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ENVIRONMENTAL IMPACT ASSESSMENT OF DEVEWPMENT PROJECfS IN THE PHILIPP!NES - SOME EXPERIENCES
Q.L. Kintanar Deputy Director-General
NatioTUIJ Science and Technology Authority Bicutan. Taguig, Metro Manila, Philippines
ABSTRACT
Environmental Impact Assessment of de..elopment projects as a distinct scientitic endea\Or is a fairly recer:t development. The Environmental Code of the Philippines which requires Environmental Impact Statements for development projects was decreed (P.D. JISt-Philippine Environmental Policy) in 1977.
In thi.~ paper, I shall review the rationale, methodology, format, and problems of Environmental Impact Assessment work using my own experience with three EIA/EIS;namely:
I) Biro! River Basin Development Projects 2) Barangay Water Supply Project 3) Southern Negros Geothermal Project
as iUusuative cases.
Introduction
The requirement for an Environmental Impact Statement (EIS) for " every action project or undertaking which significantly affects the quality of the environment" was decreed in the Philippines in 1977 (P.D. J 15 I -The Philippine Environmental Policy).
This followed developments in the United States of America which passed a law -- the National Environmental Protection Act (NEPA) - in 1970, which required EIS to be prepared for "major Federal actions significantly affecting the quality of the human environment."
Before these environmental laws were passed, it was common practice to suhject major projects to analyses and evaluations which were confined to the assessment of their technological or technical feasibility and their economic viability. The new requirement for an Environmental Impact Assessment (EIA) made compulsory the consideration of long-term environmental effects together with short -term cost-benefit analysis in the overall planning and decision-making of development projects (Fig. I). ldcaUy, this EIA should be done early in the project planning process so that it can be a factor in the selection of the best available alternative to achieve a given desirable objective (Fig. 2). Additionally,
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38 Transactions National Academy of Science
Usual Project J::nvfronmental Decisicnon Feasibility Study lmpQCt Assessment Project
I. Technical feasibility NO GO GO GO
2. Economic Viability NO
a. Return on Investment GO GO
GO b. Cost· Benefit Analysis
3. Environmental NO Effects and Impacts GO GO
Cost of Prevention/ GO
Mitigation
GO NO NO NO
Final Decillion GO GO GO
Fig. 1. Development Project Planning - Study, Analylis and Do:.:isinn.
Program Planning
Project Environmt>ntal Feasibt~ty Assessment
1.:1 ~
I I I
Project Monito · lrnplt:men· ring tat ion
GO
GO
GO
GO
Fig. 2 . Enviromn~ntal Impact Assessment as an lnt~gral Componl.'nt of the Planning & 0 l'cision Makin!! Process
Kintanar, ElS of Development Projects 39
the EIA identifies measures to mitigate probable adverse environmental effects and suggests parameters to be monitored to serve as an early warning system.
Rationale for EIA/EIS
The rationale for requiring an EIA/EIS for development projects is to ensure that besides meeting a desired development objective, these projects:
I) avoid drastic and/or long term harmful effects on man and nature 2) promote an optimal balance of the various developmental concerns
such as - population growth, economic development and protection of the environment
3) consider the carrying capacity of ecosystems 4) encourage and support " design with nature" rather than "design with
out nature", and 5) prolong the availability and use of resources rather than lead to ex·
haustion or extinction.
Projects and Actions Requiring EIA/EIS
Both Philippine and U.S. Laws, do not clearly define the scope of "major Federal actions significantly affecting the quality of the human environment" (Sect. 102, NEPA, 1970) or "every action project or undertaking which signi· ficantly affects the quality of the environment" (Sect. P.D. 115 1-1977) which require mandatory EIA/EIS. To help clarify the scope of this provision, the National Environmental Protection Council (NEPC) listed 11 criteria in its EIA Hand· book (Fig. 3).
These are general criteria requiring tlle project proponent to prepare and submit an EIS if any one or a combination of the listed criteria exist. However, exemptions from this EIA/EIS requirement are possjbJe for certain projects, for reasons of national security or international commitment as determined by the President or the NEPC Executive Director.
Methodologies in EIA
The methodologies for EIA are still evolving. No single method is adequate and applicable to all types of action, project or undertaking.
40 Transactions National Academy of Science
Five main classes of methodologies have been applied by EIA practitioners since 1970. These methodologies for identifying and predicting envirorunental impacts are:
I. Checklist Method which lists typical impacts to be checked, if present. The listed impacts differ depending on the category of development projects (Fig. 4).
Fig. 3. Critt:ria which can he Utilizt:d as a Basi:; for R~quiring the Preparation of Environ· mental impact Statement
L Changes in land use patterns; 2. Changes in energy supply/demand ; 3. Increased development in 11oodplains; 4. Discharge of substantial toxic materials or chemicals; S. Significant changes in ambient air/water qualitY; 6. Destruction of important natural, ecologically significant, historical or cultural resource(s); ?. Destruction of fL~/wildlife habitats, especially, pertaining to threatened rare and/or
endangered species; 8. Substantial displacement of people/community structure; 9. Significant changes in surface/griundwater quantity;
10. Potential threat(s) to health, safety or property; and, 11. Exceeding the natural, physical, biological or spatial carrying capability of an vea (e.g.
community, ecosystem. municipality or city).
Fig. 4 . Environmental Impacts Associated with Sit~ Preparation Activities.
Site Preparation Activities
1. Demolition/ Removal 1. 1 derelict buildings 1.2 remnant pavement 1.3 remnant footings 1.4 abandoned utilitie s 1.5 diseased tr~es
1.6 hazardous/overgrown hntsh, weeds or vin~s
l. 7 rocks and boulders
Potential Em·ironmental Impacts
I. displa"-em.,nt of people 2. generation of noise 3. soil erosion 4. disturbance of natural drainage 5. interference with w at ~r table 6. wate r pollution 7. air pollution (dust, exhaust,
fumes, smoke) 8. damage/destruction of wild lift'
habitat 9. Joss ofsccnicquality.open
space., historic sites. recreation spai."~, parks
I 0. loss oi aesthetic value d uc to site preparation activities
Kintanar, EIS of Development Projects 4 1
2. Matrix Method which allows the correlation of specific project act ivities wi th the corresponding environmental effects i.n a two-way table (Fig. 5).
3. Networking Method which expands the concept of a matrix by presenting a more complicat~:d network of cause-condition-effect , including cumulative and indirect effects (Fig. 6 ).
