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According to Vietnam Constitution land is the property of the entire people, which is Consultant report submitted to DANIDA (09/2007) Institutional and Regulatory Context of Natural Resource Managemen[.]

Consultant report submitted to DANIDA (09/2007)

Institutional and Regulatory Context of Natural

Resource Management in Vietnam

By MA Dinh Duc TruongFaculty of Environmental and Natural Resource Economics

National Economics University (NEU)

207, Giai Phong RoadHanoi, VietnamEmail: dinhductruong@yahoo.com

September, 2007

II LAND GOVERNANCE IN VIETNAM

1 Overview

2 Land institutional arrangement

3 Regulatory framework and land use right in Vietnam

4 Assessment of land reform process in Vietnam

III WATER GOVERNANCE IN VIETNAM

1 Overview on water resource in Vietnam

2 Institution arrangement for water resource management in Vietnam

3 Overview of the process of formation and development of

Vietnam’s legal system on water resource protection

4 Assessment of Vietnam’s legislation on WRP

IV MINERAL RESOURCE GOVERNANCE IN VIETNAM

1 Overview on mineral resources in Vietnam

2 Institution arrangement for mineral resource management in

Vietnam

3 Government regulatory and policy

4 Assessment of mineral regulatory implementation in Vietnam

V CONCLUSION

REFERENCES

4456912121214

15202020

21232526

DFID Department of International Development

DGMV Departmentof Geology and Minerals of Vietnam

DONRE Department of Natural Resource and Environment

GDLA General Department of Land Administration

GDHM General Department of Hydrology and Meteorology

LEP Law on Environment Protection

LWR Law on Water Resources

NWRC The National Water Resources Council

LUC Land use certificate

MARD Ministry of Agriculture and Rural Development

MOC Ministry of Construction

MONRE Ministry of Natural Resources and Environment

MOI Ministry of Industry

MOH Ministry of Health

MOF Ministry of Finance

MOT Ministry of Transportation

MPI Ministry of Planning and Investment

UNDP United Nation Development Programme

WHO World Health Organization

WRP Water Resource Protection

I INTRODUCTION

In 1986, the Government of Vietnam embarked on a renovation process named "Doi moi"

to guide the country from a centrally-planned toward a market economy Vietnam hassince then opened up its economy and has entered the process of trade liberalization.While has been successful in generating strong economic growth, it is necessary to takemeasures to protect and use the country’s natural resources in a sustainable and efficientway After decades of wars and being under a central economy which considers allnatural resources as common property, the natural resources in Vietnam had depleted anddegraded quickly (Chung 2002) However, with the ongoing reform process, togetherwith globalization, Vietnam has a unique opportunity to learn from the experiences ofother countries for the development and implementation of creative regulatoryframeworks and policies for natural resource management (Son 2005)

For some recent years, Vietnam has implemented a number of policies and reforms tocomply with its commitment on sustainable development that emphasizes the importance

of sustainable use of natural resource Several Government strategic documents aboutsustainable development have been promulgated such as: The National Strategy onEconomic Growth, Hunger Alleviation and Poverty Reduction (2002), NationalSustainable Development Strategy (Agenda 21) (2004), National Strategy onEnvironmental Protection to 2020 (2003), Law on Environmental Protection and the like.Beside changes in regulatory system, there have also been significant reforms ofinstitutional structures to deal with natural resource issues Accordingly, the roles andresponsibilities for implementing management policies in Vietnam have been more

decentralized than those of two decades ago (Nhu et.al 2006)

This paper aims at examining the institutional and regulatory aspects of natural resourcemanagement in Vietnam Focusing on land, water and mineral, it addresses the questionthat how these resources are managed and how the policy-making process regardingmanagement has been made For each resource, the paper will first highlight theinstitutional context of its management, then to provide an overview on legal frameworkand policies which are presently in active for managing these resources Finally,achievements and shortcomings when implementing these framework and policy are alsoidentified and analyzed

