed under other goods, usually heavy
items such as scrap metal. Once across the border, the
products disperse quickly to processors and fi nally to
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Mongolia
4
the end users, at which point the product and its origin
are virtually untraceable.
Mongolia’s three largest trade centers are located in
or near Ulaanbaatar. ey include the Tsaiz market
(in Ulaanbaatar), Emeelt market (45 km west), and
Nalaikh (45 km east). Another three markets inside
Ulaanbaatar’s city limits (Naraan Tuul, Khuchit
Shonkhor, and Kharhorin) play a lesser role in wildlife
trade, for the most part selling to the domestic market
and international tourists.
Other major trade centers are located in Choibalsan
(near Mongolia’s eastern border with China),
Baganuur, Tunkhel, Govi-Altai, Mongonmort, and
Erdentsant. Each of these markets represents a major
collecting point from which products travel directly to
the border with some potential for additional transfer
to the Ulaanbaatar markets.
Although exact amounts are diffi cult to verify, all
indications are that volumes of wildlife passing
through these markets have been high. One trader
at the Tsaiz market reported total sales in 2004 of
500,000 to 600,000 marmot skins, 50,000 wolf skins,
and 50,000 each for red and corsac fox skins. He
also admitted trade in small quantities of medicinal
products without estimating total volumes. We were
unable to verify these statements with independent,
objective data, but the volumes for all but wolf appear
plausible. We suspect wolf trade may be exaggerated or
refl ect trade moving through Mongolia from Siberia.
Wildlife markets and collecting points in Mongolia
are relatively susceptible to enforcement. For the most
part, they are open, easily accessible, and wildlife
products are sometimes openly displayed and adver-
tised. e exceptions are small, highly valuable trade
items associated with medicinal trade such as bear gall
bladder or musk deer pods, or with illegal fur trade
such as snow leopard skins. Given the diffi culties with
patrolling vast hunting areas or trying to track goods
in transit, enforcement is best focused on the trade
markets and collection points.
Trad e S u s t a i nabilit y
ere is near unanimous agreement among hunters,
traders, and biologists in Mongolia that continued
wildlife trade at the volumes reported is unsustainable.
While the causes of decline have been attributed to
several factors—including infrastructure development,
conversion of habitat for agriculture, overgrazing,
competition for forage, and mining—the most serious
and immediate threat is overhunting, most of it illegal.
In Mongolia, infrastructure development is still
limited to a few urban areas where wildlife habitat is
not a concern. e reported increases in agricultural
land use are an unlikely culprit in species de-
clines—Mongolia is an arid country with less than 1
percent of the entire country suitable for agriculture,1
most of which is centered in the Selenge River basin.
Even if all appropriate land had been converted to
agricultural production, the increases would not have
aff ected signifi cant percentages of wildlife habitat for
any species occurring in Mongolia, and would not
adequately explain the recent 50 to 90 percent declines
documented for some species.
e increase in livestock over the last 15 years is
certainly a cause for concern, but few studies have
assessed the degree to which either overgrazing or
competition for forage are aff ecting wildlife. Two stud-
ies hint strongly at the potential impact of competition
for forage; however, neither has concluded that this
would have any signifi cant impact on wild ungulate
numbers.
A strong indicator of decreasing populations and
increasing demand is the increase in prices for wildlife
products. Prices have increased for wolf, red and corsac
fox, red deer parts, saiga antelope horns, and marmot
skins and meat. Also reacting to price increases and
decreasing supplies, border markets in China sell a
number of imitation products for all types of wild
animal skins, saiga horns, and other parts.
Impacts of Wildlife Trade on
Biodiversity Conservation
e rapid decline in wildlife is likely to have a cascade
eff ect across Mongolia’s ecosystems.
Hunting pressure has occurred on a monumental
scale, and species declines are likely to have
1 e Area Handbook for Mongolia, U.S. Country Studies reports
Mongolia having 0.77 percent arable land.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
5
unintended large-scale eff ects on non-target species,
including predators, competitors, symbiotes (species
with close ecological relationships, e.g., species that
utilize marmot burrows for dens), and even vegetation
composition.
Unfortunately, almost nothing is known about the
signifi cant ecological roles performed by the species
that are heavily hunted. While many studies have been
done by national and international biologists over the
past fi fteen years for certain species (e.g., argali, snow
leopards, marmots, Mongolian gazelle, black-tailed
gazelle, saiga antelope, corsac fox, gray wolf, red deer,
musk deer, Asiatic wild ass, taimen, saker falcon), they
are not enough to fi ll the knowledge gap for several
reasons:
Many of these studies still focus only on popula-
tion surveys, which are useful in documenting
declines, but cannot by themselves conclusively
explain the reasons for those declines.
Only a few have looked at specifi c questions of
ecology (e.g., feeding ecology, dietary overlap,
migratory patterns, etc.).
None have assessed the impact of hunting.
Several species directly impacted by hunting and
wildlife trade have not been studied at all within
the Mongolian context (e.g., red squirrel, roe deer,
brown bear, moose, ibex, wild boar, lynx, beaver,
red fox, badger, muskrat, Daurian hedgehog,
Altai snowcock, great bustard, Eurasian eagle owl,
black grouse, white ptarmigan, greylag goose,
gadwall, arctic loon, Dalmatian pelican, Daurian
partridge, Pallas’ sandgrouse).
Non-game species have received almost no atten-
tion, leaving biologists and managers guessing at
the possible chain reactions that severe decreases
in certain game species will cause.
With this knowledge base, we can only postulate
that some of these may be keystone species (e.g.,
Siberian and Altai marmots) for biodiversity and even
ecosystem engineers. If true, they contribute positively
to the sustainability of the grasslands and therefore the
long-term livelihoods of pastoralists.
In addition to ongoing studies, Mongolia urgently
needs to develop studies designed to assess the impact
of hunting on target and non-target species, as well as
biodiversity conservation.
Impacts of Trade on Rural Livelihoods
Local hunters have gained from wildlife trade, but at
the present rate of consumption, those gains will be
short-lived. Of the total trade economy of about $100
million in 2004, we estimate that individual hunters
throughout the country garnered roughly half of the
profi ts. On a per capita basis for the total number of
hunters (≈ 250,000), this represents average yearly
earnings of $200 per hunter—an amount equal to
roughly four to fi ve months salary for rural residents.
Actual earnings among hunters varied signifi cantly.
For many hunters, wildlife trade is a subsistence
activity with only a few animals or parts sold each
year. For a few, hunting for wildlife trade is a full-time
activity with annual sales of hundreds, even thousands
of animals.
e other half of wildlife trade profi ts went to traders
located in Mongolia’s small and large collection
centers, outdoor markets, and restaurants. With no
more than 10,000 full-time traders in the country,
we estimate per capita earnings of $5,000/yr; ap-
proximately 10 times an average annual salary for rural
residents and almost three times the annual per capita
GDP of $1,800 (2003 est.).
Harvests over the last decade have clearly outstripped
the capacity of the resource to recover. Population
surveys and anecdotal information such as increasing
hunter eff ort all point to severe declines for several
species and hint at the potential for their economic
and local, if not complete, extinction. Saiga antelope
may have already crossed into economic extinction at
least for organized hunts that specifi cally target this
species.
e loss of species, whether for trade or individual
consumption, will send ripple eff ects throughout the
economy and Mongolia’s culture. On an individual
level, herders will be forced to either purchase meat
on the local market or consume their own livestock
to replace the protein previously obtained from wild
game. Purchasing meat at market means cash out of
pocket that many people, especially in Mongolia’s
countryside, do not have.
Using livestock has even greater implications, as it will
cost not only the market value of the animal but also
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Mongolia
6
the continuing values of dairy products, wool and/or
hair, and other products (including the production of
young) obtained from the animal during its life.
Because of the varying levels of use and wide-ranging
economic status of hunters, it is not possible to
quantify the impact the loss of wildlife will have
on individual budgets. Taken together, Mongolia’s
economy will sustain large, long-term losses as the
earning capacity from wildlife trade dwindles.
Given the magnitude of the wildlife trade, the costs of
policy neglect are having serious negative impacts to
the present value and future earning potential of the
country.
Enabling Wildlife Management
e single most important institutional constraint to
wildlife management is the lack of any agency at the
national or local level with adequate capacity and full
authority to assume the task.
Established in 1989, the Ministry of Nature and
Environment has never created an agency dedicated
to wildlife management. Instead, Mongolia’s wildlife-
related laws delegate managing authority to local
governments that do not have the training or funding
to implement eff ective management.
e Academy of Sciences’ Institute of Biology has
only 15 biologists to survey at least 59 species directly
targeted by wildlife trade. Even if the institute had the
capacity, its work would still only result in recommen-
dations to the Ministry of Nature and Environment,
rather than actual quotas.
e Ministry, however, has no personnel with the
expertise to adequately review and make such deci-
sions. In addition, the Ministry’s interest in increasing
revenue coupled with the power to make these
decisions presents a clear confl ict of interest that has
led to harvest quotas in excess of those recommended
by the Institute of Biology.
Recommendations to correct these institutional
defi cits will not work if funds are not available to sup-
port these individuals and their activities. e system
already provides at least a portion of the needed funds.
Earning a reported $4.1 million in 2003 (trophy
hunting and saker falcon sales), wildlife trade was the
third highest natural resource earner behind mining
licenses and land fees.
Following the Law on Reinvestment of Natural
Resource Use Fees, which requires that 50 percent
of hunting fees be reinvested, should have resulted in
at least $2 million being made available for wildlife
management in 2004. Instead, only $545,000 was
dedicated to conservation and rehabilitation activities
for all resources, including wildlife, water, forests,
land, and natural plants.
Four major constraints exist to adequate funding:
(1) the Ministry of Nature and Environment’s is the
least-funded ministry in the country; (2) the ministry
has no specifi c budget allocated for wildlife; (3)
the law requiring investment in the resource is not
followed; and (4) the Public Sector Management and
Finance Law nullifi es funding opportunities for local
governments.
Numerous regulatory constraints also make it diffi cult
to adequately manage wildlife. Some of the more
critical gaps include the lack of any law or regulation
directed at wildlife trade; decision-making procedures
that prevent a science-based approach to quota setting,
a problem that constitutes a violation of Mongolia’s
CITES obligations; population survey requirements
that are too infrequent to inform management
decisions and are not adaptable to emerging needs;
the absence of any tagging or registration system for
hunting and trade; the existence of statutorily defi ned
seasons that deny wildlife managers the needed fl ex-
ibility to adjust seasons annually or even mid-season
if necessary; the lack of any defi ned season for certain
trophy species; the absence of sex-based regulations
and size limits; civil fi nes and penalties that have no
deterrent value because they are only a fraction of the
market value; and no incentives or rights to support
community-based alternatives to national management
and enforcement.
Management Recommendations
After completing surveys and conducting preliminary
analyses, this project held a working conference with
over 100 participants from government, civil society,
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
7
international experts, donors, and relevant parts of
the private sector to review the fi ndings of the study
and explore the most eff ective possible means of
controlling the trade, as well as suggesting initiatives
for the sustainable management of certain of these
valuable natural resources. Conference participants
cited numerous gaps and confl icts in law, management
structures, implementation practices and enforcement
capacity that have allowed the overuse of Mongolia’s
wildlife resources for more than a decade. Among the
main themes are:
e lack of any legislation directed specifi cally at
wildlife trade.
Off take levels that are not scientifi cally based.
Inadequate training and capacity to enforce
existing hunting and trade restrictions.
Inadequate use of economic incentives and
disincentives in hunting legislation.
A lack of incentive and legal basis for eff ective
community participation.
A failure to capture revenue from the system for
the benefi t of the resource.
A lack of systematic knowledge on hunting and
wildlife resources.
A lack of inter-agency cooperation and sharing of
enforcement data.
Corruption at all management levels.
As a fi nal product of the conference, the conference
participants submitted a number of recommendations
directed at fi ve management areas: (1) international
trade enforcement, (2) domestic trade enforcement, (3)
hunting management, (4) trophy and sport hunting
management, and (5) community-based approaches to
management.
Supplementing these main themes, working groups
at the conference off ered several crosscutting and
sector-based recommendations, which the reader will
fi nd outlined in the section entitled “Recommenda-
tions for Priority Actions.” To the extent possible,
recommendations have been prioritized and reference
likely implementation authorities. Ultimately, respon-
sibility for implementation rests with the Mongolian
Government and its people. Central to eff ective trade
management will be the following:
e Mongolian Academy of Sciences should set
scientifi cally based, sustainable off take levels for
all targeted species and monitor populations.
e Ministry of Nature and Environment should
take a lead role in designing needed legislation,
procedural mechanisms, and enforcement
protocols for both national and local management
actions.
e State Specialized Inspection Agency should
assume primary enforcement responsibility and
coordinate overlapping tasks with other key
authorities.
e State Border Defense Agency should engage
in monitoring and enforcement of cross-border
trade within the country.
e Mongolia Central Customs Authority should
develop new methods of detecting trade and
establish eff ective cross-border cooperation with
China and Russia.
e State Police should control the infl ux of
weapons and ammunition into the country and
enforce relevant laws in local areas.
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– 9 –
Introduction
At the outset, it is important to place this
study within the context of the country
of Mongolia, its wildlife, and its cultural
heritage. Although offi cially open to the
western world for more than a decade, Mongolia is still
relatively unknown. Among the uninitiated, Mongolia
is a country of mystery whose borders lie somewhere
just off the map of the known world. Mention of the
name often evokes singular images of the wild and
strange and, considering its history, sometimes strong
emotions. For some, it is hordes of marauding horse-
men galloping across the steppe; for others, grasslands
that extend as far as the eye can see, nomads living a
life unchanged for centuries, or the haunting melody
of throat singers. What few realize, but more are learn-
ing, is that Mongolia is also one of Central Asia’s last
wildlife refuges—a place where herds of Mongolian
gazelle, thousands strong, still migrate across a vast
unbroken steppe; where seeing a wolf in the wild is
almost commonplace; and where freshwater salmon
grow to sizes that stretch the imagination.
Perched in the Central Asian highlands far from the
moderating infl uence of any ocean, Mongolia is a
land of climatic and geographic extremes that shape
both the natural world and the people that live there.
Temper a tu r e s d i ff erences as much as 85°C (154°F)
between summer and winter challenge the hardiest to
survive; summer highs reach 40°C (104°F) and winter
lows -45°C (-50°F). In the southern Gobi, scarce and
unpredictable precipitation defi nes the fragile, sparsely
vegetated environment of the world’s northernmost
desert; making this region one of the least populated
in the world outside the polar ice caps. In the north,
rain falls often enough to support the world’s
southernmost reaches of taiga (northern coniferous)
forest and some of Mongolia’s richest grasslands.
While the south thirsts for water, the north contains
some 3,000 rivers stretching over 67,000 km (41,200
miles). Nestled against Mongolia’s northern border
with Russia, Mongolia’s Lake Khuvsgul is estimated
to contain 2 percent of the world’s freshwater. Most of
Mongolia’s 2.5 million people live in and around these
resources.
e landscape is similarly severe. Averaging over
1,580 m a.s.l. (5,180 ft), the ground descends over
3,850 m (12,600 ft) in elevation from the towering
Altai Mountains in the west (highest peak is Khuiten
Mountain in Bayan Ulgii Province at 4,375 m (14,350
ft)) to the steppe and deserts of the south and east
(lowest elevation is Khukh Nuur in Dornod Province
at 518 m (1,699 ft)).
Gobi lyn x. Image: Dr. Richard R eading.
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Mongolia
10
ese extremes have helped shape a natural world
full of strange encounters and unique assemblages of
plants and animals. is sparsely populated country is
situated just north of the most populous, China, and
harbors Asia’s largest tracts of intact grassland. ese
grasslands have supported teeming populations of
Mongolian gazelle, which are today virtually extinct
in neighboring China, as well as millions of Siberian
marmot and large numbers of corsac fox, red fox, and
wolf. Where the last stands of taiga forest approach the
sands of the Gobi Desert, the habitats of wild Bactrian
camels and musk deer nearly merge. Where the west-
ern mountains descend to the plains, saiga antelope
occasionally mingle with wild mountain sheep. Where
the forests give way to grass and sand, Eurasian lynx
leave their forest home to roam the steppe and the
desert’s northern reaches. In the far south, an unlikely
population of brown bear (Mongolia’s Gobi bear) can
be found hunting the mountains and plains of the
Gobi.
For centuries, Mongolians have carved an existence
adapted to the extremes of this land. e most obvious
adaptation is the nomadic lifestyle dictated in large
part by scarce precipitation and marginal resources.
Nomadism is one reason Mongolians historically
established few permanent settlements compared to
their southern and northern neighbors. e advent
of Soviet rule brought with it a partial settling of
the culture, but even here, the forces of development
remained isolated and changed traditional nomadic
practices only by restricting movement, but not
eliminating it. Today, infrastructure development is
even more concentrated, primarily in Ulaanbaatar and
a few major cities.
e harsh climate and lack of resources have played
a role in keeping the population low. Despite the
impressive size of the former Mongol empire, there
have never been very many Mongolians. In the early
1900s, records indicate a total population of only
600,000—less than 0.5 persons per square kilometer.
Government-sponsored programs over the last 80
years have helped to increase this number to 2.5
million—four times as many, but still just 1.5 persons/
km2. Traditional knowledge—born of long experience
with a fragile environment, reinforced by Buddhist
tradition—has taught Mongols to respect nature and
Wolf skin disp layed by hunter in Mongoli a’s G obi-Altai Province (Sha rgiyn Gobi). Image : Henry Mix/N ature Conservation I nternational.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
11
avoid disturbing the earth and water. Consequently,
the country’s landscape remains largely untouched
and unspoiled even in modern times. Compared to
neighboring countries, wildlife in Mongolia thrived in
a culture that left their habitat intact and gave them
the space to survive.
Against this backdrop of natural beauty, abundant
wildlife, and cultural heritage is a country struggling
to fi nd solid ground after 70 years of Soviet control
and subsidy. As this report documents, wildlife has
paid the price in this struggle. e question is, will it
lose the battle?
e international community is wakening to the
threat wildlife trade presents globally and in Asia.
It has been reported that “[i]llegal commercial trade
in wildlife, parts and products is second only to the
illegal drug trade in overall dollar value, estimated to
exceed $5 billion annually worldwide” (Jagodinski
2001). is crisis is particularly acute in Asia due in
large part to a growing market for wildlife products
used in traditional medicine and furs used in clothing.
Numerous studies have looked at the issue in South-
east Asia, but few have turned their attention north,
to an area that contains some of the last remaining
tracts of open wild land, including vast expanses of
temperate forests and grasslands supporting large
populations of wildlife. One of the countries for which
there is a paucity of data, but which has an enormous
open border with China, is Mongolia. is study was
conceived to fi ll that knowledge void. It is a fi rst for
Mongolia and the region, and it documents a wildlife
trade crisis with profound implications for the country,
its ecology, economy, and culture.
Before the study began, the main principles underlying
the growing crisis were already known. Mongolia’s
by now well-publicized move from communism to
capitalism was in many respects extremely diffi cult.
For long years, the economy in the country rested
heavily on Soviet subsidies. In exchange, Mongolia
fed its natural resources into the maw of Soviet
production. When the socialist system collapsed, so
did the subsidies and with them the economy, leaving
this land-locked country with only marginal capacity
to function, but a decided ability to extract natural
resources. Almost without pause, individuals across
the country learned that wildlife could become a new
currency; and there was almost nothing to get in the
way of accessing it. Funding cuts incapacitated wildlife
enforcement personnel at all levels. e borders to
China and Russia were suddenly open more than
they had been in 70 years. Mongolians did not need
visas to enter China, and the market was ready and
willing to accept whatever anyone could supply. For
fi fteen years, Mongolia’s wildlife was the target of
increasing numbers of hunters who were taking ever
larger numbers from this fragile resource. As time
passed, Mongolia was joining the ranks of countries in
Africa and Asia where habitat loss is no longer the sole
concern for wildlife, but where uncontrolled wildlife
trade has now become a global and local threat to
biodiversity.
However, there was virtually no information about
how much of what species were being traded, what
the primary drivers were, or what impact trade was
actually having on targeted species. Many people,
ranging from scientifi c experts to local stakeholders,
expressed their concern and some even studied a few
species in a few areas, but overall a solid understanding
of wildlife trade was missing. Nonetheless, from
these early studies it was clear that wildlife provide
numerous economic benefi ts to local people. ese
benefi ts include a source of protein, fur, and medicine
as well as supplemental income from trade. For many
people in Mongolia, the availability of wildlife is a
cornerstone to economic and even physical survival. It
provides food for the table, medicine for the sick, and
furs to protect against the bitter winters of Central
Asia. Moreover, it also means that livestock does
not have to be slaughtered for consumption, instead
providing years of benefi ts in the form of milk, wool,
trade in these products for other crucial items, and a
combination of savings, wealth, and insurance.
ere is, therefore, a critical need to address the rapid
loss of economically important wildlife species in
Mongolia. However, before this can be done, it is
essential to determine the types, extent, rate, trends,
and impacts of unsustainable trade in wildlife. e
goal of this project is to better understand the role
of wildlife trade in Mongolia; the impacts on traded
species; and, through a working conference, design
recommendations for improved wildlife management.
e results of the various activities and inquiries call
attention to the overuse of many species in Mongolia
and the known or probable impacts such use will have
on Mongolia’s culture, environment, and economy.
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– 13 –
Before beginning the survey, the project team
identifi ed and tested a suite of information
sources and methods that would assist in
determining wildlife trade types, volumes,
values, and trends. ese included direct observation
and questioning in markets, random sampling of
shops in urban areas, random sampling of individuals
(hunters and consumers), and the collection and
comparison of information from offi cial government
sources and other conservation projects. Over a
three-month period—from June to August 2005—we
completed 4,010 household surveys (0.65 percent of
all households) in all 21 aimags in Mongolia, 1,100
market surveys at individual markets in major and
minor urban centers across the country, and 100
market surveys in northern China along the border
with Mongolia.
O cial Data Sources
One of the ultimate goals of this study (along with
documenting levels of wildlife trade) is to initiate
discussions on improving management mechanisms
for wildlife hunting and trade. Critical to this
endeavor is an understanding of how offi cial statistics
are gathered, what they measure, and how the results
of these statistics compare to other forms and sources
of information. In other words, we wanted to know
what the offi cial baseline tells us, how accurate it is
and, where necessary, what types of information or
recording procedures would improve it.
1. Wildlife Trade Survey Methods
Offi cials sources that we used in this study included
customs trade data from China, Mongolia and Russia;
enforcement records from the Mongolian State Border
Defense Agency and the State Specialized Inspec-
tion Agency; offi cial hunting quotas issued by the
Ministry of Environment, aimag (province), and soum
(county) governments; CITES export records from
the management authority at the Ministry of Nature
and Environment (MNE); and historical records
for species population levels, recommended hunting
quotas, and trade volumes from the Mongolian
Academy of Sciences. roughout the project, we
were able to work well with the Mongolian Central
Customs Authority and through them received some
(although limited) information from Russian and
Chinese authorities. e MNE provided CITES data
from 2000 for comparison. Cooperation with the State
Border Defense Agency was positive with important
information made available.
Despite exceptional government cooperation, our
eff orts to review such data still met with several
obstacles. First, some of the most important data
we were looking for simply do not exist. Key to
understanding the impact of current trade on any
given species is an understanding of the animal’s
biology and ecology, distribution, and population
trends. Very few species that are hunted in Mongolia
have ever been studied in any detail, and even for these
species, population surveys have been infrequent. is
study compiled such data to the extent that they exist.
Where data were not available (and purely for purposes
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Mongolia
14
of comparison), we describe relevant information for
the same or similar species in areas outside Mongolia.
Creating additional and probably permanent data
gaps is the fragmented history of wildlife management
in Mongolia. Since the beginning of offi cial wildlife
management in the 1930s, management authority has
changed hands almost every 10 years, and at least six
separate entities have been delegated some responsibil-
ity. ese include the Ministry of Trade and Industry,
Ministry of Foreign Trade, Ministry of Nature and
Environment, Mongolian Central Customs Offi ce, the
Mongolian Hunter’s Association, and the Mongolian
Academy of Sciences. With the changing of hands, the
format for data collection and reporting changed, and
in some instances, data were lost. Fortunately, this was
not true for wildlife trade records, for which we were
able to review original documentation dating as far
back as 1926.
For the information that does exist, we faced three
additional obstacles—insuffi cient detail to allow more
than rudimentary analysis, inconsistent record-keeping
practices that prevented comparisons across areas and
years, and the reluctance of at least one government
agency to share available data. For the most part, there
is no detailed accounting system for wildlife-related
uses. Data reported typically come in the form of
aggregate numbers; that is, total number of permits
sold in a given year, total income from sales, total
volume traded, or total enforcement volumes. Critical
information—including demographics of license
purchasers, amounts paid for each license, whether
and where licenses sold have been fi lled, and virtually
all details associated with enforcement—is either not
collected, not compiled in a central database, or not
published. Because data are not compiled centrally, the
best source of wildlife licensing information is at the
local government level. However, because of inconsis-
tent record-keeping practices, obtaining information
from this source yields a confusion of data that is all
but unusable. Diff erent inspectors keep records in
diff erent ways at diff erent times, making it virtually
impossible to track wildlife licensing information
over time. In some instances, exiting inspectors take
their data with them, leaving large gaps in the record.
Especially frustrating was the reluctance of the State
Specialized Inspection Agency to share enforcement
records in anything other than highly aggregated
form. Invoking the Law on State Secrets and perhaps
unwilling to harm the reputation of companies
that violated the law, this agency shared only the
percentage of enforcement activity related to wildlife.
As a result, we were unable to learn what species were
involved, what volumes and values were associated
with enforcement, the location of enforcement actions,
or the outcome of any enforcement proceedings.
In this study, we therefore resolved to focus on trade
volumes, the limited wildlife population data available,
and a few reported enforcement statistics, realizing
that much information critical to a full understanding
of the situation is simply unavailable.
Household and Market Survey Methods
Given the size of the study area (countrywide), the
short time-frame (3 months), and number of species
potentially within the purview of the study, we devised
separate survey methods for estimating current hunt-
ing and household consumption levels as well as trade
volumes based on retrospective respondent recall.
ere are advantages and disadvantages to this
approach. Social science research often relies on
“longitudinal” surveys where individual, families, or
groups are monitored over a long period, often several
years. e resulting time-series data allow studies
of trends and transitions over time, and would be
of particular use in measuring trends in wildlife use
patterns. Such a study design was never an option for
this particular endeavor, given the short time frame
available. However, a recall survey is a cost-eff ective
method that, when carefully applied, can be a sur-
rogate for longer-term longitudinal survey methods.
To assist in the development and beta test of both
market and household survey questionnaires, we used
several survey test methods, including (1) cognitive
interviews, (2) respondent interviews, and (3) analysis
of non-responses.
To eliminate major problems with the questionnaire,
cognitive interviews were used after initial develop-
ment by a team of subject-matter experts on selected
respondents who were asked to describe their thought
processes when responding to the questions.
Following this, we used interviewer debriefi ng at
various stages of fi eld-testing—after each interviewer
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
15
had conducted 1–2 interviews under fi eld conditions
(10 interviews total), after each survey team completed
one morning session under fi eld conditions (approxi-
mately 5 interviews per group, 25 interviews total) and
after each team completed two full days under fi eld
conditions (100 interviews total). Interviewer debrief-
ings were conducted using group discussions with the
entire survey team present. We collected information
about the interviewers’ perceptions of problems,
prevalence of the problems, reasons for the problems,
and suggested solutions to the problems. Interviewer
debriefi ngs continued periodically for three weeks after
initiating fi eld surveys in both group and individual
settings, and contributed to adaptive redesign during
the initial stages of the survey.
In addition, survey designers analyzed non-response
rates from collected data to determine which questions
were too diffi cult for respondents, which questions
respondents refused to answer, and which questions
were simply not applicable. ose questions that
were too diffi cult or were refused by a majority of
respondents were eliminated from the questionnaire.
Non-responses due to non-applicability were retained
for further analysis after data from other areas had
been collected and compiled. If the question continued
to receive no response, we eliminated it from the
questionnaire. e fi nal data set contains only those
response columns that remained valid throughout the
survey period.
We were able to devise and conduct a nationwide sur-
vey by using a base team of ten volunteer students and
by outsourcing surveys to projects located throughout
Mongolia. Assisting organizations included the WWF
Mongolia Program Offi ce, International Takhi Group,
Taimen Conservation Fund, Mongolian Conserva-
tion Coalition, Community Conservation Network
(CoCoNet), World Bank/GEF Khuvsgul Project,
UNDP/GEF Eastern Steppe Biodiversity Project,
UNDP/GEF Conservation of the Great Gobi and its
Umbrella Species Project, Argali Project, and Denver
Zoological Foundation. After beta testing, the base
team and survey developers provided training on the
use of the questionnaire to representatives of these
organizations. Surveys were conducted during one
season only and were therefore not repeated for any
region or with any of the respondents. Each survey
method and questionnaire is described in the sections
that follow.
Household Consumption Surveys
Household consumption surveys were directed at
individuals throughout the country. rough an
approximately 20-minute interview, they identifi ed the
types and quantities of species hunted, the quantities
later sold to markets, and the amounts and types
purchased by individuals at such markets. e method
was adapted from Starkey (2004), who examined
bushmeat trade in Koulamoutou, Gabon. We
completed 4,010 household surveys in all 21 aimags in
Mongolia.
To quantify harvest volumes, we formulated questions
looking at several components of an individual or
family’s wildlife harvests on a species-by-species
basis. ese included the names of the species
harvested, amounts harvested for each species per
hunting excursion, the number of hunting trips per
year, estimated yearly harvest, harvest seasons and
level of eff ort, trends in harvest amounts and species
harvested, techniques used currently and any changes,
and any observed changes in the quality or abundance
of species harvested.
To quantify domestic sales volumes, we asked respon-
dents to identify species parts and quantities of parts
sold, prices of wildlife products sold by the hunter
on the market, and trends in the commercial sale of
wildlife products.
For wildlife use, we devised a similar set of ques-
tions to quantify any use and directed them to all
respondents regardless of whether they also harvested
the same species. Many hunters in Mongolia are not
entirely reliant on their own harvests and therefore
also factor into the market from the end-user side.
Questions included the names of the species used, the
parts, purposes, amounts, and market prices for each
species used, the yearly average of use, market sources
for each species, the amount of wild game meat
consumed, the amount of meat (whether domestic or
wild game) consumed on a daily basis, trends in use
(amounts or types of species), trends in market values,
and any observed changes in the quality, availability,
or quantity.
Because of the large geographic region and sparsely
populated landscape, we used a multi-stage sampling
method. To select survey areas, we created a cluster
random sampling map divided along Mongolia’s 21
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Mongolia
16
provincial boundaries (aimags). We then overlaid this
with rough distribution maps for species known to
be hunted. Sampling areas were then selected from
each provincial area that occurred inside and outside
marked species distribution boundaries. Within
each selected cluster area, specifi c urban and rural
communities were selected based on a convenience
sampling strategy that identifi ed available survey staff
and travel routes. To sample urban populations, we
used a stratifi ed sampling methodology that divided
the urban population into non-overlapping districts
using the district mapping available from the city or
town’s central administration offi ce.
Urban areas were sampled using a simple random
sampling method. For larger urban centers, such
as Ulaanbaatar, we conducted an equal number of
sidewalk interviews at randomly selected locations
within each district. On site, survey staff designated
a square on the sidewalk. After waiting one minute,
the fi rst person to enter the square was questioned.
is process was repeated, with one minute waiting
periods between interviews, until the desired number
of interviews for the area had been completed. In
smaller urban centers, aimag and soum centers, we
conducted house interviews. To do this, researchers
fi rst numbered each of the streets in the district
(typically less than 10). Surveyors were then instructed
to pick a number from a bag with slips of numbered
paper and conduct interviews on the corresponding
street. To select the house at each street, researchers
again selected a number from the bag and conducted
one interview at the corresponding residence.
Outside urban areas, we conducted ger (house)
interviews along pre-selected transects between urban
areas within the sampling clusters. Transects were
therefore both a function of convenience and cluster
sampling methods. Because of the nomadic lifestyle of
countryside residents, random sampling was entirely
a function of interviewing people as researchers found
them.
We placed signifi cant energy and resources into this
household eff ort for the following two reasons. First,
there is just enough enforcement in the country to
make wildlife traders wary of people who ask too
many questions. is is especially true for those
who trade in endangered species, but also for wolf
and marmot traders where little or no enforcement
is visible. e market is therefore the most diffi cult
and most unreliable source of information. Second,
the primary source of wildlife products for traders is
individual hunters located throughout the country.
In our experience, individual hunters were willing
to discuss their activities with us in the context of
one-on-one interviews. Only one project area located
along the southern border east of Dalanzadgad
reported any diffi culty with reluctant interviewees.
Apparently, enforcement in the area is somewhat more
intense, with many interviewees recounting arrests and
jail time for poaching.
Market Surveys
Market surveys followed roughly the same method
for household surveys, with some exceptions. To get
a better understanding of the overall market and to
design the questionnaire, we fi rst employed a “snow-
ball” method by targeting known markets that actively
sell wildlife products. In these locations, we conducted
observational surveys and some unstructured direct
questioning of shop owners posing alternately as
tourists, hunters from the countryside, foreign traders
interested in purchasing large volumes, and as student
researchers. From this exercise we learned that the
most diffi cult areas to sample would be the larger trad-
ing centers (referred to as “container shops” because of
the dual use of railroad containers as storage units and
sales locations) in and around Ulaanbaatar and using
“student researchers” would be the least productive
questioning technique for sampling trading centers. In
the end, market surveys in the “container” shops were
done posing as traders. For surveys in other stores,
students posed simply as students. Interviewer debrief-
ings and a review of returned questionnaires indicated
that “students” in shops within the city did not meet
with any more diffi culties than other approaches. A
single approach reduced complications and misunder-
standings among the interviewers.
e resulting list of questions attempted to identify
the types of species and products sold, purchase and
sale prices, and quantities sold over time. e same
method was used to assess the status of wildlife
trade in restaurants, tourist shops, clothing stores,
outdoor markets, grocery stores, wholesale markets,
and container shops. Separate questionnaires were
developed only for restaurants.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
17
We then used essentially the same multi-stage
sampling methodology using the previously developed
cluster random sampling map to select general survey
areas. Specifi c sampling areas were similarly selected
from each provincial area that occurred inside and
outside marked species distribution boundaries, but
with an emphasis on areas known as staging centers
for trade and areas assumed to be outside normal
market chains. Convenience again dictated which
communities would be sampled, typically coinciding
with household consumption survey eff orts. To sample
individual shops, we stratifi ed communities into non-
overlapping districts on the same basis as household
surveys. In smaller communities, particularly soum
centers, we attempted to sample all shops in each
district. For larger urban centers, such as Ulaanbaatar,
we used randomly selected bus stops as center points
and sampled all shops within approximately 100 meters.
In China, a survey team comprised of Chinese wildlife
biology students, wildlife biologists, and a teacher
from Inner Mongolia targeted only a narrow portion
within Inner Mongolia running along the border with
Mongolia. Cities visited by the survey team included
Ereen Khot, Shiliin Khot, Hailar, Dong Wu, Xin
Barga Baruun, Suni te zuo qi, Saikhan Tal, Khokh
Khot, Tong Liao, Wu La Te, DaMao, Mandula, and
Alashan Zuoqi. e intent was to identify border areas
that were part of the trade routes and chains coming
from Mongolia, the species traded, types of trade
(medicinal, fur, trophies, etc.), and fi nally the volumes
Research staff condu cting market survey i n Ulaanbaatar. Image: J. W ingard, August 2005.
and values of Mongolia’s wildlife trade with China.
e questionnaire developed for use in Mongolia’s
markets was modifi ed to sample all shops in the
tourist districts and randomly sample other shops
in cities along China’s northern border, selected for
convenience and as known or suspected trade routes.
In China, tourist districts are known to sell wildlife
products of all types. ey are typically clustered
in a single area and therefore may be sampled with
minimal expenditure of time and eff ort. Although
staff used a slightly modifi ed questionnaire based on
the template developed by the Mongolian team, they
targeted the same questions and results. Shop owners
were considerably less willing to talk to researchers due
to stricter enforcement. As a result, researchers were
unable to keep questionnaires with them and were
forced to complete forms from memory. is may have
led to some errors and omissions in the data, but staff
felt confi dent that they were able to record a majority
of the responses accurately.
A similar system was developed for sampling Russian
shops in urban areas close to Mongolia’s in Ulaan Ude
and Naushk, but it was soon discovered that market
surveys there would be much more diffi cult. Russian
shop owners for the most part refused to respond to
questions. Results are therefore anecdotal, but still
instructive of general trends and some key aspects of
enforcement and markets that aff ect wildlife trade.
Survey staff completed 1,100 market surveys in Mongo-
lia and 100 market surveys in several cities in China.
Data Analysis Methods
Analyzing survey data—and scaling
up from samples to estimates across
an entire country—always requires
certain assumptions and is limited by
several factors, including the sampling
design, quantity, and quality of the
data. Our eff orts to draw inferences
from the samples to obtain estimates
for entire populations are no diff erent.
In the following description of our data
analysis methods, we have attempted to
be as transparent as possible, acknowl-
edging assumptions and pointing out
shortcomings of our survey design and
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Mongolia
18
results. Despite these limitations, we are confi dent
that our estimates are good approximations of wildlife
off take and trade in Mongolia. Our estimates agree
with other studies conducted on individual species and
the perspectives of those familiar with wildlife harvest
in the country.
Although data were gathered on a number of param-
eters (income levels, knowledge of legal requirements,
changes in resources), the analysis contained in this
report is restricted primarily to quantitative analyses
of certain responses only, e.g., numbers of hunters,
number of animals harvested, value of species traded.
Additional quantitative assessments were performed
to determine the existence of signifi cant relationships
between certain variables within the data set. For
example, paired t-tests were used to examine whether
mean harvest levels of specifi c species per hunter
depended on vehicle ownership. We performed similar
tests looking at hunting prevalence and (1) age, (2)
gun or trap ownership, and (3) hunter residency by
region and by urban and rural classifi cation. However,
it was never the intention of this study to perform a
complete analysis of all data collected; this was well
beyond the scope of the inquiry and timetable of this
report. Collected data will be further analyzed to
more clearly identify relationships and elucidate trends
across the spectrum of wildlife trade issues in Mongo-
lia. e original data are available from the authors,
dependent upon an agreement with the World Bank.
Assessment of Data
When reviewing the data and deciding on which
calculations and method to use, we were careful to
consider sample design, researcher bias, quantity and
quality of the data, and internal consistency (e.g., were
respondent income estimates compatible with vehicle
ownership levels, was level of eff ort consistent with
level of take, etc.). In our assessment, we feel that the
accuracy of our results and our ability to draw infer-
ences may have been aff ected by the following:
i. Our original sample design was intended to
sample evenly from each of the 21 provinces
within the country. is was not possible pri-
marily due to the logistics of designing and
implementing a survey of this magnitude in
such a short period. Sample size therefore varied
somewhat between aimags and was comparatively
low in Dundgovi, Arkhangai, Khentii, Orkhon,
and Darkhan Uul. For fi ner scale inquiries (e.g.,
number of marmot hunters in the region) these
areas were excluded, resulting in lower overall
hunter and harvest estimates.
Figure 1: Sampling results of males and hunters interviewed compared to Mongolian
male population
Source: 20 04 Wildlife Trade Study res ults and NSO-Mo ngolia. 2004. Mon golian Statistical Yearboo k 2003. Ulaanbaatar,
Mongoli a: National Statist ical Offi ce of Mongolia.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
19
ii. Second, our sample design resulted in an under-
sampling of individuals between the ages of
10–24 and >70 years relative to sampling for all
other age groups. Figure 1 compares our sampling
of men by age category to the number of hunter
respondents and the number of males in the
population (it became clear during data collection
that females were rarely directly involved in
hunting). e left axis is the measure of males
interviewed (maroon bars) and hunter respondents
(orange bars), while the right axis measures the
population of all males in the country (blue bars).
e under-sampling of the younger age group in
particular may have aff ected our overall hunter
and harvest estimates. Both experience and survey
results tell us that the younger age group (starting
around age 15) can be important participants in
wildlife harvests and trade.
iii. Because the study was outsourced to a number
of cooperating organizations, the potential for
researcher bias to aff ect results was larger than
if it were centrally administered. Training was
provided to one individual per organization with
experience conducting resource use surveys in
Mongolia’s urban and rural areas. We were not
able to supervise additional training given to all
participants in the study. To achieve our target
number of interviews and area within the existing
timeframe, this risk was unavoidable. To reduce
researcher bias entering the results, completed
forms from each survey group were reviewed
for errors and obvious bias before data entry.
Any sheets with clearly incorrect responses were
eliminated from the data pool.
iv. Respondent recall surveys have inherent limita-
tions that cannot be avoided. Despite survey
design elements used to prompt recall, we were
concerned about respondents’ ability to remember,
and remember accurately, how many of what
species they harvested, how many they sold, and
for how much. ere is no way to conclusively
evaluate how well our survey population recalled
without recourse to and comparison with detailed
harvest and market records and wildlife popula-
tion data, none of which exist. erefore, we
cannot know defi nitively whether some survey
respondents were systematically under-reporting
or over-reporting harvests. Both add error to our
measure of hunting levels. In the end, there may
be a bias in either direction, or they may neutral-
ize each other when analyzed for general trends.
However, for some responses, recall is not a
signifi cant issue. For example, asking whether
or not an individual hunts does not require the
respondent to remember any detail and thus we
feel these responses can be interpreted with rela-
tive freedom. Other responses require an ability to
recall details of events that have happened in the
past and are therefore subject to a certain degree
of uncertainty. To minimize the impact of this
uncertainty, before extrapolating data, we fi rst
determined distribution and removed extreme
outliers from harvest results.
v. e lack of detailed information on the age
structure of the human population by region also
presented some limitation to the accurate extrapo-
lation of results. We relied upon the statistics
generated by the Mongolian National Statistics
Offi ce to scale the number of hunter respondents
on a regional basis. It is not known what, if any,
bias this data gap may have introduced into the
results.
vi. Finally, some degree of error is likely due to the
timing of the survey (summer), when hunting and
wildlife trade are minimal, and to the limitation
of the survey to one season, when hunting and
trade in Mongolia are highly seasonal events. e
estimates provided by interviewees therefore may
tend to refl ect the survey season and not the entire
year.
Estimating the Number of Hunters
It became clear during data collection that females
were rarely directly involved in hunting. None of
the 894 women sampled stated that they hunted.
erefore, our nationwide estimates assumed that the
contribution of women to hunting was so negligible
that we could estimate it as none. Hunter estimates are
derived solely from the responses of men.
To estimate the total number of hunters in the
country, we fi rst determined the number of males
interviewed in the course of our survey (ma=3,119)
wb silentsteppe text 8-10.indd 19wb silentsteppe text 8-10.indd 19 8/10/06 12:14:28 PM8/10/06 12:14:28 PM
Mongolia
20
and the number that said they hunted (mh=949). We
then estimated the total population of hunters in the
country using four separate calculations. For each of
these calculations, we made the assumption, based on
survey results and experience, that hunters younger
than age 15 and older than age 60 are rare (see Table
C4: Estimate of total number of hunters weighted by
age class, p. 142). We therefore excluded these age
groups from the pool of potential hunters using the
age structure of Mongolian population from the State
Statistics Annual Report 2003 (NSO 2003). e
exclusion of these ages may introduce some negative
bias into the overall estimates.
i. e fi rst, and simplest, calculation estimated the
total number of hunters using the formula:
(1) ,
where Nh = estimated total number of hunters,
Nm = number of males in Mongolia (>14 and <60
years of age, NSO 2003), mh = the number of
males surveyed that hunt, and ma = the number
of adult males surveyed. is estimate created
a baseline for comparison with the results of
weighted calculations in equations 2–4.
ii. In the second calculation, we weighted hunter
estimates by age class using national age structure
statistics (NSO 2003) to refl ect population
diff erences between age groups. is calculation
aggregates the total number of hunters from
separate estimates of each age group based on
the relative percentage of hunters in the age class
(e.g., 30 percent of all males ages 20-24) and the
population of the age class (e.g., 100,000). Our
hypothesis was that signifi cant diff erences in
hunter percentages and population levels would
aff ect overall estimates. For example, a high
percentage of hunters coming from an age class
with a relatively low population level would result
in lower overall estimates. To test if this was
true in our study results, we used the following
formula:
(2) ,
where Nh = estimated total number of hunters,
i = age class, Nmi = the number of males in the ith
age class (NSO 2003), mhi = the number of males
surveyed in the ith age class that hunt, and mai =
the number of males in the ith age class surveyed.
Results are provided in Table C4, p. 142.
iii. Our third calculation weighted hunter estimates
by aimag residency. Because the national statistics
do not provide male-to-female ratios by age class
for each aimag, this calculation assumes the same
proportions provided in Table C4 (NSO 2003).
We also assume the same proportion of hunters
for each age class. e formula used is:
(3) ,
where Nh = estimated total number of hunters,
j = aimag, Nj = number of people in the jth aimag
(NSO 2003), Nm = the number of males in
Mongolian population (ages 15-60) (NSO 2003),
NT is the total population in Mongolia (ages
15 -6 0), mhj = the number of males surveyed in
the jth aimag that hunt, and maj = the number of
males surveyed in the jth aimag. Results provided
in Table C5, p. 142.
iv. Our fourth calculation weighted hunter estimates
by urban/rural residency. For this calculation, we
also assumed the same male-to-female ratios by
age class for each as provided in Table C4 (NSO
2003) and the same proportion of hunters for each
age class. e formula used is:
(4) ,
where Nh = estimated total number of hunters,
r = residency classifi cation, Nr = number of
people in the rth residency classifi cation (NSO
2003), Nm = the number of males in Mongolian
population (ages 15-60) (NSO 2003), NT is the
total population in Mongolia (ages 15-60), mhr =
the number of males surveyed in the rth residency
classifi cation that hunt, and mar = the number of
males surveyed in the rth residency classifi cation.
Results provided in Table C6, p. 143.
To arrive at a fi nal estimate of hunters in the country,
we used the results from the third calculation as the
lowest estimate and a better fi t for estimating harvest
NN
N
N
m
m
hj
m
T
hj
aj
j
=∗
⎡
⎣
⎢⎤
⎦
⎥∗⎡
⎣
⎢
⎢
⎤
⎦
⎥
⎥
⎛
⎝
⎜
⎜
⎞
⎠
⎟
⎟
=1
211
∑
NN
N
N
m
m
hr
m
T
hr
ar
r
=∗
⎡
⎣
⎢⎤
⎦
⎥∗⎡
⎣
⎢⎤
⎦
⎥
⎛
⎝
⎜⎞
⎠
⎟
=
∑
1
21
NN
m
m
hmi
hi
ai
i
=⎡
⎣
⎢⎤
⎦
⎥
⎛
⎝
⎜⎞
⎠
⎟
=
∑*
1
12
NN m
m
hm
h
a
=∗
⎛
⎝
⎜⎞
⎠
⎟
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
21
levels that fl uctuate regionally according to species
distribution. In addition, we adjusted our result from
this calculation downward to refl ect the percentage of
individuals that engage in hunting only as a hobby.
ese individuals do not hunt regularly or contribute
to the overall harvests by subsistence and commercial
hunters in the country, which was the primary
concern of this study. e number of “hobby” hunters
was calculated based on responses to Question #14,
Purpose of Hunt, in the Household Consumption
questionnaire, Appendix D: Household Consumption
Survey, p. 145.
Estimating Wildlife Harvests
It is important to remember that the accuracy of the
estimates provided in this report will likely diff er
from a complete census that might be achieved using
offi cial records on hunter licensing and success rates.
Furthermore, sample survey estimates always have two
types of errors, sampling and non-sampling, and fi nal
estimates are dependent on both of them. However,
the full extent of non-sampling errors is unknown.
erefore, the potential for bias must be considered
and caution exercised when interpreting the data.
