When you look for a site for a resort hotel, the first map you open is not the zoning map. It is the Ministry of the Environment’s park-area map. Inside a National Park or Quasi-National Park, a layer sits above the building rules that govern a structure’s shape — a layer that decides whether you may operate that business in that place at all. That layer is the park plan and the authorization to execute a park project under the Natural Parks Act. Lock up a site without checking it and the deal can fail before design work even begins.

This article cross-references the land-classification breakdown of Japan’s 35 National Parks — roughly 2,447,855 hectares (Ministry of the Environment, as of April 10, 2026) — against supply data for 33 resort municipalities that host National Parks, covering 140,920 rooms in total, and quantifies what the regulation actually does to supply and to room rates. The conclusion up front: regulation reliably shuts off supply, but it does not guarantee a high rate. Developers, funds and regional banks each need to check things in a different order.

The Natural Parks Act has two layers — the project and the act are judged separately

The legal layers that bite when you build or acquire a hotel in a National Park fall broadly into two. They are easily confused, but the reviewing authority and the criteria are different things.

The first is the “project layer.” Article 2 of the Natural Parks Act defines a park plan as “a plan concerning the regulations or projects for the protection or use of a National Park or Quasi-National Park,” and a park project as “a project executed on the basis of a park plan.” An accommodation business is one type of park project, and under Article 9 it is decided by the Minister of the Environment after hearing the opinion of the Central Environment Council. Article 10(1) then provides that “National Park projects shall be executed by the State,” while Article 10(3) provides that “persons other than the State and public entities may, as provided by Ministry of the Environment ordinance, execute part of a National Park project with the authorization of the Minister of the Environment.”

In other words, for a private operator to run an accommodation business inside a National Park, two things must hold: (1) an accommodation business must be designated for that location in the park plan, and (2) the operator must obtain the Minister’s authorization to execute it. Where the park plan does not designate an accommodation business, acquiring the site does not let you run one. This is what needs checking before site acquisition, not after.

The second is the “act-regulation layer.” Article 20(3) requires, for 18 categories of act within a Special Zone — including “newly building, rebuilding or extending a structure” — permission from the Minister of the Environment in National Parks and from the prefectural governor in Quasi-National Parks. Article 21(3) imposes stricter controls within Special Protection Zones, and Article 33(1) makes new construction of “structures exceeding standards specified by Ministry of the Environment ordinance” in Ordinary Zones subject to notification.

These two layers are independent. Authorization to execute a park project does not get you a building if you fail the permit criteria, and meeting the permit criteria does not let you execute a project that is not in the park plan. Due diligence has to confirm both, separately.

Source: prepared by MetroEngines Research & Consulting from Ministry of the Environment, “Area by Land Classification, National Parks” (as of April 10, 2026)

Land-classification mixes vary enormously from park to park. Across all 35 National Parks, Special Zones account for 74.9% (of which Special Protection Zones are 15.0%) and Ordinary Zones for 25.1% — but in Chubusangaku National Park, Special Protection Zones alone are 36.8% and Ordinary Zones only 13.1%. In Yakushima National Park, Ordinary Zones are 0.3% (65 ha), meaning that in practice the entire park is Special Zone. At the other end, Ordinary Zones make up 51.1% of Nikko National Park and 52.2% of Joshinetsu-Kogen National Park. “It’s inside a National Park, so you can’t build” does not hold; the judgment has to be made from the land classification on the area map, not from the park’s name. Five parks — Shiretoko, Oze, Myoko-Togakushi Renzan, Hakusan and Minami Alps — have zero hectares of Ordinary Zone, with every part of their area designated as Special Zone.

Quantitative requirements by land classification — even a Class 3 Special Zone caps gross floor-area ratio at 60%

The permit criteria for regulated acts are written out numerically in Article 11 of the Enforcement Regulation of the Natural Parks Act and in the Ministry of the Environment’s “Review Guidelines for Various Acts within National Parks” (Kanjiki No. 570 of November 20, 1974; revised by Kanjiho No. 657 of November 14, 1990). The numbers that matter to a developer are these.

Source: prepared by MetroEngines Research & Consulting from the Enforcement Regulation of the Natural Parks Act (e-Gov Japanese Law Search) and the Ministry of the Environment’s “Review Guidelines for Various Acts within National Parks” and “Outline of Permit Criteria for Various Acts within Special Zones of National and Quasi-National Parks”

Set these numbers beside our earlier zoning series and the difference in regulatory intensity is an order of magnitude. In urban commercial districts a floor-area ratio of 400–700% is common, and a limited-service hotel by a station builds its economics by using that volume up. Against that, the gross floor-area ratio ceiling is 60% in a Class 3 Special Zone and 40% in a Class 2 Special Zone. Being able to build only 600 sqm of floor area on a 1,000 sqm site (Class 3) means that, at 25 sqm guest rooms and 35 sqm per room including common areas, a 1,000 sqm site yields about 17 rooms. A 13 m height limit caps you at roughly four storeys, so stacking floors is not available as a workaround either. Note that outside park areas too, sites beyond the urbanization promotion area are governed on the same schedule-defining basis by development permits and farmland conversion (see 61% of 2026 openings are outside urbanization promotion areas).

