CRITIC ON THE ENVIRONMENTAL IMPACT

STATEMENT OF THE
PROPOSED 100,000 LITERS PER DAY BIOETHANOL
MANUFACTURING PLANT PROJECT
INTRODUCTION

In support of the Bio Fuels Act, Alsons Consolidated Resources, Inc., the Proponent,

proposed to erect a 100,000 liters per day Bioethanol Manufacturing Plant Project to

provide an environmentally-friendly, energy efficient and cost effective petroleum

fuel additive. The project will be located in a 17.6 hectares of idle land in Barangay

Mambuaya in the City of Cagayan de Oro, Misamis Oriental. The project is classified

as Non Environmentally Critical Project (NECP) by the DENR.

Components of the processing plant include the Milling of the Cassava Feedstock,

Fermentation, Distillation, Dehydration, Storage Facilities and Instrumentation and

Control. Other support facilities include Combination of Coal – Biogas – Biomass –

Fired Steam Boiler, Water Supply and Distribution System, Fire Protection System

and Extraction of water supply from Munigi River. To ensure mitigation of pollution

effects, the following measures are instituted such as Air Pollution Control Devices

(APCDs) to offset pollution effects on air, Waste Water Treatment Plant – Zero

Effluent Technology, to ensure that water are recycled and re-used, and,

Solids/Slops Management System, to ensure the proper disposal of solid waste.

The project is estimated to cost 2.6 billion pesos with manpower complement of 300

– 500 during construction peak and down to 115 personnel during full commercial

operation.

THE PROJECT

Section 2 of the Biofuels Act of 2006 states that, “It is hereby declared the policy of

the State to reduce dependence on imported fuels with due regard to the protection
of public health, the environment, and the natural ecosystems consistent with the

country's sustainable economic growth that would expand opportunities for

livelihood by mandating the use of biofuels as a measure to:

a) Develop and utilize indigenous renewable and sustainable-sources clean energy

sources to reduce dependence on imported oil.

b) Mitigate toxic and greenhouse gas (GSG) emissions;

c) increase rural employment and income; and

d) Ensure the availability of alternative and renewable clean energy without any

detriment to the natural ecosystem, biodiversity and food reserves of the country”.

The projects aims to support the Government’s thrust that encourages the use of

ethanol blend which is an environmentally friendly fuel additive on petroleum

products to reduce the effects of pollution and improve the prices of fuel products

while effectively balancing pollution effects. It will generate employment

opportunities in the area and be able to take advantage of technology transfer. This

will eventually benefit the whole economy as it will reduce the dependence on

imported petroleum products.

During construction, the land shall be converted from agricultural to industrial-

agricultural classification in order to comply with the requirements of land

classification. Necessary permits shall be applied from the DENR and comply with all

its requirements in the cutting of few trees and terrestrial flora/fauna clearing.

Domestic sewage shall be an engineered sceptic vault to ensure effective holding of

waste water. In order to comply with domestic waste disposal, Solid Waste

Management Law, RA 9003 and its implementing rules shall be adopted.

Construction wastes shall be handled by a third party disposal team and those that

can be re-used shall be recycled.

During operation, process water shall be sourced out from the Munigi River and

discharge shall be through the use of Zero Effluent Technology. Excess waste water

from waste water technology shall be used to irrigate the plantation during non-

rainy days. Operations shall comply with the Clean Water Act and its implementing

rules and regulations. Air pollution will be mitigated by the use of coal combustion

design and technology that will control the carbon dispensing in the air. Coal usage

shall be in accordance with the specification that is consistent with the clean air

program set by the project. Air pollution control devices shall also be put in place to

help mitigate what the preceding plans can’t control. Emission shall also be subject

to engineered emission stack. Handling of coal and its storage shall be under

prescribed safety requirements.

Environmental Impact Assessment (EIA) is being conducted to obtain an

Environmental Compliance Certificate from the DENR. EIA is being conducted by a

team of technically and environmentally experienced individuals who has prepared

approved EIA reports for various Environmentally Critical Projects (ECAs). General

approach to the assessment shall follow the usual format used by previous EIA

reports. First level scoping shall be done to serve as basis for the content/format of

the EIA report. Second level scoping shall be done swerving as basis for identifying

and addressing the environmentally-related concerns of the stakeholders.

ENVIRONMENTAL IMPACT ASSESSMENT

The Environmental Impact Assessment Team cosists of a Team Leader who is in

General Consultancy for other bioethanol and coal fired boiler projects, who, also is

an Industry Sector representative to EIA Systems Review with the Environmental

Management Bureau EMB. The assistant Team Leader has wide experience and
exposure to EIA preparation and EIA Systems Review with the EMB. Eight other

members of the EIA team are in the field of Sociology, Sociology, Terrestrial Faunai

Ecology, Terrestrial Floral Ecolgy, Chemical Engineers, learned in Air Quality/Air

Dispersion Modelling, Site coordinator and a site investigator.

The methodology instituted is reasonably within the ambits of the regulations on EIA

preparation and have been performed well as presented by the Environmental

Impact Statement EIS. The result of the EIA shows no major environmental risk

unmitigated. Wastes dispersed in the air are captured by its process and other air

pollution control devices. Water wastes are controlled because water used are 70%

converted to steam which will just evaporate. The 30% shall be extracted from the

solids and will pass through its waste water treatment facility so that it can be

recycled and re-used in its operation thus minimize the dependence to river water

source. The rest of the recycled waste water shall be used for irrigation of cassava

plantation.

