INTRODUCTION AND TECHNICAL GUIDELINES119.92.161.2/portal/Portals/21/IEC Material/Volume I.pdf ·...

VOLUME I

INTRODUCTION ANDTECHNICAL GUIDELINES

Handbook for the Application of the

Enhanced Environmental Performance

Monitoring and Audit System of the

Philippine Environmental Impact

Assessment System

STRENGHTENING THE ENVIRONMENTAL PERFORMANCE MONITORING & EVALUATIONSYSTEM OF THE PHILIPPINE ENVIRONMENTAL IMPACT STATEMENT SYSTEM (SEPMES-PEISS)

The World Bank

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INTRODUCTION ANDTECHNICAL GUIDELINES

Handbook for the Application of the

Enhanced Environmental Performance

Monitoring and Audit System of the

Philippine Environmental Impact

Assessment System

HANDBOOK FOR THE APPLICATION OF THE ENHANCED ENVIRONMENTALPERFORMANCE MONITORING AND AUDIT SYSTEM OF THE PHILIPPINEENVIRONMENTAL IMPACT ASSESSMENT SYSTEM

VOLUME I:INTRODUCTION AND TECHNICAL GUIDELINES

ISBN 971-8986-64-2

Published under the World Bank Institutional Development Facility (IDF) GrantNo. TF050534: Strengthening the Environmental Performance Monitoring and Evalu-ation System of the Philippine Environmental Impact Statement System Project withthe cooperation of the Environmental Management Bureau-Department of Envi-ronment and Natural Resources

Reproduction of this book in whole and in part in whatever manner is not allowedexcept for citation in scholarly journals and other publications or review for print andelectronic mass media.

Maiden Issue January 2005

Printed in the Philippines

9 8 7 6 5 4 3 2 1 0

ACKNOWLEDGEMENT

The preparation of this handbook is the result of the collaborative efforts of several individuals forwhich we would like to extend our gratitude.

For his continued support and relentless encouragement, we would like to acknowledge formerDENR Undersecretary for Management and Technical Services Dr. Rolando L. Metin.

Similarly, we would like to acknowledge the Philippine Geothermal Incorporated and Na-tional Power Corporation in Mak-Ban and Mirant Pagbilao and Mr. Jose Reynato M. Morenteof Mirant Philippines for their participation in pilot-testing of the proposed enhanced environmen-tal monitoring and auditing scheme.

This is also to acknowledge the active participation of the pilot Multistakeholder Monitoring Teams(MMTs): The Makban Geothermal Power Plant MMT especially Forester Luis L. Awitan ofBatangas PG-ENRO and Forester Edmund A. Guillen, Provincial Government Environ-ment and Natural Resources Officer of Laguna and the Mirant Pagbilao Coal-fired PowerPlant MMT especially Quezon Provincial Administrator Evelyn S. Abeja and Ms. Ma. ElisaO. Robles.

It is also with deepest sincerity that we extend our heartfelt appreciation to Dr. Maya G. Villaluzof the World Bank for her invaluable support in the completion of this handbook.

And last but not the least, to the stakeholders of the Philippine EISS and M&A to whom thisundertaking is primarily dedicated.

JULIAN D. AMADOREMB Directorand SEPMES PEISS Project Director

The publication of this handbook evolved from a series of pilot-testing the environmental moni-toring and audit scheme. The following have actively shared in carrying out this project:

MR. REYNALDO P. ALCANCES, Project Manager and Chief EIA DivisionENGR. PURA VITA G. PEDROSA, Deputy Project ManagerENGR. ESPERANZA A. SAJUL, Chief Monitoring Section, EIA DivisionENGR. ELSIE CEZAR, Multi-Stakeholder Participation CoordinatorMS. CONSOLACION CRISOSTOMO, Foreign- Assisted Training Projects CoordinatorMS. JANUSETTE UY, Training CoordinatorMR. JONATHAN S. ABEJUELA, Financial Management and Disbursement OfficerMS SONIA C. ALCON, Logistics and Procurement Assistant

DR. MARLITO L. CARDENAS, Environmental Specialist and Volume 1 AuthorDR. MARY ANN P. BOTENGAN, Participation Specialist and Volume 2 AuthorMS MA. DULCE M. CACHA, Financial Specialist and Volume 2 Co-AuthorMS JO ROWENA D. GARCIA, Institutional Specialist and Volume 3 AuthorMS SOCORRO L. PATINDOL, Training Specialist

MR. MANUEL RAY M. ALMARIO, Technical Associate, Volume 1 Co-Author, HandbookLayout and Graphics ArtitstMR. EDGAR A. DE JESUS, Technical Associate and Volume 1 Co-AuthorMR. VANDERLEAF C. CAPALUNGAN, Institutional Associate and Volume 3 Co-AuthorJULIUS E. REYES, Technical Research AssociateGERTIE M. APIGO, Technical Research Associate

Process Documentation Team Members:ENGR. JESS L. ADDAWEMR. RYAN FILIPERTO P. BOTENGANMS FILMA C. CALALOMR. RONALD C. GARCIAMR. ARMANDO C. RAMOS JRMR. VICTOR N. MADLANGBAYAN

ENGR. MALOU AVENIDO, EIA Division Chief, EMB Region 3MR. REDENTOR LAURETA, Chief Monitoring Section, EIA Division, EMB Region 3, PEMAPs

Pilot-test Participants:MS. CHERRY SANTOS, EIA Division, EMB Region 3, PEMAPs Pilot-test ParticipantFORESTER SALVACION P. VILLANUEVA, EIA Division Chief, EMB Region 4-AFORESTER CORAZON C. GASAPOS, EMB Region 4-A Pilot-test ParticipantENGR. JENNIFER A. GAPPE, EMB Region 4-A Pilot-test ParticipantDENR-PENRO DANILO MORALES, Batangas ProvinceMR. LEONEL F. BARTE, DENR-PENRO Batangas Province Office

ERIC M. LOPEZ, Handbook Technical EditorRAY FRANCIS M. ALMARIO, Handbook Layout and Graphics Artist

TABLE OF CONTENTS

Volume 1: Introduction and Technical GuidelinesAcknowledgementList of Tables .......................................................................................................... ivList of Figures ........................................................................................................ vList of Appendices .................................................................................................. viList of Acronyms/Terminologies ................................................................................ vii

PART 1: INTRODUCTION, OVERVIEW, BASES, ROLES, AND REQUIREMENTS

I.INTRODUCTION ................................................................................................... 1

A. BACKGROUNDER ..................................................................................... 11. The Philippine Environmental Impact Statement System .......................... 12. SEMPES-PEISS Project ....................................................................... 2

B. Highlights of the PEIS System Assessment .................................................. 31. Profile of the Regulated Community ........................................................ 42. Monitoring Performance based on ECC-issued Projects............................ 53. Organizational Structure, Capability and Financial Mechanisms ................ 6

a. Organizational Structure .................................................................. 6b. Capability Assessment ................................................................... 7c. PEISS M&E Financial Management and Administration ..................... 7

4. Multistakeholder Participation ................................................................ 10C. Overview of the EIA M&A System Handbook ................................................. 11

1. Purpose, Legal Basis, and Target Users of the Handbook .......................... 112. Organization and Brief Description of the Handbook ................................. 12

a. Volume 1: Introduction and Technical Guidelines .................................... 12b. Volume 2: Multistakeholder Participation ......................................... 12c. Volume 3: Administrative Procedures ............................................... 12

3. Guidance on Use of the Handbook.......................................................... 13

II. Overview and Rationale of the Enhanced PEISS M&A System ........................ 14

A. Overview of the Enhanced PEISS M&A System ............................................. 14B. Rationale for the Enhancements .................................................................. 15C. The Generic EMA Process over the Project Lifecycle and EIA Stages.............. 15D. Key Functions of the Project-level EIA M&A System ...................................... 22

III. PEISS M&A Stakeholders, Roles and Responsibilities,and General Requirements ......................................................................... 23

A. Description of the EIA M&A System of the Three Lead EIA M&A Stakeholders .............................................................................................. 23

1. Proponent-based EIA M&A System ........................................................ 232. Community-based EIA M&A System ...................................................... 243. EMB-based EIA M&A System ................................................................ 25

Introduction and Technical Guidelines

World Bank - DENR SEPMES PEISS i

B. Roles and Responsibilities of Stakeholders of the EnhancedProject-level EIA M&A System ..................................................................... 26

C. Summary List of Technical EnvironmentalDocuments/Reports to be prepared by the Key Actors ...................................... 261. Baseline Monitoring and Audit Plan and Manual (BEMAP/M) ....................... 302. Environmental Monitoring and Audit Plan and Manual (EMAP/M) ................. 313. Self-monitoring Report (EIA Module) .......................................................... 33

a. Baseline Environmental Monitoring and Audit Reports ........................... 33b. Periodic Self-monitoring Reports ......................................................... 34

D. Selection and Prioritization of Projects for Monitoring ........................................ 35

PART 2: GUIDELINES IN IMPLEMENTING ENVIRONMENTAL MONITORING AND AUDIT AND REPORTING SYSTEM

IV. GUIDELINES FOR PREPARATION OF BASELINE ENVIRONMENTALMONITORING AND AUDIT PLAN AND MANUAL (BEMAP/M) ANDENVIRONMENTAL MONITORING AND AUDIT PLAN AND MANUAL(EMAP/M) BY PROPONENT ......................................................................... 36

A. NATURE AND PURPOSE .............................................................................. 361. Baseline Environmental Monitoring and Audit Plan and Manual .................... 362. Environmental Monitoring and Audit Plan and Manual ................................. 39

B. CONTENTS OF THE BEMAP/M and the EMAP/M ........................................... 401. Executive Summary ................................................................................ 412. Environmental Policy and EM&A Objectives ............................................... 423. Baseline Monitoring ................................................................................ 424. Compliance Monitoring ............................................................................. 435. Impact Monitoring .................................................................................... 43

a. Identification of Significant Environmental Aspects and Impacts ............. 43b. Selection of Monitoring Parameters .................................................... 45c. Sampling and Measurement Plan ....................................................... 46d. Setting Environmental Quality Performance Levels ............................... 49

6. Budget ................................................................................................... 507. Accountability ......................................................................................... 518. Stakeholder Participation .......................................................................... 519. Complaints Management, Communication and Reporting ............................ 5110. Environmental Impact Event / Action Response Plan ................................... 5211. Audit Plan or Program .............................................................................. 5212. Schedule for Baseline Monitoring and Preparation of BEMAM/EMAM

for Design, Construction, Operation, and Decommissioning Phases .............. 52

V. GUIDELINES FOR PREPARATION OF THE BASELINEENVIRONMENTAL MONITORING AND AUDIT REPORT ANDSELF-MONITORING REPORT BY PROPONENT............................................... 53

A. PURPOSE OF THE GUIDELINES ................................................................... 531. Baseline Environmental Monitoring and Audit Report ................................... 532. Self-monitoring Reports ............................................................................. 53

ii World Bank - DENR SEPMES PEISS

B. CONTENTS OF THE BASELINE ENVIRONMENTAL MONITORINGAND AUDIT REPORT AND THE SELF-MONITORING REPORT(EIA MODULE) .............................................................................................. 541. Executive Summary ................................................................................. 542. Introduction ............................................................................................. 543. Project Background ................................................................................. 544. Methodology ........................................................................................ 555. Results and Discussion ........................................................................ 55

a. Summary of Previous Monitoring ..................................................... 55b. Reports of Complaints and Environmental

and Health-related Accidents ...................................................... 56c. Current Monitoring Results and Findings ........................................... 57

6. Conclusions and Recommendations ....................................................... 57a. Compliance Status ......................................................................... 57b. Environmental Quality Status ........................................................... 58c. Environmental Management Plan Status ........................................... 58d. PEMAPS Score ............................................................................ 58e. Work Plan for Next Monitoring Period ............................................... 58

References ............................................................................................................ 59Appendices............................................................................................................. 61

World Bank - DENR SEPMES PEISS iii

iv World Bank - DENR SEPMES PEISS

Table Page

1-1 2002 Accomplishments of EMB CO and Region 3 Office 71-2 Summary of Technical and Institutional Aspects

of the System Assessment 82-1 List of Current Practices and Proposed Enhancements 163-1 Roles and Responsibilities of the Stakeholders of the

Enhanced Project-level EIA M&A System 273-2 List of Technical Environmental Reports to be Prepared by

the Key Actors under the Proposed Enhanced PEIS EMA System 293-3 Sample Risk-Based Environmental Monitoring and Audit

Strategy Selection Matrix 364-1 Environmental Monitoring and Audit Summary Matrix 414-2 Selection of Parameters for Monitoring of Critical Environmental

Aspects and Impacts (EA&I) 475-1 Summary Matrix for BEMAR & SMR 545-2 Dummy Table for Reporting Methodological Revisions 555-3 Summary Table for Reporting Monitoring Results 57

List of Tables

World Bank - DENR SEPMES PEISS v

List of FiguresFigure Page

1-1 Certificates issued by DENR and EMB: 1980-2003 41-2 Profile of the Regulated Community by Major Project Type: 1980-2003 51-3 Current Status of PEISS Monitoring 62-1 PEISS M&A System Framework 142-2 Generic Simplified EMA Process over the Project

Life-cycle and EIA Stages 212-3 Enhanced Community-based Multipartite Monitoring and Audit System 22

List of Appendices Appendix

1 Project Environmental Monitoring and Audit Prioritization Scheme (PEMAPS) 2 Examples of Environmental Policy, Objectives and Targets 3 EMB Compliance Monitoring Form No. CM-3 4 Stressor-impact Matrices for Various Power Project Types 5 Environmental Stressor Rating Scheme (ESRS) 6 Sampling and Measurement Plan (SAMP) Matrix 7 Example of Environmental Quality Performance Levels (EQPLs)


vi World Bank - DENR SEPMES PEISS

List of Acronyms/ TerminologiesAsian Development BankAdditional InformationAdministrative Order, a legal issuance of the Philippine PresidentAssociation of Official Analytical ChemistsAmerican Public Health AssociationAmerican Society for Testing MaterialsAnnual Work and Financial PlanBaseline Environmental Monitoring and Audit PlanBaseline Environmental Monitoring and Audit ManualBiochemical Oxygen DemandComprehensive Agrarian Reform ProgramCease and Desist OrderCommunity Environmental and Natural Resources Office(r)ChlorofluorocarbonsCompliance Monitoring and Validation ReportClearance LetterCentral Office; carbon monoxideChain of CustodyChemical Oxygen DemandCode of EthicsDepartment Administrative Order, this refers to a legal issuanceof the Department of Environment and Natural ResourcesDiameter at Breast Height of a treeDepartment of Budget and ManagementDepartment of Environment and Natural ResourcesDissolved OxygenData Quality IndicatorData Quality ObjectiveEnvironmental Aspects and Impacts, refers to a project’s environment-relevantactivities and elements (environmental aspects) and their singular or jointeffects on the environment (environmental impacts)Environmental Baseline Monitoring ReportEnvironmentally Critical AreaEnvironmental Compliance CertificateEnvironmental Compliance and Impact Monitoring ReportEnvironmentally Critical ProjectEnvironmental Guarantee FundEnvironmental Impact AssessmentEnvironmental Impact Assessment DivisionEnvironmental Impact Assessment and Management DivisionEnvironmental Impact StatementEnvironmental Monitoring and Audit, refers to a process to followup EIArecommendations during implementation of a project granted an ECCwith the goal of improving the project’s environmental performanceEnvironmental Monitoring and Audit Fund

ADBAIAOAOACAPHAASTMAWFPBEMAPBEMAMBODCARPCDOCENROCFCsCMVRCLCOCOCCODCOEDAO

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EBMRECAECCECIMRECPEGFEIAEIADEIAMDEISEM&A orEMA

EMAF

World Bank - DENR SEPMES PEISS vii

Environmental Monitoring and Audit ManualEnvironmental Monitoring and Audit PlanEnvironmental Management Bureau, a line bureau of DENR mandatedto implement the Philippine EIS SystemEnvironmental Monitoring FundEnvironmental Management PlanEnvironmental Monitoring PlanEnvironmental and Natural Resources Office(r)Environmental Quality Performance Level(s)Environmental StressorEnvironmental Stressor Rating SchemeExecutive CommitteeForeshore Costal ZoneFocus Group DiscussionGovernment AgencyGreenhouse GasesGovernment OfficeGovernment of the PhilippinesInformation, Education, and CommunicationImplementing Rules and RegulationsKey Informant InterviewLaboratory control samplesLocal Government UnitMonitoring and AuditMonitoring and EvaluationMonitoring and Audit CommitteeMotion for Reconsiderationmilligram per cubic meterMultipartite Monitoring and Audit SystemMultipartite Monitoring TeamMemorandum of AgreementManual of OperationsMultistakeholder ParticipationNot ApplicableNon-Environmentally Critical Project

National Government AgencyNongovernment OrganizationNitrogen OxidesNotice of ViolationNational/Regional Industry Prioritization SchemePollution Control SystemPresidential DecreePhilippine Environmental Impact Statement SystemProject Environmental Monitoring and Audit Prioritization SchemePhilippine Environmental Partnership ProgramMeasure of acidity or basicity of a liquidParticulate Matter with less than 10 micron diameterParticipatory Monitoring and EvaluationPeople’s OrganizationQuality Assurance/Quality Control

EMAMEMAPEMB

EMFEMPEMoPENROEQPLESESRSExeComFCZFGDGAGHGGOGOPIECIRRKIILCSLGUM&AM&EMACOMMFRmg/cu mMMASMMTMOAMOOMSPNANECP orNon-ECPNGANGONO

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viii World Bank - DENR SEPMES PEISS

EIA Review CommitteeRegional OfficeSampling and Measurement PlanSocial Development ProgramSignificant or Critical Environmental Stressors and ImpactsStrengthening Environmental Enforcement and Compliance CapacityTechnical Assistance ProjectSmall and Medium EnterprisesSelf-monitoring ReportSulfur OxidesSectoral Regulatory UnitSuspended SolidsTotal Suspended ParticulatesUniversal Resource LinkUpper Respiratory Tract InfectionVolatile Organic CarbonThe World Bank

RevComROSAMPSDPSEAISEECCTA

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World Bank - DENR SEPMES PEISS ix

RA Republic Act


World Bank - DENR SEPMES PEISS 1

VOLUME 1


I. INTRODUCTION

The Environmental Impact Assessment and Management Division formerly known as the Environ-mental Impact Assessment Division (EIAD) of the Environmental Management Bureau (EMB),Department of Environment and Natural Resources (DENR) publishes this three-volume Hand-book as a set of guidelines to make the Philippine Environmental Impact Statement System (PEISSystem or PEISS) responsive to the policy goals of Presidential Decree 1586. In similar direction,the Handbook provides a basis to establish a more efficient and effective platform in consolidatingmultistakeholder collaboration in advocating environmentally sound project undertakings.

