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In light of the problematic nature of the void-for-vagueness doctrine, this note argues that a defendant should never have standing to challenge a statute as unconstitutionally vague unless sufficient facts have been established to allow the court to review the statute in its actual application to the defendant. If, however, Washington courts insist upon reviewing a challenged statute on its face, they should be alert to the possibility that judicial review under the void-for-vagueness doctrine will become unduly expansive. This note suggests that courts can minimize potential abuse by carefully framing the constitutional issue and by appropriately construing the challenged statute.

In light of the problematic nature of the void-for-vagueness doctrine, this note argues that a defendant should never have standing to challenge a statute as unconstitutionally vague unless sufficient facts have been established to allow the court to review the statute in its actual application to the defendant. If, however, Washington courts insist upon reviewing a challenged statute on its face, they should be alert to the possibility that judicial review under the void-for-vagueness doctrine will become unduly expansive. This note suggests that courts can minimize potential abuse by carefully framing the constitutional issue and by appropriately construing the challenged statute.

Includes bibliographical references. ; Presented at the Building resilience of Mongolian rangelands: a trans-disciplinary research conference held on June 9-10, 2015 in Ulaanbaatar, Mongolia. ; In Mongolia, partners from national and aimag governments, academia and NGOs have developed regional conservation plans that balance the government commitment to protection of natural habitats with planned development of mineral resources and related infrastructure. A key input is a mapped classification of major habitat types, or ecosystems, to represent the range of natural habitats and function as a surrogate for biodiversity. We developed a GIS model to map ecosystems across the Mongolian Gobi Desert region by comparing the distribution of plant communities and major vegetation types, taken from field surveys and national maps, with patterns of above-ground biomass, elevation, climate and topography derived from remote sensing. The resulting mapped classification is organized as a hierarchy of 1) biogeographic regions, 2) terrestrial ecosystem types based on vegetation, elevation and geomorphology, and 3) landforms. This provides a first-iteration map to support landscape-level conservation planning and a model framework that can support field surveys and future model revisions, with other applications to land use planning, research, surveys and monitoring. To facilitate that, the GIS results are publicly available either for download or to view and query in a web-based GIS available at: http://s3.amazonaws.com/DevByDesign-Web/MappingAppsVer2/Gobi/index.html