The ECC application was hounded by oppositions from various sectors including the

residents, barangay officials, government dignitaries, the Catholic church and the

media. These sectors have rallied toward the disapproval of the ECC application for

grounds that the site is within close proximity to Tagpangi River and the Iponan

River which are both within the 3000 ha. watershed zone of Cagayan de Oro City.

Through such oppositions, the oppositors succeeded in halting the proposed project

as Alsons had scrapped the project.

A newspaper reports the stoppage of the project by Alsons as such:

“MANILA, Philippines--Alsons Consolidated Resources Inc. has scrapped its planned

bioethanol project in Cagayan de Oro City, citing “certain ambiguities’’ in the

implementation of the Biofuels Law and difficulties in dealing with some

government agencies as reasons.

In a disclosure submitted to the Philippine Stock Exchange Monday, ACR chief

financial officer and compliance officer Luis Ymson Jr. said that during Friday’s board

meeting, the company’s board decided to junk the project due to “deterrents’’

stemming from various fronts, including the government, the Catholic Church and

even nongovernment organizations.

“ACR regrets having taken this action, which has stemmed from, among other

deterrents, its perception of the current ambiguities in the implementation of the

Biofuels Act, its experience of unjustifiable delays in the issuance of an

environmental clearance certificate by the [Department of Environment and Natural

Resources’] regional office, the congressional intervention into the executive branch

functions over the issuance of the project’s ECC, and the Catholic Church’s and the

NGO sectors’ apparent lack of genuine concern for the plight of the poor," he said.”

The project just died of natural causes through withdrawal of proponent. Although,

the concerns of the oppositions are outlined, the EIS does not answer the concerns

at hand. It does not consider the location as a matter of a risk factor to the

watershed area and its effects on it. How much of a risk does the project can impact

the watershed if any, even with the mitigations instituted to suppress pollution.

There has been no quantification as to the risk involved. The EIS may be useful if it

can anticipate the equivalent impact of a per day failure of any of such mitigations

because conduit to highly delicate resources surrounding the location of the project

are directly adjacent. The opposition is basically maintaining that the project is just

within the area of the watershed which is not suitable for industrial operations.
The Clean Air Act of 1999 shows the intention of the legislators to protect the right

of each citizen to a healthful ecology as such:

SEC. 2. Declaration of Principles. - The State shall protect and advance the right of

the people to a balanced and healthful ecology in accord with the rhythm and

harmony of nature.

The State shall promote and protect the global environment to attain sustainable

development while recognizing the primary responsibility of local government units

to deal with environmental problems.

The State recognizes that the responsibility of cleaning the habitat and environment

is primarily area-based.

The State also recognizes the principle that “polluters must pay”

Finally, the State recognizes that a clean and healthy environment is for the good of

all and should, therefore, be the concern of all.

Excerpts from the "Ecological Solid Waste Management Act of 2000." states its

policies:

Sec. 2. Declaration of Policies. - It is hereby declared the policy of the State to adopt

a systematic, comprehensive and ecological solid waste management program

which shall:

(a) Ensure the protection of the public health and environment;

(b) Utilize environmentally-sound methods that maximize the utilization of

valuable resources and encourage resource conservation and recovery;

 (c) Set guidelines and targets for solid waste avoidance and volume reduction

through source reduction and waste minimization measures, including composting,

recycling, re-use, recovery, green charcoal process, and others, before collection,

treatment and disposal in appropriate and environmentally sound solid waste

management facilities in accordance with ecologically sustainable development

principles;

(d) Ensure the proper segregation, collection, transport, storage, treatment and

disposal of solid waste through the formulation and adoption of the best

environmental practice in ecological waste management excluding incineration;

(e) Promote national research and development programs for improved solid

waste management and resource conservation techniques, more effective

institutional arrangement and indigenous and improved methods of waste

reduction, collection, separation and recovery;

(f) Encourage greater private sector participation in solid waste management;

(g) Retain primary enforcement and responsibility of solid waste management

with local government units while establishing a cooperative effort among the

national government, other local government units, non- government organizations,

and the private sector;

(h) Encourage cooperation and self-regulation among waste generators through

the application of market-based instruments;

(i) Institutionalize public participation in the development and implementation of

national and local integrated, comprehensive, and ecological waste management

programs; and
 (j) Strength the integration of ecological solid waste management and resource

conservation and recovery topics into the academic curricula of formal and non-

formal education in order to promote environmental awareness and action among

the citizenry.

CONCLUSION

The environmental policies and laws provide for mechanism to control pollution but

do not answer directly all questions surrounding a number of issues. It assigns the

responsibility to certain government agencies for its implementation which

depending on the strength and direct concern of each agencies, can be ineffective

in addressing the issues at hand. The law does not pinpoint the process that will

address issues and bring about specific environmental concern. It just prescribed

the agency responsibility.

In some ways, having the ECC as a pre requisite to project approval, somehow

performs the essence of the law being that the approval is anchored with public

consultations and discretion of the government agency vested with approving

rights. The strong opposition from the different sectors, made it very difficult for

the DENR to hastily make any findings and approval of the project. I should expect

that the law should by itself sufficient to address environmental violation and issues

with independent consideration of its rules and not by pressures of oppositions or

by a mob.