To estimate wildlife harvests for individual species, we
fi rst reviewed all information reported by respondents
for each species in the main data fi le to correct data
entry mistakes and omissions. We then produced a
separate data set containing the basic demographic
parameters (age, residency, vehicle ownership, gun or
trap ownership, and income) and harvest information
(level of eff ort, numbers harvested per trip, total
harvest per year). Using SPSS Base 12.0, we deter-
mined the distribution of the annual harvest levels and
removed outliers.
In reviewing the data for some species (marmot, red
squirrel, red fox, corsac fox), it became clear that
reported harvests for virtually all respondents were
general fi gures (200, 100, 50, etc.) with no reported
numbers in between. We felt that respondents tended
to round fi gures up to the nearest 10 or even 100.
Without adjustment, this rounding up would result in
substantially infl ated mean harvest levels and grossly
exaggerated total harvest estimates. Unfortunately,
there is no way for us to know how much rounding up
occurred. We therefore made the assumption that no
one rounded up more than 50 percent and used the
middle fi gure of 25 percent to adjust reported harvest
levels of 10 or above, the lowest level at which we felt
rounding was likely to occur.
In addition, some individuals reported harvesting
numbers that experience told us would be unlikely for
one individual and were probably harvested by a group
of hunters, or simply a function of exaggeration by
the respondent. To adjust for either case, we used our
best judgment and reduced reported harvest levels for
these individuals to the mean harvest calculated for
the remaining respondents for the area and species in
question.
In the fi nal calculation of harvest estimates, we used
the same method of weighting hunter estimates
by aimag set out in the third calculation of hunter
estimates, multiplied this by the proportion of hunt-
ers in the aimag that reported hunting the species
analyzed, and again by the adjusted mean harvest level
for species in the aimag. us:
(5) ,
where all variables are the same as equation 3 with
the addition of msj = the number of hunters in the jth
aimag that hunt a given species, and Hj = the adjusted
mean harvest level per hunter in the jth aimag. Results
are provided in Table C8, p. 144.
NN
N
N
m
mH
aj
m
T
sj
aj
j
j
=∗
⎡
⎣
⎢⎤
⎦
⎥∗⎡
⎣
⎢
⎢
⎤
⎦
⎥
⎥∗
⎛
⎝
⎜
⎜
⎞
⎠
⎟
⎟
==
∑
1
21
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– 23 –
2. History of Wildlife Trade in Mongolia
A
brief look at historical wildlife take and
trade is useful to understanding the present
situation. e most important lesson is that
today’s heavy trading and declines in wild-
life populations have happened before in Mongolia.
rough a combination of strict measures, increased
control, and refi ned management, Mongolia has twice
in the past managed to slow trade and preserve its wild
heritage. is section describes the historical trends in
wildlife trade.
Hunting and at least some form of trade,—whether
bartered, paid as tribute, or sold on the market—has
always been a part of Mongolian culture. Many of the
species that occur in the country provide a tradi-
tional source of protein, fur, and medicine. Marmots
(Marmota sibirica and M. baibacina), for example, are
especially important, providing meat, fur for clothing,
medicinal oils high in natural cortisone, and other me-
dicinal products. Marmot oil contains naturally high
levels of corticosterone2 and has several traditional
uses in Mongolia, including as a leather conditioner,
to treat burns, frostbite, anemia, tuberculosis, and
as a dietary supplement for animals and children.
Wol f (Canis lupus) meat, tongue, and spleen are used
to treat all kinds of ailments from colds to asthma.
Red fox (Vulpes vulpes), corsac fox (Vulpes corsac), and
Pallas’ cat (Otocolobus manul) furs have long protected
Mongolians from the bitter winters. Wolf fur is
considered the warmest of all and is especially prized.
Wild boar (Sus scrofa), roe deer (Capreolus pygargus),
Mongolian and black-tailed gazelle (Procapra gutturosa
and Gazella subgutturosa), and Asiatic wild ass (Equus
hemionus) are common sources of wild game meat.
Several birds have also been hunted for their meat and
medicinal properties. Game birds include hazel grouse
(Tetrastes bonasia), white ptarmigan (Lagopus lagopus),
rock ptarmigan (Lagopus mutus), Daurian partridge
(Perdix dauuricae), chukar partridge (Alectoris chukar),
Eagles are t raditionally use d in hunting in parts o f Mongolia. This Ka zakh
man in Gobi -Altai, western Mo ngolia, is training a yo ung bird to hunt mar-
mot. Image : Pete Middleton, 2003
2 Corticosterone (or cortisol) in marmot spp. is secreted by the
adrena l cortex in response to stressors. It has a strong anti-
infl ammatory eff ect, increases mobilization of amino acids from
muscle (increasing protein breakdown), increases mobilization
of fatty acids (increasing lipid concentrations in the blood), and
increases blood glucose concentration (Wingfi eld and Romero 2001).
wb silentsteppe text 8-10.indd 23wb silentsteppe text 8-10.indd 23 8/10/06 12:14:34 PM8/10/06 12:14:34 PM
Mongolia
24
Pallas’ sandgrouse (Syrrhaptes paradoxus), black grouse
(Tetrao tetrix), western capercaillie (Tet rao ur o g a l lus ),
black-billed capercaillie (Tet r ao par v i r ostr i s ), and bar-
headed goose (Anser indicus). Birds used in traditional
medicine include the Altai snowcock (Tet ra ogall us
altaicus), common crow (Corvus corax), eagle owl
(Bubo bubo), Daurian partridge, cinereous vulture
(Aegypius monachus), greylag goose (Anser anser),
black-eared kite (Milvus lineatus), ptarmigan, gadwall
(Anas strepera), and arctic loon (Gavia arctica).
Given the degree of traditional use, it is not surprising
that hunting rights were a concern long ago. e
formal codifi cation of hunting rights and prac-
tices began, as did all written law in Mongolia, with
Chingis Khan’s Ikh Zasag in 1206. is law, and the
many that followed through the centuries, addressed
several environmental concerns, among them the
management of wildlife resources. Chingis Khan’s
directives established hunting grounds, defi ned access
rights, specifi cally permitted and prohibited certain
hunting practices, and set penalties (some severe) for
violation of the law. However, formal trade in species
and harvests that exceeded domestic consumption was
never a subject of legal concern. It is this gap in Mon -
golia’s legal and management framework that has more
than once in Mongolia’s history led to a wildlife crisis.
At least as early as 1755, formal trade with the
Manchu empire included furs from Mongolia (Scharf
and Enkhbold 2002). Until Mongolia’s fi rst revolution
in 1911, annual tribute to China was paid in the
form of sable (Martes zibellina) furs or an equivalent
number of substitute furs—1,352 sables or 4,066 lynx
furs, 2,704 red fox furs, or 54,080 squirrel pelts.3 At
the beginning of the 20th century, increased Chinese
presence and global demand for furs put heavy pres-
sure on Mongolia’s wildlife. Central to trade then, as
now, was the Siberian marmot. Records from the turn
of the century show trade levels that were among the
highest ever recorded, averaging more than 2.5 million
furs per annum in the years leading to Mongolia’s fi rst
revolution in 1911 (Figure 2).
Mongolia’s revolution in 1921 brought with it a
fundamental shift in trade from south to north,
but not necessarily a respite from extreme harvests.
Immediately following the change in power, existing
trading companies were dissolved and replaced with
Soviet-controlled entities who obtained the exclusive
right to harvest and trade in all raw materials, includ-
ing wildlife (Scharf and Enkhbold 2002). Mongolia
continued to sell marmot furs and, with the addition
of new species to offi cial trade (e.g., red and corsac fox,
wolf, wild boar, Mongolian gazelle, and red squirrel),
was again approaching historic volumes (3.2 million in
1910, 1 million in 1922, and 2.5 million in 1927).
World War II was a mixed blessing for wildlife, halting
trade in some areas and causing sharp increases in
others. In the east, the Japanese occupation of Man-
churia in 1931 and Inner Mongolia in 1937 eff ectively
stopped all wildlife trade with China. To the north,
however, Mongolia began supplying the Russian
army with as much game meat and furs as it could
process. Wildlife trade more than doubled from the
mid–1930s to the mid–1940s and record harvest levels
were documented for a number of species. Among the
hardest hit were Mongolian gazelles, Siberian mar-
mots, and even wolves (Avirmed 1999). As a result, the
sustained harvest volumes continued from the 1920s
until the 1950s, again reaching more than 3 million
animals traded in a single year in 1953.
Aware of the need to curb uncontrolled harvest and
trade, the decades following the 1921 revolution
witnessed a fl urry of related legislative activity. A
general mandate to conserve and sustainably use
wildlife in 1924 was followed in 1925 by the establish-
ment of hunting license requirements for domestic and
trophy hunters, with further amendments in 1926. A
3 Scharf and Enkhbold 2002, citing D. Avirmed, “Hunting and Wild
Animal Conservation in the History of the Mongols” [Report],
1999.
Commercial ly harvested gazel le ready for loading an d transport to Choi-
balsan. S ome 10,000 gazelle were h arvested on this hunt fo r sale on the
internatio nal market. Due to the poo r condition of the meat, n one of them
were actua lly sold. Image: He nry Mix/Natur e Conservation Inter national.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
25
year later, the rights to purchase and trade marmot
furs were legally granted to a single cooperative, the
Mongolian People’s Commercial Cooperative. e
1930s saw prohibitions on the hunting of rare animals,
fi shing restrictions, and bans on the use of vehicles to
chase antelope or use of military weapons for hunting.
However, not until the 1950s was Mongolia able to
bring its wildlife harvest and trade within some form
of nationwide management system. After a number
of minor management shifts, hunters were eventually
organized into brigades located in each soum and
aimag center and managed by a Central Hunting
Association. ese brigades were fully vested with the
power to harvest wildlife for offi cial trade, as well as
investigate and prosecute poaching incidents. Com-
pared to today, they were impressively well-organized
and outfi tted. Khentii aimag alone boasted 12 hunting
brigades with 604 members, 16 vehicles, and the funds
to engage in hunting and enforcement patrols (Scharf
and Enkhbold 2002). Offi cial harvest levels dropped
by almost 50 percent compared to the war years.
For most species, the record harvests of the 1940s
and 1950s were not to be seen again, at least until
the 1990s. e exceptions were red fox, Mongolian
gazelle, and wild boar, all of which either continued to
climb or experienced substantial harvests even into the
196 0 s.
Ultimately, the long years of overhunting and
uncontrolled trading forced the Mongolian govern-
ment in the early 1970s to ban hunting of all species
for international trade. Foreign experts were called
in from Hungary and East Germany to assist with
the study of wildlife populations and refi nement of
hunting management. In 1981, Parliament passed a
long-needed piece of legislation requiring population
surveys for all fi sh, birds, and mammals. For some
species, offi cial trade was never restarted. For others,
the respite lasted fi ve years, from 1975 to 1980.
As relations between China and the Soviet Union
softened, the opportunity to trade medicinal products
to the south reopened, including red deer blood antlers
and shed antlers, tails, genitals, and incisor teeth,
and reindeer blood antlers (Scharf and Enkhbold
2002, citing data provided by the Central Hunting
Association).
Figure 2: Total Annual Legal Wildlife Trade in Mongolia 1926–1985
Source: Mo ngolian Academy of Scie nces, Institute of Biol ogy, Historical Trade Recor ds, 1926 –1984; Adi ya Ya., 2000.
/VNCFSPG"OJNBMT5SBEFE
:FBS
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Mongolia
26
Despite trade decreases for certain species and the
hunting bans of the 1970s, wildlife trade continued
to play a substantial role in the economy. Mongolia’s
trained, equipped, and organized hunting units
diversifi ed their activities, seeking out other species
to exploit, while the Hunting Association found
new markets to supply. Beginning in the late 1950s,
Mongolia added roe deer, ground squirrel, lynx,
Pallas’ cat, mink, weasels, steppe polecat, tolai hare,
pikas, and Mongolian gazelle to the offi cial fur trade.
Trading partnerships were established with Poland,
Hungary, Bulgaria, and Romania. Eff orts were even
made to introduce certain wildlife populations; e.g.,
raccoon dogs (Nyctereutes procyonoides) in the eastern
steppe and muskrat (Ondatra zibethicus) colonies
along Mongolia’s major rivers (Scharf and Enkhbold
2002). In 1981, fur exports accounted for 5 percent of
Mongolia’s foreign currency receipts, mostly from the
sale of lynx, mink, muskrat, fox, and marmot (BBC
1982).
Unfortunately, Mongolia did not have the ability to
extract full value from this resource. e country
still had limited capacity to process furs and was thus
forced to trade them at rates far below world market
values. For example, marmot skins were traded for
just 7 rubles, or $0.19 (Scharf and Enkhbold 2002).
However, wildlife trade remained an economic force
because of the sheer volume. In 68 years of recorded
trading, Mongolia supplied its southern and northern
neighbors with a total of 119 million pelts, 13 million
kilograms of game meat, and 1.5 million tons of red
deer antlers. Laid end to end, the furs would stretch
some 34,000 km, easily circling the globe at the 45th
parallel (Mongolia’s latitude).
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– 27 –
3. Wildlife Take and Trade Today
The collapse of the Soviet Union in 1990
and disbanding of the socialist trade
network was the undoing of Mongolia’s
century-long eff ort to control wildlife
trade. e economy halved, infl ation skyrocketed,
incomes fell to near zero, and store shelves emptied.
Suddenly without funding or direction, Mongolia’s
biologists were no longer able to pursue the manage-
ment objectives established only a few short years
before, or conduct the research necessary to inform
those activities. With no fuel, ammunition, or salaries,
the erstwhile hunting brigades (Mongolia’s only insur-
ance against widespread poaching) fell apart. With
no steady supply of furs and a wall of trade tariff s on
the border with Russia, Mongolia’s state-operated fur
processing center was no longer able to function. In
short order, the system Mongolia had worked long and
hard to develop disintegrated.
Wildlife trade may have slowed as a result,
but it did not stop. Virtually everyone was
looking for a way out of sudden poverty and
for many, wildlife—now unclaimed and
unprotected—provided the answer. Small-scale
traders started to fi ll the economic void, carry-
ing easily concealed wildlife products south and
north over the border. Red deer blood antlers
and shed antlers, saiga antelope horns, marmot
skins, squirrel skins—in short, anything that
would fi t in a bag or on a truck—started to
leave the country. Ereen Khot, a remote and
poorly connected border town in China,
enjoyed a boom as Mongolian traders funneled Re d deer antlers transp orted by truck. Im age: Michael Muhle nberg.
into the city. Additional trading posts opened up all
along the border to China, making it possible for
the fi rst time in 70 years for Mongolians across the
country to trade conveniently with this enormous
market. Relaxed gun ownership laws and rapidly
increasing market values fueled a hunting spree that
has continued to today. is study estimates that more
than 250,000 Mongolians actively harvest wildlife for
personal consumption, domestic, and international
trade. More than 1 million Mongolians (38 percent
of the total population) use wildlife in some form,
either for personal consumption or trade. Wildlife
trade has skyrocketed in volume and value; in 2004, it
was worth as much as $100 million to the Mongolian
economy.
e number of species aff ected by this growing
trade has similarly increased. e list of Mongolia’s
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Mongolia
28
endangered species targeted by this trade now
includes snow leopard, brown bear, saiga antelope,
taimen, wolf, musk deer, argali, Asiatic wild ass, saker
falcon, Dalmation pelican (Pelicanus crispus), and
great bustard (Otis tarda). e high harvest levels
documented by this study also raise concerns for a host
of other species. ese include red deer, Siberian and
Altai marmot, red fox, corsac fox, Mongolian gazelle,
black-tailed gazelle, moose, roe deer, red squirrel, and
Altai snowcock.
Changes in Management
Since the inception of the modern Mongolian state
in 1921, management of wildlife harvests and trade
changed hands a number of times. Incorporated as a
component of state production, the Ministry of Trade
and Industry had the responsibility for regulating
harvests, with exports delegated to the Ministry
of Foreign Trade. ese responsibilities were later
consolidated in the 1970s under the Ministry of Trade
and Industry, and were later delegated to the Hunter’s
Association. is organization had responsibility until
hunting management was moved the Ministry of
Nature and Environment (MNE) in the late 1980s.
Control over wildlife product exports became the
domain of the Mongolian Central Customs Offi ce.
rough these shifts and reorganizations, wildlife
management remained a recognized and important
management exercise.
For the most part,
institutional structures
managing wildlife have
changed little from their
pre-1990 form. e MNE
is still responsible for
setting quotas pursuant
to recommendations by
the Academy of Sciences.
Quotas are distributed to
soum governments, which
in turn are responsible for
local implementation and
enforcement. e Central
Customs Authority and
State Border Defense
Agency control the borders
and have the authority to
confi scate illegal traffi c. Joining the Convention on
International Trade in Endangered Species of Wild
Flora and Fauna (CITES) in 1996 has not changed
this structure or the basic functions. e Academy of
Sciences is the scientifi c authority and provides quota
recommendations to the MNE, which has manage-
ment authority.
However, there are important distinctions that make
the present situation diff erent from the past. In
Mongolia’s socialist period (1921 to 1991), hunting was
an integral part of a managed system. Regular wildlife
population surveys informed management; harvest
numbers and trade values were well documented;
gun ownership and ammunition supplies were tightly
controlled; hunting management at the local level was
well organized, equipped, and funded; and hunting
quotas were strictly observed—including a total
hunting ban in the early 1970s. Today, Mongolia’s
hunting law establishes general management prin-
ciples, but it does little to regulate trade and is only
marginally eff ective at controlling hunting. Funding
constraints mean infrequent population surveys. Only
a small percentage of actual harvest and trade values
are recorded; Gun ownership records are admittedly
inaccurate, ammunition is cheap and abundant, and
current hunting bans have limited, if any, eff ect. For
example, despite a total ban on marmot hunting, the
State Border Defense Agency reports confi scating
over 26,000 marmot skins by August 2005 (only
three months into the post-hibernation period). In
sum, while the former system did not ensure against
Mongolia n truck returning to Mon golia from Ereen Khot , border town in north ern China, after unlo ading trade
goods. Im age: Zhao Yao
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
29
overhunting, it did eff ectively prevent the development
of an uncontrolled market.
Becoming a member of CITES should have helped,
at least for some species, but Mongolia’s management
practices either negate or fail to take advantage of
benefi ts accruing from this convention. Fourteen
species of wildlife occurring in the country are
controlled by Appendix I of this convention, and
another 47 species by Appendix II. Of these, 15 species
from both appendices are actively traded on domestic
and international markets. International trade in any
of these species requires Mongolia to issue export
permits subject to the harvest levels determined by
the national scientifi c authority. Mongolia’s CITES
implementation regulation, however, is in contraven-
tion of the convention by granting the management
body the authority to resolve disputes surrounding
harvest quotas established by the scientifi c authority
and eff ectively allowing the management authority to
exceed harvest quotas. During this project, Academy
of Science biologists and hunting companies both
complained that quotas in recent years have been
almost double the recommended levels.
Moreover, the benefi ts of using Appendix III of the
treaty have gone unused. Appendix III is a list where
individual countries can place a species if it has
concerns about trade within or from its own country,
regardless of its status in other countries. Trade in an
Appendix III species requires a certifi cate of origin
to assure other CITES members that the species
did not originate in the
listing country. Although
CITES does not regulate
domestic trade, member
countries must observe
CITES trade restrictions
when participating in
international trade of
listed species. Appendix III
listings would be appropri-
ate for a number of species
listed in the Mongolian
Law on Fauna as “very
rare” or “rare,” but which
otherwise have no status
in CITES. ese include
Siberian ibex (Capra [ibex]
sibirica), Ussurian (A. a.
cameloides) and Yakut moose (A. a. pfi zenmayeri),
black-tailed gazelle, wild boar, Daurian hedgehog
(Mesechinus dauuricus), Altai snowcock, and taimen.
Appendix III might also be used to control trade in
species experiencing rapid declines as a direct result of
international trade. is list might include Siberian
and Altai marmot, gray wolf, red fox, and corsac fox.
Without the necessary legal structure, and an increase
in funds and personnel to monitor and control this
market, Mongolia’s wildlife managers have been fi ght-
ing an impossible battle. e rapid population declines
documented for several species across Mongolia are the
inevitable result.
Changes in Take
e relaxation of gun ownership laws in 1995 and
increasing supply of cheap ammunition have allowed
far more individuals to harvest wildlife and in larger
quantities than were ever imagined under the socialist
system. In this study, more than 30 percent of all
Mongolian males interviewed (949 of 3,119) claim to
hunt wildlife. Weighted by age class, residency popula-
tion statistics, and respondent residency, an estimated
245,000 Mongolians actively hunt today. is com-
pares to the 25,000 envisioned under the Soviet-style
hunting brigade system. is number translates into
1 out of every 10 citizens hunting, giving Mongolia a
high hunter/non-hunter ratio relative to other coun-
tries (Table C7, p. 143). Almost 96 percent of hunter
Hunter in sou thern Tov aimag hunting Mong olian marmot despit e the current ban. Imag e: J. Wingard
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Mongolia
30
respondents said they own a gun (911 of 949), which
extrapolates to 240,000 gun owners. Offi cial gun
ownership records from the State Police, based on tax
receipts, document only around 30,000 gun owners
nationwide. Over 70,000 people own traps, although
there are no offi cial data on the number and types
of traps owned or used by hunters in Mongolia. e
overwhelming majority of today’s Mongolian hunters
use a rifl e; only 8 percent are trappers.
Hunter age quartiles show that almost half (44
percent) of all hunters are between the ages of 15 and
28, 30 percent are between ages 29 and 42, and 26
percent are 43 and older. Many hunters take multiple
species (36 percent take two or more species, with a
maximum of 12). For the most commonly hunted
species, the number of hunters break down as follows:
a majority of all hunters (61 percent; 139,000) target
Siberian marmots; 40 percent (75,000) hunt gray
wolf; 28 percent (44,000) hunt red fox; 24 percent
(34,000) hunt Mongolian gazelle; 16 percent (29,000)
hunt wild boar; 15 percent (25,000) hunt corsac fox;
12 percent (29,000) hunt roe deer; and 15 percent
(>20,000) harvest fi sh (mostly taimen, lenok, arctic
grayling, and whitefi sh). For the remaining species,
the number of hunters drops off sharply—10 percent
hunt tolai hare; only 5 percent harvest Altai marmots;
4 percent take red squirrel; 2 percent hunt red deer;
less than 2 percent hunt wild ass, ibex, and brown
bear; and less than 1 percent hunt argali. e smaller
number of hunters, however, does not necessarily
mean that their activities and harvests are unimport-
ant —these hunters are often focusing on species that
are already rare or endangered.
Using the estimated number of hunters and a mean
harvest per hunter, we were able to calculate overall
harvest volumes for most species recorded by the
survey. e highest volumes were recorded for Siberian
marmot. Despite a total harvest quota (commercial
and subsistence) of only 100,000 for marmots
in 2004, average harvests were approximately 53
Siberian marmots and 46 Altai marmots per hunter,
with a maximum harvest of 1,000 claimed by one
interviewee. Such large numbers were not included in
our overall estimates of species off take because they
represent outliers. We estimate total marmot harvest
volumes for both species in 2004 at over 3 million.
is compares to an estimated harvest of 1 to 1.5 mil-
lion in 1999 (ESBP 1999). Harvest volumes for other
species were similarly astonishing. Red fox harvests
averaged 4.7 per hunter and totaled more than
185,000 for 2004. Although targeted by fewer hunters,
corsac fox averages were higher than red fox (likely due
to higher market values for skins) at over 10 per hunter
and a total harvest exceeding 200,000. Mongolian
gazelle harvests were 6.5 per hunter, totaling more
than 250,000 on the year. is compares well with
an estimate of 8.3 per hunting family, 150,000 to
200,000 total from a previous WCS gazelle hunting
survey on the Eastern Steppe performed in 2004 (K.
Olson pers. comm.), and an estimate of 4.8 per hunter
from a 1998 study by Reading et al. in the same area.
Red squirrel harvests averaged 27.2 per hunter, with
a maximum of 150 for one hunter and a total harvest
volume of more than 170,000.
Comparing these results to historical trade volumes
for certain species shows that current trade is equal to,
and often orders of magnitude greater than, historic
highs. e highest trade in red fox skins occurred in
1965 at 49,487; average trade volumes by decade never
exceeded 75 percent of the maximum. is survey
estimates that 2004 trade exceeded the historic trade
volume peak by 270 percent. Corsac fox numbers are
similar, with a past maximum trade level of 62,926
recorded in 1947, average trade was close to 50 percent
of the high, and the 2004 estimate was more than 220
percent of the historic upper limit. Mongolian gazelle
harvests peaked at 77,700 in 1962, averaging only 13
percent of the maximum trade volume in 13 years of
recorded trade. Our 2004 estimates show Mongolian
gazelle harvests exceeding 200 percent of the 1962
high. e following table compares historic averages
for each decade from 1926 to 1985 with our harvest
estimates for 2004 for selected species (Figure 3).
is study did not reveal any dramatic changes in
the primary method of take for any species. e rifl e
has been and remains the preferred method for most
mammals and birds, with some trapping of marmots
(roughly 50 percent for M. baibacina but only 14
percent for M. sibirica), muskrat (40 percent), corsac
fox (37 percent), red fox (18 percent), badger (10
percent), wolf (7 percent), and Mongolian gazelle (5
percent). We believe that at least some trapping occurs
for both snow leopards and ground squirrel, but none
of the survey respondents claimed to use this method.
Vehicle ownership (including motorcycles) is likely
having an impact on hunter mobility and therefore
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
31
overall harvest levels, but the results vary depending
on the species analyzed. For example, data analysis
shows only a slightly higher mean take for wolf
hunters that own a vehicle (5.63/hunter/yr) compared
to those not owning a vehicle (4.67/hunter/yr).4
Similarly, red fox hunters owning a vehicle had only
marginally higher harvest levels (7.68/hunter/yr)
than those with no vehicle (6.71/hunter/yr). For
Mongolian gazelle, mean hunter harvests for vehicle
owners was surprisingly lower (5.58/hunter) compared
to non-owners (7.26/hunter/yr). is result probably
refl ects low vehicle ownership rates in the countryside
and the sharing of transportation, rather than a
diff erence in hunting methods. Mongolian gazelle are
typically hunted from a vehicle or from the back of
a motorcycle. For Siberian marmots, mean take was
signifi cantly higher in certain areas (particularly the
eastern steppe region)—62.13/hunter/yr with a vehicle
compared to 42.35/hunter/yr with no vehicle. Vehicle
ownership also appeared to signifi cantly aff ect harvest
levels for corsac fox (15.93/hunter/yr with a vehicle
vs. 10.93/hunter/yr with no vehicle) and brown bear
(10.00/hunter/yr with a vehicle vs. 7.30/hunter/yr with
no vehicle).
Changes in Trade
e opening of the wildlife trade market has translated
Mongolia’s collapse in management into an open
season on all economically important wildlife in the
country. e open and accessible market directly feeds
an increased demand for wildlife products, as well
as an increase in the types and values of the species
traded, both domestically and internationally.
Recorded growth in Mongolia’s international trade
since 1990 has been strong, exceeding $600 million
for the fi rst time in 2003. Wildlife trade has been
a part of this growth, even if the full volume has
never been documented. Not surprisingly, China is
Mongolia’s largest international trading partner for
all types of products and, with its population of 1.2
billion and an average economic growth of more than
8 percent per year, it simply dwarfs the demand and
purchasing power of the former Soviet state. Individu-
Figure 3: Average trade levels for selected species relative to historic peak trade
volumes and compared to 2004 harvest estimates
Source: Mo ngolian Academy of Sci ences, Institute of Bio logy, Historic Trade Record s, and Wildlife Trade Study Su rvey
Results
4 Mean ta ke for wolf in this analysis was derived from hunter
respondents and may not be accurate due to apparently infl ated
estimates given by hunter respondents to the survey.
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Mongolia
32
als queried in this survey indicated that most wildlife
trade goes to China, with limited amounts going to
Russia, Korea, and Japan.
e most visible change in Mongolia’s international
wildlife trade is the increase in the number of species
traded. While still under the political control of the
Soviet Union, trade focused on a limited number of
species (24 species), primarily for fur (17 species);
during and for a short while after World War II, game
meat (4 species); and, with the easing of Sino-Soviet
tensions, a few medicinal products (3 species). Today,
however, Mongolia off ers a larger wildlife menu of
34 species to the international community, including
many that are globally endangered. ese include 14
mammals for the fur trade—red squirrel, American
mink, sable, stone marten (Martes foina), Eurasian ot-
ter, muskrat, Eurasian lynx, ground squirrel, Eurasian
badger, red fox, corsac fox, Siberian marmot, Altai
marmot, and snow leopard. Another three species are
for the medicinal trade—saiga antelope, brown bear,
and musk deer. Two species are primarily for trophy
hunting—argali and Siberian ibex. Red deer and gray
wolf both have multiple trade purposes. Red deer are
sold to international trophy hunters and harvested for
the medicinal properties of their antlers, genitalia, and
tail. Wolf are sold stuff ed as trophies, or their skins
as decoration, and their teeth, ankle bones, and other
parts are important to traditional medicine.
Driving the increase in trade volumes are the never-
before-seen prices paid by traders. Marmot skins sold
to Russia for $0.19 per pelt in the 1980s now sell for
fi fty times as much on the Chinese border. A good
wolf skin can command as much as $250 compared
to just $5 twenty years ago. Red fox skins have gone
from $4 to as much as $18 in the last decade. Corsac
fox has jumped from $1 to $28 per skin. Lenok and
Siberian whitefi sh both sell for as much as $3 per
kilo to markets in China. An average elk shed antler
fetches $18 per kilo, blood antler $70 per kilo, genitals
$30, and tail $30. Musk deer pods sell for as much
as $45 per 100 grams. One brown bear gall bladder
brings $250, the skin $100, and the paws $50 apiece.
A Eurasian lynx skin is $30. Live saker falcons are on
the market for $2,500 per bird. e only species still
selling for relatively low prices are muskrat, which can
be found on the market in Russia and China for only
$1 to $2 a skin, and Pallas’ cat, which sells for $3 at
the market in Mongolia. ese increases are certainly
welcome as the percentage of Mongolians living below
the poverty level has increased since the early 1990s,
growing from 13 percent in 1995 to over 35 percent in
2000.5
With the opening of Mongolia’s once closed borders,
legal and illegal international trade has become
much easier. Along its southern border, arguably the
most important for wildlife trade, Mongolia has 10
seasonal border trade points (open at certain times
each month), most of which are remote and severely
understaff ed. Survey results show that all of these are
important to wildlife trade, with no particular crossing
more important than another. In an eff ort to at least
slow illegal traffi c, the Central Customs Authority
deliberately does not publish opening and closing
schedules for each area. However, this is not enough
to really hinder the organized network of traders
operating on both sides of the border, who simply
use cell phones to alert each other to border openings
(pers. comm. wildlife trader in northern China). To
the north, there are nine permanent stations equally
understaff ed and ill-equipped. e most well-known
and heavily used by traffi ckers is the Khankh station
immediately north of Lake Khuvsgul. Chronic
understaffi ng makes this border point especially
susceptible to illegal traffi cking. Of the 21 offi cial
Roadside s tand in Emeelt Market a dvertising marmot , red fox, corsac fox,
and wolf sk ins despite the ban on mar mot hunting or lack of any l egally
issued quot a for either fox speci es. Image: J. Wingar d, August 2005
5 Figures based on statistics provided by the UN Common Database
at http://globalis.gvu.unu.edu.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
33
border crossings, only two, Zamiin Uud in the south
and Altanbulag in the north, have even marginal
capacity to investigate and control illegal traffi cking.
Wildlife traders in China explained that they can and
do circumnavigate the Zamiin Uud station. Traders to
the north primarily use the Khank station, but other
crossing points also factor into trade fl ow.
Operating alongside international trade is a burgeon-
ing domestic wildlife market. While the age-old barter
system continues, a new economic opportunity has
blossomed for entrepreneurs across the country—pro-
viding wildlife products at a price. Urban city dwellers
(more than half the population) are now able to buy
wild game meat, furs, and medicinal products at
outdoor markets in almost every one of Mongolia’s
329 soum centers, including several markets located in
and near the capital city.
Once relatively rare, several species of fi sh can now be
found at domestic markets, including taimen, river
perch (Perca fl uviatilis), Amur catfi sh (Silurus asotus),
northern pike (Esox lucius), lenok (Brachymystax lenok),
Siberian whitefi sh (Coregonus spp.), Potanin’s osman
(Oreoleuciscus potanini), the (introduced) common
wild carp (Cyprinus carpio), Siberian grayling ( ymal-
lus arcticus), and a species of lamprey (Lethenteron
reissneri). Wild game meat has also become a common
commodity, including black-tailed gazelle, moose,
Mongolian gazelle, wild boar, roe deer, Tibetan hare,
as well as gray wolf and corsac fox meat for medicinal
purposes. Specialty items from certain species can also
be purchased locally, such as argali horns, ibex horns,
moose trophies, brown bear skins, gall bladders, and
paws; as well as trophies, such as snow leopard skins,
Eurasian lynx skins, sable fur, beaver skins, roe deer
skin and blood, Daurian hedgehog live specimens,
and Gobi-Altai mountain vole (Alticola barakshin,
for medicinal purposes). Mongolia’s bird species are
also traded at domestic markets. Altai snowcock and
ptarmigan meat are consumed for their medicinal
properties. In addition, great bustard, black grouse,
and Daurian partridge are sources of game meat.
Other species and products include eagle trophies and
beaks, Northern raven, Dalmatian pelican beaks, and
snowy owl.
Similar to the international market, domestic prices
have steadily increased over the last decade, making
it a lucrative business for many. For example, marmot
meat had a market value of $1.50/kg in 2004, a price
that has doubled since the hunting ban instituted in
2005. Asiatic wild ass had no known market value,
but can now be purchased for $0.80/kg in soum
centers, black markets, and local container shops. Roe
deer blood, corsac fox meat, Yakut moose meat, and
many other local wildlife products are all now for
sale. Taimen fi lets, once unknown in Ulaanbaatar’s
restaurant, now sell for $10.00/plate. For a complete
list of wildlife products and prices compiled during the
survey, see Table C3: Wildlife Product Market Values
by Species, p. 140.
Ranking of Species In Order of Importance to
Take and Trade
e following short tables rank the top 10 species in
order of their importance to six aspects of take and
trade: (1) estimated number of hunters that target the
species; (2) mean annual harvest per hunter; (3) esti-
mated total harvest in 2004; (4) estimated potential
domestic trade value per animal; (5) estimated total
trade value in 2004; and (6) offi cial trophy hunting
permit and license fees. Data have been extracted from
Table C3: Wildlife Product Market Values by Species)
on p. 140, Table C4: Estimate of total number of
hunters weighted by age class) on p. 142, and Table
C8: Estimates of the total number of hunters and
harvests by species) on p. 144.
e core species in Mongolia’s wildlife trade are
those that appear in almost every ranking. ese
include Siberian marmot, gray wolf, corsac fox, red
fox, Mongolian gazelle, roe deer, and red squirrel.
Interestingly, of these species, only one (gray wolf)
also appears in the ranking of domestic trade value per
individual animal (Table 4, but see below). e key
to their ranking as core species is volume. Although
comparatively low in value, these species are all hunted
in large volumes by thousands of hunters across the
country. By comparison, species with the highest
domestic values rarely represent signifi cant income
levels.
In all but two rankings (Table 4, value per animal
and Table 6, trophy value), Siberian marmot is the
lead species—hunted by more people, with the largest
take per hunter, and having the largest trade volume
and total trade value. Closely linked is the Altai
marmot, which is second behind Siberian marmot for
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Mongolia
34
mean annual harvest per hunter. It does not appear
as high in the other rankings because there is only a
small population in the country (in the western Altai
Mountains). It is nonetheless targeted by the market
and may in fact be more at risk because of its smaller
population. Gray wolf also fi gures prominently in
Mongolia’s trade equation because of the high number
of hunters, moderately high market values, and harvest
levels, all combining to make it one of the more
lucrative trade species. From our data, wolf ranked
eighth in mean annual harvest per hunter, estimated
Table 1: Ranking of species by estimated number of hunters that target the species
No.Scienti c Name Common Name Estimated Number of
Hunters in Mongolia
1. Marmota sibirica Siberian marmot 139,000
2. Canis lupus Gray wolf 75,000
3. Vulpes vulpes Red fox 44,000
4. Procapra gutturosa Mongolian gazelle 34,000
5. Capreolus pygargus Roe deer 29,000
6. Vulpes corsac Corsac fox 25,000
7. Sus scrofa Wild boar 20,000
8. Sciurus vulgaris Red squirrel 6,500
9. Cervus elaphus Red deer 5,000
10. Lynx lynx Eurasian lynx 3,000
Table 2: Ranking of species by reported mean annual harvest per hunter
No. Scienti c Name Common Name Mean Annual Harvest
per Hunter
1. Marmota sibirica Siberian marmot 53.66
2. Marmota baibacina Altai marmot 46.8
3. Sciurus vulgaris Red squirrel 27.2
4. Vulpes corsac Corsac fox 10.2
5. Procapra gutturosa Mongolian gazelle 6.5
6. Ondrata zibethicus Muskrat 5.3
7. Vulpes vulpes Red fox 4.7
8. Equus hemionus Asiatic wild ass 4.2
9. Gazella subgutturosa Black-tailed gazelle 3.0
10. Capreolus pygargus Roe deer 2.7
total harvest volume, and estimated total trade value.
However, the harvest levels estimated by hunters in
the survey appear to be substantially higher than the
total estimates for wolf populations in the country and
have therefore not been included in the fi nal estimates.
Corsac fox ranks second in total trade value for reasons
similar to the gray wolf. A high number of hunters
each taking a large number of animals every year are
enough to place it fi fth in overall trade volume and
second in total trade value.
6 Mean annual harvest taken from eastern steppe region. L ower harvest rates were recorded for areas with minimal distribution resulting in an
adjusted nationwide mea n har vest rate of only 23.6 as shown in Table C8.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
35
Table 3: Ranking of species by estimated total harvest volume in 2004
No. Scienti c Name Common Name Estimated Trade Volume
1. Marmota sibirica Siberian marmot 3,000,000
2. Procapra gutturosa Mongolian gazelle 250,000
3. Vulpes corsac Corsac fox 200,000
4. Vulpes vulpes Red fox 185,000
5. Sciurus vulgaris Red squirrel 170,000
6. Capreolus pygargus Roe deer 100,000
7. Marmota baibacina Altai marmot 66,000
8. Sus scrofa Wild boar 30,000
9. Cervus elaphus Red deer 6,000
10. Equus hemionus Asiatic wild ass 4,500
Table 4: Ranking of species by domestic trade value per animal7
No. Scienti c Name Common Name Domestic Market Value
($ )
1. Pelecanus crispus Dalmatian pelican 2,000.00
2. Ursus arctos Brown bear 1,340.00
3. Cervus elaphus Red deer 985.00
4. Alces alces p zenmayeri Yakut moose 900.00
5. Ovis ammon Argali 515.00
6. Alces alces cameloides Ussurian moose 400.00
7. Canis lupus Gray wolf 310.00
8. Equus hemionus Asiatic wild ass 300.00
9. Uncia uncia Snow leopard 272.00
10. Sus scrofa Wild boar 200.00
7 Includes values for all products derived from the species that are not exclusive of other products or uses. For example, red deer values include
the sale of blood antlers, but not mounted trophy. Estimates also include substitute values for meat. For example, S. scrofa did not appear in our
market survey results; however, the meat has value as a substitute for purchasing domestic meat on the market or consuming domestic livestock.
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Mongolia
36
Table 5: Ranking of species by estimated potential total trade value in 2004
No. Scienti c Name Common Name Estimated Trade Value8
($) Primary product
1. Marmota sibirica Siberian marmot 30,000,000 skin
2. Procapra gutturosa Mongolian gazelle 8,500,000 game meat
3. Sus scrofa Wild boar 6,000,000 game meat
4. Vulpes corsac Corsac fox 5,600,000 skin
5. Cervus elaphus Red deer 4,900,000 medicinal
6. Marmota baibacina Altai marmot 4,600,000 skin
7. Capreolus pygargus Roe deer 4,500,000 game meat
8. Vulpes vulpes Red fox 3,500,000 skin
9. Equus hemionus Asiatic wild ass 900,000 game meat
10. Sciurus vulgaris Red squirrel 360,000 skin
8 Values based on market (or substitute) values paid in Mongolia for the primar y product (t ypica lly game meat and/or skin) and do not include
values for trophy hunting. For an explanation of substitute values, see Table C3.
Table 6: Ranking of species by trophy hunting permit and license fees
No. Scienti c Name Common Name Permit and License Fees
($ )
1. Ovis ammon ammon Altai argali 18,000.00
2. Ovis ammon darwini Gobi argali 9,000.00
3. Falco cherrug Saker falcon 4,600.00
4. Capra sibirica Siberian ibex 1,000.00
5. Cervus elaphus Red deer 900.00
6. Alces alces p zenmaryeri Yakut moose 900.00
7. Capreolus pygargus Roe deer 900.00
8. Sus scrofa Wild boar 400.00
9. Canis lupus Gray wolf 400.00
10. Procapra gutturosa Mongolian gazelle 300.00
11. Gazella subgutturosa Black-tailed gazelle 300.00
12. Hucho taimen Taimen 150.00–300.00
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
37
Trade Chains, Markets, and Enforcement
Opportunities
We ident i fi ed fi ve diff erent trade chains active in
Mongolia: (1) hunters to domestic end users; (2)
hunters to domestic markets; (3) hunters to domestic
processors; (4) hunters to cross-border markets; and
(5) hunters to the international trade chain. (Figure 4:
Diagram of Trade Chain Types, p. 40)
Trade Chain 1: e fi rst and shortest chain consists
of individual hunters and anglers supplying wildlife
products directly to end-users. is chain, sometimes
referred to as an informal network, consists of individ-
uals obtaining wildlife products of all types (fur, game
meat, medicinal products) from friends or relatives
who hunt. It is probably the oldest form of wildlife
trade in the country and is still an important part of
trade in several species, including marmot, roe deer,
moose, red deer, most fi sh species, Altai snowcock, etc.
However, the advent of a market economy has added a
new twist to the trade, especially for fi sh where anglers
catch and sell directly to consumers. is chain is the
least susceptible to enforcement: volumes are small
and dispersed, and actual trade occurs in residences
or areas that are impossible to monitor eff ectively. A
second variant of this trade chain, however, occurs at
roadsides and is easily visible to enforcement personnel.
Trade Chain 2: e burgeoning domestic market has
created a second trade chain one step removed from
the fi rst. Instead of supplying consumers
directly, hunters bring wildlife products
that require little or no processing (fi sh,
unprocessed skins, meat, and animal
parts) to small local markets and
restaurants for resale to local consum-
ers. For many, the costs and risks of
transporting goods (often perishable) are
outweighed by the benefi ts of a central
market with ready buyers and consum-
ers. e majority of outdoor markets
surveyed in the wildlife trade study
off er marmot meat. Also common were
Mongolian gazelle, black-tailed gazelle,
wild ass, Altai snowcock, taimen, and
several other species of fi sh. A number
of other species and products make up
the remainder of this market chain,
including eagle owl, brown bear oil and
meat, and marmot oil. is second chain also has an
international component where some products, (such
as furs from wolf, lynx, fox, snow leopard, horns from
ibex and argali) are marketed to international tourists
who then transport them across borders as souvenirs.
Enforcement opportunities are much better with this
degree of trade formalization. Even small markets
have fi xed locations and larger ones are sometimes
staff ed with inspectors responsible for enforcing
trade regulations. However, actual enforcement here
is still relatively weak. With the exception of illicit
trade items such as snow leopard skins or musk deer
pods, traders openly display pelts of all types and
are generally willing to show them on request. Some
traders are even eager to show not only what they have
at the market but stockpiles of skins kept in containers
or at home. e current marmot hunting ban has had
only a limited eff ect on the marketing of marmot at
the Ulaanbaatar train station—anyone interested in
buying marmot can easily locate containers or stalls
with available product.
International transport of illegal wildlife products by
tourists also presents relatively simple enforcement
opportunities. For the most part, tourists are not
traders and are rarely willing to risk trouble at border
points. Appropriate information on trade regulations
and wildlife products at ports of entry (an activity
already sponsored by WWF-Mongolia), in tourist
shops, or other destinations frequented by tourists, will
Young Mongoli an entrepreneurs s elling fi sh o n the Orkhon River. Image : J. Wingard, June
2005.
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Mongolia
38
likely have a positive impact on this type of trade. For
those not deterred, customs authorities are suffi ciently
equipped to monitor this type and volume of trade.
Trade Chain 3: e third trade chain feeds domestic
processors, who in turn sell to local markets for
domestic consumption. is is virtually the only
“value-added” component of any trade chain in opera-
tion in the country. e past several years have seen a
growing number of small fur processors in operation
in Ulaanbaatar who accept wildlife pelts. Processed
furs are sold in tourist shops and at black markets in
Ulaanbaatar to Mongolians and international tourists.
Surprisingly, this chain has also ventured into the
processing and sale of Asiatic wild ass meat (turned
into sausages) despite the species’ status as “rare” under
the Law on Hunting and the prohibition on take or
trade for personal or commercial purposes. is third
chain shares the same fi xed location and international
trade components as the second, and therefore has the
same enforcement opportunities.
Trade Chain 4: e fourth chain consists of indi-
vidual harvesters who sell directly across the border to
markets in Russia and China. ese harvester/traders
may collect from other hunters, but individual
volumes are relatively small and tend to center on
trade of easily concealed medicinal products such as
bear gall bladders, musk deer pods, or red deer blood
antlers. Survey respondents informed us that most
trade goes to China, and surveys completed in shops
along the border confi rm this trade path. Korean and
Japanese traders apparently buy some quantities of
medicinal products; however, their activities appeared
to be restricted to the larger trading centers around
Ulaanbaatar, and their overall presence in survey
responses was minimal. Shop owners in border towns
in China stated that they often buy small quantities of
products directly from Mongolians, with the primary
trade occurring in the fall and winter. While this trade
is diffi cult to track, enforcement opportunities exist on
both sides of the border where Mongolian traders cross
into China with illicit goods. It appears that most,
if not all, of this trade passes through offi cial border
points. Up to now, traders have been able to rely on
the volume of border traffi c and ill-equipped and
complicit customs authorities to escape detection.
Emeelt Mar ket approximately 45 ki lometers to the west of Mo ngolia’s capital cit y, Ul aanbaatar, is a major colle cting point for wildlife products arriving from
the western a imags. Image: J. Win gard, August 2005.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
39
Trade Chain 5: e fi fth type of trade chain, and
the one through which the largest volume of wildlife
passes, consists of both professional and amateur hunt-
ers harvesting wildlife in remote areas and bringing
their products to various collecting or trade points
depending on accessibility. Smaller collection points
will typically transport items to a larger market such
as Ulaanbaatar. It then will be sold to an international
buyer, packaged, and shipped across the border, often
concealed under other goods such as scrap metal.
Once across the border, the products disperse quickly
to processors, markets, and fi nally to the end users,
at which point the product and its origin are virtually
untraceable. Given the diffi culties with patrolling
vast hunting areas or trying to track goods in transit,
enforcement is usually best focused on these trade
markets, collection points, and to the extent they are
used, regular border crossings.
Mongolia has several well-known wildlife trade
markets and many collecting points throughout the
country. Almost every soum center hosts at least one
individual who acts as a collector for others in the
area. Despite the illegal status of most trade, who
this person is and where they are located are not
secret. ree of the largest markets/collection points
are located in and around Ulaanbaatar. e Tsaiz
market is the largest inside city limits. Another three
markets inside Ulaanbaatar’s city limits (Naraan
Tuul, Khuchit Shonkhor, and Kharhorin) play a
lesser role in wildlife trade, for the most part selling
to the domestic market and international tourists.