4 . The Composite Map Technique which is an application of the usual land use and landscape architect ure technic to EIA. Trus allows the spatial superimposition of various feat ures and properties. or data on the same map (Fig. 7).
5. Ad hoc Procedures which usually means the assembly of specialists t o identify impacts in their own areas of expe rtise .
NATURl AND CHARACTFRISTK' or TlH PROPOSI·.O DtV~LOPMENT
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l·il,!. 5. Jn t<"Tal'tio n Ll'OI)Old Matrix.
MAJOR CONSEQUENCts DREDGING
ADAPTED FROM SORENSFN, I.C. A FRAMEWORK FOR IDENTil' l( ATION .l CONTROL OF RESOURCE DEGRAilATION t\ CONFLICT 11\.THE MULTIJ'U USE OF THE COASTAL ZONF, IN ENVIRONMENTAL IWPACT ASSESSMt:NT, BY LARRY W. CANTER (NEW YORK; Me GRAW·Hli.LBOOK COMPANY, 197') P. 197.
Fig. 6. Network Analysis Dredging Operations.
z .. c. 0
[
~ c. G 3 '< 0 ....,
COMPOSITE MAP (ENVIRONMENTAL
Kintanar, EIS of Development Projects
CONSTRArnl~S1)11~~IJ]i~~!!!i~~~ SOILS MAP
SLOPE MAP
LEGEND; ENVIRONMENTAL CONSTRAINTS
--HIGH
~MEDIUM
LOW
NEGLlGmLE
Fig. 7. Example for Composite Mapping.
43
From 1970 to 1974, there were 3,400 final EIS submitted to NEPA in the U.S.A. The majority of the projects were roads, watershed, flood control, energyrelated projects, airports, navigation, parks and wildlife refuge, pesticide, herbicides and timber management. In the Philippines, there were 37 EIS covering projects such as heavy industries, resource extractive industries, infrastructure projects.
Conceptual Framework of EIA
Conceptually, EIA is simply the identification, prediction and evaluation of the environmental impacts of alternative courses of actions or projects to achieve
44 Transactions National Academy of Science
a desired objective. The environmental impacts of a sel!!ctcd project may be represented as the difference between the future environmental conditions with the project and thqse without the project (Fig. 8). The best course of action or alternative, environmentally speaking, would be the one with the least adverse environmental effects. Another way of looking at it would be to project the condition of the environment without the action and with the action (Fig. 9). The difference between the two curves would represent the environmental impact of the action or project_
PRESENT DEVELOPMENT FUTURE ENVIRONMENTAl CONDITIONS WITH PROJECT ENVIRONMENTAl PROJECT
SEITING AND CONDITIONS+
NO PROJECT Less
FUTUREENnnRONMENTAL CONDITIONS WITHOUT PROJECT
6, =ENVIRONMENTAL DIFFERENCE
.. ENVIRONMENTAL IMPACT OF PROJECT
Fig. !1. Conceptual Framework of Environmental impact Assessment.
CONCEPTUAl SCHEMATIC OF ENVIRONMENTAL CHANGES
CONDITION OF THE ENVIRONMENT 'WilltOUT ACTION'
1
~ ~ '~ CONDITION OF THE
~ ENVIRONMENT
""'1111\.-Y' 'WITH ACTION'
"'"' ----------
Fig. 9. Conceptual Schematic of Environmental Cllanges.
Kintanat, EIS of Development Projects 45
One of the major problems in the evaluation of environmental impacts of alternative courses of action or projects achieving the same desired developmental objective is the non-comparativeness of the impacts of these different alternatives. One approach to this problem is the use of an aggregate index of overall impact through some form of a weighted factor method where nwnerical weights for importance of factors and scores for each factor are made by experts. Two methodologies using the approach are : I) the Bate lie Environmental Evaluation system and 2) the Georgia or Odwn Optimwn Pathway Matrix. These two methods attempt to arrive at a common basis for comparison of the environmental impacts of different alternative actions or projects, thus making direct comparison of aggregate index of environmental impacts possible.
Typical Format of EIS
The outline of a typical EIS is shown in Fig. 10.
Fig. 10. Environmental Impact Statement Outline.
I . Name and Address of Project Proponent 2. Type of Project 3. Overview/Summary 4. The Project Setting
4.1 Declaration and Objectives 4.2 The Need 4.3 Alternatives 4.4 Associated Projects
5. The Proposal 5.1 General Layout 5.2 Pre-Construction Details 5.3 Construction Details 5.4 Operation and Maintenance 5.5 Contingency Plans 5.6 Abandonment
6. A Brief Hbtory of Past Environmental Conditions and a Description of the Existing Environment and Resource Use 6.1 CUrnate 6.2 Terrain 6.3 Hydrology 6.4 Oceanography 6.5 Atmosphere 6.6 Vegetation 6. 7 Fiah and Wildlife 6.8 Land and Resource Use 6.9 Socio-economic Aspect!
7. Future Environmental Cooditions Without the Project
46 Transactions National Academy of Science
8. Prediction and Assessment of Impacts 8.1 Physical and/or Chemical Effects
8.1.1 Surface Water 8.1.2 Ground Water
8.1.2.1 Atmosphere 8.1.2.1.1 Air Characteristic
8.1.2.2 Wind 8.1.2.3 lnversion
8.2 Eoological Effects 8.2.1. Terrestrial Species
8.2.1.1 Vegetation 8.2.1.2 Wildlife
8.2.2 Aquatic Species and Habitats 8. 3 Aesthetic Effects
8.3.1 Land 8.3.2 Atmosphere 8.3.3 Water 8.3.4 Flora and Fauna 8.3.5 Man-made Objects 8.3.6 Composition
8.4 Socio-economic F. ffects 8.4.1 Demography 8.4.2 Manpower 8.4.3 Transportation 8.4.4 Housing and Community Infrastructure 8.4.5 .Education, Health and Social Services 8.4.6 Lifestyle
9. Contingency Plans 10. Environmental Briefmgs and Monitoring 11. Mitigating Measures 12. Residual/Unavoidable Impacts 13. Information Deficiencies 14. Appendices 15. Consultation and Conunents Including Public Recommendations*
•For Final Environmenta11mpact Statement Only.
EIA Process and EIS
To give you an idea, let me describe the process (Figs. II & 12) and procedural flow of the Philippine EIS system {Fig. 13).
