The Role Of Private Sector In EIA, The RTNMC/CBNC Experience                           Presented By:          Jose S. Sare...
THE ROLE OF PRIVATE SECTOR IN EIA, THE RTNMC/CBNC EXPERIENCE1                                      Presented by:          ...
1.1    RTNMC/CBNC PROFILE AND HISTORYThe Rio Tuba Nickel Mining Corp. (RTNMC) is a Filipino-Japanese partnership that hasb...
economic development, environmental protection, pollution control, safety and health are itstop priority and the yardstick...
mechanical welding shops and hardware stores locally. This has given residents access tomuch needed commodities, which was...
•   To provide all the proposed data requests of both the consultants, the DENR and          host community residents/ sta...
Because of this unique characteristic, efforts have been made to ensure that this isprotected. It is in this premise that ...
Similarly, the EIA in 2000 for the HPP Complex followed the same process. While both EIAshad to undergo consultations, rev...
Supreme Court decided to deny with finality the petition and uphold DENR’s decision toissue the ECC to our HPP project. It...
In the RTNMC/CBNC EIA, communication lines were opened to the extent that conflictingparties have agreed to communicate an...
support and trust of communities within our impact areas, who are the most sensitivestakeholders of our project.Second, tr...
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Jose S. Saret, Senior Vice President (RTNMC)
Arturo T. Manto, Chief Environmental Officer (CBNC)

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  1. 1. The Role Of Private Sector In EIA, The RTNMC/CBNC Experience Presented By: Jose S. Saret, Senior Vice President (RTNMC) Arturo T. Manto, Chief Environmental Officer (CBNC)
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  3. 3. THE ROLE OF PRIVATE SECTOR IN EIA, THE RTNMC/CBNC EXPERIENCE1 Presented by: Jose S. Saret, Senior Vice President (RTNMC) Arturo T. Manto, Chief Environmental Officer (CBNC)I. INTRODUCTIONSimilar to most developing countries, the Philippines has to balance economic advancementneeded to support the basic needs of its increasing population on one hand, and conservingand protecting its declining natural resources on the other. To achieve this balance,Government through the Department of Environment and Natural Resources (DENR)developed and put in place the Environmental Impact Statement (EIS) System.The Philippines has about a quarter of century of experience in the implementation of its EISsystem, starting in 1977 through the formulation of the Presidential Decree (PD) 1151 or thePhilippine Environmental Policy. This was reinforced by the enactment of PD 1586 -Philippine EIS System in 1978. The implementation of the EIS system was strengthenedfurther by the issuance of its implementing rules and regulations (IRR) in 1979. Since then,the IRR have been amended several times and recently, with the approval of DENRAdministrative Order 2003-30. This new regulation further streamlines the EIS system by: • Providing a more detailed listing of projects that are within and outside of the scope of the EIS system based on project types and size; • Simplifying the requirements for securing an ECC by detailing the requirements of the different project types; and • Streamlining further the procedures for ECC application by detailing at which levels of authority can issue an ECC as well as setting time limits and allowing the automatic approval of projects, which have exceeded the allowable processing times.Other regulations have also been formulated to further support the implementation of theEIS system especially in providing additional guidelines and standards to gaugeenvironmental impacts notably, the Republic Act No. 8749 – Clean Air Act of 1999, RepublicAct No. 9275 – Clean Water Act, Republic Act No. 6969 – An Act to Control ToxicSubstances and Hazardous and Nuclear Wastes and Republic Act No. 9003 – EcologicalSolid Waste Management Act.Presidential Proclamation No. 2146 identified the major categories of EnvironmentallyCritical Projects (ECP) or those located in Environmentally Critical Areas (ECA) first definedin PD 1151. Specifically, Section 4 states that “no person, partnership or corporation shallundertake or operate any in part such declared ECP or project within an ECA without firstsecuring an ECC”. Major resource extractive industries including major mining projects werethen classified as ECP. Thus, the Rio Tuba Nickel Mining Corporation (RTNMC) is amongthe mining companies that have undergone the EIA process when it applied for thecontinuous use of its 110 mining claims and conversion to MPSA in 1996 and thedevelopment of the HPP project in 2000.1 Paper written for the Forum on Environmental Impact Assessment in the Philippines: Roads Taken. LessonsLearned (February 11, 2005 Manila, Philippines) in collaboration with MLND Catalon and MD Manaog. 1