II LAND GOVERNANCE IN VIETNAM

1 Overview

According to Vietnam Constitution, land is the property of the entire people, which isallocated or leased by the State to organizations, households or individuals for long-termuse Depending on their status, land users are fully or partly granted the rights of landexchange, transfer, inheritance, mortgage, lease and investment into joint-venture (Vo2002) The land policies in Vietnam have been more centrally legalized in more than twodecades from early 1980s Beginning with the 1980 Constitution, followed by the 1988Land Law, then the 1993 Land Law and most recently the 2003 Land Law (Nhu 2006).The last one has perfected further the land management mechanism in Vietnam on the

basis of supplementation and the amendment of a number of articles of the 1993 LandLaw According to the new Land Law in 2003, land has initially been considered as acommodity that will be openly traded in market However, it is a special commodity andspecial stipulations will be worked out for this market Nevertheless, it is an especiallyimportant step forward to help Vietnam develop a rational market mechanism, spurring ahealthy socio-economic development, especially in rural areas, and particularly in themountainous regions that abound in land potential, but the inhabitants are the poorest(Ausaid 2001).

2 Land institutional arrangements

In 1986, the State of Vietnam decided to innovate its economic system under the marketeconomy model with state management Since then, land administration has beenregarded significant to secure political stability, social justice and economic development

In general, the land administration system of Vietnam is a nationwide four-level systemincluding the MONRE at the central level, DONRE at provincial level belonging toprovincial People Committee (provincial government), Division of Natural Resourcesand Environment at district level belonging to District People Committee and one/twoLand Officers in each commune (MONRE 2007)

In early 1994 Vietnam Government decided to establish the General Department of LandAdministration (GDLA) by merging and reorganizing two state bodies; GeneralDepartment of Land Management and National Department of Surveying and Mapping(Vo 2002) In 2002, the Ministry of Natural Resources and Environment (MONRE) wasestablished by merging the General Department of Land Administration, GeneralDepartment of Meteorology and Hydrology, National Environmental Agency (belonging

to MOSTE), General Department of Geology and Minerals (belonging to MOI) andDepartment of Water Resource Management (belonging to MARD)

Within MONRE, Department of Land and Department of Land Registration and Statisticshave main functions to implement state management regarding land in Vietnam.Specifically, Department of Land is responsible for state management of land policy andregulatory while Department of Land Registration and Statistics is in charge of managingland survey, assessment, valuation, classification; land use planning, land allocation,lease and claimation; land inspection and mapping

At other levels, land administration bodies are responsible for the following tasksregarding land management:

Implementating of cadastral system including land register, cadastral, mapping,cadastral documentation, land tenure certificate issuance, and land recordsystem update;

Carrying out land investigation and inventory for land classification, landassessment, and land valuation;

Undertaking land statistics and current land use mapping;

Setting long term and annual land use planning;

Implementing land inspection;

Solving land disputes;

Making reference geodetic system definition, coordinates and leveling controlnetwork construction;

Managing aerial-satellite imagery

Doing hydrographic survey;

Setting topographic map and base map systems for inland and seabed;

Managing geo-database and Land-database

Figure 1: Institutional Structure of land management in Vietnam

Department of NaturalResource andEnvironment

Division of NaturalResource andEnvironment

Office of NaturalResource andEnvironmentManagement line

Technical guidline

Data reported line

Source: Trung, T.N (2005)

3 Regulatory framework and land use right in Vietnam

Legal framework of land management

Soon after the Democratic Republic of Vietnam (former name of the Socialist Republic ofVietnam) was founded, Vietnam suffered from wars for 30 years between 1945 and 1975.Land administration was ignored in the following 1975 - 1986 period because of thecentrally planned economy model (Que 1999)l In the first half of 80’s of the last century,Vietnam’s economy had very low productivity in agriculture, which caused lack of foodfor social needs The economic solution to this problem was based on the allocation ofagriculture land to individuals and households

In 1986, the State of Vietnam decided to innovate its economic system under the marketeconomy model managed by the State Since then, land administration has been regardedsignificant to secure political stability, social justice and economic development The firstLand Law of Vietnam was approved by the National Assembly in 1988 After havingbeen implemented for 5 years, some articles proved to be not encouraging enough fordevelopment of the market economy (Chung 2001) A revised land law was thereforepromulgated and approved by the National Assembly in 1993, called the 1993 Land Law.Then the 1993 Land Law was replaced by the 1998 Land Law and most recently the 2003Land Law The last one has perfected further the land management mechanism inVietnam on the basis of supplementation and the amendment of a number of articles ofthe 1993 Land Law According to this new Land Law in 2003, land use right has initiallybeen considered as a commodity that will be openly traded in market (Ausaid 2001) Implementing the Decree on the Land Law, Decree 181/2004/ND-CP ("Decree 181") wasissued by the Government on 29 October 2004 Decree 181 contains 186 articles andcovers a wide range of land issues It repeals nine Decrees and partly repeals certain otherlegal instruments Decree 181, which had been expected to be issued prior to 1 July 2004(which was the effective date of the Land Law), deals with the planning of land use,allocation of land, lease of land, change of purposes of using land, land resumption andland requisition, land use right certificates, the real estate market, rights and obligations