Another market near Ulaanbaatar’s train station sells
game meat, in particular marmot. Despite the ban,
it continues to operate, albeit in a somewhat more
concealed manner, but certainly taking advantage of
increased prices due to the scarcity of product. Beyond
the Tsaiz market, the next largest markets are outside
the city approximately 45 kilometers, one on the east
side (Nalaikh) and one on the west (Emeelt). ese
two markets serve as major receiving areas for nearly
all wildlife and domestic animal products coming
from eastern and western aimags. In addition to these,
there are well-known markets located in Choibalsan,
Baganuur, Tunkhel, Govi-Altai, Mongonmort, and
Erdensant. Each of these markets represents a major
collecting point from which products travel directly to
the border with some potential for additional transfer
to the Ulaanbaatar markets.
e volumes of wildlife passing through these markets
have been high, but exact amounts are diffi cult to
verify. One trader at the Tsaiz market reported total
sales in 2004 of 500,000–600,000 marmot skins,
50,000 wolf skins, and 50,000 each for red and corsac
fox skins. He also admitted trade in small quantities of
medicinal products without estimating total volumes.
ere is no way to test the validity of these estimates
other than comparison with this study’s harvest
estimates. With the exception of gray wolf trade, all
appear plausible. e numbers of gray wolf pelts may
have been exaggerated, similar to harvest estimates, or
may refl ect trade coming from Russia’s Siberian forest
region and moving through Mongolia. Interviews
with other traders in the Nalaikh and Emeelt markets
outside the city were less productive; enforcement
actions presumably made them less willing to answer
questions. However, traders who did respond reported
selling skins of all types by the thousands.
Wildlife markets and collecting points in Mongolia
are relatively susceptible to enforcement. For the
most part, they are open, easily accessible, and
wildlife products are sometimes openly displayed and
advertised. e exceptions are small, highly valuable
trade items associated with medicinal trade such as
bear gall bladder or musk deer pods, or with illegal fur
trade such as snow leopard skins. is trade is jealously
guarded. Traders of these products tend to be wary
of outsiders and deal principally through established
connections and with known customers. As a result,
attempts to question them about this trade were
generally unsuccessful.
With all forms of trade that cross the border, Mongolia
can and should seek additional international assistance
and cooperation. CITES provides a mechanism for
increased international enforcement by allowing a
country to designate any species of national concern in
Appendix III. Export of the species requires an export
permit from Mongolia’s CITES Management Author-
ity (the Ministry of Nature and Environment) and
would be subject to the harvest levels determined by
the national scientifi c authority (Mongolian Academy
of Sciences). Parties to the convention are on notice
that trade in such species without the appropriate
documentation is illegal. Eff ectively using Appendix
III listings can increase enforcement opportunities for
species that, while banned in Mongolia, are still legally
traded in neighboring countries such as China.
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Mongolia
40
Known and Probable impacts
Wildlife trade is causing severe population
declines. ere is near unanimous agreement among
hunters, traders, and biologists in Mongolia that
continued wildlife trade at the volumes reported is
unsustainable. In the absence of other factors, the
recorded declines appear to be directly linked to trade.
While the causes of decline have been attributed to
several factors—including infrastructure development,
conversion of habitat for agriculture, overgrazing,
competition for forage, and mining—the most
serious and immediate threat is overhunting, most of
it illegal. In Mongolia, infrastructure development
is still limited to a few urban areas where wildlife
conservation is not a concern. e reported increases
in agricultural land uses are an unlikely culprit in
species declines—Mongolia is an arid country with
less than 1 percent of the entire country suitable for
agriculture, most of which is centered in the Selenge
River basin. Even if all appropriate land had been
converted to agricultural production, the increases
would not have aff ected signifi cant percentages of
wildlife habitat for any species occurring in Mongolia
and would not adequately explain the 50 to 90 percent
declines documented for some species. e increase
in livestock over the last 15 years is certainly cause for
concern, but few studies have assessed the degree to
which either overgrazing and competition for forage
are aff ecting wildlife. Two studies report signifi cant
dietary overlap between domestic sheep and goat and
argali (G. Wingard 2005) and Mongolian gazelle
(Campos-Arceizi et al. 2004). While both studies hint
strongly at the potential for competition, neither has
concluded that this would have any signifi cant impact
on wild ungulate numbers.
Meanwhile, Mongolia’s wildlife is being hunted by
the millions. is study estimates that 220,000 to
250,000 Mongolians actively harvest wildlife for
personal consumption, domestic and international
trade. More than 1 million Mongolians use wildlife in
some form. Wildlife trade has skyrocketed in volume
and value, and in 2004 was worth as much as $100
million to the Mongolian economy. Volumes include
over 3 million marmots annually, 250,000 Mongolian
gazelles, 200,000 corsac fox, 185,000 red fox, 170,000
red squirrel, 100,000 roe deer, 30,000 wild boar,
6,000 red deer, 4,500 Siberian ibex, and 3,000 Asiatic
wild ass.
Figure 4: Diagram of Trade Chain Types in Mongolia
Explana tory Note to Figure 4: This fi gure graphic ally represe nts the fi ve tra de chains identifi ed du ring the wildlife tra de
study. The le ft side represent s the starting po int of trade in Mongol ia, with the small gray circ les as the wildlife har vest-
ers. The ri ght side, separated by a b old line, represents t he international trad e elements. Each line co rresponds to the
descripti ons provided in this sec tion. The size of the circ les is intended only to gen erally indicate the volu me of trade
associate d with the type trad e chain depicted.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
41
e associated declines have been rapid and drastic.
Population surveys conducted over the last 30 years
record dramatic declines for a suite of species, all of
them of economic importance. Siberian marmots,
numbering over 40 million in the wild in the 1940s,
had dwindled to only a few million by 2002 (Batbold
2002); as few as 170,000 were reported for the eastern
steppe in 2005, a region that once counted millions
(Townsend and Zahler in press). Red deer were
130,000 strong in 1986. Twenty years later, there are
only 8,000 to 10,000—a 92 percent decline in 18
years. Argali populations were recorded at 60,000 in
1985, but only 15,000 in 2001—a 75 percent decline
in 16 years. Saiga antelope, counted at 2,500 in 1998,
decreased about 50 percent in seven years (WWF
2004, Amgalan pers. comm.). Even the saker falcon,
which in 1999 numbered 3,000 breeding pairs in
Mongolia, had been reduced to 2,000 breeding pairs
by 2004 (Shagdarsuren et al. 2004) (Figure 5).
Anecdotal evidence suggests the same is happening
to other wildlife species for which only limited
population data are available; a trend that, however
unstudied, is fully known by Mongolians across the
country. During the course of this survey, hunters
frequently commented that red squirrels have all but
disappeared from many forests. ey complain that
red and corsac foxes are becoming harder to fi nd.
ey also state that roe deer, brown bear, black-tailed
gazelle, and musk deer are all vanishing. When asked
to characterize the wildlife resource, hunters and
non-hunters expressed concern that unbridled hunting
around the country is emptying the landscape. e
vast majority of respondents (96 percent) believe that
Mongolia’s wildlife resources are fast disappearing,
accurately refl ecting the status of those few species for
which population data are available (Figure 6).
Traditional me dicine at Urumai marke t, China. Image: Dr. Rich ard Reading.
Figure 5: Relative Rates of Decline for Selected Species in Mongolia
Source: Ba tbold 2002; Shagdarsu ren et al. 2004; WW F 2004; Lhagvasure n 2001; D ulamtseren 1970.
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wb silentsteppe text 8-10.indd 41wb silentsteppe text 8-10.indd 41 8/10/06 12:15:31 PM8/10/06 12:15:31 PM
Mongolia
42
ere are two exceptions to this trend in public
perception. e fi rst is the perceived increase in wolf
numbers. However, even here, many Mongolians
recognize that the decreasing wildlife prey base would
result in wolves shifting to livestock, therefore giving
the false impression of increased numbers. In fact,
evidence from off take numbers and research eff orts
suggest that wolves are almost certainly declining
in number. Notably, a recent international study of
wolves in the Gobi ended before it could begin when
researchers discovered that the wolf populations
present in the study area the year before had been
almost completely hunted out (C. Walzer pers. comm.).
Another recent attempt to perform a study on live
wolves in Dornod Aimag had researchers count a
total of 53 wolves killed by hunters during a three-day
period within their study area (K. Olson pers. comm.).
e second exception to the trend in public perception
is the recognition by older respondents that wildlife
resources 30 to 40 years ago were also low due to
overexploitation, had recovered somewhat in the 1970s
and 1980s, only to sink again with the latest onslaught
of hunting. is shifting baseline in public perception
highlights the need for increased public awareness not
only about the current fate of many species, but the
history of trade, its impact on wildlife, and manage-
ment lessons learned.
e rapid decline in wildlife is likely to have
a cascade eff ect across Mongolia’s ecosystems.
“Cascade eff ect” refers to the myriad impacts the
decline or ecological extinction of a species has on
other species that depend on it or share its habitat. e
basic principle is that declining or ecologically extinct
species no longer serve their role in the ecosystem
(even though some may persist) by providing a source
of food and/or shelter, altering vegetation composition,
or serving additional functions that aff ect the survival
of other species. e decline of prey species can lead
to prey switching by predators, for example when
wolves turn from wild prey to livestock. Alternatively,
the loss of larger predators such as wolves can lead to
meso-predator release where smaller predators become
abundant and increase predation, causing declines in a
variety of small prey species.
Cascade eff ects have been documented in several
places around the world. Perhaps most similar to
Mongolia’s current situation with marmots is the loss
of prairie dogs (Rodentia: Cynomys spp.) from over
95 percent of their range in the grasslands of North
America. At least nine other species depend directly
on prairie dogs or their activities to some extent, and
another 137 species are associated opportunistically
(Kotliar et al. 1999). Among other species aff ected,
prairie dog declines caused the ecological and near-
Figure 6: Public Opinion Poll—Status of Wildlife Resources in Mongolia
Source: Re sults of Household Co nsumption Survey, askin g public perception of w ildlife resource over las t 50 years.
N=3,860
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
43
complete extinction of black-footed ferrets (Mustela
nigripes). In another example, wolf reintroductions
in Yellowstone National Park have highlighted the
importance and complexity of cascade eff ects: the rein-
troduction of wolves has aff ected at least 16 vertebrates
in ecologically important ways, including the decrease
in smaller predators (coyotes, Canis latrans), increase in
scavengers, and shifting of elk distribution and habitat
use resulting in changes in vegetation composition (e.g.,
regrowth of riparian willows) and a consequent increase
in the density of songbirds dependent upon this habitat
for nesting (Berger and Smith 2005).
Marmot declines are likely to have similar cascade
eff ects to those documented with prairie dog losses.
Marmots play an important role in the overall structure
and health of the steppe and mountain ecosystems
they inhabit and as such, are likely a “keystone species”
(Puzansky 2004, Zahler et al. 2004). ese subter-
ranean architects burrow into the ground, bringing soil
to the surface, recycling nutrients, and aerating the soil.
eir burrows provide shelter for many native species,
including ground squirrels, pikas, hedgehogs, mustelids,
foxes, and Pallas’ cat (Adiya 2000, Zahler et al. 2004).
eir selective feeding habits aff ect the diversity and
composition of vegetation. ey are also an important
food source for a wide number of raptors and carnivo-
rous mammals, such as eagles, buzzards, wolves, snow
leopards, foxes, steppe polecats, and brown bears.
Given the central role of marmots in defi ning the
landscape, creating shelter for several species of birds
and mammals, and providing a source of protein for
Mongolia’s carnivores, the serious decline in marmot
populations is likely to have an impact on Mongolia’s
biodiversity as a whole. Declines in other species may
also have unexpected cascade eff ects across Mongolia’s
ecosystems.
Rapid wildlife declines are forcing the Mongolian
government to implement crisis management
measures that are often hastily designed reactions
to complex problems, are costly to implement, and
have a low likelihood of success. Today’s harvest lev-
els are similar to or greater than those that prompted
the Mongolian government to ban wildlife harvests
in the 1970s, and are again forcing the government
to adopt crisis management measures. Commercial
hunting of Mongolian gazelle was banned in 2001,
marmot hunting was banned altogether in 2005 for
two years, red deer trophy and subsistence hunting
was banned in 2000, and there has been some thought
given to banning taimen fi shing. Bans have also been
in place since 1995 for all species classifi ed under
Mongolian law as “very rare.” Despite this classifi ca-
An enormo us and now silent marmot co lony in Mongolia’s easter n grasslands. Once fi ll ed with marmots, all th e burrows in this photo are e mpty.
Image: K . Olson
Taimen. Image : Zeb Hogran
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Mongolia
44
tion and associated hunting ban, several species from
this category continue to fi gure prominently in trade
as documented by this study, and include brown bear,
snow leopard, Siberian moose, saiga antelope, and
musk deer. Household hunting of all legally declared
“rare” species is similarly banned. e associated
trade list includes red deer, stone marten, black-tailed
gazelle, wild boar, Siberian ibex, Eurasian lynx, argali,
and Asiatic wild ass.
ere is ample evidence that bans alone will not be
enough. Despite legislative action, hunters continue
to harvest both marmots and gazelle for commercial
trade. e State Border Defense Agency reports
confi scating over 26,000 marmot pelts in only the
fi rst three months of the six months that marmots
are active above ground (marmots hibernate through
the winter). Marmot and gazelle meat are still avail-
able for purchase at local markets without reported
enforcement consequences. Saiga antelope horns,
brown bear gall bladders, musk deer pods, and red
deer antlers, genitalia, and tails from Mongolia are
still sold at shops along the border in China. One
researcher from this project found 13 fresh Mongolian
snow leopard skins in a border town in northwestern
China, at the same time that Russian border guards
confi scated 15 skins coming from Mongolia’s Altai
region. Asiatic wild ass is not only consumed locally,
but is also available as sausages from a meat processor
in Ulaanbaatar. More than 16 percent of all hunters
interviewed hunt at least one wild boar every year.
Black-tailed gazelle, ibex, and argali continue to be
poached by locals for meat. Lynx skins can be easily
purchased in Mongolia’s open-air markets.
To counteract the market that pursues the resource
will require more than one management approach.
To turn the tide in wildlife declines, a strong and
coordinated eff ort will be needed, including the
creation of sound legislation aimed at managing both
hunting and trade; incorporating communities in the
management of the resource; and training, equipping,
and mobilizing enforcement staff within all relevant
agencies, including the State Border Defense Agency,
State Specialized Inspection Agency, the Ministry of
Nature and Environment, and the Central Customs
Authority.
Even under the best of circumstances, policing
Mongolia’s vast open areas would be a diffi cult
undertaking. It is an unthinkable task without
adequately trained, equipped, and mobilized enforce-
ment staff . Presently, the capacity for Mongolia’s law
enforcement staff to control this situation is well below
what is needed. Local departments are understaff ed,
underpaid, and poorly equipped. Almost all protected
areas within Mongolia task individual rangers with
the responsibility of patrolling thousands of square
kilometers, and sometimes expect them to provide fuel
for patrols from their own salary (which can be as low
as $37 a month). Even if a ranger had a vehicle and
dedicated their entire salary to conduct patrols, today’s
fuel costs would limit travel to a little more than 200
kilometers per month; not enough to conduct one full
patrol of a ranger’s average territory. Other government
agencies involved in wildlife law enforcement are
similarly handicapped by a lack of funding, equip-
ment, and training.
However, simply improving enforcement capacity
will have limited eff ect if local communities are not
suffi ciently incorporated into management. With a
total population of only 2.5 million and a territory of
roughly 1.5 million km2, Mongolia is one of the least
populated countries on earth. Enforcement staff , to the
extent they exist, cannot hope to cover these remote
areas without help from the small but important com-
munities that inhabit them. Most important to this
endeavor will be the creation of adequate incentives
for communities to use wildlife resources sustainably,
exercise self-restraint, and assist with enforcement
eff orts. At present, Mongolia’s legal framework
delegates the responsibility of wildlife management
to local government, but provides no basis and off ers
little incentive to community participation.
Without adequate management mechanisms
in place to control trade, the declining trend in
wildlife populations is likely to continue and will
eventually lead to the loss of biodiversity in Mongo-
lia. If Mongolia is unable to launch a serious manage-
ment campaign, the only present hope for preventing
the ecological or complete extinction for some species
is the elusive and uncertain point where it is no longer
economically viable to harvest the species (economic
extinction). However, by then it may be too late to
reverse the decline. Any number of factors may present
obstacles to recovery, including stochastic events such
as hard winters (something for which Mongolia is well
known), limited diversity of the gene pool, fragmented
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
45
or degraded habitat, or even behavioral shifts (e.g.,
Milner-Gulland et al. 2003). Of course, economic
extinction did not prevent the complete extinction
of a number of species. Famous examples include the
passenger pigeon (Ectopistes migratorius) of North
America, perhaps the most numerous bird species that
ever existed, which was hunted in numbers totaling
well over a million a year in the 1870s. e last
survivor died in captivity in 1914. A second example is
the Great Auk (Alca impennis), a 3-foot tall fl ightless
seabird that was hunted to extinction for its feathers,
which were used for mattress and pillow stuffi ng.
Recovering from such drastic declines is further
hampered by the enormous investments required
to bring a species back from the brink. Mongolia is
already familiar with this problem. e Przewalski’s
horse (Equus przewalski) became extinct in Mongolia
in the 1960s. Since 1990, the government and several
international organizations have spent millions of
dollars (and are still spending millions) to ensure their
successful reintroduction (C. Walzer pers. comm.).
Costs include captive breeding programs, reintroduc-
tion programs (transport, holding pens, veterinary
care, staffi ng, etc.), and the subsequent long-term costs
of post-reintroduction monitoring.
Unfortunately, declining wildlife numbers do not
automatically mean decreased wildlife trade for two
reasons. First, as a species decreases in number, it
becomes more valuable. So long as profi ts exceed the
costs of harvesting, there remains a market incentive
to poach. is trend is already seen in Mongolia.
Refl ecting the decreased supply, prices for several
species have been steadily increasing, including prices
for wolf, red and corsac fox, red deer parts, saiga
antelope horns, and marmot skins and meat. To date,
this decrease does not appear to be having a serious
eff ect on wildlife take or trade. Mongolian hunters are
still actively harvesting marmot despite their recorded
disappearance from many areas. e same is true for
virtually all species targeted by hunters. Restaurants
off er taimen despite its special protection under the
law and reportedly decreasing numbers. Musk deer,
brown bear, moose, and others are all still commonly
hunted in the face of reduced numbers.
Second, the productive capacity of the country
(Mongolia’s hunters) does not disappear; instead it
turns its attention to new resources and the develop-
ment of new markets. is happened in the 1960s and
1970s in Mongolia when the hunting brigades, faced
with decreasing wildlife populations, did not quit but
instead expanded the number of targeted species. e
same thing is happening today with hunters apparently
switching to Mongolian gazelle horns to replace the
increasingly scarce supply of saiga antelope. Where
substitute wildlife is not available, imitation products
enter the market. Chinese traders questioned about
the fate of the wildlife trade were generally aware of
decreasing supply but seemed unconcerned, explaining
that they would move to something else if the supply
stopped. is “something else” includes shifting to
the sale of imitation wildlife products. Border towns
in China, already reacting to decreasing supplies, sell
a number of imitation products for all types of wild
animal skins, saiga antelope horns, wolf ankle bones,
ibex trophies, and other parts.
Ultimately, short-term gains from wildlife trade
will be outweighed by long-term losses. In the short
term, local hunters and traders have gained from
wildlife trade. Of the estimated trade value of $100
million, approximately half was garnered by individual
hunters throughout the country. On a per capita
Imitatio n wildlife pelts mad e from dog skins hang ing outside a shop in
Ereen Khot , China. Image: J. Win gard, 2005
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Mongolia
46
basis, this represents average yearly earnings of $200
per hunter—an amount equal to roughly four to fi ve
months salary for rural residents. e rest of the trade
earnings went into the pockets of traders located in
Mongolia’s small and large collection centers, outdoor
markets, and restaurants. is is a substantial sum
considering the limited number of traders in the
country, estimated at not more than 10,000. Per capita
earnings for traders for this level of trade would equal
$5,000/yr, approximately 10 times an average annual
salary for rural residents and almost three times the
annual per capita GDP of $1,800 (2003 est.).
However, at the present rate of consumption those
gains will be short-lived. Harvests over the last decade
have clearly outstripped the capacity of the resource to
sustain itself or potentially recover. Population surveys
and anecdotal information all point to severe declines
for several species and hint at their economic and local,
if not complete, extinction. For example, if consump-
tion rates remain steady, scientists predict the loss of
wild ass in the next ten years (Asiatic Wild Ass Con-
ference 2005). Dwindling brown bear numbers have
already forced at least some portion of the gall bladder
trade to move into Russia in search of a resource. For
wildlife still available in the country, many hunters
asked during the survey explained that they are already
expending greater eff orts to fi nd wildlife. Saiga
antelope may have crossed into economic extinction at
least for organized hunts that target the species. Of the
approximately 800 to 1,500 animals left in the country,
no more than 25 percent of them are male, and an
even smaller percentage are adult males (approximately
10 percent of all males) that sport the sought-after
horns. Using the higher population estimate of 1,500,
the viable market is therefore probably no more than
38 animals. Each saiga antelope horn is worth $30 on
the market in Mongolia (UB Post April 2004),
making each adult saiga male worth just $60. e
total potential market value, if all remaining saiga
males were taken, would be only roughly $2,200; less
if the horns are taken after the animal dies and the
horns lose blood content. Because the animals are
taken using a vehicle (to knock them down without
killing them), saiga hunting has comparatively higher
fuel costs than other forms of hunting. is is espe-
cially true considering the vast territory they inhabit
(2,860 km2) and their relatively small numbers. Such
market equations, however, would not apply to
opportunistic hunting that still occurs.
e loss of species, whether for trade or individual
consumption, will send ripple eff ects throughout the
economy and Mongolia’s culture. On an individual
level, to replace the protein normally obtained from
wild game, herders will be forced to either purchase
meat on the local market or consume their own
livestock. Purchasing meat of course means cash out
of pocket that many people, especially in Mongolia’s
countryside, do not have. Using livestock has even
greater implications, as it will cost both the value
of the animal on the market, as well as the value of
dairy products, wool and/or hair, and other products
(including the production of young) from the animal
during its life.
e depletion of wildlife resources will in turn have
larger implications for the overall economy, which can
probably best be compared to the depletion of a trust
account. e wildlife resources in Mongolia can be
thought of as a trust fund where the principal is made
up of wildlife populations. e principal produces
interest in the form of wildlife production used for
medicine, food, and leather products. Overharvesting
Shop owner i n Ereen Khot, China on th e border with Mongo lia describing
how a Mongol ian blood antler is sl iced into thin wafers and s old as medi-
cine. Image : J. Wingard, July 200 5
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
47
is the equivalent of consuming both the interest and
the principal, so that with each passing year there is
less principal and less interest, until eventually there
is nothing left. From a longer-term perspective, while
present benefi ts from overharvesting may be impres-
sive, they compare poorly with benefi ts that could be
obtained with a lower harvest rate (i.e., consuming
only the interest) over time.
To illustrate the point, consider this highly simplifi ed,
but nonetheless useful, example. Survey estimates
show that a population of wildlife (species X) has
dropped from 40 million to 5 million over a period
of 50 years, likely due to sustained harvests averaging
around 1.5 million per year. Quick calculations tell
us that species X is losing roughly 700,000 animals
each year from the “trust fund” and has experienced
a total decline in “principal” of approximately 87
percent. Looking at the future, it is easy to estimate
that continued harvests of 1.5 million per annum will
result in the full depletion of this wildlife account in
about 3 years. In the end, 53 years of overexploitation
(consuming principal and interest) yields 79.5 million
animals. If each animal has a total market value of $5,
earnings will reach $397 million before the trust has
been fully depleted.
What would be the long-term benefi t of a sustainable
off take, or consuming only the interest earned from
this wildlife trust? To keep this example simple, we
will ignore the complexities of determining a scientifi -
cally based sustainable off take for a given species and
say that in our example the interest from species X
population was roughly 800,000. Consuming only
this for the same 53 years would thus yield 42.4 mil-
lion animals with a value of $212 million. is may
be only half the value obtained from overharvesting,
but after 53 years the entire principal remains intact
allowing, in the absence of other factors, continued
consumption at the same rate. is includes the
potential to meet and exceed earnings realized through
overharvesting, theoretically without limit. In three
years time, when the overharvest strategy described in
the previous paragraph is producing $0 per annum,
the interest-only strategy will still be contributing $4
million to the economy. is scenario can be sketched
for most, if not all, species currently being hunted in
Mongolia.
Given the magnitude of the problem, the costs of
policy neglect are having serious negative impacts
to the present value and future earning potential
of the country. If Mongolia were a company, we
might compare this overharvesting to the strategy of
leveraging profi ts through the sale of assets as opposed
to trade. e basic lesson from this tried and failed
strategy is this: while the “income statement” may look
good today, the future earnings potential dwindles
because the company’s strategy is slowly destroying its
ability to earn. Mongolia’s income from wildlife trade,
even though most of it is unrecorded, has certainly
contributed to the overall economy. At the present rate
of consumption, however, the ability to generate these
rents is disappearing as wildlife populations decline
and, in some instances, disappear. As a business, the
doors will eventually have to close.
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– 49 –
4. Enabling Wildlife Management
Since 1994, Mongolia has actively engaged in
the development of an environmental legal
regime that contains many of the components
necessary to control illegal hunting. A few
critical gaps remain, however, exacerbated by a lack
of funding and capacity to implement and enforce
established mandates.
Institutional Constraints
e single most important institutional constraint is
the lack of any agency at the national or local level
with adequate capacity and full
authority to assume the task of
implementing and enforcing
established mandates.
At the national level, wildlife
management is divided between
the Institute of Biology within the
Academy of Sciences, the Minis-
try of Nature and Environment,
and the Cabinet Ministry. e In-
stitute of Biology is charged with
conducting surveys and making
recommendations for hunting
quotas. is institution employs
nineteen fi eld biologists—eleven
to study the thirty-one mammals,
four to study eighteen birds, and
another four to study ten fi sh
species that we know from this Wolves. Imag e: K. Olson
study (likely it is more) are harvested, some of which
occur throughout Mongolia’s 1.5 million km2. Even
with adequate training, there is simply no physical
way this number of people can cover game species or
the territory, let alone non-game species. Granted, a
number of international organizations and volunteer
students from the Mongolian National University
are actively supporting research eff orts, but the gap
between need and capacity is still daunting.
Unfortunately, adequate capacity within the Institute
would answer only part of the equation as its work
only results in recommendations to the Ministry of
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Mongolia
50
Nature and Environment, which maintains the right
to set fi nal quotas diff erent from those recommended.
e ministry, however, has no personnel with the
expertise to adequately review and make such deci-
sions. In addition, the ministry’s interest in increasing
revenue coupled with the power to make these
decisions presents a clear confl ict of interest that has
led to harvest quotas in excess of those recommended
by the institute. For example, argali trophy quotas
in 2004 were set by the MNE at 80 when biologists
reportedly recommended only 40 (Anonymous pers.
comm.). is decision-making process coupled with a
lack of ministry expertise threatens Mongolia’s ability
to ensure that harvest levels are based on science and
not economics.
e same is true for the institute and ministry’s
relationship to the Cabinet Ministry, which retains
the authority to make decisions for trophy hunting
quotas. is additional step was originally created as
a hedge against the corrupting infl uences of dealing
in lucrative trophy species. However, it does not guard
against approving unsustainably high quotas as the
Cabinet Ministry, like the Ministry of Nature and
Environment, does not have the expertise to review
and make such decisions. At a minimum, this calls
into the question the need for this extra step. More
importantly, it remains a political process legally
disconnected from the scientifi c basis for quota setting.
e research and quota setting procedures are only
the beginning of the problem. e real work of
implementation, monitoring, and enforcement falls to
local governments and institutions. With little to no
training, limited or nonexistent procedural guidelines
or manuals, and little fi nancial support, the central
government expects these local entities to establish
and manage, among others things, hunting reserves
and hunting concessions with private individuals and
companies for industrial hunting. In addition, they
must enforce hunting laws and regulations over vast
territories, conduct surveys, and compile and report
on all baseline data. at they are not equipped to do
this, along with the many other tasks, is a fundamen-
tal constraint to active management.
Economic Constraints
As the previous section demonstrates, wildlife manage-
ment in Mongolia struggles with limited capacity;
that is, professional staff at the local, regional, and
national level with the training and equipment
necessary to accomplish management tasks. But no
recommendations to correct this defi cit will work if
funds are insuffi cient to support these individuals and
their activities. is section takes a detailed look at
Mongolia’s economic realities, in particular the legal
and practical constraints that have conspired to make
adequate fi nancing for wildlife management an elusive
proposition.
First, we should note that over the last ten years,
Mongolia has steadily improved its overall economic
health, a fact that should allow for greater investment
in natural resource management, including wildlife.
Highlights include a more diversifi ed economy, a
steadily increasing GDP with a total volume of $4.87
billion in 2003 and a growth rate of 10.6 percent
in 2004, a per capita GDP of $1,800 in Purchasing
Power Parity (PPP) (2003 est.), relatively low infl ation
rates (4.7 percent in 2003), and expanding trade, which
exceeded $600 million for the fi rst time in 2004.9
e following sections can be summarized as follows:
despite the growing level of economic activity in the
environment sector and the increasing volume of state
revenues derived from natural resource uses, govern-
ment investment in wildlife management remains
woefully inadequate to stem to the tide of unsustain-
able practices. e failure to capture revenue from the
existing wildlife trade further exacerbates the problem.
Wildlife-Related Revenues
Because wildlife uses and trade belong to Mongolia’s
largely unmeasured “black economy” (or informal
sector), their true contribution to the overall economy
appears nowhere in offi cial statistics. However, this
study estimates a volume of roughly $100 million,
making it possibly the third largest contributor to the
Mongolian economy behind mining and tourism.
Trade in metals, primarily copper and gold, dominate
the economy, representing 49 percent of total exports
9 US Department of State, Bureau of East Asian and Pacifi c A ff airs,
June 2005, http://www.state.gov/r/pa/ei/bgn/2779.htm.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
51
in 2003,10 compared to tourism receipts of $159
million,11 $65 million in agricultural exports (Ruzicka
2004) and an informal gold mining sector valued at
more than $70 million per year (Grayson 2004).
Even though signifi cant revenue sources remain
untapped (most of it operating outside the formal
economy), natural resource revenues still represent an
important percentage (6.15 percent) of all government
income—a revenue source that has been increasing
rapidly in recent years. Some of the largest increases
are directly attributable to increased wildlife rents.
Table 7 contains fi gures on state revenues from
natural resources from 1999–2003. Line items 5a
and 5b (highlighted in the table) show the reported
revenues from hunting and saker falcons sales in 2003
as respectively MNT 2.17 and 2.62 billion ($1.9 and
$2.2 million at 2003 exchange rate of MNT 1,169
= $1), or a combined $4.1 million. Compared to all
other resource uses, wildlife trade is the third highest
natural resource earner behind mining licenses and
land fees.
Table 7: State Revenues from Natural Resources 1999-2003
Revenue Source 1999 2000 2001 2002 2003
mil.
MNT %mil.
MNT %mil.
MNT %mil.
MNT %mil.
MNT %
1 Forest 262.8 4.1 460.5 5.2 568.3 4.4 574.3 2.5 629.9 2.6
2Land 1,256.6 19.6 3,224.3 36.8 4,996.4 38.8 6,077.2 26.8 6,077.2 24.7
3 Minerals 3,302.1 51.5 3,431.5 39.2 3,707.5 28.8 11,545.9 51.0 11,545.9 46.9
4 Petroleum 499.6 7.8 469.2 5.3 450.9 3.5 0.0 0.0
5a Hunting 815.7 12.7 9 07.6 10.3 1,975.4 15.3 2,174.3 9.6 2,174.3 8.8
5b Saker Falcon Sales 0.0 0.0 855.7 6.6 1,408.5 6.2 2,620.8 10.7
6 Environment Related Licenses12 0.0 1.4 0.02 17.9 0.1 546.8 2.4 910.3 3.7
6a Water 205.0 3.2 200.9 2.3 231.6 1.8 234.9 1.0 0.0
6b Abundant Minerals13 60.8 0.9 52.3 0.6 89.2 0.7 92.0 0.4 0.0
7 Other 0.0 0.0 0.0 636.8 2.6
Total Natural Resource Revenues (NRR) 6,4 02.6 100 8,747.7 100 12,892.9 100 22,653.90 100 24,595.2 100
Total State Revenues 267,764.0 279,550.0 425,372.0 4 09,383.0 4 00,000.0
NRR as % of Total State Revenu es 2.4 3.13 3.03 5.53 6.15
12 Beginning in 2003, the category “environment related licenses” includes fees for both water and abundant minerals. is change in accounting
practice has led to some discrepancies in fi gures presented for review. e numbers included in this table should therefore be considered
approximations.
13 is categor y refers to construction grade building materials such as sand, rock, mud, etc.
Source: MNE , MOSTEC, Open Govern ment Website.
Budgeting for Wildlife Conservation
While signifi cant revenues are generated by hunting
and saker falcon sales, investment in wildlife manage-
ment remains slim. Four major constraints exist:
(1) the Ministry of Nature and Environment is the
least-funded ministry in the country; (2) no specifi c
budget is allocated for wildlife; (3) the law requiring
investment in the resource simply is not followed; and
(4) the Public Sector Management and Finance Law
nullifi es funding opportunities for local governments.
According to Table 8, the MNE receives the second
smallest budget of all ministries, receiving just 0.74
percent of the total state budget in 2003, ahead only
of the Ministry of Industry and Commerce. However,
this table does not refl ect all funds received and used
by the “self-funding” agencies within this ministry, in
particular the Mineral Resource Authority of Mongo-
10 Offi cia l production worth $137 million in 2003.
11 is fi gure was reported by the Mongolian Tourism Board. e
authors were not able to discern what income sources were included
and suspect that some may be from business visitors and not
“tourists.”
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Mongolia
52
lia. “Self-funding agencies” operate on an undisclosed
budget funded by permits and concessions. Given the
volume of economic activity in the mining sector, it
is a reasonable guess that the actual budget for the
Ministry of Industry and Commerce is higher than
the MNE; making the MNE the least funded of all
ministries. e fact that hunting and saker falcon
receipts exceeded the entire budget for the MNE in
2003 (MNT 4.79 billion from hunting and saker
falcon sales compared to the ministry’s total budget of
MNT 4.29 billion) underscores the potential and the
need to return at least some of these funds to manage
the resource.
Furthermore, recent increases in the Ministry of
Nature and Environment’s budget have had no
real impact on actual funding available for wildlife
(Table 9). Due to changes in accounting procedures
brought on by the Public Sector Management and
Finance Law, it appears that the MNE’s budget has
increased signifi cantly in recent years, going from $2.3
million in 2001 to $3.8 million in 2004 (65.2 percent
increase). But this is a misleading picture. Pursuant to
the fi nance law, the MNE receives a consolidated bud-
get that includes amounts for MNE’s local branches,
such as protected areas, Aimag environment offi ces,
and local hydrometeorological stations. e apparent
increases in the MNE’s budget are due almost entirely
to the inclusion of these local budgets as opposed to
more money for the ministry’s activities.
Within this relatively small budget, the Ministry
of Nature and Environment has even less room for
wildlife management—despite the responsibility to
engage in wildlife conservation and the legal obliga-
tion to earmark 50 percent of hunting-related revenues
for conservation of the resource. A quick review of the
budget breakdowns for 2001–04 (Table 9) shows the
lack of a specifi c budget and, when compared to Table
7, reveals discrepancies between actual and required
expenditures.
Wildlife conservation would technically fi t within line
item #3, Conservation and Rehabilitation Measures,
which was set at MNT 670 million ($568,000) in
2004. From the 2004 budget, 4 percent of this line
item was dedicated to reforestation, leaving MNT
643 million ($545,000) for other resources, including
wildlife, natural plants, land, timber, and water.
However, following the Law on Reinvestment of
Natural Resources Use Fees, the amount allocated in
2004 should look signifi cantly diff erent. Each resource
law (hunting, water, forests, and land) has an accom-
panying act that establishes fees for varying types of
uses based on the “user pays” principle. ese laws are
complimented by a statute requiring the investment
Table 8: Comparative Ministry Budgets 2002–2003
Ministries 2002
(thous. MNT) % of Total 2003
(thous. MNT) % of Total
Ministry of Nature and Environment 4,424,181.50 0.79 4,294,801.20 0.74
Ministry of Industry and Commerce 2,185,187.20 0.39 2,734,677.30 0.47
Ministry of Infrastructure 48,590,207.20 8.62 64,440,209.20 11.07
Ministry of Food and Agriculture 12,001,281.70 2.13 11,091,869.00 1.91
Ministry of Education, Culture, and Science 111,810,630.30 19.84 123,318,963.70 21.18
Ministry of Finance and Economy 158,555,853.80 28.14 125,259,642.70 21.51
Ministry of Justice and Internal A airs 34,915,457.40 6.20 37,158,689.80 6.38
Ministry of Health 62,197,483.40 11.04 62,067,222.50 10.66
Ministry of Defense 18,248,169.90 3.24 17,882,426.90 3.07
Ministry of Foreign A airs 8,202,111.50 1.46 10,612,587.00 1.82
Ministry of Social Security and Labor 102,372,216.90 18.17 123,369,978.60 21.19
Total Budget for all Ministries 563,502,780.80 100.00 582,231,067.90 100.00
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
53
of a percentage of collected fees for conservation of
the resource. (Percentages and categories contained in
Tabl e 10).
Table 10: Conservation Reinvestment Percentages
Type of Natural Resource Fee Percentage
Natural plants 30
Hunting 50
Land fees 30
Timber and fuelwood 85
Water 35
As shown in Table 7, just four of these fi ve resources
(no reported fees generated for natural plant use)
generated MNT 12.4 billion ($10.6 million) in 2003.
Applying the percentages required by the law to the
revenue of each resource would have resulted in the
following reinvestment requirements for 2004:
Hunting—50 percent of MNT 4.8 billion =
MNT 2.4 billion ($2.1 million)
Forests—85 percent of MNT 630 million =
MNT 535 million ($458,000)
Land—30 percent of MNT 6.1 billion = MNT
1.8 billion ($1.6 million)
Water—35 percent of MNT 246 million = MNT
86 million ($73,600)14
e total conservation budget available to the MNE
in 2004 should have been at least MNT 4.8 billion
($4.1 million), a fi gure that exceeds the MNE’s entire
budget for that same year by almost 10 percent. Ap-
proximately half of this should have been dedicated to
wildlife conservation. Even if the entire conservation
budget had been dedicated to wildlife management
in some form, the MNE’s budget shortfall in 2004
for wildlife alone was at least 73 percent. If wildlife
revenues are spread among other budget items, then at
least half of all the MNE’s activities should have been
directed at wildlife management. In fact, they do not
come even close.
Funding for Wildlife Research
Further exacerbating wildlife management is the lack
of any budget in the Ministry of Nature and Environ-
ment for wildlife research. All science and technology
Table 9: Ministry of Nature and Environment Budget 2001–2004
Line Items 2001 Budget
(thous. MNT)
2002 Budget
(thous. MNT)
2003 Budget
(thous. MNT)
2004 Budget
(thous. MNT)
Total MNE Budget 2,754,562 .20 2,784,063. 80 3,817,836.50 4 ,408,076.90
1 Subtotal—MNE Administrative Budget 472,163.70 571,596.4 0 572,775.10 705,448.60
1.8 Nature, Forest and Water Resource Agency 0.00 0.00 28,514.60 52,322.90
1.9 National Watershed Committee 0.00 0.00 6,915.90 7,316.50
2Subtotal—Aimag HMEMA 0.00 0.00 2,405,141.40 2,632,820.90
2.1 Aimag Hydrometeorology O ces 0.00 0.00 1,410,328.00 1,702,009.40
2.2 Aimag Environment O ce 0.00 0.00 482,893.40 452,311.50
2.3 Local Protection Measures and Rehabilitation 0.00 0.00 407,500.00 245,500.00
2.4 Local Budget for Forest Measures 0.00 0.00 104,420.00 233,000.00
3 Conservation and Rehabilitation Measures 910,000.00 1,110,000.00 521,000.00 670,000.00
4 Special Protected Areas 216,098.50 259,067.40 318,920.00 399,807.40
5 Hydrometeorology Integrated Measures 400,000.00 0.00 600,000.00 600,000.00
6 Integrated Environment Measures 0.00 0.00 178,800.00 350,000.00
7 Environment Protection Fund 400,000.00 400,000.00 65,000.00 100,000.00
8 Investment for Environment 356,300.00 21,000.00 65,000.00 0.00
9 Plant Conservation and Rehabilitation Activity 0.00 0.00 35,000.00 0.00
10 Water Resource Conservation Measures 0.00 0.00 45,000.00 0.00
Source: MNE Fi nance Department
14 Water license fees for 2003 are not separately accounted for in
Table 7. e amount shown here was calculated using the relative
percentages of line items 6, 6a, and 6b in 2002 as applied to the
total revenue recorded in line item 6 for 2003.
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Mongolia
54
funds are managed by the Ministry of Science,
Technology, Education and Culture (MOSTEC),
which has budgetary oversight for Mongolia’s forty-fi ve
research institutes and nine research and production
corporations. Of these, 17 belong to the Mongolian
Academy of Sciences—one of which, the Institute of
Biology, has primary responsibility to conduct wildlife
research. Table 11 shows the total budget for science
and technology for the years 2001 to 2003. In 2003,
the Academy of Sciences received a little over $1
million, an increase of 6.3 percent over 2001 levels.
e budget for the Institute of Biology in 2005 was
MNT 108 million ($90,800). Of this, MNT 15.9
million ($13,000) went to the study of mammals;
MNT 9.6 million ($8,000) for ornithology, and MNT
9.8 million ($8,200) for limnology. Compared to
the overall budget for the Academy of Sciences, this
amount is very small at just under 3 percent of the
total. Conversations with biologists at the Institute
of Biology indicate that the budget they do receive is
dedicated almost entirely to salaries, and that they rely
on outside funding for much of their fi eld work.
Funding for Wildlife at the Local Level
e Public Sector Management and Finance Law
adopted in 2002 represents a serious obstacle to fund-
ing wildlife conservation work at the local level, even
though legally local governments still enjoy the returns
on resource use fees such as hunting (PSMF §52.1.1
(2002)). In principle, the new structure is designed to
guarantee the central government’s ability to even out
local budget discrepancies by applying needed funds
to areas that are otherwise unable to generate them on
their own.
In reality, the new law deprives local governments of
funds generated by resource uses in their territory,
leaving conservation work at the local level virtu-
ally unfunded. In brief, the law works like this: the
Hunting Fee Law requires payment of licensing fees to
the soum budget. However, the Public Sector Finance
consolidates all fi nancing into the state central budget
and budgeting practices decrease a soum government’s
allocation by the amount received from hunting fees.
e result is no net gain for the community and no
local money to engage in the management activities
mandated by the Law on Hunting.
As discussed earlier, local budgets for environment are
consolidated within the MNE’s budget. As a matter
of practice, these budgets are only a portion of what is
actually required or what might be mandated by the
reinvestment law. e shortfall must be supplemented
through local natural resource fi nes and fees. In short,
the national government tells the local government
what to do and then gives them only a portion of the
funds necessary to accomplish the task. Compared
to the many urgent funding needs at the local level,
wildlife management receives little, if any, attention.
Table 11: Comparative Research and Development Expenditures 2001–03
Scienti c Field
2001 2002 2003 % Annual
Increase in
MNT
% Annual
Increase
in $
(mil
MNT) ($ tho us.) (mil
MNT)
($
thous.)
(mil
MNT) ($ tho us.)
Natural Science 182.8 165.9 231.5 207.6 286.5 245.1 18.1 16.2
Agriculture Science 491.7 446.2 590.9 530.0 583.0 498.7 7.8 5.3
Mongolian Academy of Sciences 1,011.8 918.1 1,285.7 1,153.1 1,227.4 1,050.0 8.8 6.3
Medical Science 351.2 318.7 390.4 350.1 438.1 374.8 9.9 7.5
Social Science 180.8 164.1 200.5 179.8 165.7 141.7 -4.6 -7.9
Engineering 411.8 373.7 542.8 486.8 613.8 525.1 16.5 14.4
Others 191.4 173.7 279.9 251.0 466.5 399.1 29.5 28.2
Total S&T Budg et 2 ,821.5 2, 560. 3 3,521.7 3 ,158. 5 3,781.0 3 ,234.4 12.7 10 .4
Nominal GDP (mil. USD) 1,028.0 1,119.0 1,200.0
S&T as % of GDP 0.25 0.28 0.27
Source: MOSTEC
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
55
Brief Overview of Wildlife
Take and Trade Laws
Use and conservation of Mongolia’s wildlife are
governed by four primary laws directed separately
at hunting management (Mongolian Law on Hunt-
ing—MLH); the conservation of endangered species
(Mongolian Law on Fauna—MLFa); the payment
of fees for licenses and permits (Mongolian Law on
Hunting Resource Use Payments and on Hunting and
Trapping Authorization Fees—MLHF); and, regula-
tion of domestic procedures for international trade in
endangered species (Law on CITES Implementation).
e purpose of the Mongolian Law on Hunting
is to “regulate the hunting and trapping of game
animals and the use of hunting reserves” and divides
wildlife take into four major categories – industrial,
household, special purpose, and scientifi c. Typical of
all Mongolian resource legislation, the hunting law
delegates primary management responsibility to the
local government while reserving primary control
over the setting of quotas and trophy hunting to the
national government. Critical gaps lie in the defi nition
of hunting types, the fl exibility of the law to react
to a changing resource, the lack of management and
enforcement capacity at the fi eld level, the inadequate
use of economic incentives and disincentives, and the
absence of any basis for local communities to benefi t
from use (or management) of the resource.
e Law on Fauna is Mongolia’s answer to endangered
species legislation. In broad strokes, it calls for the clas-
sifi cation of species as “very rare” or “rare” depending
on generally defi ned criteria to assess the status of the
population. By default, all other species are considered
“abundant” and, if considered a game animal, are the
subjects solely of the Law on Hunting. Unlike endan-
gered species legislation in other countries, however,
the process of listing species under the Mongolian
law is fi xed by parliamentary approval, denying
much-needed fl exibility and perhaps unintentionally
politicizing the process.
e Law on Hunting Resource Use Payments
establishes the rates applicable to obtaining hunting
permits and licenses. First promulgated in 1995, the
law has never been updated and was the subject of
severe criticism at the 2005 International Conference
on Wildlife Trade in Mongolia held during this study.
e primary concerns surrounded the law’s inability to
refl ect market changes, compensate the state for use of
the resource, and provide an economic evaluation that
can act as a true disincentive to illegal activity.
Having joined CITES (Convention on the Interna-
tional Trade in Endangered Species of Wild Flora and
Fauna), the Mongolian government is responsible for
developing appropriate legislation to regulate internal
procedures in compliance with the treaty. Mongolia’s
CITES Implementation law designates the Ministry of
Nature and Environment as the management authority
responsible for issuing export permits and the Mon-
golian Academy of Sciences as the scientifi c authority
responsible for setting quotas for Appendix II species.
However, the dispute resolution provisions of the
law confl ict with the requirement that the scientifi c
authority have ultimate control over quota setting for
permissible trade, eff ectively allowing the Mongolia’s
management authority to exceed quotas and places
Mongolia in violation of CITES requirements.
Recent amendments to the Law on Environmental
Protection grant local communities stronger access
rights to local resources, including wildlife. e new
provisions, however, are still only framework-oriented,
with many details left to further regulation.
Regulation of Wildlife Take
Wildlife take is regulated primarily by three of the
four laws described above—the Law on Hunting,
Law on Fauna, and Law on CITES Implementation.
Together, they rely on six management mechanisms
to limit take. ese include (1) total bans, (2) closed
areas, (3) closed seasons, (4) fi xed quotas, (5) restricted
techniques, and (6) regulation of eff ort.
Notably, these laws do not contain two common
regulatory schemes—(1) sex-based regulations or (2)
size limits—both of which are essential components of
an adaptive hunting management regime. Sex-based
regulations would limit the number of male or female
animals that may be taken by a given hunter and has
the potential to dramatically reduce hunting impacts
on a population. Size limits are often applied in fi shing
regulations, but may be used for other species such
as red deer where antler size can be determined. By
ministerial order, sport fi shing for taimen now comes
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56
with an adjusted price tag based on the size of the fi sh
caught, but there are no set restrictions on how many
of what size can be taken (and no provision made for
catch-and-release).
