Is the Raw Coal Ban a Silver Bullet to Solving Air Pollution in Mongolia?: A Study of the Mongolian Government’s Air Pollution Reduction Policies and Recommendations in the Context of COVID-19

Written by
Soomin Jun
May 5, 2021

By Soomin Jun


Since 2005, Ulaanbaatar, the capital city of Mongolia, has become infamous for being one of the most polluted cities in the world. In response to growing public concerns over air pollution, on May 15, 2019, the Government of Mongolia (GoM) implemented a ban on raw coal – a type of fuel that poor citizens in the city use to survive harsh winters in the world’s coldest capital – and introduced “refined coal briquettes” at a subsidized price close to the price of raw coal. Since the COVID-19 outbreak and the country-wide economic shutdown, lower-income families are struggling to afford food, let alone refined coal briquettes; as a result, they are resorting to burning cheap, dirty fuel, including trash to keep themselves warm. Despite GoM’s efforts to reduce air pollution, in October 2020, Ulaanbaatar’s air quality, again, ranked the worst in the world, ahead of Lahore, Pakistan; Delhi, India; Chengdu, China, and other cities infamous for hazardous levels of air quality. While reducing raw coal consumption is critical to improving air quality, the raw coal ban is not a panacea to solving Mongolia’s air pollution. Poverty is the true culprit behind Ulaanbaatar’s subpar air quality. If Mongolia is to sustainably reduce air pollution, the raw coal ban must be accompanied by social and economic policies that aim to lift people out of poverty. 


Air pollution is challenging Mongolians’ right to live in a safe and healthy environment, as stipulated in Article 16.2 of the Constitution of Mongolia and Principle 1 of the Stockholm Declaration. Since Mongolia’s democratization in the 1990s, rapid urbanization, an increase in migration, climate change, and extreme weather have driven the rural poor to migrate to the capital city of Ulaanbaatar in large numbers. The poor in the city live in ger districts, where people set up semi-permanent camps with traditional Mongolian yurts called ger. These districts are unplanned areas on the outskirts of the city that lack social infrastructure such as heating and water. During the winter, which lasts from early October until April, ger dwellers must burn materials to keep themselves warm. Eighty percent of air pollution in the city is generated from over 200,000 ger households burning coal and other combustion (ADB 2019, 9). Since 2005, Ulaanbaatar has become infamous for being one of the most polluted cities in the world. In the winter, particulate matter (PM) 2.5 in the capital city of Ulaanbaatar reaches levels well above 1,000 micrograms per cubic meter (μg/m3), which is 40 times higher than the recommended standard of the World Health Organization. Direct and indirect impacts of air pollution have recently amplified the public’s concerns. From 2008 to 2018, respiratory complications increased by 6.3 times, reaching 240 per 10,000 Mongolians (GoM 2019, 56). Infant and under-five mortality rate related to air pollution also increased during this period. 



"Ulaanbaatar Air Quality Improvement Program in Mongolia" by Asian Development Bank is licensed under CC BY-NC-ND 2.0.
"Ulaanbaatar Air Quality Improvement Program in Mongolia" by Asian Development Bank is licensed under CC BY-NC-ND 2.0.

In response to growing public concern over air pollution, on May 15, 2019, the Government of Mongolia (GoM) implemented a raw coal ban, a law to completely ban individual and business use of raw coal in six central districts of Ulaanbaatar (Songinokharikhan, Bayanzurkh, Chingeltei, Khan-uul, Sukhbaatar, Bayangol), excluding power plants with special licenses (Ooluun 2018). Instead, GoM provided an alternative product on the market called “refined coal briquettes” at a subsidized price close to the price of raw coal. The ban reduced short-term raw coal consumption resulting in a visible improvement in air quality over the first year of implementation in 2019 (Ganbat et al 2020, 2284). To understand ger residents’ perception of the policy, the author’s team conducted a survey of 41 ger households. Results suggest that while ger residents experienced some adjustment difficulties when the ban was first introduced, they hoped their sacrifice would help improve air quality and contribute to the overall enhancement of citizens’ health.

In the first few months of the policy’s implementation, eight residents died, and one thousand were hospitalized due to carbon monoxide poisoning, resulting from a lack of awareness regarding the proper burning of refined coal briquettes, which differs from burning raw coal (Lundstrom 2020). Moreover, since the COVID-19 outbreak and the country-wide economic shutdown, lower-income families are struggling to afford food, let alone refined coal briquettes; as a result, they are resorting to burning cheap, dirty fuel, including trash, to keep themselves warm, contributing to the decrease in air quality during the winter of 2020. In October 2020, Ulaanbaatar’s air quality, again, ranked the worst in the world, ahead of Lahore, Pakistan; Delhi, India; Chengdu, China, and other cities infamous for hazardous air quality (IQ Air 2020). While reducing raw coal consumption is critical to improving air quality, the raw coal ban is not a silver bullet to solving Mongolia’s air pollution. Poverty is the true culprit behind Ulaanbaatar’s air quality. If Mongolia is to sustainably reduce air pollution, the raw coal ban must be accompanied by social and economic policies that aim to lift people out of poverty. 