The Handbook was prepared with the financial support of the World Bank (WB) under its Institu-tional Development Facility Grant No. TF050354 through a project entitled “Strengthening theEnvironmental Performance Monitoring and Evaluation System of the Philippine EnvironmentalImpact Statement System” (SEPMES-PEISS). The Handbook shall be known as the “Environ-mental Performance Monitoring and Audit System Handbook” or “EPMA System Handbook” orPEISS M&A System Handbook.

A. BACKGROUNDER

1. The Philippine Environmental Impact Statement System

Presidential Decree (PD) No. 1151, entitled the “Philippine Environmental Policy” man-dated the creation of the Environmental Impact Statement (EIS) System in the Philip-pines. Issued in 1977, PD 1511 (section 4) explicitly requires “all agencies and instru-mentalities of the national government, including government-owned and controlledcorporations, as well as private corporations, firms and entities to prepare an environ-mental impact statement (EIS) for every action, project or undertaking which signifi-cantly affects the quality of the environment.”

The Philippine EIS System was formally created in 1978 by PD No. 1586. Pursuant tothe policy statement of PD 1151, it declared environmentally critical projects (ECPs)and projects located within environmentally critical areas (ECAs) as projects whichrequire the submission of an EIS. Section 4 of PD 1586 states that “no person, partner-ship or corporation shall undertake or operate any or in part such declared ECP orproject within an ECA without first securing an Environmental Compliance Certificate(ECC).” PD 1586 also identified the lead agency for the implementation of the EISSystem and provided sanctions for its violation.

The major categories of ECPs and ECAs were mandated through Presidential Procla-mation No. 2146, series of 1981. The categories were given technical definitions byEMB’s predecessor agency, the National Environmental Protection Council (NEPC),through NEPC Office Circular No. 3, series of 1983.

PART 1: INTRODUCTION, OVERVIEW, BASES, ROLES, AND REQUIREMENTS


2 World Bank - DENR SEPMES PEISS

PD 1586 was implemented through the issuance of a number of administrative regula-tions and guidelines. The first of such administrative issuance is the implementingrules and regulations (IRR) released by NEPC in 1979, and amended in 1984.

Over the years, the PEISS was subjected to several refinements to make it a moreeffective planning, management, and regulatory tool in addressing environmental prob-lems in the country. Innovative features and requirements were adopted in response tochanging political, economic, and social realities, the growing environmental conscious-ness of the Filipinos and the worsening environmental deterioration.

Upon assuming the NEPC’s mandate, DENR subsequently amended NEPC-issuedrules through its issuance of Department Administrative Order (DAO) No. 21 in 1992.

Chiefly, the need to sustain the environment’s carrying capacity and its productivebalance stood as riveting backdrop of the expanding and diversifying activities of theindustry sector in the succeeding years. Across this period, new issues over PEISSunderpinned for a more rational basis to qualify and expand its scope and to furtherattune the sector’s activities with sustainable development.

On 2 Dec. 1996, the DENR issued DAO No. 96-37 to further strengthen the PEISS. On2 Nov. 2002, the Office of the President issued Administrative Order No. 42 (A.O. 42)which intends to rationalize the implementation of the PEISS to make it a more effectiveplanning as well as management tool for sustainable development.

The IRR of A.O. 42 was issued as DAO No. 03 series of 2003 or DAO 2003-30.The procedural manual was released in December 2004.

A key requirement under DAO 03-30 is the establishment of an EIA Monitoring andEvaluation (M&E) System as a tool for strengthening EIA Follow-up and Implementa-tion. This three-volume Handbook presents the key features and implementation re-quirements of the Enhanced Monitoring and Audit (M&A) System of the PEISS.

2. SEPMES-PEISS Project

The “Strengthening the Environmental Performance Monitoring and Evaluation Systemof the Philippine Environmental Impact System (SEPMES-PEISS)” Project is managedby EMB-EIAMD and funded by the World Bank under its Institutional DevelopmentFacility Grant No. TF050534. The Grant Agreement was signed on 29 Jan. 2002 andwas concurred by the Government of the Philippines (GOP) through the Department ofFinance on 1 Feb. 2002.

The objectives of SEPMES-PEISS are to:

1. strengthen the monitoring and evaluation aspect of the EIS System by implement-ing an EIS M&E model based on a comprehensive analysis of the System takinginto consideration the various constraints (e.g., financial, institutional, regulatory)as well as focusing on the most critical environmental concerns of developmentprojects, minimizing duplication of functions among different government agenciesand encouraging cooperation among various stakeholders;



2. strengthen the capability of the environmental regulatory agency tasked to imple-ment the EIS System, encourage LGUs and communities in the monitoring, evalu-ation, and reporting of compliance to environmental rules and regulations (includingthe implementation of the Environmental Management plans by Project Propo-nents), especially the World Bank supported projects; and

3. improve the capacity of GOP to develop and adopt innovative financial and institu-tional mechanisms including participatory approaches that will ensure continuedimplementation of EMPs and compliance to environmental covenants.

The SEPMES-PEISS Project has three components to accomplish each of the follow-ing main tasks:

1. carry out a comprehensive assessment of the policy, legal, and regulatory and institutional frameworks governing the EIS Monitoring and Evaluation and develop an enhanced EIS Monitoring and Evaluation Model;

2. determine the effectiveness of the EIS M&E Model through pilot-testing and en-hancing the capability of the regulatory agency in the implementation of the EISM&E Model; and

3. develop and implement mechanism to encourage public disclosure of environmen-tal performance and multistakeholder participation in EIS Monitoring and Evalua-tion.

The project ended in January 2005. The PEISS M&A System and this ApplicationHandbook are the main deliverables of the SEPMES-PEISS Project. These outputsresulted from a comprehensive PEIS System Assessment as well as design, pilot-testing, consultations on, and finalization of the PEISS M&A System. The highlights ofthe PEIS System Assessment are presented in the following section.

B. HIGHLIGHTS OF THE PEIS SYSTEM ASSESSMENT

The PEIS System Assessment was aimed at:• assessing policy and practice of the PEISS M&E System, and• recommending improvements to the PEISS M&E System.

The System Assessment focused on the following tasks:

• Understanding the origin, characteristics and structure of the current PEISS M&E Sys-tem

• Estimating the size of the regulated community to be monitored and analyzing themajor PEISS M&E requirements

• Assessment of the environmental aspects of the project-based M&E functions• Assessment of the institutional aspects of EMB as the lead PEIS M&E unit• Assessment of the multistakeholder participation in PEISS M&E• Assessment of the institutional linkages of DENR on PEISS M&E• Assessment of the legal framework for the management of environmental performance/

other legal issues



Figure 1-1 Certificates Issued by DENR and EMB: 1980-2003.

The results of the System Assessment were used as a major basis for designing the EIAM&A System. The major findings are briefly presented in the following.

1. Profile of the Regulated Community

The regulated community encompasses those projects that are covered by PEISS,either as ECPs or ECAs. These projects may be captured in the System through theapplication for and issuance of ECCs to covered projects. Those covered projectsoperating without ECC are in violation of PD 1586 and subject to cease-and-desistproceedings. Projects which applied for and are issued either a Certificate of Non-Coverage (CNC) or an Environmental Compliance Certificate (ECC) are followed upthrough Post-ECC monitoring and evaluation.

From 1980 to 2003, DENR and EMB issued more than 23,000 certificates (see Figure1-1). Most of these issued certificates (around 83%) are ECCs based on the PD/IEE,a simpler form of EIA documentation. A total of 1,993 ECCs were issued based on theEIS, the more comprehensive EIA documentation. About the same number (1,993 or9%) of projects were issued CNC and thus, do not normally require monitoring andevaluation. All in all, more than 21,000 ECCs were issued over this period of study.

A breakdown of projects issued ECCs by major project type by DENR and EMB CO isshown in Figure 1-2. The Resource Extractive Industries account for 48%, followed byInfrastructure at 30%, then Heavy Industries at 17%, SMEs 3.4%, Golf Courses 1.4%,and lastly, Biodiversity and Reforestation 0.15%.



Figure 1-2 Profile of the Regulated Community byMajor Project Type: 1980-2003.

2. Monitoring Performance based on ECC-issued Projects

The current status of PEISS monitoring as of 2002 is given in Figure 1-3.

Out of the more than 21,000 projects issued ECCs, around 3,000 were monitored.These consisted of 17.60% of IEE monitored by EMB RO, 0.20% of EIS monitored byCO, 0.20% of EIS monitored by MMTs, and 0.01% of IEE monitored by MMTs. Whatis alarming in these figures is the proportion of unmonitored projects which accounts foraround 82% of projects issued ECCs. By any standard, this monitoring performance isnot tenable if the PEISS goal of environmental protection is to be significantly achieved.Thus, improvements in the PEISS M&E System must be identified and implemented ona continuous basis. Such improvements or enhancements must consider current ca-pacity constraints of the DENR-EMB to be effective and sustainable. This Handbookpresents various enhancements which will increase the productivity of each major actoreven with current levels of budget and logistics.

One key area for enhancement is the preparation, approval, and implementation of theEnvironmental Monitoring Plan (EMoP). The System Assessment indicated that theEMoPs are generally of poor quality and oriented mostly to compliance monitoring andto lesser extent to impact monitoring. The parameters monitored cover all impactsidentified during the EIA study instead of being selective to the more critical ones.However, the socioeconomic and ecosystem impacts are less considered. Also, thereis little evaluation or audit EMoPs. Proponents with certified EMS such as ISO 14000series, however, undergo third-party audit.



Figure 1-3. Current Status of PEISS Monitoring

3. Organizational Structure, Capability, and Financial Mechanisms

a. Organizational Structure

The EIA Division has been an ad hoc division of then NEPC and present EMB sincePEISS was established. As such, there is no plantilla organization and all the staffmembers are either seconded from other divisions or contractual (the greater ma-jority). This is an overwhelming constraint, but, as accomplishments have shown,not insurmountable.

Table 1-1 shows the 2002 Accomplishments of CO and Region 3 Office. Based onthe reported accomplishments, it was estimated that CO must have a staffingcomplement of 18 technical staff but actually has only 12 and all are contractual.On the other hand, Region 3 Office has a staffing complement of 2 permanent and4 contractual technical staff but required an additional 22 people for its level ofaccomplishments. The lack of personnel suggests that the quality of service ren-dered and other tasks such as monitoring and evaluation must have also sufferedinspite of the remarkable efforts from the current staff members. The overall poormonitoring performance of 18% of ECC-issued projects (see Figure 1-3) validatesthis finding.

The recently issued AO 42 by the President recognizes this organizational weak-ness which subsequently created a regular EIAM division. However, the Depart-ment of Budget and Management (DBM) has yet to favorably act on the request forplantilla positions and operating budget. Moreover, in view of the of the the govern-



ment budgetary shortfall, all contractual positions are to be abolished in 2005. Thiswill leave EIAMD with no personnel except for a few seconded EMB staff andshared personnel from field units of DENR.

Aside from the lack of EMB personnel for M&E functions, there are other concernsidentified during the System Assessment. A tabular summary of the main technicaland institutional findings is shown in Table 1-2.

The institutional and technical concerns have been addressed by this three-volumeHandbook.

b. Capability Assessment

The main findings of the Capability Assessment is that the MMTs and EMB/DENRfield personnel are, with few exceptions in some EMB ROs, not technically quali-fied and experienced to conduct appropriate and scientifically credible monitoringand evaluation studies. In particular, the surveyed persons have difficulty in techni-cal sampling and data processing and almost nil skills in laboratory analyses.However, they are good in preparing reports. This situation indicates that there ismuch to be improved in terms of training. The lack of skills is exacerbated by thepoor logistics support, such as vehicles, field sampling equipment and measure-ment kits, and minimal operational budget for per diems and miscellaneous andincidental expenses.

c. PEISS-M&E Financial Management and Administration

Three of the four current EIA financial mechanisms, namely, ERF, Review SupportFund, and EMF were created to fund activities related to the implementation of theEIS system. EGF, on the other hand, is a mechanism to ensure that the Proponentwill be held responsible or will pay for the prevention, rehabilitation or restoration of,and actual damages to life, health, property, and environment that may be brought



Strength / Good Practice Gap / WeaknessTECHNICAL

1. EIAMD CO initially developed the PEISS

database/ MIS for EIS review, M&E, & adjudi-

cation functions

2. EMB has developed standardized reviewand monitoring forms; and an operationaldocument tracking system3. EMB CO has documented its existingreview and M&E Operational Control Proce-dures for the PEISS4. Most EIAMD RO practice integratedcompliance monitoring with EQD

1. Lack of documented systematic guidelines on

M&E

a. Defining the objectives, coverage & methods for

EMA (only compliance M&E: No baseline M&E,

limited Impact M&E, no environmental audit)b. Criteria for selection and prioritization of projectsfor M&E (driven by public pressure)c. Content & organization of EMoP (no EMoP/poorEMoP design)d. Technical Guidelines for MSP in EMA (M&EMechanics only in MOA, no Manual)e. Review Criteria of Proponent’s performance (lackof M&E technical review criteria)2. PEISS database largely contains project metadataand no interoffice/interagency networking

INSTITUTIONAL

1. EIAMD is systems-oriented, i.e., ISO14001-certified

2. EIAMD/EMB has developed partnershipsand linkages since 1992 (18 MOAs onPEISS + several LGU MOAs)

3. EIAMD CO/RO practice a more defined/detailed system in handling violations thanwhat is provided in the Procedural Manual

4. EIAMD CO/ROs despite limited manpowerand financial resources were able to attainsignificant accomplishments (e.g., processed>20,000 ECCs since 1980)

1. Lack of integrated M&E goal

2. Too centralized functions, inadequate structureand manpower (CO:12 current technical staff vs 21required; R3: 6 technical current vs. 37 required)

3. Lack of definite timelines, authorities, liabilities inresolving complaints/ violation information, and legalprotection to EMB personnel

4. Weak M&E linkaging within and outside DENR

5. No review on the effectiveness of the existing 18interagency MOAs on PEISS implementation

Table 1-2.Summary of Technical and Institutional Aspects of the System Assessment



about by its project or undertaking.

The proponents or the industry can view these financial mechanisms in the follow-ing manner:

:

With these obviously rational behaviors that can be expected of the industry/propo-nents on the various financial mechanisms, the following must be considered inreviewing and assessing the various mechanism: 1) receipts from penalties willeventually become less as the industry or business being monitored becomesaware of the law and sees it more beneficial to comply with the law; 2) as theeconomy improves, there will be more businesses that will apply for clearance; 3)businesses or businessmen are willing to pay reasonable fees as long as they getwhat they need on time or promptly; 4) awareness of the environment and publicparticipation can only increase over time and it is good business sense to betransparent and open to public participation; 5) it is the responsibility of the localgovernment units to monitor industries within their area of jurisdiction; 6) whilecorporate social responsibility is a sound business policy, not all companies are upto facing their responsibilities especially when confronted with potential additionalcost.