This constraint structurally determines the business model for resort development. A model that recovers cost through room count does not work; only a model that recovers through rate and length of stay remains. That accommodation inside National Parks skews small and expensive is a consequence of the regulation, not a preference of operators. Put the other way round: a brand or operator that cannot compete in that band cannot run a site inside a park even after acquiring it.

Room counts back-solved from the regulatory ceilings — sensitivity on site area x land classification

The “17 rooms on 1,000 sqm” above is a single point estimate on mid-case assumptions. For an investment decision it is faster to see, as a surface, which of the two variables — site scale or land classification — does the work. What follows mechanically applies the upper limits in the permit criteria (building coverage 20% or less, gross floor-area ratio 40% for Class 2 and 60% for Class 3, building footprint 2,000 sqm or less, height 13 m or less) to a site area and divides by 35 sqm per room including common areas. These are not figures from real projects; read them as an upper-bound guide back-solved from the regulation.

Source: MetroEngines Research & Consulting estimate from the quantitative requirements in Article 11 of the Enforcement Regulation of the Natural Parks Act and the Ministry of the Environment’s “Review Guidelines for Various Acts within National Parks”

Two things stand out. First, the gap between Class 2 and Class 3 is a consistent 1.5x (40% versus 60% gross floor-area ratio) — move one step in land classification and the rooms you can take from the same site shift by half. Second, on a 10,000 sqm site, using up the 20% building coverage gives a 2,000 sqm footprint, which exactly matches the footprint cap in the permit criteria. Beyond that site size the binding constraint is no longer the ratio but the absolute 2,000 sqm limit, and combined with the 13 m height limit (roughly four storeys) gross floor area tops out at about 8,000 sqm, or around 228 rooms. Inside a park area, taking a larger site does not buy you economies of scale.

Next, flex the estimate’s most sensitive input: area per room including common space. The more generously you size guest rooms to resort specification and the heavier you build out restaurants, spa and large communal baths, the fewer rooms the same gross floor area yields.

Source: as above (rough estimate dividing gross floor area by area per room; fractions discarded)

The spread is not small. On identical conditions — a 3,000 sqm site in a Class 3 Special Zone — the answer runs from 40 to 60 rooms, a 50% range, depending on how common areas are handled. Skip the volume study on a park-area project and build the financials first, and that spread becomes the error in your business plan. Taken together with the data in the preceding sections: the room ceiling is set by regulation, and the rate is set by demand. Both are variables to be pinned down before the site-acquisition decision, and reversing that order is not recoverable.

Has supply really stopped? Stock turnover across 33 municipalities and 140,920 rooms

From here we test it against data. For 33 resort municipalities nationwide that host National Parks or Quasi-National Parks, we aggregated total rooms at accommodation properties confirmed to be operating, and rooms at properties confirmed to have opened since 2020. Against 140,920 rooms in total, 14,410 have opened since 2020 — a ratio of 10.2%. The dispersion between municipalities, however, is extreme.

Source: MetroEngines Research & Consulting (room counts and opening years based on confirmed OTA listings; ADR is July 2026 and N is the number of properties covered; estimated occupancy is based on August 2026 OTA listed inventory. “—” indicates too few properties covered to publish a figure)

Source: MetroEngines Research & Consulting (based on confirmed OTA listings, N=33 municipalities, 140,920 rooms)

At the bottom, Noboribetsu City has added just 4 rooms since 2020 against total stock of 1,459 (0.3%); Kamikawa Town 8 rooms against 1,615 (0.5%); and Kokonoe Town 14 rooms against 1,383 (1.0%). In every case these are municipalities whose main accommodation cluster overlaps a National Park’s use base (a group facility district or similar). Noboribetsu Onsen and Toyako Onsen lie within Shikotsu-Toya National Park, Sounkyo within Daisetsuzan National Park, Handa Kogen within Aso-Kuju National Park, and Shiga Kogen within Joshinetsu-Kogen National Park. The bottom five municipalities — Noboribetsu City, Kamikawa Town, Kokonoe Town, Toyako Town and Yamanouchi Town — hold 13,388 rooms between them, but new supply since 2020 amounts to 216 rooms, a ratio of 1.6%.