Poverty is the true culprit behind Ulaanbaatar’s air quality. If Mongolia is to sustainably reduce air pollution, the raw coal ban must be accompanied by social and economic policies that aim to lift people out of poverty. 

The following section of this paper describes the historical, political, economic, and social context of Mongolia. The section, “Air Pollution as a Development Problem” provides a background on ger districts and poverty-related issues, and elaborates on the direct and indirect costs of air pollution. The following section, “Previous Measures and Bottlenecks,” describes previous laws and policies to address air pollution and discusses key bottlenecks. Thereafter, “Recent Efforts: NPRAEP and Raw Coal Ban'' discusses more recent policy efforts, including the National Program for Reducing Air and Environmental Pollution (NPRAEP) and the raw coal ban. To understand the logistical challenges of the raw coal ban, the “Survey” section analyzes a survey conducted in 2019 regarding ger residents’ perception about the usability of the subsidized refined coal briquette. Lastly, “Implications of COVID-19 on Air Pollution” touches on the implications of COVID-19 on air pollution, while the last two sections provide recommendations for improving the raw coal ban’s implementation. 


Mongolia: Country Brief

Mongolia is the world’s second-largest landlocked country, located in Northeast Asia between China and Russia, with just over three million people. The country transitioned away from a Soviet-dominated communist regime to a democratic state in March 1990, reforming its political system and economic structure in the process. The country’s renouncement of communism resulted in a new constitution, a multi-party system, and a market economy. The replacement of central planning with a laissez-faire economic approach is often described as “organizational chaos,” mainly due to the lack of institutions to manage a young market economy (Marshall 2004, 9). The change in Mongolia’s economic and political structure and an 80 percent reduction in its trade with Russia had enormous repercussions. In the first decade after the transition, poverty increased considerably, providing the foundation for the current inequality in the country. 

Despite high poverty rates and growing inequality, Mongolia’s GDP per capita has tripled since 1991. The country is resource-rich with vast untapped mineral wealth, mainly composed of coal and copper, which account for 25 percent of GDP and 90 percent of total exports (Helble et al. 2020, 73). In 2011, the mineral boom led the country to a 17.3 percent growth, the second-highest in the world. By 2015, Mongolia was an upper-middle-income country. However, only one year later, growth plummeted due to a significant drop in commodity prices coupled with a heavy reliance on mining; consequently, Mongolia was recategorized as a lower-middle-income country. The economy has been on the road to recovery since 2017, with a growth of 5.2 percent between 2016 and 2017; and the country’s GDP per capita reached $4,339 USD in 2019, the highest since after the 2015 economic crisis (World Bank Open Data, n.d.). Nevertheless, the COVID-19 pandemic and a decrease in commodity prices resulted in a one percent decrease in real growth in 2020, down from the 5 percent growth that was forecasted before the pandemic struck (IMF 2020, 12).

Mongolia has made outstanding human development index (HDI) improvements. Mongolia’s HDI value increased from 0.58 to 0.74 between 1990 and 2019 (UNDP 2020, 3). The mean years of schooling increased by 2.6 years from 1990 to 2019, and significant declines in maternal and child mortality compared to 1990 contributed to a 9.6-year increase in life expectancy at birth (World Bank 2020). Mongolia has a relatively young population and a robust education system. Women outpace men in educational attainment, and the ratio of female to male labor force participation rate is near 80 percent. Nevertheless, the economy’s high reliance on mineral extraction has generated little new employment. Youth unemployment reached a high of nearly 20 percent in 2016 and 16 percent in 2019 (World Bank Open Data, n.d.). The lack of economic diversity further limits job opportunities.


Air Pollution as a Development Problem

The Formation of Ger Districts

Despite Mongolia’s positive socio-economic performance since 1990, most of the benefits from rapid economic development have been concentrated in Ulaanbaatar, increasing one-directional migration from rural areas to the capital city. Among other things, the 1992 constitution lifted restrictions on the movement of people within the country (Article 16.18). In addition, climate change is increasing the occurrences of dzud (extremely cold winters and extremely dry summers).  This severe weather kills nomads’ livestock – often the only source of income for the rural population – driving them to move to the city. [1] As a result, rural migrants now make up 60 percent of the city’s population.

Migrants who move to Ulaanbaatar can choose a hashaa (0.07 hectares of land given to all citizens, regardless of age or sex, per Article 3.1.2. of the Law on Land). After paying $2 USD to the respective khoroo (subdistrict administrative office), to claim their plot of land, they can unpack their gers or build a home. These small plots of land have expanded into ger districts located on the outskirts of the city. As of 2018, around 65 percent of the city residents live in the ger districts, representing an overflow of people in a city designed for 500,000 residents that now has a population nearly three times larger (GoM 2019, 54). Ulaanbaatar is unable to handle the growing ger district population. The slum districts are left without proper social infrastructure such as roads, water, sewage, and heating, creating various environmental and public health challenges.

Air Pollution Born from Poverty

Poverty in Ulaanbaatar has increased in recent years; the wages of those in the lowest income bracket have remained stagnant, worsening income inequality in the city (World Bank 2020). Recent migrants have difficulty finding higher-paying jobs, primarily because they tend to have lower levels of human capital. Interestingly, Signh (2017) finds no statistically significant association between migrant status and income in Ulaanbaatar when controlling for age, gender, education status, employment status and residential location in Ulaanbaatar. This result suggests that while individuals face considerable discrimination based on their migrant status, simply being a migrant does not have a causal effect on higher urban poverty rates. Instead, characteristics associated with being a rural-urban migrant, such as educational attainment, employment opportunities, and unemployment, play a bigger role in urban poverty, which is important to understanding the issue of poverty in Mongolia.