The various innovative funding mechanisms were devised to support the properimplementation of the EIS system which has been allocated with limited resourcesfrom the general fund or regular appropriations. It was also a creative way of avoid-ing the legal requirement of depositing all collection with the National Treasury orGeneral Fund and which will not be available for its operations. While the mecha-nisms provided flexibility and enabled the undertaking of the critical pro-cesses in EIS system, it remains remedial in nature. There is still the real needto further strengthen and institutionalize the implementation of the EIS system,funding sources included.

Over the years, the requirements of the EIS system have multiplied. The organiza-tion mandated to implement the system has gone through a number of modifica-

• Paying penalties (source of the ERF) can be avoided if it complies with thelaws (particularly PD No. 984 and 1586), and its rules and regulations;

• Paying a certain amount of fee to hasten the processing of an application forclearance will eventually result in savings and lower total business costs ifsuch will result in shorter processing time;

• The MMT activities (funded by EMF), within reasonable limits, will not onlyimprove relation with the community but will also serve as a confirmation of theinternal or self-monitoring mechanism, which will lessen overall risks in poten-tial damages due to its operations/undertaking; hence lessen the actual chargesthat may be made against EGF or other forms of insurance or financial instru-ments;

• Reasonable expenditures on the education of the community (charged againstEGF) will eventually prevent further damages due to accidents or increase thepool of capable workers, while expenditures on livelihood will enhance or uplifteconomic circumstances that will lessen undesirable/criminal incidences andimprove economic activities within the area.



tions, being transferred from one department to another, merged with other organi-zation, converted from a council to a staff bureau and then line agency. The orga-nizational unit in charge of its implementation started as an ad hoc unit and re-mained such through all these transformations of its mother organization. Admin-istrative Order No. 42, Rationalizing the Implementation of the Philippine EIASystem...was issued on 2 Nov. 2002 by President Arroyo. This AO, aiming toremedy the negative impact of an inefficient implementation of the EIS system onthe country’s economic development, mandated, among others, the conversion ofthe ad hoc EIA unit at the Central and Regional Offices into full pledged division.Given such mandate, it has to be done within the existing budgetary resources andwithin the government system. Hence, even if funds are available through thevarious EIA financial mechanisms, the conversion of the ad hoc unit into “full pledgeddivision” will have to be done without using such funds or funding sources.

Thus, it becomes apparent that while “extra-budgetary” financial mechanismscan provide necessary support and flexibility for operation, they cannotprovide institutional/ organizational requirements, particularly the itemizedpositions and regular budget for operations. Hence, tedious the processes maybe, sustainable funding sources will have to be worked out within the na-tional budgetary and accounting systems.

4. Multistakeholder Participation

The major findings of the assessment of MMT, currently the main mechanism ofmultistakeholder participation in PEISS, are as follows:

• Skewed participation of two stakeholder groups (EMB and Proponent to the detri-ment of the third group (the local stakeholders);

• Stakeholder identification limited to project impact area boundaries;• Confused and inconsistent organizing of MMT ;• Vague expectations as regards MMT functions;• Irregularity of EMB-DENR attendance to MMT activities and as Chair;• Disparate MMT organization and structure across areas;• Lacking substantive provisions in the Pro-forma Memorandum of Agreement;• Dearth of MMT Manual of Operations; and• Unclear public disclosure, complaints, reporting, and IEC guidelines.



C. OVERVIEW OF THE EIA M&A SYSTEM HANDBOOK

1. Purpose, Legal Basis, and Target Users of the Handbook

This Handbook describes the administrative and technical procedures for the applica-tion of the enhanced model for the Environmental Impact Assessment (EIA) Monitoringand Audit (M&A) System in the Philippines for all phases of a project. It providesdetailed instructions to the EMB regulatory staff, project proponents, and stakeholderswho will be the major players in the implementation of the proposed enhanced model.

The enhanced system is part of the EIA Follow-up or Post-ECC Requirements neededto ensure that the projects covered by the EIA system cause no or minimal undesirableor unacceptable impacts on the environment and attain and maintain optimum environ-mental performance. There are however enhancements introduced during the Pre-ECCPhase that set the staging point for an effective Environmental Performance Monitoringand Audit System

The specific purposes of this Handbook are to:

• describe the Enhanced EIA M&A Model as an EIA policy instrument for attainingand maintaining optimum project environmental performance;

• provide administrative and technical guidelines on applying the model for the regu-lated projects under the PEISS;

• illustrate procedures for operationalizing multistakeholder participation; and• elucidate capability building measures to effectively apply the Model.

The Handbook is anchored on several environmental laws and policy pronouncements,namely:

• PD 1152 (Environmental Code) and PD 1586 (basic EIA law)• DAO 96-37 (IRR)• Memorandum Circular on Revised 2nd Edition of the DAO 96-37 Procedural Manual• DAO 2000-05 (Programmatic Compliance EIA)• DAO 2003-14 (PEPP)• AO 42 (2003) and DAO 2003-30 (EIA IRR)• DAO 2003-26 (Ecowatch)• DAO 2003-27 (Self-monitoring Reports) and Procedural and Reference Manual• DAO 2003-30 Procedural Manual

The complete text of these legal issuances may be downloaded from the DENR(www.denr.gov.ph) and the EMB (www.emb.gov.ph) websites.

The primary target end-users are the key stakeholders of the enhanced Model, namelythe EMB officials and staff as the regulatory agency or first party, the proponent orregulated community as the second party, and the local stakeholders (including LGUs)as the host community or third party, and other third-party entities such as the indepen-dent environmental auditor, media, civil society, other concerned sectors and technicalresources engaged in the EIA M&A activities.



2. Organization and Brief Description of the Handbook

The Handbook is divided into three volumes, as follows:

• Volume 1: Introduction, PEISS M&E System and Technical Guidelines• Volume 2: Multistakeholder Participation• Volume 3: Administrative Procedures

a. Volume 1: Introduction and Technical Guidelines

The major topics of Volume 1 are as follows:

• Introductiono Backgroundero Highlights of System Assessmento Overview of the Handbook

• The Proposed Enhanced PEISS M&A Systemo Overview of the Enhanced PEISS M&A Systemo Rationale of the Enhancements The Generic EM&A Process over the Project Life Cycle and EIA Stageso Key Functions of the Project-level PEISS M&A System

• Technical Guidelines for the Preparation of:

b. Volume 2: Multistakeholder Participation


• Nature and Concept of Participation• Stakeholder Identification and Analysis• Formation of the Multipartite Monitoring Team (MMT)• Operationalizing the MMT Monitoring• Environmental Monitoring and Audit Fund Mechanism• Monitoring and Validation Activities• Public Disclosure and IEC• MMT Performance Audit

c. Volume 3: Multistakeholder Participation


• Administrative Procedures for the Review and Validation of following documents:

o Environmental Monitoring and Audit Plan and Manual, including BaselineEMAP/M

o Self-Monitoring Report, including Baseline EMA Report and PEMAPS

o Environmental Monitoring and Audit Plan (EMAP) and Manual (EMAM) ofProponents

o Selfmonitoring Report (SMR) and Baseline Environmental Monitoring andAudit Report (BEMAR) of Proponents

o Manual of Operations (MOO) with Code of Ethics of the Multipartite Moni-toring Teams (MMTs)

o Compliance Monitoring and Validation Report (CMVR) of the MMTso Annual Work and Financial Plan (AWFP) for EIA Monitoring and Audit of

EMB ROs and MMTs



• Administrative Investigation and Enforcement Procedures• EMA System and Performance Audit Protocols

Volume 3 has the objective of providing systematic guidance primarily to DENR-EMB and MMTs on the implementation of the functions of the EMA System.

This Handbook is also applicable to the Proponent as well as to other PEISSstakeholders who may want to undertake an internal review and self-audit of theirEMA plans, reports, and over-all performance against the PEISS standards asprovided for in the legislation, its Implementing Rules and Regulations, and sup-porting Procedural Manuals.

This Handbook provides step-by-step procedures, timelines, delineated responsi-bilities and authorities as well as support forms and criteria to ensure effective andefficient implementation of the EMA functions and proper documentation of theEMA performance. It supports the EMB thrust towards a substantive and progres-sive analysis of the EMA data for the EMA planning, policy enhancements, deci-sion-making and last but not least, for public information towards well-informed andmore meaningful participation in EMA of projects and their environs. The Handbookis, thus, a very practical tool, for the continual improvement of the EMA System.

3. Guidance on Use of the Handbook

The three-volume System Handbook will play a key role in the institutionalization of theenhanced PEISS M&A System. The Institutionalization Action Plan (IAP), a separatereport and one of the major outputs of the SEPMES-PEISS Project, details the pro-posed implementation schedule, the initial phases of which is the timely issuance ofpolicy statements and guidelines and capacity building program especially in the use ofthis handbook.

PEMAPS is one enhancement that may be effected immediately after the initial strate-gic planning and training of concerned personnel without any new policy issuance.EMB regional offices may prepare their annual EMA plans using the results of PEMAPS.Likewise, proponents may begin incorporating PEMAPS and other enhancements intheir SMRs on a voluntary basis while awaiting the new policy issuance.

Another enhancement not requiring policy issuance but EMB approval is the formationand operation of the local MMTs and existing MMTs under the new guidelines initiallyon a voluntary basis initially until the new policy is issued.

o Project Environmental Monitoring and Audit Prioritization Scheme(PEMAPS) Reports of EMB Regional Offices and Proponents



Figure 2-1. PEISS M&A System Framework

II. OVERVIEW AND RATIONALE OF THE ENHANCED PEISS M&A SYSTEM

A. OVERVIEW OF THE ENHANCED PEISS M&A SYSTEM FRAMEWORK

In using the Handbook, it is essential that the reader has full understanding and apprecia-tion of the PEISS M&A System Framework (Figure 2-1) for the following reasons:

1. The System Framework can be used as a common reference for all the stakeholders onhow to view the system from their points of interest and participation.

2. The Framework depicts the M&A System as manageable components or elementswhere specifications depend on the desired level of achievements of the system.

3. The Framework serves as an aid in the analysis of the system’s effectiveness, effi-ciency, and sustainability in achieving its objectives;

4. The Framework situates the proposed areas for enhancements in the system.

The understanding of the PEISS M&A System Framework (Figure 2-1) starts from its core(project-based) functions which include the planning, implementation, and evaluation activi-ties for the selection of the appropriate EMA strategy for the project, processing or prepara-tion of M&A requirements prior to a project’s implementation, the EMA proper at the project-level, the evaluation and subsequent investigation or recognition of the results of EMA. Thesystem management function is necessary to ensure that the entire EMA system is de-signed, constructed, operated, and continually improved to support the core functions. The

PROCESS

(Planning,Implementation

& Evaluation)

1) Core Functions (project-based)

a) Preparation ofPost-ECC EMArequirements

b) EMA Proper(Baseline,Compliance &ImpactMonitoring &Validation)

c) Surveillance ofProjectswithout ECC

d) AdministrativeInvestigationof Issues

2) System Management Functions

INPUT

1. Management Directions

2. Project Profile

3. Project Requirements

4. Process, Procedures

5. Tools

6. Stakeholders

7. Resources

OUTPUT

EMA Plans/Manuals;

EMA institutionalinstruments(e.g., MOA)

EMA Reports;

EMA DecisionDocuments;

Audit Reports;

ProposedSystem

Improvements

OUTCOME

ImprovedProponent /

DENR /Community /

OtherStakeholders’Performance——————

ImprovedProject

Design &Operations—————Improved

StakeholderParticipation

& Partnership——————

ImprovedEnvironmental

Status——————

SustainedDevelopment



system has input, output, and outcome elements, as described briefly below. Feedbacks toeach of the elements trigger the continual improvement in the EMA system.

The input element provides the enabling mechanisms to operationalize the functions of theEMA System. These input elements are comprised of management directions (EMA goalsor target outcomes, policies, legislations, rules and regulations), the consolidated profile ofthe regulated community or projects covered by the PEISS, the EMA project requirements(e.g., monitoring plans, MMT MOA, EGF), the EMA processes and procedures (e.g., for theregular validation, issue investigation, performance audits), tools (manuals, checklists, forms,dataBase systems), stakeholders (e.g., the lead EMA units: the proponent, EMB, and thelocal community, LGUs, other relevant goverment agencies, and the third party auditors),and resources (e.g., manpower, budget, equipment).

The output element manifests the performance against the project-based and system man-agement functions; these are the monitoring plans and manuals prepared, the monitoringreports produced from the monitoring and audit activities and the decisions made based onthe evaluation of the EMA reports.

The outcome element is a measure of the effectiveness and efficiency of the outputs againstthe EMA goals and policies. The actual outcome is the resultant or net compliance andperformance of the projects and the EMA stakeholders after M&E efforts. The outcomes aretargeted to achieve the following goals in an enhanced and sustained manner: a) projectenvironmental compliance and performance; b) project improvement in design and opera-tions; c) social equity/enhancements; d) meaningful public participation and performance inEMA; and e) harmonious partnership among proponent, the public and& the governmentregulatory units.

B. RATIONALE FOR THE ENHANCEMENTS

The specific areas of enhancements and key features of the enhanced Project-level EIAM&A System are presented in Table 2-1. The enhancements derive from the assessmentof the current PEISS M&E practices, the results of which are also presented in Table 2-1.

Other inputs into designing the enhancements included survey of good M&E practiceslocally and globally, recent DENR policy issuances, mainly the promotion of Self-Monitoringand Regulation as well as Environmental Partnership and Community Participation and theadherence to the sustainable development framework.

C. THE GENERIC EMA PROCESS OVER THE PROJECT LIFECYCLE AND EIA STAGES

Figure 2-2 presents the generic EMA process showing the enhancements over the projectlife-cycle from prefeasibility to final design/preconstruction, construction, operation, andabandonment phase and cutting across all stages of the EIA process from scoping to EISpreparation and submission, EIS review, ECC issuance, and post-ECC follow-up phase.Figure 2-3 focuses on the enhanced post-ECC EIA M&A System which shows the relation-ship of the three (3) lead monitoring units - the Proponent, LGU, Community and DENR/EMB, through their EMA plans, manuals, and reports.

What is most significant in the enhanced system is the integration of the EMA concernsand requirements at the prefeasibility project phase and the EIA Scoping Stage. Thus, thequality, extent, depth, frequency, and stakeholders involved in the post-ECC follow-up activi-



AREA OF ENHANCEMENT

PRESENT PROPOSED RATIONALE

A. EnvironmentalMonitoringPlanning:Selection andPrioritization ofprojects formonitoring

Lacks screening andprioritization criteriafor M&E: projectsselected for M&E areusually based onconvenience or publicpressure

1) For the collective setof projects issuedECCs: Application ofscreening usingPEMAPS (ProjectEnvironmentalMonitoring and AuditPrioritizationScheme), a risk-based evaluation andcategorization ofprojects into high-,medium- and low-riskclusters, withcorrespondingappropriate monitor-ing strategies

2) For the project-specific monitoringrequirement: use ofPEMAPS togetherwith the EMB policyon ECP/NECPmonitoring, as basisto determine if theproject will be subjectto EMA and what isthe appropriatemonitoring strategyfor the project

1) Indicates outright theneed for monitoringand correspondingpriority ranking forplanning purposes;

2) Rationalizes alloca-tion of scarce M&Eresources to projectsthat matter to environ-mental quality con-cerns

3) Reduces regulatorypressures on firmscomplying and withgood environmentalperformance trackrecord and those thatdo pose only low en-vironmental risks.

B. Baseline Monitoring

1) Baseline data gathering matrix in Scoping Report :

2) Actual baseline data gathering during the conduct of the EIA;

3)PEISS IRR with no subsequent explicit requirement to the proponent to continue baseline data gathering (“baseline monitoring” ) during preconstruction stage;

4)On a case-to-case basis, some proponents conduct baseline monitoring, and continue such during operations by monitoring “control stations”

1) During ScopingPhase:

Preparation and submis-sion by the proponent of acomprehensive BaselineEMA Plan/Manual(BEMAP/M) to establishgood baseline data, withdue consideration to andintegration of, the otheragencies’ requirements forM&E

2) During EIA Preparation:Recognition that thebaseline data gathering isthe initial baselinemonitoring for the project;

1) Improves scientificreliability ofbenchmarkinformation used insetting perfor-mance criteria forevaluating impacts;

2) Allows identificationof relevantmonitoring stations

Table 2-1. List of Current M&E Practices and Proposed EMA Enhancements.