IUustrative Cases
For examples, I shall draw from my own personal experience and present the summary of project description and environmental impacts from ElS that I had a
Kintanu, EIS of Development Projects 47
direct hand in making. The number of pages and volumes of these Environmental Assessment Reports are shown in the References at the end of this paper.
Vag. 11. Environmental Impact Assessment Process.
BASELINE STUDIES COMMENTS AND SUGGESTIONS BY ~ DRAFT ENVIRONMENTAL___, FROM RELEVANT AGENCIES
MULTIDISCIPLINARY TEAM IMPACT STATEMENT AND INTERESTED GROUPS
t DECISION ON
PROJECT FINAL ENVIRONMENTAL +--- PUBLIC HEARINGS
IMP ACT STATEMENT (if ne«ssary)
EJA of the Barangay Water Project
A. Project Description
The purpose of the project is to establish and to ensure the maintenance of viable water supply systems for small rural communities of 5,000 people or Jess in 25 provinces selected from among the 28 provinces participating in the Pro· vincial Development Assistance Project (PDAP) in the Philippines. Between I 00 and 200 individual water system subprojects, costing from P20,000 ($2, 700) to P500,000 ($68,000) each, will be established in the three years from 1978 to 1980. There will be 15 participating provinces in 1978, 20 in 1979, and the full projected number of 25 provinces in 1980.
The four major components of this project are:
I. training and organization activities which consist of training personnel at the national, provincial, municipal and barangay levels for planning, management and technical work related to the project. Besides orga· nizing trained personnel at the various levels of government, there will also be organization of local water associations at the community or barangay level to ensure the continued viability of the local water supply systems.
2. design activities which require that all subprojects take into special consideration ecology, health, safety, minimal construction and opera· tion costs, community involvement, and present and future demands for domestic water. To illustrate the lower and upper limits of the size of the water supply systems to be built, two hypothetical examples with their corresponding likely components are given below:
Example I. Small system to serve as few as 300 people:
natural spring development or deep weU (more than 45 feet deep) plus
~ IDI::NTIF!CA"!ION OF EV AlUATIO:< Of ENV IRONMENTAL IMPACTS
AS~-.. I'II.OJECT Ill l:"NIT .. T 2.8 l 1ALTI::RNATIVES IMPACTS ~ MEASURES r ,........__
... I I T 2 I 3 I-ncH I MEDIUM j ww r T 3l--P1
I 2
...&..
! EN V 11\0NM ENT A I. IMPACT DOCt:MENT (EIP)
....... I PROJECT DE<":ISION l
I PROJECT coMPO:-.cNTs l DESCRIPTION OF ENVIRONMENTAL SETTING
I I I I ] r I I
SITE PREPARATION CONS'fRUCTION OPERATIONS ~ATURAL SOCIO-ECONOMIC CULTURAL ENVJRO?\ME~'T ENVIRONMENT ENVIRONME!•IT
CLEARING PLACEMENT ('OSSUMPTION OF I.AND UV i:.LIIIOOD OF STRUCTVRES RESOURCES llFESTY Lf.S
GRliBBJNG INSTAlLATION DISCHARGE OF AIR INC'OME TRADITION
GRADING OF liTILITIT:S LJQUID WASTI'S WATER POPULATlO!\ ARCHFOLOGJCAL
LAYOiiT OF MAINTENANCE Rf.SOl.lRCFS DEM.OUTION ('I RCU LA TION Of MACH1XES SYSTEM & STRUCfCRES VEGHATION PUBLIC'
SFRVJ('f. HISTORICA L LANDSCAPING DISPOSAL OF RESOURCES & FENCING SOLJD WASTE
Fig. 12. Envi.ronmcntal Impact Assessment Flo wchart .
KiJHanar, EIS of Development Projects
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~-------- ~-------JrrO t"<' B.L<O)(U£SD! nne NON-v>Sl)AN('f OF !::(;t ;
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Fig. 13. Procedural Aow of the EIS System.
J,..A. LLADAGt-KV FJS..J.t: Fu a~rw roww.rrTEt: lol(~ NATIONAL ENVJilONW&TAJ.
rxoncTX>N r;0\1K('ft.
49
50 Transactions National Academy of Science
1 2.5-5.0 HP submersible or centrifugal pump l 5,300 gallon elevated storage tank 600 feet or 3 and 4 inch pipeline I 0 metered public faucets
Example 2. Large system to serve about 5,000 people:
deep well (more than 45 feet deep) 1 7.5-20.0 HP submersible or centrifugal pump I 20,000 gallon elevated storage tank 3,000 feet of 3 and 4 inch pipe valves and meters for houses and 20 public faucets.
3. construction activities which include (a) preparation of a water source which would involve drilling a well in most cases, (b) construction of a concrete storage tank, (c) building a pump house and installing an electric pump and (d) installing transmission and distribution pipes, valves and public faucets; and
4. operation and maintenance activities which include (a) start-up, initial clean-up and disinfection, (b) continuing supply of potable water to paying members of the Water Association and (c) maintenance and repairs of the system as needed.
B. Summary of Environmentallmpacts
1. There will be the usual minor environmental impacts assodated with small-scale construction activities. These impacts include erosion of soiJ loosened during trenching, dust pollution, exposure of area residents to open trenches and traffic congestion.
2 . Since the usual water source is a deep well, there is some chance of exposing ground water to outside contamination and the remote possibility of releasing toxic chemicals from a contaminated source.
3. In the case of a deep well source , there is the possibility of noticeably lowering the water table, saline intrusion and ground subsidence.
4. There wouJd be a minor redistribution of surface water in the case of a natural spring source and a major redistribution of surface water in the case of a stream or river source. In the latter case, there would be some adverse effect on the aquatic ecosystem.
5. In the case of a stream or river source, there would be the need for chemical treatment of the water.
6. Water in the distribution lines might be contanlinated with leaks in the absence of proper design and construction .
7 . Given that most subprojects will result in an increase in per capita water use by a factor of four , there will be an increase in sullage or excess water from domestic usc.
8. An elevated storage tank, depending upon its location and protect ive
Kintanar, EIS of Development Projects 51
measures, might be a hazard to small children who would be tempted to play on it.
C. Alternatives
I . No project. 2. Delay of Project. 3. Other Projects With the Same Effect. 4. Sources Other Than Deep Well. 5. Limited Distribution System. 6. Other Energy Sources.