"Ger District Panorama" by Anthony Knuppel is licensed under CC BY 2.0.
"Ger District Panorama" by Anthony Knuppel is licensed under CC BY 2.0.

As of 2018, while nearly 99 percent of the urban population has access to electricity, ger district residents still use traditional stoves to burn raw coal because the implementation cost of electric stoves is high, and the electricity fee is considerably higher than consuming raw coal (GoM 2019, 25). Raw coal is easy to find in Mongolia. The price is as low as ₮200-700 Mongolian tögrög (MNT, around $0.07 to $0.25 USD) per 2.5kg sack, largely because state-owned coal mining companies are obligated to sell their output at depressed prices to support subsidized power plants. The total amount of coal consumed during one winter season is, on average, 3.3 metric tons per household, which amounts to ₮450,000 MNT ($158 USD). Mongolians traditionally save money before the winter and purchase coal in bulk for the entire season. On average, each ger household spends 20 percent of its monthly income on fuel; for the poorest quintile expenditures are about 40 percent of income (World Bank and ASTAE 2009, 33). However, those who cannot afford neither raw coal nor wood must start burning whatever they can find, including trash, plastic tires, and dung, contributing to air pollution.

Direct and Indirect Costs of Air Pollution

Ulaanbaatar’s pollutants are mostly fine particles with a diameter of less than 2.5 µm, or particulate matter (PM) 2.5; their small size allows these pollutants to travel deeper into the cardiopulmonary system than other pollutants (USEPA n.d.). During the winter, the Air Quality Index (AQI) reading often surpasses 300, a hazardous air quality that triggers health warnings. In addition, Ulaanbaatar’s topography exacerbates the problem, as the mountains surrounding the city trap emissions.

Over the last decade, national medical records indicate that respiratory complications are one of the primary causes of death in Ulaanbaatar. The incidence of acute broncholithiasis has increased by 6.3 times, reaching 240 patients per 10,000 (GoM 2019, 84). The impacts on children are even more alarming; the most common diseases among children are respiratory diseases, such as pneumonia, caused by exposure to air pollution. Air pollution threatens long- and short-term health outcomes in youth, including a higher risk of death from lung-related complications, fetus disorders, and miscarriages. A UNICEF study (2018) showed a 350 percent increase in fetal deaths in the winter compared to summer months. According to a survey conducted by the Ministry of Health, healthcare spending, which already consists of ten percent of average household expenditures, increases by an additional ₮500,000 MNT ($175 USD) in the winter. Indirect costs, including the loss of future income due to higher absences in schools for children suffering respiratory illness or other diseases from air pollution, cannot be dismissed. Evidence suggests that an additional year of schooling is, on average, associated with a 9.1 percent increase in expected future income in Mongolia (UNICEF 2018, 29).

The negative impacts of air pollution disproportionately fall on the most vulnerable.

The negative impacts of air pollution disproportionately fall on the most vulnerable. Low-income families are more likely to live and work in the most polluted parts of the city, struggle to afford medical care, and rarely wear masks due to lack of awareness; when they do wear masks, they struggle to purchase high-priced filtered masks that are typically procured from overseas. Women, who are traditionally responsible for cooking and heating the home during the winter, often use raw coal, and thus are exposed to dangerously poor indoor air quality. Mongolian women with young or sick children and elderly family members spend more time engaging in unpaid labor in the home, reducing their ability to partake in paid work or pursue professional careers (ADB 2019, 2). Women who are part of the labor force are predominantly employed in the health and education sectors,  where they are also exposed to poor air quality at public facilities that often lack air purifiers and proper ventilation. 

The consequences of air pollution have contributed to increased public shaming and discrimination against the rural migrants who are, out of necessity, generating much of the pollution. Although ger residents are among the most vulnerable victims of air pollution, they must burn to survive. Ger residents are often labeled the culprits behind Ulaaanbaatar’s air quality when, in fact, the culprit of air pollution is poverty. 


Previous Measures and Bottlenecks

Recognizing the severity of the problem, the GoM implemented various measures to create a legal environment for reducing air pollution and implementing programs with support from various multilateral and donor organizations. Since 2010, the Law on Air, incorporated with the Law on Reducing City Air Pollution, was passed, subsidizing electricity for heating and banning coal. In 2011, the Clean Air Fund was established, which the World Bank supported through the Clean Air Project. The Clean Air Project subsidized clean stoves, electricity for heating, air quality monitoring, and research for innovative technologies. In 2016, the Law on Hygiene was passed, prohibiting the burning of all types of waste that have considerably contributed to deteriorating air quality. In addition, initiatives such as distributing free facemasks and providing state-subsidized paid sick leave for parents with sick children - to avoid overcrowding in hospitals - were implemented. Along with these direct interventions, since 2013 the Municipality of Ulaanbaatar City, with support from the Asian Development Bank, has implemented a sustainable infrastructure development program. With a total estimated cost of $320 million USD, the program aims to transform ger districts into affordable and eco-friendly housing (ADB, n.d.).