Accurate baseline pre-vents baseless accu-sation of firms for anenvironmental event ifproven to be due tonatural or externalcausative factors

3)



AREA OF ENHANCEMENT


3) ProjectPreconstruction

(Post-ECC Phase):

Continuation of BaselineMonitoring to be continuedthrough the pre-constructionstage.

Table 2-1. List of Current M&E Practices and Proposed EMA Enhancements(continuation).

C. Environmental Monitoring and Audit Plan / Manual

1) EnvironmentalMonitoring Plan(EMoP) incorporated inEMP but mainlycompliance and less ofimpact monitoring;

2) Uses mainlyshotgun approachand lacks focus andrelevance

1) Replacement of EMoPwith a more comprehen-sive EMA Plan and Manual(EMAP/M) cutting acrossthe project life-cycle, to pre-identify most significantenvironmental aspects andimpacts (SEAI); 2) prioritizethe aspects and impactsthrough the EnvironmentalStressor Rating System(ESRS) and monitor atvarious levels (earlywarning or red alert level,action level, limit /standardlevel) through theEnvironmental QualityPerformance Levels(EQPLs).

1) EMAP/M incorporatesself-monitoring andself-regulation;

2) Reduces technicalmonitoring tasks ofEMB and MMT tovalidation (Focuseswork of MMT todoable tasks)

3) EMB and MMT canopt to confirmproponent’s datathrough anothersampling andmeasurement ofquestionableparameters andsampling stations

4) The normally single sampling by the proponent and mere valida tion by MMT and EMB reduces safeguards costs of proponent

D. Environmental Management Planning

EMoP and EMPapproved during ECCapplication remainmostly unchangedirrespective of monitor-ing results – changeswithin the scope of theexisting ECC areofficially presented anddiscussed only duringMMT meetings but notsubmitted by theproponent to the DENR/EMB. It is assumed thatthe DENR-EMB memberof MMT reflects suchchanges in its assess-ment of the projectperformance over time.

Systematic link of EMP/EMAP/M to environmen-tal management withEMB annual review &approval of updatedEMAP/M and EMP basedon EMA results

1) Ensures EMP,through updates onthe EMAP/M, as aliving document

2) Provides dynamismand relevance toenvironmentalmanagementthroughout the projectlifespan

3) Ensures better environmental performance and lesser financial risks from environmental liability of proponents



AREA OF ENHANCEMENT



Reporting andDisclosure

E. 1) Limited guidelines for quarterly reporting by the proponent and MMT;

2) Monitoring limited to compliance monitoring

3) Poor disclosure of environmental performance or IEC program both by the proponents and by MMT

1) Technical andadministrativeguidelines for theproponent’s semi-annual Self-monitoringReport (SMR) for thePD 1586 module

2) Technical, operational& administrativeguidelines through theManual of Operations(MOO) for the MMT’sSMR-based Compli-ance Monitoring &Validation Report(CMVR), IEC anddisclosure programsand complaintsmanagement by MMT

3) Relevant and transpar-ent review andvalidation of SMR andCMVR throughstandardized andcomprehensiveadministrativeguidelines andprocedures

1) Provides optimumpublic transparencyand disclosure ofEMA informationleading to goodcommunity relationswith proponent andEMB.

2) Nurtures proponents’positive corporateimage and good-neighborly relations

Conforms with inter-nationally acceptedenvironmental report-ing by exporting pro-ponents

3)

MMT Role andComposition

F. 1) Preliminary identifica-tion of stakeholdersand analysis ofparticipation issuesduring the ScopingPhase, through ameaningful process ofSocial Preparation bythe Proponent

2) Delineation of theMMT member roles &functions andrevision of validationprocess to ensurelocal stakeholders’voice is heard anddocumented.

Transformation ofMMT to MultipartiteMonitoring and AuditSystem (MMAS): aProponent and DENR--EMB each comprisingseparate parties, and only

3)

1) There is not enoughguidelines forselection of membersto the MMT and forthe MMT’s administra-tive management ofits operations

2) EMB, Proponent, andlocal stakeholders aremembers of the MMT.Studied MMTs showhigh potential forconflict of interest andsubliminal intimidationof local stakeholdersdue to dominance ontechnical expertiseand administrativemanagement of EMBand proponent.Proponent’s financialclout prone to abuseand to influence MMTcompliance monitor-ing reports

1) Avoids potentialconflict of interest forEMB and proponent;

2) Provides betterconditions forexpressing localknowledge,observations,perceptions, andrecommendations

3) MMT COE screenslocal communitymembers withsincere interests inproviding voluntaryservice for vigilantM&E of projectsMMT MOO providesguidelines for properadministrative man-agement of MMT anddocuments the delin-eation of roles andfunctions of the mem-bers of the reconsti-tuted MMT as

4)



AREA OF ENHANCEMENT



as well as the relation-ship of the memberswith DENR/EMB and theproponent

local stakeholders, civilsociety and NGAsconcerned comprisingthe community-based,reconstituted MMT.EMB continues toserve its regulatory,technical, policyadvisory roles – withadded coaching/nurturing role, whilethe proponent continu-ing its technical role –with the specialrecognition that theproponent is the driverof the Project-basedEMA System throughits EMAP/M and SMRsubmissions, and thesustainer of thefinancial feasibility ofthe MMT throughprovision of the EMF.

Formulation of theCode of Ethics andEMAP-based MOO forthe reconstituted MMT;

Capacity- buildingprogram for reconsti-tuted MMT, proponentand DENR/EMB fortheir tasks under theenhanced MultipartiteEMA System

4)

5)

FinancialManagement andSustainability

G. 1) Sampling andmeasurement tasksconstitute the mostexpensive part ofthe MMT monitoringbut merelyduplicates theproponent’s self-monitoringunnecessarilyProponent, orExecom, of whichProponent is amember, managesEMF/EGF: PEISSM&E System

2)

1) Sampling andmeasurements to beregularly done only byproponent; MMT andEMB to normally doonly validation, and onspecial cases,confirmatory samplingto be undertaken forquestionable data and/or validate complaints.

2) Revised guidelines onsetting up, disburse-ment and overallmanagement of EMF

1) Reduce unneces-sary tasks andwastage of financialresources ofproponents;

2) Timely and efficientrelease of funds toMMT work

3) Train local commu-nity to be responsibleand learn to beaccountable forentrusted fundsAvoids unneces-sary proponentcosts demanded by

4)

Current roles are:1) DENR/EMB provides

direction on policy, acts asChairman and Secretariat,leads sectoral sampling,provides technical advice,leads in discussions andsometimes drafts the MMTreports. (However, thesefunctions and roles areconsistent with the role of theDENR/EMB, as described inthe PEISS IRR).

2) Proponent providesmonitoring funds, equipment,logistics, shares technicalexpertise in the conduct ofsampling for MMT’s impactmonitoring, assists the EMBin leading the discussionsand assists the secretariatdraft the MMT reports.(However, these functionsand roles are not necessarilyinconsistent with the role ofthe proponent as described inthe PEISS IRR).

3) Local stakeholders in theMMT are supposed toserve as the voice, eyesand ears of the commu-nity in monitoring theenvironmental perfor-mance of the proponentagainst the ECC and EMP.However, the process ofsampling / monitoring,discussions / delibera-tions, drafting the report,disclosure, and IEC do notshow or document theindependent observationsand independent processof deliberations of thecommunity.



AREA OF ENHANCEMENT



5)

MMT if not in the ap-proved AWFP

3) Fund administrationby professional (oneof the qualifyingmember organizationsof the local stake-holder members ofthe proposedreconstituted MMT);

4) Disbursement basedon approved AWFP;

MMT allowed fund-raising activities

Assessmentshows slow andinadequate releaseof funds by theproponent orExecom

ties have been predetermined, costed, and allocated with the proper institutional support bythe proponent during the EIS Review process. The Proponent serves as the driver of theEMA process— through the Proponent’s preparation or submission of EMAP/M and SMRfor the review and validation of EMB and the community MMT for projects with MMT require-ments. (Note: For other projects with no MMT, the current (DAO 03-30) requirement of athird party auditors’ report will be adequate as the basis of the EMB for evaluation of theproponent’s environmental performance.).

As the principal stakeholder of the enhanced EMA System, proponent’s self-monitoringshould be comprehensive, relevant, and scientifically credible. Thus, selfmonitoring will beguided by an EMAP and EMAM to be prepared by the proponent according to the guide-lines in this Handbook and reviewed and approved by EMB. The implementation of EMAP/M will result in the periodic preparation and submission of SMR by the proponent to EMB.

EMB may use additional information provided by MMT through the latter’s semiannual Com-pliance Monitoring and Validation Report (CMVR) as well as periodic audit reports, if deemednecessary. Under normal conditions, only the proponent’s self-monitoring will involve highlytechnical and costly work such as sampling and measurement of environmental media andreceptors. Validation by EMB and MMT may involve confirmatory sampling and measure-ment under certain circumstances, but in general, the enhanced Model relies mostly on theveracity and adequacy of the self-monitoring data to properly evaluate the project’s environ-mental performance. It is therefore expected that the self-monitoring focus of the enhancedmodel will avoid unnecessary duplication of expensive sampling and measurement effortsand prove to be more cost-effective than the current practices.



Figure 2-2. Generic Simplified EMA Process over theProject Life-cycle and EIA Stages.

DOCUMENT PREPARATION ANDSUBMISSION

Ø Project Description with BEMAP/M, M&E Re-quirements Checklist for reference in screen-ing and scoping, preliminary PEMAPS ratingby Proponent

Ø Scoping Report with BEMAP/M and M&E Re- quirements Checklist, List of Stakeholders &

Participation Issues

EIS with EMAP/M with SEAI, ESRS & EQPLwithin the EMP for all project phases (i.e, Pre-Construction, Construction, Operation and, Aban-donment); EIS w/ confirmed PEMAPS rating, fi-nal sectoral stakeholder list & issues

Ø

Ø Formation & Operationalization of the Commu-nity MMT; Generic & Detailed MOA signing

Ø Pre-construction Baseline EnvironmentalMonitoring Report

Updated EMAP/M for Construction/ Opera-tion (CEMAP/M /OEMAP/M), for significantchange in design/operation within ECC cov-erage

Ø

Abandonment EMAP/M, if project is termi-nated

Ø

Community MMT

• Reviews EMAP/M for comments& to prepareMMT MOO: sub-mits MOO to EMB

• Validates SMR,prepares andsubmits CMVRto EMB Prepares

Proponent EMB / RevCom /MACOM

D E N R /EMBProject

Stage inthe PEISS

Project Pre-FS;EIA Screening &Scoping

Project Pre-FS/FS;EIS Preparation,Review andECC Issuance

ProjectImplementationandEnvironmentalPerformanceM&E

ProjectAbandonment;EIA Monitoring &Closure



D. KEY FUNCTIONS OF THE PROJECT-LEVEL EIA M&A SYSTEM

In summary, the Enhanced EIA M&A System consists of four data gathering functions onthe environmental performance of development projects, namely:

• Baseline Monitoring – undertaken for the purpose of establishing a solid environmen-tal profile of the baseline or similar control environment as reference for comparison ofchanges due to the project or natural causes. This is done by the proponent during theEIA, and continued after ECC issuance up to preconstruction phase. In the case ofcontrolled stations, monitoring may be done throughout the project lifespan and evenafter abandonement as in the case of landfill sites and other “brownfield” sites.

• Compliance Monitoring and Validation– undertaken for the purpose of establishingcompliance with the ECC conditionalities and EMP commitments, which include theEMAP/M. This is done by the proponent at all phases of the project from preconstruction,construction to operation and abandonment. This is also regularly done by MMT thusits witnessing, authentication or confirmatory sampling. MMT validates the proponent’sSMR, with at least twice a year reporting of its findings through its CMVR.

• Impact Monitoring – undertaken for the purpose of determining actual impacts causedby the project on the receiving environment. This is also done to monitor residual andcumulative impacts due to the project. This monitoring is conducted by the proponent

Figure 2-3. Enhanced Multipartite Monitoring and Audit System



III. PEISS M&A STAKEHOLDERS, ROLES AND RESPONSIBILITIES, AND GENERALREQUIREMENTS

A. DESCRIPTION OF THE EIA M&A SYSTEM OF THE THREE LEAD EIA M&ASTAKEHOLDERS

The overall manager of the PEISS M&A System is EMB as the mandated regulatory agency.However, the proponent plays a major role as the source of potential environmental stres-sors, impacts, and interventions that are subject to regulation and other forms of manage-ment actions. The host local community, on the other hand, by virtue of its approval of theproject’s operation in its jurisdiction, stands to directly or indirectly benefit from the project,but in the process, it also will be the receptor of the potential impacts likely to arise from theproject’s construction and operation. Descriptions of their unique EIA M&A Systems are asfollow:

1. Proponent-Based EIA M&A System

The enhanced EIA M&A System is predominantly proponent-driven, primarily triggeredby the proponent’s self-monitoring function as manifested by the preparation of EMAP/M and SMR submissions to DENR/EMB. The project proponent is expected to makeinvestments in M&E as a tool for assuring that its committed environmental manage-ment plan will be implemented effectively and periodically calibrated according to theresults of the M&E to improve environmental performance. Investments in M&E aredeemed internal costs or overhead of the project and not of society and government.

The proponent-based EIA M&A System includes its internal policies, objectives andtargets for M&E, its internal processes and procedures which may be embodied in anEnvironmental Management System (EMS), for implementation by its environmentaland social institutional unit (i.e., environmental staff or internal auditors) which canaccess M&E experts/consultants and third party auditors to heighten the quality andpractice transparency in its M&E. The proponent who is proactive in its M&E programnormally would also have as part of its system, the necessary tools and resources foran effective and efficient management information system, reporting, and communica-tions and disclosure system and other management functions which ensure continual

during construction, operation, and abandonment phases. This can also be periodicallydone by MMT and EMB, although the skill required to interpret the data is more appro-priate for experts. Thus, this implies the need for MMT to access the services of ex-perts, preferably from the local community, if available, and for EMB to first access thesectoral regulatory units within DENR who have expertise and mandate over the areasof concern, or to avail of the pool of auditors accredited by or registered with DENR,Board of Investments or any internationally recognized registration body.

• Project Environmental Performance Audit – undertaken by accredited environmen-tal auditors or registered EMS auditors. The auditors may be direct-hired by the propo-nent or through MMT.



The rural landscape of the community hosting the Mak-ban-PGI geothermal power plant in Bay,Laguna.

improvement without necessarily incurring excessive cost. Part of the proponent-basedEIA M&A System is its linkaging with other stakeholders. The ideal proponent-basedEIA M&A System would normally value continuing guidance and support to a commu-nity-based multi-stakeholder M&E team towards capacitation to carry out various EMAfunctions, self-sustenance, mutual trust, and buildup of harmonious partnership acrossthe project life.

The tools to be used by the proponent in the conduct of its self-monitoring are dis-cussed in detail in this volume– Introduction and Technical Guidelines. For the propo-nent to be knowledgeable of its EMA role with respect to the community stakeholders,the guidelines are provided in Volume 2 of the Handbook. With respect to the prepara-tion of the proponent for the review and validation of its outputs by the regulatory agency,Volume 3 provides the proponents with the guidance on the review of its EMAP/M,SMR, PEMAPS-rating, investigation of issues raised against the proponent and proto-cols for system audit which are applicable to any of the project stakeholders.

2. Community-Based EIA M&A System

The multistakeholder participation in the enhanced EIA M&A System limits the involve-ment to the local community representatives. The proponent and DENR/EMB, by virtue



of the redefined roles of the latter two sectors as the entity subject to regulation (propo-nent), and the regulatory entity evaluating the performance of both the proponent andMMT are exclued.

The community-based EIA M&A System has the primary function of serving as thepeople’s eyes, noses, and ears on events and issues likely to affect the community. Itshall be the public voice through which advisories and other project environmental infor-mation can be released and disseminated to the public-at-large. It shall be the people’sconscience in following through and investigating any complaint lodged before it byanyone and referring its initial findings and recommendations to the proponent andEMB for appropriate action.

Its LGU member, through its independent mandate as enforcer of environmental laws,can immediately enforce temporary mitigating and contingency measures to protectpublic and environmental safety while EMB validates and investigates adverse situationfor more permanent and long-term resolution of the case at hand. The reconstitutedMMT serves as the early-warning mechanism of impending environmental pollution andthreat to public safety due to project operations.