  4. 4. 1.1 RTNMC/CBNC PROFILE AND HISTORYThe Rio Tuba Nickel Mining Corp. (RTNMC) is a Filipino-Japanese partnership that hasbeen in operation since 1977. The company is engaged in the mining, production, andexport shipment of beneficiated nickel silicate ore to Japan. The mining operations involvethe extraction of lateritic nickel ore deposits by surface mining method. The RTNMCminesite and hydrometallurgical process plant (HPP) complex is located in Barangay RioTuba, Municipality of Bataraza, Province of Palawan.Since the start of the mining operations in 1977, RTNMC has exported saprolite ore to aJapanese ferronickel producer. Low-grade ore and laterite, which are not used as rawmaterial for ferronickel production, are separated from saprolite ore. This low-grade ore isnot exported to Japan for refining and commercial use since the export and refining processis not economically viable. The low-grade ore is stockpiled at the mine area according tonickel content. At present, the volume of stockpiled low-grade ore amounts toapproximately 20 million dry metric tons (DMT).In 1996, an Environmental Impact Assessment (EIA) was conducted for the renewal ofRTNMC’s 990-ha Nickel Mining Claims and the conversion of the mining lease contract intoa Mineral Production Sharing Agreement (MPSA), as well as for its continued operations.The Environmental Compliance Certificate (ECC) was granted in late 1997.Since 1986 however, extensive metallurgical test works for the extraction and recovery ofnickel and cobalt from the low-grade nickel ores were conducted. The tests indicated thatnickel and cobalt could be extracted from the low-grade ores by hydrometallurgical process.Subsequently, the process was modified and a pre-feasibility study was carried out, whichconcluded that a process to produce mixed sulfide from the low-grade ore is the mostattractive and feasible option.The recent increase in international nickel prices as a result of a tight nickel supplyworldwide has resulted in RTNMC’s venture into nickel ore processing. Thus, theHydrometallurgical Processing Plant (HPP) Complex Project was drawn up. The HPPproject is owned and operated by the Coral Bay Nickel Mining Corporation (CBNC), which isa 90% foreign-owned corporation consisting of Sumitomo Metal Mining, Sojitz, Mitsui andRTNMC.The HPP project is intended to enhance resource utilization capability by processing theexisting low-grade nickel ores currently stored in open dumpsites within its property, whichfor sometime, was regarded as a waste stream that had to be disposed of in areas thatcould have been better utilized rather than as a dumpsite.To realize this project, an EIA was conducted starting in November of 2000 and concludedwith the issuance of its ECC on July of 2002. Despite the issuance of the ECC, other EIA –related activities relative to legal concerns were conducted.1.2 ENVIRONMENTAL, HEALTH AND SAFETYRTNMC/CBNC espouses the principle of sustainable development. Its operation is hingedon a pro-people, pro-community and pro-environment orientation and goals. Socio- 2
  5. 5. economic development, environmental protection, pollution control, safety and health are itstop priority and the yardstick to measure its performance and successes.For the period 1991-2004, RTNMC had invested almost PhP 135M for environmentalprotection. This includes construction and maintenance of soil erosion control measures,dust suppression, reforestation among others.Our mine rehabilitation and reforestationefforts over the years have resulted in the reforestation of some 203has. of mined-out areasand some 132has outside of these.Of the total cost for construction and development of the HPP project, more than PhP 900Mwas used for health, safety and environmental concerns while approximately PhP 230Mannually is allotted for such concerns during the projected 20-year operation of the plant.The Contingent Liability and Rehabilitation Fund (CLRF) for the HPP project, which has thesame purpose as the Environmental Guarantee Fund (EGF) has been established anddeposited in the Development Bank of the Philippines (DBP). This amounts to PhP5.25MConsequently, RTNMC has been the recipient of various awards because of its strictadvocacy of these principles. Among our notable awards are: • Presidential Mineral Industry Environmental Awards – Highest Award (2001-2002) • PMIEA – Titanium Award (1997-1998) • PMIEA – Platinum Award (1998-1999) • PMIEA – Platinum Award (1999-2000) • Certificate of Recognition (Adopt a Tree-Adopt a Mining Forest Movement – 1992 - 1996) • Adopt a Tree-Adopt a Mining Forest Movement - 3rd Runner Up (1998-1999) • Plaque of Recognition Adopt a Tree-Adopt a Mining Forest Movement (1999-2000) • Safest Surface Mine, 1st Place (1983-1985, 1986-1988, 1992-1996, 1997-2000, 2002-2003, 2004) • Most Improved Safety Record, 1st Place (1983-1985, 1986-1988, 1997-1998, 1999- 2000)CBNC has likewise received a Safety Award for its 3 million man-hours without lost time foraccidents during the construction period of the HPP project, which started in July 2002 untilAugust 2004.1.4 SOCIO-ECONOMIC CONTRIBUTIONSThe RTNMC operations in Barangay Rio Tuba have brought about significant economic andsocial benefits to the community. The company provides employment for residents of thehost barangay and nearby areas. It presently employs 367 regular employees, 160 casualemployees, and 152 contractual employees. The company’s operations has stimulatedlocal business with annual purchases of the company and its employees amounting to morethan ten million pesos worth of locally produced products from local residents within thecommunity.The company’s presence has encouraged the establishment of various commercialestablishments particularly, pharmacies, gasoline stations, rice mills, an ice plant, 3