Regrettably, many of the previous initiatives have been deemed ineffective, with little success in reducing air pollution or decreasing raw coal consumption, despite a public expenditure of ₮147.3 billion MNT ($52 million USD) on direct air pollution reduction measures from 2008 to 2016, and an additional $60 million USD in donor-funded programs (UNDP 2019, 11). While the key to solving the problem is treating air pollution as a cross-cutting issue rather than a stand-alone problem, most of these efforts have been designed and implemented in silos. Mongolia’s air pollution affects many sectors beyond the environment.  Infrastructure, migration, education, health and the economic sectors all contribute to or are negatively impacted by air pollution. As long as these sectors do not address the issue together, the gap between policy intent and implementation will continue to grow, increasing the probability of repeating the mistakes of past programs. All sectors must work in tandem to analyze the root problem and design policies that allow each sector to use its expertise and resources to tackle the issue from a multi-dimensional perspective. 

Historically, most of the budget for air pollution reduction was allocated to the Ministry of the Environment and Tourism (MET) and Ministry of Construction and Urban Development (MCUD), the two ministries that were perceived as most responsible. These two ministries have lacked the political will to cooperate on air quality improvement policies, resulting in the underutilization of approved budgets from 2010 to 2018 (UNDP 2019, 33).

Lack of accountability has also prevented the country from fully benefiting from air pollution reduction efforts. The Clean Air Fund was quietly terminated in 2015 following a corruption incident (UNDP 2019, 33). Using a $40 million USD budget from the Millennium Challenge Corporation (MCC), the GoM distributed more than 100,000 fuel-efficient stoves imported from Turkey sold at ₮25,400 MNT ($9 USD) each, representing a subsidy of 93 percent (Jargalsaikhan 2018). A few months after the policy went into effect, stove prices reverted back to the unsubsidized prices due to politicians smuggling money from the MCC fund (Jargalsaikhan 2018). Thus, the stoves were no longer attractive in the market. 

Policy design and implementation had also fallen short. When the fuel-efficient stove programs were executed, the GoM did not execute awareness campaigns highlighting the importance of using cleaner stoves. During the implementation stage, only ten percent of ger district area households were covered under the previous projects that provided refined coal briquettes from 2008 to 2016 due to limited production capacity and supply chain issues. Subsidies were suspended due to the GoM’s lack of budget, and producers suddenly closed down their plants. In addition, there was not a strategy to attract customers to purchase refined coal briquettes, including its price positioning compared to raw coal and awareness campaigns regarding the importance of using refined coal briquettes, resulting in poor policy outcomes. Furthermore, black market sales were not adequately monitored. As a result, ger district residents had little incentive or buy-in to participate in the program, instead often selling the stoves and fuel they had received free of charge on the black market. 


Recent Efforts: NPRAEP and Raw Coal Ban

In 2017, the GoM led by then-prime minister, Khurelsukh U. responded to public demonstrations over air quality by approving the NPRAEP, which was created based on the recognition that “earlier efforts to reduce environmental pollution did not reach the desired results” (UNICEF 2018, 20). The NPRAEP aims to reduce air pollution through urban planning, decentralization, infrastructure improvement, and encouraging environmentally-friendly lifestyles. The program’s main objectives include implementing a free night-time electricity policy for select ger districts to encourage the use of electric stoves for heating, distributing processed coal to reduce emissions, and expanding heating networks. The total budget for the first seven years of the program is over MNT ₮9.8 trillion MNT ($4 billion USD), accounting for 4.1 percent of nominal GDP. 

The critical shortcomings of the program center around cost-efficiency and practicality. Based on UNDP’s cost-benefit analysis of NPRAEP, the program’s air pollution reduction targets are lower than those of previous programs conducted between 2008 to 2016, yet its budget is 30 times higher. Previous programs aimed to  provide energy efficient stoves and refined coal briquettes, expand the heating network, and invest in power plants to reduce smoke, with an annual budget of just ₮32 billion MNT ($11.4 million USD). In contrast, NPRAEP seeks to reduce air pollution by 80 percent between 2016 and 2025, with an annual average funding of ₮1 trillion MNT ($357 million USD), suggesting that the budget size is significantly higher than previous efforts, calling into question the GoM’s ability to procure and spend the allocated funds. Yet, there are notable enhancements, including independent auditing of NPRAEP and the establishment of the National Committee for Reduction of Air and Environmental Pollution (NCRAEP) responsible for coordinating ministries and agencies to monitor and evaluate performance indicators (Aminaa 2016).