MMT through the guidance provided by the Environmental Quality Performance Levels(EQPLs) in the Proponent’s EMAP/M, will provide the local community with a laymanizedpicture of the project environmental condition before the situation becomes worse orviolative of environmental standards. This is made possible with the MMT’s use of pseudo-indicators of pollution such as perceptible odor, color, dust, noise, fish kills, and croploss which can be correlated with specific range of EQPLs.

The elements of the community-based EIA M&A System are generally the same as theproponent’s, with differences only in the specifications of the community M&E targets,its procedures, its institutional and administrative arrangements which are all embod-ied in the proposed Manual of Operations (MOO) described in Volume 2 of the Hand-book. The community is guided by Volume 1 on the technical basis, scope andlimitations of its EMA tasks while Volume 3 provides the community-based EIA M&ASystem with guidance on the administrative procedures for its review and validation ofthe proponent’s EMA documents and reports.

The community-based EIA M&A System is linked with that of the proponent throughthe M&E superordinate goal of promoting project and stakeholder performance, andimproving environmental status while ensuring sustained project operations and devel-opment in a manner that promotes public participation and partnership with the propo-nent.

3. EMB-based EIA M&A System

The EMB-based EIA M&A System is comprised of the functions of a) review andvalidation of the EMA documents and reports of both the proponent and the community-based MMT, b) administrative investigation of the issues and complaints, and c) con-duct of system and performance audits of any stakeholder or partner of DENR/EMB inEMA. All the necessary tools (e.g., review forms, field validation forms, complaintsinvestigation report form, system audit forms and checklists) have been provided inVolume 3 of the Handbooks. The criteria for the review of the EMA documents are



contained in the Volume 1 and Volume 2 of the Handbook.

EMB is mandated to implement and manage the PEIS System law and is thereforeprimarily responsible for ensuring that all projects covered by the PEISS do not signifi-cantly impact the environment and are continually improving in environmental perfor-mance. In carrying out this mandate, EMB shall equip itself with monitoring informationgathered on its own, the proponent’s self-monitoring reports, third-party validation suchas that of the MMTs and independent auditor, and general inputs from the public suchas investigation results due to complaints.

Being proponent-driven, EMB is not obliged to conduct regular sampling andmeasurement activities except when there is a need to validate the proponent’smonitoring reports or third-party audits or validation reports, or when reliabledata are required for complaint validation, for noncompliance issue resolution,litigation, and adjudication, and for scientific research and educational pur-poses.

B. ROLES AND RESPONSIBILITIES OF STAKEHOLDERS OF THE ENHANCED PROJECT-LEVEL EIA M&A SYSTEM

The three lead EMA units – proponent, community MMT, and DENR/EMB – are supportedby other key actors in the enhanced EIA M&A System such as the pool of experts whoassists EMB in the review of EMA requirements during the EIS review (the RevCom) andoptionally, during the post-ECC review of EMA documents, the Monitoring & Audit Commit-tee (MACOM). DENR/EMB is also assisted in its EMA functions by the sectoral regulatoryunits (SRUs) who have direct mandates over the project (e.g., EQD on RA 6969, 8749; FMBon forestry, DAR on “carpable” areas (e.g., under CARP), LGUs on social development andemployment programs). The public-at-large is also considered a key actor since feedbackto the regulatory agency on the performance of the proponents and of other sources outsidethe PEISS M&A System are received by the lead M&E units through them.

The respective roles and responsibilities of the key actors are presented in Table 3-1.

C. SUMMARY LIST OF TECHNICAL ENVIRONMENTAL DOCUMENTS / REPORTS TO BEPREPARED BY THE KEY ACTORS

Table 3-2 presents the list of EMA documents that are expected to be produced or used bythe key actors in carrying out their specific roles and functions. These documents can beclassified into three types namely: (1) regulatory requirement, (2) procedural tools, and (3)output documents. Regulatory documents are those that are required from the Proponent orMMT as a prerequisite of a certain EMA policy. Procedural tools on the other hand, arethose that are used by EMB to facilitate the EMA processes and procedures such as forms.Output documents are those resulting from the conduct of a certain EMA activity such asreview and validation (refer to Volume 3 for details).

Pursuant to the enhanced EIA M&A System, the proponent is required to prepare (in-houseor outsourced) and submit for EMB approval the following documentation:

• Baseline Monitoring Plan, Manual and Report(s)• EMAP/M



• reviews revised EMAP/M and EMA Reports,when deemed necessary by the EMB

Table 3-1. Roles and Responsibilities of the Stakeholders of the EnhancedProject-Level EIA M&A System.

Key Actor

1) EMB Central Office • the regulatory agency tasked to manage the entire EMAprocess from pre-ECC/project feasibility phase to post-ECC/project operational to abandonment phase;

• specifically, EMB CO supervises the implementation of M&Erequirements during the pre-ECC phase

• preliminary assessment of issues for referral to EMB ROsand management of the appeal process

PEIS system management at the national level on effective-ness, efficiency, and sustainability of the system: undertakessystem and performance audits of EMB RO, and its M&Epartners such as MMTs, LGUs, among others.

•

2) EMB Regional Office• the regulatory agency tasked to supervise the implementa-

tion of the EMA process and performance of the variousstakeholders from post-ECC phase to project operations/abandonment for ECPs whose ECC’s were issued by theDENR Central Office; handles all M&E requirements at allphases of the EIA process for downloaded ECPs (i.e., forinfrastructure), and NECPs

• detailed assessment and investigation of issues referred to it by MMT, EMB CO, LGUs, other sources of complaints

• PEIS system management at the regional level on effective-ness, efficiency, and sustainability: undertakes system andperformance audits of the EMB ROs, and its M&E partnerse.g., MMTs and LGUs, within the region

3) Proponent • the regulated entity to submit all required the EMA docu-ments i.e., EMAP/M, SMR, response to NOV, compliancereport on Case Decisions, among others.

• fund provider to MMT

• trainor to the community MMT on technical aspects of the EIA M&A System

General Role and Responsibility in EMA

4) EIS Review • body of internal and/or external experts designated by DENR to review EIS, including the enhanced M&E requirements

5) Monitoring and Audit Committee (MACOM)

To MMT: technical and policy resource person, coach and nurturer,trainor and supervisor

•



Table 3-1. Roles and Responsibilities of the Stakeholders of theEnhanced Project-Level EIA M&A System

(continuation).

Key Actor General Role and Responsibility in EMA

6) Multipartite Monitoring Team (MMT)

Autonomous body to review and validate compliance byproponent, and a mechanism for public participationserving as a focal body for meaningful public participationand for public disclosure of the proponent’s performance,including investigation of issues on likely nonconfor-mance on ECC/EMP commitments

7) Third-party Auditor Independent Environmental Checker, for optional third-partyvalidation of M&E Reports and for conduct of third partyPerformance Audits

8) Other agencies/ entities /sectoral regulatory units (SRUs)

• conduct actual monitoring on parameters within their M&Emandates;

• provide proof of proponent’s compliance to EMB on theSRU’s respective permits/requirements pursuant to theirenvironmental-related mandate;

9) The wider public and the host local communities

• review/comment on EIS, including the enhanced M&Erequirements;

• lobby for societal and community welfare and rightfulshare in the fruits of development; inform EMB of anyviolation on PEISS rules and regulations including theECC;

•

provide EMB with list of M&E requirements for use in screening and scoping of all project for M&E requirements

•

assist the regulatory agency in ensuring project’s compli ance to cease orders and other resolutions.

•

•



• Decision on Appeals

Information received

• EIS Review and Approval Report

• PEIS System Audit Report

Initial Assessment Report on Violation

KEY ACTOR TECHNICAL ENVIRONMENTALDOCUMENT PREPARED

RECIPIENT OFDOCUMENT

EMB RO, Proponent

EMB ROs, Propo-nent, Complainant

EMB RO, Proponent

EMB CO, EMB ROs

1) EMB Central Office

2) EMB Regional Office

EIS/IEE Review and Approval Report•

•

•

MMT Performance Audit Report

SMR Field Validation Report

• Complaint Field Validation Report

• Technical Hearing Report

• Case Decision Document, i.e., CL or NOV

• Decision on MFRn Report

• Case Documentation Report

• Case Proceedings Report (Feedback)

EMB RO, Proponent

EMB CO, cc: MMT andProponentEMB RO

EMB RO, cc: Proponent

and Complainant

EMB RO

Proponent, cc:

Complainant

Proponent

EMB RO

Complainant/ Public

3) Proponent • Scoping Report with BEMAP/M

• EMAP/M for all project phases

• SMR

• Response to Notice of Inquiry

• Compliance Report on Case Decision Document

4) MMT • MOO

• CMVR

• Complaint Validation Report

• Public Disclosure EMA Report

EMB RO, cc: to Proponent



Public

EMB CO/RO

EMB CO/RO and MMT

EMB CO/RO and MMT

EMB RO

EMB RO, MMT, otherparties concerned

Table 3-2. List of Technical Environmental Reports to be Prepared by the KeyActors under the Proposed Enhanced PEIS EMA System.

•



Table 3-2. List of Technical Environmental Reports to be Prepared by the KeyActors under the Proposed Enhanced PEIS EMA System (continuation).

1. Baseline Monitoring and Audit Plan and Manual (BEMAP/M)

The Baseline Environmental Monitoring and Audit Plan (BEMAP) and Manual (BEMAM)are the initial documents prepared and submitted under the enhanced M&E Model.These documents are ideally prepared during the Scoping Phase of the EIA Study andsubmitted with the Scoping Report. BEMAP forms part and is subject to the sameapproval process as the Scoping Report. BEMAP shall cover the monitoring periodrequired by the EIA study and shall continue as long as possible until the proposedproject activities are expected to physically change the environment such as earthmovingduring the construction stage.

BEMAP selects the potential critical environmental issues to monitor from alonglist of issues identified during various stages of the Scoping Process. BEMAPwill define the monitoring needs, objectives and targets, location, and respon-sibility center, among others. BEMAM, on the other hand, will elucidate thedetailed actions for implementing BEMAP.

Baseline monitoring is needed because it will provide the basic information about theoriginal, natural or preproject or no-project environmental characteristics, processes,and trends. The baseline monitoring results will provide an estimation of the vulnerabil-ity of the various environmental components to environment-relevant project aspects.Such baseline data are essential inputs to the EIA study, particularly for impact identi-fication, prediction, and evaluation as well as generating environmental managementoptions.

Baseline monitoring will identify other potential natural or man-made environmental stres-sors in the vicinity. The baseline data will also serve as the benchmark or reference

5) EIS Review

Committee

6) MACOM

7) Auditor

8) SRUs

9) Public

KEY ACTORS RECIPIENT OFDOCUMENT

• EIS Review Report, i.e., EMP

• EMAP/M Review Report

• 3rd Party Audit Reports

• Sectoral M&E Reports

• PEISS Violation Information

• Compliance Monitoring Report

EMB CO/RO

EMB CO/RO

EMB CO/RO

EMB CO/RO

EMB CO/RO

EMB CO/RO

w/ EMAP/M

* Forms are provided in Volume 3 for the various technical environmental document

TECHNICAL ENVIRONMENTALDOCUMENT PREPARED



Joint proponent and MMT ground water sampling station survey at MIRANT- Pagbilao in QuezonProvince.

point for detecting future changes and for comparing such changes in the environmentalconditions as influenced by project activities under the “with-project” scenario. In thismanner, baseline monitoring will allow attribution of significant environmental changeeither to natural fluctuation or to the project or to other causes.

More importantly, the baseline data will form the basis for determining the EQPLs forthe project which will be used as decision criteria during the environmental audit as wellas forward environmental management planning of the project. The environmental qual-ity performance levels will initially be approved during the ECC review stage and may bemodified as new information accumulates and necessitates review by EMB.

2. Environmental Monitoring and Audit Plan and Manual (EMAP/M)

EMAP is submitted with the EIA document upon application of the proponent for issu-ance of an ECC. EMAP shall describe the proponent’s commitments, objectives,strategies, and measures to track environmental aspects and impacts of the project.Thus, in conjunction with appropriate environmental management measures in EMP,the proponent ensures that negative residual impacts are avoided, if not, minimized topredetermined acceptable levels. On the other hand, positive impacts of the project areexpected to be enhanced though EMP and EMAP.



Opening of a secured borehole by a MIRANT-Pagbilao technical staff for the joint proponent and MMTground water monitoring.

EMAP shall present the justification for selection of critical environmental aspects andimpacts (EA&I) and other issues and concerns to be monitored. EMAP shall alsocontain indicative Work and Financial Plans for the EM&A activities and commitments,such as the establishment of an Environmental Monitoring and Audit Fund (EMAF) andMMT as well as building in-house capacity for environmental management includingmonitoring and audit.

It is ideal for EMAP to already contain the action plan for the Detailed Design Phasebeforehand. This can take into account any later changes in the final design, whetherthese are modifications, additions or deletions in materials, processes, products, loca-tion, and construction scheduling, that may affect the project’s EA&I and consequentlyits EMP and ECC.

EMAP is reviewed with the other EIA documents during the ECC processing stage.The reviewers from EMB, RevCom or MMT may comment and provide inputs towardmaking EMAP a better tool for achieving optimum environmental performance by theproject. EMAP is approved during the ECC processing stage and made an integral part



of the ECC conditionalities, if the project is issued an ECC.

Should there be significant changes in project design but still within the gen-eral approved terms and conditions of the ECC, the attendant EMAP must bemodified and submitted to EMB for approval before construction can be initi-ated.

EMAM details the aspects, arrangements, requirements, and actions to be un-dertaken by the proponent to effectively implement and attain the objectives ofEMAP. It will serve as the guide for the proponent in carrying out its commitment underECC to comply with its EMP and ECC.

EMAP and EMAM may be amended during the course of project operations shouldmonitoring results indicate the need thereof.

The technical guidelines for preparing EMAP and EMAM are in Chapter IV.

3. Self-monitoring Report (EIA Module)

a. Baseline Environmental Monitoring and Audit Reports

BEMAR present benchmark information gathered on the preexisting environ-mental conditions, that is, collected on a continuing basis commencing during theEIA baseline studies and lasting until the physical start of project construction andother activities causing environmental changes. As described earlier, the baselineenvironmental conditions once properly established serve as a scientifically validbases for determining the significance or insignificance of environmental changesby setting environmental performance thresholds for red-flagging, action and limitlevels.

BEMAR may also provide information gathered on “controlled environmentalcomponents”, if the project’s BEMAP and BEMAM have directed so. The con-trolled environmental components or systems are selected portions of the environ-ment which are similar to or representative of the components or systems likelyaffected by the project and shall serve as the undisturbed or natural conditions ofthe environment but not impinged upon by the project’s EA&Is. Controlled environ-mental components are therefore selected to allow tracking of natural fluctuationsand trends in the environment and provide reference point for evaluating project-affected environmental changes.

BEMAR may also describe reference environmental sites which similar to the “con-trolled environmental components” are selected to reflect the “with project” and“without project” conditions. An example of a reference environmental point orstation is the segment of a river located before an end-of-pipe outfall. The referencestation will be compared with the selected environmental characteristics at theoutfall and downstream of the outfall. Statistically significant differences in themonitoring results of these stations (upstream, at and downstream of outfall) willallow the determination of any project impact, if any.

Introduction, PEISS M&A System & Technical Guidelines


Inspection of the air quality monitoring station by MIRANT-Pagbilao together with its MMT.

b. Periodic Self-monitoring Reports

The results of the compliance and impact monitoring will be compiled by the propo-nent on a weekly or monthly basis, depending on management preference, andconsolidated in a quarterly SMR to EMB.

SMRs are quarterly reports submitted by the proponent under DAO 2003-27. DAO2003-30 requires a semiannual submission of self-monitoring reports with respectto the proponent’s compliance to PD 1586 which is an integral part of the SMR asthe EIA Module. The EIA module of the SMR can serve as a summary for the othermodules as EIA by its nature cuts across various regulations. It shall ideally reviewthe results, findings, recommendations, and actions of the various SMR modules inthe past quarters. The SMR’s fourth quarter data shall be compared with the previ-ous three quarters and on this basis, the EIA module of the fourth quarter SMRshall conclude key issues in EM&A with the planned objectives, strategies, andactions for subsequent monitoring, if EM&A activities are still further warranted.Noncompliances and exceedances in the project’s environmental performance shouldbe addressed with appropriate revisions in the EMP. The EIA module of the fourthquarter SMR shall also contain the EM&A Work and Financial Plans for the follow-ing year. Any revision in EMAP/M and EMP should be highlighted. The annualreport will be reviewed by EMB and, as needed, its EIA Monitoring and Audit Com-mittee (MACOM).

PEIS and granted ECCs which account to more than 20,000 nationwide. Moreover, thecurrent ad hoc practice of monitoring mainly in reaction to public pressure or controversydoes not guarantee an efficient use of the limited resources in attaining optimum environ-mental performance. It is therefore useful to develop an objective and rational system ofprioritizing progress to monitor.