  6. 6. mechanical welding shops and hardware stores locally. This has given residents access tomuch needed commodities, which was not present before the RTNMC operations.Between 1991-2003, RTNMC had invested over PhP 50M for community developmentalone. The company has provided valuable community services such as the establishmentof a hospital with pharmacy, schools, gymnasium and other recreational facilities, markets, aCatholic church, a mosque for the Muslim community, communal latrines, among others. Ithas contributed to the development of transportation and basic accessibility within the areathrough the construction and maintenance of about 51 kms. of farm to market roads withinthe community and neighboring barangays.With the establishment of the HPP complex, additional employment opportunities weregenerated. The project is also expected to contribute further to the local economy dueincreased commercial activities.In addition, the HPP project enhanced the existing social development programs. For this,RTNMC/CBNC have committed more than PhP 90M for their five-year program, which willdirectly benefit ten (10) barangays including IPs.The HPP Project was one of the largest investments in the country in 2002 with a projectcost of more than US$180M. The expected income generated from its operation wouldaccrue to the local, provincial and national levels thus, it is expected to fulfill strategiceconomic goals for the country.II. EIS SYSTEM AND RTNMC/CBNC EIA EXPERIENCE2.1 ROLE OF THE PROPONENTIn the past, project proponents/developers were more inclined to be observers in the EIAprocess, just waiting in the background for the issuance of their ECCs. In December 1996,the DENR Administrative Order 96-37 was approved, which adopted and institutionalizedthe participatory and community-based EIA approach. This regulation called for the activeparticipation of the proponents and other stakeholders in the EIA activities.The participatory and community-based EIA approach allows the the stakeholders to beinformed on the details and the possible effects of the project so that they can determinewhat components in the environment the EIA should look into and what appropriatemitigation measures can be adopted. The project proponent is, in itself, an importantstakeholder since its operations may adversely affect not only the host communities, butalso even its workers that may affect the viability of the project.The project proponent is an active participant in the EIA process. First and foremost, theyshoulder the financial responsibility for the conduct and review of the EIA. Second, theproponent must also be able to articulate intelligently the plans and coordinate credibly withvarious sectors including the DENR. Third, there are administrative and coordinating works,which is the responsibility of the project proponent in an EIA. It should be emphasized thatthis should be done by the proponent themselves since putting the responsibilities to otherparties, e.g. the environmental consultants, would contradict the third party assessment roleof the latter. Thus, the role or the deliverables of the project proponent in the EIA activitiesare: 4
  7. 7. • To provide all the proposed data requests of both the consultants, the DENR and host community residents/ stakeholders; • To facilitate and attend to the logistical requirements of any consultation requested; • To be available to respond and negotiate on issues concerning the details of the proposed project during any meeting/ consultation called relative to the project; • There are certain documents that the proponent should provide which are included in the final EIS e.g. Locational/Zoning Clearance, Water use permits, proofs of socials acceptability, etc. • Prior to and during the conduct of the EIA the project proponent should have and should continue to establish contact with stakeholders, initiate consultations with them and seek their approval of the project (a best case scenario). The reason for this is that the EIA will determine the level of awareness of the stakeholders about the project, the level of consultations conducted by the proponent with the stakeholders and the level of project support. A key element in the issuance of the ECC is the social acceptability of the project; • Initiate the establishment of the Environmental Monitoring Fund and/or Environmental Guarantee Fund as may be stipulated in the ECC; • Ensure that appropriate post-assessment monitoring and reporting are carried out as required and submit the reports to the EMB.Aside from this, the proponent must work to ensure that the project enjoys socialacceptability. For the project to become socially acceptable it must be: • Needed by the country and the host community; • The permits issued are legal and binding; • There was a clear, transparent and comprehensive process of consultation among various stakeholders; • The project is culturally acceptable; • The project has acceptable level of negative