The GoM, as part of NPRAEP objectives, introduced a raw coal ban in six districts in Ulaanbaatar on May 15, 2019. According to GoM, if all residents used refined coal briquettes instead of raw coal, PM 2.5 and PM 10 would fall by 50 to 60 percent, and air pollution in the city would plummet by 40 to 50 percent. This policy incorporates lessons learned from the past. First, it is estimated that annually, Ulaanbaatar residents consume 600,000 metric tons of fuel. Tavan Tolgoi Fuel LLC, a state-owned fuel company established for the production of refined coal briquettes, announced its capacity to produce up to 600,000 tons of refined coal briquettes annually with the construction of a second plant in November 2020 (Baljmaa 2019). Second, any raw coal transport is blocked from entering the city. There have been more than 180 cases of raw coal smuggling since October 2019, but the Ulaanbaatar Inspection Department is working with the Police Department to curb raw coal smuggling attempts at 36 checkpoints. Third, the government-subsidized price of improved coal is competitive compared to the price of raw coal. Per ton, the subsidized price of refined coal briquettes is ₮156,000 MNT ($55 USD), which is comparable to the average market price of raw coal. In December 2020, GoM approved a resolution to reduce the price of refined coal briquettes by 50 percent until April 2021 to support financially strapped citizens during the COVID-19 pandemic. According to the MET, this represents another ₮30 billion MNT ($10.6 million USD) in subsidies. In addition, MET provided 37 packets of refined coal briquettes free of charge to 10,000 low-income households (Ministry of Environment 2020). Lastly, the logistics of fuel distribution have been simplified. Respective khoroo administrative offices distribute “Sain” cards to each qualifying household based on their household registration. Sain cards allow ger dwellers to purchase up to 6 packs of fuel per week (₮22,500 MNT, or $8 USD), with a limit of three tons over 20 weeks for the winter, at small vendors that originally sold raw coal. In early 2020, the GoM announced that more than 610 distribution points will be set up around the city, and contracts will be made with more than 1,000 vendors in 2020. However, as of November 2020, there are less than 500 distribution points, resulting in public dissatisfaction. 



"Ulaanbaatar Air Quality Improvement Program in Mongolia" by Asian Development Bank is licensed under CC BY-NC-ND 2.0.
"Ulaanbaatar Air Quality Improvement Program in Mongolia" by Asian Development Bank is licensed under CC BY-NC-ND 2.0.

The GoM announced that there was a 60 percent reduction in pollution in 2019, the first year of the raw coal ban enforcement, compared to 2018. A recent report comparing the PM levels in Ulaanbaatar with the mean maximum values of the previous five years suggests a 46 percent to 55 percent reduction in PM 2.5 and PM 10 (Ganbat et al. 2020, 2284). However, there were mixed views regarding refined coal briquette’s actual impact on health and air pollution, resulting in lower levels of acceptance of refined coal briquettes during the first year. During the first few months of implementation, eight residents died and 1,000 were hospitalized from carbon monoxide poisoning. Processed briquettes  require different burning methods and more oxygen. The GoM and NCRAEP provided guidelines and instructions through radio, TV, and trained volunteers only after the carbon monoxide poisoning deaths and injuries (Lundstrom 2020). In addition, Tavan Tolgoi Fuel LLC was accused of producing poor-quality briquettes that might have emitted invisible toxic chemicals when ignited. As a result, Mongolians initially perceived refined coal briquettes as unsafe. A press conference was opened to rebut media reports and rumors on social media, and Tavan Tolgoi Fuel LLC informed the public that their products are regulated by quality inspectors and meet established standards (Bayarsaikhan 2019).



The author and their team conducted a survey in the winter of 2019 among 41 ger district residents in Ulaanbaatar to understand the ger dwellers’ experiences of the ban in terms of cost, logistics, heating quality, and perception of the subsidized fuel. This survey attempts to understand the implications of the raw coal ban and how the public perceives this policy after the carbon monoxide deaths and injuries that occurred in the earlier months of implementation. To the authors’ knowledge, no similar survey has been conducted. 

The survey team designed a questionnaire with 12 questions in consultation with the Urban Governance Program team and the Environment team at the Asia Foundation Mongolia. Survey participants were volunteers who lived in the six ger districts where the raw coal ban took effect in early 2019. Surveys were conducted in Mongolian over the phone and in person, depending on the interviewee’s preference, between November and December 2019. The results of the survey were translated into English after all surveys were completed.

Six categories of questions were asked – general information about the respondent and dwelling type, heating method, previous year’s fuel consumption, current year’s fuel consumption, access to subsidized refined coal briquettes, and an open-ended question regarding the raw coal ban. Before the survey was conducted, all participants were informed that the survey responses would be kept anonymous. This was crucial to receiving honest responses to the question on whether respondents used raw coal during the ban, which is associated with a fine of ₮300,000 MNT ($107 USD) to ₮3 million MNT ($1,070 USD). No compensation was offered.

The survey has some limitations. First, the survey was conducted between November and December 2019. Since Mogolian winters typically last until early April, this fails to capture the full impact of the policy in the first winter. Secondly, although respondents were informed that the survey is kept anonymous, they may not provide honest answers due to fear of the heavy fines associated with burning anything other than refined coal briquettes. Thirdly, the results from the survey may not represent the sentiment of the broader population considering the small sample size. Furthermore, this study was not perfectly randomized, which may skew the results. The volunteers were identified based on their residing districts through existing networks and referrals due to the difficulties of conducting random visits during the winter. The survey findings are presented below.