This Handbook presents an enhanced prioritization and selection scheme to obtain moremeaningful monitoring information. This information serves as a gauge in accomplishing andbasis for corrective actions in executing monitoring plans improving monitoring system. Therisk-based scoring system called the Project Environmental Monitoring and Audit PrioritizationScheme (PEMAPS) can be situated as an input in the planning function of the M&E cycle.The M&E cycle can be simply viewed to involve planning, implementation, monitoring, andevaluation. As shown in Figure 2-1, the planning tasks may start with the formulation of theEMB M&E policy or mandate from which M&E goals and targets can be set, in consider-ation of M&E goals from other DENR offices, and the super-ordinate goals of DENR itself.Thereafter, the projects can be selected and prioritized, preferably synchronized with theproject list of other monitoring units within and outside the DENR. From the shortlistedprojects, annual work and financial plans and monitoring strategies can then be formulatedbased on the available resource mix. The planning inputs are the Major Final Outputs (MFO’s),the most critical regional environmental issues, and the project profiles to where the PEMAPScan be specifically applied.

For this purpose, PEMAPS may be used. PEMAPS was taken up from a risk-basedmethodology called National/Regional Industry Prioritization Scheme (NRIPS) developed atEMB but remained unused. The scheme may be employed to rank all the projects coveredwithin PEIS according to the potential risks on environment and human health and welfare.The ranking will be the basis for categorizing the projects into three groups:

• High environmental risks• Medium environmental risks• Low environmental risks.

Each category will correspond to a specific mix of EM&A strategies and varying levels ofintensity as illustrated in Table 3-3.

To facilitate the conduct of environmental evaluation and monitoring, the particiapation of theProponent in data gathering is critical. Because the Proponent is abreast with project ope-rations he can provide some information as asked in PEMAPS (Appendices 1a-b) withwhich EMB will be using as part and parcel of the scoresheets for the conduct of environ-mental evaluation and monitoring prioritization.

T

D. SELECTION AND PRIORITIZATION OF PROJECTS FOR MONITORING

Given the limited resources, it is not possible to monitor all the projects covered by the

Introduction, PEISS M&A System & Technical Guidelines




Table 3-3Sample Risk-Based Environmental Monitoring and

Audit Strategy Selection Matrix.

PotentialRisk

(Based onPEMAPS

score)

High(70-100points)

Medium( 4 0 - 6 9points)

Low( 1 - 3 9points)

Surveillanceand

InspectionCompliance Monitoring Impact

MonitoringPerformance

Audit

Desk Field Party PartyDesk Field

X X X X X X X X X X

X X X X X X X X X

X X

The PEMAPS criteria used for project prioritization and the mechanics and worksheet for applyingPEMAPS for EIA M&A are in Appendix 1.

EMBEMB EMB EMB EMB EMBMMT MMT

3rd 3rd

Environmental Monitoring and Audit Strategy



IV. GUIDELINES FOR PREPARATION OF BASELINE ENVIRONMENTAL MONITORING AND AUDIT PLAN AND MANUAL (BEMAP/M) AND ENVIRONMENTAL MONITORING AND AUDIT PLAN AND MANUAL (EMAP/M) BY PROPONENT

A. NATURE AND PURPOSE

1. Baseline Environmental Monitoring and Audit Plan and Manual

Baseline environmental monitoring and audit refers to sampling, measurement,and evaluation of activities to determine with sufficient credibility and reliability the am-bient environmental conditions of the influence area of a given project. Thedata collection is initiated at the outset of the project cycle. The longer the measure-ment period, the more credible and reliable are the time-series data to set the bench-mark or reference conditions.

Baseline environmental monitoring and audit by its nature will identify all significantpotential natural or man-made environmental stressors in the vicinity. Aside frombeing able to compare environmental changes caused by project activities, baseline moni-toring will also allow for such changes either to natural fluctuation or to other causes,

man-made or natural. This is essential to the development of EMAP/M as a comparativebasis between conditions obtaining in “with” and “without” project scenarios.

The baseline monitoring data is critical in determining the environmental im-pacts of a project. Baseline monitoring will provide an estimation of the vulnerability ofthe various environmental components. This is essential in impact identification, predic-tion, and evaluation as well as generating environmental management options.

Without a properly conducted and scientifically defensible baseline monitoring regime,the basis for all succeeding monitoring endeavors will be prone to errors with the analy-sis resulting as a subject of doubtful validity and short of properly approximating empiri-cal environmental condition.

This monitoring can either be time- or geography-bounded. Time-bounded samplingtechnique takes into account environmental conditions before project constructionand operation. Once a project is established and operating, all monitoring activities willalready show the effects of the project and will no longer show the “natural” environmentor the “without project” scenario.

Geography-bounded sampling technique accounts samples from an area that isnot affected or is not within the impact zone of the project. For example, ambient airmonitoring baseline data can be taken upwind from a project such as a cement plant orin the case of water, upstream of the river where a wastewater treatment plant dis-charges its effluent. However, in all cases the monitoring stations selected must be

PART 2: GUIDELINES IN IMPLEMENTING ENVIRONMENTAL MONITORING AND AUDIT AND REPORTING SYSTEM



intrinsically linked to the scoping process and should be prepared at this process andsubmitted as part of the scoping report. It is during the scoping process that significantimpacts and environmental risks are identified. The range of issues, actions, alterna-tives, and impacts including the direct impact area and any secondary impact areasthat need to be included in EIS are defined, identified, and agreed upon during thisstage. The scoping process determines the coverage, focus, depth, and the extent ofEIA and the basis for its review. As such, this subprocess is the basis for identifying theparameters and the stations for collecting baseline information and for all future moni-toring activities.

Moreover, BEMAP, particularly its built-in tool of Environmental Stressor Rating Sys-tem (ESRS), can be particularly useful in evaluating the identified scoping issues,thereby filtering out insignificant ones. Once the critical environmental issues areidentified, the monitoring objectives are easily determined. But more importantly, theidentified critical environmental issues and concerns will guide the scope and focus ofthe EIA study proper and consequently be addressed in the crafting of the Environmen-tal Management Plan (EMP) of the EIA document.

BEMAP/M also provide additional inputs to the EIA report itself, since baseline informa-tion also needs to be presented in this report. The EIA report will focus on the identifiedcritical impacts from the scoping report, the scientifically selected monitoring stationsin BEMAP/M, and the presentation of baseline information in BEMAR.

BEMAM is derived from BEMAP. BEMAM provides more details on the baselinemonitoring activities and discussions of the selection of monitoring locationsand the methodology (including specific sampling and measurement procedures andequipment, QA/QC procedures, reporting formats, among others.) that will be usedduring the monitoring exercise. BEMAP will also define the monitoring needs,objectives, targets, location, and responsibility center, among others. The Manual,on the other hand, will elucidate the detailed actions for implementing BEMAP.

BEMAP shall cover the monitoring period agreed upon in the scoping process and shallcontinue as long as possible until the proposed project activities are expected to physi-cally change the environment such as earthmoving.

BEMAP and the BEMAM may be submitted together as part of the scoping report. Itwill also form part of the EIA report as an attachment, together with the Baseline EMAReports prepared during the EIA study proper. It will be reviewed as part of the scopingreport and as part of the EIA report (scoping report is attached to the EIA report) todetermine if it is sufficient to meet the needs of the baseline monitoring for that particu-lar project. Reviewers of the scoping report and BEMAP/M should ensure that theinformation presented is technically adequate for the specific project and follows thescoping process appropriate for the project.

comparable to the natural state (without project) of the area where the project wasconstructed, and thus can be called as a control station for future monitoring activities.

The Baseline Environmental Monitoring and Audit Plan and Manual (BEMAP/M) are



Securing water samples obtained by MIRANT-Pagbilao during their joint proponent-MMT marine waterquality survey.

Reviewers of the scoping report and BEMAP/M should ensure that the informationpresented is technically adequate for the specific project and follows the scoping pro-cess appropriate for the project.

2. Environmental Monitoring and Audit Plan and Manual

The Environmental Monitoring and Audit Plan and Manual (EMAP/M) are key documentsin the proposed Enhanced EIA M&E System. These documents are prepared and sub-mitted by the proponent to EMB and become the main basis for EMB, stakeholders, andother third-party validators to assess the environmental performance of projects and otherundertakings covered by PEISS.

EMAP is submitted initially with the EIA documents as part of the Environmental Manage-ment Plan (EMP) upon the application ECC. EMAP is a broad outline of commitmentsand measures that the proponent will undertake to monitor and audit the project’simplementation of its EMP as well as compliance to the ECC terms and other postECC follow-up activities.

EMAM is derived from and expounds on the EMAP. EMAM contains the detailed ac-tivities of the proponent to track the implementation of its EMP, to institute re-



sponse mechanisms to noncompliance or exceedances or complaints, to providefor resources and enabling mechanisms to implement EMAP, and to undertakewhatever is reasonably needed to attain optimum environmental performance.

EMAM may be submitted together with EMAP during the EIA review, or after the ECC hasbeen granted as long as the approval is given by EMB before any construction activity. In thelatter case, changes in project design or construction or operation should be considered in thedrafting of EMAM.

The EMB EIA staff and the EIA RevCom shall ascertain that the proponent submits its EMAPand EMAM that is sufficient in form and substance. During the procedural review of EIAdocumentary submissions at the Pre-ECC stage, EMB shall ensure that EMAP/M containthe complete topics required. EMB endorses the complete EMAP/M with other documentaryrequirements to the EIA RevCom for a substantive review.

The EIA RevCom members (during Pre-ECC Stage) and MACOM (during Post-ECC stage)should be experts in the necessary scientific discipline to credibly review the submitted EMAP/M. Basically, the EIA RevCom and MACOM members should ensure that the approach,methods, and technical analysis are adequate, feasible, relevant, and accurate for the specificproject and that there are no fallacious or dubious analyses. They should ensure that the logicof the discussion is rational and that the information presented is credible. This will includereviewing the identified impacts and the mitigating measures, monitoring parameters, thesampling locations, schedule and frequency, sampling methodology (including transport ofsamples to laboratories), set standards, and the recommended EQPL, among others.

Reviewers should ensure that the information presented and its rationale is technically ad-equate for the specific project. However, reviews should be limited to what is really needed inthe project and not toward the reviewer’s bias for his/her own specific field of interest or towardhis own person. They should also ensure that the EIA report did not miss anything essentialin the protection of the environment such as additional parameters, better treatment optionscompared to the ones presented, sensitive receptors not included as sampling locations.Reviewers should also ensure that the proponent has the ability to implement its EMAP/M.The use by the proponent of an accredited consulting firm to implement the EMAP/M is

acceptable.

B. CONTENTS OF BEMAP/M AND EMAP/M

EMAP/M shall contain the following topics:

• Executive Summary• Environmental Policy and Monitoring and Audit Objectives• Baseline Monitoring (for BEMAP/M only)• Compliance Monitoring• Impact Monitoring

o Identification of Significant Impacts to Monitoro Selection of Monitoring Parameterso Setting of Environmental Quality Limitso Sampling and Measurement Plan, including Quality Assurance

• Budget• Accountability



• Stakeholder Participation• Complaints Management, Communication and Reporting• Environmental Impact Event / Action Response Plan• Audit Program• Schedule for Baseline Monitoring and Preparation of EMA Manual for Design, Construc-

tion, Operation, and Abandonment Phases• Appendices

1. Executive Summary

The Executive Summary serves as an overview of BEMAP or EMAP. It shall contain aSummary Matrix (Table 4-1) that lists the environmental and audit (EM&A) objective,significant environmental aspects and impacts (EA&I) selected for monitoring and specifythe monitoring elements, such as the parameters selected for the monitored aspect orimpact, the sampling and measurement methodology for each parameter, the account-ability for each monitoring task and logistics required. The following format may beused as guide. The contents of the environmental aspects and impacts may varydepending on whether it is a BEMAP or an EMAP.

EnvironmentalMonitoring andAudit Objective

Environmental Aspect & Impact ParameterSampling andMeasurementSpecifications

Budget Accountability

To comply withECC and EMPrequirements

To detect anyresidual impact

ComplianceMonitoring

ImpactMonitoring

ECC Conditionalities

EMP Commitments

Table 4-1.Environmental Monitoring and Audit Summary Matrix.

To track anynoncomplianceand compliance

ComplianceIssues andComplaints

The Executive Summary will also provide a brief narrative on the monitoring and auditdesign. The narration will specify the parameters or characteristics of the EA&I to bemeasured, what, where, when, how to sample and measure the parameters, the envi-ronmental performance evaluation criteria, the environmental management response tomonitored changes, especially noncompliance and complaints, communication andreporting protocol, accountability and logistics. An audit scheme must be included,which may be done in-house and third party, such as the MMT and an independentenvironmental checker (auditor).

Any significant change in project design that may affect BEMAP, or EMP and EMAPshould also be summarized and the corresponding EM&A objective change noted.



Reviewers should ensure that the policy and objectives are achievable and aligned withthe goals of the EM&A activities.

3. Baseline Monitoring

Baseline environmental monitoring involves the sampling and measurement of environ-mental parameters during a representative preimplementation period to:

• Determine the nature and ranges of natural variations. Baseline environmental datawill show the condition of the natural environment and upper and lower fluctuationsbefore the project is established and identify other possible sources of environmen-tal impacts

• Establish EQPLs. By conducting a baseline monitoring, the proponent can setlevels that will serve as a warning of environmental deterioration because of projectactivities. For example, a water body that will be directly affected by a proposedtuna canning facility has been identified during the baseline monitoring to have abiochemical oxygen demand (BOD) of 20 mg/L. The proponent can then set theEQPL for that water body. If future environmental monitoring shows that the waterquality in terms of BOD is deteriorating (i.e., higher BOD values), it will serve as awarning that the project may have an impact and that additional mitigation measuremay be needed to address the deterioration.

• Show the suitability of impact, control, and reference monitoring stations. It isduring the baseline monitoring, specifically during the preparation of BEMAP/Mthat monitoring stations are identified. To properly identify the monitoring stations,the basic design and blueprints of the project must already be available to deter-mine potential impact points of the project. These will then be contextualizedwithin the landscape of the proposed location of the project. For example, sam-pling stations will be established for the source of impacts such as the ash pond fora power plant, stack emissions, and effluent outfall. Sampling stations will also beestablished for sensitive receptors such as the nearest community downwind of theproject, a national park serving as the habitat of certain endangered species, thewater source of the community, and agricultural lands affected by the project. Sam-

Reviewers should ensure that all the abovementioned information is presented and thatthe section is technically accurate.

2. Environmental Policy and EM&A Objectives

An Environmental Policy Statement must be made by the proponent’s top manage-ment. The Policy Statement shall address the proponent’s commitments and prin-ciples governing the project’s environmental performance and shall provide the frame-work for setting of environmental monitoring and audit objectives, targets, and strate-gies for implementation. A typical Policy Statement will elaborate the proponent’scommitment to comply with the ECC conditionalities and EMP requirements and rel-evant environmental laws and standards, and to pursue continual improvement of envi-ronmental performance through an established environmental management system.Examples of environmental policy, EM&A objectives and targets are given in Appendix2.



pling stations will also be established at areas that are not affected by the project toact as control and reference stations. These areas will include a community up-wind of the project site, a groundwater source upgradient of the water table or abathing area upstream of the effluent outfall.

4. Compliance Monitoring

Compliance monitoring is focused on the status of proponent’s delivery of commit-ments made in its EMP and meeting the ECC terms and conditions. Appendix 3presents the form currently used by EMB which will further be retained under the En-hanced System. This form will be integrated into EMAP/M.

In case ECC contains specific conditionality related to compliance with environmentallaws, rules and regulations other than PD 1586 and its IRR, the compliance status ofthe specific conditionality shall be merely noted in the EIA Module of the SMR and thecompliance issue resolution referred to other more appropriate SMR modules (i.e., PD984 or RA 6969 or RA 8749 or RA 9003 modules) pursuant to DAO 2003-27.

5. Impact Monitoring

Impact monitoring addresses actual changes in the environment that project featuresand activities to have triggered or directly caused. The occurrence or nonoccurrence ofan impact is the best concrete indicator of a project’s environmental performance. How-ever, it is best to detect a potential problem ahead of the actual impact rather than laterto minimize any damage that may be caused by the project.

The Philippine EIA System views the environment to be composed of physicochemical,biological, and socioeconomic components. Thus, impact monitoring will cover allkinds or environmental aspects of a project as well as broad categories of impacts fromboth the natural and man-made environments.