social impact that can be mitigated and which does not tragically divide the community; • The project has an acceptable level of negative environmental impact that can be mitigated that environmental risks are acceptable; • The proposed project presents benefits that will accrue to the country and to the host community in which the development is sustainable and not a boom bust type of activity.2.2 THE RTNMC/CBNC EIA EXPERIENCERTNMC/CBNC have fulfilled our role as project proponents. What therefore sets apart ourEIA experience from similar projects?The RTNMC Mine Site and CBNC HPP complex is located in the Province of Palawan,considered a frontier area owing to its abundant natural resources and the presence ofunique floral and faunal species. Studies have shown that plant and animals species foundin the province are not found in other areas of the Philippines. Aside from this, the studieshave revealed that species diversity and endemicity is high. 5
  8. 8. Because of this unique characteristic, efforts have been made to ensure that this isprotected. It is in this premise that the Republic Act 7611 or the Strategic EnvironmentalPlan (SEP) of Palawan was approved in 1992. The SEP seeks to ensure that the uniqueenvironment and natural resources of the province are protected, preserved and developedin a sustainable manner involving the participation of the different sectors of the societyincluding the indigenous peoples (IPs). The implementation of the SEP was formalizedthrough the creation of the Palawan Council for Sustainable Development (PCSD).Under the mandate of the PCSD, the proposed developments are evaluated whether theyconform to the SEP through the Environmental Critical Areas Network (ECAN). The ECAN isa graded system of protection and control of the various areas in the province comprisingthe terrestrial and marine components and tribal ancestral lands. These areas are classifiedas areas for strict protection (core zones); areas for restricted, controlled or traditional useareas (buffer zones) and multiple use areas.In order to implement the SEP, the ECAN zones have to be delineated through mappingand inventory. This is just however, the start of the process. Section 22 of PCSD ResolutionNo. 94-44 lays down the procedures for the preparation and declaration of the ECAN zoningplan. The procedure include: 1. Organization of a planning team in each municipality or city composed by the Planning and Development Coordinator, Municipal Environment Officer, CENRO, District Manager of the PCSD, and representatives from the private community; 2. Preparation by said planning team of the draft ECAN Zoning plan; 3. Presentation of the draft plan for public hearing in the locality; 4. Endorsement by the Sangguniang Bayan/Panglunsod and the Sangguniang Panlalawigan to the Council Staff; 5. Endorsement by the Council Staff to the PCSD; and 6. Final approval of the plan by the PCSD.In spite of the ratification of the SEP in June of 1992 and the adoption of the ECANguidelines in May 1992, the ECAN Zoning has just started the mapping and inventory stage.The delay in the implementation of SEP (absence of approved zoning) wielded pressure toour company causing delay in the permitting process, unnecessary financial expendituresand further delay in the implementation of our project. This is due to the absence anapproved guideline, which could have addressed the issues related to our project in blackand white. In particular, the need for the Free and Prior Informed Consent (FPIC) from theIPs, location of our facilities, continued mining operations, among others.As stated previously, an Environmental Impact Assessment (EIA) was conducted for therenewal of RTNMC’s 990-ha Nickel Mining Claims, and the conversion of the mining leasecontract into a Mineral Production Sharing Agreement (MPSA). The EIA activitiescommenced in August of 1996 following the provisions of DAO 96-37. In particular, thescoping process and extensive consultation activities were included in the EIA that wascarried out. 6
  9. 9. Similarly, the EIA in 2000 for the HPP Complex followed the same process. While both EIAshad to undergo consultations, review and evaluation with the PCSD prior to the issuance ofa (PCSD) Clearance, the HPP Complex EIA had undergone more and extensiveconsultations including three scoping sessions, focus group discussion (FGDs) with NGOs,Information, Education and Communication activities starting in 2001, validation meetingsand technical conference with PCSD, site walkthrough with PCSD and NGOs, projectpresentation at the Palawan Provincial Board and a public hearing.The EIS document was submitted to the PCSD in July 2001. After the above-listedactivities, the PCSD Clearance was issued for the HPP Project last 29 November 2001.Apart from complying with technical requirements, the EIA that was conducted wasparticipatory and transparent. This has resulted in RTNMC’s generating a documentedclose to 80% support rating in the perception survey, endorsements from the following localgovernment offices, non-governmental organizations, host community residents, andpeople’s organizations, tribal councils, among others. :Consequently, RTNMC/CBNC submitted the EIS document to the DENR-EMB