Among 41 survey respondents, 41 percent of respondents said that they live in gers and 59 percent live in houses. In terms of stove use, 37 percent of respondents use improved stoves, either distributed by the GoM or self-purchased, 22 percent uses only traditional stoves, 20 percent uses wall stoves that are usually attached to either improved or traditional stoves (it was not clearly identified in the survey when the question was asked), 20 percent use boilers, and only one household (2 percent) had an additional electric heater, which was used only when the electricity fee is free at night as it is subsidized by the government to encourage electricity usage. The respondents’ annual spending on fuel before the ban varied depending on dwelling types and the size of the house ranging from ₮100,000 MNT ($35 USD) to ₮1,000,000 MNT ($350) (Figure 4). 


Minor issues were observed concerning the process of purchasing refined coal briquettes and the distribution of “Sain” cards. Most vendors were located within a 1-km radius from households who reported spending 10 minutes to 1 hour on travelling to the distribution sites. Most respondents have cars and found it necessary to drive to distribution points, increasing travel time given heavy traffic, because of the cold weather and the weight of the fuel sacks. Conversely, 37 percent of the respondents said they walked to the distribution point due to traffic and road conditions. 15 percent of the respondent said that the vendors often did not ask for “Sain” cards at purchase, suggesting that actual limits per household were not tracked carefully through a centralized monitoring system. Additional problems included weekly travels to distribution points that caused disproportionate challenges for the elderly and the disabled, suggesting more research is needed regarding support systems for those who cannot travel outside every week. Lastly, survey respondents did not have prior experience with burning refined coal briquettes, and therefore were unaware the extent to which it burns more efficiently than raw coal. Since the survey was conducted in the earlier months of the policy implementation, when households had not yet grown familiar with refined coal briquettes, the purchase limit of three metric tons per household was of concern for households with larger houses and more family members that typically consumed more than three metric tons of raw coal, thinking it might fall short.


All respondents reported a change in fuel consumption behavior. Traditionally, Mongolians stock up on all of their fuel needs before the winter starts, but due to the weekly limits on refined briquettes imposed by the ban, people burned less to keep fuel from running out before the end of the week. The policy has also caused a change in spending patterns. Given that households must purchase on a weekly basis with a cap on the amount of purchase, they must save money to purchase refined coal briquettes until the end of winter, whereas before, they could purchase as much as they needed at the beginning of the winter season.

Heating quality and perception of the refined coal briquettes 

Respondents did not report either significant problems with the new briquettes’ heating quality or any significant improvement compared to raw coal. However, the main concern was the potential for adverse health impacts and indoor air quality in the earlier months of implementation, when there was a lack of awareness of how to safely  burn refined coal briquettes. Due to the carbon monoxide poisoning incidents, survey respondents were concerned about the refined coal briquette’s impact on indoor air quality. One respondent said “there is a strange sulfur-like smell” when burning refined coal briquettes, fearing it might generate toxins. In an open-ended question, two respondents said that “refined coal briquettes ignite quicker and burn faster than raw coal” and that refined coal briquette “does not keep the warmth as long” as raw coal. Because many briquettes were broken into pieces, fuel efficiency decreased. These findings contradict the GoM and Tavan Tolgoi’s claim that refined coal briquettes are more heat-efficient and produce less ash. 


Survey results show that while there were some adjustment difficulties when the ban was first introduced, respondents hoped their sacrifice would help improve the air quality and contribute to the overall enhancement of citizens’ health. While 71 percent of respondents say that the refined coal briquette generates more ash than raw coal, 62 percent of them said they prefer refined coal briquette over raw coal, even though they have to clean up the stove more frequently due to ash accumulation. 89 percent of those who said they prefer refined briquettes over raw coal even with more chores responded that they think air quality improved, suggesting that they were willing to do additional work for better air quality. However, there were widespread concerns over the enforcement and monitoring at the vendor and household level, mistrust in the safety of refined coal briquettes, and uncertainty in the availability of refined coal briquettes and the production capacity of Tavan Tolgoi. A lack of monitoring that fails to enforce the same price of refined coal briquettes at different vendors can eventually lead to an increase in the price, given that the availability of refined coal briquettes is limited and public demand for the fuel is inelastic. Monitoring and enforcement of raw coal usage at the household level are also left wanting, which the ADB too identified as one of the critical risks of the policy (ADB 2019, 1). Additionally, the carbon monoxide poisoning deaths and injuries that stemmed from poor awareness of the proper use of refined coal briquettes had a chilling effect on the briquette’s usage. Lastly, the lack of transparency in refined coal briquettes’ availability was among the main concerns. Respondents feared a sudden shortage of fuel or a sharp increase in price in the middle of the winter, fearing another shortage-induced price hike as they had experienced during the 2017 GoM subsidisation of refined coal briquettes. 



Figure 2. Summary Statistics of Survey
Figure 1. Summary Statistics of Survey


Implications of COVID-19 for Air Pollution

The Mongolian People’s Party (MPP), previously unpopular ruling party won the June 2020 parliamentary elections in a landslide, a feat that analysts attribute to its then successful containment of COVID-19 and measures such as the raw coal ban (The Asia Pacific Foundation of Canada, n.d.). The question now is whether this is a financially sustainable approach to combating the air pollution problem, especially during the economic downturn caused by COVID-19 containment policies. In the first half of 2020, GDP contracted by 9.7 percent due to the fall in external and domestic demand, underscoring the economic vulnerability of a commodity-dependent country (Ankhtuya 2020). The Mongolian tugrik depreciated against the U.S. dollar by four percent by the end of December 2020 compared to the beginning of 2020. Questions around the sustainability of the measure arose when Ulaanbaatar ranked as having the worst air quality in the world again in October 2020 (IQ Air 2020).