In view of the wide range of environmental aspects and impacts potentially attributableto a project, it is practical and much more useful for environmental decision-making tofocus on significant and critical ones in the light of limited resources. There are severaltools that can be employed for the identification of significant environmental aspectsand impacts as well as the selection of critical parameters that must be monitored.

a. Identification of Significant Environmental Aspects and Impacts

The first step in preparing the project-specific BEMAP or EMAP is to select theproject’s critical environmental aspects and impacts (EA&Is) that will be moni-tored. EA&Is are derived from the long list of significant EA&Is identified in longlistscoping process, EIA study and articulated in EMP, which may also be incorpo-rated in ECC.

By definition, the project’s environmental aspects are those environmentally rel-evant project elements and activities, including processes, procedures, mitigationand enhancement measures, and the likes, excluding monitoring and audit. Theelements that pose potential burden to the environment are also called environmen-tal stressors. The environmental impacts are physical, chemical, biological orsocioeconomic changes in the environment that may either be positive or negative



caused by the project’s environmental aspects. The emphasis in BEMAP andEMAP is on the negative environmental impacts.

The critical EA&I selection criteria include the following:

• Probability to cause adverse environmental damage to environmental systems(flora, fauna, habitats, ecosystems) and human health and welfare if improperlymanaged. Examples are the specific activities of highly pollutive or high-riskECPs and projects in ECAs generating toxic and hazardous wastes

• Vulnerability and high conservation value of potential environmental receptors,such water supply, fishing grounds, and protected areas

• Long gestation period for mitigation or remediation or enhancement, such asreforestation, transplantation of corals, and sanctuary establishment

• Uncertainties due to unproven or unfamiliar technology used or mitigation mea-sure employed or unfamiliar operating environment

• Other criteria that EMB or RevCom may impose.

The selection process can employ a weighting-scaling formula, which may be de-rived from Delphi or other consensus-building techniques, similar to the ones usedin the EIA Impact Assessment phase. Alternatively, an environmental risk assess-ment technique may be used, such as the NRIPS developed by the IndustrialEnvironmental Management Project. An highly recommended adaptation of theNRIPS for selecting and prioritizing EIS-issued projects called PEMAPS is shownin Appendix 1.

Another method which is more sophisticated and thus more difficult to use is theADB’s environmental evaluation technique or the extended benefit-cost analysisframework. Environmental checklists for various project categories are available inthe literature and may be used in selecting the EA&I and the corresponding param-eters for monitoring and audit (Appendix 4).

The scoping report will identify the impact zones of the proposed project. Impactzones are areas that will most likely be directly or indirectly affected by the project.Impact zones are primarily identified based on the type of project and knowledge ofthe biophysical and social environments of the proposed location. These areasshould be delineated on a map.

The EIA system identifies two types of impact areas:

• The primary impact area(s) are areas where the project will construct facilitiesor infrastructures such as a waste treatment plant, buildings, access roads,mining area, among others. These areas could cause critical environment orsocial change such as population displacement, potential flooding, deforesta-tion, disturbance of habitats, and other possible adverse changes.

• Secondary impact area(s) refer to the influence area of the project that couldbe indirectly affected. These may include areas in the vicinity of the directimpact zone, and may include communities outside of the direct impact areathat may benefit from employment from the proposed project, subtributaries ofthe river system which can be indirectly affected by pollution, or water sourcesoutside of the direct impact zone which could be affected by drawdown fromthe project.



In any case, the end point of the EA&I selection is a prioritized list that can beexpanded or trimmed off depending on the available manpower and logistics as wellas overall attainability of the environmental monitoring and audit tasks and objec-tives.

b. Selection of Monitoring Parameters

Each critical or significant EA&I selected for monitoring will be included in BEMAP/M and EMAP/M for the specific project. The monitoring design will specify theparameters or characteristics of EA&I to be measured, among others. The selec-tion of the parameter(s) to use for each of EA&I is a very important step in estab-lishing the credibility and validity of the entire monitoring and audit program.

The following criteria may guide the selection of parameters for EA&I:

• Relevance – The parameter must provide the type and amount of informationneeded to meet a specific monitoring objective. For example, if the objectiveis to track the effectiveness and compliance of a mitigation measure such as awastewater treatment plant for an organic pollution, then the parameter to beused is the biochemical oxygen demand (BOD) of the end-of-pipe effluent.Another example, if the monitoring objective is to protect a downwind commu-nity from air emissions of a cement factory, then the parameter of choice mustbe the total suspended particulates of the stack emission as well as the ambi-ent air quality at the community or, better, several sampling points before theemission reaches the community. Another example, if the objective is to pro-tect an adjacent community from contaminated water supply of a coal-firedpower plant, then the parameter is the content of heavy metals, such as mer-cury and cadmium, in the ash pond and the affected groundwater, including thepoint of abstraction of drinking water by the community.

• Representativeness – The parameter must indicate directly or reflect indi-rectly the unique characteristic(s) of EA&I relevant to environmental values anddecision-making. For example, the organic pollution of a water body may berepresented as the organic carbon content or by BOD or by other parameters.

• Measurability - The parameter must be able to measure, perceive or appreci-ate quantitatively or qualitatively in a replicable and standardized manner. Themeasured data must be able to be processed and tested for statistical validityand presented in graphs or tables or other data processing and presentationformat.

• Cost-Effectiveness – The sampling and measurement costs must be afford-able and commensurate to the environmental value of the parameter and itsEA&I.

• Simplicity - The parameter must be simple to understand and appreciate interms of environmental decision-making.

The parameter-rating called Environmental Stressor Rating Scheme (ESRS)may be used to facilitate selection of parameters to monitor, as adopted from theADB Economic Valuation Handbook (1996), is shown in Appendix 5. It is worth-while to review the selected critical parameters in terms of inclusion of stakeholderconcerns and other public interest issues.

A summary table (Table 4-2) showing the selected critical monitoring parameters



integrating relevant information for designing a Sampling and Measurement Planshould be included. The information required are: the EM&A objective being ad-dressed, the significant EAI identified, the monitoring parameters, recommendedaction or mitigation measure in case of noncompliance or exceedances as well asthe project phase when the monitoring should be done. This information is com-bined with the source of the environmental stressor, the environmental pathway andthe location of vulnerable receptors (see Appendix 5) as well as with the selectedsampling and measurement methodology for each parameter to almost completethe design of a Sampling and Measurement Plan discussed in the next section.

c. Sampling and Measurement Plan

Another foremost concern of the proponent is the scientific credibility of the datasets. Any misinterpretation, miscalculation or error arising from the sampling andmeasurement activities can be very costly to the proponent. As they say, “GarbageIn, Garbage Out”. Thus, the proponent has his best interest in mind by preparing ascientifically sound and socially acceptable EMAP. A good EMAP is charac-terized by a carefully designed sampling and measurement plan (SAMP) foreach of the parameters selected.

Scientific credibility is best attained by adhering to the official and standard meth-ods developed and adopted by the different professional associations and imple-menting a QA/QC program. In the environmental chemistry field, for example,physico-chemical analysis of air, water, and soils are managed by the Associationof Official Analytical Chemists (AOAC) and the American Public Health Association(APHA), among others. Standard methods for a wide variety of materials are handledby the American Society for Testing Materials (ASTM). There are European, Japa-nese, and other country-specific standard methods as well. In the Philippines,EMB has released official methodologies for both air and water studies, but these,while still valid, are in dire need of major updating efforts.

The sampling and measurement plan should also contain the following features:

• Parameters Selected - The type and number of measurements selected foreach parameter must yield relevant data sets that can be subjected to statisti-cal processing and interpretation as well as presentation in graphs or tables.This means that there should be enough replication for each control and treat-ment (if any) sampling point to allow computation of mean and standard devia-tion values for comparing both and enough repetition or replication over loca-tion, time and season to allow analysis of variance.

• Sampling Protocols - The sampling points or locations, frequency, duration,method of sampling and sample handling and preservation and other standardrequirements for the parameters to be measured must be specified in relationto the objective of the monitoring.

• Methodology - The specific sampling and measurement design for each pa-rameter should adopt official and standard methods set for that parameter byrelevant professional groups or scientific associations. If there are no official orstandard methods, the procedure commonly accepted and performed by therelevant professional or scientific body should be employed. It is thereforeimportant that EMB or its MACOM should include an expert or a specialist forthe relevant discipline as a resource person.



ObjectiveEnvironmental

Aspect orImpact

MonitoringParameter

Action for Non-compliance /

Mitigation Measure

Project Stage

Des Con Ope Aba

To protectvaluablereceptorsagainstenvironmen-tal stressorsfrom a coal-fired powerplant

Stack emission Total SuspendedParticulates;heavy metals infly ash

Increase stackheight; install addi-tional air pollutioncontrol device, e.g.,wet scrubber, elec-trostatic precipitator

X

Downwindcommunity

Ambient airquality: TotalSuspendedParticulates;heavy metals;URTI morbidityand mortality

Increase stackheight; installadditional airpollution controldevice; providepersonal air filtermask in case ofexcursions

Downstreamcommunal watersupply

Heavy Metals inash pond andgradient ofadjacent ground-water body,including abstrac-tion point

Seal leakagesfrom ash pond;intensify monitor-ing; providealternative drinkingwater source

X X

X X

DownwindProtected Forest

Ambient airquality: SOX,TSS; precipita-tion: acidity/pH;flora and faunabiodiversityIndex; treegrowth rate (dbh)of protectedspecies

Coral reef nearcooling wateroutfall

Water temperaturein mixing zone andadjacent ambientwaters; live coralcover andcomposition; fishcatch

To protect theecosystemfrom landdevelopment(housingsubdivision)

Small farms ofneighboringfarmingcommunity

2)

1)

Table 4-2. Selection of Parameters for Monitoring of CriticalEnvironmental Aspects and Impacts (EA&I).

X X

Legend: Des: design, Con: construction, Ope: operations, Aba: abandonment



o Field Blank Samples - nonexposed sample of the medium being used fortesting (e.g., mixed cellulose ester membrane filter).

o Laboratory Control Samples – Example, matrix spiked with known con-centration of lead analyzed for each sample matrix e.g., paint chip, woodchip, brick substrate, and mixed cellulose ester filter. Laboratory controlsamples (LCS) consists of each matrix spiked with a certified referencematerial such as in the case of the example mentioned: paint chips - NISTStandard Reference Material 2589, air sampling filters - Fisher ScientificLot # 973670-24, TCLP extracts -High Purity Standards Lot # 726120, andsoil - Environmental Resource Associates Inorganic Trace Metals Lot #235. Laboratory control samples are analyzed with each sample setprocessed to verify that the accuracy and bias of the analytical processare within control limits.

• Quality Assurance - The sample analysis must be performed by EMB-ac-credited laboratories and signed by registered chemists. Quality assuranceprocedures of these laboratories must be specified including interlaboratorycomparisons and statistical techniques. Data quality objectives (DQO) anddata quality indicators (DQI) should be included. The number of QA/QC samplesto take, such as duplicates, blanks, and trips must be specified for each pa-rameter. A Chain of Custody (COC) procedure must also be built into SAMP.Lastly, the decontamination procedure to be used if needed during the actualsampling activity must be defined. The COC will document each sample fromthe time of its collection until its receipt by the analytical laboratory. Internallaboratory records then documents the custody of the sample through its finaldisposition.

• Sample Labeling - Each sample should labeled with a unique project identi-fication number recorded on a sample data sheet along with other informationsuch as sampling date, location of the sample, size of the sample (volume orarea), sampling flow rate, sampling start/stop time, and conditions (environ-mental and operational) of sampling.

• QA/QC samples include the following;

• Each sampling and analysis plan should include a schedule that clearlyspecifies the time when each element of the monitoring and evalua-tion report will be completed. Elements to be scheduled include:

• Maximum holding times for each type of sample should be explicitly speci-fied. Along with the schedule, a brief discussion should be provided describing

o Replicate Sample Analysis - determines the precision of the analyticalmethod on each matrix.

o Method Blanks - documents any contamination resulting from the analyti-cal process.

o Field mobilizationo Field samplingo Field demobilizationo Shipment of samples to laboratorieso Initiation and completion of physicochemical and biological analyseso Initiation and completion of data validationo Submission of draft and final reports



the rationale for the frequency, timing, and phasing (if any) of the sampling andanalyses.

• The records of all sampling and measurement activities and results should bekept for at least two years in case there is a need for audit later on.

• SAMP is subject to review both by MMT and EMB. EMB shall approve the finalSAMP as the core of the EM&A program for the specific project.

An example of a SAMP is given in Appendix 6.

d. Setting Environmental Quality Performance Levels

EQPLs are environmental performance criteria set for each selected parameter. Atleast two EQPLs are required, namely action and limit levels. A third optionalcriterion is the early warning level which is actually a red-flagging alert level.

The limit level may indicate the regulated threshold of a pollutant or environmentalcharacteristic, which may be expressed in terms of standards that must not beexceeded (as in the case of pollutants) or optimum range to maintain (as in tem-perature and pH or acidity of a water body). In quantitative terms, reaching andexceeding the limit level is the worst case of environmental performance. If the limitlevel is exceeded, the appropriate environmental management action cantake the form of the following:

• Issuing a cease-and-desist order (CDO) to stop any imminent threat or actualdamage to the environment, property, and limbs and lives,

• Instituting emergency response to contain the damage or threat or protectpotential receptors and launch rescue operations, where needed,

• Implementing rehabilitation and remediation measures, when called for.

Where there are no legal standards, scientific criteria or internationally ac-cepted thresholds may be employed to set the limit level. Alternatively, for param-eters that are not regulated nor have a scientific or international criteria or basis,consensus- building among the key stakeholders may be resorted to. Stake-holder consensus can also be used in setting environmental quality criteria forhard-to-quantify parameters such as some socioeconomic indicators related toquality of life or poverty indices.

The action level on the other hand, is usually that point where the environmentalchange is significant enough but has not yet reached the limit level. The actionlevel indicates that management measures must be employed such that furtherdeterioration to the limit level is not reached and, preferably, reverse the deteriora-tion to pre-impact or optimum environmental quality.

Management measures can take the form of intensifying the monitoring and auditprogram, scaling up or upgrading the mitigation measures or introducing innovativeand effective control measures or improving or changing the project technology(such as clean production, clean technology). Either expert judgment or similarexperience elsewhere or statistical techniques may be employed to set the actionlevel.

If an early warning is desirable, a third optional level called the red-flag level may beset. This usually signals that the environment is starting to change toward a nega-



tive direction (deterioration of environmental quality) indicating that the project iscausing residual impacts. However, this change may be due to a natural fluctua-tion or another environmental stressor apart from the project, or a sampling andmeasurement error or another factor external to the project.

The red-flag level is best set using statistical techniques. For example, the red-flaglevel of mercury, a highly toxic metal, in a stream classified as Class C waters maybe set at 2 to 3 times the standard deviation of the baseline average mercurycontent, provided that this value is still below the action and limit levels. The mainidea is to be able to detect the start of a significant environmental change and callthe attention of the proponent to study the matter more closely.

Pertinent responses in case the red-flag level is reached are, for instance: 1) re-peating or confirming the analytical results, preferably using an accredited refer-ence laboratory, 2) reviewing the potential stressors and the mitigating measures,3) investigating other possible stressors outside the project, or 4) establishing ad-ditional, more reliable control points through additional baseline measurementsthat can better detect natural fluctuations of the parameter.

An example of the setting of EQPL is given in Appendix 7.

6. Budget

A realistic and sufficient budget for conducting the environmental monitoring and auditactivities is the clearest indication that the proponent will effectively implement its ap-proved BEMAP or EMAP. The following cost items are expected to be identified inBEMAP and EMAP:

• Personal services (regular and contractual staff as well as external auditors andconsultants)

• Maintenance and Other Operating Expenseso Travelo Supplies and Materialso Equipment Rentalo Laboratory Fees

• Capital Outlayo Equipment (Field and Laboratory)o Laboratory and other related Facilitieso Vehicleso Software and Hardware

• Miscellaneous Expenses

The proponent should particularly include in the detailed budget the full cost of thesampling and measurement program. In case of outsourced services, the de-ployed equipment must be identified and where these will be sourced. Moreover,the proponent must give information on the cost of procuring or renting the equip-ment, the cost of the containers and preservatives to be used, and the cost oftransporting the samples. The budget should also specify the cost per parameterfor laboratory analyses.

DAO 2004-30 further requires the proponent to establish an Environmental Guaran-



tee Fund (EGF) and an Environmental Monitoring Fund (EMF). EMF is used tosupport the activities of MMT organized for the specific project or cluster of projects,as the case may be. Respective guidelines for EMF and MMT are found in ChapterVII of this Handbook.

7. Accountability

BEMAP/M and EMAP/M shall specify the requirements for qualified personnel chargedwith the routine EM&A of the project activities, detailing the education, training, knowl-edge, and experience of the environmental team. The Plan/Manual may identify theneed for independent auditing of the environmental performance at all stages of projectimplementation.