of land users, procedures for exchanges, transfers, leases, mortgages and inheritances ofland and regulations on the settlement of claims and disputes in respect to land TheDecree came into effect on 16 November 2004 (Nhu 2006) Some impotantlly admendedpoints in this Decree is summarized as follow:

Real Estate Market

The Decree recognizes the ‘real estate market’ and describes land as a ‘specialcommodity’ Permitted activities in the real estate market include conversion,assignment, lease, sub-lease, mortgage, inheritance of or gifting land use rights, provision

of guarantees secured by land use rights, contribution of capital by way of land use rightsand investment in construction and development of residential property However, not allland users are entitled to carry out all these activities The activities which are allowed

depend on the land users legal status, whether the land is allocated or leased by the Stateand the land users residual financial obligations toward the State in respect to that land (ifany).

Land Use Right Certificates

A land use right certificate (LURC) is the form of registration of "ownership" of landconferring various rights on the owner However, most conferred rights fall short of thefreehold title to land recognized in many other jurisdictions LURCs are to be issued in astandard form for all types of land Decree 181 also deals with the issuance of LURCs inspecific circumstances including to land users using land for construction of offices ofadministrative agencies and to land users using land for construction of housingdevelopments and apartment buildings

Overseas Vietnamese and Foreigners

Under current land laws, with the exception of overseas Vietnamese who can be allocatedwith land from the State, foreign organizations and individuals (including foreigninvested enterprises) are permitted to lease land from the State only, except where theland is located in an industrial zone or in circumstances where the Vietnamese partner to

a joint venture contributes land as capital to the joint venture company Decree 181 hasconsolidated a number of legal instruments dealing with the use of land by foreigninvested enterprises as well as providing new provisions

Procedures for Allocation or Lease of Land

After obtaining the agreement of the authority on the location of the project, the foreigninvestor must submit an application file for allocation or lease of land to the Department

of Natural Resources and Environment ("DNRE") The DNRE then will examine theapplication and submit documents to the provincial people’s committee for issuance of aland use right certificate The timeframe for issuance of a land use right certificate isstated to be 20 working days from the date of receipt of appropriate documents from theinvestors

Rights and Obligations of Joint Ventures in Using Land

Joint ventures between foreign organizations, foreign individuals and overseasVietnamese with a domestic company in respect of which the Vietnamese partnercontributes land use rights to the joint venture shall not be required to convert the landtitle to land lease in some circumstances In such cases, joint venture companies will not

be required to convert the contributed land to a "leasehold title" and will have rights andobligations similar to those of the Vietnamese company which contributed the value ofland use rights to the joint venture These regulations also apply to joint ventures towhich an overseas Vietnamese who has been allocated land by the State contributes theland use rights value and has paid the land use fees to the State In particular, such jointventures are entitled to assign the land use rights and infrastructure attached to the land,

to lease the land use rights and infrastructure attached to the land or to contribute the landuse rights to form a joint venture with Vietnamese organizations, overseas Vietnamese,foreign organizations or individuals.

Besides these two main legal documents, other important regulations promulgated forland management in Vietnam include:

 Prime Minister Decree No 64/1993 on the enactment of regulations on theallocation of land to households and individuals for stable and long term use for the purpose of agricultural production

 Prime Minister Decree No 02/1994 on the enactment of regulations on theallocation of forestry land to organizations, households and individuals for stableand long term use for forestry purposes

 Prime Minister Decree No 61/1994 on buying, selling and trading in residentialhouses

 Government Resolution No 01/CP 1995 on the allocation and contracting of land

to state enterprises for agriculture, forestry and aquaculture production;

 Government Decree No 163/1999/ND-CP concerning the allocation and lease offorest land to organizations, households and individuals for long-term forestrypurposes;