As discussed previously, Mongolia’s early and strict measures to prevent the COVID-19 outbreak have pressured the state budget, raising concerns regarding its capacity to sustain the NPRAEP. NPRAEP is a highly ambitious program with a budget totaling ₮9.8 trillion MNT ($4 billion USD), and according to UNDP, 80 percent of the funding required for the implementation has not been structured (UNDP 2019, 11). Since Mongolia’s COVID-19 policy focus is on containing the virus, it has implemented looser fiscal policy to accommodate automatic stabilizers and emergency spending, thus having a large adverse impact on the budget in 2020 and 2021 (IMF 2020, 5). Despite these challenges, in its June 2020 country report, the International Monetary Foundation (IMF) forecasts Mongolia will bounce back to an eight percent growth in 2021 and 5.5 percent growth in 2022, largely driven by increased demand for coal and copper from China (Doojav 2020). While GoM needs to generate more fiscal space to continue financing NPRAEP, the decline in tax revenue, negative growth, and low exports bring the sustainability of the program into question. Monitoring and evaluation of the raw coal ban may also suffer, as GoM prioritizes its COVID-19 response over other policies.

Furthermore, the household-level shocks caused by COVID-19 are expected to be long-lasting and disproportionately impact the most vulnerable. Based on the COVID-19 household survey conducted in May 2020 by the Mongolian National Statistics Office and the World Bank, since January, 16 percent of self-employed workers received no income, and 73 percent experienced loss of income (World Bank 2020, 2). While wage employment was less affected, 75 percent of households and 85 percent of the poor experienced economic difficulties from increasing food prices and job loss. Half of the poor were uncertain about their ability to obtain food, and 23 percent expressed concerns about food security in the next week (World Bank  2020, 16).

Unfortunately, after a prolonged period of no local transmission, Mongolia experienced mass local COVID-19 transmission in early November 2020, leading the government to impose even stricter lockdowns and stay-at-home measures until March 2021. In the winter of 2020-2021, the lowest-income ger residents are choosing the cheapest fuel, including dirty coal - a type of raw coal that emits a high amount of pollutants - and other materials they can burn to keep themselves warm. Consequently, air quality in Ulaanbaatar continues to be poor in 2021 despite the raw coal ban. 


Recommendations and Takeaways 

Although both air pollution and COVID-19 have impacted every Mongolian resident, the policy responses to both have engendered inequitable consequences (Jun and Gerelt-Od 2020). Vulnerable populations in ger areas have had to adapt to a new way of life and use new, refined coal briquettes despite being fearful of possible health risks. Those who are self-employed or daily wage earners have lost their jobs at the expense of measures to contain the virus. Though UNICEF reports that the annual average cost of inaction against air pollution in 2021 is about ₮7.2 billion MNT ($2.5 million USD), the question is, can the GoM continue to implement the raw coal ban while not placing the burden squarely on the poor? This section discusses the current shortcomings of the raw coal ban and provides recommendations to improve air pollution reduction measures so that all Mongolizan citizens benefit equally from the policy.

  1. Recognize the vulnerable population’s different needs, especially those with less mobility, through selective and targeted support in providing refined coal briquettes.

    Despite widely available distribution points, ger residents who consume refined coal briquettes must travel weekly outside in the cold weather, and the distances to vendors from each household vary. Those who have less mobility, including the elderly and the disabled and especially those with existing health complications who are more vulnerable to COVID-19, are in need of additional support to ensure equal access to refined coal briquettes. The GoM should work with khoroo administrative offices to cooperate with civil society organizations and establish a delivery system for vulnerable households at their request, reducing the burden of weekly travel and potential exposure to COVID-19 for those with existing health complications. Moreover, lifting weekly purchase limits for select households and allowing bulk purchases while maintaining total allowance per winter season will decrease stress from weekly outdoor travel. This measure would also support single-parent households who often cannot leave children alone at home when schools are closed during lockdown. Such selective and targeted support can ensure equal access to refined coal briquettes and reduce the policy’s disproportionate impacts on the vulnerable population.
  2. Launch an application that locates all distribution points and refined coal briquette stock by cooperating with the Science, Industrial Development and Innovation Agency of Ulaanbaatar (SIDIA), and the Hub Innovation Start-up Center (HUB).

    Although the GoM has announced that there are more than 1,000 distribution points as of 2020, the public finds it difficult to purchase the number of refined coal briquettes they need at a single distribution point, since supply delivery times are not reliable and vendors often run out of briquettes toward the end of the day. As people find it necessary to travel to two or three distribution points to collect their weekly fuel needs, it creates more opportunities for the virus to spread and increases the time needed for retrieving fuel. A smartphone application that connects all vendors and consumers with the availability of refined coal briquettes, location, and price can also support the centralized monitoring system. SIDIA should partner with HUB, whose entrepreneurs have developed successful map applications.
  3. NCRAEP should improve the monitoring of  vendors and households more closely to continue incentivizing the use of refined coal briquettes.