D. Conclusions and Recommendations
I. General
a. This environmental assessment leads to the conclusion that the relatively insignificant adverse effects of the Barangay Water Project cannot offset the great health and socio-economic benefits that would accrue to the small rural communities that would be served by the project.
b. The EA team recommends that the feasibility study for each project explicitly consider the capacity of the waste water disposal system. If the system appears inadequate, then a simple disposal system should be designed and incorporated into the subproject.
c. The EA team recommends that the Barangay Water Project staff assist provincial development staffs in designating more subprojects in rural communities with incomes below the national average. The few subprojects reviewed by the EA team were located in relatively well-off communities. Communities with incomes lower than the national average, even though less fman· cially attractive, would be more in keeping with the AID stated objective of assisting the rural poor.
d. The EA team recoJIUllends that the Barangay Water Project staff assist and support provincial development staffs in designing less sophisticated water supply systems. These systems would consist primarily of a deep well/electric pump and only one or a few public standpipes. These simple systems, which are encouraged by the Misamis Oriental Rural Electric Service Cooperative among others, could reduce system cost per household by as much as 75 percent. Such a reduction in system cost would mean that financial resources would be available to serve many more communities.
e. The EA team xecommends that the Project be implemented without delay.
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2.
Transactions National Academy of Science
Unique to Lolomboy, Bocauc, Bulacan
a. The EA team recommends that the residents of Lolomboy be regularly made aware that proper disposal of liquid and solid wastes is necessary to maintain the improvements in human health achieved by an improved and expanded source of water supply.
b. The EA team recommends that the subproject in Lolomboy provide a larger tank capacity adequate to meet t.he demands of current residents in the service area, as well as the projected population in the near future. The present design calls for a
storage tank of 20,000 gallons. A more appropriate size tank would be 38,000.
3. Unique to Ariston Weste-Bantog, Asingan, Pangasinan
a. The EA team recommends that the residents of Ariston WesteBancog be maue aware on a regular basis that proper disposal of liquid and solid waste is necessary to maintain the improvement in human health achieved by an improved and expanded source of water supply.
b. The EA [Cam recommends that the Ariston Weste-Bantog sutr project include building a fence around the water storage tank in order to keep the school children off it.
EJA of !he Bicol River Basin Development Projects
A. Project Description
The Bkol River Basin Development Projects is one of the USAID-financed activities in the Philippines, the primary aim of which is to raise the standard of living of the Basin people to the national average at the end of the century and maffitain its growth rate after the year 2000. It involves an integrated development approach toward infrastructure development such as irrigation and drainage, sal.inity control, flood control, roads, agricultural practices, fish culture and domestic water supply projects on a basin-wide scale covering some 3 t 2,000 hectares. The program has three major thrusts namely: agricultural development strategy, indus· trial development strategy and social services strategy.
B. Summary of Environmental Effects
I. Effects on the Natural Environment : Soils: Soil erosion is anticipated to occur during construction and upon project operation and development. Unstable embankments on the llicol River would be subjected to erosion when irrigation water from impoundments are released during the dry season.
Kintanar, EIS of Development Projects 53
Water Quality: Water quality would tend to deteriorate near impoundments due to concentration and accumulation of nutrients from agricultural run-off. Also, as a result of increased fertilizer and pesticide use, nutrient accwnulation in water may decrease the present levels of dissolved oxygen. Despite the tidal barriers, salinity intrusion may also occur on the Bicol River and may also percolate to groundwater sources due to overpumping of water for irrigation and/or domestic use. Vegetation: Significant impacts on vegetation involve the loss of mangrove swamps near San Miguel Bay. Some 300 kilometers of secondary vegetation arc also expected to be committed for the construction of new roads. Te"estrial L1[e: Loss of mangrove habitat connotes the loss of terrestrial fauna, notably the Rufus hornbill. Rodents are expected to increase in number in agricultural fields near irrigation levees. Aquatic Life: Deterioration of water quality from nutrient accwnulation usually results in fish kills. Bicol River would experience a reduction in fish diversity. Brackishwater species, especially the migratory ones, would be eliminated by the tidal barriers. Salinity control, however, would permit the pen culture of freshwater species. Marshlands and wetlands which are potential fl.sh habitat would be irreversibly corrunitted for agricultural use, hence, limiting fish areas.
2. Effects on the Socio-Economic Environment: Land Use: More areas would be devoted to agricultural production as a result of irrigation and reclamation of swamplands. Human settlements are expected to increase as a result of development; thus, increases in urban lands are likely to occur. Income: The Basin per capita income is expected to improve significantly with improved and intensified agril~ultural activities. Income would be equally distributed enabling the public sector to widen investments in other business endeavors. This would tend to improve the people's life-styles and standard of living. Employment: The projects envisioned for the Basin would expand employment opportunities for the residents. The working class is expected to grow and improve steadily as a result of development. Health: The health of the Basin populace is to be protected and safe. guarded by the integrated health and nutrition program. Disease vectors are only expected to increase in see-page areas along irrigation canals. The domestic water supply project would assure improved sanitation and hygiene. Population/demography: With the onset of progress, immigration wiH result in anticipated changes in demography. The influx of settlers would create greater competition and demands for more resources.
ltaDIIC1iona National Academy of Scieace
C. AJtematives
No Project: The "no project" alternative would avoid all the ad...ene effects at the expense of the Basin progress. Non-implementation of the de...elopment projects would entail a future of poverty, unemployment and social unrest among the residents. Deltzy Project: The delay of the propo!!ed projects would allow the further deterioration of the current socio-economic condition in the area. It would also mean an increase in the final cost of the project due to increased prices of construction materials which would ultimately result in the delay of potential benefits. Different Projects to Achieve Same Goal: Unless alternative projects can be identified feasible and would achieve the same goal with lesser adverse effects and more beneficial effects, no further alternative can be considered.
D. Conclusions and Recorrunendations
Findings of the study indicate that the maximum potential benefits may not be fully derived due to the adverse environmental consequences of the proposed projects. The following recommendations are suggested:
I ) Environmental monitoring of project activities is necessary to maintain and/or improve the ecological and socio-economic condition. It should involve the participation of inter-agencies, especially the Regional Offices in Bicol.
2) The BRBDP as lead agency should launch an infonn~!!~~ ~diiipaign about cumulativef~<!v~Cr~e ~f!e~~~ of pesticides and proper disposal of solid and 1iquid wastes.
3) Mitigation measures for adverse environmental effects have been identified and should form the basis of an immediate action plan.
4) Vegetation/wildlife inventory and censusing should be done comprehensively in order to ~ertain the existing ecological balance needed to formulate an effective environmental resource management and conservation.