Total bans are implemented in two ways. First, there
is a total ban on hunting any species classifi ed as “very
rare” under the Law on Fauna. is list includes twelve
mammals, fi ve birds, and four fi sh. Second, total bans
may be declared for any species in decline. Total bans
have been issued recently on this basis for red deer,
Siberian marmot, and Altai marmot.
Closed areas may be implemented through three
mechanisms. First, all of Mongolia’s protected areas
are closed to hunting, with two zones within national
parks open to fi shing for household purposes only.
Second, each local government has the authority to
close hunting within its territory for a period of up to
three years. Finally, the central government has the
authority to close hunting in political subdivisions that
have not conducted “hunting management activities,”
a euphemism for wildlife population surveys. While
the Law on Hunting does not prescribe methodologies
or set survey standards, it does require that assessments
defi ne species distribution, numbers, structures,
reproductive rates, and the available hunting resource.
Such surveys must be conducted once every four
years for the entire territory and every year following
an industrial hunt. With the exception of “industrial
hunting” surveys, hunting surveys are fi nanced from
the central budget.
ere are two critical problems with this last
construct. First, population surveys are required far
too infrequently to eff ectively inform management
decisions. is is especially true when poaching is
rampant and populations are known to be declining.
Using the relative rates of decline for red deer and
marmot in Figure 5, it becomes clear that, even if
the law were followed, population surveys would
have happened only once after the targeted species
had already experienced a 15 to 20 percent decline.
However, one study is just a snapshot and will not
be able to determine a trend. A second study would
occur only after a 30 to 40 percent decline. By this
time, signifi cant damage has already been infl icted on
the population and severe restrictions will probably
be necessary to allow the species to recover. Without
more frequent surveys, the risk is high that important
trends will be missed and management unnecessarily
forced into crisis mode. Second, by requiring surveys
after industrial hunting occurs, the entire point of
conducting a survey is negated. To be of any value,
surveys need to be conducted before the resource is
used to ensure the existence of a viable resource, defi ne
a scientifi cally based quota, and prescribe appropriate
management activities. Industrial hunting in Mongolia
enjoys the lion’s share of the resource and the profi ts.
Requiring surveys before harvesting would be no
greater burden than the law already mandates. It
would, however, ensure that the benefi t of conducting
the survey accrues to the conservation of the resource.
Closed seasons are the same for both industrial and
subsistence hunting and have two notable problems.
First, a lack of precision in naming covered species
leads to confusion in management. For example,
the list of birds specifi cally names only nine species,
but may include as many as thirty depending on the
interpretation. For example, the law refers to “ducks”
and “other wetland birds” without clarifi cation or
limitation. Similarly, the list of fi sh identifi es only four
by name with possibly as many as forty-six included
in an undefi ned catch-all category. In the list of
mammals, this problem is minimal (both marmot
species are listed together). Second, statutorily defi ned
seasons deny wildlife managers the full benefi t of this
mechanism. e ability to change seasons from year to
year is a fundamental component of adaptive hunting
management. Adjusting the length of the season
has the primary purpose of controlling the hunter’s
window of opportunity. Longer seasons typically result
in higher take rates and are used when a population
needs to be reduced. Shorter seasons reduce take and
can be useful in limiting the impact on a declining
species. In either case, seasons are usually reviewed
on an annual basis to assess the impact on wildlife
population levels and the ability of the management
regime to meet defi ned population management goals.
However, because Mongolia defi nes hunting seasons
directly in the legislation, they have only been changed
once by an act of parliament since the hunting law
was fi rst written in 1995. Without changing this
procedure, it will remain impossible for Mongolia to
make eff ective use of this tool and react in a timely
manner to changing resources.
Fixed quotas also restrict the number of animals that
may be harvested and can substitute for a total ban.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
57
Unchanged from Mongolia’s socialist era, quotas
are established top-down. For “abundant” species,
the Ministry of Nature and Environment sets limits
pursuant to recommendations from the Academy of
Sciences and issues these to aimag governments, who
then set limits for each soum administration. For
“rare” species, the ultimate decision rests with the
Cabinet Ministry and permits are issued directly by
the Ministry of Nature and Environment. e law
does not defi ne how or on what basis quotas must
be established for either set of species. However, this
point is essentially moot, as budget constraints have
meant only a few surveys over the past 20 years for a
handful of species and none for the majority of them.
Without wildlife surveys to inform the decision-mak-
ing process, quota setting since 1990 for virtually all
species has been either guesswork or based on old and
probably no-longer-relevant data. Moreover, until this
study, the degree of illegal hunting in the country
had never been adequately studied and is still not
refl ected in hunting quotas. Although not explicitly
stated in the law, the lack of a quota is eff ectively the
same as a hunting ban. In practice and for many years,
local governments have sold permits with or without
quotas and regularly exceed them without apparent
repercussions. For example, an assessment of marmot
permit sales in 2002 showed that the average license
exceeded the per person maximum 18 times (Scharf
and Enkhbold 2002).
Similar to most hunting laws around the world,
the Mongolian Law on Hunting prohibits various
techniques that are likely to result in higher harvest
levels. Among them is the use of automatic weapons,
pursuing animals by vehicle, destroying nests or
dens, and the use of pits, triggered guns, fi shing
nets, chemicals, explosives, or other indiscriminate
techniques. Reality is of course diff erent from the
letter of the law. Vehicles are regularly used to pursue
animals. A special case is the saiga antelope, where
vehicles are not only used for pursuit, but to knock the
animal down allowing the taking of the horns while
it is still alive. Asiatic wild ass is taken using shotguns
fi red from close range out of a jeep window while
chasing the animal. Chasing down wolves in jeeps on
the wide-open steppe is a common sport. Weapons
of all types are used, including automatic rifl es. Nets
are frequently used by subsistence and commercial
fi shermen despite restrictions. In their legal construc-
tion, these restrictions are straightforward. Only the
lack of enforcement capacity prevents the law’s full
implementation.
Asiatic wi ld ass, or khulan. Ima ge: C. Walzer
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Mongolia
58
Regulation of eff ort, although included in the hunting
law, is limited to hunting for household purposes.
It certainly has value and application for all types
of hunting and should be expanded. is type of
legislation limits the amount of time that may be spent
in a given area for hunting. e premise is that scarce
resources mean greater eff ort (i.e., more days spent
hunting) must be expended to reach quotas. Limiting
level of eff ort can therefore automatically limit the
number of animals harvested and serves to react to
changing population levels not predictable in advance
of the season. Typically this type of provision is
much more diffi cult to enforce than hunting seasons,
which can serve the same purpose. Level of eff ort is
in essence a “season” personal to the hunter and can
only be enforced if there is an adequate method for
monitoring individual activities. With trophy hunting,
there may be easily implemented methods. Monitoring
individual subsistence hunters across Mongolia’s vast
landscape is probably impossible and, as our study
shows, the concept is completely ignored by local
hunters.
Overall, the management mechanisms described in
this section are widely ignored. As this study docu-
ments, many species are harvested in contravention
of permanent or temporary bans, actual numbers of
animals taken per year exceed authorized quotas by
orders of magnitude, and techniques are used in areas
and during seasons that are prohibited by law.
Regulation of Wildlife Trade
Regulation of wildlife trade is limited to a few short
provisions in the Law on Hunting and one ministerial
resolution requiring “certifi cates of origin” for trade
in wildlife parts. As originally drafted, the MLH only
focused on the actual hunting and not the subsequent
use, possession, or sale of the animal. In other words,
once an animal or part entered the wildlife trade
chain, enforcement was impossible. In 2002, the
Mongolian Parliament amended the law to require
certifi cates of origin for the sale of wildlife products.
e Ministry of Nature and Environment later
approved a resolution allowing the use of specialized
tags for this purpose. e system was implemented
in 2003 with positive results reported by the State
Specialized Inspection Agency. is simple mechanism
enables enforcement personnel to inspect not only in
hunting areas, but also market places and transporta-
tion routes.
Another vital gap in the regulation of trade is the
inadequate defi nition and regulation of commercial
hunting. e MLH does not regulate “commercial”
hunting per se, restricting its focus to “industrial
hunting” – a narrow area of commercial use applicable
to registered companies that harvest animals in large
quantities for a given market. All environmental laws
assume a greater level of responsibility for companies
and levy signifi cantly higher fi nes for violating the law.
Commercial hunting of wildlife, however, occurs in
many forms and is not restricted to organized com-
panies. Even so, individuals engaged in commercial
exploitation of wildlife are treated more leniently by
the law and typically risk only 10 percent of the fi nes
applied to registered companies. For example, the same
off ense under the hunting law subjects a company to a
fi ne of $250, but for an individual the fi ne is only $25.
is myopic legal view is mirrored by industrial
hunting quotas that do not yet adequately consider the
full impact on target species of all harvests (legal and
illegal) whether for commercial ventures or personal
consumption.
CITES Regulation
In April 1996, Mongolia became the 133rd signatory
(April 1996) to the Convention on International
Trade in Endangered Species of Wild Fauna and Flora
(CITES). Of those faunal species on the national lists,
seven species are designated as “very rare” and two are
designated as “rare.” Five abundant species are found
in CITES Appendix I,15 while another 47 abundant
species are on Appendix II.16
15 CITES Appendix I includes species threatened with extinction and
that are or may be aff ected by international commercial trade. ese
species may not be traded internationally for primarily commercial
purposes. ey may be exported and imported for non-commercial
purposes.
16 CITES Appendix II includes species that, although not necessarily
threatened with extinction, may become so unless trade is strictly
regulated in order to avoid utilization incompatible with their
survival. Species also may be listed on Appendix II if their parts or
products cannot be readily distinguished from those of other species
listed on CITES Appendix I or II. International commercial trade in
Appendix II species is allowed, but is strictly controlled. Parties may
only grant a permit to export such species after it has determined that
the export will not be detrimental to the survival of the species.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
59
Until 2002, the Management Authority was headed
by the Director General of the Environmental Protec-
tion Agency. e Management Authority has eight
members, including international trade and customs
offi cers of the Ministry of Agriculture and Industry.
e scientifi c authority of the CITES is headed by the
Vice Minister of the MNE and consists of six scientists
from the Mongolian Academy of Science’s Institute
of Biology and Institute of Geo-Ecology, and the
Mongolian National University.
ere is some discrepancy in export fi gures for
Mongolia’s CITES-regulated species reported in
diff erent documents. To create the following table, we
relied primarily on the UNEP-WCMC CITES Trade
Database and cross-referenced other sources as stated
below. e table shows only those species for which
export records are available.
Mongolia’s membership in CITES could help with
conservation and management, in particular with the
trade in falcons. Mongolia has 10 species of falcons
that are listed in Appendix II of the convention, of
which the saker falcon is the prime target species.
Seven cases of illegal saker falcon exports have been
revealed and a total of 43 falcons released from captiv-
ity. One foreign citizen managed to take four falcons
without an export certifi cate but fortunately was
arrested in Singapore. An additional two foreigners
attempted to take twelve saker falcons out of Mongolia
by car; they were caught by Tuvan Customs offi cials in
Russia. e threat for continuing illegal exportation is
real, as is the value of cooperation with parties to the
Convention.
Mongolia’s CITES implementation regulation,
however, is in contravention of the Convention.
CITES specifi cally requires that trade quotas for
Appendix II species must be decided independently by
the country’s scientifi c authority. However, Mongolia’s
management authority, the Ministry of Nature and
Environment, has reserved to itself the authority to
resolve disputes concerning trade quotas, and exceed
them if it deems necessary. In so doing, the regulation
usurps the authority of the scientifi c authority and
violates the terms of the convention. During the
course of the wildlife trade study, Academy of Science
biologists and hunting companies both complained
that quotas in recent years have been almost double
recommended levels.
In addition, Mongolia has yet to take advantage of the
benefi ts available under Appendix III of the Conven-
tion. is appendix allows a member state to list a
species of national concern and places other countries
on notice of its restricted trade status. As with trade
in Appendix II species, export permits are required
and, although the treaty does not govern domestic
trade or laws, member countries must observe CITES
trade restrictions when participating in international
trade of listed species. Appendix III listings would
be appropriate for a number of species listed in the
Mongolian Law on Fauna as “very rare” or “rare”
but which otherwise have no status in CITES. ese
Table 12: Mongolian CITES Exports for Selected Species 1996–2004
Species 1996 1997 1998 1999 2000 2001 2002 2003 2004
Argali trophies 23 44 2 13 44 44 69 67 68
Brown Bear 1 1 — — — 1 3
Gray wolf 526 111 16 15 60 69 164 87 136
Snow Leopard — — — 8 — — —
Pallas’ Cat 4 — — — 18 31 6 3 2
Lynx 1 41 55 1 — — —
Saker Falcon 25 154 25 61 50 187 303 400 385
Cinereous vulture 149 35 5 — —
17 is fi gures includes 28 trophies and 16 skulls. In 1998, the GOM prohibited the export of skulls.
Sources: CI TES Tr ade Database at ww w.c ites.org; Mongol ian CITES report ; Cabinet Ministr y Orders for trophy hunt ing licenses; D. Shijirma a, 2nd Symposium:
Journal of Su stainable Use, 200 0; Ministry of Nat ure and Environment, CIT ES Management Authori ty.
17
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Mongolia
60
include Siberian ibex, Ussurian and Yakut moose,
black-tailed gazelle, wild boar, Daurian hedgehog,
Altai snowcock, and taimen. Appendix III might also
be used to control trade in species experiencing rapid
declines as a direct result of international trade. is
list might include Siberian and Altai marmot, gray
wolf, red fox, and corsac fox.
Regulation of Trophy Hunting
Trophy hunting falls under the category of “special
purpose” hunting under Mongolian law. Special
purposes hunting also includes the take of species
for scientifi c research and cultural purposes. Trophy
hunting represents a signifi cant opportunity for
wildlife management in Mongolia. Eff ective manage-
ment of this market has the potential to support
wildlife management for the target species and other
wildlife species as well. Mongolia is lucky enough to
be home to several trophy animals, including ibex,
wild boar, Siberian red deer, brown bear, Yakut moose,
Siberian roe deer, the largest salmonid in the world
(Hucho taimen), and the largest mountain sheep in the
world—the Altai argali. Ostensibly as a hedge against
corruption, trophy hunting decisions are consolidated
at the Cabinet Ministry level.
Defi cits in the trophy hunting system stem from three
primary sources—a lack of defi ned management for
targeted species; inadequate funding to conduct re-
search, monitoring, and enforcement activities; and no
local community support. Even though the Ministry
of Nature and Environment has established trophy
hunting permit fees for almost all trophy species (and
some that are not, e.g., corsac fox), there are still no
management plans for any of these species. Price tags
vary from as much $25,000 to $100 with annual state
revenues exceeding $2 million. Despite these actual
and potential revenues, purported budget constraints
still prevent the timely implementation of adequate
population surveys to inform decision makers. Finally,
despite laws for investment of trophy hunting fees back
into conservation of the resource, current practices
deny local communities and conservation eff orts the
legal benefi t of revenues (Amgalanbaatar et al. 2002,
Wingard and Erdene-Ochir 2004). As a result, some
local offi cials are working to eliminate trophy hunting
from their territories (Amgalanbaatar et al. 2002).
Prior to the consolidation of all government fi nancing
in 2002, fees paid by trophy hunters fl owed in three
directions—the central budget, the soum budget,
and the Environmental Protection Fund. Pursuant to
the Mongolian Law on Hunting Fees, the reserve use
fee was set at 60 to 70 percent of the trophy animal’s
current market value, and
the license fee was equal to
20 to 30 percent of its value.
According to the hunting
fee law, 10 percent of reserve
use fees were supposed to
fl ow into the Environmental
Protection Fund. In
2000, this percentage was
increased to 50 percent
pursuant to a new law on
the reinvestment of natural
resource use fees for conser-
vation purposes. Sums paid
in excess of government fees
go to the hunting company
that conducts the hunt.
Because of the lucrative
potential, the number of
licensed argali hunting
companies in Mongolia has
Argali ram . Image: Dr. Richard Read ing
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
61
increased at least 14-fold since 1993.18 Many of these
companies have no experience operating hunts (e.g.,
only 12 of the 70 argali licenses distributed in 2002
were given to companies that hunted previously) and
others acquire licenses simply as a speculative venture,
reselling them to more experienced companies for a
quick profi t (Anonymous 2002, Kherlen 2002). is
activity highlights the need to include restrictions
on the transferability of trophy hunting licenses and
criteria for selecting professional hunting companies.
It also calls attention to the need to reassess license-fee
levels to remove this economic margin.
Local opposition to trophy hunting is occurring,
especially in areas where trophy hunting has historically
occurred. Opposition stems from concerns over the
impacts of trophy hunting on local wildlife populations
and the lack of any fi nancial incentives to the soum
government. e problems are multiple but can be sum-
marized as (1) little to no fi nancial benefi t to the local
community, (2) illicit activities by established hunting
companies (e.g., driving game from protected areas in
order to hunt them), and (3) budget practices that deny
local communities the benefi t of the resource use.
Regulation of Status and Conservation
Measures
As of 2004, Mongolia has one law dedicated solely to
the conservation of rare and endangered fauna. Similar
to its predecessor law, the Law on Fauna contains the
list of “very rare” species and provides for a second
list of “rare” species to be set by the Cabinet Ministry.
By default, the remaining species are considered
abundant. As a result, lists of “very rare” and “rare”
species are locked in when a more fl exible, science-
based approach is needed. ere are no legally defi ned
procedures or guidelines for the scientifi c determina-
tion of a given species’ status. Ultimately, the decision
to list a species rests with the Mongolian Parliament,
substituting a political decision for what should be a
science-based one.
e Law on Fauna has a relatively strong focus on
the use of fauna, to some extent separate from hunt-
ing, and specifi cally requires habitat conservation.
However, the law contains precious little direction on
how conservation objectives are to be achieved, citing
only that activities shall not adversely aff ect habitat or
otherwise cause damage to the species. Local admin-
istrations are once again responsible for fi nancing
implementation of the legislation, but lack the skills
and funding necessary to make this scheme a reality.
Community-Based Wildlife Management
Community-based natural resource management
(CBNRM) is an evolving and fl exible concept based
on the premise that local people directly dependent on
a given resource are critical to its adequate and long-
term management. CBNRM initiatives seek to defi ne
processes and mechanisms that enable communities
to participate as a group in both the management
of the resource and the benefi ts it provides. Because
the concepts of “participation” and “community” are
highly culture-, place-, and resource-specifi c, there can
be no single recipe for success.
However, increasing experience with designing and
implementing community-based natural resource
programs has helped to refi ne our understanding. e
broad categories include (a) meaningful participation
in policy formulation and decision making; (b)
appropriately defi ned community organizational
structures, internal processes, and rights; (c) compre-
hensive and secure community resource access rights;
(d) responsive institutional structures and planning
requirements; (e) promotion of sustainable resource
uses; and (f) effi cient and fair enforcement of rights
and dispute resolution both internally (within the
organization) and externally (outsiders— private and
government).
Local people directly and indirectly depend on
Mongolia’s wildlife resources and will be critical to
the success of any wildlife management/conservation
program. Recognizing this need, the Mongolian
government has already started to formulate policies
and laws that simultaneously enable communities
to engage in conservation and allow them a stake
in Mongolia’s resource base. Until the fall of 2005,
proposals remained focused on forestry, but with
the adoption of certain amendments to the Law on
Environmental Protection, the concept has been
18 While only 3 companies received argali trophy licenses in 1993, 25
companies applied for and 18 received licenses in 1999. In 2002, 43
companies received licenses out of 112 applicants (K herlen 2002).
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Mongolia
62
expanded to include other resources. Unfortunately,
there are still only a small number of Mongolian legal
specialists involved in eff orts to promote sustainable
community-based natural resource management,
and no institution is yet fully committed to it on the
national level.
At present, Mongolia’s communities have the right to
form local organizations and gain access to resources,
but additional regulatory work will be required to
complete the process. e three most critical issues are:
First, community groups need recognition as a
legal entity. Pursuant to the amendments on the
Law on Environmental Protection and Civil Code
§481, community-based organizations (Nokhrolol)
are intended to be ‘unregistered’ bodies. Without
registration, Nokhorlol will not have the status of
a legal entity under Mongolian law. is presents
numerous impediments to such organizations’ ability
to actually benefi t from the use of any resources other
than for personal consumption. Among them are the
inability to open a bank account, own property jointly,
enter into contracts, obtain insurance, or conduct any
transactions with third parties as an organization.
is will force them to operate as individuals and
thereby increase the risk that the group’s eff orts will
be “hijacked” by individual members and result in
disputes both internally and externally for which there
is only limited judicial remedy. A simple example
would be the sale of community property by one
member to a third party who has no knowledge and
no way of knowing of the property’s “joint” owner-
ship. Without notice, the third party cannot be held
liable for any breach of contract or law, leaving the
remaining members with recourse solely against the
member who sold the property. Where the property in
question is unique or where the value is otherwise not
recoverable from the member in breach, such a remedy
would be inadequate.
Second, Mongolia still needs to develop a full
framework for community participation that ensures
adequate and timely access to information, admittance
to government meetings, and full participation in
policy formulation and decision making. ey may
have some of these rights now but it is in name only,
not in practice.
ird, legal access to resources needs to be coupled
with suffi cient security in the right. e granting of
access rights has not yet been coupled with the right to
exclude other, possibly confl icting uses, such as grazing
or mining. Of all land tenure rights currently avail-
able, only mining and petroleum concessions enjoy
real tenure security.
Enabling Enforcement
Arguably, law enforcement is the single most critical
factor in controlling the unsustainable and illegal
hunting that is causing dramatic declines in Mongo-
lia’s wildlife. Presently, the capacity for Mongolia’s law
enforcement staff to control this situation is well below
what is needed. Local departments are understaff ed,
underpaid, and poorly equipped. Many protected areas
within Mongolia make individual rangers responsible
for thousands of square kilometers, and require them
to provide fuel for patrols from their own salary
(which can be as low as $37 a month). Assuming a
ranger had a vehicle, at today’s fuel costs, if a ranger
dedicated their entire salary to conduct patrols, they
would be able to travel little more than 200 kilometers
per month. Other government agencies involved in
wildlife law enforcement are similarly handicapped
by a lack of funding and equipment. Enforcement
issues also encompass international trade, and border
patrol and airport personnel are similarly ineff ective in
controlling cross-border trade in wildlife species.
Better law enforcement will require adequate recruit-
ment, training, and provisioning of offi cers. is, in
turn, will require additional fi nancial investment,
which we believe exists if a portion of the income
generated by current, legal wildlife exploitation were
provided for this purpose. For example, hundreds
of thousands of US dollars are generated by argali
trophy hunting alone each year, yet almost none of this
money helps pay for wildlife law enforcement, despite
laws written to help ensure this happens. e proceeds
of a single argali hunt could fund an annual confer-
ence on wildlife management to coordinate argali
(or even all wildlife management) activities around
the country. Saker falcon receipts alone are almost
half the entire budget of the Ministry of Nature and
Environment, 10 percent of which would be adequate
to fully equip, train, and mobilize anti-poaching units
throughout the country. Charging small license fees
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
63
for Mongolian hunters (e.g., marmot hunters) also has
the potential to generate signifi cant income for wildlife
management in Mongolia. Obviously, some money
generated by wildlife exploitation must also go to
support wildlife monitoring and research, the results
of which would form the foundation for credible and
sustainable wildlife management in the nation.
Another signifi cant gap, common to many of
Mongolia’s environmental laws, is the lack of adequate
disincentives (fi nes and penalties) to poaching. e
primary justifi cation for the application of fi nes is
twofold: (1) to deter the targeted behavior, and (2)
compensate for damage caused. Mongolia’s civil
penalties for violating hunting legislation do neither.
One of the problems is the fi xed status of penalties in
the law. As a matter of legislative drafting, all fi nes are
specifi ed in the organic legislation (ten years ago for
most laws) with no provision for infl ation-indexing or
regulatory mechanism to adjust fi ne levels. e result
is a signifi cant reduction in disincentive and compen-
sative values. While amendments to some laws increase
these fi ne levels, they remain fi xed for long periods and
therefore incapable of following market trends.
Even if the fi nes had been infl ation-indexed, initial
values were still insuffi cient to compensate for damages
caused. e Hunting Law contains the most compli-
cated set of administrative penalties, but still fails to
establish adequate disincentives. Even though many
targeted species have appreciable value, the hunting
law applies fi nes as little as 1,000 Mongolian tugrugs
(< $1) for certain forms of poaching. e majority of
fi nes would cost the violator $10 to $20 (not including
poaching rare animals for which criminal charges
apply19).
In addition, applicable fi nes range widely for any given
violation. While the upper-end fi nes might have some
eff ect, the lower end of the range is so small as to be
meaningless. Even in a cash-poor environment, the
deterrent eff ect of a $10 fi ne for poaching a brown
bear (worth as much as $1,300 on the black market)
is questionable at best. Moreover, none of the laws
provide direction on when to apply a higher fi ne,
leaving this entirely up to the discretion of the inspec-
tor or ranger.
Another aspect worth reconsidering is the application
of diff erent fi nes depending on the status of the
violator as a private citizen, economic entity, or public
offi cial. A number of fi nes address illegal market
activity and yet still distinguish between private
citizens and companies. Regardless of the individual’s
employment status, income generation is the primary
function of the activity and fi nes should refl ect this
practical reality.
19 e L aw on Fauna sets fort h a list of “rare” animals that may not
be hunted except for certain purposes. is list is separate from t he
concept of “huntable” rare animals referenced in the hunting law,
such as argali. Poaching from the fi rst category may carry a fi ne of
MNT 20,000 to 50,000(< $20-50 ), while hunting from the second
category carries criminal penalties.
Commercial g azelle hunter proudly d isplaying his catch. Photo t aken in
1999. Since then, the M ongolian governmen t has banned commercial hu nt-
ing of gazel le. Image: Henry M ix/Nature Conser vation Internationa l.
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– 65 –
5. Recommendations for
Priority Actions
In 1991, Mongolia’s new constitution declared
wildlife to be the property of the government, a
common resource for the Mongolian people. e
constitution, with the best intentions, was meant
to lay the foundation for a new form of environmental
management headed by the Ministry of Nature and
Environment; but this severely underfunded and
understaff ed ministry has struggled to establish itself,
leaving a management vacuum that remains mostly
open. In practice, Mongolia’s wildlife still belongs
to no one. Established in 1989, the Ministry of
Nature and Environment has never created an agency
dedicated to wildlife management. Instead, Mongolia’s
wildlife-related laws delegate managing authority to
local governments that do not have the training or
funding to implement eff ective management. With no
one watching (fi guratively and literally), hunters across
the country have fi lled the void, staking their claim
to ever increasing numbers of animals to off set low
incomes, supplement livestock, or simply as a hobby.
Traders in neighboring countries, especially China,
have been the happy recipients of this new stream of
wildlife product, consuming millions of animals every
year and generating enormous profi ts.
To discuss management options, the project held a
stakeholder Workshop on Mongolian Wildlife Trade
in Ulaanbaatar on August 17–19, 2005. Over 120
people attended the three-day event, including staff
from four ministries representing wildlife enforcement
and management bodies in Mongolia, interested
national and international nongovernmental organiza-
tions, hunting and tourism company representatives,
resource specialists, and international experts. Beyond
presentation of results, the conference provided input
from biologists and management specialists for the
participants to consider. Conference discussions
focused on fi ve management areas: international trade,
domestic trade, hunting management and enforce-
ment, trophy and sport hunting, and community-
based approaches.
A major output from this workshop was the agreement
that wildlife trade is having serious impacts not only
on endangered species, but on several other species
that occur in Mongolia; and that immediate, compre-
hensive measures are necessary to stop uncontrolled
trade and prevent the potentially permanent loss of
biodiversity. Conference attendees cited numerous
gaps and confl icts in law, management structures,
implementation practices, and enforcement capacity
that have all allowed the overuse of Mongolia’s wildlife
resources for more than a decade. Among them are:
1) e lack of any legislation directed specifi cally at
wildlife trade.
2) Off take levels that are not scientifi cally based.
3) Inadequate training and capacity to enforce
existing hunting and trade restrictions.
4) Inadequate use of economic incentives and
disincentives in relative legislation.
5) A failure to capture revenue from the system for
the benefi t of the resource.
6) A lack of incentive and legal basis for eff ective
community participation.
7) A lack of systematic knowledge on hunting and
wildlife resources.
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Mongolia
66
8) A lack of inter-agency cooperation and sharing of
enforcement data.
9) Corruption at all management levels.
Supplementing these main themes, working groups
at the conference off ered several cross-cutting and
sector-based recommendations, which are outlined
in this section. To the extent possible, recommenda-
tions have been prioritized, and they reference likely
implementation authorities. Ultimately, responsibility
for implementation rests with the Mongolian govern-
ment and its people. However, central to eff ective trade
management will be the following:
1) Mongolian Academy of Sciences—to set
scientifi cally based, sustainable off take levels for
all targeted species and to regularly and accurately
monitor populations.
2) Ministry of Nature and Environment—to take a
lead role in designing needed legislation, proce-
dural mechanisms, and enforcement protocols for
both national and local management actions.
3) State Specialized Inspection Agency—to shoulder
primary enforcement responsibility and coordi-
nate overlapping tasks with other key authorities.
4) State Border Defense Agency—to engage in
monitoring and enforcement of cross-border trade
around the country.
5) Mongolia Central Customs Authority—to
develop new methods of detecting trade and
establish eff ective cross-border cooperation with
China and Russia.
6) State Police—to control the infl ux of weapons and
ammunition into the country and enforce relevant
laws in local areas.
Recommendations have been divided into six separate
sections, including (1) cross-cutting recommendations,
(2) international trade enforcement, (3) domestic trade
enforcement, (4) hunting management, (5) trophy and
sport hunting management, and (6) community-based
approaches. Each section identifi es short-term, long-
term, and regulatory goals in order of priority within
each subsection.
In drafting these recommendations, we are conscious
of the fact that wildlife management requires the
combination of a number of equally important ingre-
dients. For example, public awareness campaigns will
have little meaning if there is still no local incentive to
conserve the resource or report violations; value-added
processing will only result in higher incentives to
poach if not coupled with adequate monitoring and
enforcement; and improved systematic knowledge of
the resource will have only marginal impact if decision
making continues to ignore it and there is no capacity
to implement interventions. erefore, while we seek
to establish a semblance of priority, none of the recom-
mendations are intended as stand-alone solutions. It is
also important to recognize that long-term improve-
ments cannot be achieved without strong regional and
international cooperation and sustained technical and
fi nancial assistance from the international community.
Cross-Cutting Recommendations
For the government of Mongolia to eff ectively manage
the growing challenges to wildlife trade enforcement,
it must focus its attention on eliminating several
critical gaps in the overall management framework.
e following recommendations are cross-cutting in
nature; responsibility for pursuing them will devolve
to the Ministry of Nature and Environment, Central
Customs Authority, State Border Defense Agency, and
State Specialized Inspection Agency in cooperation
with other key organizations such as the Academy of
Sciences, Ministry of Education, State Police, Mobile
Anti-Poaching Units, and Protected Area Rangers.
Improving Wildlife Financing
Few of the recommendations contained in this chapter
will have much chance for success without adequate
fi nancing. We have therefore chosen this as the start-
ing point for all subsequent suggestions. Some of the
goals prioritized here rely on funds already generated
by wildlife trade being made available to the Ministry
of Nature and Environment for conservation. e one
regulatory goal targets national legislation that needs
revision to help unlock these funds.
Short-Term Goals:
Assess and Prioritize Wildlife Financing Needs:
is is a short-term and continuing initiative that
should be done as part of any sound fi scal man-
agement policy. If lessons from other countries are
any indicator, funding will always be an issue, in
particular for non-game species. In anticipation
of continuing budgetary constraints, priorities
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
67
should be established; i.e., for endangered species,
revenue-generating trophy species, and species in
decline because of subsistence hunting and trade.
Establish a Specifi c Budget in the MNE for Wild-
life Management: e MNE’s accounting format
fails to provide any specifi c budget for wildlife
management, despite this being one of the largest
potential income sources and a legally required
expenditure. Regardless of the budget ultimately
allocated, this is the place to start. It is also an
action that requires little to no input from outside
sources. Sub-accounts within this budget might
include:
Research and monitoring (allocable and priori-
tized by species).
Wildlife Project (agency) administration (orga-
nizational support, communication, computing
capacity, fee collection, contract administration,
etc.).
Transportation and lodging for Wildlife Project
(agency) fi eld personnel.
Equipment for Wildlife Project (agency and
enforcement) personnel.
Facilities maintenance.
Specifi c activities (i.e., infrastructure development,
watershed or range restoration, GIS and mapping,
etc.).
Set Goals for Achieving Reinvestment Require-
ments: Actually meeting the requirements of the
Law on Reinvestment of Natural Resource Fees
will take time. To assist in targeting and achieving
full compliance, the MNE should establish viable
goals tied to budgetary requests and internal
accounting.
Develop a Wildlife Management Budget for Other
Agencies: As part of each responsible agency’s
annual planning, a separate section devoted to
wildlife management should be used to prioritize
needs, outline required costs, avoid duplication of
eff ort, ensure compliance with legally mandated
funding requirements, and highlight progress
from the previous year.
Long-Term Goals:
Establish Monitoring System for Wildlife Account-
ing: e primary objective should be to develop
a system linked to project implementation that
evaluates project results to determine whether
or not objectives have been met, what costs and
investments were made to achieve results, how
well the system is working, and what changes in
fi nancing would improve results.
Regulatory Goals:
Revise the Public Sector Management and Finance
Law: Acting as the primary constraint to ear-
marking funds generated by wildlife hunting and
trade for conservation purposes, this law should
be a priority for legislative review and amendment.
Because this touches on the overall fi scal manage-
ment of the country, it is not expected that such
changes will be possible in the short term.
Improving Systematic Knowledge
Lack of systematic knowledge prevents policy makers
from assessing what needs to be done to improve
Gray wolf in M ongolia’s eastern step pe. Image: K. Ols on
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Mongolia
68
wildlife management systems or reform legislation. In
Mongolia, the lack of systematic knowledge in wildlife
management, especially trade, is substantial. Popula-
tion estimates for many hunted species are either
nonexistent or too infrequently conducted to inform
management decisions. Local governors requesting
hunting quotas for their area reportedly rely on data
given to them almost 20 years ago. Harvest quotas and
licensing totals are recorded by numerous bodies, but
not reported to a central authority and are therefore
not capable of being tracked from year to year.
Enforcement data is often treated as secret information
and not shared. A conference held in October 2005
has started to put together a Mongolian Biodiversity
Databank that will certainly improve the current
situation. Recognizing that these ongoing eff orts
are beginning to answer some needs, the following
recommendations highlight some of the basic require-
ments for improving systematic knowledge identifi ed
by the participants to the International Wildlife Trade
Conference.
Short-Term Goals:
Establish a Wildlife Trade Database: To ensure the
effi cient and timely sharing of critical wildlife data
among management and enforcement bodies, a
wildlife database should be created and recognized
as the primary data repository for all species. e
database could be part of the existing Mongolian
Environmental Information Databank managed
by the MNE and should be made available at the
national, aimag, and soum levels.
Update Range and Distribution Maps: Range and
distribution maps for most species important to
hunting and trade were completed in the 1970s.
ese maps are available only at small scales
and are too small to be useful in documenting
changes. Very few have been updated in the last
30 years. Range maps should be produced at
scales adequate to inform management and be
used to develop cooperative monitoring programs
(and perhaps regional quota systems) at the
national and local levels.
Identify Important Habitats: Results of population
surveys should be used to identify important habi-
tats that are worthy of consideration for reserve
status. Such sites might include areas containing a
major population of a species or containing a criti-
cal breeding ground for a species. MNE should
be made aware of these sites for consideration as
protected areas. For various reasons, not all such
areas will warrant reserve designation, but should
be designated by MNE as “important ranges” and
managed accordingly, with the potential to close
them to hunting should local populations show
consistently negative trends or reach critical levels.
Long-Term Goals:
Conduct Population Surveys to Monitor Trends:
ere is a critical need for regular, replicable, and
scientifi c best-practice monitoring for all game
animals to determine if populations are declining
or otherwise under threat. If monitoring data
suggests that a population is in decline and/or not
sustainable, hunting should be prohibited until
monitoring can prove that the population is again
numerous enough to sustain hunting. As can be
seen from the description of individual species
above, almost no accurate, replicable, or regular
monitoring has been attempted on any of the
species. It is essential that the national (preferably)
or aimag governments expend more funding,
resources, and manpower to survey and monitor
these species to determine their true condition and
trends.
Defi ne Sustainable Off take Levels: e Mongolian
Academy of Sciences is responsible for conducting
population surveys and providing recommended
off take numbers for consideration by the MNE
and the Cabinet Ministry. However, there are still
no methodologies to legally establish sustainable
off take levels, an obvious prerequisite to defi n-
ing appropriate harvest quotas. e improved
understanding of the resource supported by the
previous three objectives will assist in defi ning
off take levels.
Regulatory Goals:
Coordinate Wildlife Surveys and Monitoring:
Wildlife monitoring should be coordinated
through a central point, although actual collection
of data is likely to remain the responsibility of
multiple agencies, perhaps with an increasing
role at the local level. e primary goal of central
coordination is to ensure availability of data to
support sound decision making at a national level.
is also implies the use of standardized tools and
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69
methods for collecting, analyzing, and interpret-
ing data.
Legally Require Scientifi c Basis for Off take Levels:
For off take levels to have meaning, they must be
recognized by Mongolia’s quota-setting body, the
MNE. At present, the Academy’s quota numbers
are only recommendations and can be exceeded
by the MNE at its discretion. e result is harvest
levels issued by the MNE that often exceed the
Academy’s best estimate of sustainable levels.
erefore, there is a need to delegate authority to
determine harvest quotas and seasons to a single,
objective, scientifi c organization (i.e., Mongolian
Academy of Sciences) with no fi nancial interest in
the use of the species. It should be required that
quotas be based on the best available scientifi c
data, and that there be full publication of all data,
methodologies, discussions, and results for wildlife
research.
Develop and Standardize Enforcement Informa-
tion Collection and Sharing: Several govern-
ment bodies have enforcement authority and
regularly conduct patrols within their jurisdiction.
However, there is no standardized method for col-
lecting, processing, or distributing data to other
agencies. At a minimum, an agreement should be
reached that all enforcement bodies must supply
information on all wildlife trade or illegal hunting
interceptions with partnered agencies and include
at least the following enforcement details:
Arresting personnel’s division, region, title,
location, name and ID number.
Information suffi cient to fully and accurately
identify the violator(s).
Date(s) and location(s) of enforcement.
Type(s) of wildlife product seized.
Species name(s).
Volume of product in a measure that allows
determination of the number of animals (i.e., the
number of skins as opposed to weight or estimated
value).
Estimated value of the product.
Storage location.
Other items seized during enforcement (i.e.,
equipment, vehicles, weapons, money).
Regulate Chain of Custody Requirements:
Successful adjudication of poaching incidents
depends in part on the integrity of the system of
collecting, preserving, and submitting evidence to
laboratories for testing and courts for presentation
in case proceedings. At present, no such system
exists. At a minimum, the following elements
should be addressed either in law or regulation as
appropriate:
When evidence must be sent to a laboratory for
service or courts for adjudication proceedings.
What documents must be included when submit-
ting evidence.
Design of an evidence submittal form.
Design of a chain-of-custody form.
Guidelines for packaging, sealing, labeling,
tagging, and shipping evidence (including special
procedures for perishable materials).
e Community Dimension
One fundamental similarity across countries and
cultures is that any government program must appear
to be public, transparent, eff ective, and legitimate. In
other words, the concept and contents of the program
(including relevant legislation) have to be made avail-
able to citizens so that they can be easily understood.
Simply restating what the law says (a regular practice
in Mongolia) is rarely understood by local communi-
ties and fails to make the initiative relevant to their
lives. e information must also be easily available
in common places or media—television, radio,
newspapers—vs. bulletins posted on the inside of
government buildings. is information should clearly
defi ne procedures for its application; that is, it should
be user-friendly. Finally, it must be created using
recognized procedures from a recognized authority.
While the following list of recommendations does
not address all of these issues, it does emphasize the
need in Mongolia to amplify citizen involvement and
understanding of wildlife management goals. Without
the involvement of citizens in decisions on wildlife
management, the value, validity, and integrity of
attempts to include the public in hunting management
and anti-poaching campaigns will likely fail.
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Mongolia
70
Short-Term Goals:
Establish Wildlife Hotline: A simple and relatively
easy measure to implement would be the establish-
ment of a toll-free “Wildlife Hotline” telephone
number in areas with adequate infrastructure for
reporting illegal wildlife trade activity. e hotline
would maintain a critical link with the public,
fi elding calls and ensuring caller anonymity by
not requiring them to reveal their names, testify
in court, or sign affi davits. Most important, it
would allow the public to report wildlife viola-
tions directly to law enforcement personnel, or in
the alternative to a nongovernmental organization,
and potentially to a specially trained task force.
Obviously, such a system would not be available
in Mongolia’s vast remote landscapes, but much
of the trade occurs in developed cities and towns
that have increasingly well-connected cell phone
services.
Expand Existing Information Campaigns:
Continue and expand on the information
campaigns targeting both Mongolian nationals
and international visitors. Current eff orts focus
on trade in certain endangered species and are
limited to billboards located at the Chinggis Khan
International Airport. Additional opportunities
to “get the message out” include distribution of
wildlife trade pamphlets to visa applicants in
Mongolian embassies abroad and at the foreign
national registration offi ce in Ulaanbaatar. Costs
of the program could be passed on to tourists
through moderate increases in visa or registration
fees.
Design Anti-Poaching Education Campaign:
Broadcast anti-poaching public service announce-
ments on TV channels, radio channels, and other
media sources. Promote to children and adults
a greater understanding of Mongolian wildlife,
their habitats, and the threats to their survival
by allowing people to read, listen to, or watch
free educational material. Investigate potential
to incorporate anti-poaching messages into
established school curricula.
Long-Term Goals:
Develop and Implement a National Program for
Public Awareness: Coupled with an appropriate
community-based program, public education at
the national and local level would go far toward
reducing illegal wildlife harvests in Mongolia. A
public relations and education program should
focus on the rich cultural heritage that Mongolia
boasts (UNDP 2000, World Bank 2003) and
how poaching negatively aff ects and refl ects on
that tradition. It should work to strengthen the
conservation ethic that already exists and work
to reinforce social barriers to poaching. Such a
program should be linked to a social development
plan that provides alternatives to illegal practices.
Providing jobs in law enforcement is one example,
but this approach should be even more compre-
hensive and enlist the assistance of people trained
in these areas.
Regulatory Goals:
Increase Whistle-Blower Incentives: e current
whistle-blower provision in the Hunting Law does
not protect the reporter’s anonymity and does not
provide enough incentive. It pays cash rewards
that are 15 percent of the fi ne. In many instances,
the fi nes are so low that a percentage would be
meaningless. To be eff ective, the law should
establish minimum rewards, with higher mini-
mums for reporting endangered species violations.
Substantial awards (i.e., up to $1,000) could be
off ered for information leading to the arrest and
conviction of anyone in possession of or trading
more than a certain quantity of wildlife parts.
Establish Participatory Processes: If wildlife trade
policy is to accommodate multiple interests, the
legal framework needs to provide an eff ective
mechanism by which diverse stakeholders can
make their interests known and, perhaps more
importantly, interface with policymakers. is is
as important at national and regional levels as it
is at the level of particular communities. Critical
areas to consider include access to information
and participation in policy formulation and
resource decisions. To help accomplish this goal,
Mongolia should consider becoming a signatory to
the Aarhus Convention.
Inter-Agency Cooperation and Capacity Building
In the struggle against illicit wildlife trade, there can
be no substitute for well-coordinated, equipped, and
trained management authorities. For the Mongolian
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71
government to design, implement and enforce eff ective
wildlife trade laws and policies, capacity building for
wildlife trade management must be undertaken in the
Ministry of Nature and Environment, Central Cus-
toms Authority, State Specialized Inspection Agency,
State Border Defense Agency, as well as with local-
level administrations. At a minimum, there must be
one management authority with primary responsibility
for the design, coordination, and implementation of
wildlife management programs. Priorities include the
following steps and measures.
Short-Term Goals:
Develop and Implement Inter-Agency Training
Program: Assess enforcement capacity and
training needs on a site-by-by site basis. A range
of specialists—including State Border Defense
Agency and police trainers, legal experts, and
specialist wildlife trainers—should conduct
training.
Create an Inter-Agency Wildlife Trade Enforce-
ment Handbook: Draft and publish an Inter-
Agency Wildlife Trade Enforcement Handbook
for use by Central Customs, State Specialized
Inspection Agency, State Border Defense Agency,
Protected Area Rangers, and police.
Organize Annual National Wildlife Management
and Trade Seminars: Organize annual national
seminars—including all private, government,
and NGO representatives who manage wildlife
trade—to discuss ongoing and emergent issues
and continue to refi ne management directives.
Long-Term Goals:
Establish Wildlife Management Agency: A
number of government agencies in Mongolia
have been delegated some authority for wildlife
management. However, there is no single author-
ity responsible for managing the system as a
whole. e result is piecemeal actions by several
authorities with sometimes little communication
or cooperation, and ultimately ineff ective manage-
ment. A single authority would provide a central
hub to all agencies having some management
or enforcement authority and a focal point for
initiatives aimed at improving the system.
Strengthen Judicial Capacity to Adjudicate
Wildlife-Related Cases: Training programs
are urgently needed to build knowledge and
strengthen the capacities of judges, as well as that
of public prosecutors, to deal with wildlife trade
issues. In general, the judicial system is still weak
and inadequately trained to handle environmental
litigation. is proposal is probably the most
diffi cult and will require a coordinated eff ort
to achieve. Assistance in the development and
implementation of such a training program should
come from agencies with wildlife enforcement
responsibilities and the Ministry of Justice.
Regulatory Goals:
Refi ne Delegations of Authority in Existing and
Proposed Legislation: As a counterpart to
the establishment of a Wildlife Management
Authority, legislative action will be required to
refi ne delegations of authority and coordinate
joint initiatives such as research, monitoring, and
enforcement. ese issues need to be addressed
and roles clarifi ed in a manner that will enable
quick action by identifi ed agencies to issues related
to wildlife management.
In the event legislative action is not possible, two
alternatives may be possible:
1. Develop Regulation on Inter-Agency Coopera-
tion: As a substitute for legislation and to ensure
full and prompt cooperation between sometimes
competing agencies, conference attendees
recommended the development of a separate
regulation to defi ne cooperation requirements,
provide specifi c procedures, and delineate fi nes for
noncompliance.
2. Establish Inter-Agency Cooperative Agreements:
With or without a law or regulation, all relevant
agencies should still seek to establish operating
agreements for wildlife monitoring, enforcement
protocols, population survey methodologies, and
any associated schedules. Agreements should
stipulate prompt exchange and sharing of new and
existing data and reference appropriate sections of
Mongolia’s administrative or other law to ensure
adherence.
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Economic Incentives and Disincentives
Economic incentives and disincentives will be a key
factor in generating revenue from the resource and
providing a check against corruption. e decision
to use such measures must be made in the context of
the country’s overall economic planning and strategy.
For this reason, we list a few examples that should be
considered with the understanding that they are part
of longer-term strategies still to be developed.
Long-Term Goals:
Provide Enforcement Incentives to Government
Staff : For many years, the State Specialized
Inspection Agency, Customs offi cials, and MNE
staff have watched as Mongolia’s wildlife leaves the
country. ere is no mystery as to the responsible
parties, little secrecy concerning collecting points
and markets, and no lack of evidence. It continues
for many reasons, but one is the lack of incentive
to engage in diffi cult, and sometimes dangerous,
enforcement actions. One solution to the problem
would be to incorporate enforcement incentives
designed to motivate and reward public offi cials
whose enforcement performance exceeds existing
regulatory requirements.
Value-Added Processing of Wildlife Products:
Products from wildlife should be transformed as
much as possible within Mongolia to maximize
the value captured from the resource and
employment opportunities. To achieve this goal,
appropriate technical assistance and fi nancial
mechanisms will be required from the interna-
tional community, NGOs and the Mongolian
government. While this is a high-risk strategy
(because it carries the potential to increase incen-
tives to poach), it is nonetheless a fundamental
principle of economic development—that a
producing country should seek to extract the
maximum value from the use of a given resource
through adding value to the production. is
should not be considered a viable goal unless other
components aimed at controlling hunting and
trade have already been achieved.