    Lack of close monitoring on over 600 vendors may create room for price hikes without significantly reducing demand, given the public’s distrust of the GoM’s capacity to meet ger dwellers’ demand and intransparency around the availability of refined coal briquettes. To prevent refined coal briquettes from being sold on the black market at the marked-up price, NCRAEP should create a strategy to monitor the enforcement of the price at the vendors and usage at the household level.
  4. Provide transparent information on the budget allocation and expenditures for air pollution reduction measures. There is concern that the price and supply of refined coal briquettes will abruptly change due to tightening fiscal space. Clear and transparent information is required to prevent black market sales from rising and panic buying, especially in the context of COVID-19. By indicating that there is political will to continue providing refined coal briquettes at current prices, GoM can send a clear message to provide short-term assurances to the public. For example, GoM could create a detailed cost breakdown of NPRAEP activities. 
  5. Provide clear information to increase awareness of the consequences of air pollution and instructions on how to properly burn refined coal briquettes.

    Due to carbon monoxide poisoning deaths and hospitalizations from incorrect refined coal briquettes use, there is a general mistrust toward refined coal briquettes, disincentivizing the public from completely substituting away from raw coal. Public awareness, advocacy, and changes in norms and behaviors can further encourage consumption of refined coal briquettes. Providing evidence-based information is critical to countering the flow of misinformation through social media. The GoM should consider partnering with local civil society organizations that have the capacity to produce posters and short informational clips that can be easily disseminated on social media.



The causes of air pollution vary across the world. At times, air pollution is mainly owed to industrialization or unresolved transnational political issues, such as the tensions over air pollution between China and South Korea. At other times, air pollution is a symptom of burning fossil fuels spurred by demand for transportation. In Mongolia, air pollution has the face of poverty. Unequal benefits from democratization, capitalism, and economic development have driven the most vulnerable to migrate to Ulaanbaatar, surrounding the city with ger districts that now contribute to 80 percent of the city’s air pollution. 

The recent approval of NPRAEP shows the GoM’s will to overcome the challenges of previous measures to combat air pollution. This more comprehensive and structured plan with short-, medium-, and long-term objectives, along with the Mongolian citizens’ determination to solve the issue, is promising for Mongolia’s air quality. Even the raw coal ban of 2019, a relatively dramatic policy to replace ger residents’ consumption of raw coal with refined coal briquettes, received public support. The ruling Mongolia People’s Party’s air pollution policies have been met with widespread public approval, contributing to its landslide win in the June 2020 parliamentary election. 

Nevertheless, the implications of COVID-19 on Mongolia’s economy have increased concerns over the long-term sustainability of the raw coal ban. While the GoM’s early and strict measures to contain the virus were successful, the crisis has taken a major toll on the Mongolian economy. Despite GoM’s strict lockdown measures, the number of daily COVID-19 cases have increased to over 1,000 in April, triggering civil unrest. The most recent lockdown has been extended until the second week of May, further exacerbating the country’s precarious economic situation. The most vulnerable are expected to feel the impacts of the crisis more acutely and for longer than those with a higher socio-economic status. Though COVID-19 and air pollution negatively impact every Mongolian resident, the ramifications for the poor are disproportionately negative. If people cannot afford food, how can they afford refined coal briquettes even at a subsidized price? 

The outcome of the raw coal ban policy on air quality in the winter of 2020 to 2021 was disappointing despite GoM’s efforts to provide targeted support to Ulaanbaatar’s ger residents, including through increased subsidies for refined coal briquettes and the provision of free stoves and refined coal briquettes to the poor. Nevertheless, the impact is partially underestimated due to the COVID-19 pandemic, which reduced the GoM’s monitoring capacity, increased the share of poor households, and prolonged period of lockdown increased the time people spent inside their homes, which was also responsible for increased burning at home and air pollution. Stronger monitoring of vendors and households, transparent fiscal policy, measures such as user-friendly apps that tell users where refined coal briquettes are available, and public awareness campaigns can increase the raw coal ban’s long-term impacts on air pollution. Most importantly, these strategies to combat air pollution must also address rising urban poverty, overcrowding, and widening inequality. Unless the GoM tackles the issue of poverty by leaving no one behind, pollution will continue to linger in the Mongolian air.

*This article was edited by Rocio Cara Labrador (Princeton University), Sofia Alessandra Ramirez (Princeton University), and Ziqra Raza (University of California, San Diego).

About the Author

Soomin Jun is a Master in International Policy candidate at the Freeman Spogli Institute at Stanford University, with a focus on Governance and Development. Before attending graduate school, Soomin spent four years working in Mongolia with The Asia Foundation. She can be reached at [email protected].


The author would like to give special thanks to her colleagues, Munkhshur Erdenebat, Delgermaa Lkhagvasuren, Hyeon Jeong Lee, Enkhjargal Lkhagvadorj, and Saranzaya Gerelt-Od, for their key roles in supporting the author in understanding the topic's complexity, drafting the questionnaire, and conducting interviews. This publication would not have been possible without their invaluable support and encouragement. The author would like to note that this publication was written independently and does not reflect the view or opinions of The Asia Foundation.


1.  In 2019, nearly 9,000 families saw their entire herds freeze or starve to death due to dzud.


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