5) Specific plans for remedial! measures should be carried out and integrated into de'Velopment plans of the projt:et.
6) Project construction phase should, as much as possible, limit destruc· tion of aquatic and wildlife habitat.
7) Multi-sectoral efforts of the BRB program should include environmental awareness and emphasize the balance between development and environment.
8) The proposed projects should be implemented without delay upon assurance that environmental protectiOn •will be accomplished and realized as part of the over-all project sdtsne.
Kintanar, EIS of Development Projects
The Southern Negros Geothennal Project
Palinpinon I. Sununary of EIA
A. Overview of Project
55
The Southern Negros Geothermal Project (SNGP) is an electric powergeneration project utilizing geothermal energy from wells drilled in the Puhagan (112.5 MWe) and Nasuji..Sogongon (110 MWe) geothermal fields of Palinpinon, Negros Oriental.
The 3 x 37.5 MWe power plant in Puhagan is targeted for start-up in 1983. Another 2 x 55 MWepowerplant in Nasuji-Songongon is targeted for 1985, project· ing a total of 222.5 MWe in 5 years. This projected addition to the existing bulk electric power supply of Negros Island is expected to meet its electric power needs for the next 5-10 years with any spare capacity intended for the neighboring Cebu Island, should there be a need to export power.
A comparison of bulk electric power development alternatives for Negros (Table S-1) shows that the SNGP is the most attractive alternative in consonance with regional development goals to accelerate industrialization of Negros Oriental and the rest of Region VII.
B. Significant Findings, Conclusions and Recommendations
This environmental impact assessment of SNGP has identified and evaluated some neg~tiv~ environmental impacts associated with the various project phases. Corresponding preventive, mitigating and or monitoring measwes are recommended (Table S-2).
In the evaluation of negative impacts, those associated with Phase IV-Well Testing, and Phase III-Deep Drilling were rated fust and second, respectively, in relative importance. For the duration of these two phases, geothermal effluents containing toxic gases, ions, salts and heat are released freely into the environment. Moreover, civil earthworks in connection with road construction and drill pad preparations could result in devegetation and soil erosion with far more serious environmental consequences. Therefore, certain chemical and physical environmental standards would probably be exceeded during these phases.
During the electrical generation phase, geothermal waste water and vapor condensate will be reinjected back into the reservoir. This process would minimize the adverse envirorunental effects of geothermal effluents, as observed in the MakBan Geothermal Project. However, the power plant and related facilities such as collecting and transmission pipelines, cooling towers and electric cwrent trans· mission and distribution lines will become permanent features of the landscape.
Environmental impacts during the Reconnaissance and Detailed Exploration phases are least significant and are limited to unavoidable localized clearings, soil removal and compaction, dewgetation and alteration in land use at the site. Identification of positive and negative impacts and corresponding management measures
Table S-1. Summary or comparison of bulk electric power development alternative for Negros
A ltematives
l.SNGP
Cost
Approximately ?1.6B for 222.5 M.We installed capacity by 1985
Benefits
o The provision of abundant, relatively cheap electric power to the area will: - spur economic
activity accelerate industrialization
-· genetate more employment
- improve quality 0 r life thru arti· fkial light, domestic water supply and other conveniences and amenities dependent on electric power
o Equivalent lin-ported oil savings of at least 2.02 million barrels a year worth S78.5 Million or 1."'613.3 Million will be realized. (Velasco, 1980)
J:.'nvirmJmental!mpact
Please see Table S-2 and S-3
Remarks
Most attractive alternative in consonance with regional deve-lopment goals.
Table S-1 Continued
Alter1111tives Cost
2. No Power Project None
3. Delay of Project Cost .,.,ill escalate at the estimated rate of inflatioll of 1 0% annually
4.Upgrudlng of exi5t· lng power generating facilities
5_ Additional oil-fired power plant
6. Coal-fired plants
Dependent on how much upgrading is required
An equivalent installed capacity to the SNGP (222.5 :\{We) will cost approximately I"81JM (using General Santos Power Plant cost estimates). This is equivalent to 2.02 Million barrels of oil/ year valued at S 78.5 Million or 1"6133 Million 1980)
(Velasco,
Approximately Pl.4 B for 222.5 MWe installed capacity (using the
Benefits
None
Same as SNGP alternative, but the onset will be correspondingly delayed.
Significant savings from improved and more cffi· cient power generation and delivery
Same as SNGP except that it will mean more importation and depen
dentt! on foreign sources of oil.
Same as SNGP: would decrease dependence of Negros on fuel oil
Environmentallmpact Re1111lrks
None Status quo
Same as SNGP alternative but onset is correspondingly delayed.
Some i.mprovemet~t over present situation due to more e ffieient opera· tions but negative im· pact from pollution will increase if power output is increased
Greater oil pollution than a geothermal projecl
Even greater pollution than oil-tires plant and greater overall environ-
:-o;o compelling reason to delay project
This alone is insuffi· cient for planned development and would result in the continued dependence on imported fuel oil
L~:ss attractive because of additional intportation of fuel rcq uiring foreign exchange outlay equivalent to about Sl9.4M annually
Cannot be realized immediately and completely since mined coal
Table S-1 Continued
A /tenlllttves
7. Hydro-electric Power Plant
8. Nuclear Power Plant
Cott
Calaca, Batangas coalrued power plant estl· mates)
Approximately P' 1.38 for 222.5 MWe installed capacity (using the Magat Hydro Plant cost estimated)
The 620 MW Nuclear Power Plant in Bagac, Bataan otiginally estimated to cost S 1.1 B or !"8.58 B wW now cost $1.8 8 or P 14 B because of the delay and additional safety features (lbana, 1980)
Bene]lls
Same as SNGP. would lower the demand for fuel oU
Would provide suffi· cicnt electric power with its concommitant socio-economic effects but would still depend on imported uranium for fuel
Environmental Impact
mental impact than SNGI" considering the entire fuel cycle of ntining, transporting and utiliza,~rion of coal as fuel.
Would submefl',e a lazge illea of land and water which would otherwise be available for other uses.