Promote Alternatives to Wildlife Use: Identify and
promote economically feasible alternatives to
direct wildlife use. Examples have already been
developed by the International Snow Leopard
Trust, active in the western part of the country,
and could be expanded upon for use in other
areas.
Develop ‘Soft’ Enforcement Measures: In addition
to strengthening traditional means of enforce-
ment, there is also a need to develop alternative,
“softer” means of law enforcement. is includes
the use of positive incentives and voluntary
agreements. e latter are likely to be vital for
securing environmental commitments from local
communities and the expanding private sector.
International Trade Enforcement
Illegal international trade poses the greatest threat
to Mongolia’s wildlife. Many of the animals hunted
would have little or no value in a purely domestic
market and for those with local value, trade volumes
would be orders of magnitude smaller. Improving
international trade enforcement must therefore be
a cornerstone in any approach to managing wildlife
trade in Mongolia. Primary responsibility falls to two
agencies, the Central Customs Authority and the State
Border Defense Agency. Sharing some responsibility is
the State Specialized Inspection Agency. All struggle
Siberian ib ex. Image: Luke Diste lhorst.
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with legal and management defi cits to implement
existing national mandates. e following actions
should be undertaken in the immediate future to cor-
rect existing defi cits and create a positive environment
for cooperative action:
Short-Term Goals:
Improve Border Point Investigation Capacity:
e Central Customs Authority is well aware of
the areas most important to cross-border trade
in wildlife. But they cannot stop it without the
equipment and personnel capable of detecting
wildlife contraband. Even the Zamiin Uud and
Altanbulag locations need substantial equipment
upgrading and personnel training to eff ectively
investigate trade. While some of the equipment
would be expensive and diffi cult to maintain (i.e.,
scanning equipment), other techniques, such
as using trained dogs, are not only feasible, but
many agents already have experience using them
for other types of investigation, primarily for
narcotics trade. Programs in the United States,
South Africa, and Canada have shown that dogs
can be used as an eff ective law enforcement tool to
enhance the eff ectiveness of CITES and domestic
wildlife trade controls.
Institute Random and Undercover Border Trade
Investigations: To increase the potential
eff ectiveness of enforcement actions, border
trade areas should be monitored by sporadic and
unannounced visits from the State Specialized
Inspection Agency and/or other enforcement
personnel.
Long-Term Goals:
Establish Formal Links with Trade Partners:
Establish formal links with Chinese and Russian
agencies, and with land managers in border areas,
to facilitate information exchanges and coopera-
tive management ideas.
Institute a Multi-Level, Multi-Partner Exchange
and Training Program: Exacerbating eff orts
to control international trade is the inadequate
exchange of information and enforcement
methods with similar agencies in neighboring
Russia and China. is recommendation seeks to
engage communication and forge action partner-
ships at the international level directed at similarly
situated implementing bodies. e exchange
program could include joint investigative eff orts
to follow up on enforcement leads, joint training
at identifi ed cross-border trade points, and regular
and full disclosure of domestic and cross-border
enforcement actions.
Regulatory Goals:
Restrict Legal Wildlife Trade to Identifi ed Border
Points : Only two border points (Zamiin Uud and
Altanbulag) are equipped to process legal wildlife
trade. Restricting legal trade to these areas would
not by itself prevent traders from attempting to
smuggle through other border points, but it would
allow enforcement personnel to focus their eff orts.
For example, any wildlife trade passing through
other points would automatically be subject to
confi scation.
Develop Standard Protocols for Handling Con-
fi scated Wildlife Products: To date, no organi-
zational protocols clearly defi ne the relationship
between prosecutors, police, inspectors, rangers,
expert government witnesses, and the courts.
Enforcement bodies can therefore unilaterally
decide how to proceed with confi scated goods,
making it diffi cult to manage court proceedings
and ensure the preservation of valuable evidence.
Domestic Trade Enforcement
Domestic wildlife trade in Mongolia began in earnest
with the economic collapse of the early 1990s and has
grown along with the nation’s improving economy.
Wild game meat (e.g., marmot, roe deer, Mongolian
gazelle, black-tailed gazelle, Yakut moose, Asiatic wild
ass) is a popular item found on the market in many
local areas, as are a number of medicinal products or
species (e.g., Altai snowcock, wolf, corsac fox, Eurasian
badger).
Short-Term Goals:
Expand and Improve Mobile Anti-Poaching Units:
Mongolia’s mobile ant-poaching units have
managed to gain some ground, albeit limited,
in the fi ght against poaching and wildlife trade.
Growing recognition by and cooperation with the
Professional Inspection Agency has helped give
their presence and actions a degree of power. In
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74
the immediate term, these units are in need of
fi eld training and communication equipment.
Strictly Enforce the Prohibition on Advertising
Wildlife Parts in National or Local Media: Ad-
vertising laws already make it illegal to advertise
wildlife parts for sale, but enforcement remains
poor. Increasing fi nes and creating an incentive to
citizen reporting (whistle-blower provisions) has
the potential to increase the eff ectiveness of these
provisions.
Long-Term Goals:
Develop Long-Term Funding Strategy for Mobile
Anti-Poaching Units: ese units still exist on
the margins of management supported almost
entirely by outside funding. If they are to become
a part of permanent anti-traffi cking eff orts, their
status and capacity needs to move to the next
level. In the long term, these units will need
identifi ed sources of income and support, includ-
ing potential policy changes to recognize their
status in anti-poaching eff orts.
Regulatory Goals:
Incorporate Eff ective Anti-Corruption Measures
in Legislation: It is no secret that enforcement
personnel are sometimes part of the problem. e
eff orts to disengage enforcement from manage-
ment through the creation of the State Specialized
Inspection Agency have not resulted in any real
change in corruptive practices. All enforcement
personnel still suff er from impossibly low salary
levels and inadequate training, support, and
safeguards for their often dangerous jobs. e
situation gives new meaning to the old adage—if
you can’t beat them, join them. Anti-corruption
measures need to be incorporated into legislation
that has suffi cient deterrence values.
Develop Wildlife Registration and Tagging
Requirements: Tagging is a fundamental tool
in hunting enforcement that has not yet been
fully developed in Mongolia. e Ministry of
Nature and Environment should, in concert with
all other enforcement bodies (State Specialized
Inspection Agency (SSIA), State Border Defense,
Customs, and Police), develop wildlife registration
and tagging requirements to enable tracking and
enforcement of hunting and trade restrictions. In
this system:
Registration would apply to a set list of species and
parts that are traded for their trophy, aesthetic,
or medicinal value; i.e., snow leopard pelts and
skulls, brown bear paws, argali skulls and horns,
ibex skulls and horns, etc.
Tag gi ng would apply to all animals harvested for
any purpose (scientifi c, household, commercial,
or trophy) by whatever means and constitute both
the permission to hunt and possess the animal
indicated on the tag by a specifi c person. Failure
to immediately tag would constitute a violation
equal to hunting without permission. Tags would
be required to remain with the animal at all times
until consumed. Tags would not be transferable.
Possession of a tagged animal by someone other
than the hunter would constitute an off ense
punishable by civil and criminal penalties.
Develop Wildlife Registration and Tagging Sys-
tem: To implement the preceding requirements,
the same government agencies should develop a
wildlife registration and tagging system to ensure
the fair and effi cient administration of the require-
ments. To avoid confusion, registration should be
restricted to the offi ces of responsible government
agencies. Tag distribution, however, may happen
through local government agencies, but is also
possible through licensed private companies
(pursuant to a competitive bidding process). is
type of arrangement would be consistent with
government policy to allow private businesses the
opportunity to provide public services they can
deliver effi ciently.
Prohibit Possession of Unregistered/Untagged
Animal Parts: MNE, with input from interested
Mongolian and international agencies and NGOs,
should seek to amend existing law to make pos-
session, sale, purchase, and transportation of any
wildlife parts illegal unless properly tagged and/or
registered. e law would apply to all species
equally with more detailed requirements (special
registration, number locking tags, etc.) to control
trade in endangered species parts such as snow
leopard skins and meat, brown bear paws and
skins, argali and ibex horns, Dalmatian pelican
beaks, saiga antelope, etc.
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75
Implement Grace Period for Wildlife Part Registra-
tion: MNE, or an entity designated by MNE,
should register within a specifi ed time frame (e.g.,
six months from publication of law) all hides,
skulls, and other animal parts for specifi c species
currently in the possession of any government
agency, economic entity, or individual. Possession
of any parts after the registration period will
subject possessor to criminal and civil penalties
pursuant to amended legislation. A small sample
of skin or hair may be collected at the time of
registration for future genetic studies. Individual
owners will be informed in writing at the time
of registration that it is illegal to sell or trade the
registered part. Any unregistered hides or skulls
encountered by law enforcement agents after the
end of the amnesty period will be confi scated and
the possessors prosecuted.
Redesign Wildlife Economic Assessments: e
hunting law assigns licensing fees and civil fi nes
based on the “ecological and economic assess-
ment” of the species in question. Participants in
the wildlife trade workshop felt the assessments
are confusing and do not refl ect actual market
prices. In practice, the assessment assigns a price
per kg of meat and a total value equal to the
average number of kg for the animal in question;
the “ecological” measure, along with many other
market values for medicinal parts and furs, is
completely ignored. Fees and fi nes therefore fail
to adequately pay for the use of the resource, act
as a deterrent to illegal activity, or compensate
the state for violations. Assessment requirements
should be redefi ned to eliminate the unused and
confusing “ecological” measure and tie values
to known market values using an identifi ed and
independent source. e value should be reviewed
annually and be suffi ciently higher than the
market value of the animal parts to deter poach-
ing. Market value can be determined through
consultation with international entities that
monitor trade in wildlife, such as TRAFFIC.
Annually Revise Fine Levels to Mirror Market: As a
matter of legislative drafting, all fi nes are specifi ed
in the organic legislation (ten years ago for most
laws) with no provision for infl ation-indexing or
regulatory mechanism to adjust fi ne levels. e
result is a signifi cant reduction in disincentive
and compensative values. e Hunting Law
contains the most complicated set of administra-
tive penalties, but still fails to establish adequate
disincentives applying a fi ne of MNT 10,000 to
25,000 for poaching (not including “huntable”
rare animals for which criminal charges apply). To
be eff ective, fi nes need to be set suffi ciently higher
than current market values and adjusted through
formal channels on an annual basis. Even though
fi nes are viewed in large part as revenue genera-
tors, the deterrent principle behind the application
of administrative or monetary fi nes cannot be
ignored. For this to work, acting illegally (and be-
ing caught) has to be more expensive than acting
legally—and it must keep pace with the market.
One way to do this is to ensure the regular
updating of fi ne levels and, once appropriately set,
defi ne a procedure that keeps pace with infl ation.
Hunting Management
Mongolia’s wildlife trade begins with individual hunt-
ers across the country. Eff ective hunting management
is therefore a fi rst step in controlling wildlife trade.
Attendees of the International Conference on Illegal
Wildlife Trade complained that local permissions
exceed authorized quotas, that hunters infrequently
purchase licenses and, if they do, often exceed license
limits. e MNE continues to issue quotas even in the
face of dwindling resources, and there is little to no
enforcement of hunting restrictions at the local level.
Furthermore, the legal basis for hunting management
is missing several key components.
Redressing the problems involving unsustainable and
illegal hunting in Mongolia will require reforming
hunting and population management to ensure (1)
openness and transparency, including external review
and oversight; (2) a mix of top-down and bottom-up
authority that enjoys local support; and (3) active and
adaptive conservation and management, including
anti-poaching enforcement, and using funds generated
by hunters. If Mongolia does not take immediate steps
to halt this crisis and reverse the dramatic decline in
wildlife, the country may soon face a series of country-
wide extinctions that will forever alter the biodiversity,
ecological structure, and economy of the country.
Recommendations include:
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76
Short-Term Goals:
Conduct Population Surveys to Monitor Trends:
ere is a critical need for regular, replicable, and
scientifi c best-practice monitoring for all game
animals to determine what level of hunting, if any,
a given game species population can support.
Defi ne Sustainable Off take Levels: e Mongolian
Academy of Sciences is responsible for conducting
population surveys and providing recommended
off take numbers for consideration by the MNE
and the Cabinet Ministry. However, there are still
no methodologies to legally establish sustainable
off take levels, an obvious prerequisite to defi ning
appropriate harvest quotas.
Design and Implement Hunting Districts: Other
than protected areas, there are no restrictions
on where hunting may take place in Mongolia.
Signifi cant benefi ts may be gained by limiting
hunting to specifi c areas and adjusting manage-
ment directives to meet the needs of the wildlife
resources in the area. In general, hunting districts
should have a clearly defi ned area, suffi cient
resources to support the type of hunting permit-
ted, a designated management authority whether
government or a local community, trained manag-
ers within those organizations, and a management
plan with clearly defi ned requirements for its
development, renewal, and legal status.
Regulatory Goals:
Revise Existing CITES Legislation to Comply with
Convention: Mongolia’s CITES implementation
regulation is in contravention of the convention
by granting the management body the authority
to resolve disputes surrounding harvest quotas
and thereby exceed harvest quotas. Academy of
Science biologists and hunting companies both
complained that quotas in recent years have been
almost double the recommended levels.
Prohibit Hunting of Species with Decreasing
Populations: Prohibit the taking of any species
unless data indicates that the population is either
stable or increasing (i.e., sustainable use at the
permitted level is likely), and that the population
is numerous enough to sustain hunting.
Require Management Planning: Require the
development of management planning on a
species-by-species basis, including compliance
with this plan for local hunting management
planning and activities. is will take substantial
time and investment to comply with and it is
therefore recommended that the requirement be
phased in starting with priority species, such as
marmot, wolf, red and corsac fox, etc. As manage-
ment plans are completed and to ensure they are
used, an additional regulatory requirement may
be added explicitly restricting hunting in any area
where there is no modern, replicable monitoring
system in place.
Limit Hunting Licenses to Single Season: Without
any specifi c limitations, hunting permissions are
freely used in the following year if the hunter does
not use it the year it was issued.
Tie Hunting Seasons to Flexible Management
Scheme: Seasons, similar to quotas, should be
set and adjusted pursuant to monitoring results
using a fl exible regulatory mechanism (not organic
legislation) and adjusted on an annual basis as
needed. To do this will require amending the
law on hunting to defi ne how and when such
seasons will be defi ned, which organization will
be responsible, the basis for establishing such
seasons, and appropriate inter-governmental
dispute resolution mechanisms that ensure fair
administration of the process, but also respect the
need for a science-based approach.
Establish Fines that Off set Market Incentives:
Establish penalties through a regulatory mecha-
nism that can adapt to and refl ect the changing
status of species, markets, and types of illegal
uses. Related to this would be the elimination of
distinctions between private citizens, companies,
and public offi cials in setting penalty levels,
basing them instead purely on the severity of the
off ense (type of species, number taken, subsequent
off enses, etc.). Finally, include suspension of
hunting privileges for certain types of off enses.
Refi ne Commercial Hunting Agreements and Leg-
islation: Similar to, but separate from, hunting
concessions, commercial hunting agreements need
refi ning to become sustainable and ensure that
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77
local communities benefi t fully from the harvested
species. Specifi c elements to consider include:
a) Full Market Analysis: Prior to approving a
commercial hunting agreement concession,
require the contractor to defi ne the market for
the resource (including the fi nal product) and
any particular demands, including product
refi nement, packaging, delivery, etc.
b) Value-Added Production Requirements:
Consider including value-added production
requirements into hunting concession contracts
to ensure that a greater portion of the market
value is captured by the local community. At
present, commercial hunting ventures (whether
conducted by companies or individuals) deal
almost exclusively in the sale of raw products to
China.
c) Habitat Protection Requirements: Fully
describe habitat protection requirements,
standards, and procedures.
d) Hunting Company Certifi cation: Establish
specifi c criteria for selection of qualifi ed
commercial hunting companies to ensure that
only companies with adequate capacity and
no previous record of illicit activities will be
allowed to engage in this economic activity.
Qualifi cations may include, but are not limited
to, suffi cient staff with adequate training in the
harvest and processing of the targeted species,
adequate fi nancial capacity to perform all
requirements that may be imposed (including
habitat and resource protection requirements),
monitoring activities, and value-added product
development.
e) Incentives for Community Involvement:
Create incentives for and require cooperation
with local communities. Ensure that a percent-
age of hunting revenues are shared with the
local community separate from other budget-
ing processes;
Trophy and Sport Hunting Management
ere is little in the way of formal management
of trophy and sport hunting in Mongolia. When
initially conceived, the Law on Hunting identifi ed
sport hunting, but limited its application to foreign
hunters. Mongolia’s improving economy, relaxed gun
controls, and abundant supply of ammunition have
made it possible for a growing number of people,
including Mongolians, to discover (or rediscover)
the sport. Numerous sport hunting companies now
off er high-end hunting excursions in the country for
a number of species, including argali, ibex, wild boar,
Yakut moose, Mongolian gazelle, black-tailed gazelle,
and Siberian roe deer.
Many of the goals stated in this section are the same or
similar to those listed in the recommendations under
the previous section. We repeat them here with slight
changes for clarity.
Short-Term Goals:
Conduct Population Surveys to Monitor Trends:
ere is a critical need for regular, replicable, and
scientifi c best-practice monitoring for trophy and
sport game animals to determine if populations
are declining or otherwise under threat. If
monitoring data suggests that a population is in
decline and/or not sustainable, hunting should
be prohibited until monitoring can prove that the
population is again numerous enough to sustain
hunting. As can be seen from the description of
individual species in Appendix A, almost no ac-
curate, replicable or regular monitoring has been
attempted on any of the species. It is essential that
the national (preferably) or aimag governments
expend more funding, resources, and manpower
to survey and monitor these species to determine
their true condition and trends.
Defi ne Sustainable Off take Levels: e Mongolian
Academy of Sciences is responsible for conducting
population surveys and providing recommended
off take numbers for consideration by the MNE
and the Cabinet Ministry. However, there are still
no methodologies to legally establish sustainable
off take levels, an obvious prerequisite to defi ning
appropriate harvest quotas.
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Design and Implement Trophy Hunting Reserves:
With the exception of protected areas, there are
no restrictions on where trophy hunting may take
place. As with other hunting districts, trophy
hunting reserves should have a clearly defi ned
area, suffi cient resources to support the type of
hunting permitted, a designated management
authority whether government or a local commu-
nity, trained managers within those organizations,
and a management plan with clearly defi ned
requirements for its development, renewal, and
legal status.
Regulatory Goals:
Revise Existing CITES Legislation to Comply with
Convention: Mongolia’s CITES implementation
regulation is in contravention of the convention
by granting the management body the authority
to resolve disputes surrounding harvest quotas
and thereby exceed harvest quotas. Academy of
Science biologists and hunting companies both
complained that quotas in recent years have been
almost double the recommended levels.
Prohibit Hunting of Species with Decreasing
Populations: Prohibit the taking of any species
unless data indicates that the population is either
stable or increasing (i.e., sustainable use at the
permitted level is likely), and that the population
is numerous enough to sustain hunting.
Require Management Planning: Require the
development of management planning on a
species-by-species basis, including compliance
with this plan for local hunting management
planning and activities. is will take substantial
time and investment to comply with and it is
therefore recommended that the requirement be
phased in starting with priority species, such as
argali, ibex, taimen, etc. As management plans
are completed and to ensure they are used, an
additional regulatory requirement may be added
explicitly restricting hunting in any area where
there is no modern, replicable monitoring system
in place.
Tie Hunting Seasons to Flexible Management
Scheme: Seasons, similar to quotas, should be
set and adjusted pursuant to monitoring results
using a fl exible regulatory mechanism (not organic
legislation) and adjusted on an annual basis as
needed. To do this will require amending the
law on hunting to defi ne how and when such
seasons will be defi ned, which organization will
be responsible, the basis for establishing such
seasons, and appropriate inter-governmental
dispute resolution mechanisms that ensure fair
administration of the process, but also respect the
need for a science-based approach.
Establish Fines that Off set Market Incentives: Estab-
lish penalties through a regulatory mechanism
that can adapt to and refl ect the changing status
of species, markets, and types of illegal uses.
Related to this would be the elimination of
distinctions between private citizens, companies,
and public offi cials in setting penalty levels,
basing them instead purely on the severity of the
off ense (type of species, number taken, subsequent
off enses, etc.). Finally, include suspension of
hunting privileges for certain types of off enses.
Develop Full Hunting Regulations for Sport
Hunting: Sport hunting for foreigners is mostly
a function of the permit system from the MNE.
Where, when, and how sport hunting can occur
has not been adequately addressed and is resulting
in negative impacts to communities and targeted
species. Cited problems include a lack of defi ned
local hunting areas; hunting tourism companies
moving with relative freedom in search of
trophies; hunting scouts driving animals out of
protected areas so they can be hunted within the
technical requirements of the law; hunting during
seasons that overlap with breeding times; failure
to comply with buff er zone requirements; no
requirements, monitoring, or budget at any level
for actual conservation of the resource; and little
or no connection with local communities.
Refi ne Hunting Concession Agreements and Legis-
lation: As part of sport hunting legislation, it may
be desirable to defi ne concession agreements—al-
though this concept should be treated carefully, as
it has the potential to result in the privatization of
the resource and does not by itself guarantee the
achievement of targeted management outcomes.
Mongolia is currently experimenting with the
concept of concession agreements for sport fi sh-
ing, but has yet to approve any law or expand the
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79
concept to other wildlife. Several components to
a fair and enforceable system should be explored
including, but not limited to:
a) Outfi tter Certifi cation: Establish specifi c
criteria for selection of qualifi ed hunting outfi t-
ters. Hunting tourism is classifi ed as “tourism”
and is therefore open to any company with
experience running a tourism operation,
even completely unrelated forms of tourism.
e result is an ever-increasing number of
applicants and still no established criteria for
selecting companies.
b) Incentives for Community Involvement:
Create incentives for and specifi cally defi ne all
elements of cooperation with local communi-
ties. is may include requirements for select-
ing and training local community members to
provide various supplemental services; a share
in hunting profi ts earmarked for community
initiatives and separated from government
budgets; and development of value-added local
products and services associated with hunting
tourism.
c) Capacity Building Requirements: Consider
adopting capacity building requirements into
hunting concession contracts to identify and
build local capacity to engage in hunting
management and production of wildlife
products.
d) Resource Protection Requirements: To
ensure the sustainable use of hunting resources,
companies should be responsible for adequately
protecting the resource within their concession.
Such requirements should not only include
protection of the species, but also habitat.
e) Increase Monitoring Requirements: Hunting
companies are currently required to assess the
status of hunted populations and areas once
every year. Stricter monitoring and controls
need to be instituted to ensure compliance with
this provision. Monitoring of some species only
once per year may also be insuffi cient to inform
management.
Community-Based Approaches
With chronic unemployment across Mongolia,
the government has naturally focused much of its
attention on creating economic opportunities for its
citizens. To this end, Mongolia has also been part of
the worldwide trend to foster community approaches
to manage a variety of natural resources. Recognizing
the need to involve communities, the government has
begun the process of enabling communities to stake
a claim in Mongolia’s resource base. e legislative
vehicles for local access to resources are the Law on
Environmental Protection, the Law on Forests, and the
Regulation on Community-Based Natural Resource
Management.
However, important changes in both law and practice
will be required if community-based initiatives are to
succeed.
Short-Term Goals:
Develop a Strategy for Community-Based Wildlife
Management: e Ministry of Environment has
recently engaged in the development of a regula-
tion aimed at implementing the community rights
contained in the Law on Environmental Protec-
tion. Access to wildlife resources is an intended
part of that regulation, but remains a diffi cult
subject because of the special requirements of
wildlife management. Before implementing this
regulation, it would be useful to develop a strategy
to address these issues on a test basis for later
inclusion into the regulation.
Long-Term Goals:
Implement Community-Based Wildlife Manage-
ment Nationally: In the long term, the creation
of a nationwide system for community-based
wildlife management should be the ultimate goal.
Such a system will be in large part dependent on
the legal system that supports it, (described in
the next section) as well as the full commitment
of the government to support the eff ort. As with
any natural resource management system, it will
also need careful tailoring to the communities and
wildlife resources of the various regions and sub-
regions in Mongolia. What may be appropriate for
a community reliant on marmots for subsistence
purposes may not be adequate for a community
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Mongolia
80
engaged in the management of a trophy hunting
species such as argali.
Regulatory Goals:
Legally Recognize Community-Based Organiza-
tions: Even though there is little hope of
achieving this goal in the short term, it is a critical
step in this process. Any organization forced to
act without recognition as a legal entity faces
unavoidable risks and insurmountable obstacles.
Giving local people the right to access resources,
but taking away their right to form a legally
recognized entity may in the end cause more
problems than it solves. erefore, this should be
a priority.
Develop Appropriate Framework for Community
Participation: Mongolia has yet to develop an
appropriate framework for community participa-
tion that ensures adequate and timely access to
information, regular admittance to government
meetings, and full participation in policy formula-
tion and decision making. At present, the laws
directed at participation remain principles without
defi ning a guaranteed and specifi ed process and as
such are almost entirely ineff ective.
Provide Secure Community Access Rights: As of
November 2005, Mongolian citizens now have
the right to access certain natural resources.
Land-lease tenure provisions contained in the
Law on Land provide a starting point, but tenure
security has not been adequately defi ned and will
likely confl ict with other concession types such
as mining and petroleum. Without security, there
can be no long-term interest in the sustainable use
of the resource, which is one of the ultimate goals
of this approach.
Devolve Real Rights to Engage in Local Manage-
ment: e trend in community resource
legislation in Mongolia has been to delegate the
right to protect resources or advise on resource
uses without adequate rights to actually manage
resource use or enjoy the benefi ts. e result is
understandably a lack of interest by local com-
munity members. A fundamental shift in policy
direction will be required that ensures a return to
local communities for their investment in resource
protection.
Clearly Defi ne the Balance of Power between
Local and National Government: From a
purely technical point of view, there is clearly
a need to involve government in community
approaches. While local communities are in the
best position to aff ect local management, they
lack fundamental capacities that can only be
improved with the help of responsible government
agencies and through appropriately selected
policies and actions. A fi ne balance of power
therefore needs to be defi ned and achieved to
foster and sustain community management
activities. is would include the identifi cation of
(1) services the government or other organization
is uniquely positioned or authorized to provide,
(2) the complementary or supplementary role of
communities, and (3) cooperative mechanisms to
allow the smooth functioning of these sometimes
separate, sometimes combined roles.
Clearly Defi ne Community Enforcement and
Dispute Resolution Mechanisms: e legal
framework is still silent on private enforcement
and dispute resolution mechanisms. Dispute
resolution is the exclusive domain of the Ministry
of Justice and local governors, neither of whom
are adequately equipped to handle the growing
complexity and frequency of resource-related
disputes. Providing comprehensive guidelines
for community dispute resolution will provide a
measure of effi ciency in the system and support
the fair administration of community rights at the
local level.
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– 81 –
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– 89 –
Appendix A:
Species Case Studies
In addition to conducting surveys and reviewing
offi cial data sources, the project team engaged
in the review of scientifi c papers on the status of
targeted trade species in Mongolia. e follow-
ing case studies highlight the impacts of hunting on
Mongolia’s wildlife resource and provide a summary
of what is known about each species’ legal status,
distribution and densities, and the results of the
surveys conducted during this study.
In general, the case studies provide ample evidence
that the suspected and observed patterns of overuse
extend to most, if not all, species and echo sentiments
expressed by participants to the Mongolian Biodi-
versity Databank workshop held in October 2005.
During our survey, we did not limit our questions
to a pre-selected group of species and therefore
collected data on many—several of which are also
under extreme pressure. Moose and wild boar, for
example, are considered to be declining in the north
(Pratt et al. 2004); ibex, roe deer, lynx, red fox,
corsac fox, otter, sable, wolverine, and Pallas’ cat are
all under threat and likely to be declining. ese
species are heavily hunted throughout their range for
their meat, skins and/or for the international trade
in body parts. In virtually all cases, hunting occurs
outside of the legal requirement for permits, quotas, or
hunting areas.
Pallas’ cat. I mage: Dr. Richard Readin g
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Mongolia
90
Marmot (Marmota sibirica and
Marmota baibacina)
Because of the marmot’s importance to Mongolia’s
culture, economy, and ecology, this case study provides
more detailed information than the rest. In addition to
discussing population distribution and trends, the text
also provides background on taxonomy, habits, and
habitat to inform the discussion on hunting impacts,
and biodiversity conservation.
Taxonomy : Some controversy exists surrounding
the number of marmot species in the world, the
disagreement centering on the species occurring in
Eurasia. Some authorities count only three while
others as many as eight (Corbet 1978, Nowak 1999).
Following the systematics of Marmota presented in
Walker’s Mammals of the World (Nowak 1999) and
Adiya (2000), there are 14 marmot species worldwide,
of which 8 inhabit the Eurasian continent including
M. baibacina, M. bobak, M. camtchatica, M. caudata,
M. himalayana, M. marmota, M. menzbieri, and M.
sibirica (Corbet 1978; Hall 1981; Hoff man et al. 1979;
Hoff man et al. in Wilson and Reeder 1993).
Two of these species, M. baibacina (Altai marmot)
and M. sibirica (Siberian marmot or “Ta r vag ” or
Trans-baikal marmot) are found in Mongolia. e
most common of these two is the Siberian marmot
and, according to Russian and Mongolian scientifi c
literature, it comprises two subspecies—the Mongo-
lian mountain marmot (Marmota sibirica caliginosus,
Bannikov and Scalon 1949) and the Mongolian plains
marmot (Marmota sibirica sibiricus, Radde 1862).
e literature describes separate distributions for
each—mountain marmots inhabit higher mountains
and ranges in the Altai, Khangai, and Khuvsgul
regions and plains marmots occupy Mongolia’s vast
steppe and grasslands stretching from the far eastern
steppe to the Altai Mountains of the west. However, a
majority of the literature reviewed does not treat them
separately, subsistence hunters and fur traders do not
distinguish between them, and there are no genetic
studies confi rming this distinction. We therefore
discuss these sub-species in this text without separate
reference.
Legal and Conservation Status in Mongolia:
Hunting of any marmots was recently banned for two
years starting in 2005 through the end of 2006. Prior
to 2005, Mongolia’s hunting law allowed hunting
of Siberian and Altai marmots from August 10 to
October 16. Each hunter was allowed take three
marmots. In addition to the hunting season, the
law requires local governments to conduct surveys
every four years and gives them the authority to
close areas for the protection of the species. In areas
where industrial hunting takes place, surveys must
be completed on an annual basis and paid for by the
hunting company. e Mongolian Law on Fauna does
not regulate conservation of marmots. e Mongolian
Red List of Mammals (Clark et al. 2006) classifi es
the Siberian marmot as Endangered, and the Altai
marmot as Data Defi cient.
Legal and Conservation Status Worldwide: Neither
Siberian nor Altai marmot conservation is regulated by
international, multi-lateral or bi-lateral agreement. e
IUCN Red List (assessments in 1996) classifi es both
the Siberian and Altai marmots as Lower Risk/Least
Concern.
Summary: Marmots may be a keystone species and
are experiencing signifi cant declines across their
range in Mongolia, roughly 75 percent in the last 60
years (Eregdendagva 1972, Demberel 1997, Adiya
2000, Batbold 2002). ey are a traditional source
of protein, medicine, and fur, with annual fur trade
exceeding 1.2 million skins on average since the
late 1800s. Harvest volumes were estimated at 1-1.5
million in 1999 and over 3 million in 2004. Because
of their heavier coat, Altai marmot are the preferred
species in Mongolia’s fur trade, although their limited
range results in most marmot skins in Mongolian
trade coming from Siberian marmot.
Siberian m armot. Image: K . Olson
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
91
Figure 7: Siberian Marmot Distribution 1970
Source: Du lamtseren, S. 1970. Mongolia n Mammal Guideboo k. Ulaanbaatar,
Mongolia.
Habitat and Distribution (Marmota sibirica): Ty pi -
cal of marmot species, the Siberian marmot occupies
open grasslands, alpine meadows, pastures, and forest
edges (Nowak 1999). It may be found in Mongolia,
neighboring Buriyat, Tuva, southern Siberia, northern
China and Manchuria. (Adiya 2000, Nowak 1999). In
Mongolia, it occurs between elevations of 600-3,000
meters a.s.l. and occupies all but a small portion of
suitable habitat, (Demberel 1997). Its range extends
from the edge of the northern taiga forest regions
south through Mongolia’s steppe to the edge of the
Gobi desert; from the base of the Nomrog Mountains
in the east to the Altai Mountains in the west (Adiya
2000). Its distribution in Mongolia was fi rst mapped
in 1935 by Simokov, with updates in 1950 (Scalon and
Bannikov), 1954 (Bannikov), 1956 (Pavlov), and 1972
(Eregdendagva). e maps produced are extremely
small scale, making it diffi cult to compare or use them
as a reference to record changes in distribution. e
1970 distribution map shows an even distribution
over approximately 68 percent of Mongolia’s territory,
or roughly 1.07 million km2. In recent years, more
detailed surveys conducted in the eastern steppe region
show substantially reduced distribution over much
of the territory (Batbold 2002), with only 5 percent
of existing burrows now active and perhaps as few as
159,000 remaining in this region covering the aimags
of Dornod, Sukhbaatar and Khenti (Townsend and
Zahler in press). Anecdotal information suggests that
they have already disappeared from many areas where
they were once numerous.
Habitat and Distribution (Marmota baibacina):
e Altai marmot resides in high elevation alpine
meadows. It may be found in the northern Mongolian
Altai, and along the same mountain range in
southwestern Siberia, eastern Kazakhstan, Kyrgyzstan,
and Sinkiang (Nowak 1999, Adiya 2000). Mongolian
biologists record six main populations in the Altai
Figure 8: Percentage coverage map for marmots in Mongolia
Source: ada pted from Adiya, Ya., 2000.
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Mongolia
92
range covering an area approximately 1,000 km2 in
size and belonging to Bayan Ulgii and Khovd aimags.
(Amantai 1990, Adiya 2000). Although Kastschenko
recognized M. baibacina as a separate species as early
as 1899, distribution maps for the species in Mongolia
did not separate it from M. sibirica, noting only three
local populations (Bannikov 1954, Adiya 2000).
Distribution maps in the 1970s did not include even
this much detail.
Mongolia’s scientifi c literature distinguishes fi ve
loosely defi ned marmot distribution patterns based on
percentage of distribution coverage for 17 aimags in
Mongolia and makes no distinction between Siberian
and Altai species. According to the data summarized
by Adiya (2000), four aimags have populations occur-
ring throughout their territory—Arkhangai, Dornod,
Khentii, and Bayan Ulgii; an estimate that is at odds
with the distribution map in Figure 7. Another four
have 89.5 percent–94.1 percent coverage—Khovd,
Zavkhan, Khuvsgul, and Gobi Altai. Five aimags have
77.7 percent to 83.3 percent coverage—Bayankhongor,
Dundogovi, Ovorkhangai, Sukhbaatar, and Uvs.
Dornogovi and Tov have only 30 percent and 48.3
percent coverage respectively, while Omnogovi and
Selenge have no marmots. ere is some inconsistency
between the data for Dornogovi aimag presented in
Figure 8. Dornogovi shows 30–48 percent coverage,
but density data are missing. Recent survey results
indicate that these coverages are greatly reduced today
(Batbold 2002; Townsend and Zahler in press).
Habits: Siberian marmots are active approximately
six months of the year (one month longer than their
mountain relative the Altai marmot) beginning in
March, with hibernation starting sometime in Septem-
ber. Altai marmots fi rst emerge from hibernation in
April. Both species have an average lifespan of 10 years
and they take at least three years to mature. Breeding
age lasts seven years from ages 4-10. About half the
females breed in a given year and for Siberian marmots
litter sizes average 3-4 pups but may be as many as
12; one study recorded an average of 7 pups (Adiya
2000). Approximately 25 percent to 30 percent of the
pups do not survive the fi rst year with an estimated
reproductive capacity of 60 percent in the absence
of other factors, such as hunting, habitat conversion,
plague, or other disturbance. Due to intensive hunt-
ing, Mongolian scientists estimate actual reproduction
for Siberian marmots at only 20 percent. Altai marmot
litters, while large compared to Siberian marmots
(about six pups compared to three), suff er high fi rst
Figure 9: Marmot population declines 1940–1997
Source: Bat bold 2002; Adiya Ya., 2000.
1PQVMBUJPO&TUJNBUF
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
93
year mortality with less than 20 percent surviving the
fi rst year (Adiya 2000).
Population Trends: Typical of marmot species,
Siberian and Altai marmots live in fairly large colonies
and have recorded densities in Mongolia as high as
400/km2. In his thorough literature review, Adiya
(2000) notes some inconsistency in population survey
data and a lack of any standardized methodology.
Some surveys, for example, do not count juveniles
(not defi ned, but presumably marmots between 0 and
2 years of age) while others do, making the estimates
diffi cult to compare.
Despite these problems, the results over the last 60
years document a decline in total population size of
approximately 75 percent from a high of 40 million in
1940 (Eregdendagva 1972) to a low of just over 10 mil-
lion in 1997 (Demberel 1997) (Figure 9). One biologist
(Dash 1970) attributes the sharp decline between 1940
and 1970 to a sevenfold increase in agricultural land
use during that period. More likely, the precipitous
decline is related to the massive sustained marmot
harvests to supply the Russian army with meat and
furs during the same period. Mongolia is an arid
country with less than 1 percent of the entire country
suitable for agriculture, most of which is centered in
the Selenge river basin, an area that has never had very
many marmots. Even if all appropriate land had been
converted to agricultural production and all of that
land were suitable marmot habitat, the increases would
have aff ected less 2 percent of marmot habitat across
the country and does not adequately explain the 50
percent decline in the species during the same period.
e continuing decline from the 1970s to the 1980s
may be related to any number of factors including
extermination campaigns, inaccurate survey data, or
continued habitat conversion for agriculture. During
this period, a single authority controlled commercial
trade and reported take remained steady at roughly
1 million animals per annum. e sudden drop in
population from 1989-1991 corresponds in time
with Mongolia’s transition to a market economy and
is probably linked to increased reliance on wildlife
during that period, an increase in marmot fur values,
and collapse of management systems.
Take and Trade: Exported almost exclusively to
Russia from the 1920s to 1991, the bulk of marmot
fur trade now fl ows south to China, with a small
percentage continuing to arrive in Russia. Our study
Figure 10: Official Marmot Skin Trade in Mongolia 1892–1997
Source: Mo ngolian Academy of Scie nces, Institute of Biol ogy, Historical Trade Recor ds, 1926 –1984; Adi ya Ya., 2000.
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Mongolia
94
did not uncover any marmot fur trade with Japan or
Korea. Fur trade alone resulted in intense hunting
pressure at least as early as the 1890s and likely earlier.
Harvests in excess of 2 million animals happened on
several occasions since records were kept (1906-1910,
1927, 1929, and 1946-1954) with a record high 3.2
million animals taken in 1910. From the 1960s to the
late 1980s, harvest rates steadily decreased.
Since 1991, we no longer have reliable trade data.
Looking only at the enforcement record indicates that
harvest levels have consistently exceeded established
quotas. A hunting study conducted in 2002 observed
trade volumes in Siberian marmot skins in eastern
Mongolia that exceeded hunting quotas threefold.
Although the government issued 100,000 marmot
licenses, 88,000 marmot skins were found in the mar-
kets of just three towns in Mongolia in 2001, while in
that same year 200,000 skins were offi cially imported
to China from Mongolia (Scharf and Enkhbold 2002).
In 2003, just two seizures of illegal shipments into
China totaled 37,332 marmot skins. In 2005, despite
the ban, the Mongolian State Border Defense Agency
reports confi scating over 26,000 before the end of
August, just a few months after marmots emerged
from hibernation and still one month before the legal
hunting season would normally begin.
In each instance, confi scations and observed market
activity were undoubtedly only a small fraction of
the number of marmot skins that cross the border.
In 1999, the Eastern Steppe Biodiversity Project
estimated total harvest volumes between 1 and 1.5
million animals. Our study estimates 2004 harvest
levels at between 3 and 4 million. Mean harvest
levels for Siberian marmot hunters is 54 and for Altai
marmot hunters 46. Together, total harvest volumes
are between 3 and 4 million. International trade value
of one marmot skin averages $10, making this trade
worth $340 million.
However, marmot skin trade is only part of the picture
and is not exclusive of other forms of marmot trade.
All the parts sold on the local market can be and often
are sold separately from the skin. Local trade for meat
and medicinal parts is therefore additive to skin trade.
Prized for its meat, oil, fur, and medicinal properties,
subsistence hunting of marmots has likely been a
part of the Mongolian diet since well before recorded
history. Virtually all parts of the animal are consumed
(excluding the tongue) and are believed to be good
for several ailments including the general health of
heart, lungs, liver, and kidneys. Marmot oil has several
traditional uses including as a leather conditioner, to
treat burns, frostbite, anemia, tuberculosis, and as a
dietary supplement for animals and children. (Adiya
2000). Even though domestic livestock is abundant,
many Mongolians continue to harvest marmot as a
supplement to their diet.
Of the hunters questioned in the wildlife trade
survey, more than 60 percent said they hunt marmot.
is translates into an estimated 139,000 hunters
nationwide. Many more purchase marmot at local
markets or obtain products from friends and relatives
who hunt. Survey results show that 27 percent of
all Mongolians (445,000 people age 15 and older)
use marmot products in some form on a regular
basis. For the majority of these (85 percent, 370,000
people), the primary use is meat. Oil is the next most
important use at 5 percent, followed by kidney—3
percent, “khun” meat—2 percent, lung—1 percent
and stomach—1 percent. However, only 25 percent of
all consumers (110,000 people) obtain their marmot
products from hunter friends or relatives. e remain-
der either hunt it themselves, or purchase from a local
market, which means that local purchasers may be as
many as 160,000 across the country. On average, these
consumers spend $25 annually on marmot for a total
of $4 million in domestic marmot trade.
Harvest Sustainability: Even though there are no
recent surveys to determine the decline of marmots,
all circumstantial evidence points to a critical and
catastrophic decline across most of their range in
Mongolia. Besides the level of annual off take, the
other primary concern is the timing of the hunt,
which begins for the fur market as soon as the animals
emerge from hibernation sometime around mid-
March for Siberian marmot, and mid-April for Altai
marmot.64
Spring hunting is preferred by some hunters because
the fur is denser in the spring and therefore commands
a higher market price. e animals are also easier to
64 Hunting for meat and oil does not occur until after the animals
have gained suffi cient fat and pups weaned, usually beginning mid-
August.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
95
take at this time because they are hungry and must
spend longer periods of time outside their burrow to
feed compared to later in the season. However, spring
is also critical to the reproduction of the species. As
with all other members of this genus, Siberian and
Altai marmots have a single mating season per year,
beginning shortly after they emerge (Adiya 2000,
Armitage and Downhower 1974, Banfi eld 1974,
Godin 1977). Young are born anywhere from April to
June, fi rst emerge from the burrow after 1 month, and
are fi nally weaned 2 weeks later (Adiya 2000). Taking
females during this period removes them from the
reproductive capacity of the population and, for pups
already conceived, destroys any chance of survival they
may have. e potential impact is particularly severe
for Altai marmots that experience fi rst year mortality
rates already as high as 80 percent (Adiya 2000).
Without actual data, it is impossible to determine
the degree of impact this type of hunting is having.
However, employing some conservative numbers, a few
basic assumptions, and a highly simplifi ed calculus, we
can at least give some idea of the theoretical impact.
Using the 2004 hunting quota of 100,000 as a starting
point, what would be the impact on a population if
these animals were taken in the spring?
Regardless of the season, we would assume equal rates
of take for male and female marmots. We believe
this assumption is justifi ed for several reasons. First,
although the ratio of male to female in any given
population fl uctuates, it is typically 1:1 (Adiya 2000).
Second, one of the only ways to distinguish between
males and females is early in the year when males
are moving between hibernaculars and are therefore
more exposed. ere is no practical way to distinguish
between them simply by looking at them. Although
females are slightly smaller than males (Adiya 2000),
size alone is not an eff ective indicator. Younger yet
mature males may be of equal size. Further, we assume
that all animals taken are mature and capable of
reproduction. is assumption works only if we also
assume that all animals are taken by rifl e. Rifl e hunters
are capable of and do select for mature animals; trap-
pers of course do not. Hunters distinguish juveniles
by their overall size and the coloring of the tail (Adiya
2000). Hence, in this scenario taking 100,000 adult
marmots in any season is likely to result in the removal
of 50,000 females.
According to prior research, we know that mature
females in Mongolia do not always breed every year,
often skipping a year (Adiya 2000). Mongolian biolo-
gists estimate that only half of the mature females are
reproductively active in any given year (Adiya 2000).
us, we assume that of the 50,000 females taken in
the spring, 25,000 would either be pregnant or have
recently given birth. Using average birth and fi rst year
survival rates, we can estimate the number of off spring
potentially lost to the population due to a spring
hunt of this magnitude. Siberian marmots have litters
ranging from three to four pups and fi rst year survival
rates of 70 percent. Using a mean of 3.5 pups/litter,
we would expect 2.45 pups to survive from each litter.
Consequently, taking 25,000 reproductively active
female Siberian marmots would translate into the
elimination of an additional 61,250 animals above
and beyond the 100,000 taken by hunters; taking the
same number from an Altai marmot population would
eliminate an additional 30,000 (6 pups/litter, 20
percent fi rst year survival rate = 1.2 pups/litter).
e probable scale of out-of-season hunting is certainly
several times greater than what we have pictured
here. Even though Mongolia’s hunting law correctly
prohibits marmot hunting during this period, spring
hunting is common in many areas.
Other reats: Similar to other areas and marmot
species, Siberian marmots in Mongolia have reportedly
suff ered habitat loss due to agricultural production.
However, the total impact of habitat conversion
on Siberian marmots has likely been overplayed.
e coming of agriculture on any serious scale is
a relatively recent event in Mongolia’s history; the
plowing of large fi elds virtually unknown until the
1950s, long after marmot population declines were
already being documented. Agricultural production
is also concentrated in Mongolia’s Selenge river basin
where marmots have apparently never been numerous.
Increases in habitat conversion may have removed
some former strongholds but, with almost 70 percent
of the country considered suitable habitat, would have
represented an extremely small percentage of marmot
habitat overall. Since 1991, agricultural production
has declined sharply and much of the land previously
used has been left fallow, at least in theory allowing
Siberian marmot to regain some of its former territory
similar to experiences with M. bobac bobac in Eastern
Europe (Zimina and Gerasimov 1973). A longer-term
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Mongolia
96
and perhaps more realistic threat to marmots has been
the extermination campaigns waged against them
over the last hundred years to curb the risk of bubonic
plague. In recent years, however, neither habitat
conversion nor extermination campaigns can claim
serious impacts. A majority of agricultural land has
been left untilled since the early 1990s and extermina-
tion campaigns no longer target marmots. e only
real present threat comes from overhunting.
Impact on Biodiversity: Given the central role of
marmots in defi ning the landscape, creating shelter for
several species of bird and mammal, and providing a
source of protein for Mongolia’s carnivores, the serious
decline in marmot populations is likely to have an
impact on Mongolia’s biodiversity as a whole.
Marmots play an important role in the overall struc-
ture and health of the steppe and mountain ecosys-
tems they inhabit and as such, are likely a ‘keystone
species’. (Puzansky 2004, Zahler et al. 2004). ese
subterranean architects burrow into the ground
bringing soil to the surface, recycling nutrients, and
aerating the soil. eir burrows provide shelter for
many native species including long-tailed ground
squirrel (Spermophilus undulatus) and Daurian ground
squirrel (S. dauricus); Mongolian (Ochotona pallasi),
Daurian (O. dauurica), and northern (O. hyperborea)
pika; the least weasel (Mustella nivallis); ermine or
stoat (M. erminea); Eurasian badger (Meles meles);
hedgehogs (Hemiechinus spp.); foxes (Vulpes spp.); and
Pallas’ cats (Otocolobus manul). (Adiya 2000, Zahler
et al. 2004). eir selective feeding habits aff ect the
diversity and composition of vegetation. ey are also
an important food source for a number of raptors
and carnivorous mammals; e.g. eagles (Aquila spp.),
upland buzzard (Buteo hemilasius), gray wolf (Canis
lupus), snow leopard (Uncia uncia), foxes (Vulpes spp.),
steppe polecat (Mustela eversmanni) and brown bear
(Ursus arctos).