By contrast, at the top, Kutchan Town is at 25.1%, Nasushiobara City 19.0%, Minamiaso Village 17.2%, Furano City 17.1% and Takayama City 16.8% — turning over roughly a fifth of their room stock in six years. That gap is not a gap in demand; it is a gap in how far the supply side can move.

Source: MetroEngines Research & Consulting (new-supply ratio based on confirmed OTA listings; ADR is July 2026, for the 25 municipalities with 20 or more properties covered)

Stopping supply does not lift the rate — a correlation of 0.18

This is the core of the article. The intuition that “hard to build means supply is fixed means a scarcity premium” is not supported by the data.

Across the 25 municipalities with 20 or more properties in the ADR estimate, the correlation between new-supply ratio and estimated transacted ADR for July 2026 is 0.18 — effectively no correlation. The 12 municipalities below the median new-supply ratio (8.0%) have a median ADR of about ¥14,400, while the 13 at or above 8.0% come in at about ¥17,500: if anything, the places where supply is moving carry the higher rate.

Looked at individually the structure is clear. Kamikawa Town, with a new-supply ratio of 0.5%, has an estimated transacted ADR of about ¥8,200; Taketa City, at 4.2%, about ¥8,100. Meanwhile Kutchan Town at 25.1% runs about ¥17,500, Karuizawa Town at 14.3% about ¥24,700, and Atami City at 13.6% about ¥21,900. About the only municipality with frozen supply and a high rate is Minamioguni Town (3.3% new supply, about ¥25,900), and that is because Kurokawa Onsen stands there as a strong demand-side brand.

Translated into investment terms, it comes to this. The Natural Parks Act reliably closes the valve on the supply side, but that alone does not form a price. Scarcity converts into a premium only where demand-side conditions — access (time from a Shinkansen station, expressway or airport), recognition, year-round usability — are also in place. The argument that “the regulation is strict, so values will rise” does not hold up when used without demand-side support. Conversely, places where demand is strong and supply is closed — Minamioguni Town, Hakone Town, Nasu Town — have a structure that new entrants are unlikely to break, which makes them prone to competitive bidding.

On estimated occupancy, the demand floor is solid

Even in municipalities where rates are not growing, demand itself is not weak. On estimated occupancy for August 2026 (based on OTA listed inventory), 12 of the 13 municipalities for which a figure could be compiled exceed 85% — the sole exception being Minamioguni Town at 78.8%.

Source: MetroEngines Research & Consulting (August 2026, estimated from OTA listed inventory)

Matsumoto City at 97.5%, Karuizawa Town at 95.8%, Kokonoe Town at 92.9%, Atami City at 92.6% and Nasushiobara City at 92.5% — inventory is thin at the summer peak. Even Kokonoe Town, where supply is not moving, sits at 92.9%, which tells us demand is not thinning out. There are municipalities where demand exists but is not being converted into rate — and that is better read not as an operational problem at the property level, but as a consequence of the physical plant (room size, building age, facilities) being hard to renew, on both the regulatory and the capital side.

What is happening in the acquisition market — property data from listed REITs

In a market where new development is difficult, acquiring existing properties becomes the main arena for capital. Cross-referencing all 302 properties held by seven listed hotel REITs (ownership master, snapshot as of August 31, 2026) against the 33 municipalities covered here returns 20 properties. They are listed below from most to least recently acquired.

Source: prepared by MetroEngines Research & Consulting from an ownership master built on each REIT’s disclosures (snapshot as of August 31, 2026; 20 of N=302 properties matched)

Among recent acquisitions, Invincible Investment Corporation’s purchase of Kirishima Kokusai Hotel in August 2025 (165 rooms, ¥6,534m, ¥39.6m per room) and the same REIT’s purchase of Kamenoi Hotel Izu-Kogen in July 2024 (55 rooms, ¥5,563m, ¥101.1m per room) show capital moving toward mid-sized properties in resort locations. Per-room pricing varies widely with property grade and location: Kai Kirishima (49 rooms, ¥3,913m) comes to ¥79.9m and Hoshinoya Karuizawa (77 rooms, ¥7,600m) to ¥98.7m.

By owner, 12 of the 20 properties are held by the resort-focused Hoshino Resorts REIT, followed by Invincible Investment Corporation with 4, Japan Hotel & Residential Investment Corporation with 3, and Japan Hotel REIT Investment Corporation with 1. Acquisition prices total ¥91,279 million.

That said, this is 20 properties out of 302, and against 140,920 total rooms in the municipalities covered, REIT holdings are 2,037 rooms, or 1.45%. Most of the accommodation stock in park areas remains in the hands of individuals and local capital, and the listed-REIT ownership share is strikingly low compared with urban markets. The competitive bidding is happening in that thin top layer. Where the buyer is foreign capital, note that separately from the Natural Parks Act, foreign-investor rules on hotel acquisition and the notification duties in special watch zones land on the closing schedule.