Needs special radioactive waste disposal system and manageme.Jt ; with adverse environmental impact considerin.g the total fuel cycle from mining, procesmtg, transporting utilization to radioactive waste disposal
Remarks
in the country is still in short supply. Also, the coal-fued plant would compete with other coal-fired plants and Industrial plants converting from oil-to· coal for both local and imported coal supply (Bomasang, 1 980)
No suitable river system for large hydro-electric power except perhaps the llog-Hilabangan River basin in Neg~os Occidental which has a drainage area of 1945 kJn2
Not enough demand for electric power in the area anticipated in the next 1 S years to warrant nuclear power development.
f-n
"'
Table s-2. Negative environmental impacts and environmental management measures associated with the various phases of SNGP
Proj«t PhtUe
I. ReconEUdsance
II. Detailed Exploration
N~gtztiv~ Environmmtlll lmptztts
Umlted localized devegetation from trail and line clearing
Civil earthworks devegetation Soil erosion Land alteration No be Aesthetic lmpacU from presence of construction equipment and facilities Short·term river contamination with mud and drilling chemicals from !hallow ex· ploratory drilling activities Socio-economic impacts arls· ing from influx of strangers and above impacts
Relativ~ /mportllnu of lmPilets:
1 = Grutett S = Lutt
5
4
Environment« MtzNJgement Mu~Uret
None required
o Consideration of environ· mental inputs In selection of exploration sites. road routes civil works spoil dump sites, location of sumps
o Coordination of Drilling Group whh Enviro~n~ Staff regarding downhole of kerosene, diesel chromium and other toxic compounds for driDing
o Construction of sump ponds with oiJ traps for containment of drilling waste
o Discriminated fencing and sta· bilization of sump perimeter
o Stabilization/Reforestation of unstable slopes or probable landslide areas
o Regular monitoring of enViron· mental (i.e. quality of river systems and other water bodies
Table S-2 Continued
Project Phose
III. Deep Drilling
Negative Em•ironmemallmpacts
Same nature of impa~.;ts as in Phase 11 but of greater magnitude anr.llonger duration
Re!atiJ•e lmportaii CC of Impacts:
1 = Greatest 5 = Least
2
Em•ironmenta/ Measures
likely to be affected by drilling al.'tivities) and socioeconomic para.rnetcr s
o Implementation of a welldirected information program
o Same as in Phase II except that environmental monitoring should be more comprehensive, more detailed and should consider long-term consequen· ccs of civil work and drilling activi tics/progrlilll
Kinta.nar, EIS of Development Projects 61
was also done for each module or environmental component considered for this EJS (Table S-3).
If the probable long·term socio-economic benefits of SNGP are balanced againsts its limited negative environmental impacts (Table S4), the benefits will far outweigh the risk of environmental degradation. There are also adequate man· agement measures available to keep adverse environmental impacts to within acceptable levels. Moreover, monitoring activities are being w1dertaken to serve as an early warning device of impending environmental problems.
Concluding Remarks
The ElS partakes of a fuU disclosure document which provides information on both the positive and negative en virorunental effects of a proposed action or project. The ultimate aim is to include this analysis in the initial stages of the planning of any project which significantly affects the quality of the environment, so that the final decision on whether to go ahead with the project will depend not only on conventional tcclmical feasibility and economic viability st udies but also on the long term and secondary and tertiary impacts on the physicO·Chemical, biological, cultural and socio·economic environment.
In the Philippines, some of the problems related to the proper implemcn· ration of an EIA/EIS system are:
1) lack of appropriate S & T specialists to tmdertake baselirlc studies and monitor the environmental parameters
2) lack of equipment and instruments to make the baseline and monitoring measurements
3) lack of fmanciaJ resources to undertake a thorough environmental impact assessment
4) lack of experienced EIA/EJS Experts to prepare docwnents 5) undue interference in the EIS system by way of exemption frcm
coverage 6) non-compliance of project proponents and relevant agencies to the law
and NEPC rules and regulations on EIA/EIS. To show the breadth ofEIA/ElS, a partial list of Regulatory Agencies respon
sible for some aspect of environmental protection is shown in Fig. 14.
References
Canter. L. 1977. Environmentallrnpact Assessment. 3 31 pp. McGraw-Hill Book Co., New York. Inter-Agency Committee for Ecological Studies. 1978. Environmental Assessment of the
Darangay Water Project 60 pp. Inter-Agency Committee for Ecological Studies. 1978. Environmental Assessment of the Bicol
River Basin Development Projects. Vol. 1-132 pp. & Il-233pp. National Environmental Protection Cotmcil. 1981. Philippine Enviromnental Law - Comments
& Materials 530 pp. PNOC Environmental Staff. 1981. The Southern Negros Geothermal Project - Palinpinon 1 -
An Environmental Impact Statement. Vol. f-405 pp. , Vol. 11-263 pp. National Environmental Protection Cotmcil 1983. Environmental Impact Assessment Hand
book. 242 pp.
