A. THE SUBJECT APPLICATIONS FOR WATER PERMITS SHALL AND WILL ADVERSELY AFFECT THE ECOLOGICAL BALANCE OF LAGUNA LAKE.

B. THE SUBJECT APPLICATIONS FOR WATER PERMITS SHALL AND WILL ADVERSELY AFFECT THE AGRICULTURAL LANDS OF MAJAYJAY.

x x x x x x x x x

J. SINABAK SPRING, PATAK-PATAK SPRING AND MANGULILA SPRING ARE EXISTING GROUNDWATER SOURCES AND THERE IS NO WATER PERMIT FROM NWRB ATTACHED TO THE SUBJECT APPLICATIONS FOR WATER PERMITS AS REQUIRED UNDER THE IRR-LLDA.

K. THERE IS NO PROPER NOTICE TO THE BARANGAY CHAIRMAN WHERE PATAK-PATAK SPRING IS LOCATED AS THE LATTER IS NOT SITUATED IN BRGY. AMONOY BUT IN BRGY. BALAYONG, MAJAYJAY, LAGUNA.

L. THE SUBJECT APPLICATIONS FOR WATER PERMITS WILL CAUSE ADVERSE EFFECT TO PUBLIC AND/OR PRIVATE INTEREST.

M. THE SUBJECT APPLICATIONS FOR WATER PERMITS WILL AFFECT THE PRESENT BRGY. WATER SYSTEM.

x x x x x x x x x

Q. THE APPLICATIONS FOR WATER PERMITS SHALL AND WILL PUT IN DANGER THE LIVES AND HEALTH OF THE PEOPLE OF MAJAYJAY AS THEY WERE MADE IN VIOLATION OF SECTION 13 OF THE IRR-LLDA WHICH PROVIDES THAT “NO CONSTRUCTION WORK OR PRIVATE SECTOR PROJECT SHALL COMMENCE UNTIL THE PLANS,

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SPECIFICATIONS AND IMPLEMENTING SCHEDULES ARE DULY APPROVED.”

1. It is of utmost importance to conduct the appropriate

ocular inspection of the location, source and natural flow of as well as

the agricultural lands and public and private interests affected by the

three (3) Springs subject matter of the questioned water permit

applications to enable the oppositors to establish the above-

enumerated grounds in their Opposition.

2. Similarly, there is a necessity to conduct an ocular

inspection to establish that the questioned water permit applications

were made in violation of Section 13 of this Honorable Office

Implementing Rules and Regulations (IRR) which provides that no

construction work or private sector project shall commence until

the plans and specifications for the diversion works, pump

structure, water measuring device and other required structures,

and the implementing schedules of construction are duly

approved by this Honorable Office.

3. The oppositors would like to manifest to this Honorable

Office that in gross and open violation of Section 13 of the IRR of this

Honorable Office and even while its questioned applications for water

permits are still pending for processing, the applicant has started and

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continues to make construction work for the excavation and laying of

water pipes in Majayjay, Laguna (Majayjay for short) for its intended

water distribution system which will put in danger the lives of the

people in Majayjay because the construction work was made without

approval by this Honorable Office of the aforesaid plans and

specifications and implementing schedules. Copies of the pictures of

the excavation and the laying of water pipes are hereto attached as

Annexes “A”, “B”, “C” and “D”, respectively.

4. For instance, it is reported that the water pipes being used

by the applicant are sub-standard water pipes for potable water and/or

water pipes not designed for distribution of potable water. Worse, the

water pipes were installed and joined in violation of the accepted

engineering practice for the installation and joining of such water

pipes as shown from the fact that installation of the water pipes was

made without the required sand cushion of at least six (6) inches of

sand beneath the water pipes and another six (6) inches of sand atop of

the water pipes.

5. Such kinds of construction works will certainly put in

danger the health and lives of the people as the materials for the sub-

standard water pipes and the irregular installation of the water pipes

will most likely absorb or seep into the water pipes the water or

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soil moisture outside of the water pipes, thereby contaminating

the potable water passing thru the water pipes.

6. In other words, the materials for the sub-standard water

pipes and the irregular installation and joining of the water pipes will

contaminate the potable water passing thru the water pipes which will

pose clear and present danger to the health and lives of the people of

Majayjay as the potable water will be used for drinking and cooking

of foods of the people of Majayjay. This clear and present danger to

the health and lives of the people of Majayjay can be prevented if this

Honorable Office will strictly implement the mandates of Section 13

of its IRR.

7. Accordingly, oppositors respectfully submit that the

appropriate ocular inspection must be made to accord due process of

law to them and to compel respect and compliance with the IRR of

this Honorable Office. This Honorable Office should not allow the

applicant to violate with impunity the IRR of this Honorable Office,

otherwise, it will render ineffective and inutile the powers granted by

law to this Honorable Office.

8. Section 13 of IRR of this Honorable Office is not mere

formality but it serves as a precautionary measure or safeguard to

protect the health and lives of the people who are supposed to be

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given water services by the applicant for water permit. In other

words, the lives of the consumers of a water system depend on the

strict implementation by this Honorable Office of the said approved

plans and specifications and implementing schedules for the intended

water distribution system. Thus, in order to protect the health and

lives of the people of Majayjay, the oppositors respectfully submit that

this Honorable Office should strictly enforce the mandates of Section

13 of its IRR especially considering the fact that the water permit

applications of the applicant are still pending for adjudication and

approval by this Honorable Office.

WHEREFORE, the oppositors most respectfully pray to this

Honorable Office that an ocular inspection be made on the location,

sources and natural flow of as well as the agricultural lands, public

and private interests affected by the three (3) Springs, Sinabak, Patak-

Patak and Mangulila Springs, subject matter of the instant applications

for water permit and an ocular inspection of the excavation and lay

outing of water pipes made by the applicant, including the water pipes

used therein.

Other reliefs just and equitable in the premises are likewise

prayed for.

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