for initialscreening on December 2001. The EIA Review Committee between February and May2002 conducted at least four technical conferences. During the course of the consultationsand validation meetings, RTNMC/CBNC had invested in the conduct of further studies tovalidate the concerns that were raised during these meetings. Some of these studies werelater included as part of the requirements of the ECC issued for the HPP Project. Among thestudies conducted were: • Archaeological Impact Assessment of the proposed Gotok Limestone Quarry; • Environmental Health Impact Assessment of the RTNMC Mining Operations; • Survey and Assessment of Caves and other Sinkholes at the Gotok Limestone Area and Vicinities; • Flora and Fauna Biodiversity Survey of Caves and Vicinities in Gotok Limestone Area; • Groundwater Resource Potential of the Gotok Limestone Area; • Groundwater Characterization in the Vicinity of the Proposed HPP Site of RTNMC; • Soil Erosion Modelling of the RTNMC Mine Site; • Assessment of the Marine Ecosystem of the Ameril Island; • Coral Bay Wet Season Simplified Suspended Sediment Transport ModelingThe DENR-EMB/EIA Unit conducted a separate public hearing and site inspection in March2002. Following favorable endorsement by the EMB Director, the ECC was issued/signed bythe DENR Secretary in July 2002.Thereafter, the Environmental Legal Assistance Center, Inc. (ELAC) wrote the Secretary ofDENR seeking recall of the ECC on grounds, which had been previously raised (andresponded to by RTNMC/CBNC on a point-per-point basis). The Palawan NGO Network,Inc. (PNNI) and ELAC filed a Petition for Certiorari at a Manila Court of Appeals inDecember 2002. The Court of Appeals dismissed the case for lack of merit on September2003. After a motion for reconsideration was denied, the PNNI/ELAC elevated the case tothe Supreme Court. Their petition was first denied on February 2004 and finally, the 7
  10. 10. Supreme Court decided to deny with finality the petition and uphold DENR’s decision toissue the ECC to our HPP project. It took 555 days for this case to be resolved.The RTNMC/CBNC EIA is unique in the sense that it had to have clearance from the PCSDbefore the DENR-EMB could review and evaluate the EIS. In essence, it has undergonetwo separate reviews, which translated to a longer review process.Moreover, the major role that NGOs played in the EIA activities confirms that the presenceof active and educated NGOs is valuable since it is one way of ensuring that developmentaddresses environmental and social issues. Their active participation pushes theenvironmental movement to the limits. At the extreme, it puts project proponents likeRTNMC/CBNC in a vulnerable position in that interest groups can become very influential tothe extent that decision-making processes involved in permitting are delayed or decisionsare altogether questioned.For instance, the PCSD was influenced to the extent that it considered cancellation of theClearance it issued for the HPP project. Almost two years after it was issued, the PCSDcontemplated to cancel the Clearance it issued for the HPP project as requested by thePNNI. This request was based on old issues previously brought up by the group and whichwere comprehensively answered by RTNMC/CBNC. The PNNI request resulted inadditional inspections by a Technical Working Group formed by the PCSD. In August 2004,the PCSD finally decided to uphold the Clearance it issued to the HPP project.Similarly, the DENR, through Special Order 2003-251 formed a Multisectoral Committee toconduct an investigation into issues raised regarding the ECC granted for the HPP project.Thus, the participatory and transparent conduct of the EIA exercise required the DENR toexhaust more effort to re-evaluate the project until such time that all issues related to socialacceptability have been resolved. This, notwithstanding that an ECC had been granted forthe project and that the issues are passé having been discussed and responded to/clarifiedin several fora.The presence of IPs in the area led the others to demand for a Free and Prior-InformedConsent (FPIC) as a requirement for the issuance of the ECC. An FPIC however is requiredfor the MPSA and the Mineral Processing Permit (MPP). However, no ancestral domainclaims have been field and approved for the project areas.This issue was used by the different interest groups to support their opposition to theproject. Consequently, this has resulted in the delay of processing the companys’application for a MPSA and MPP.III. LESSONS LEARNED3.1 SUCCESS IN THE RTNMC/CBNC EIA PROCESSIt can be said that as a whole, the RTNMC/CBNC EIA has been successful despite theextended route that it has undergone. It has been a useful tool in achieving balance ofinterests between development and environment, sustainability, and accruing benefits notonly for RTNMC/CBNC but also for interest groups and the environment, in general. 8