Regulation and Enforcement: Even though the
government has instituted a complete ban on marmot
hunting for two years beginning in 2005, without
amending the underlying legal framework the problem
will continue, as evidenced by marmot skin seizures
by the State Border Defense Agency in the summer of
2005 (>26,000). Looking at past reactions to hunting
limitations in the absence of active management, we
see only one basic response that is not likely to have
any serious impact on the actual number of animals
harvested – for the most part, offi cials will adhere to
the hunting ban and refuse to issue any licenses for
household consumption. Legally correct, the result
will be that household hunters will hunt without a
license—most of them do so anyway.
When the hunting ban fi nally ends, there will still be
the problem of adequately defi ning “household” and
“industrial” hunting. “Household” hunting is loosely
defi ned as the number of animals an individual may
take for personal consumption. For marmots, the
hunting law sets a limit of three (Scharf 2002, Win-
gard and Odgerel 2001). “Industrial” hunting does
not have a specifi ed limit, but it implies an organized
hunt by a registered company for strictly commercial
purposes (Wingard and Odgerel 2001, Zahler et al.
2004). Most hunters fall between the two categories,
hunting more than the three marmot “household”
limit but without crossing the legal threshold into
“industrial” hunting.
Siberian m armot. Image: K . Olson
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Wolf (Canis lupus)
Legal and Conservation Status in Mongolia:
Mongolia’s wolf population may be hunted for house-
hold and industrial purposes. ere is no season and
no quota limit. e Mongolian Red List of Mammals
(2006) classifi es the species as Near reatened.
Legal and Conservation Status Worldwide: Canis
lupus is recognized by CITES under appendix II of
the Convention, requiring export permits from the
country of origin. Although it still faces some threats,
its relatively widespread range and stable global
population trend mean that the species does not
meet any of the criteria for the threatened categories.
erefore, it is assessed on IUCN’s Red List as Least
Concern.
Distribution and Population Trends: Largest of the
wild individuals in the family Canidae, the gray wolf
was historically one of the most widely distributed
mammals in the world, ranging across the entire
northern hemisphere north of 15°N latitude. Hunting
and extermination campaigns (trapping, poisoning,
bounty systems) succeeded in extirpating the species
from many areas (most of western Europe, United
Wolves for sal e at a border market. Im age: K. Olson
States and Japan) and reducing its overall distribution
by about 30 percent. In the last 30 years, increased
legal protections (CITES, endangered species acts,
hunting restrictions), reintroduction programs,
land-use changes, and shifting human populations
from rural to urban areas have all helped stabilize
global declines and allowed some areas to be naturally
re-colonized (Nowak 1999).
Unfortunately, we can only guess at the total number
of wolves in Mongolia. No population studies have
ever been conducted to determine wolf population
densities, distribution, pack size, or range. In the
1970s, Mongolian biologists produced a map
describing widespread distribution covering the entire
country with no estimate of area-specifi c densities
or population numbers. National and international
experts believe the population has probably fl uctuated
greatly due to intense extermination and harvest
campaigns and point to indicators, if not actual proof,
of both past and present population declines. At least
once in the past (1976 to 1980), concerns over popula-
tion declines led to the banning of wolf hunting. Some
biologists believe the same may be happening now
because of extreme harvest numbers. However, we still
do not have any assessment of the population.
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98
Wolf pack home ranges and average pack sizes may
provide some clue to potential wolf numbers in
Mongolia, but have not yet been adequately studied in
Mongolia. Wolf home ranges typically correspond to
a defended territory and have little or no overlap with
neighboring packs. Home range size in combination
with average pack size can therefore be a useful tool in
estimating overall population numbers. Two projects
in Mongolia (WCS and International Takhi Group)
have managed to collar wolves and have started
tracking their movements. However, results are not yet
available.
For purposes of comparison only, the following
information describes wolf populations from other
countries. Worldwide, wolf home ranges vary consider-
ably and are directly linked to food availability, season,
and wolf population sizes. e largest home range for
one pack ever recorded was 13,000 km2 during the
winter in Alaska (Mech 1970). e smallest, at 18
km2, was in southeastern Ontario during summer.
Pack ranges in Canada and Kazakhstan were as little
as 30 km2 in areas with abundant food and cover and
as much as 1,000 km2 in desert or tundra regions
(Bibikov et al.1983).
Similar to home ranges, biologists have recorded vastly
diff erent densities for wolf populations around the
world. In Canada, for example, density levels varied
from as low as 1/520 km2 to 1/26 km2 (Fuller and
Keith 1980, Mech 1970). e highest recorded densi-
ties occurred on Isle Royale, where the wolf population
reached 1/10 km2 before experiencing a crash (Nowak
1999). Density estimates for Alaska are 4–5 wolves
per 100 km2 (Nowak 1999). Population densities in
Kazakhstan may be as low as 1.5 wolves/100 km2
(Dimitriyev 2005). For all populations, densities are
likely a function of many factors, but food supply
appears to be a main determinant (Peterson 1977).
Total wolf populations in Canada were estimated
at 30,000 to 60,000. In Alaska, scientists estimated
populations ranging between 4,000 and 7,000 (Car-
byn 1983, 1987; eberge 1991). According to Soviet
biologists, between 150,000 and 200,000 wolves
survived in the Soviet Union after World War II. is
dropped to around 15,000 by 1962 due to a govern-
ment control program that killed 40,000-50,000
every year for a 15-year period, but has rebounded
to an estimated 44,000 in 1999.65 A recent report
claims there are over 40,000 wolves in Kazakhstan;
an increase attributed to the cessation of government
sponsored hunting programs (Dimitriyev 2005).
Even assuming the highest possible wolf density ever
recorded, Mongolia’s total wolf population would not
exceed 157,000 wolves. At the wolf density rates for
Alaska of 3-5/100 km2, Mongolia’s wolf population
would be approximately 62,000.
Take and Trade: In Mongolia, wolves are targeted
by hunters because of livestock predation, perceived
threats to humans, for sport, and for a growing
domestic and international trade in wolf pelts for the
fur market and other body parts for the traditional
medicine market.
While still under Soviet tutelage, wolf hunting in
Mongolia was a function of government mandates.
Even though Mongolia was not offi cially a part of the
Soviet Union, it was certainly a part of the system,
and wildlife harvests generally followed Soviet models,
requirements, and trends. In Mongolia, wolves were
offi cially harvested to control numbers and provide
furs since at least the early 1920s (Figure 11). From
192 6 to 1985, offi cial wolf harvests averaged 5,308
animals with a peak harvest of 18,000 in 1933 and a
total trade volume of 313,153 in 55 years of recorded
trade. However, these are only the offi cial numbers.
Certainly, Mongolians hunted wolves in addition
to offi cial trade to protect livestock, for traditional
medicines, and killed pups during extermination
campaigns, none of which was ever recorded.
is compares to wolf extermination campaigns in the
Soviet Union that averaged 50,000 wolves annually
from the mid 1950s through the 1960s. According to
V.V. Kozlov, the USSR destroyed 42,300 wolves in
1945, 62,700 wolves in 1946, 58,700 wolves in 1947,
57,600 in 1948, 55,300 in 1949, and similar numbers
for the next two decades. Even though overall harvest
levels dropped in the 1970s, as they did for most
species, hunting never stopped completely and in the
1980s sobering harvests over 30,000 were recorded.
65 Wolf Cull Dilemma for Russia, Bounties Are Paid for Wolf Kills,
CNN News/December 2000.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
99
Mongolians have a special relationship to the wolf that
paradoxically spurs the hunt and yet in some ways has
probably forestalled its complete annihilation. On a
personal level, attitudes toward wolves in Mongolia are
the same as they are for any rural community depen-
dent on livestock for survival. e wolf is one of three
large predators in the country (snow leopard and lynx
are the other two) that prey on livestock and is there-
fore considered a direct threat to the Mongolian way of
life. In years past and in concert with the Soviet Union,
Mongolia declared the wolf an enemy of the state.
Unmitigated by an understanding of wolf ecology, the
ultimate goal during the communist regime was the
elimination of the animal. Today, the wolf is one of the
only animals in Mongolia for which there is a blanket
authorization to hunt without limit or season.
However, the taking of wolves in Mongolia is not
just a function of fear, competition, and government
mandates. Mongolians have a historic and cultural
relationship to the wolf that, while not ensuring the
wolf’s survival in the region, at least gives it a fi ghting
chance. e wolf is a mythical being believed to
possess great power, and virtually all parts fi nd some
use in traditional medicine. To the casual observer,
the fi erceness and suddenness with which Mongolians
will pursue and shoot a wolf can be easily mistaken as
an expression of aggression toward a feared and hated
animal. However, Mongolians hunt wolves with such
passion because of their traditional respect, even rever-
ence, for the wolf; its power, tenacity, and cunning. In
parts of Mongolia, it is still believed that no one can
see a wolf unless he or she is that wolf’s equal, and no
one can kill a wolf unless the wolf chooses to submit
and, in so doing, admits the superiority of the hunter.
Killing a wolf is thus celebrated because it confi rms
the hunter’s power and skill, not simply because it has
eliminated a dangerous threat. More important for the
survival of the species, the wolf is linked by legend to
the origin of all Mongolians, and when pressed, most
will say that the wolf should remain a part of their
landscape, albeit in controlled numbers. It is this belief
that led to the practice of leaving one or two pups
in wolf dens during state-sponsored extermination
campaigns in the Soviet era and probably prevented
more serious declines than otherwise experienced. It
remains to be seen whether history and tradition will
win against the market.
Even though numbers are no longer kept, this survey
indicates that the gray wolf has been and continues to
be important to Mongolia’s domestic and international
trade. In domestic trade, virtually all parts of the wolf
have value. e fur is considered one of the warmest
and a good wolf pelt sells for as much as $150; lesser
quality pelts sell for $50. Wolf meat is consumed as a
Figure 11: Official Wolf Skin Trade in Mongolia 1927–1985
Source: Mo ngolian Academy of Sci ences, Institute of Bio logy, Historical Trade Reco rds, 1926 –1984
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100
tonic against numerous ailments from the common
cold to asthma and goes for as much as $5 per kilo on
the market. Wolf bones, tongue, kidney, and spleen
complete the wolf’s pharmaceutical contributions and
bring an additional $50 to the purveyor. One gray
wolf is thus worth as much as $300 to $350 on the
market in Mongolia.
Internationally, wolf trade is almost exclusively with
China. Gray wolf carcasses, pelts, ankle bones, paws,
skulls, teeth, and trophies were common items in most
(64 percent) of the shops surveyed in 15 cities along
China’s border with Mongolia. Wolf pelts were openly
displayed and priced as high as $250 for good quality
and $35 for low quality. Teeth sold for $2 to $3 apiece.
Ankle bones ranged from $3 to $10. Paws had a price
tag of $6. Skulls were $5. Wolf carcasses commanded
a small price of $50 compared to mounted trophies
that sold for $375.
Given the market values and traditional medicine
practices in both China and Mongolia, and Mongo-
lians’ relationship to the wolf, it is not surprising that
it is the second most targeted species by hunters in
Mongolia. Of the 949 hunters surveyed throughout
the country, almost 40 percent (321) claim to hunt
wolves. Extrapolated out to the entire population of
hunters in the country (245,000), this means poten-
tially 75,000 hunters actively harvest the animal. e
adjusted mean take for these hunters was 3.4 animals
with the highest harvest being 100 animals for a
single hunter. Looking only at the hunter
respondents in the survey, at least 1,777
wolves were killed in 2004. Total harvest
volumes were diffi cult to estimate and are
likely the result of exaggeration on the part
of respondents. Without absolute certainty,
we believe it is possible that Mongolian
hunters may have taken at least 20,000-
30,000 wolves in 2004 with a potential
market value of approximately $7 million.
One market in Ulaanbaatar claims to have
sold 50,000 wolf pelts in 2004 alone. We
were unable to verify if all pelts were from
Mongolia or from the same year. Given that
Mongolia’s maximum carrying capacity for
wolves is likely to be somewhere between
50,000 and 100,000 based on estimates
from elsewhere, and the actual population
is very likely well below this, the current
level of off take is almost certainly unsustainable.
While we are unable to state with any clarity what the
true off take is for wolf in Mongolia, hunting levels ap-
pear to be highly unsustainable and evidence suggests
that the wolf in Mongolia is currently undergoing a
severe and precipitous decline in numbers. Circum-
stantial evidence points to localized disappearance of
wolves in areas of the Gobi and Eastern Steppe. While
herders have implied that wolf numbers are actually
increasing due to an increase in livestock losses in
some areas, this is more likely to be the result of loss of
wild prey in the area (e.g., marmot, red deer, gazelle),
which is forcing the remaining wolves to turn to
livestock for food.
Wolf canine s on sale in China. Imag e: J. Wingard
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
101
Corsac Fox (Vulpes corsac)
Legal and Conservation Status in Mongolia: Corsac
fox hunting for household and industrial purposes
is permitted by the Law on Hunting from October
21st to February 16th. In an apparent attempt to
limit corsac fox hunting, the Ministry of Nature and
Environment has not issued hunting quotas in recent
years. e Mongolian Red List of Mammals (2006)
classifi es the corsac fox as Near reatened.
Legal and Conservation Status Worldwide: e
IUCN classifi es the corsac fox as a species of Least
Concern (assessment in 2004). It has no special status
under CITES.
Distribution and Population Trends: e corsac
fox is a small canid adapted to arid landscapes and
ranges from northern Afghanistan to Tibet, through
Mongolia to northern Manchuria (Heptner and
Naumov 1992). It is a typical inhabitant of steppes
and semideserts; avoids forests, thickets, plowed fi elds,
and human settlements. V. corsac lives in burrows,
sometimes self-excavated, but often taken over from
other animals such as marmots or badgers. Its diet
comprises primarily small rodents, pikas, birds,
insects, and plant material. e mating season for V.
corsac is between January and March with a gestation
period of 50-60 days. Litter sizes are typically between
2 and 6 young at a time, with reported litters of up to
11 young (Nowak 1999). Other than humans, wolves
and large predatory birds are probably their only
serious enemy.
Despite its Asia-wide distribution, scientists know little
about the biology and ecology of this small carnivore
(Sillero-Zubiri et al. 2004). However, older studies
of wild and captive populations suggest that some
of its behavioral and ecological characteristics are
unique among fox species. For example, corsac foxes
are reportedly known to live gregariously in ‘corsac
cities’ that are composed of several adjoining den
complexes shared by multiple family groups (Murdoch
2005 citing Novikov 1962, Ognev 1962, Heptner and
Naumov 1992). Corsac foxes have also been described
hunting in small packs (Dinnik 1914, Ognev 1962,
Stroganov 1962), migrating during periods of low
prey abundance, and exhibiting large population
fl uctuations (Ognev 1962, Heptner and Naumov
199 2). ese accounts, however, are largely based on
Corsac fox . Image: Dr. Richard Read ing
anecdotal observations and it is unclear how accurate
they are. Most quantitative information on the species
is from hunting records and taxonomic studies. Details
of the species’ fundamental biology (i.e., ranging
behavior, diet, or basic social organization) or habitat
requirements are few (Sillero-Zubiri et al. 2004).
e corsac fox is probably most similar to the kit fox
(Vulpes macrotis) and swift fox (V. vel ox) of North
America, small species that are also arid adapted,
depend on underground dens often “borrowed” from
other burrowers, make use of multiple dens during
the year, and exhibit large population fl uctuations at
least partly in response to interaction with humans.
For example, the swift fox was driven to extinction
in Canada by 1928 and declined by up to 90 percent
across the US prairie grassland during the last century,
primarily due to a combination of general predator
control eff orts, direct hunting for fur, and habitat loss.
Take and Trade: Corsac fox has been a staple source
of fur in Mongolia for many years. Of the larger
mammals traded for their fur, only marmot and roe
deer were ever traded in greater volumes. From 1932
to 1972, more than 1.1 million corsac fox furs were
sold to the Soviet Union with a peak trade of 62,926
in 1947. In 1973, concerns that harvest levels had been
unsustainable for many years caused the Mongolian
government to ban trade in corsac fox furs. It was
never reinstated under the communist system.
In the 1990s, Mongolians once again started harvest-
ing this small carnivore to sell on the international
market. With the shift in government, trade went
primarily south to China along with virtually all other
forms of wildlife trade.
At $28, corsac fox skins are substantially more
valuable than red fox skins ($18). Spurred by rapidly
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Mongolia
102
Figure 12: Official Corsac Fox Fur Trade in Mongolia 1932-1985
Source: Mo ngolian Academy of Sci ences, Institute of Bio logy, Historical Trade Reco rds, 1926 –1984
increasing prices, corsac foxes have also been harvested
in greater numbers than almost all other species
with the exception of marmot and red squirrel.
Approximately 12 percent of hunter respondents to
the wildlife trade survey actively harvest the species.
We estimate over 25,000 hunters across the country
participate in corsac fox trade. Likely stemming from
their comparatively higher market value (and the fact
that they live at higher densities and are less shy than
the red fox), adjusted mean harvests per hunter for
corsac fox (10.2) are more than twice what they are for
red fox (4.7/hunter). e maximum harvest for one
hunter was 100 animals in a single year. Total harvest
estimates for 2004 are 200,000 with an international
fur market value exceeding $5.6 million.
Adding to this trade, at least in cash value if not
total harvest volumes, is the little known domestic
market for corsac fox game meat, purported by some
respondents to the survey to have medicinal properties.
Purchased in small quantities for relatively high prices,
one corsac fox is worth approximately $37 just for
its meat. Because the skin is sold separately from the
carcass, one corsac fox in Mongolia can be worth as
much as $65 to the enterprising hunter. Response
numbers from the survey were too low to make an
accurate estimate of the total trade volume of V. corsac
game meat.
Overhunting, coupled with habitat disturbance, has
caused the corsac fox to disappear from much of its
historic range (Ognev 1962, Stroganov 1969). e
current level of trade in Mongolia has the potential
to similarly impact the species. is study estimates
total trade at more than twice the annual volume
that caused the Mongolian government to institute a
hunting ban in the 1970s. e lack of hunting quotas
is a signal, if not an eff ective management tool, that
concerns over dwindling populations will again make
hunting bans necessary to prevent extermination of
the species.
Hoping to generate more revenue from the resource,
the Mongolian government has established trophy
hunting rates for corsac foxes. A single trophy license
sells for $100 (MNE 2004). Not typical of trophy
species, our research and inquiries were unable to fi nd
any hunts currently being off ered. If other trophy
hunting off ers in Mongolia are any indication, corsac
fox (if it is ever marketed) will probably be taken as
part of hunts for larger trophy animals and will thus
be incidental to the main excursion.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
103
Red Fox (Vulpes vulpes)
Legal and Conservation Status in Mongolia:
Red fox is an “abundant” species under the Law
on Hunting and may be hunted for household and
industrial purposes from October 21st to February
16th. Although hunting has not yet been banned, no
hunting quotas have been set in recent years. Trophy
hunting is permitted pursuant to special permit, which
may be purchased from the Ministry of Nature and
Environment for $100. It is classifi ed as Near reat-
ened in the Mongolian Red List of Mammals.
Legal and Conservation Status Worldwide: Vulpes
vulpes is not listed by CITES in any appendix. IUCN
assessed it as a species of Least Concern in 2004.
Distribution and Population Trends: Rivaling the
gray wolf, the red fox has one of the widest natural
geographical distributions of any living mammal,
ranging throughout the temperate regions of Europe,
Asia, and North America (Nowak 1999, Wilson and
Reeder 1993, Sillero-Zubiri et al. 2004, Murdoch
2005). Habitats vary from forest to arctic tundra, open
grasslands, and farmland, but typically the species pre-
fers areas with highly diverse vegetation (Ables 1975).
In Mongolia, V. vulpes can be found throughout the
Red fox in Ik h Nart Nature Reser ve. Image: Dr. Richard R eading
country inhabiting a diverse range of habitats from the
arid Gobi to the northern taiga (Ognev 1962, Heptner
and Naumov 1992), but apparently avoiding open
habitat with little relief or dense vegetation. In contrast
to corsac foxes, red foxes typically maintain one den
and one or more emergency burrows within their
home range. Generations of foxes may use the same
den. Red fox studies in Asia indicate they are general-
ist predators and opportunistically feed on animals
ranging in size from steppe voles (Microtus brandti)
to tolai hares (Lepus tolai) to newborn domestic sheep
and goats (Ognev 1962, Heptner and Naumov 1992).
e competitive relationships between red foxes and
other carnivores is important to conservation. Red
foxes are adept competitors and known to exclude
smaller sympatric carnivores in some regions. In Fen-
noscandia (Norway, Sweden, Finland), for example,
red foxes are known to kill arctic foxes (Alopex lagopus)
and exclude them from optimal breeding habitats
(Tannerfeldt et al. 2002). Researchers also suggest
that the southern limit of arctic fox range is largely
determined by interspecifi c competition with the red
fox (Hersteinsson and Macdonald 1992). In Mongolia,
red foxes undoubtedly compete for resources with
the smaller corsac fox. Heptner and Naumov (1992),
for example, report that interference competition
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Mongolia
104
occurs between the species as red foxes kill corsac
foxes during encounters. In open habitats, where
competition between species that interact aggressively
can be intensifi ed (Creel et al. 2001), understanding
the degree of competition and the mechanism of
coexistence between corsac and red foxes will be useful
for conservation eff orts (Murdoch 2005).
Knowledge of red fox abundance and regional ecology
will also be important to conserving the species in
Mongolia (Murdoch 2005). So far undetermined
in Mongolia, it is possible that the country supports
red fox populations approaching 1 million animals.
Studies have shown that population densities for red
foxes in the most favorable areas average one or two
adults per square kilometer (Ables 1975, Haltenorth
and Roth 1968), however, home range sizes vary
with habitat conditions and food availability (Ables
1975). Under natural conditions, home ranges average
1–10 km2, but can be as small as 10 ha. in suburban
landscapes (Grzimek 1990). Similar to the gray wolf,
red foxes have defended home ranges having little
overlap with other individuals (Storm and Montgom-
ery 1975). One home range is typically occupied by a
breeding pair, sometimes one male and two females,
and their young.
Take and Trade: Red foxes are an important
economic species in Mongolia with annual fur trade,
past and present, running closely behind corsac fox
trade. Historic trade volumes averaged almost 18,000
animals per annum from 1932 to 1972, compared
to 19,500 corsac foxes annually for the same period.
Total trade was slightly more the 1 million skins over
40 years (Figure 13). Offi cial red fox trade peaked
20 years later than corsac fox trade (1967) and never
breached the 50,000 mark before coming to an offi cial
close in the early 1970s.
In tandem with corsac fox harvests, the 1990s saw
renewed hunting for red fox fur that likely became
signifi cant with the relaxation of gun ownership laws
in 1995. At the same time, newly opened border
crossings along Mongolia’s southern border with
China provided numerous access points to a formerly
closed market.
At $18 per pelt, red fox skins are roughly two-thirds
the value of corsac fox. However, a wider distribution
and possibly greater numbers result in a larger popula-
tion of hunters targeting them. Just over 28 percent of
all hunter respondents spread over much of Mongolia
Figure 13: Official Red Fox Fur Trade in Mongolia 1932–1985
Source: Mo ngolian Academy of Sci ences, Institute of Bio logy, Historical Trade Reco rds, 1926 –1984
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
105
claim to harvest red fox and almost 100 percent sell
their skins to the Chinese market. Survey results
calculate over 44,000 hunters involved in red fox
harvests. In contrast to corsac fox, however, individual
hunters take far fewer animals on average (4.7/hunter)
resulting in slightly smaller overall harvest rates for
red fox. e maximum reported harvest for one
hunter was 100 animals in a single year. Total harvest
estimates for 2004 are 185,000 with an international
fur market value of over $3 million.
Red foxes have also been included in Mongolia’s eff orts
to increase sport hunting revenues. e same price set
for corsac fox applies to red fox trophy permits—$100.
e total potential value of fox trophy cannot be
estimated as no known hunts have yet been off ered or
advertised. However, supplemental services associated
with trophy hunts often generate 10 to 20 times the
cost of offi cial permits.
Unlike corsac fox, which has some additional domestic
value for the medicinal properties of its meat, domestic
trade red fox is limited to fur for hats and coats. e
overall volume of domestic trade is almost negligible
relative to international trade. Fewer than 2 percent of
all respondents from the survey purchase red fox skin
at local markets in Mongolia.
Red fox. Ima ge: Luke Distelhorst
Siberian Roe Deer (Capreolus pygargus)
Legal and Conservation Status in Mongolia:
A traditional source of meat, medicine, and fur,
Mongolia’s roe deer may be hunted for household
consumption from August 1st to December 1st. A
standard permit allows the hunter to take one animal
per year. Foreign sport hunters may hunt the species
pursuant to a special permit priced at $900 and issued
by the Ministry of Nature and Environment. ere is
no restriction on age, size, or sex. No known quotas
issued. e Mongolian Red List of Mammals (2006)
classifi ed the species as Least Concern.
Legal and Conservation Status Worldwide:
Considered a common species, IUCN lists C. pygargus
as Lower Risk/Least Concern; the last assessment
was in 1996. It is not listed in CITES, or in other
international agreements.
Distribution and Population: Capreolus pygargus
occurs from the Don River to southeastern Siberia,
Korea, and as far south as central China. Common in
many parts of Mongolia, roe deer can be found almost
anywhere that off ers cover including forests, sparsely
wooded valleys, open fi elds, and agricultural areas
(Olson et al. 2004).
No population studies have ever been done for C.
pygargus in Mongolia. In general, members of this
species live alone or in small groups, but herds of
Siberian r oe deer. Image: WWF M ongolia.
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as many as 100 have been documented at favorable
feeding sites or in migration (Hewison, and Danilkin
2000). During the spring, when Capreolus lives alone
or in doe-fawn pairs, both male and female adults
establish defended territories that range in size from
7-25 ha for males and 3-180 ha for females. is
defended territory represents only a portion of the total
home range, with spring breeding ranges for males
as large as 170 ha and covering as much as 500 km
during seasonal migrations recorded in Russia. Unlike
many other deer species, most males will usually escort
only one female (Nowak 1999).
Take and Trade: From 1950 to 1973, Mongolia
traded roe deer skins with Russia. For several years
trade volumes exceeded 100,000 skins annually
and averaged more than 87,000 for the 23 years of
recorded trade. However, because of declining popula-
tions, trade volumes decreased rapidly beginning in
1965 and were eventually stopped in 1974, never to be
restarted as offi cially sanctioned trade. Today, there
is no apparent international trade for roe deer meat,
antlers, or other parts (Figure 14).
Domestic harvests and trade have stepped in to replace
the former international trade with volumes that
equal and may even exceed historic records. e 2005
wildlife trade survey results place roe deer seventh in
the list of most targeted species in the country with
roughly 12 percent (112 of 949 hunter respondents)
of hunters in the northern forested regions engaged
in the harvest. We estimate that 34,000 Mongolians
actively hunt the species. Total take in 2004 for the
112 roe deer hunters queried during the study was
491. Adjusted mean take per hunter was 2.7 with the
highest reported take at 50 animals for a single hunter.
We estimate an annual harvest exceeding 100,000,
a volume that approximates offi cial trade volumes
recorded in the 1950s and 1960s.
Harvesting roe deer is primarily for personal
consumption for meat (96 hunters of 112, or 86
percent), with the remainder also harvesting for the
medicinal properties of its blood, liver, and oil. No one
interviewed during the wildlife trade survey reported
using or selling roe deer antlers. One roe deer yields
approximately 20 kg of meat and at 2.7 per hunter
provides roughly 60 kg of game meat, or 25 percent of
an average Mongolian family’s meat intake for the year
(based on average family size of 4). Hunters take the
species in the fall for game meat, liver, and oil. In the
spring, the animal is also hunted for its blood, which
Figure 14: Official Roe Deer Trade in Mongolia 1950–1985
Source: Mo ngolian Academy of Sci ences, Institute of Bio logy, Historical Trade Reco rds, 1926 –1984
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
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hunters consume fresh after the kill, believing it cures
liver ailments and makes the user’s blood “rich.”
Eleven percent (12 of 112) of the roe deer hunters
interviewed said they sell roe deer meat and other
parts to local markets. Because the trade survey was
conducted during the summer months, surveyors
did not observe any trade in roe deer meat or other
perishable parts. Only one domestic market located in
Sukhbaatar Aimag (eastern Mongolia) reported selling
a small quantity (9) of roe deer skins at $6 apiece.
Contrary to the observed trend for other species (i.e.,
marmot), the mean take for commercially motivated
harvests was signifi cantly lower at 2.7/hunter than
the mean take for subsistence purposes (6.6/hunter).
One explanation for this diff erence is the degree of
informal trade associated with the species. Of the
respondents who do not hunt but still use roe deer
meat, the majority (75 percent) obtains them directly
from hunters they know and not the market. is
compares to only 25 percent of marmot users whose
supply comes directly from hunters. In other words,
while some hunters take numbers (20-50 animals, or
400 to 1,000 kg of meat) clearly greater than personal
consumption warrants, these harvests are not refl ected
in our analysis of commercial harvests because the
same hunters reportedly do not sell them even though
they may trade them to non-hunters for other goods.
A number of companies off er sport-hunting trips that
include Mongolia’s roe deer. e Siberian roe deer
in Mongolia is larger than its counterpart in Europe
(Capreolus capreolus), making it a viable trophy animal
in its own right. Trip costs start at around $4,500
depending the number of trophies included and length
of stay.
Brown Bear (Ursus arctos)
Legal and Conservation Status in Mongolia:
Mongolia’s wildlife legislation distinguishes between
brown bear (U. arctos pruinosus) and Gobi bear (U.
a. gobiensis—“mazaalai” in Mongolian). e brown
bear has no protected status and may be hunted
for household purposes from October to February.
Mazaalai is listed as “very rare” in the Law on Fauna,
and the Mongolian Red List of Mammals (2006) clas-
sifi ed the species as Critically Endangered. All hunting
of this subspecies is prohibited. While the brown bear
is hunted as a trophy animal in neighboring parts of
Russia, this survey did not fi nd any advertised hunts,
nor has the Ministry of Nature and Environment
established a trophy hunting fee for the species. e
Mongolian Red List of Mammals (2006) classifi ed the
brown bear as Data Defi cient.
Legal and Conservation Status Worldwide: Ursus
arctos is generally listed in CITES Appendix II,
although some subspecies and populations (like those
in Mongolia) are included in Appendix I. Mongolia
has never issued an export permit for brown bears
occurring in its territory. Mazaalai are also covered
under Appendix I.
Distribution and Population Trends: e brown
bear has one of the greatest natural distributions of any
mammal in the world, occurring throughout northern
Asia, Europe, and North America (and previously
Gobi bea r. Ima ge: WWF Mongoli a
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108
also in northern Africa). Historically the brown bear
ranged throughout the region north of approximately
35º latitude, but often extending further southward
along a number of mountain chains.
In Mongolia, the brown bear occurs primarily in the
northern taiga forest zone in the north-central aimags
of Selenge, Khentii, and Khuvsgul. A small pocket
of bears, numbering between 20–40, lives isolated
in the Gobi Desert and is considered by some to be a
separate subspecies (McCarthy 1999). According to
a Mongolian Institute of Biology report from 1986
(General and Experimental Biology Institute 1986),
there were about 500 brown bears in Mongolia
inhabiting 50,000 km2, or approximately 1 bear for
every 100 km2. is compares to reported population
densities in neighboring Lake Baikal of 1 bear per 60
km2, and the Carpathian Mountains of 1 bear per 20
km2. Brown bears have greater population densities in
areas with greater food resources such as the coastal
regions in Alaska and in Russia’s Kamchatka peninsula
where salmon is plentiful.
Take and Trade: Since 1986, no population surveys
have been performed for brown bears in Mongolia.
However, circumstantial evidence suggests that the
number of brown bears and their distribution in Mon-
golia have declined sharply since the early 1990s. Most
likely, this is a result of illegal hunting and increased
demand for bear body parts in the medicinal trade.
Survey results show hunting activity restricted to the
northern-forested region of Mongolia, which coincides
with brown bear habitat in the country. Researchers
did not uncover any incidents of poaching Gobi bears,
found exclusively in Mongolia’s southwestern Gobi
Desert region.
While many reports cite the growing international
trade in brown bear gall bladders (TR AFFIC 1995),
this survey discovered that the domestic market
in Mongolia might be similarly important. Bear
parts can be found at domestic markets, such as the
Ulaanbaatar’s black markets, central train station, or
in container shops that deal in wildlife products. Bear
products traded domestically include the meat, kidney,
gall bladder, oil, and paws. Bear meat is a source of
protein, while the oil, kidney, gall bladder, and paws
are used in traditional medicine. e brown bear has
also not escaped the growing interest in hunting as a
Gobi bea rs. Image: WWF Mo ngolia
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
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sport in Mongolia, but is not yet marketed by hunting
tourism operators.
Not including potential sport hunting values, one
brown bear has a total potential domestic market
value of over $1,300. A set of four paws can be sold for
$100; a bear gall-bladder sells for $250–300, the skin
is worth $200–300; bear meat can be purchased for
$1.50/kg (an average bear yields approximately 300 kg
of meat66); and bear oil is sold for $1.00/kg (Table C3).
Although many parts of the brown bear are used in
traditional Chinese medicine, international trade in
brown bear parts from Mongolia appears to be almost
entirely focused on gall bladders with no recorded dif-
ference in market values between China and Mongo-
lia. e bear gall bladder is a cornerstone in traditional
Chinese medicine used for treating cancers, burns,
pain and redness of the eyes, asthma, sinusitis, pain,
and liver disease. Researchers observed some brown
bear skins in markets on China’s northern border, but
the age of these trophy furs suggested that active trade
was minimal. In an October 2004 UB Post newspaper
article (Anonymous 2004a), it was reported that three
Vietnamese nationals were captured attempting to
smuggle 80 bear gall bladders out of Mongolia. Even
if this were the only smuggling eff ort involving brown
bear parts, it is still likely a sizeable fraction of the
brown bears left in Mongolia. Traders interviewed at
the Tsaiz market admit to some intermittent trade in
gall bladders, but were unable to confi rm if these were
coming from Mongolia or Russia. No gall bladders
were observed in surveys conducted in Mongolia,
Russia, or China; this may be because gall bladders are
traded in small quantities and are easily concealed.
Part of the problem with controlling gall bladder trade
is the lack of a domestic ban on trade in either China
or Mongolia. Domestic markets in both countries
remain open and easily feed the international black
market even though CITES bans international trade
in this sub-population of brown bear. us, the only
obstacle to trade is the international border, which
presents no real problem to traders.
Moose (Alces alces p zenmayeri
and A. a. cameloides)
Legal and Conservation Status in Mongolia:
Mongolia has two subspecies of moose, Alces alces
pfi zenmayeri and A. a. cameloides. Both are listed in
the Law on Fauna as Very Rare. e Law on Hunting
makes no distinction between the two subspecies
and limits hunting to scientifi c purposes only. e
Mongolian Red List of Mammals (2006) classifi es
both subspecies as Endangered.
Legal and Conservation Status Worldwide: In 1996,
the species A. alces was classifi ed by IUCN as Lower
Risk/Least Concern. A separate assessment was also
performed in 1996 for the subspecies A. a. cameloides,
classifying it as Lower Risk/Near reatened. ere
was no separate assessment for A. a. pfi zenmayeri,
which is considered common. Neither the species or
either of the subspecies is listed in CITES.
Distribution and Population: e largest member
of the deer family, the species A. alces historically
occurred from northern Europe to the Caucausus
to eastern Siberia and Manchuria, and from Alaska
throughout Canada to Northern Colorado and the
northeastern United States. Of the six subspecies of A.
alces in the world, two make their home in Mongolia;
66 Bear weights vary depending on the time of year. Bears weigh
the least in the spring or early summer. ey gain weight rapidly
during late summer and fall. At this time most mature males weigh
between 180– 410 kg. with extremely large individua ls weighing as
much as 640 kg. Fema les weigh half to three-quar ters as much.
Ussurian moo se in Nomrog Strictly Pro tected Area, Sukhbaa tar aimag,
Mongoli a. Branched antler s just visible bet ween trees. Image : Chadd
Fitzpatrick
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Mongolia
110
A. a. pfi zenmayeri (Yakut moose) and A. a. cameloides
(Ussurian moose).
e Yakut moose is similar in size to the North
American moose. A good set of antlers can span over
100 centimeters and bulls can weigh over 500 kg. e
Yakut can be found from the Yenisei River in Siberia
to northern Mongolia. In Mongolia, A. a. pfi zenmayeri
occurs in the northern boreal forests, preferring moist
areas with abundant willows and poplars. is habitat
type comprises roughly 8 percent of Mongolia’s total
territory, or 125,000 km2.
A. a. cameloides, or Ussurian moose, is similarly
sized but physically distinct from A. a. pfi zenmayeri,
sporting small branched antlers rather than large
palmate ones. Little is known about the subspecies A.
a. cameloides other than that it occurs in Mongolia’s
eastern Nomrog Strictly Protected Area, with
populations in neighboring Manchuria. Nomrog SPA
is situated at Mongolia’s far eastern edge where vast
expanses of grassland fi nally give way to the Khyangan
Mountains. e protected area covers 311,205 ha,
one-fi fth of which is forested and provides habitat for
A. a. cameloides. A 2004 WCS survey of ungulates
in Nomrog SPA came up with a rough population
estimate of 73 Ussurian moose in the protected area
(Fitzpatrick pers. comm.).
Males and females are sexually mature at two years of
age, but full growth potential is not reached until 4 or
5 years of age. At that age, females are at their repro-
ductive peak. e mating season begins in September
and lasts until October. Females give birth in the
spring (May-June) following an eight-month gestation
period (Franzmann,1981, Wilson and Ruff 1999)
Population surveys of moose have never been com-
pleted in Mongolia, and it is diffi cult to extrapolate
possible numbers based on other regions. Worldwide,
population densities vary from 0.1/km2 to 1.1/km2,
but may reach as high as 200/km2 in local areas.
Population estimates suggest there may be as many as
1 million moose in Eurasia (Nowak 1999).
Take and Trade: is survey and literature review did
not discover any international trade for moose meat
or parts from Mongolia. ere are also no historical
records for international trade in the species. However,
despite clear legal restrictions both subspecies receive
Hunting of mo ose for subsistence pu rposes. Image: K . Olson
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
111
hunting pressure for personal consumption, domestic
wild game trade, and from sport hunters as a trophy
animal.
Even though the number of respondents is too low
to estimate the total number of moose hunters and
harvest volumes in the country, the wildlife trade
survey documented both subsistence hunting and
a domestic market for moose meat. Of the more
than 4,000 people interviewed during the survey,
only three reported hunting moose in 2004. ese
three respondents were all from Khuvsgul aimag, a
boreal forest region in north-central Mongolia, and
reported taking 2 animals per year. One of the hunters
interviewed explained that he sells moose meat at the
black market in the local soum center. One moose can
provide as much as 200–300 kg of meat, enough to
feed a Mongolian family of four for one year. Average
meat prices in Mongolia are approximately $2 per kg
making one moose worth as much as $400–600 for
the game meat alone, an income equal to one year’s
salary in rural Mongolia.
e Tsaatan (or Dhuka) reindeer people residing in an
area to the north and west of Lake Khuvsgul are noted
for pursuing Yakut moose as an important source of
protein in their diet. However, the increasing harvest
of moose and other wildlife in the area is having a
serious impact on their traditional way of life. As
populations of wild game decrease, the Tsaatan have
no choice but to consume the reindeer herds upon
which they are primarily dependent for survival (K.
Olson pers. comm.).
In addition to domestic hunters, international sport
hunters are also targeting the resource. Legal restric-
tions notwithstanding, several national and interna-
tional hunting tourism companies market moose hunts
in Mongolia on the Internet. Surprisingly, one com-
pany based in Russia even off ers moose hunts in the
Gobi Gurvan Saikhan National Park where hunting of
any kind is prohibited (www.irkutsk-baikal.com) and
where no moose are known to occur. Another article
reports that “[o]f the few Yakut moose hunted by
Americans, many have come from Mongolia, probably
taken incidentally on hunts for other game, such as
sheep.” (McIntyre 2004). A market visited by the
survey team in Songin Khairkhan soum (north-central
Mongolia) had a moose trophy on display with a price
tag of $500.
Snow Leopard (Uncia uncia)
Legal and Conservation Status in Mongolia:
Classifi ed by the Mongolian Red List of Mammals
(2006) as Endangered. e species is also listed in the
Mongolian Law on Fauna as “very rare” pursuant to
parliamentary approval in 1994. e Mongolian Law
on Hunting prohibits subsistence and commercial
take, but allows hunting for scientifi c purposes.
Poaching is subject to criminal penalties under the
Mongolian Criminal Code and civil penalties under
the Law on Hunting.
Legal and Conservation Status Worldwide: Listed
in the IUCN Red Data Book as Endangered and on
Appendix I of the Convention on International Trade
in Endangered Species of Fauna and Flora (CITES),
which include species considered threatened with
extinction. e IUCN Species Survival Commission
Cat Specialist Group assign the snow leopard a Global
Vulnerability Ranking of Category 2 (highly vulner-
able) and actively threatened due to hunting.
Distribution and Population Trends: e snow
leopard’s range is restricted to the mountainous
regions of Central Asia including the Altai, Tien
Shan, Kun Lun, Pamir, Hindu Kush, Karakoram,
and Himalaya ranges. It is known to occur in twelve
countries, including Afghanistan, Pakistan, India,
Nepal, China, Bhutan, Mongolia, Russia, Tajikistan,
Uzbekistan, Kazakhstan, and Kyrgyzstan, with occu-
pied habitat of between 1.6 and 2.0 million km2. Snow
leopards most frequently occur at elevations between
2,000 and 5,500 m, in areas of steep and broken rocky
slopes that support shrub, grass, or steppe vegetation.
In the northern limits of their range, in Mongolia
and Russia, they may use elevations as low as 600
m in relatively fl at terrain, and occasionally occur in
forested habitat. Range-wide, population estimates
vary from 3,500 to 7,500.
Snow leopards are widely distributed in the mountains
of western Mongolia and occur in the Altai Moun-
tains, the Khangai Mountains, the Khan Khukhii Uul
and Kharkhyra ranges, and in isolated mountainous
sections of the Trans-Altai Gobi. ey are thought to
occur in up to 10 aimags and 107 soums with a total
range of about 100,000 km2. Population estimates
vary from about 800 to 1,700 animals. Highest
densities are thought to be in the South Gobi, Central
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Mongolia
112
Trans-Altai Gobi, and Northern Altai. Remnant
populations occur in the Khangai and possibly
Khuvsgul, although no snow leopards have been
sighted in the latter area since the 1960s, coinciding
with the near disappearance of argali and ibex from
the same region.
Take and Trade: Despite being aff orded complete
protection in Mongolia, illegal hunting is an
ongoing problem of unknown magnitude. ere
are three incentives to poaching: 1) a high value on
the international market (primarily for fur, but also
bones), 2) the need to protect livestock from depreda-
tion, and 3) for the meat, which is believed to have
medicinal properties. Although the illegal kill has
been estimated at more than 100 animals per year,
there is no clear method for calculating more than a
minimum estimate. During the 2005 wildlife trade
survey in Mongolia, only one individual reported
hunting snow leopards for the fur trade. Another
three individuals admitted harvesting the animal for
medicinal purposes. Poaching for commercial reasons
may be on the rise as trade with China increases,
particularly at border stations where law enforcement
is more diffi cult. Researchers in China uncovered 13
fresh snow leopard skins from Mongolia in one of
China’s northwestern border towns in 2005. e value
of snow leopard bones on the Asian medicinal market
will likely continue to make this an attractive activity
for poachers and traders. e recent rise of the middle
class in the Tibet Autonomous Region has led to a
sharp increase there in illegal traffi c of big cat skins
(including snow leopard), which have long been used
in traditional clothing. An increasing demand for pelts
in Eastern Europe may also be driving prices up for
snow leopard hides in Russia, which will make trade in
that direction, and cross-border poaching, an escalat-
ing concern. In the summer of 2005, Russian border
guards uncovered 15 snow leopard skins apparently
taken from Mongolia’s North-Altai region. According
to sources in Mongolia and China, snow leopard pelts
are sold for as much as $250 per meter length, with
good pelts measuring over 2 meters from head to tail.
Retaliatory killing of snow leopards by herders who
have experienced livestock losses is diffi cult to quantify
and only a small fraction of kills are made known to
authorities. Information campaigns by the Interna-
tional Snow Leopard Trust and other organizations,
along with more focused enforcement action by the
government and WWF-sponsored anti-poaching units
appear to have had at least some impact. Of more than
1,000 herders questioned during the survey who live
in snow leopard habitat, all were aware of the snow
leopard’s protected status. None, however, claimed to
kill snow leopards in retaliation for livestock depreda-
tion, although this is a well-documented problem in
the country. Snow leopards may take horses, yaks,
and camels more readily than small livestock because
large stock is often allowed to roam untended in areas
where leopards occur. e economic impact of snow
leopard depredation can thus be substantial to an
individual herder, despite the fact that, overall, herders
in snow leopard range lose a very small percentage
of their herds to the cat. Snow leopards are not easily
hunted in the wild, but can be relatively easy to shoot
or trap when they are on livestock kills. Because most
herding in snow leopard range is conducted far from
towns, kills of the cat are rarely reported or discovered
by authorities. Given the value of the pelt, chances are
high that pelts from retaliatory kills also end up in the
market chain.
Snow leopa rd. Image: Sabin e Schmidt.
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Wild Boar (Sus scrofa)
Legal and Conservation Status in Mongolia: A
traditional game animal, S. scrofa in Mongolia is
classifi ed as “rare” by the Law on Fauna, and may be
hunted only for “special purposes,” which includes
sport hunting by foreigners. It is classifi ed as Near
reatened in the Mongolian Red List of Mammals
(2006). Trophy permits are available for $400 from
the Ministry of Nature and Environment. e hunting
season is set from August 1st to December 1st.
Legal and Conservation Status Worldwide: S. scrofa
has no trade status under CITES. It is classifi ed as
Lower Risk/Least Concern by IUCN (assessment in
1996). No other international agreement regulates
hunting or trade of the species in Mongolia.
Distribution and Population Trends: Wild boar
inhabit many kinds of habitat, but generally prefer
areas with some cover. ey tend to be most plentiful
in forests and reed beds in Asia, with a major limiting
factor thought to be snow depths greater than 40-50
cm (Groves 1981). Activity is mainly nocturnal
and crepuscular. S. scrofa is omnivorous and its diet
consists of fungi, tubers, bulbs, green vegetation,
invertebrates, small vertebrates, and carrion. Estimated
home ranges are 500–1,000 ha for adult females and
twice that for adult males (Nowak 1999).
Wild populations of S. scrofa were exterminated from
much of their former range including the British Isles
and Scandinavia, but have been successfully reintro-
duced in the latter (Lever 1985). In general, the species
has remained more common than some other large
game animals in eastern Asia (Oliver 1993). From
1965 to 1975, populations across Europe dramatically
increased, with hunter off take more than doubling and
reaching 100,000 per year in Russia (Saez-Royuela
and Telleria 1986). However, wild boar populations
are known to fl uctuate widely over much of their
range, showing periodic sharp declines due to hard
winters and disease outbreaks, suggesting that “adap-
tive management” (e.g., shifting quotas and seasons
dependent upon population trends) may be especially
important for this species.
Mongolia’s wild boar population persists mainly in the
northern forested regions of Khuvsgul, Khentii, and
Selenge aimags, with a small population in Nomrog
Figure 15: Historic Wild Boar Trade in Mongolia 1932-1985
Source: Mo ngolian Academy of Sci ences, Institute of Bio logy, Historical Trade Reco rds, 1926 –1984
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Mongolia
114
Special Protected Area in the east (Fitzpatrick pers.
comm.). Population densities, ranges, and numbers
have not been adequately studied.