 Prime Minister Decision No 178/2001/QD-TTg on the rights and obligations ofhouseholds/individuals who have been allocated forest land for benefit sharing

 MONRE Circular 24/2004/QD-BTNMT on the certificate of land use rights

 Prime Minister Decree No 188/2004/ND-CP on the methods to valuing landprices and price frame for land categories

 MOF Circular No 114/2004/TT- BTC provide guilines for the implementation ofthe Prime Minister Decree No 188/2004/ND-CP on the methods to valuing landprices and price frame for land categories

 Prime Minister Decree No 198/2004/ND-CP on the collection of land use tax

 MOF Circular No 117/2004/TT- BTC provide guilines for the implementation ofthe Prime Minister Decree No 198/2004/ND-CP on the collection of land use tax

 Prime Minister Decree No 197/2004/ND-CP on the compensation andresettlement support in case of State land reclaimation

 MOF Circular No 116/2004/TT- BTC provide guilines for the implementation ofthe Prime Minister Decree No 197/2004/ND-CP on the compensation andresettlement support in case of State land reclaimation

 Prime Minister Decree No 17/2006/ND-CP on changes and admendments ofsome articles in Decrees guiding the implemention of Land Law

 MONRE Decision No 08/2006/QD-BTNMT about regulations on land usecertificate

 Prime Minister Decree No 84/2007/ND-CP on admendments of the issue of landuse certificate, land reclaimation, the implementation of land use right, proceduresfor land compenstation, resettlement and denunciation

 MONRE Circular No 06/2007/BTNMT on the guidelines of Prime MinisterDecree No 84/2007/ND-CP on admendments of the issue of land use certificate,land reclaimation, the implementation of land use right, procedures for landcompenstation, resettlement and denunciation

 Prime Minister Decree No 123/2007/ND-CP on complementing some articles ofPrime Minister Decree No 188/2004/ND-CP on the methods to valuing landprices and price frame for land categories

Land use right development

The 1980 Constitution vested all rights in land to the state This principle appeared in the

1988 Land Law, but was changed to people’s ownership and state management in the

1992 Constitution and 1993 Land Law Since the central and local governments exercisethe right of land ownership on behalf of the people, they also have rights to possess, useand dispose the land The 1993 Land Law (LL) set out six main principles governingland: (1) land belongs to the entire people; (2) is uniformly administered by the state; (3)which promotes effective and economical usage Further, (4) the state protectsagricultural land; (5) encourages investment in land; and (6) stipulates the value of land(LL 1993)

While retaining ultimate control over legislation and policy, the central state has devolvedland management to People’s Committees City level People’s Committees, for example,possess broad discretionary powers to allot land use rights in urban areas Localauthorities are also responsible for promulgating zoning and land use regulations,registration and settling certain types of land use disputes As a concession to theemerging mixed market economy, the Land Law recognized various private interests inland, which can be transferred, leased and encumbered, without disturbing the underlyingprinciple of state ownership of land These rights were extended and clarified by the 1998

amendment to the Land Law Land use rights (quyen su dung dat) convey extensive

occupation, disposal (vat quyen) and encumbrance rights Private ownership of

immovable other than land, such as building and trees is permitted under the Civil Code(articles 172.205) Maintaining the socialist distinction between income and non-income

producing land, authorities allocate land for urban residential use on a stable long-termbasis Land used for income production, is in contrast, allotted or leased for short periodsdetermined by business production plans (Ausaid 2001).

There are three methods of gaining access to land namely, allotments, leasing andtransfers

Allotment

City People’s Committees allot land in urban areas (LL, article 23) This discretionarypower is circumscribed by urban planning designs contained in city master plans,business feasibility plans approved by state authorities and socioeconomic policies Sincemost urban land is currently being used, allotments only take place where large parcels ofstate land are subdivided, compulsorily acquired land is reallotted and unofficial land isconverted to land use rights (Ausaid 2001)

Allotted and leased land use rights

Allotted land (giao dat) is the highest form of land use rights It is only available for

non-commercial organizations (unusually political organizations), family households andindividuals Though falling short of full ownership, land allotted for residential useconveys rights in perpetuity to transfer, bequeath, lease, and mortgage After paying aninitial land allocation fee, no further state charges apply In practice, if not legal theory,allotted land differs little from Western freehold estates Land is also allotted tocommercial organizations for infrastructure projects; however, the full range of rights isonly granted where fees are prepaid (LL 1998, article 78c)