Park areas and the supply-turnover map

The map below shows where the 33 municipalities sit and how room scale relates to new-supply ratio. Circle size is total rooms; color is the new-supply ratio since 2020.

Source: prepared by MetroEngines Research & Consulting

The Shikotsu-Toya, Daisetsuzan and Akan-Mashu areas in Hokkaido, the western side of Aso-Kuju in Kyushu (Kokonoe Town, Minamioguni Town) and Shiga Kogen (Yamanouchi Town) line up in dark blue — low turnover. In each case the park’s use base sits at the center of the accommodation cluster. Municipalities whose accommodation clusters sit outside or on the fringe of the park area — Kutchan Town, Furano City, Nasushiobara City, Takayama City, Beppu City — shift toward the lighter colors.

How far has the policy tailwind actually changed practice?

The Ministry of the Environment has run the National Park Enjoyment Project since 2016, and on March 31, 2026 it published its “Policy Direction from 2026 Onward.” The policy rests on three pillars: (1) delivering attractive stay experiences unique to National Parks, (2) strengthening brand power and promotion for both communities and visitors, and (3) contributing to local areas by realizing a virtuous cycle of protection and use. The first pillar explicitly states that the Ministry will “examine the operation of relevant systems and the revision of plans in light of private-sector proposals, in order to further promote private investment,” and adds that it will “also consider approaches to preventing new buildings from being abandoned.” It is positioned as the final push toward the 2031 centenary of Japan’s National Park system. How far the scope for accommodation businesses may open up varies park by park, and has to be read against each park’s own plan.

On the institutional side, the 2021 amendment to the Natural Parks Act is what bites in practice. Article 16-2 established councils involving municipalities and operators, and Article 16-3 introduced a framework for drawing up a “use-base development and improvement plan” and obtaining the Minister of the Environment’s certification for it. Such a plan records the development and improvement of facilities relating to park projects, and by incorporating the required items into the plan, projects that would need consultation and authorization under Article 10 can be processed through a single integrated procedure. Furthermore, under Articles 8-2 and 9-2, a council may propose to the Minister of the Environment a change to the park plan, or the decision or amendment of a park project itself.

The practical implication is clear. Where the old answer was “no accommodation business in the park plan, no deal,” there is now a legally provided route to work on the plan side through a council. There is no guarantee a proposal will pass, however, and it must satisfy the certification requirements: appropriate in light of the park plan, contributing to improving the quality of the use base, posing no risk of impeding protection of the park, and likely to be implemented smoothly and reliably. On timing, the process of forming a council, drawing up a plan, applying for certification and obtaining the Minister’s certification adds a lead time separate from ordinary building confirmation.

Visitor numbers have recovered too. According to the Ministry of the Environment’s survey of natural park visitors, National Parks drew 336.14 million visits in 2024, up 4.2% year on year, with natural parks overall at 808.69 million (up 2.5%). The most-visited is Fuji-Hakone-Izu National Park at 124.18 million, or 36.9% of all National Park visits. The volume of demand is extremely concentrated in parks close to the Tokyo metropolitan area, and that concentration maps onto the ADR gaps seen in the previous section.

A practical checklist — developers, funds, regional banks

The order of checks and the points at issue change with the reader’s position.

Conclusion

The Natural Parks Act sits on a different layer from the building-related rules covered in our earlier work. If an accommodation business is not designated in the park plan, the project cannot be executed whatever the land classification. Before confirming that a site is legally buildable, you have to confirm that the business can exist there at all.

On top of that, the permit criteria impose ceilings — a 60% gross floor-area ratio even in a Class 3 Special Zone, 13 m in height, a 2,000 sqm footprint — under which a model that recovers cost through room count is structurally unworkable. That constraint reliably closes the valve on supply: in the bottom five of the 33 municipalities covered, six years of new supply amounts to 1.6% of total rooms.

But fixed supply does not guarantee rate. The correlation between new-supply ratio and estimated transacted ADR is 0.18, close to none, and municipalities with frozen supply and low ADR (Kamikawa Town, Taketa City) coexist with municipalities where supply is moving and ADR is high (Karuizawa Town, Atami City, Kutchan Town). Scarcity turns into a premium only where the demand-side conditions are in place.

With the 2021 amendment and the 2026 policy direction for the Enjoyment Project, a route now exists in law to work on the park plan and the park project themselves through a council. Projects in park areas have entered a stage where the contest is decided not by “can it be built” but by “can it be designated as a project, and how much time can you put into that.”

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• 61% of 2026 openings are outside urbanization promotion areas — how development permits and farmland conversion change time to opening
• Foreign-investor hotel acquisition rules 2026 — 165 municipalities in special watch zones and three notification duties
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