Take and Trade: Wild boar is another species that
Mongolia historically traded with the Soviet Union.
Offi cial statistics record trade volumes in kilograms
of meat only. To estimate the total number of animals
traded, we used the average meat yield (100 kg) for
one animal as published by the Mongolian Academy
of Sciences, although weights may vary and this level
may be high—some of the largest wild boars taken
by hunters are only slightly heavier and much of the
weight is not usable meat.
Wild boar meat trade began in 1932 with the modest
number of 5 animals. Trade remained small, averaging
just 13 animals per year through 1950. In 1951, trade
suddenly jumped from 2,000 kg the previous year to
over 56,000 kg (567 animals). From 1951 to 1975,
trade averaged 226 animals annually. e next year
saw the beginning of a ban eff ective for all species in
the territory of Mongolia. Trade resumed in 1981,
averaging approximately 50 percent of former trade
volumes through 1985. From that point on, records are
no longer available. In the 53 years for which records
exist, Mongolia harvested approximately 6,500 wild
boar (650,000 kg) in total.
Wild boar is a traditional game meat favorite in
Mongolia but has no reported medicinal properties.
Roughly 8 percent (n=73 of 949) of the hunters
interviewed admitted taking wild boar every year,
despite the ban on subsistence hunting. Nationwide,
we estimate a wild boar hunter contingent of more
than 20,000. Most claimed to hunt only one animal
per year (70 percent) with a few harvesting as many
as 5 for a mean take of 1.9 per hunter. Total take is
estimated at 30,000 animals in 2004.
Internationally, the only documented form of trade is
sport hunting. e Ministry of Nature and Environ-
ment has established a sport-hunting fee of $400 per
trophy, with trophy hunts selling for approximately
$4,500.
Little is known about the impact of hunting on wild
boar populations in Mongolia. Studies in other areas
show that wild pig populations have the potential to
triple every year when conditions are optimal, as wild
pig sows can produce two litters per year of fi ve to
six piglets each. However, the breeding rate is highly
dependent on environmental conditions. When envi-
ronmental conditions are unfavorable (e.g., drought
or crop failure), birth rates are lower and mortality of
young wild pigs can be high. If these conditions are
particularly severe or predation is exceptionally high,
the population can decrease rapidly. Studies in Europe
indicate that off take levels as high as 80 percent of
the total population may be possible.67 However,
it is unlikely that a similar off take level would be
sustainable in Mongolia, where productivity is lower
(much more arid environment, fewer mast tree species)
and winters are much more severe, likely resulting in
lower population densities and population swings.
Close (yearly) monitoring of wild boar populations
and adaptive changes in legal take is recommended to
properly manage this species in Mongolia.
67 On the European continent wild boar numbers are often controlled
by hunting with a sustainable harvest of 0.4 million taken from a
population of 0.5 million (Myberget 1990).
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Red Deer (Cervus elaphus)
Legal and Conservation Status in Mongolia:
Red deer is listed in the Law on Fauna as “rare,” a
designation mirrored in the Law on Hunting, which
restricts hunting to “special” (or sport) purposes only.
Trophy permits for foreign hunters were quoted at
$700, however all sport hunting has been temporarily
stopped due to declining populations. e species was
assessed as Critically Endangered in the Mongolian
Red List of Mammals (2006).
Legal and Conservation Status Worldwide: IUCN
lists C. elaphus as Lower Risk/Least Concern (assess-
ment in 1996). ere is no other international treaty
or agreement regulating take, trade or habitat for the
species.
Distribution and Population Trends: C. elaphus is
the largest of the Cervus genus (Groves and Grubb
1987). Animals in the populations of northeastern
Asia are among the largest in the world, similar in size
to the North American elk or red deer, and usually
larger than those of Europe and southern Asia. Males
are larger than females. C. elaphus is highly gregarious.
Discrete herds are formed, with males and females
remaining separate for most of the year.
Red deer are both grazers and browsers with much
of the spring forage consisting of grass, shifting to
forbs and woody plants in the summer, changing
again to browse and dried grasses in late summer and
fall, and fi nally moving to shrubs and conifers that
persist above the snow in winter (Chen et al. 1998).
Siberian red deer were once common throughout
much of Mongolia. ey occurred in large numbers
in the forested north, and occurred in lesser and more
scattered numbers, but still common, across much
of the steppe, where they were usually found near or
within wooded or hilly regions. Cover in the form of
bushes or trees is critical, as it provides both protection
from predators such as wolves and important food in
winter in the form of browse.
Unfortunately, red deer have also declined cata-
strophically across Mongolia. According to a 1986
government assessment, the population size was
approximately 130,000 inhabiting 115,000 km2. e
most recent population assessment in 2004 showed
that only about 8,000-10,000 red deer are left, a Bu ll red deer in Siberia n Taiga . Image: WWF Mon golia
greater than 77 percent decrease in less than twenty
years.
Take and Trade: Red deer played no role in Mongo-
lia’s foreign exchange with the Soviet Union. With the
easing of Sino-Soviet relations, however, a new wildlife
trade opportunity opened for Mongolia in the form
of red deer antlers for traditional Chinese medicine.
Once trade began, the volumes were shockingly high.
Starting in 1965, Mongolia began shipping thousands
of tons of red deer blood antlers to China. is trade
was followed immediately by shipments of shed antlers
at twice the volume. In just the fi rst year of trade,
Mongolia sent 33,700 tons of red deer blood antlers to
its southern neighbor. e following year, the volume
of blood antler trade increased to 40,000 tons and
was coupled with almost 90,000 tons of shed antlers.
Over the next 8 years, trade steadily increased for both
blood and shed antlers, reaching a high of 57,000 tons
of blood antlers and 155,000 tons of shed antlers.
While habitat loss may play a small role, over-harvest-
ing from the mid-1960s to the mid-1980s, followed by
uncontrolled and illegal hunting from the 1990s on,
is the primary reason for the dramatic decline. ere
is no information available on the impact of historic
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Mongolia
116
or 50 percent of the estimated remaining population.
Even accounting for exaggerated responses, there is a
strong indication that continued unsustainably high
harvests are occurring in the country and may soon
cause local extinctions of the species.
Figure 16: Red deer Antler Trade with China 1965–1974
Source: Mo ngolian Academy of Sci ences, Institute of Bio logy, Historical Trade Reco rds, 1926 –1984
3FE%FFS4IFE"OUMFST
3FE%FFS#MPPE"OUMFST
Red deer a ntler chips for sale in Ere en Khot, Inner-Mo ngolia, China.
Image: J. W ingard, July 2005
blood antler trade on red deer populations, but experi-
ence with attempts to harvest blood antlers in the early
1990s is a strong indicator that animals were either
shot or died from the handling. Trade in blood antlers
was often the equivalent of harvesting the animal.
Much of the poaching and subsequent trade is
directed toward the international medicinal market,
and include harvesting for antlers ($60–100/kg),
male genital organs ($70–80), fetuses ($20–50), and
female’s tails ($50–80).
In this wildlife trade study, only 3 percent (26 of 949)
of all hunter respondents targeted this species. ese
hunters came primarily from the northern part of
the country in Khentii, Selenge, Tov, and Khuvsgul
aimags. Weighted by human population densities in
these areas, the total number of hunters harvesting red
deer may be as many as 5,000, although this fi gure ap-
pears to be high. e mean harvest rate based on their
responses was 1.9/hunter with a maximum of 4 for one
hunter. e total harvest volume in 2004 of the hunt-
ers queried was 53. With such a low level of hunter
response, estimates of total take are diffi cult to make.
Tentative estimates are approximately 6,000 animals
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Argali (Ovis ammon)
Legal and Conservation Status in Mongolia: Ovis
ammon is listed in the Law on Fauna as “rare.” It is
classifi ed in the Mongolian Red List of Mammals
(2006) as Endangered. e Law on Hunting allows
hunting only for “special” purposes pursuant to license
issued by the Ministry of Nature and Environment.
A highly prized trophy animal, argali licenses range
in price depending on the regional population. Altai
argali (Ovis ammon ammon) are the largest and
command a license and permit fee of $25,000. Gobi
argali (O. a. darwini) are smaller with fees of $16,000.
Altai argali may be hunted from July 20th to October
31st. e Gobi argali trophy season extends from July
20th to November 15th. No subsistence or commercial
hunting is permitted.
Legal and Conservation Status Worldwide: Biolo-
gists currently recognize 9 diff erent subspecies of O.
ammon, 7 of which are listed in CITES Appendix II
and 2 of the most critically endangered subspecies,
O. a. hodgsonii and O. a. nigrimontana, are listed on
Appendix I. e IUCN Red List separately evaluated
each subspecies as follows: Altai argali as Vulnerable
(VU—A2cde, C1); Gobi argali as Endangered
(EN—C1); Kazakhstan argali (O. a. collium) classifi ed
as Vulnerable (VU—A2cde, C1); Tibetan argali (O.
a. hodgsonii) Vulnerable (VU—A2cde); Northern
Chinese argali (O. a. jubata) Critically Endangred
(CR—C2a); Tien Shan argali (O. a. karelini) Vulner-
able (VU—A2cde, C1+2a); Kara Tau argali (O. a.
nigrimontana) Critically
Endangered (CR—C2b);
Marco Polo argali (O. a. polii)
Vulnerable (V U — A 2 cde,
C1); and Kyzylkum sheep
(O. a. severtzovi) Endangered
(EN—A2cde, C2b) (IUCN
2004).
Distribution and Population
Trend s : e 9 recognized
subspecies of argali occur
throughout central Asia with
each subspecies’ distribution
restricted to separate regions.
e furthest west is O. a.
severtzovi, which occurs in
Uzbekistan, and the furthest east is Gobi argali in
Mongolia. Some contention surrounds the designation
of two subspecies of argali in Mongolia. For many
years, biologists have recognized the Altai argali (Ovis
ammon ammon) and Gobi argali (Ovis ammon dar-
wini) (Tsalkin 1951, Zhirnov and Ilyinksi 1986, Geist
1991). However, the results of a recent DNA study
do not support the distinction, suggesting that argali
in Mongolia may be a single, polytypic subspecies
(Tserenbataa 2003).
e argali is described as a highly social animal
spending much of the year in single-sex herds with as
many as 100 individuals. Mating season for Mongolia’s
argali begins late September to early October and lasts
approximately one month, during which time males
and females will congregate in a single herd and males
will compete for females. Females have a 5-month
gestation period and give birth sometime in March or
April to a litter of 1 or 2 lambs (IUCN 2003).
Owing to its status as a trophy animal, argali is one
of the few species in Mongolia for which population
surveys have been done. Despite inconsistencies in
study methodologies and results, in general Mongolia’s
population of argali appears to be declining. Historical
data record a general distribution of argali across
approximately 400,000 km2 of Mongolia’s western,
southern, and central aimags (Institute of Biology
2001). Population estimates have varied consider-
ably from 40,000 in 1970 (Dulamtseren 1970) to
just 10,000–12,000 in 1976 (Shanyavskii 1976)
Adult rams in Ik h Nature Nature Reser ve. Image: Dr. Richard Rea ding
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Mongolia
118
to 18,000-20,000 in 1985 (Gruzdev et al. 1985),
compared to 60,000 also estimated in 1985 (Institute
of Biology 1985). A number of smaller studies have
been conducted in discrete areas since 1990 using
diff erent methodologies and for the most part were
never repeated (Institute of Biology 2001). Not until
the summer of 2001 did the Mongolian government
sponsor a nationwide survey, 16 years after the last
nationwide estimate. Conducted from July to August
2001 by the Institute of Biology, this study documents
a sharp decline in argali populations from 60,000
in 1985 to just 13,000-15,000 in 2001 (Institute of
Biology 2001; Amgalanbaatar et al. 2002).
Take and Trade: Mongolia’s earliest documented
experience with argali trophy hunting goes back as
far as 1910 when Curruther brought home trophies
from Mongolia’s western Altai. Offi cially, trophy
hunting of argali has been allowed in Mongolia since
the late 1960s and generated over $20 million from
the taking of 1,630 rams between 1967 and 1989
(Amgalanbaatar 1993, Luschekina 1994). Average
annual take was 74 trophies per year with each ram
bringing approximately $12,000 to the Mongolian
economy—a striking sum in comparison to the value
of other traded species for the same period (e.g.,
marmot skins sold for $0.09 each) and a refl ection of
Mongolia’s direct interface with economies outside the
Soviet Union.
Amidst much controversy and despite their
threatened status, argali trophy hunting remains
legal in Mongolia. While recommended quotas from
Mongolia’s CITES Scientifi c Authority (Academy of
Sciences) have remained steady since the early 1990s
(approximately 60), the number of licenses has steadily
increased from fewer than 20 in 1993 to 40 in 2001,
to 80 in 2002 (Amgalanbaatar et al. 2002). Notably,
the last fi gure surpasses the Scientifi c Authority’s
recommended quota and is in direct contravention
of Mongolia’s CITES obligations. e increase also
represents a doubling of the quota in a single year.
Mongolia reported selling only 68 trophies in 2004,
but this fi gure is still more than the recommended
quota of 40 issued by the Academy of Sciences.
e driver behind the increase is the species’ unique
status in the trophy hunting community and
concomitant high price tag. Mongolia’s argali is the
largest of the world’s wild sheep and the Altai argali is
considered the pinnacle of the “Ovis World Slam,” a
hunting endeavor monitored by US-based Ovis, Inc.
that requires the legal taking of a trophy from 12 wild
sheep species in the world. Trophy hunting companies
catering to an elite and wealthy group of hunters off er
excursions from $25,000 to $50,000.
Because of its potential to provide needed funds for
local communities and the conservation needs of the
species, the controversy, whether voiced nationally
or internationally, centers on the failure to improve
management. For local communities, the core com-
plaint is that monies given to them by one law (Law
on Hunting Resource Use Fees; herein “Hunting Fee
Law”) are taken away by another (Law on Public Sec-
tor Finance). e Hunting Fee Law requires payment
of licensing fees to the soum budget, which it sets
at 20-30 percent of the current market value of one
trophy. For a Gobi argali, the license costs $2,000, and
for an Altai argali, $4,000. However, the Public Sector
Finance consolidates all fi nancing into the state central
budget and budgeting practices decrease a soum
government’s allocation by the amount received from
hunting fees. e result is no net gain for the commu-
nity and no local money to engage in the management
activities mandated by the Law on Hunting.
For conservationists and concerned citizens, the
complaints are numerous but primarily center on
the lack of funds made available for conservation of
the species, government corruption, the absence of
management planning, and illegal and unsustainable
trophy hunting practices. One of the most disconcert-
ing problems is the lack of funds for conservation.
Given the species’ high trophy value and Mongolia’s
legal requirements, more than enough funds should
be available to engage in regular monitoring and
comprehensive conservation eff orts. e 1995 Hunting
Fee Law required that 10 percent of “hunting reserve
use fees” paid to the central budget be transferred to
an Environmental Protection Fund. In 2000, a new
law (Law on Reinvestment of Natural Resource Use
Fees for Conservation of Natural Resources; herein
“Reinvestment Law”) increased this amount to 50
percent (Wingard and Odgerel 2001). e Hunting
Fee Law sets the resource use fee at 60-70 percent
of its trophy value, or $14,000 for Gobi argali and
$21,000 for Altai argali. e 1995 Hunting Fee Law
would thus require payments to the Environmental
Protection Fund of $1,400 and $2,100 respectively,
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
119
while the 2000 Reinvestment Law would increase
these payments to $7,000 and $10,500. From 1996 to
1999, Mongolia reports exporting 66 argali trophies.
No breakdown of the number of Altai and Gobi argali
is given. However, a simple estimate is possible using
the 1995 requirement of 10 percent and assuming a
mean of $1,750 per trophy. Under these terms, the
fund should have received approximately $115,000 in
4 years. From 2000 to 2004, Mongolia exported 292
trophies. Applying the 2000 reinvestment obligation
of 50 percent and a mean trophy value of $8,750,
the Environmental Protection Fund should have
received more than $2,550,000, for a total of more
than $2,650,000 over the last 10 years. In the same
period, only one nationwide study has been conducted
on argali populations at a cost of less than $18,000
(Institute of Biology 2001), less than 1 percent of the
estimated revenues generated.
Internationally, the controversy was voiced in a U.S.
lawsuit alleging the failure of the U.S. Fish and
Wildlife Service to exercise “due diligence” in its
determination of Mongolia’s management of the spe-
cies. e U.S. Endangered Species Act allows hunters
to import trophies of endangered species only where
the exporting country has completed nationwide
surveys showing population trends and the responsible
agency has sustainable management plans that are
actually conserving the species. e implication of the
lawsuit was that U.S. hunters, the largest percentage
of Mongolia’s customers (Amgalanbaatar et al. 2002),
would not be able to import their trophies if the
Mongolian government was not able to prove it was
managing the species.
e combination of public outcry in Mongolia and the
U.S. lawsuit prompted the Mongolian government to
conduct a nationwide study in 2001. e Minister of
Nature and Environment even contributed personal
funds to implement the study (Institute of Biology
2001), which was especially surprising as there should
have been over hundreds of thousands of US dollars
in the Environmental Protection Fund for this sort of
activity.
However, one study does not equal eff ective manage-
ment and in the absence of on-the-ground actions
and local incentives to conserve the species, poaching
remains a serious problem, adding to threats posed by
trophy hunting, predation by domestic guard dogs,
and competition with domestic livestock (Amgalan-
baatar and Reading 2000, Wingard 2005). In the
wildlife trade survey, however, the number of hunters
who admitted taking argali was low (4 of 949, <1
percent) with a mean harvest of 1.3 and a maximum
harvest by one individual of 20. Anecdotal informa-
tion collected during the wildlife trade study and
reports by many respondents suggest that poaching
is common throughout the country, with game meat
a primary motivator but also the sale of argali horns
and mounted trophies to markets in China (Institute
of Biology 2001, Amgalanbaatar et al. 2002, Maroney
2003, Wingard 2005).
None of the respondents to either the household
consumption survey or market survey reported selling
or trading argali meat. However, one individual in the
survey reportedly took 20 argali in 2004. One adult
argali ram yields approximately 120 kg of meat; 20
would supply the hunter with 2,400 kg—enough to
feed 13 families of 4 individuals for a year. Although
this hunter did not claim to sell or trade argali meat,
the quantity harvested is well beyond the level of
personal consumption. Whether traded or not, the
meat has value as a substitute for purchasing domestic
meat on the market. Based on a single animal game
meat yield of 120 kg with a value of $2 per kg (substi-
tute value for domestic meat), one argali has a nominal
domestic value of $240. e market survey also found
mounted trophies for sale at $275, making the total
potential market value of an argali ram approximately
$515.
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Mongolia
120
Saker Falcon (Falco cherrug)
Legal and Conservation Status in Mongolia:
Curiously, saker falcon is an unregulated species in
Mongolia. e Law on Hunting does not establish a
season for taking the bird; nor does the Law on Fauna
classify them as “very rare” or “rare.” e species is
also not listed in the Mongolian Red Book.
Legal and Conservation Status Worldwide: e
IUCN Red List classifi es F. cherrug as Endangered
(A2bcd+3bcd) (assessment in 2004). e classifi ca-
tion is due to the species’ rapid population decline,
particularly on the Central Asian breeding grounds,
owing to inadequately controlled capture for the
falconry trade. Rapidly declining populations have led
many range states to protect and red-list the species,
especially in the western part of the range (Baumgart
2000). CITES gives the species Appendix II trade
status and in 2002 imposed a trade ban on the United
Arab Emirates (Fox 2002). A similar ban on all saker
trade states has been proposed by CITES, including
Mongolia.
Distribution and Population Trends: Falco cherrug
has a wide Palearctic distribution stretching from
eastern Europe to China. It is known to breed in
several countries within this range including Austria,
Hungary, Czech Republic, Slovakia, Serbia and
Montenegro, Bulgaria, Romania, Moldova, Belarus,
Ukraine, Turkey, Iraq, Armenia, Russia, Uzbekistan,
Tajikistan, Kyrgyzstan, Kazakhstan, Mongolia
and China, and at least formerly in Turkmenistan,
probably Afghanistan, and possibly India. Regular
wintering or passage populations have been docu-
mented in Italy, Malta, Cyprus, Israel, Jordan, Egypt,
Libya, Sudan, Tunisia, Ethiopia, Kenya, Saudi Arabia,
Yemen, Oman, UAE, Bahrain, Kuwait, Iran, Pakistan,
India, Nepal, Afghanistan and Azerbaijan (Birdlife
International 2005, Haines 2002, Snow and Perrins
199 8 ).
In 1990, the global population of saker falcons was
estimated at 8,500-12,000 pairs. By 2003, this
number had dropped to 3,600-4,400 for an estimated
global decline of 61 percent (ERDWA 2003). Mon-
golia is home to roughly half the world’s remaining
population of saker falcons, but this avian sanctuary
has been discovered and declines here are as dramatic
as in other countries. In 1999, Mongolia’s saker falcon
population was estimated at 3,000 breeding pairs
(Shagdarsuren et al. 2001). However, in 2000, the
population dropped to an estimated 2,200 pairs. In
2003 the number of falcons breeding in 6 study sites
was less than 50 percent that of previous years, with
most sites being unproductive. Today, Mongolia’s saker
falcon population is threatened by illegal trapping,
eff ects from Brandt’s vole poisoning, and electrocution
(Gombobaatar et al. 2003). e extent to which
these diff erent factors contribute to saker declines in
Mongolia requires urgent analysis, but it is likely that
international trade is the greatest driver in population
declines.
Take and Trade: Because of their large size and
capable hunting skill, saker falcons are highly prized
among falconers. Trapping for the falconry trade,
especially the export trade to the Middle East,
is growing rapidly. e Ministry of Nature and
Environment records saker exports pursuant to CITES
Appendix II requirements. Similar to argali trade,
there has been a sharp increase in offi cially sanctioned
falcon trade, going from a yearly average of 63 birds
from 1996 to 2000 to almost 400 birds in 2004 (Table
A1). is current level of trade in Mongolia is roughly
10 percent of the estimated remaining population
Saker falco n. Image: Simon Busit til/RSPB
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
121
of sakers in the world and almost 20 percent of
Mongolia’s declining population.
With no management plan in place for the protection
of the species, harvesting areas and levels appear to
be a function of convenience if not greed. While
somewhat more than 300 licenses were purportedly
issued in 2004, as many as 250 falcons were taken
from one aimag (Sukhbaatar) in Mongolia’s Eastern
Steppe region. Anecdotal information from individuals
surveyed suggests that population levels have decreased
substantially in the east, following similar declines in
the west.
Table A1: Export revenue from saker falcon in Mongolia 1996–2003
Yea r
Number of
Falcons
Exported
Direct
Payments68
Fees Total
Revenue
1996 25 85,000 88.50 85,088
1997 154 520,000 545.00 520,545
1998 25 85,000 88.50 85,088
1999 61 200,000 215.00 200,215
2000 51 170,000 180.00 170,180
2001 180 712,350 641.40 776,490
20 02 3 03 1,155,945 1, 073.10 1,263,255
20 03 392 1, 3 45,932 1,430.80 1, 826, 096
Total 1,191 4,274,227 4,261.90 4,278,488
Source: Mi nistry of Nature and Env ironment 2004, Wing ard and Odgerel 2001, CITES Dat abase, 2005.
68 Payments for the years 1996–2000 were estimated based on mean trade values for subsequent years. ese fi gures may not be accurate, but were
used as approximate values in the absence of offi cial data.
Saker falcons are not traditionally used by Mongolians
and do not factor into any known form of domestic
trade. Still, illegal international trade occurs. From
1993 to 1999, there were 16 known attempts to
smuggle a total of 69 falcons from the country, mostly
by foreign nationals (Badam 2001). However, we do
not know, and there is no way to measure, the true
level of illegal trade actually occurring. None of the
respondents to the wildlife trade survey reported
harvesting or trading falcons.
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Mongolia
122
Saiga antelope (Saiga tatarica mongolica)
Legal and Conservation Status in Mongolia:
Mongolia has prohibited hunting saiga antelope by
law since 1930. In 1953, the species was listed as a
protected species by Mongolia government. e law
on fauna lists S. t. mongolica as very rare, prohibiting
both personal or commercial hunting, but allowing
take for scientifi c purposes. Two of the prime areas
for saiga are under state protection, Sharga-Mankhan
Nature Reserve established in 1996 and Khar Us Nuur
National Park established in 1997. e subspecies is
listed in the Mongolian Red List of Mammals (2006)
as Endangered.
Legal and Conservation Status Worldwide:
S. tatarica was assessed by IUCN as Critically Endan-
gered (A2a) in 2003, with a regional assessment of S. t.
mongolica in 2005 as Endangered (A2acd) (November,
2005). S. t. tatarica is listed in Appendix II, CITES.
S.t. mongolica is listed in CITES Appendix I.
Distribution and Population Trends: Saiga antelope
are migratory herd animals that live on open steppe
and desert steppe. ey once spanned the Eurasian
continent from southeastern Europe to Mongolia
and China. Today, they may be found only in Russia,
Kazakhstan, Turkmenistan, Uzbekistan and far
western Mongolia. e Mongolian saiga antelope (S.
t. mongolica) is a distinct subspecies that has long been
isolated from the main populations in Kazakhstan
and Russia by the Altai Mountains. Historically,
S. t. tatarica occurred in the Dzungarian Gobi of
Mongolia, but became regionally extinct there around
the mid-1950s. S. t. mongolica (Bannikov 1948) is
endemic to Mongolia and was formerly found in the
semi-desert zone, from Mongolia’s northwest corner,
east to approximately 101 E. Populations have declined
drastically from historic levels and today this rare
species exists only in the southwestern part of the
country, primarily in Khovd and Govi-Altai aimags.
More specifi cally, it may be found in Shargiin Gobi,
Khuisiin Gobi, Khuren tal and the Mankhan area.
Population estimates over the last 30 years vary, but
ultimately refl ect a decrease of approximately 50
percent in the last 7 years. Dash et al. (1977) estimated
the surviving Mongolian population as low as 200.
Reports from the 1980s show an increase to around
300 animals. Assessments in 1997 recorded 1,000
animals, rising in 1998 to between 2,000 and 2,500. A
study conducted by WWF Mongolia showed continu-
ing growth in numbers to a high of 5,200 in 2001.
However, a survey in 2002 sadly recorded a decline to
1,020 and a further study in 2003 by WWF Mongolia
recorded a mere 750. (WWF 2003). e most recent
survey estimates 1,500 saiga remaining in Mongolia
(Amgalan 2005).
e decline in Mongolia follows shortly after a similar
collapse in the major populations of saiga in Kazakh-
stan and Russia, where populations have crashed by as
much as 97 percent from over 1 million in the early
1990s to perhaps as low as 31,000 in recent years
(Millner-Gulland et al. 2001). e decline is exacer-
bated by skewed sex ratios due to focused hunting on
the horned males, which has negatively aff ected the
populations’ breeding system and its ability to recover
(Millner-Gulland et al. 2003).
Take and Trade: e single most important driver
in S. t. mongolica declines is the Chinese medicinal
market for saiga horn. Mongolians do not traditionally
use saiga horn and the value of the meat is either
so low or non-existent that hunters do not trade it.
Furthermore, a WWF Mongolia survey conducted
in 2004 confi rmed that the 2,860 km2 area where
saiga presently occur in Mongolia has no major
environmental problems (i.e., overgrazing, habitat
fragmentation), nor were there any negative climatic
conditions that might contribute to the observed
decline in the species. In other words, the reduction in
Mongolia’s saiga population is directly, and possibly
solely, related to hunting.
During the course of the study, WWF Mongolia
spoke with a number of poachers and learned the
astonishing reality behind saiga harvests. Because the
blood horn is the singular object of pursuit, poachers
attempt to harvest them while the animal is still alive.
Chinese buyers apparently pay much more for horns
taken using this technique ($30 per horn) because the
horn contains more blood. To do this, poachers pursue
the animal by car and literally run into the saiga.
en, and while the animal is still alive, the horns are
removed with an axe. Having no further value, the
injured animal is left to bleed to death (WWF 2004).
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
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With such drastically reduced numbers, the real
threat to the survival of the species may shift from
hunting to stochastic events. While hunting will likely
continue at least on an opportunistic basis, organized
hunts may no longer be commercially viable. e
actual market resource (adult males) is only a small
percentage of the total population – estimated at 10
percent of males, which make up only 25 percent of
the total population. e present population of 1,500
may therefore only have 380 males and of these, only
38 with real market value. At $60 per male, the total
potential market could be as little as $2,300. With
so few animals spread over such a large area, it may
not make economic sense to continue to hunt them
as a targeted species, although opportunistic hunting
is likely to continue. However, those same small
numbers mean the population is extremely vulnerable
to stochastic events such as hard winters and drought,
limited diversity of the gene pool, and/or fragmented
or degraded habitat.
Mongolian gazelle (Procapra gutturosa)
Legal and Conservation Status in Mongolia:
Mongolian Law on Hunting permits subsistence take
of Mongolian gazelle from August 1st to October
1st with no restriction on age, sex, or size. Industrial
hunting is permitted by the same law, but was banned
in 2000 pursuant to an order by the Ministry of
Nature and Environment. e species was classifi ed by
the Mongolian Red List (2006) as Endangered.
Legal and Conservation Status Worldwide: e
IUCN Red List evaluated P. gutturosa in 2003 as Least
Concern based on an assumption of a population of
approximately 1,000,000. However, the IUCN Red
List also cautions the need for annual monitoring
of the status of the species as the impacts of disease,
severe winter conditions, legal and illegal harvests
could result in a sharp decrease qualifying for a
classifi cation of Near reatened or Vulnerable.
Herd of Mon golian gazelle in Do rnogovi Aimag near Ik h Nature Nature Reser ve. Image: Dr. RichardR eading
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124
Figure 17: Trade in Mongolian gazelle game meat in Mongolia 1932–1985
Source: Mo ngolian Academy of Sci ences, Institute of Bio logy, Historical Trade Reco rds, 1926 –1984
"OOVBM)BSWFTU7PMVNFTLH
Distribution and Population Trends: Mongolian
gazelles still number around 1 million animals in
Mongolia, and represent one of the great migratory
ungulate spectacles in the world, and the last such
event in Asia. Historically they occurred throughout
the eastern aimags and in a broad band across central
Mongolia and west to the base of the Altai Mountains.
is range has been dramatically constricted over the
past 100 years, with much of the loss occurring in
western Mongolia. Today, only a few western locations
still contain gazelles.
Globally, Mongolian gazelle range has dropped by as
much as 75 percent over the past 50 years in at least 3
of its 4 range states, which included Mongolia, China,
Russia, and Kazakhstan. In Mongolia, range fell from
780,000 km2 in the 1940s to only 190,000 km2 in
1997. Similarly, in Inner Mongolia, China the range
contracted from 300,000 km2 in 1970 to less than
75,000 km2 by 1995. e species has disappeared from
Kazakhstan and been virtually eliminated from its
range in Russia outside of a small migratory popula-
tion in the Chital region across the northeast border
of Mongolia (Bannikov et al. 1961, Lhagvasuren and
Milner-Gulland 1997, Xiaoming et al. 1997, Jiang et
al. 1998). Over 90 percent of the remaining popula-
tion of this species is in Mongolia.
In Mongolia, population estimates have ranged from
as few as 180,000 to as many as 2,670,000 (Milner-
Gulland and Lhagvasuren 1998, Olson et al. 2004).
Olson et al. (2004) estimated 800,000–900,000
gazelles (about 10–11 gazelles/km2) over an area of
80,000 km2 in Mongolia’s eastern steppe. In 1994,
Mix et al. estimated a total population of 2,670,000
after surveying over 475,000 km2 of gazelle range
(unpubl. data cited in Reading et al. 1998); an area 6
times larger than the Olson study. In 1998, Reading
et al. (1998) reported 250,000–300,000 gazelles
occurred in Dornod Aimag based on local interviews.
In 2001 V. Kiriuluk made an educated guess that
300,000–500,000 gazelles remained throughout
eastern Mongolia, while in 2003 B. Lhagvasuren
estimated 750,000 gazelles in all of Dornod (Olson et
al. 2004 citing pers. comm.).
In late August and early September of 1998, a massive
die-off of gazelles occurred following record rainfall
levels. A study conducted by WCS and the Mongolian
Institute of Biology in the same year showed that af-
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
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fected animals had signs typical of a bacterial infection
(Fusobacterium) of the feet of livestock kept in muddy
conditions. e disease is known to aff ect caribou in
Alaska during unusually wet conditions. Later in the
fall, thousands of gazelles succumbed as the weather
turned cold and the year’s planned commercial harvest
was canceled to allow the population to recover
(Schaller 1998).
Other than overhunting, threats to the continued
survival of Mongolian gazelle include 1) infrastructure
development such as the Millennium Road that
threatens to divide the steppe and disrupt gazelle
migration; 2) proposals to remove large portions
from protected areas; and 3) changing land use
practices that also threaten long-term sustainability,
including agricultural expansion, fencing of land, and
overgrazing due to disruption of pastoral traditions.
Oil and mineral extraction in the area may also pose
a substantial threat if it is not carried out in a manner
consistent with ecological preservation of migratory
movements.
Take and Trade: Mongolians have traditionally
harvested Mongolian gazelles to supplement their
diet, and from 1932 to 1976, the species was com-
mercially harvested for trade with the Soviet Union
(Milner-Gulland and Lhagvasuren, 1998, Reading et
al. 1998). Offi cial statistics do not give actual numbers
of animals taken, instead quoting total kilograms of
meat processed. is taxon of gazelle typically weighs
between 20–40 kg (Nowak 1999). Using a median of
30 kg and subtracting weight not attributed to meat
(roughly 50 percent) gives an average game meat yield
of 15 kg per animal for a total of 845,000 animals
offi cially traded in 45 years, with an average trade
related harvest of 15,665 animals per year and peak
harvests exceeding 50,000 animals in the early 1950s
and 63,000 animals in 1961. Halted in 1976, offi cial
trade was never reestablished in socialist times.
Commercial hunting began again in 1995 with aver-
age quotas of 20,000 gazelles per year. e primary
market was China. In 2000, the Ministry of Nature
and Environment announced a ban on commercial
hunting. However, in 2001 the Chinese government
was still offi cially permitting the import of gazelles
from Mongolia, approving the import of 100 tons of
Mongolian gazelle meat or roughly 6,600 animals
(Scharf and Enkhbold 2002). at Chinese offi cials
approved imports at any level is symptomatic of the
management disconnect between the Mongolian
government and counterparts in Chinese agen-
cies—with limited ability to control actual harvests,
the continued open market in China has immediate
and negative consequences for managing wildlife
harvests in Mongolia.
It is almost certain that hunting for subsistence
purposes continued after 1976, but there are no
records for the level of off take. Subsistence hunting
was certainly a factor after 1990 as economic hardship
forced Mongolians to return to subsistence practices
including hunting. e opening of additional border
points between China and Mongolia along with gener-
ally increasing trade to the south encouraged hunters
to harvest wildlife, including Mongolian gazelle, for
the new market. Again, no records exist documenting
the actual level of off take.
However, a hunting survey conducted in 2001 found
that local herders in the Eastern Steppe region take
as many as 200,000 gazelles annually (K. Olson pers.
comm.). Urban dwellers in just one city in eastern
Mongolia (Choibalsan) were estimated to consume
approximately 16,000 gazelles a year (Scharf and
Enkhbold 2002). is wildlife trade survey found that
similar numbers continue to be harvested throughout
the gazelle’s distribution in the country. Of the 3,119
hunters interviewed, 150 report harvesting gazelle
(5 percent of all hunters). Our estimate of the total
number of gazelle hunters nationwide is 40,000. e
adjusted mean harvest level for these respondents was
5.2 with a maximum harvest of 100. e total harvest
in 2004 may have been as high as 250,000.
Seventeen percent (n=25 of 150) of the Mongolian
gazelle hunters interviewed said they sell gazelle meat
and other parts to local markets. e majority of these
sell the game meat (n=17), while a few also sell the
skin (n=5), blood (n=1), or the whole animal (n=2).
Because the trade survey was conducted during the
summer months, surveyors did not observe any trade
in gazelle meat, blood, or skins.
Mongolian gazelle trade appears to be even more com-
mercialized than marmot trade, with only 20 percent
of users obtaining parts from hunters compared to 25
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126
percent of marmot users whose supply comes directly
from hunters. Much of this trade can be found in local
markets or the train station in Ulaanbaatar.
In addition to commercial harvests and subsistence
trade, Mongolia has recently started advertising gazelle
trophy hunting. Offi cial trophy permit and license fees
are $300. Sold by hunting companies as a combina-
tion hunt, individual gazelle trophies are sold to the
hunter for around $550 per trophy. Hunting starts in
September 1st and extends to December 1st. Average
trophy horns measures 8-11 inches in length.
Millner-Gulland and Lhagvasuren (1998) developed a
harvest model that suggests a total sustainable off take
of 6 percent, or 60,000 gazelles a year if the total
population is 1 million. With estimated total harvests
exceeding this level by more than 300 percent, it is
possible that Mongolian gazelle are experiencing a
decline similar to that documented for many other
species in Mongolia. is decline could accelerate
if there is a commercial switch from saiga to gazelle
horns. Evidence for this ominous trend has been found
in the recent increase in price for gazelle horns and a
market in China for gazelle heads of $12 per specimen.
Musk Deer (Moschus moschiferus)
Legal and Conservation Status in Mongolia: e
Mongolian Red List of Mammals (2006) classifi es the
musk deer as Endangered. e Law on Fauna (2000)
and Law on Hunting (1995) both describe the species
as “very rare.” No personal or commercial hunting is
permitted.
Legal and Conservation Status Worldwide: M.
moschiferus is classifi ed as Vulnerable (A1acd) by the
IUCN Red List (assessment in 1996). e justifi cation
for this classifi cation is based on an estimated or
suspected reduction of at least 20 percent over the
last 10 years as shown by direct observation, a decline
in area occupancy, and actual or potential levels of
exploitation for musk deer pods. M. moschiferus is also
listed in Appendix II of CITES, except for subpopula-
tions in Japan, Denmark, and the Himalayas. Musk
deer species found in Afghanistan, Bhutan, India,
Myanmar, Nepal and Pakistan are listed in Appendix
I. Because of continuing illegal trade at levels likely to
cause signifi cant population declines, musk deer have
received additional attention from CITES. Notably,
In April 2000, at the 11th meeting of the Conference
Gazelle h eads discarded afte r commercial harves ting. In recent years, ga zelle horns have begun to en ter the market as a
substitute f or saiga antelope hor ns. At the time this photo was t aken (1999 ), the heads and horns we re simply discarded .
Image: He nry Mix/Nature Co nservation Intern ational.
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
127
of the Parties to CITES (CoP11), member states
adopted Resolution Conf. 11.7—Conservation of and
Trade in Musk Deer. e resolution asks all CITES
Parties to “take immediate action in order to reduce
demonstrably the illegal trade in musk”. In particular,
member states are asked to:
1. Introduce innovative enforcement methods and
strengthening enforcement in key border regions;
2. Develop a labeling system to identify products
containing musk;
3. Develop and use forensic tests to detect the
presence of (genuine) musk in products;
4. Encourage musk deer range States and consumer
States not Parties to CITES to accede to the
Convention;
5. Work with musk consumers to develop alterna-
tives to musk, to reduce demand for the product,
while encouraging the safe and eff ective use of
techniques to collect musk from live deer;
6. Develop bilateral and regional agreements for
improving musk deer conservation and manage-
ment, strengthening legislation and enforcement
eff orts (Homes 2004).
Distribution and Population Trends: e taxonomy
of musk deer has not been conclusively resolved, but
there are at least four (Himalayan or Alpine Musk
Deer Moschus chrysogaster ; Black Musk Deer M. fuscus;
Forest Musk Deer M. berezovskii; and Siberian Musk
Deer M. moschiferus) and possibly six or more species
of Moschus spp. Little is known about their biology.
Musk deer occur in at least 13 countries in South
Asia, East Asia, Southeast Asia and the eastern parts of
Russia and northern Mongolia (Homes 1999).
Musk deer are unusual, primitive members of the deer
family. Musk deer do not grow antlers—instead, males
develop elongated ‘tusks’ that extend downward and
are used as sexual ornamentation and for dominance
displays. ese small deer live in thickly forested
regions across much of Asia. Musk deer habitat
comprises conifer forests, often in mountainous areas,
with good lichen abundance—this item provides a
majority of the winter diet and is critical for the deer’s
survival.
In Mongolia, M. moschiferus can be found in the
northern slopes of the Khentii and Khuvsgul Moun-
tains and along the mountaintops of the Khangai and
Khan Khokhii mountain ranges. ey are distributed
through 40 soums, involving 10 aimags across 27,000
km2 (Dulamtseren et al. 1975). In 1975, the Institute
of Biology estimated Mongolia’s musk deer population
at over 44,000. Biologists believe that the population
has declined sharply since then, primarily due to the
liberalization of trade and increased harvests for the
valuable musk pods. Surveys have not been completed
in the last 20 years and the current population is
unknown.
Take and Trade: M. moschiferus are hunted for the
valuable scent glands, or pods, which only male musk
deer produce, at the rate of about 23–25 g of musk,
per animal, per year. Musk pods, the glands that
secrete the musk, are harvested by killing the deer, and
three or more musk deer may be killed before a male
with a suffi ciently large musk gland is caught (Homes
2004). Musk secreted from the scent pods of male
musk deer has been used for thousands of years in
traditional medicines in Asia to treat conditions such
as pain, swelling, convulsions and delirium. e musk
deer pod is also one of the most expensive natural
products, with a retail value that has been described as
higher than that of gold (although this survey found
2005 values of gold to be about 4 times the market
price of musk).
e majority of the medicinal products containing
musk and sold in the U.S. are produced in China.
Research by TRAFFIC North America conducted in
2003 shows increased availability of musk products
in major cities in the United States. For example,
the study found musk products “in all of New York
City’s traditional Chinese medicine (TCM) stores
and 50 percent of San Francisco’s TCM shops”. ese
numbers highlight a signifi cant increase in “the
availability and use of musk products over previous
years.” (Homes 2004).
Although no national surveys have been performed
for Mongolia’s musk deer population in the last 30
years, there is evidence of an unsustainable increase
in hunting of this species. Population levels for the
few areas surveyed by Mongolian scientists show
disproportionately low ratios of male to females
resulting from hunting pressure and suggest that some
populations are barely viable (Homes 2004). Over
a fi ve-year period from 1995-2001, the number of
musk deer traders increased by a factor of four and
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128
the number of musk pods traded increased six-fold,
probably as a direct result of the price of a musk deer
pod increasing six times. Mongolian scientists believe
that musk deer populations peaked at 44,000 in the
1980s due to strict state control of hunting and trade.
Over the last 11 years, market-based estimates of
off take were as high as 33,000 (Tsendjav and Batbold
2003). A report by TRAFFIC Europe (Homes 2004)
found that in Russia, an estimated 80 percent of all
musk deer killed appear to have been poached and the
illegal trade in musk is thought to have been fi ve times
that of the legal trade in the early 2000s. In neighbor-
ing Mongolia, despite the fact that hunting of musk
deer has been illegal since 1953, a minimum average
of 2,000 male musk deer have been poached annually
(Homes 2004).
Because of the relatively heavy civil and criminal
penalties for poaching musk deer, respondents to the
wildlife trade survey appeared unwilling to admit
to trade in musk deer pods. However, three markets
reported selling musk deer pods at a price of $4.50 per
gram, primarily for export to China.
Musk deer. Imag e: Dr. Richard Reading
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– 129 –
Appendix B:
Additional Species Information
1) Dalmatian pelican (Pelicanus crispus)—In-
cluded in the Mongolian Red Book (1987) and
Appendix I, CITES and the Bonn Convention on
Migratory Species (CMS). Listed as “very rare”
in the Mongolian Law on Fauna. Hunting in
Mongolia has been prohibited since 1953.
e Dalmation Pelican is distributed in the
Balkans, Black Sea, and Caspian Sea across
Central Asia to Mongolia and China. ey breed
from the Yellow River west to the Balkan Penin-
sula. Historically they were present in Mongolia
as summer migrants to Khar Us, Khar, Airag,
Hyargas, Uvs, Khunguin Khar, Boontsagaan,
Orog, Kholbooj, Taaziin Tsagaan, Ugii Lakes.
Today only a few breeding pairs persist in Khar
Us and Airag Lakes in summer.
An estimated 3,200, to 4,200 Dalmatian pelicans
can still be found in the world, and the species
is classifi ed by the IUCN Red List as Vulnerable
(A2ce+3ce) (assessment in 2006). Studies in
Mongolia record declines over the last 50 years for
most areas. In 1956, over 300 were counted on
Shuvuun Tsuglaan and Khar Us Lake. By 1972,
this number had dropped to 207, and to only
10 birds by 1981. Surveys record just over 200
Pelicans present in Mongolia today (WWF 2004).
e Dalmatian pelican has been traditionally
hunted by Mongolians for its beak, which is used
to scrape sweat off horses after a run. Highly
prized, Dalmatian pelican beaks are now one of
the most expensive wildlife parts in the country.
Prices probably vary, but wildlife trade researchers
were quoted $2,000 by traders at an outdoor
market in Ulaanbaatar. e limited supply has
also resulted in the production of imitation beaks
carved from ibex and cattle horns. Imitation beaks
are openly displayed while real specimens are not.
2) Ta i men (Hucho taimen)—Classifi ed by the
Mongolian Red List of Fishes (Ocock et al. in
press) as Endangered and listed as “rare” in the
Mongolian Law on Fauna. Take is restricted to
sport fi shing for which the Ministry of Nature
and Environment has set a $150–300 price tag
depending on the size of the fi sh. In 1996, the
IUCN Red List assessed the taimen’s European
relative (H. hucho) as Endangered (A2bcde,
B1+2bce). At this time the Mongolian population
was regarded as a subspecies of H. hucho, and it
was thus included within the Endangered clas-
sifi cation; it is now recognized as a separate species
in its own right.
e largest of all freshwater salmonids (capable
of exceeding two meters in length), the taimen
is an especially important species in Mongolia’s
rivers, both ecologically and economically. e
known distribution stretches from the Urals in
the west across Siberia to the Amur River basin.
Little is known about the life history of taimen in
Mongolia. According to studies in river systems
connected or adjacent to Mongolia, Siberian
taimen exhibit increasing migration patterns
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130
as they grow in size, seeking out ever deeper
over-wintering habitat. Popular belief holds that
older taimen establish over-wintering holes to
which they return year after year (Augerot 2000).
Because of the length of time to fi rst breeding
(up to 6 or 7 years) relatively low densities, and
long lifespans (>30 years), taimen are extremely
vulnerable to over-fi shing.
Despite restrictions, Mongolia’s taimen are
harvested both for personal consumption and
to supply an increasing market in Ulaanbaatar’s
restaurants and food stores. Prices range from
$1–3 per kg. No data are available on the average
weight of taimen, but it is not unusual for one fi sh
to weigh 20 kg, with the largest weighing as much
as 50 kg. Using the lower weight of 20 kg makes
one taimen worth approximately $20 to $60 on
the market in Mongolia. e wildlife trade survey
was unable to estimate the probable volume of
sales due to low response rate from interviewees,
but anecdotal information suggests that taimen is
common fare in many markets and restaurants.
In addition, several fl y-fi shing companies off er
trips with some (in particular, the Association of
Mongolian Angling Guides, www.taimen.mn)
limiting their activities to catch-and-release only.
eir eff orts, however, remain a self-regulated
attempt to conserve the resource while ensuring
that local communities benefi t from the use and
provide an alternative to poaching. e Law on
Hunting has not yet been amended to support
such initiatives.
3) Lynx (Lynx lynx) — e Eurasian lynx is listed
by the Law on Fauna as “rare” and may be hunted
for “special” purposes pursuant to the Law on
Hunting. e hunting season extends from
October 21st to February 16th. e species is
listed in the Mongolian Red List of Mammals
(2006) as Least Concern. e IUCN Red List’s
global classifi cation of the species lists it as Near
reatened (assessment in 2002) and international
trade is restricted by CITES Appendix II status.
e Eurasian lynx is found in the forests of
northern Europe and in the Siberian taiga from
the Ural Mountains to the Pacifi c. In 1992, the
Russian population was estimated at 36,000-
40,000 (Matjuschkin 1978, Zheltuchin 1992).