Commercial organizations (including foreign investors) and households using land forcommercial purposes, other than for infrastructure development, are granted leases (LL

1998, article 78d) The rights conveyed by leases depend on the quantum of rentrepayment For example, commercial organizations paying rent annually are grantedrights to mortgage and transfer the unexpired term of leaseholds Where the entire rental

is prepaid, additional rights to sublease or contribute the leasehold as capital for a foreignjoint venture are granted The duration of leases is determined according to businessplans that rarely extend beyond 20 years

Land transfers

Private access to urban residential land in both official and unofficial land markets isprimarily gained through land transfers Since land is owned by the people legislation

refers to land use rights transfers (chuyen nhuong), rather than buying and selling.

Although, the Civil Code (article 694) requires the transfer of land use rights to be based

on price formula set by the Ministry of Finance There are two methods of acquiring landuse right certificates: one, land use right certificates are issued when People Committeesallot and lease urban land; two, in some circumstances those occupying untitledresidential land can apply for the allotment of land use rights (Ausaid 2001)

4 Assessment of land reform process in Vietnam

4.1 Achievements

Land policies that distribute land to individuals and assign LUR (i.e some degree ofprivate property rights) allow the development of land markets that can bring about anefficient allocation of resources, given certain conditions Because well-defined andenforceable private property rights are one of these necessary conditions, efficientallocation of resources depends on the nature of prevailing property rights Under theVietnamese Constitution (2003), land is the property of the people as a whole and theState administers it on their behalf The new 2003 Land Law states that the government is

the ‘representative of the people’s ownership’ Since land is ‘owned’ by the people as a

whole, it is not possible for individuals (or corporations) to own land However,individuals, households and organizations can hold and transfer rights to use land Thisalso increases the motivation to use land in an efficient way by those with land use right(Hung 2006)

In Vietnam, following the land allocation according to Decree 64/1993 and Decree02/1993, agricultural land use titles were issued to farm households By 1998 land usecertificates (LUCs) had been issued to 71% of farm households, and by the end of 2000this number was more than 90% (Do and Iyer 2003) For forestry land in upland andmountainous areas, where many traditional and cultural issues complicated landallocation, the certification process was slower (Ministry of Agriculture and RuralDevelopment 2002, Vy 2002) The process of issuing land use certificates is stillcontinuing In 1998 two additional LUR were assigned to farmers, the right to re-leaseland and the right to use the value of LUR as joint venture capital for investment In

2003 further revisions to the 1993 Land Law resulted in farmers being assigned the right

to gift their land to relatives, friends or others The revisions also set out thecircumstances for allowing land related changes and procedures for registration ofchanges

Land policy changes in Vietnam since 1981 are recognized as contributing significantly

to production increases and development in the agricultural and rural sectors Landallocation and its subsequent step – land registration partly supports Vietnam to haveproperty reducing from 58% of population living under the poverty line in the year 1993

to 29% year 2002; GDP from VND132,000 billion in year the 1990 to VND 362,000billion year 2004 and GDP grew up by about 7% per year, (GSO, 2000 - 2005) Totalagricultural output increased by 6.7% annually during the period 1994–99 and about4.6% during the period 2000–03 (Hung 2006) Food security at the national level is nolonger an issue and poverty has continuously decreased Forest covered area also rapidlyincreased from 27.2 percent in 1993 to 37 percent in 2004 (Vietnam Government 2005)

4.2 Shortcomings

Firstly, problems with the grant of land use certificates (titling)

Wars, regime change and weak local administration have induced land-titling chaos inViet Nam urban centers By 1999 only eleven percent of urban households in Hanoi hadreceived land use certificates Low conversion (from untitled to titled land use rights) was

attributed by authorities to high land allotment fees (up to 20 per cent of the lands value).However, substantial fee reductions introduced by the 1998 Land Law amendments haveonly partially resolved this problem Institutional attitudes to land-titling the central statewants land-titling to extend the principle of land management over all urban areas It iscurrently difficult to control illegal construction and land transfers, becauseapproximately 90 per cent of land users are unregistered Just as importantly, the statesees land tax as a dependable (difficult to avoid) revenue source (Ausaid 2001)

