MSESDD-MEMS-2019-03-0150

March 29, 2019

RENE J. ELUMBARING
Purok 1, Upper Doongan
Butuan City

Dear Mr. Elumbaring:

This is in reference to your submitted Environmental Protection and

Enhancement Program (EPEP) and Final Mine Rehabilitation and/or
Decommissioning Plan (FMR/DP) for the proposed Mountain Soil Quarry
Project which we received last March 13, 2019. Results of our preliminary
evaluation are as follows:

Environmental Protection and Enhancement Program (EPEP)

1. On Page 5, the data for the volume reflected in Table 3 for the
Extractable Rock Reserves and on Paragraph 3 of the same page
does not coincide. It shows that on Table 3 the total volume
Extractable Rock Reserves is 653,445 m 3 or 1,206,890 MT and on
Paragraph 3 the volume is 454,069 m3 908,138 MT.
2. Gantt chart showing the environmental activities from Year 1 to 5
including the corresponding activity costs was not reflected.
Include the costs for the construction of drainage canals, siltation
pond, fuel/oil waste trap, nursery and its operations, etc. Also
include costs for water spraying, maintenance works, monitoring
of water, air and noise, etc.
3. On item 2.7.2.3 Drainage Plan and Sedimentation Ponds:
a. The Drainage Plan was not properly illustrated. The attached
Drainage Map only shows the existing drainage map in the
area thus, it does not show the drainage system within the
quarry site.
b. The sedimentation ponds capacity and dimension was not
discussed and illustrated.
4. Land Resources – Acceptable Impacts and Control Strategies:
 a. Please provide discussions on the pre-mining preparation
activities that will be conducted such as stripping and clearing
of trees in the area, if there’s any. Inquire with the CENRO
concern the need to conduct tree inventory before
removing/cutting trees within the project area;
5. Water Resources – Acceptable Impacts and Control Strategies
a. Items like process water, tailings pond, sewerage among
others, may not be included in the program if these are not
applicable in the project;
6. Noise – Acceptable Impacts and Control Strategies
a. Items like explosives, crusher and other ore treatment plant,
powerhouse, permanent or temporary relocation of
residences affected (control strategy), among others may not
be included in the program if these are not applicable in the
project;
7. Air Quality – Acceptable Impacts and Control Strategies
a. It is recommended to include regular air quality monitoring as
one of the control strategies to limit the impact of the project
to air quality;
8. Approach and Scope of Environmental Monitoring Program
a. Identification of possible environmental impacts produced by
the operation cannot be considered as a purpose of
monitoring. Even before the monitoring, the company has
already identified impacts and mitigating measures to address
such. Please give a brief discussion on purpose of monitoring of
control strategies implemented for each potential impact
identified;
b. For monitoring, please indicate an improved discussion on the
monitoring methods that will be used, monitoring stations for
water quality and air quality should be identified and location
maps of these stations should be attached in the program;
9. Budget for annual EPEP (starting Year 2) will be subject to change
because this will be based on 3-5% of the direct mining cost
(DMC).

Final Mine Rehabilitation and/or Decommissioning Plan (FMRDP)

1. The timetable for the implementation of the proposed FMRDP is

not clearly presented in the plan. Similar with the EPEP, a Gantt
showing the yearly rehabilitation activities with unit of measure,
unit cost, timeframe, etc. should be included in the program;
 2. EPEP/FMRDP for quarry projects will be further evaluated and
approved by the MRFC. Monitoring will be conducted by an MMT
which acts as the monitoring arm of the MRFC. The company is
advised to create an MRFC and enter into a Memorandum of
Agreement for the Lodging of the Contingent Liability and
Rehabilitation Fund (CLRF).

Please revise the submitted EPEP/FMRDP subject to the above

comments/recommendations. Thank you.

Very truly yours,

By Authority of the OIC, Regional Director:

ROMEO M. DALODADO
Chief, Geosciences Division
Officer-in-Charge