Table s-3. GNGP impacts and management measures a.uociated with the various EIS modules
I. LAND
PHYSICAL CHEMICAL
SOIL
TERRESTRIAL BIOLOGY
FLORA
lmpocts
Soil erosion Soil contamination by toxic chemicals (i.e. As, B, Li, Cl)
ground subsidence increased seismicity and possible earthquakes
habitat destruction resulting from nonselective removal of vegetation during civil works vegetation changes could result in migration of species from the project area: appearance of new species; possible elimination of less adaptable animal species
vegetation removal resulting In a) resource extraction b) successional vegetation of cleared areas c) successional change of community com·
position towards undesirable ftod species d) change in land use due to change in
conununity composition
Mallllgement Measures
o landscaping, planting of grass and sluubs
o regulation of discharging wells and amount of discharge
o construction of adobe·lined settling ponds and channels
o reinjection o monitoring areas for evidence of ground
subsidence and considering this factor in deciding locations of SNGP facilities
o monitor seismicity as an early warning deYice
o continuous inventory of animal com· position population to monitor any changes In the community prohibitions of incliscriminate wildlife bunting
o declare the geothermal reservation as a wildlife preservation area
o control of the destruction of exist· ing plant cover a) checker-board clearing pattern use
when preparing weU sites b) splfin8 of vegetation along streams
to filter run-offs c) avoid disturbance of areas with
Table S-3 Continued
lmpttct
e) change in climate f) loss of biotic regulation of important
environmental processes and rela-tionships - evapotranspiration and water storage
with associated floods; - disruption in flow of mineral cycling
increase in soU erosion - potential land slides due to loss of
binding vegetation euthropication of water bodies receiving the erodod particles and leached nutrients
- aesthetic effects {loss of scenic vistas and unique habitats
o trampling of vegetation resulting in its temporary stunted growth of leaves
o clogging of stomata due to generated dust . reduction of light penetration due to increased reflection surfaces and opaqueness of dust particles
o decrease in soil compaction leading to soil aeration which in turn leads to a decrease in aerobic microflora popula· tion and growth of plants in the vicinity of weUs due to reduction in re~r piration
o introduction of new microsites for plant invasioo due to exposure of slopes
Mantzgement MetUUI'el
unfavorable slope, texture, and water content
d) control of illegal logging o re-vegetation of cleared sites after
project activity a) planting of indigenous tree species b) planting of economically important
tree species o Adoption of protective practices such as
contour cultivation and minimum tillage on cultivated areas
o afforestation of roadsides, residential areas, and the periphery of agricultural areas
o a special study on the local meteorological profile so that permanent facilities may be locwed to augment dispersion of geothermal air pollutants
o sufficient collection ponds as a contingency against reinjection failure
c monitoring of geothermally induced changes: a) the use of biological indicaton b) meteorologic changes c) hydrologic changes
Table S-3 Continued
IL TiiE WATER
A. HYDROLOGY OGRAPHY
B. WATER QUALITY
AND OCEAN-
Impact
o introduction of toxic and saUne effluents and H2S emissions with subsequent contamination of flora remlting in reduction of vegetation growth and death of flora
o reduction of plant transpiration, lowering of mineral and water uptake due to additional load of water vapor
o reduction of growth or death of some flora, enhanced growth of blue-green algae due to atmospheric thermal stress
o introduction of new habitat for resistant algal populations (temporary pools) brought about by steam discharge
o reduction of growth or death of vege· tation due to drilling mud contamination in immediate vicinity of well
o increased river discharge o contamination of surface and ground
water
o contamination of groundwater, river and sea water and sediments by toxic components of geothelT!lal effluents and drilling fluids
o siltation, increased turbidity
Mant~gement Measures
o formulation and implementation of a watershed management program
o reinjection o monitoring river and groundwater
o drilling waste management a) construction of sump ponds large
enough to contain the fluids and long enough to hold the fluids to allow sufficient sedimentation of mud components and evaporation
Table S-3 Continued
C. AQUATIC BIOLOGY (FRESH· WATER AND MARINE BIOLOGY)
Impact
o decrease in light penetration and consequently in photosynthetic activity of phytoplankton and benthic flora due to increased turbidity
o smothering/suffocation or death of benthos and nektonic species (i.e. fishes )
MatUZgement Met~sures
of toxic hydrocarbon fraction of diesel
b) use of rice straw, dr y bagasse or other improvised oil separators or slcimmers in sump ponds
c) chemical analysis of the drilling fluid and regular monitoring of groundwater, river and sea water for con· centration of toxic components; compliance to water quality stan· datds
o geothennal wastewater management a) reinjection b) construction of settling ponds and
channels c) regulation of discharge rate and
number of discharging weUs d) regular monitoring of geothennal
discharges for toxic ions along the river and measurement of river discharges; compliance to water quality standard
o biannual monitoring of river benthic fauna as an index of pollution
o biannual chemical analysis of biological S.Jmplcs (i.e. shells, crabs, shrimps, fishes ) for concentrations of toxic ions (Hg, As, Cd, Cr, etc.)
Table S-3 Continued
lm{Xlct
due to siltation and high amount of suspended solids
o diSIUption of feeding reproduction and other physiological processes due to high amounts of suspended solids and change in chemical characteristic! of water
o decrease/ loss of established benthic communities which may be succeeded by the establishment of new ones (towards undesirable ones such as worms) brought about by a change in the substratum and/or water quality
o temporary increase in plankton population resuhing ftom increa~ nutrient load leached from land
o eutrophication of river water due to excessive Ultation and high load of leached nutrient
o uptake/bioaccumulation of some toxic ions as Hg, As, Cd, Cr leading to ditruption of physiological processes, morphological modifications or even death and endangering man If contaminated species are used as food
o tainting of organisms due to oil uptake, smothering/suffocation due to oil coating; other sublethal and letl\al toxic effects resulting in disruption of physiological or behavioral activities or death
Maflllgement Mearures
o Maintenance of toxic ion concentratiom in river and sea water and sedlment within NPCC standards
o selection of pollution indicato.r species through uptake/tolerance studies
o regular monitoring of drilling and geothermal discharges, toxic components along the river and sea (i.e. before irrigation diversion)
o Measurement of sedimentation rates in river and sea
o cooling of geothermal effiuents in the sump pond to a temperature u close to the ambient as possible before discharging to the environment reinjection of geothermal fluids
Table S-3 Continued
UI.TIIE AIR A. METEOROLOGY
B. AIR QUALITY
lmpoct
o thennal stress on river organisms either resulting in enhanced growth and reproduction of some species or decreased physiological activities/death of other species par1icularly the bonthos
o oxidation of emitted H2S to H2S04 could bring about occasional acid uins, thus u endaD,ering terrestrial and aquatic life and various facWties of the site
o emission of C02 to atmosphere may gradually adversely affect the microclimate
o the~mal streu from release of hot steam from the well into the atmo .. pbere which could eventually result in death of te~restrial life, particularly plants in immediate vicinity of wells
o exposure to H2S emimons which could cause undesiJable effects on humans ranging from irritation of respiratory tract (1 ppm) to death (1000 ppm)