  11. 11. In the RTNMC/CBNC EIA, communication lines were opened to the extent that conflictingparties have agreed to communicate and dialogue despite their differences. Thecomprehensive discussions/dialogues between the company and different groups involvedresulted in increased information flow to the different stakeholders. This likewise resulted ina high level of awareness among various stakeholders, which assures the eventualrealization of a balance of interests between development and environment.It should be pointed out that RTNMC/CBNC has been maintaining viable operations evenbefore the EIA system has been implemented in the country. As such, the fact that we hadto undergo the EIA process has been a learning experience for the company. We have, forinstance, realized the importance of becoming even more proactive – this has led tomodification of the organizational form by which the company addresses environmental andsocial issues and to reconsider some technical aspects of our project. Through the EIA, thecompany considered environmental and technical issues that might have significant impactson the environment. Specific changes in our original plans for blasting (limestone) andcauseway design and alignment were thus implemented upon consideration of the EIAfindings. The former ensures that limestone quarrying will not destroy nearby caves in thearea. In ensuring that the project is planned and designed in environmentally sound ways,the EIA made a contribution to sustainable development.Although the EIA exercise has been a costly and time-consuming exercise forRTNMC/CBNC, we have learned albeit in a “painful” manner. The amount of scrutiny theproject had undergone including that outside the EIA process per se, has made thecompany consider and select the design, location and development of (project) componentsthat provide ways of reducing environmental consequences during the implementation stageand work on the recommendations to enhance the project’s positive impacts. As a result ofthe successful EIA, the companies have expanded existing programs for socialdevelopment, which recognize the needs of both indigenous and non-indigenous peoples inthe host community and nearby areas. The comprehensive Social Development andManagement Plan (SDMP) of RTNMC/CBNC attempts to, among others, take action on theplight of indigenous peoples (IPs) in the area. Likewise, well-defined environmental impactmitigating measures and a monitoring program have been put in place according to thecompanies’ approved Environmental Protection and Enhancement Program (EPEP). Boththe SDMP and EPEP were among the conditionalities in the project ECC.The post-ECC concerns of our company, notably, the case filed by the PNNI/ELAC and theSenate inquiry on the mining activities of RTNMC, corollary to this have brought outimportant social, political, legal and environmental issues in open. This experience likewiseeducated our foreign investors, in particular and the business sector, in general onPhilippine environmental / social issues, which we believe have far-reaching implications vis-à-vis doing business in the country. What is significant however is that the Supreme Court’sdecision to uphold the legality of the ECC issued by the DENR demonstrates that the judicialbranch of Government respects the decision of the DENR.3.2 RECOMMENDATIONSIn light of our EIA experience, we have gained some valuable lessons.Foremost, it is crucial to be true to our commitments as project proponents for our project tosucceed. The genuineness we emanate as project owners goes along way in terms of the 9
  12. 12. support and trust of communities within our impact areas, who are the most sensitivestakeholders of our project.Second, transparency in our transactions ensured that we have exerted all legal means toachieve our goals. This minimized questions regarding the legitimacy of our business.Third, our EIA experience taught us that the conduct of information, education andcommunication (IEC) activities guarantee a faster flow and accurate dissemination ofinformation thus, we have learned the importance of exerting more effort in securing the lineof communications between our company and the stakeholders.Lastly, the use of third party consultants has enabled us access to impartial and technicallysound project assessment and recommendations. Because of this, we were able to instituteappropriate modifications to improve our project design.Together with these lessons, we also realize that there are certain areas for improvementvis-à-vis the EIA process. We recognize the important role of NGOs’ steadfast dedication toprotect the environment. Relative to our experience, we encourage that NGOs get bettertechnical advice to give more merit to their work.Based on our experience, we feel the need for the DENR-EMB to select EIAreviewers/resource persons based not only on their qualifications, but also on their capacityto be impartial in carrying out their functions. We believe this is crucial to the EIA processsince it affects the integrity of their recommendations.We want to stress that the issuance of our ECC, the resolution of the post-ECC issues andthe subsequent development of our project does not mean that the exercise is concluded.Monitoring, which is an essential requirement of our ECC will be implemented throughoutthe lifetime of the project. For monitoring to be effective, a community-based approach isneeded wherein members of the monitoring team are well informed about the project andadequately trained for the task. 10