Secondly, problem of condominium ownership

Under the existing system there is no capacity to issue land use rights for airspace aprerequisite for titling condominiums and subdivided villas This is especially importantfor occupants of villas taken over, and redistributed to the needy by the state afterindependence Decree No 61 CP 1994 outlines the Government policy of transferringownership of state-owned apartments to civil servants Moreover, by the year 2020 theGovernment plans to construct 20 million square meters of residential housing In eachcase the development of strata-title law and model common property protocols isrequired

Thirdly, issues of unequal access to land use rights

The 1998 amendments to the Law on Land 1993 entrenched the unequal distribution of

land use rights (quyen su dung dat) The classification of land use according to the legal

status of occupants produces some market anomalies For example, it is comparativelyeasy for entities registered under Decree 2 on Household Business 2000 (that ishousehold businesses with a low market capitalization) to mortgage hotels constructed onresidential (allotted) land use rights In contrast, hotels owned by companies, butconstructed on short-term leasehold land are extremely difficult to mortgage This meansthat where the hotel industry is unprofitable, Decree 2 entities can unofficially usebuildings for any business permitted under applicable zoning provisions Companies,however, must strictly use leasehold land for licenced purposes, otherwise their land userights automatically revert to the state (Nhu 2006)

Fourthly, land transfers

The state manages land by controlling the transfer of land use rights This power has beendevolved to peoples committees at the provincial and district levels Provided transfertaxes are paid, transfer approval for urban residential land transfers is routinely given.Since commercial land use is treated as a special means of production, transfer approval

is based on state planning objectives Official discretion is evidently frequently exercised

to frustrate the distribution of land use rights in bankruptcy Unauthorized land transfers,including subleasing, are punished by administrative sanctions

Fifthly, land reclaimation and compensation

Although Decree 188/2004/ND-CP and Circular 114/2004/BTC stipulate a clear priceframework for land categories which is the basis for land reclaimation, theimplementation of these legal documents is of much challenge First, the market prices of

land for all types of land are much higher than being regulated by the state As a results,people with LURs do not agree with the compesation prices in most of the cases Moreparticularly, the state normally buy LURs with cheap prices and sell them for invesmentprojects with higher ones This situation, in some cases, results in severe conflictsbetween local people and state reclaimation agencies and hence lengthening the duration

of projects Secondly, the state’s delay in paying compensation and providingresettlements is also a challenge for land reclaimation

II WATER GOVERNANCE IN VIETNAM

1 Overview on water resource in Vietnam

Vietnam is a naturally rich country of surface and ground water resources Density ofriver and spring is rather high with around 2360 rivers, which are longer than 10 km,allocated all over of the country from the North to the South All rivers in Vietnam supplyapproximately a total surface water volume of 255 billion cubic meters per year (Quang1990) In addition, total potential exploitation of ground water is around 60 billions cubicmeters per year The country also has many natural lakes, of which Ba Be has a capacity

of 90 million cubic meters However, over exploitation of water resources causesincreasingly degradation of water resources in particular and degradation of environmentand other related resources in general (Trang 2005)

First concerns of water resources management and sustainable use had been raised inVietnam in 80s Then, it has been a burning issue in Vietnam since the end of last decade

At present, it is still a fairly new, urgent and topical issue, which needs to draw moreattention to and investment in

2 Institution arrangement for water resource management in Vietnam

Before establishment of MONRE (Ministry of Natural Resources and Environment) in

2002, MARD (Ministry of Agricultural and Rural Development) is a Government body,which plays key role in the state function of water resources management in collaborationwith other related Government Agencies After Government Decree No 91/2002/ND-CPspecifies the functions, responsibilities, authority and organizational structure of thenewly established MONRE, the function of state management of water resources hasbeen handed over from MARD to MONRE (Trang 2005) It is expected that theestablishment of MONRE will reduce the fragmentation of state management for waterresources in particular and natural resources in general Also, it will create a clearerseparation between state management of water resources and service of water resources The following table shows the function of water resources management before and afterestablishment of MONRE

Figure 2: Function of water resources management in Vietnam

Activities Responsibility before

establishment of MONRE Responsibility after establishment of

Rural water supply

Urban water supply

and drainage

Hydropower, reservoir

in Mekong river basin

VNMC under MARD VNMC under MARD at

present , on going thinking