o exposwe to other potentially harmful emissions such as mercury and arsenic compounds, radioactive elements, rock dust and silica·laden spray, endan&erin& humans and lower fonns of life
o consideration of dominant wind direc· tion in selection of lites
o monitoring of rain water qualit y for Indications of pollution
o updatins of meteorological data
o regular rnonitorinJ of pteOUS emissions particulady n 2s levels around the wells and wind direction
o compliance with air quality standards o provision of good ventilation in build·
inp o burning of H2S gas to form S04 which is
then scJUbbed with cooling tower water o reinjection of steam o homontal weU discharge in a controlled
direction
Table S-3 Continued
C. NOISE
IV.TIIE PEOPLE SOCIO-FCONOMIC
Impact
<> exposure to 1\igh C02 concentrations excessive noise whic\t could cause wildlife migration and adversely affect laborers by causing temporary partial hearing losses and more serious physiological and psy· cholog!cal effects
., more job opportunities/increasoo employment from a) project site hiring during development phase, and b) Dumaguete-Sibulan area due to availability of relatively cheap geothermal electric power
o rural electrification which could a) encourage latge scale expansion of establislunent of primary-based industries such as cottage and handicraft industries b) provided electric lights and refrigeration services which could have secondary effects in agricultural-fisheries production
o acceleration of p opulation trend ; increase in population density
o raise in income level in Southern Negros region: earnings from industrial em-
Management Measures
c incorporating physical separation and should barriers in plant designs to limit occupational exposure of plant workers to excessive noise
o monitoring of noise levels in vicinity of project site
o consulting land use map in planning compatibility of noise with land utilization
o use of silencers/ mufflers in wells, provi-sions of ear plugs or muffs to workers
Implementation of a well directed information program (i.e. to assuage counteract fear of people against fire hazards, crop damage and influx of strangers - the 3 categories in perception and attitude survey which elicited negative responses)
Table S.3 Continued
Impacts
ployment will be a significant addi· tion to rural income which are quite low (1976 SUlVey) because of relatively low productivity of mono-culture agri· cultural operations in maize and coconut farms
o increase in hotel and recreational facili· o ties/booster tourism in region improve·
ment/provision of infrastructure facilities such as roads, ports and airports, waterworks system
o indire<.'tly help in improvement of health conditions of Southern Negros over the next 1·15 years, with the provision of clean and safe domestic water supply thru pumps powered by cheap electricity
<.: increase in social services o improvement of peace and order situa·
tion thTU expected increase in employment and incomes
o general ·unprovement of living/worlting conditions
Management Measures
Table S-4. Positive and negative impacts of the Southern Negros Geothermal Project
Impacts
POSITIVE IMPACTS
Minimum benefits by term Increased economic activl·
tics lncrca~~ed income Accelerated lndustrializa·
tion Increased employment Increased foreign exchange savings equivalent to oil fuel displaced
Social benefits/Over-all im· provement quality of life in terms of. Safe domestic water supply and environmental sanitation by provision of electric power for water pumps electricity dependent amenities and convenience such as ractios, TV, refrigerators and 24-S lighting
Pro/xzbUity of Occurrence
Highly probable
Highly probable
Provision by the government of other requisites for increasing economic activity 3Uch as appropriate incentives, infrastructures and other supporting services to encour38e lndusttiallzation along desired lines.
Provisions by the government of a companion development project for the provision of domestic water supply.
Remarks
On balance, the socio-economic benefits far outweigh the risk of envi.ronmentaJ degradation, hu· man toxicity and possible coonomic losses should the project fall.
Table S-4 Continued
Impact~
NEGATIVE IMP ACTS
Air pollution from toxic gases such as hydrogen sulfide and mercury
Soil and water pollution from oil and toxic ions such as arsenic, chromium, boron, lithium and chloride from drilling/geothermal effluent waste water
Noise
Probability of Occurrence
Highly probable
Highly probable
Highly probable
Ma1111gement Musures
o Regular monitoring of air quality to ensure that ambient conoentrations aie kept below threshold value limits and environmental standards
o Ensuring sufficiency of physical separation/distance between points of zelease of toxic gases and the people working In the geothermal facility or in neighboring human settlements
o Controlled discharge and temporary collection of wastewater .in settling ponds with oil traps
o Adoption of a rei.njection strategy of wastewater disposal
o Regular monitoring of sediment and water quality to ensure that toxic components of waste water are within environmental standards
o Provision of silencers and other noise reducing infrastructures
o Regular monitoring of noise levels to ensure that these are within environmental standards
Despite the greater number or nqatJve than positive impacts enumerated here, the balance stiD favors the beneflta and advantages over the costs and disadvantages.
Table S-4 Continued
Impacts
Aesthetic Impect
Ground subsidence over the reser· voir
Increased seismicity and/or earthquake
Probability of Occurrence
Highly probable
Low to moderate
Low to moderate
Management Meosures
Choice of proper architectural design and avoidance of visually prominent locations for siting of geothennal facilities
·:) Adoption of a reinjection strategy to reduce net outflow of mass, thereby reducing risk of subsidence
o Construction of buildings and other heavy structures on solid ground foundation Monitoring eeisrnicity as an early warning system.
R emarks
Besides the power plant and cooling towers. kilometers of collecting and transmission pipelines arc nccc~~ary concomittants of a geothermal power project in addition to the usual power plant, electric distribution and transmission lino::s common to all power projects. However from experience in Tiwi and Mak·Ban, these arc aesthetically acceptable to the local people.
[ irl ()
r:t. 0 = ..
Kintanar, EIS of Develo pment Projects 73
Fig. 14. Partial Listing of Regulatory Agencies Responsible for Environmental Protection.
Agency
DFD
BFAR
BMGS
BL
NPCC
NEPC
HSRC
LLDA
MPWH
MTC
BPI
BAI
FPA
NM
MOH
PTA
Regulatory Aspect{s)
Land Classification/ Regulation of Forest Lands & Products, including timber, plants and animals, sawmills, veneer/ plywood mills and wood processing planh ; and, grazing lands
Fishing Privileges; Licensing of small Fishing Vessels ; and, Fishpond development
Mining Rights
Classification/Regulation of Public Lands (Non-Forest)
AJI/W ater Quality Noise Pollution
EIS System
Land Use Compatibility
Project/Program clearance relative to Pollution & Eoological Balance in Laguna de Bay Watershed Area
National Building Code
Public Land & Water Transportation Certification
Pests&: Diseases
Import/Export of Animals
Pesticides & Fertilizers
Export of National Cultural Treasures; Aichaeologlcai/H!storlcal Excavation
Sanitation/Inspection & Regulation of Food and Drugs
Tourism Development/Operation
Legal Basis
P.D. No. 706, as amended
P.D. 704
P.D. Nos. 463, as amended &: P.D. 1654
Act No. 218, CA Act No. 141 , as amended
P.D. 984, as amended & P.D. 96
P.D. 1586
P.D. 1396
R.A. No. 4850 & P.D. 813
P.D. 1096
P.D Nos. 1057 &: 1587
P.D. !587
P.D. 1587
P.D. 1144
P.D. 1587 P.D. 200
P.O. 858
P.D. 189, as amended
74
Fig. 14 Continued
PCG
PAF.X:
Transactions National Academy of Science
Rqultllory AlfNCl(l)
Control/Regulation of Pu.enger Merchant cl Laqe Fishing Ves.,els; and Marine Pollution
Import/Export of Atomic:: EneJBY Facilities; Radioactive Matedah cl Instruments
R.A. 5173, P.D. Nos. 600,601 cl 602
P.D. 1206