Procedural Issues and Internal Consistency: There are a number of procedural considerations to be taken into account regarding provisions on naturalization of stateless persons. Thus, the 2007 Citizenship Regulations require an identity document to be submitted by the applicant with an application package, which, for stateless persons, is a residence permit of stateless persons (para. 10 and 13). As has already been mentioned above the existing process of obtaining residence permits of stateless person are quite limited. Another troublesome point is documenting permanent residents, which, according to the 2007 Citizenship Regulations is proven either through a passport with a residential stamp or a residence permit of stateless person with the residential stamp in it (para 10). However, there are a number of undocumented persons who would not be able to meet the criteria, such as individuals with expired foreign passports or with no identity documents at all. Problems may also arise for the children of undocumented individuals as the latter are required to submit marriage and birth certificates in order to include their minor children in their naturalization applications (para 10). Many undocumented individuals cannot obtain marriage certificates for themselves or birth certificates for their children because the relevant laws and procedures require them to submit valid identity documents. The 2007 Citizenship Regulations provide that a written explanation for the failure to submit any of the documents listed in the law should be provided by the applicant if the reasons are beyond the applicant’s control (para. 15). UNHCR’s implementing partners, who assist stateless persons in compiling and submitting applications confirmed that the deficiency of proper identity documents frequently makes it difficult for applicants to proceed with an application, since in most cases the internal affairs bodies will not review an application without proper identity documents.17 The 2007 Citizenship Regulations list a number of documents, which may serve as evidence of a legitimate source of income (para. 10 and 13). Moreover, it permits for income to be derived from activities or assets in the Kyrgyz Republic but more importantly from outside of the country as well, which increases the possibility of stateless persons to meet the criterion for naturalization. In the 2007 Citizenship Law, provisions on naturalization of children according to the simplified procedure under Article 14.3 maybe in conflict with Article 12 and 17, which deal with the acquisition of nationality at birth or by adoption by a Kyrgyz national. All of the aforementioned articles may deal with the same category of people, but in some circumstances they are not mutually exclusive according to the letter of the law. So for example, a child with a Kyrgyz parent is [emphasis added] eligible for naturalization in a simplified manner (Article 14.3); yet according to Article 12.3, a child whose parent was [emphasis added] a Kyrgyz national at the time of the child’s birth and the other stateless or unknown, is a national of the Kyrgyz Republic automatically at birth. The reasons behind the stipulations in these two provisions maybe interpreted as: the acquisition of nationality by birth grants nationality to a child whose parents were nationals [emphasis added] at the time of the child’s birth, but who may no longer be at the time of application, the acquisition by naturalization, may enable a child, whose one parent was not a national [emphasis added] of the country at the time of the child’s birth but who has since become a national [emphasis added], to obtain the nationality of the parent’s country. However, the mutual exclusiveness of application of these provisions is not directly clear from the 2007 Citizenship Law and may leave the application of one of the other provisions to the discretion of the authorities. As an example, stateless persons who hold former USSR passports, and who have permanently resided in the country for last five years, are technically nationals of 17 The Southern survey refers to the problem of invalid passport make it unable for undocumented stateless persons to enjoy the naturalization procedures. Supra n. 2, p. 13 Small Changes ‫ ـ‬Big Gains: An Action Plan to Prevent and Reduce Statelessness in the Kyrgyz Republic 68