Management structures, procedures, and protocols shall be presented in EMAM. Anorganizational chart shall be presented showing the reporting flow and coordinationlinks of the environmental team to the project management and the project engineerduring design and construction stages of the plant or operations manager during theoperation and abandonment phases. The roles and functions of every personnel in-volved must be listed. The contact person(s) for EMB and other external transactionsshall be named.

An environmental training and awareness program shall be presented. The programshall show how a necessary and sufficient level of understanding of the environmentalissues appropriate to the targets of regulatory requirements and EMAP can be effectednot only among the environmental staff but also the management and employees at alllevels of the project facility, site, and management operations.

8. Stakeholder Participation

Stakeholders, particularly community MMT (if formed already at the time of the monitor-ing/sampling activities) should be encouraged by the proponent to participate in theconduct of baseline monitoring activities. Baseline monitoring with stakeholder partici-pation and community involvement may form an important part of the scoping process.

BEMAP/M or the EMAP/M should detail the procedure for stakeholder participation.The participation can be in the form, for example, of: 1) a structured MMT, 2) a lessstructured one through a complaints or public relations desk, or 3) organized commu-nity or stakeholder consultations. It is important to undertake proper stakeholderidentification. Refer to Volume 2 of this Handbook for specific guidelines on stake-holder participation and MMT.

9. Complaints Management, Communication, and Reporting

Protocols for managing complaints must be outlined in BEMAP or EMAP as appropri-ate and detailed in BEMAM and EMAM. These should address the complaint receivingsetup, case investigation, implementation of corrective measures, communication withthe complainant/public, and complaint documentation.

Communication and reporting procedures should also be detailed in BEMAM and EMAM.These should include:

• Methods of communication (e.g., correspondences, phone call, facsimile, andelectronic mail)



10. Environmental Impact Event / Action Response Plan

Appropriate and effective environmental impact remedial actions or mitigation mea-sures must be specified in this section in case:

In the event that the proponent faces a compliance issue, such as issuance of a Noticeof Violation or worse a CDO, the proponent should have an environmental managementplan that specifically addresses this issue. This may involve implementing remedialaction such as cleanup, storage, and disposal of wastes, restoration and remediation,and compensation or substitution. The plan should identify the persons responsible foreach segment of the response plan, the procedures necessary to implement the re-sponse plan, identify possible restraining forces that may inhibit the response plan, andidentify resources, government agencies, or plans that may make the response planmore effective.

The proponent should also document actual measures taken and report to EMB andother responsible government agencies as well as the affected communities.

11. Audit Plan or Program

In this section, the proponent shall describe any auditing activity that is planned foreach facility. The Audit Program must indicate the audit activity, purpose, audit objec-tives and criteria, audit frequency and schedule, auditor, at the very least.This auditmay be in compliance with a certified Environmental Management Systems, such asthe ISO 14000 series. The proponent may hire the services of another third-partyauditor accredited by EMB or other concerned government agencies, such as the Bu-reau of Product Standards.

12. Schedule for Baseline Monitoring and Preparation of BEMAM/EMAM forDesign, Construction, Operation, and Abandonment Phases

BEMAP/M and EMAP/M should also include a work plan for the continued collection ofbaseline monitoring data which should have started during the EIA study proper. Theschedule should show at what time baseline monitoring of each parameter will end i.e.,start date for construction or operations depending on parameter. Continuing baselinemonitoring until there is project-induced change in the environment and human condi-

• Monitoring and audit data indicate noncompliance with any of the prescribed envi-ronmental performance criteria and exceedances over any applicable environmen-tal standards or self-defined EQPL

• Vulnerable environmental media and human receptors indicate unacceptable dete-rioration or degradation or adverse health and welfare impacts, respectively.

• Liaison with EMB and other regulatory bodies, media, local community, and spe-cial interest groups and other stakeholders

• Early Warning System for imminent hazards and Emergency Response to ensurepublic safety

• Circulation of project’s environmental statement• Triggers for sending communications and reports• Type and Frequency of reporting• Persons responsible for making the report• Feedback mechanisms for complaints



V. GUIDELINES FOR PREPARATION OF THE BASELINE ENVIRONMENTAL MONITORING AND AUDIT REPORT AND SELF-MONITORING REPORT BY PROPONENT

A. PURPOSE OF THE GUIDELINES

1. Baseline Environmental Monitoring and Audit Report

These Guidelines for the Preparation of the BEMAR specify the contents and the infor-mation that the proponent/preparer is expected to submit to EMB as part of the EIAprocess.

BEMAR is based on BEMAP/M that is initially submitted by the proponent during theScoping Phase when the important environmental aspects and impacts of the projectare identified on a preliminary basis to guide the conduct of the EIA Study. BEMAR willbecome part of the EIS document subject to review for ECC processing. Henceforth,BEMAR will be submitted regularly (quarterly) until the construction phase begins oruntil significant changes due to project construction and operations are made. AsBEMAP is completed, there is a continuity of monitoring through the regular EMAP.EMB may extend the length of the baseline information period because of the need tocollect additional data to show a trend of the natural environment or in cases whenECA, such as protected areas, national parks, protected seascapes, and the likes maybe affected by the project. In case proper control monitoring stations can be estab-lished, baseline monitoring may be pursued even throughout the project life. This isuseful in adjusting EQPL whenever the natural environment has changed on its own orthrough other nonproject man-made interventions.

BEMAR contains scientific discussions and the methodologies used in determining thestate of the natural environment which will be affected by the project prior to its con-struction as well as control stations that need to be established for comparing the datacollected during the regular monitoring period. This will determine if the actual impactsare within the limits of those that were predicted under EIA and to ensure that changesto the natural environment do not go beyond the Limit Level set in the ECC.

2. Self-Monitoring Reports

The Guidelines in preparing SMRs by the proponents are intended to specify the typeand extent of information that the proponent is expected to disclose to EMB, MMT, andother stakeholders as a result of implementing EMAP/M. Pursuant to DAO 2003-27EMB requires the proponent to quarterly submit SMRs. On the other hand, in compli-ance to the EIA Module as stipulated in DAO 2003-30, proponent is also asked tosubmit semiannual monitoring report on compliance to PD 1586.

The EIA module of SMR contains the status of EA&I of the projects to determine if theproponent complies with the EMP and ECC, conditionalities. It can serve as a sum-

tion is important in fine-tuning the setting of the EQPL.

The proponent should also present the schedule in preparing and submitting the manu-als for the design, construction, operation, and abandonment phases. The manual canbe submitted individually or can be integrated as a compendium depending on theschedule of the proponents and how complicated the process for each phase is.



Table 5-1 Summary Matrix for BEMAR and SMR.

Impact/Conditionality/Commitment Status Action Taken Recommendation

mary for the other modules as the EIA by its nature cuts across various regulations.This module will therefore act as a management tool for regulators as it covers/summa-rizes the other modules in SMR. Further, it shall contain scientific discusion and themethodology used in determining the compliance of the proponent to the critical EA&Iidentified in the EMAP. Following is a discussion of the major topics in the EIA moduleof the SMR (initial version is the BEMAR).

B. CONTENTS OF THE BASELINE ENVIRONMENTAL MONITORING AND AUDIT REPORTAND THE SELF-MONITORING REPORT (EIA MODULE)

The annotated outline BEMAR and SMR is as follows.

1. Executive Summary

This section contains a summary of the whole report. It should include the scope andpurpose of the study. It should include which specific parameters were monitored, wherethe monitoring stations are located and the monitoring period.

It should also include a summary of the major findings for the monitoring period. Forexample, a statement that there were no major activities that influenced the monitoringparameters during the monitoring period can be made if there were really no activitiesby the proponent that affected the monitored parameters.

BEMAR and SMR should contain a table matrix similar to the following format:

2. Introduction

This should be a generic section that can be used for several projects’ BEMARs andSMRs. The only information in this section expected to change are:

• Name of project proponent• Name of project• Name of monitoring team/individual consultants/consulting firm• Dates• Locations



3. Project Background

This section should provide a brief background about the type of project, significantmilestones achieved i.e., date of scoping, submission of scoping report, date ECC wasapproved, and date EMAP was approved.

The section may be generic for all BEMARs or SMRs for a specific project. However,changes in BEMAP/M or EMAP/M and additional milestones may occur which willnecessitate changing/adding this section.

As part of background documentation, the following information in pictorial or map for-mat must be appended:

• Location Plan and Facility Process Flow Chart or equivalent Project OperationsDocument

• Location of Sensitive Receptors• Drawings (to scale) showing locations of the Monitoring Locations with proper la-

bels• Implementation Schedule

4. Methodology

This section should describe the steps/scientific process used in the monitoring event.It should frequently refer to BEMAP/M or EMAP/M; specifically, the Sampling andMeasurement Plan (SAMP). In the event that SAMP was not followed, the reasonsshould be given in this section. Deviations should be presented in a table as follows:

Planned Activity Actual Activity Reason for Deviation

Table 5-2 Dummy Table for Reporting Methodological Revisions.

5. Results and Discussion

a. Summary of Previous Monitoring

The key findings, recommendations, and action plan from the previous monitoringand outstanding issues from earlier monitoring periods (if applicable) should behighlighted in this section. The status of the recommendations and measuresincluded in the action plan should be described and any unmet commitment mustbe rationalized and alternative, if needed, presented.

A suggested format is to give a brief description of the environmental setting of theprevious monitoring. It should also contain the summary table in the executivesummary of the previous monitoring with an added column to check if the previousrecommendations were implemented. In the event that previous recommendationswere not implemented, the reason behind it should be specified.



(i) Compliance Monitoring

The status of compliance to the ECC conditionalities and the attainment of EMPcommitments should be elaborated in this section. The appropriate EMB formfor this purpose (Appendix 3) should be presented as a running total of compli-ances and met commitments. Reasons for noncompliance or unmet commit-ment should be explained and solutions and measures to attain full complianceof ECC terms and conditions as well as satisfactory attainment of EMP commit-ments should be discussed as renewed efforts for the next monitoring period.

(ii) Impact Monitoring

It should be noted that EIS where the decision to grant or deny ECC was basedmainly with predicted environmental impacts of a project. In this section, valida-tion of the predicted impacts through the monitoring of actual project impacts isreported to provide a basis for effective planning and management of environmen-tal measures. Graphical presentation of quantitative and semiquantitative impactmonitoring results over the whole monitoring period is an excellent way of pre-senting past monitoring results. The latest monitoring findings and conclusionshould be discussed in text form. The information added by the current monitor-ing period may also be plotted on the same graphical formats.

Qualitative impact monitoring results may be presented in text form or in terms ofpictorial coverage, if applicable. Examples of qualitative impacts are those relat-ing to quality of life, degree of happiness, and sense of environmental cleanli-ness.

b. Reports of Complaints and Environmental and Health-related Accidents

The protocols for managing complaints must be outlined in EMAP and detailed inEMAM. These should address the complaint receiving setup, case investigation,implementation of corrective measures, communication with the complainant/pub-lic, and complaint documentation. If there is an MMT established for the project,proper coordination mechanisms with MMT must be put in place.

A complaints investigation protocol may consist of the following steps:

• Log complaint and date of receipt into complaint database and inform EMB(and MMT) immediately

• Investigate complaint to determine its validity and to assess whether the prob-lem is due to project activities

• If a complaint is valid and due to project activities, identify mitigation measuresin consultation with EMB (and MMT)

• If mitigation measures are required, request decision-maker for resources andimplementation requirements

• Review implementation and current situation• Report to EMB (and MMT) on status of complaint investigation and follow-up

action• Undertake M&A to verify complaint, if needed, and identify preventive measures• Inform complainant about investigation results and subsequent actions• Log a record of complaint, investigation and follow-up actions, and results in

the monthly EM&A Reports and SMR

Communication and reporting procedures should also be detailed in EMAM. Theseshould include:



• Methods of communication e.g., correspondences, phone call, facsimile,and electronic mail

• Liaison with EMB and other regulatory bodies, media, local community, andspecial interest groups and other stakeholders

• Early Warning System for imminent hazards and Emergency Response toensure public safety

• Circulation of project’s environmental statement• Triggers for sending communications and reports• Type and Frequency of reporting• Persons responsible for making the report• Feedback mechanisms for complaints

c. Current Monitoring Results and Findings

The data collected from the various sampling and measurement events doneunder SAMP are presented in tabular form and discussed under this section.One table must be prepared for each sampling point or location. Only processedand summarized data must be presented here. The raw data should be includedin the appendices section of the report.

The results must be related to the historical trend for the parameter. Any devia-tion from this trend must be explained. More, importantly, the discussion mustfocus on point-by-point comparison of the gathered values with the set EQPLsdeveloped during the scoping and explained in detail in BEMAP/M. The monitor-ing results could also be used to determine the action and limit levels for thespecific project. These should all be presented here in detail and summarized inthe conclusions and recommendations section.

Compliances, noncompliances, and exceedances must all be thoroughly ex-plained. In cases of compliances, success factors must be cited. Fornoncompliances and exceedances, the proponent’s response should be explained.Moreover, causative factors must be identified and additional solutions and miti-gation measures proposed, if needed.

It should also include the major activities carried out on the site during the moni-toring period. It should also cite the weather conditions and other factors whichmay affect the results of the sampling activities.

A summary table may be included with the following format:

Parameter Frequency Date/Time Location Analytical ResultSampled Red- Action Limit

Flag

EQPL

Table 5-3. Summary Table for Reporting Monitoring Results.



6. Conclusions and Recommendations

This section should present the conclusions and recommendations of the currentBEMAR or SMR based on the results and discussion of the previous sections. Itshould also explain if the previous monitoring recommendations should continue (ifimplemented). On the other hand, if warranted, the recommendation may be thecessation of specific or all monitoring activities.

The conclusions and recommendations should preferably be in a bulleted format andas much as possible grouped according to coherent themes, such as the followingheadings.

For a BEMAR, a summary on identifying the alert, action, and limit levels for a spe-cific parameter and how they were set needs to be presented in this section.

a. Compliance Status

Only the key conclusions about the status of compliance to ECC and EMP areincluded in this section. The status of noncompliances should be particularlytracked throughout all SMRs even if compliance has been already attained. Rec-ommended additional measures or amendments to BEMAP/M or EMAP/M shouldbe presented here.

b. Environmental Quality Status

Only the key conclusions on meeting the set EQPLs are included in this section.

c. Environmental Management Plan Status

Only the key conclusions about the status of EMP implementation and recom-mended additional measures or amendments should be presented here.

d. PEMAPS Score

The proponent should fill up or update the project’s environmental risk scoreusing the PEMAPS earlier discussed in this Handbook.

e. Work Plan for Next Monitoring Period

The specific actions for the next monitoring period, including carry-overs fromprevious monitoring periods, should be detailed in this section.

7. Appendices

BEMAR or SMR shall typically append the following information:

• Location of Sensitive Receivers and Monitoring Stations• Location Plan of Plant and Facility Process Flow Chart• Implementation Schedule and Status• Environmental Monitoring Technical Summary• Process Audit Proforma• Regulatory Compliance Proforma• Complaint Log• Calibration Certificate• Data Presentation



REFERENCES:

Asian Development Bank (ADB). 1996. Economic Evaluation of Environmental Impacts -A Workbook Part 1. Manila: ADB, Philippines.

Guerrero, Sylvia H. et al, 1993. Public Participation in EIA. A Manual on Communication.Environmental Management Bureau and the Asian Development Bank.

DENR Administrative Order No. 21-92. Amending the Revised Rules and RegulationsImplementing P.D. 1586 (Environmental Impact Statement System).

DENR Administrative Order No. 96-37. Revising DENR Administrative Order No. 21, Series of1992, To Further Strengthen the Implementation of the Environmental Impact Statement(EIS) System.

DENR Administrative Order No. 2003-30. Implementing Rules and Regulations on theRationalization of the Philippine Environmental Statement (EIS) System Implementation.

Environmental Assessment and Noise Division, Environmental Protection Department,Hongkong. 1998.

Environmental Management Division-Environmental Management Bureau-DENR. Philippines.

Lohani, Bindu N. et al. 1997. Environmental Impact Assessment for Developing Countries inAsia Volume 1 and 2. Asian Development Bank.

Presidential Decree 1586. Establishing an Environmental Impact Statement System IncludingOther Environmental Management Related Measures and for Other Purposes.



APPENDICES

1 PEMAPS Scoring Guidelines2 Examples of Environmental Policy and Objectives3 EMB’s Compliance Monitoring Form No. CM-34 Stressor-Impact for Various Power Project Types5 ESRS6 Examples of Sampling and Monitoring Plans7 Examples of EQPLs

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