In China, lynx populations are widely if patch-
ily distributed throughout the country, mostly
concentrated in mountainous regions.
No recent studies have been completed on
Mongolia’s population. ey are thought to occur
mostly in the northern taiga forests, but at least
one individual was sighted as far south as the
Ooshiin Gobi, some 700 kilometers southeast of
Ulaanbaatar and the taiga’s southernmost extent
in the country (Reading pers. comm. 2005).
Bannikov (1954) described lynx as common in the
desert hills of south-western Mongolia.
Historically, Mongolia traded lynx pelts to the
Soviet Union, averaging 440 pelts per year from
1958 to 1974. Offi cial records do not show any
trade from that date forward. Today, lynx pelts are
one of the more common furs seen in Mongolia’s
markets following wolf, red fox, and corsac fox.
Hunters interviewed in the wildlife trade survey
were all from towns located along the northern
taiga forest region in Mongolia. Mean harvest
rates were 1.2 per hunter. Response rates were too
low to estimate probable total harvest volumes.
High quality winter pelts sell for $80 while pelts
from other seasons are only $25. Despite export
trade restrictions, a surprising number of traders
market skins to foreign tourists as souvenirs.
Undetermined quantities of pelts are also exported
directly to markets in China where they are
available for between $100 and $200. Mounted
lynx trophies from Mongolia can also be found
in China’s border markets commanding prices as
high as $375.
4) Pallas’ Cat (Otocolobus manul)—Classifi ed by
IUCN as Near reatened (assessment in 2002)
and listed in CITES Appendix II, neither the
Mongolian Law on Fauna nor the Law on Hunt-
ing off er any special or protected status to this
species. It also has no established hunting season
and so, by default, may be hunted year round. e
Mongolian Red List of Mammals (2006) lists the
species as Near reatened.
O. manul is a small cat weighing between 2-4
kg (Heptner and Sludskii 1992). It has a wide
distribution in Mongolia, inhabiting the steppes,
high deserts, and mountainous country and can
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
131
be found at elevations exceeding 4,000 meters, It
shelters in caves or burrows and feeds primarily on
small mammals and ground-dwelling birds.
Records made available to the wildlife trade
research team show historical trade in Pallas’ cat
skins beginning in 1965 and trade averaging over
5,400 skins annually until 1985. However, other
sources note that as many as 50,000 animals may
have been traded in the early 1900s, with harvests
averaging 10,000 animals per year from the 1920s
to 1980s (Heptner and Sludskii 1992, Nowell and
Jackson 1996). While there may have been some
restrictions on trade in place in Mongolia under
the former regime, this is no longer the case and
Pallas’ cat pelts are once again being traded at lo-
cal markets. ere is no evidence of international
trade from this survey, although this should not
be ruled out.
Pallas’ cat pelts are not considered high quality
fur and therefore have low values compared to
Mongolia’s other wildcat species, snow leopard
and lynx. Local hunters responding to the survey
reported selling small quantities (1 or 2 pelts) for
just $3 per skin. However, in addition to the fur
trade, Mongolians also harvest O. manul for its
oil and meat, both of which are purported to have
medicinal properties. Sold in small quantities, the
oil is sold for $4 per gram. No price was quoted
for game meat.
5) Eurasian Red Squirrel (Sciurus vulgaris)—
Classifi ed by IUCN as Near reatened (assess-
ment in 2002), Mongolia’s red squirrel population
may be hunted for household and commercial
purposes from October 21st to February 16th. It
has no status under CITES and is not protected
by Mongolia’s Law on Fauna. It is listed in the
Mongolian Red List of Mammals (2006) as Least
Concern.
Although there are few studies on S. vulgaris in
Mongolia, anecdotal information suggests that
the species is ubiquitous throughout the northern
woodlands representing roughly 8 percent of
Mongolia’s territory (200,000 km2). A 1966
study described high population numbers in areas
around Mongonmort, a town situated northeast
of Ulaanbaatar on the border of the present-day
Khan Khentii Strictly Protected Area and within
the taiga forest zone. A 1987 study conducted in
a forested region near Batshireet, also located in
the taiga forests of the Khan Khentii, reported
sightings of only a few individuals and hunter
harvests of only 4 animals. Without more detailed
and systematic study, it is impossible to say what
the trend in red squirrel populations was over
time. During the wildlife trade survey, hunters
reported drastically reduced numbers with large
forested areas virtually devoid of squirrels where
they were once plentiful.
Historic trade in squirrel skins began in 1932 with
an initial trade volume of 77,530. From then to
1985, with a brief respite from 1976-1980 when
hunting was banned, Mongolia offi cially recorded
procuring more than 4 million skins with a
peak volume of 231,000 in 1953 and an annual
average of just over 77,000. e few wildlife trade
surveys conducted in Mongolia since 1991 have
not focused on red squirrels. Reported volumes
are therefore only a small portion of the overall
trade and exist only for certain years. Scharf and
Enkhbold (2002), for example, report seizures
from 1999-2001 by Chinese Customs offi cials
of just 1,425 squirrel skins among other traded
wildlife products. Our wildlife trade survey
estimates more than 6,500 hunters (n=32 of 949
hunters) actively harvesting red squirrels. Mean
harvest volumes were 27.2 animals per hunter
with an estimated total trade volume exceeding
170,000 skins in 2004. Although hunters reported
selling skins to wholesale and black markets for
$2–$3 per skin, no red squirrel trade was visible
on the markets in Mongolia or China. is appar-
ent absence of trade is likely a result of the timing
of the survey (summer) not coinciding with the
primary trading seasons of winter and fall.
6) Ibex (Capra sibirica) —Last evaluated in 1996,
Siberian ibex is classifi ed by IUCN as Lower
Risk/Least Concern. e species has no status
under CITES, but is listed in the Law on Fauna
as “rare.” Hunting is restricted to trophy hunting
by the Law on Hunting, with the season running
from June 1st to November 15th. e Mongolian
Red List of Mammals (2006) classifi ed the species
as Near reatened.
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Mongolia
132
Capra sibirica is widely distributed through
eight range states including Afghanistan, China,
India, Kyrgyzstan, Mongolia, Pakistan, Russia,
and Tajikistan. e Siberian ibex is primarily an
alpine species that inhabits rocky hills typically at
altitudes of 3,000-5,000 meters (Nowak 1999).
In Mongolia, Siberian ibex may also be found at
lower elevations (1,500 meters) in areas provid-
ing adequate escape terrain such as Ikh Nart
Nature Reserve (Wingard 2005). C. sibirica is a
gregarious animal living in herds as large as 40-50
animals. Older males are often solitary or in small
groups of 3-4, frequently in more inaccessible
terrain.
Despite its status as a prized trophy animal among
international big game hunters, the Siberian ibex
has not been adequately studied in Mongolia. e
Mongolian Red Book (1997) cites a population
of 80,000 (without reference to when the last
survey was performed) distributed throughout
the Mongolian Altai, Gobi-Altai, Zuungariin
and Trans-Altai Gobi, Khan Khokhii, Khoridol
Saridag and Ulaan Taiga Ranges as well as the
desert and desert-steppe regions in Dundgobi and
Dornogobi amaigs. With increased pressure from
trophy hunting and poaching, it is likely that the
population has declined substantially from these
numbers. Other threats include competition with
domestic livestock for grazing and water, fatal
diseases, parasites, and severe winters (Mongolian
Red Book, 1997).
C. sibirica is hunted by Mongolians for its horns,
meat, blood, and skin. Similar to roe deer, the
blood is considered to have healing properties and
is one of the primary uses reported by 14 respon-
dents to the wildlife trade survey. Supply sources
for all parts were evenly split between the informal
network of friends/hunters and formal markets
located in soum centers; however, skin was the
only product for which respondents gave a price,
$2. To estimate the value of game meat, we used
the mean weight from hunter responses to the
survey of approximately 40 kg and gave a value
of $2/kg as a substitute for purchasing domestic
meat for a total of $80. e horns are also valued
as trophies and fetch $30 on the market in China.
e number of hunters targeting the species is
diffi cult to estimate. During the survey, only 8
hunters claimed to harvest ibex and all of whom
personally consumed the meat. e mean harvest
was 2.1 with one individual claiming a harvest of
20.
Trophy hunting also factors into the total volume
of take. From 1995 to 2000, the Ministry of
Nature and Environment authorized a total of
1,310 trophy licenses (Wingard and Odgerel,
2001). None were apparently issued in 2001.
7) Black-tailed gazelle (Gazella subgutturosa)—
is species was evaluated as Near reatened
by IUCN (assessment in 2005), and is classifi ed
as “rare” by the Mongolian Law on Fauna. e
Mongolian Red List of Mammals (2006) classifi es
the species as Vulnerable. Commercial hunting
has been prohibited since 1962 and a total hunting
ban enforced beginning in 1965. Only trophy
hunting is permitted by the Law on Hunting.
Black-tailed or goitered gazelle inhabit the south-
ern plains of Mongolia’s Gobi and Trans-Altai
desert region. Its distribution is closely associated
with spear grasses (Stipa spp.) and aggregations
of Stipa glareosa-Anabasis brevifolia in mountain
foothills; with saxaul (Haloxylon ammondendron)
and Russia thistle (Salsola spp.) in the Gobi; and
generally with shrubs and bushes in desert and
sandy steppe regions (Mongolian Red Book 1997).
Likely due to over-exploitation and competition
with domestic livestock for forage, G. subgutturo-
sa’s population and distribution sharply declined
in the 1950s and 1960s and even disappeared in
some areas. e population apparently rebounded
beginning in the 1980s, but has never reached its
former numbers. e Mongolian Red Book quotes
a current population of 60,000 without indicat-
ing when this information was collected. High
mortality during severe winters remains a concern,
as does population fragmentation resulting from
illegal hunting and disturbance (Mongolian Red
Book 1997).
Unlike Mongolian gazelle, black-tailed gazelle
were never formally traded to the Soviet Union.
By all accounts, however, subsistence use played a
signifi cant role in historic distribution reduction
and population declines. Subsistence use con-
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
133
tinues at some level in spite of legal constraints.
In the wildlife trade survey, only 6 individuals
claimed to harvest the species, with one individual
reporting a total take of 30 and the others 2-4.
e large volume by one individual is at least an
indication of commercially motivated harvests at
the local level. Another respondent who reported
purchasing black-tailed gazelle meat from the
local soum market confi rmed this suspicion.
Responses to the survey are unfortunately too low
to hazard a guess at the total of either subsistence
or commercial harvests.
Although smaller than the Mongolian gazelle,
black-tailed gazelles still produce relatively long
horns averaging 25-32 centimeters with trophies
as large as 40 centimeters. Trophy hunting outfi ts
off er black-tailed gazelle hunts in Mongolia as side
game to argali hunts.
8) Asiatic Wild Ass (Equus hemionus)— e
IUCN Red List classifi ed the Asiatic wild ass as
Vulnerable (A3bcd; C1) in 2002. International
trade is restricted under CITES Appendix II. e
species is listed in the Law on Fauna as “rare,” and
hunting is limited to “special” purposes by the
Law on Hunting, allowing the take of this species
for undefi ned “cultural” purposes. Sport hunting
is also permitted under this category, but none are
apparently off ered. e Mongolian Red List of
Mammals (2006) lists the species as Vulnerable.
E. hemionus (or “khulan” in Mongolian), includ-
ing its various subspecies, is one of the most
endangered large herbivores in the arid palearctic
zone. e status of E. h. hemionus in northeastern
Mongolia is presently unknown, but presumed
extinct in the wild (Cromsigt 2000). E. h. luteus,
a subspecies found in the Gobi Desert region of
southern Mongolia and northern China, was esti-
mated at only 10,000 in 1985 by Mallon (1985).
Although recent population surveys estimate that
as many as 20,000 persist in Mongolia, increasing
pressure by humans, including direct off take by
poachers, is resulting in rapidly declining numbers
and a shrinking distribution across its range.
E. h. luteus is hunted by Mongolians in the
southern Gobi aimags for its meat and the
medicinal properties of the liver. All products are
available at local markets, and anecdotal informa-
tion indicates that khulan game meat has been
processed into sausages in Ulaanbaatar for sale
in food markets. In any event, all such uses are
illegal. In the wildlife trade survey, 17 individuals
reported harvesting on average 4.2 animals in
2004. Khulan are not small animals and, accord-
ing to hunters who harvest the animal, can yield
between 100 kg and 180 kg of game meat. At 150
kg and a reported market price $2 per kg, one
khulan has an approximate domestic market value
of $300, not counting the value of the liver, which
sells separately for $5.
9) Lenok (Brachymystax lenok)—Lenok have
no classifi cation in the IUCN Red List, have no
trade status under CITES and may be harvested
in Mongolia pursuant to the Law on Hunting for
personal consumption. e species is classifi ed as
Vulnerable in the Mongolian Red List of Fishes
(in press).
e lenok is a medium-sized member of the
salmonid or trout family. It can reach over 50
cm in length and weigh 3-5 kg, although most
lenok caught are smaller. ey are fairly common
in most streams and rivers in northeastern Asia,
including Mongolia’s northern aimags. Two
forms are known in Mongolia, one with a down-
turned (subterminal) mouth and the other with
a terminal mouth—it is not known if these are
simply diff erent morphs or subspecies. Lenok are
found in cold-water streams and rivers, rarely in
lakes, and are a target of both local subsistence
fi shing and international sport fl y-fi shing,
although ranking a distant second in importance
to its giant relative the taimen.
Because of unclear responses from interviewees,
this survey is unable to estimate the total take
and trade of lenok in Mongolia. Respondents
to the survey did, however, indicate that lenok
have entered the local market stream and may be
purchased for about $1/kg, or roughly $3 per fi sh.
10) Altai snowcock (Tetraogallus altaicus)—Altai
snowcock are classifi ed as Least Concern by the
IUCN Red List and appear in the Mongolian Red
Book (1997). e Mongolian Law on Fauna clas-
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Mongolia
134
sifi es the species as “rare” and the Law on Hunting
permits their take for “special” purposes.”
e fi ve species of snowcock are all large gal-
linaceous birds found in mountains throughout
Asia. e Altai snowcock is limited to the Altai
Mountains of Mongolia, Russia, Kazakhstan and
China. ere they are found in the alpine zone
above treeline, where they roost on steep cliff s and
forage for roots, tubers, and other vegetation in
the early morning and late afternoon. ey live
in small fl ocks and do not migrate. e global
population was estimated at between 50,000-
150,000, with Mongolia holding the majority of
the population (Madge and McGowan 2002). e
authors identify the traditional medicinal market
as a threat to the small Chinese population, as
snowcock is considered a cure for rheumatism.
Hunted for both its game meat and the medicinal
properties, Altai snowcock was one of the most
common bird species hunted by respondents to
the wildlife trade survey. Still, only 2 percent
of all hunters (n=20 of 949) claimed to hunt it.
Potentially more than 3,000 hunters target the
species. e mean harvest per hunter was 4.5
with a maximum harvest for one hunter of 24.
e total harvest for 2004 is estimated at 14,600
birds. Available at local markets, the reported
price for one bird was approximately $3.50.
Almost 2 percent of all respondents to the survey
(n=71 of 4,010) reported using T. a l taicus with the
overwhelming majority (n=56 of 71, 79 percent)
interested in the game meat for its medicinal prop-
erties. Of all users, few (n=5, 7 percent) obtained
birds directly from hunters; the rest purchase Altai
snowcock at local markets for approximately $10
per bird.
Other Species
A number of other species receive at least some
hunting pressure, some of which are not covered by
either national legislation or international conventions.
is list includes six mammals (Eurasian badger,
ground squirrel, muskrat, American mink, sable, and
Daurian hedgehog), at least 12 species of bird (Cinere-
ous vulture, black-eared kite, great bustard, snowy
owl, ptarmigan, greylag goose, Daurian partridge,
black grouse, gadwall, Arctic loon, Eurasian eagle owl,
and Pallas’ sandgrouse), and a number of fi sh species
(Northern pike, Siberian whitefi sh, Potanin’s osman,
common wild carp, catfi sh, Arctic grayling, and
Eurasian perch).
e Eurasian badger is harvested both for its pelt and
for the medicinal properties of its meat, oil, stomach,
and blood. Respondents to the survey reported obtain-
ing badger products from several sources including
local hunters, black markets, soum center markets, and
Ulaanbaatar train station market. Ground squirrel,
muskrat, American mink, and sable are all harvested
for their fur, with sable the most expensive selling
for $35 per pelt. While sable is an important part
of fur trade in Russia, the wildlife trade survey in
Mongolia had only one respondent claim to hunt the
species, despite interviewing more than 300 hunters
in regions with suitable habitat. e lack of response
may be more an indication of reluctance to respond
on the part of hunters than lack of trade. Muskrat and
American mink are both introduced species and are
therefore not a concern for this study.
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– 135 –
Appendix C:
Tables
Table C1: Legal and Conservation Status of Harvested Species
No. Scienti c Name Common Name
IUCN Red L ist (2006)
Global category20 CITES21
Mongolian
Red List s
(2006)
(Mammals
and Fish)
Law on
Fauna22
Law on
Hunting23
Mammals
1. Spermophilus und ulatus24 Long-tailed ground squirrel LR/lc 1994 (1996) LC H/I
2. Ondatra zibethicus Muskrat LR /lc 1994 (1996) N/A
(introduced)
H/I
3. Mustela vison American mink LR/lc 1994 (1996) N/A
(introduced)
H/I
4. Mesechinus dauuricus Daurian hedgehog LR /lc 1994 (1996) LC H/I
5. Marmota sibirica Siberian marmot LR/lc 1994 (1996) EN H/I
6. Marmota baibacina Altai marmot LR/lc 1994 (1996) DD H/I
7. Meles meles Eurasian badger LR /lc 1994 (1996) LC H/I
8. Sciurus vulgaris Red squirrel NT 2001 (2002) LC H/I
9. Vulpes vulpes Red fox LC 2001 (2004) NT H/I
10. Procapra gu tturosa Mongolian gazelle LC 2001 (2005) EN H/I
11. Capreolus pygargus Roe deer LR/lc 1994 (1996) LC H/I
12. Alticola barakshin Gobi-Altai mountain vole LR/lc 1994 (1996) DD H/I
13. Martes zibellina Sable LR /lc 1994 (1996) VU H/I
14. Vul pes corsa c Corsac fox LC 2001 (2004) N T H/I
15. Canis lupus Gray wolf LC 2001 (2004) II NT H/I
16. Ursus arctos Brown bear LR/lc 1994 (1996) I DD H/I
17. Otocolobus manul Pallas’ cat N T 2001 (2002) II NT H/I
18. Cer vus elaphus Red deer LR/lc 1994 (1996) CR R Special
19. Martes foina Stone marten LR/lc 1994 (1996) DD R Special
20. Gazella subgutturosa Black-tailed gazelle or Goitered
gazelle
NT 2001 (2005) VU R Special
21. Sus scrofa Wild boar LR/lc 1994 (1996) NT R Special
22. Capra sibirica Siberian ibex LR/lc 1994 (1996) NT R Special
23. Lynx lynx Eurasian lynx NT 2001 (20 02) II LC R Special
24. Ovis ammon Argali VU A2cde 1994 (1996) II EN R Special
25. Equus hemion us Asiatic wild ass VU A3bcd; C1 2001
(2002)
II VU R Special
26. Castor ber Beaver NT 2001 (2002) EN VR Scienti c
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Mongolia
136
No. Scienti c Name Common Name
IUCN Red L ist (2006)
Global category20 CITES21
Mongolian
Red List s
(2006)
(Mammals
and Fish)
Law on
Fauna22
Law on
Hunting23
27. Alces alces cameloides Ussurian moose LR/nt 1994 (1996) EN VR Scienti c
28. Alces alces p zenmayeri Yakut m oose LR /lc 199 4 (1996) EN VR Sci enti c
29. Saiga ta tarica mongo lica Saiga antelope EN A2ad; C1+2a(ii)
2001 (2005)
II EN VR Scienti c
30. Moschus moschiferus Musk deer VU A1acd 1994 (1996) II EN VR Scienti c
31. Uncia uncia Snow leopard EN C2a(i) 2001 (2002) I EN VR Scienti c
Birds
1. Perdix da uurica Daurian partridge LC 2001 (2004) H/I
2. Corvus corax Northern raven LC 2001 (2004) H/I
3. Milvus li neatus Black-eared kite LC 2001 (2004) II H/I
4. Anas strepera Gadwall LC 2001 (2004) H/I
5. Tetrao tetrix Black grouse LC 2001 (2004) H/I
6. Aquila spp. Eagle species H/I
7. Nyctea scandiaca Snowy owl LC 2001 (2004) II H/I
8. Lagopus lagopus Willow ptarmigan LC 2001 (2004) H/I
9. Anser anser Greylag goose LC 2001 (2004) H/I
10. Gavia arctica Arctic loon LC 2001 (2004) H/I
11. Syrr haptes parad oxus Pallas’ sandgrouse LC 2001 (2004) H/I
12. Prunella montanella Siberian accentor LC 2001 (2004) H/I
13. Falco cherrug Saker falcon EN A2bcd+3bcd 20 01
(2004) II *25
14. Bubo bubo Eurasian eagle owl LC 2001 (2004) II H/I
15. Aegypius monachus Cinereous vulture NT 2001 (2006) II H/I
16. Tetraog allus altaicus Altai snowcock LC 2001 (2004) R Special
17. Otis tarda Great bustard VU A3c 2001 (2004) II R Special
18. Pelecanus crispus Dalmatian pelican VU A2ce+3ce 2001
(2006)
IVRScienti c
Fish
1. Esox lucius Northern pike NE LC H/I
2. Brachymystax lenok Lenok NE VU H/I
3. Oreoleuciscus potanini26 Potanin’s osman NE LC H/I
4. Thymallus arcticus Siberian grayling NE NT H/I
5. Silurus asotus Cat sh NE LC H/I
6. Lethenteron reissneri27 Eastern brook lamprey NE N/A
7. Coregonus spp.28 Siberian white sh H/I
8. Cyp rinu s car pio 29 Wild common carp DD 1994 (1996) N/A
(introduced)
H/I
9. Perca uviatilis River perch LR/lc 1994 (1996) LC H/I
10. Hucho taimen Taim en NE EN R Spe cia l
Table C1: Legal and Conservation Status of Harvested Species
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
137
20 CR—Critically Endangered, EN—Endangered, VU—Vulnerable, LR /nt or NT—Near reatened, LR/lc or LC—Least Concern, NE—Not
Evaluated, DD— Data Defi cient. e fi rst year listed is the date the categories and criteria used in the assessment were defi ned; the year in
parentheses is the date of the most recent assessment.
21 I— CITES Appendix I, II—CITES Appendix II
22 VR—very rare, R—rare. e scientifi c names for some species listed under Mongolian laws are not valid, and hence may diff er from those listed
in this table.
23 H/I—hunting permitted for household and industria l purposes; Special—trophy hunting permitted; Scientifi c—ta ke of animals permitted for
research purposes.
24 e Mongolian laws refer to Citellus undulatus, an invalid name which may be intended to cover more than one species of ground squirrel.
25 No apparent status in Mongolia’s hunting legislation.
26 Two other species of osman, O. angusticephalus and O. humilis are also listed in the Law on Hunting. ese species are less widespread than O.
potanini and were both classifi ed as Vulnerable in the Mongolian Red List of Fishes (Ocock et al. in press).
27 It is commonly believed that the arctic lamprey (Lethenteron camtschaticum) is present in Mongolia; a taxonomic review of Mongolia’s fi shes
currently underway determined that there is in fact no valid evidence for the occurrence of this species in Mongolia (Kottelat in prep). e only
defi nitively identifi ed species in the country is the Eastern brook lamprey, L. reissneri. Less than 1 percent of the population occurs in Mongolia,
and hence a regional assessment is not appropriate.
28 Mongolia’s laws refer to Coregonus lavaretus, a name used regionally as a catch-all for possibly as many as 50 –100 species, but is in fact only
valid for a species endemic to Lake Bourget in France. A taxonomic review by Maurice Kottelat (in prep) conservatively identifi ed three
Coregonus species native to Mongolia (C. pidschian, C. chadary and C. migratorius) and one introduced species (C. peled)—further ta xonomic
work would no doubt reveal more species. C. pidschian is commercially fi shed, and was classifi ed by the Mongolian Red List of Fishes (in press)
as Endangered. Both C. peled and C. pidschian have the global classifi cation of Data Defi cient on the IUCN Red List (assessment in 1996).
29 e wild common carp, Cyprinus carpio, is introduced in Mongolia; only C. rubrofuscus (the C. haematopterus of Russian and Chinese
literature) is native (Kottelat in prep). C. rubrofuscus is native to the Amur river basin, and may also be in trade; further work would be needed
to determine this.
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Mongolia
138
Table C2: International and Domestic Trade Purpose of Targeted Species
No. Scienti c Name Common Name
Interna tional Trade Purpose Domestic Trade Pu rpose
Fur Meat Medi-
cinal Troph y Other Fur Meat Medi-
cinal Troph y Other
Mammal Species
1. Sciurus vulgaris Red squirrel X
2. Mustela vison American mink X
3. Lynx lynx Eurasian Lynx X
4. Spermophilus undulatus Long tailed ground squirrel X
5. Castor ber Beaver X
6. Vulpes vulpes Red fox X X
7. Lepus tibetanus Tibetan hare X X
8. Marmota sibirica Siberian marmot X XXX
9. Marmota baibacina Altai marmot X XXX
10. Meles meles Eurasian badger X X X
11. Uncia uncia Snow leopard XXXXX
12. Vul pes corsa c Corsac fox X X X
13. Canis lupus Gray wolf XXXXX
14. Ursus arctos Brown bear XXXXXX
15. Martes zibellina Sable X X X
16. Ondatra zibethicus Muskrat X XXX
17. Moschus moschiferus Musk deer X X
18. Equus h emionus Asiatic wild ass X X
19. Sai ga tatarica mo ngolica Saiga antelope X X X
20. Cervus elaphus Red deer XX XX
21. Capra sibirica Siberian ibex X X X
22. Ovis ammon Argali X X X X
23. Sus scrofa Wild boar X X
24. Procapra gut tuorosa Mongolian gazelle X X
25. Gazella subgutturosa Black-tailed gazelle X X
26. Alces alces cameloides Ussurian moose X X
27. Alces alces p zenmayeri Yaku t moos e X X
28. Capreolus pygargus Siberian roe deer X XXX
29. Otocolobus manul Pallas’ cat X X
30. Mesechinus dauuricus Daurian hedgehog X X
31. Alticola barakshin Gobi-Altai mountain vole X
Bird Species
1. Falco cherrug Saker falcon X
2. Aeg ypius monachus Cinereous vulture X
3. Milvus lineatus Black-eared kite X
4. Otis tarda Great bustard X
5. Perd ix dauuricae Daurian partridge X X
6. Tetraogallus altaicus Altai snowcock X X
7. Corv us corax Northern raven X
8. Pelecanus crispus Dalmatian pelican X
9. Bubo bubo Eurasian eagle owl X
10. Tetrao tetrix Black grouse X
11. Nyctea scandiaca Snowy owl X
12. Lagopus lagopus White ptarmigan X
13. Anser anser Greylag goose X
14. Anas streptera Gadwall X
15. Gavia arctica Arctic loon X
16. Syr rhaptes parad oxus Pallas’ sandgrouse X
17. Prunella montanella Siberian accentor X
18. Aquila spp. Eagle species X
Fish Spec ies
1. Hucho taimen Taimen X X X X
2. Brachymystax lenok Lenok X X X X
3. Perca uviatilis River perch X X
4. Esox lucius Nor thern pike X X
5. Thymallus arcticus Siberian grayling X X
6. Core gonus spp. Siberian white sh X
7. Oreoleuciscus potanini Potanin’s osman X
8. Cy pri nus ca rpi o Common wild carp X
9. Silur us asotus Cat sh X
10. Lethenteron reissneri Eastern brook lamprey X
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
139
Table C3: Wildlife Product Market Values by Species
No.Scienti c Name Common Name Game
Meat Skin Medicinal and Cultural Products Mounted
Trophy
Domestic Trade
Value s30
Sport
Hunting31
Gall
bladder Gland Horns/
Antlers Other
Mammal Species
1. Ovis ammon Argali 240.0032 — — — — — 275.00 515.00 40,000.0033
2. Cervus e laphus Red deer 200.00———700.00
26 85.0027 200.00 985.00 5,000.0036
3. Al ces alces p zenmayeri Yakut moose 400.00 — — — — — 500.00 900.00 5,000.00
4. A lces alces camel oides Ussurian moose 40 0.00 400.00 —
5. Sus scrofa Wild boar 200.00—————— 200.004,500.00
37
6. Capreolus py gargus Siberian roe deer 40.00 6.00 — — — *38 — 46.00 4,500.0039
7. Capra sibirica Siberian ibex 80.00 2.00 — — 30.00 — — 112.00 4,000.00
8. Canis lupus Gray wolf 50.00 250.00 1.50 — — 8.5040 375.00 310.00 3,500.0041
9. Procapra guttu rosa Mongolian gazelle 40.003.00————— 43.003,500.00
42
10. Gazella subgutturosa Black-tailed gazelle 20.00—————— 20.00 2,750.00
11. Vul pes corsa c Corsac fox 37.0028.00————— 65.00 100.00
43
12. Vulpes vulpes Red fox —18.00————— 18.00 100.00
13. Ursus arctos Brown bear 800.00 100.00 8.00 200.00 — 232.0044 —1,340.00 —
14. Equus h emionus Asiatic wild ass 300.00—————— 300.00 —
15. Uncia uncia Snow leopard 22.5045 250.00————— 272.50 —
16. Moschus moschiferus Musk deer ———120.00——— 120.00 —
17. Martes zibellina Sable 35.00 37.5046 ———— 72.50 —
18. Sa iga tatarica m ongolica Saiga antelope ————60.00 — — 60.00 —
19. Otocolobus manul Pallas’ cat 25.00 3.00 — — — 20.0047 —48.00 —
20. Castor ber Beaver —40.00————— 40.00 —
30 Lists the highest possible combined market value for domestic uses and products traded internationally, to the extent such uses a re not mutually exclusive. For example, red deer domestic value includes
game meat, antlers, and medicinal parts, but excludes mounted trophy va lue.
31 Sport hunting values are based on average costs to the consumer quoted to wild life trade researchers or advertised on the Internet. ey include the cost of t he tour, trophy fees, government permit and
license fees, but not travel to and from Mongolia.
32 Based on average game meat yield of 120 kg and a substitute meat value of $2/k g.
33 Argali sport hunting license and permit is $25,000 . Actual hunts vary in cost from $70,000 to $35,000 .
34 Price is for blood antlers weighing 5 kg each priced at $70 per kg. is estimate is probably low. Mature bull red deer can produce as much as 10 kg per antler.
35 Includes price of tail ($30 ), female genitals ($25 ), and male genita ls ($30 ).
36 Includes $700 trophy hunting license (MNE 2004).
37 Wild boar trophy is $400 (MNE 2004).
38 Roe deer blood available on local markets. No price quoted.
39 Roe deer trophy permit is $900 (M NE 2004).
40 Includes price of 1 gray wolf tongue ($5 ), 1 spleen ($ 0.50 ), lung ($1.50 ), and kidney ($ 1.50 ).
41 Gray wolf trophy permit $400 , exportation taxes $586 (MNE 2004).
42 Mongolian and black-tailed ga zelle trophy permit is $300 (MNE 2004).
43 Sport hunting license fee. No known sport hunts off ered.
44 Includes price of four bear paws valued at $50 /ea ($200 tota l) and the value of brown bear oil used for medicina l purposes, $32 .
45 Based on the minimum average snow leopard weight of 30 kg, 50 percent of which is usable meat, and a substitute per kilo price of $1.50 .
46 Price based on average sale value in Mongolia and China. Highest recorded value was $275 for high-quality specimens on the market in China.
47 Price is for Pallas’ cat oil from one a nima l as quoted by survey respondent.
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140
No.Scienti c Name Common Name Game
Meat Skin
Medicinal and Cultural Produc ts Mounted
Trophy
Domestic Trade
Value s30
Sport
Hunting31
Gall
bladder Gland Horns/
Antlers Other
21. Meles meles Eurasian badger — 12.0048 —— —27.00
49 —39.00 —
22. Lynx lynx Eurasian Lynx —30.00————— 30.00 —
23. Marmota baibacina Altai marmot 10.00 13.00 1.00 — — 6.5050 27.50 —
24. Marmota sibirica Siberian marmot 7.00 10.00 1.00 — — 6.50 24.50 —
25. Spermophilus undulatus Long tailed ground squirrel —7.00————— 7.00 —
26. Ondatra zibethicus Muskrat 1.00 5.00 — — — * — 6.00 —
27. Lepus tibetanus Tibetan hare 2.002.50————— 4.50 —
28. Sciurus vulgaris Red squirrel —2.00————— 2.00 —
29. Mustela vison American mink — *51 ————— No price —
30. Mesechinus dauuricus Daurian hedgehog ———— — *
52 —No price —
31. Alticola barakshin Gobi-Altai mountain vole ———— — *
53 —No price —
Bird Species
1. Pelecanus crispus Dalmatian pelican ———— —2,000.00
54 — 2,000.00 —
2. Aquila spp. Eagle species ———— —1.00
55 200.00 20 0.00 — —
3. Aegypius monachus Cinereous vulture — — — — — — 150.00 150.00 —
4. Milvus lineatus B lac k-e are d k ite — — — — — — 120 .00 120 .00 —
5. Otis tarda Great bustard 30.0056 —————— 30.00 —
6. Nyctea scandiaca Snowy owl —25.00————— 25.00 —
7. Tetraogallus altaicus Altai snowcock 10.00—————— 10.00 —
8. Lagopus lagopus White ptarmigan 10.00—————— 10.00 —
9. Anser anser Greylag goose 8.0057 —————— 6.00 15–350
10. Perdi x dauuricae Daurian partridge 6.00—————— 6.00 10.00
11. Tetrao tetrix Black grouse 5.00—————— 5.00 10.00
12. Anas streptera Gadwall 1.50—————— 1.50 10.00
13. Gavia arctica Arctic loon 1.50—————— 1.50 10.00
14. Syr rhaptes para doxus Pallas’ sandgrouse 0.30—————— 0.30 —
15. Falco cherrug Saker falcon ——————— —4,660.00
58
48 Price based on average weight of one adult badger of 10 kg to 16 kg (approximately 8 k g of meat) and a substitute per kilo price of $1.50 .
49 Includes price of oil, $2 and stomach $25 ; both are used for Mongolian traditional medicine.
50 Includes price of kidney ($1), lung ($2.50), a nd oil ($3).
51 Skin traded on the international market with China. No price quoted.
52 Live specimens for sale at local markets. No price quoted.
53 Used for medicinal purposes, but no price quoted by interviewee.
54 Dalmatian pelican beaks are traditionally used a s sweat blades to wipe the sweat of a horse. Price quoted by trader at the Naraan Tuul market in Ulaanbaatar.
55 Price for one eagle beak on the local market in Mongolia.
56 Estimated value based on average weight of 18 kg and game meat yield of 15 kg priced at $2 /kg.
57 Estimated value based on average game meat yield of 4 kg per bird priced at $2 /kg.
58 Value based on offi cial export revenue statistics for off take levels and total receipts from direct payments and fees (MNE 2004).
Table C3: Wildlife Product Market Values by Species (cont.)
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
141
No.Scienti c Name Common Name Game
Meat Skin Medicinal and Cultural Products Mounted
Trophy
Domestic Trade
Value s30
Sport
Hunting31
Gall
bladder Gland Horns/
Antlers Other
Bird Species
16. Bubo bubo Eurasian eagle owl ———— — — —
17. Corvus co rax Northern raven ———— — — *
59 No price —
18. Prunella montanella Siberian accentor ——————— No price —
Fish Species
1. Hucho taimen Taimen 5.00—————— 5.005,000.00
60
2. Branhymystax lenok Lenok 3.50—————— 3.5010.00–20.00
61
3. Esox lucius Northern pike 2.00—————— 2.0010.00–20.00
4. Corego nus spp. Siberian white sh 2.00—————— 2.0010.00–20.00
5. Oreoleuciscus potanini Potanin’s osman 2.00—————— 2.0010.00–20.00
6. Cyp rinu s car pio Common wild carp 2.00—————— 2.0010.00–20.00
7. Silurus asotus Cat sh 1.80—————— 1.80 —
8. Thymallus arcticus Arctic grayling 1.80—————— 1.80 —
9. Lethenteron reissneri Eastern brook lamprey 1.80—————— 1.50 —
10. Perca uviatilis River perch 1.80—————— 1.50 —
59 Medicinal purpose, price unknown.
60 Includes sport fi shing permit of $150 for taimen up to 1 meter, and $300 for taimen exceeding 1 meter.
61 Sport fi shing permit va lues.
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142
Table C4: Estimate of total number of hunters weighted by age class
Age class (i)
Number of Males
(Nmi)
Male Respondents in
Age Class
(mai)
Hunter Respondents
in Age Class
(mhi)
Estimated Total
Number of Hunters
(Nh)
<1 42,200 — — —
1-4 189,300———
5-9 268,800———
10-14 316,90 0 18 4 *
15-19 293,100 154 40 38,753
20-24 266,100 315 98 41,853
25-29 231,200 458 160 40,105
30-34 198,9 0 0 410 152 36 , 702
35-39 181,70 0 410 151 33,110
40-44 148,700 444 138 22,782
45-49 101,900 34 4 105 15,506
50-54 69,500 235 58 8,367
55-59 58,200 137 27 5,597
60-64 49,500 88 9 2,363
65-69 36,600 60 3 *
70+ 51,400 46 4 *
Total s 2,504,000 3,119 949 245,138
Table C5: Estimate of total number of hunters weighted by aimag
No.
Aimag
(j)
Aimag Population
(Nj)
Male Respondents
in Aimag
(maj)
Hunter
Respondents in
Aimag
(mhj)
Estimated Total
Number of Hunters
(Nh)
1. Tov 985,000 442 108 74,405
2. Uvs 81,900 270 93 8,713
3. Dornod 74,400 83 45 12,459
4. Sukhbaatar 56,400 94 48 8,895
5. Dornogovi 52,100 252 46 2,937
6. Dundgovi 50,500 19 4 3,284
7. Arkhangai 96,100 11 1 2,698
8. Omnogovi 46,700 199 30 2,174
9. Uvurkhangai 113,200 194 29 5,227
10. Khuvsgul 121,500 273 137 18,832
11. Bayankhongor 83,200 112 52 11,931
12. Bayan Ulgii 100,800 193 98 15,809
13. Khentii 71,100 27 9 7,320
14. Govi Altai 61,400 75 42 10,620
15. Khovd 87,500 194 22 3,065
16. Bulgan 62,800 55 17 5,995
17. Selenge 101,800 168 53 9,919
18. Zavkhan 82,900 397 105 6,772
19. Govi-Sumber 12,200 41 9 827
20. Orkhon 75,100 9 0 0
21. Darkhan Uul 86,500 11 1 2,429
Totals 2,504,000 3,119 949 214,313
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Silent Steppe: e Illegal Wildlife Trade Crisis in Mongolia
143
Table C6: Estimate of total number of hunters weighted by urban or rural residency classification
Residency
Urban/Rural
Population
(Nr)
Male Respondents
(mar)
Hunter
Respondents
(mhr)
Estimated Total
Number of
Hunters
(Nh)
Ulaanbaatar residents 893,400 315 190 72,708
Aimag center residents 570,800 1,982 715 49,901
Countryside residents 1,039, 800 82 2 83 119 ,16 5
Totals 2,504,000 3,119 949 241,774
Table C7: Comparison of Mongolia’s number of hunters and rate in population to selected countries
Country Number of Hunters Rate in Population
Austria 110,000 1/72
Belgium 29,000 1/348
Denmark 177,000 1/29
Finland 300,000 1/17
France 1,650,000 1/35
Germany 326,000 1/247
Greece 293,000 1/35
Hungary 50,000 1/206
Ireland 120,000 1/30
Italy 895,000 1/60
Luxemburg 2,500 1/160
Mongolia 245,000 1/10
Netherlands 32,000 1/454
Norway 170,000 1/25
Poland 99,000 1/389
Portugal 243,000 1/40
Slovenia 23,000 1/84
Spain 1,000,000 1/27
Sweden 320,000 1/39
Switzerland 30,000 1/230
United Kingdom 600,000 1/58
United States 14,000,000 1/19
Sources: Cha rdonnet, Ph., des Cle rs, B., Fischer, J., Gerh old, R., Jori, F,. and Lama rque, F. (2002) . The Value of Wildlife. Rev. sci. tech. O . int. Epiz., 2002, 21 (1), 15-
51; U.S. Census Bureau 1996 po pulation estimates ; Mongolian National St atistics Offi ce 20 03 population esti mates; and this repor t Tabl e C4.
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144
Table C8: Estimates of the total number of hunters and harvests by species in Mongolia
No. Scienti c Name Common Name
Respondent
Hunters
(msj)
Estimated
Number of
Hunters
— —
Adjusted
Mean
Harvest per
Hunter
(Hj)
Max.
Individual
Harvest
Estimated
Total Harvest
Volu me
Nationwide
(Na)
Mammal Species
1. Marmota sibirica Siberian marmot 657 139,000 23.6 1,000 3,300,000
2. Canis lupus Gray wolf 321 75,000 3.4 100 !62
3. Vulpes vulpes Red fox 233 44,000 4.7 100 185,000
4. Pro capra gutturosa Mongolian gazelle 126 34,000 6.5 100 250,000
5. Vulpe s corsac Corsac fox 112 25,000 10.2 100 200,000
6. Capreolus py gargus R oe deer 106 29,0 00 2 .7 50 100,00 0
7. Sus scrofa Wild boar 73 20,000 1.9 10 30,000
8. Sciurus vulgaris Red squirrel 32 6,500 27.2 150 170,000
9. Cervus e laphus Red deer 26 5,00063 1.9 10 6,000
10. Marmota baibacina Altai marmot 18 1,400 46.8 100 66,000
11. Equus h emionus Asiatic wild ass 17 1,500 4.2 15 3,000
12. Capra sibirica Siberian ibex 14 2,000 2.1 20 4,500
13. Ursus arctos Bro wn bear 10 2,50 0 1. 2 10 *
14. Ondatra zibethicus Muskrat 8 2,000 5.3 30 *
15. Lynx lynx Eurasian Lynx 7 3,000 1.2 2 *
16. Gazella subgut turosa Black-tailed gazelle 6 1,400 3.0 30 *
17. Otocolobus manul Pallas’ cat 6 1,000 2.2 4 *
18. Ovis ammon Argali 4 * 1.3 20 *
19. Moschus moschiferus Musk deer 4 * 1.5 7 *
20. Spermophilus undulatus Long tailed ground
squirrel
4*7.530 *
21. Alces al ces Moose 3 * 1 1 *
22. Mustela vison American mink 1 * * * *
23. Martes zibellina Sable 1 * * * *
24. Mesechinus dauuricus Daurian hedgehog 1 * * * *
25. Uncia uncia Snow leopard 1 * * * *
26. Meles meles Eurasian badger 1 * * * *
Bird Species
1. Tetraogallus altaicus Altai snowcock 20 3,250 4.5 24 14,600
2. Lagopus lagopus White ptarmigan 8 * 2.3 10 *
3. Pe rdix dauuri cae Daurian partridge 5 * 4.5 30 *
4. Anser anser Greylag goose 3 * 2.0 30 *
Fish Species**
1. Branhymystax lenok Lenok 4 * 10 20 *
2. Hucho taimen Tai men 3 * 2 .0 20 *
3. Perca uviatilis River perch 3 * 15 100 *
4. Esox lucius Nor thern pike 1 * 5 5 *
* indicates either no or insuffi cient data.
** Estimates of the number of anglers and harvest volumes for individual fi sh species were not possible a s most anglers did not diff erentiate
adequately between species to enable sepa rate analyses. In tota l, approximately 10 percent of all hunters interviewed (n=92 of 949) also claimed
to fi sh for one or more species with a mean harvest rate of 21.5 fi sh per angler. Extrapolated to the entire population of anglers (exclusively in
the northern half of the country) would be approximately 20,000 with a total harvest volume for all fi sh combined of 430,000 fi sh in 2004.
62 e estimated harvest level for wolf hunters exceeds the largest possible estimate for wolf populations in Mongolia. We have therefore chosen not
to publish this fi gure. e infl ated resu lt may be a function of both the number of individuals claiming to hunt wolves as well as an exaggeration
of the number harvested per hunter.
63 e number of red deer hunters was adjusted downward more than other species to refl ect a higher than normal percentage of “hobby” hunters
responding to the survey. Although these individuals hunt red deer, they did not report tak ing any animals last year.
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– 145 –
Appendix D:
Household Consumption Survey
Date: Sur vey Member Names:
Location: Soum/Duureg: Aimag:
Family Information and Demographics:
1. Age Gender How many people are in your immediate family?
2. Where do you currently reside? Aimag Soum Bag
Nearest Aimag center? km, Soum center km?
3. What is your educational background? ❏ University ❏ Special Secondary ❏ Secondary ❏ Elementary
4. Do you work? ❏ Yes ❏ No Profession? Where? Monthly Income?
5. If you are a herder, how much money do you earn on average per year or how many livestock do you own?
6. Do you have any other sources of income? ❏ Yes ❏ No What, how much?
7. Does anyone else in your family work? Profession? Where?
How much do they earn per month?
8. How much of your salary do you save for your personal use?
9. How much meat does your family consume on a daily basis?
10. Do you own a car or a motorcycle? ❏ Yes ❏ No Vehicle Purchase price
Motorcycle Purchase price
11. Do you own a gun? ❏ Yes ❏ No Type of gun
12. Do you use traps? ❏ Yes ❏ No Type of trap Number of traps
Wildlife Harvest Information:
13. Do you or members of your family harvest wildlife now or have you in the past for any purposes?
❏ Hunt (Ages ) ❏ Never Hunted ❏ No Longer Hunt (Ages )
if no longer hunts, when stopped , why?
Attention : If interviewee has never hunted, skip to question #24.
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14. If interviewee or family now hunts or used to hunt, fi ll in the following table.
Species
Name
Where
hunted
How hunted
(gun, tr aps,
dogs, etc.)
Tran sp or -
tation
Has method
changed?
How?
Purpose of
hunt
How many
animals
taken ea ch
trip
How many
taken ea ch
year
How many
years hunted
When do you
hunt for t his
species
Why hunted
at this time
of year
How much
meat from
one animal
How
important is
hunting to
your family
Species Name Part To Whom Where When How Price Which Year How many per year
15. How many days do you spend hunting for each trip? How many hunting trips do you take each year?
16. Have the quality or quantity of the animals you hunt changed? If so, how?
17. Do you hunt for this animal more or less than you did before? Why?
18. What is the legal status of the species you harvest?
19. Do you know if you need a permit?
20. Do you know how many can you take, when, and for what period of time?
21. Have you ever obtained a hunting permit? ❏ Yes how many per year? price? ❏ No Why?
Sales from Wildlife Harvests:
22. Of those species harvested, are any parts sold? If yes, fi ll in the following table. No.
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23. Has any of this changed (parts sold, who buys it, price, quantity)?
24. What do you think about the permit process? Why?
25. Do you think hunting is a problem? Why or why not?
26. What do you think should be done about it?
Wildlife Consumption Information:
27. Do you or members of your family use wildlife products ❏ Use ❏ Never Used ❏ No Longer Use If no longer uses, when stopped , why?
28. If interview or family uses or used animal parts in the past, fi ll in the following table.
29. Has your use changed, the parts or species used, the quality or quantity of the parts changed over time? ❏ Yes ❏ No Why?
30. How would you characterize wildlife resource (abundant, rare, very rare)?
50 years ago? 30 years ago? 10 years ago? 5 years ago? Last year? Now?
Specie s Name Part Purpos e
How impo rtant is
this use
Source
(market , aimag, soum ,
person)
How often used
annually
Quanti ty per
use Price W hich year How m any years used
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Environment and Social Development
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THE WORLD BANK
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Telephone: 202 473 1000
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