is it possible (re-)configure the portable version of miktex so that write access to the distribution is not needed?

Since there was some confusion, this is hopefully a clearer version of 
my previous post.

We include the portable version of MikTeX in our software distribution 
because we have a report generation tool that uses MikTeX as a back end. 
Our users don't actually use MikTeX directly. The report generation tool 
is command line only. The MikTeX executables that we use are accessed by 
our report generation tool and are used in "batchmode". (BTW, we include 
copyright notices, etc., for MikTeX in the distribution.)

What we did is this.

1) we downloaded the 2.9 portable version of MikTeX and installed it.

2) we ran the portable version on a tex file that downloads all the 
packages to which our users need access for the report generation tool.

3) we then include the MikTeX distribution folder in our distribution. 
Our report generation tool (python) executes the MikTeX executables it 
needs to. Because we're using the portable version, no MikTeX 
initialization or Windows registry access is needed.

This actually works except for one small feature: MikTeX's pdflatex and 
latex need the files texmf.fndb and mpm.fndb (in miktex/data/le)  to be 
writeable by users, specifically, users with non-admin accounts. If we 
make these two files writeable, this approach works without any problems.

(If they aren't writeable, errors like "pdflatex: Windows API error 5: 
Access is denied" occur.)

The issue with this approach is that our customers are typically 
installing our software, including the MikTeX directory, in Program 
Files.  Some of our customers have a security requirement that no file 
in Program Files can be writeable by users. Also, these are often 
multiuser environments.

It does seem from the tests I ran that texmf.fndb and mpm.fndb do not 
need to be writeable if all the packages needed are already installed. 
Specifically, if all the packages are already available, pdflatex and 
latex do not change the contents or the time stamps of texmf.fndb and 
mpm.fndb.

My question is: is there some way to re-configure the portable version 
MikTeX so that write access to texmf.fndb and mpm.fndb is not needed.


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