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8/8/2019 Eis - Bio Ethanol
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CRITIC ON THE ENVIRONMENTAL IMPACTSTATEMENT OF THE
PROPOSED 100,000 LITERS PER DAY BIOETHANOL
MANUFACTURING PLANT PROJECT
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INTRODUCTION
In support of the Bio Fuels Act, Alsons Consolidated Resources, Inc., the Proponent,
proposed to erect a 100,000 liters per day Bioethanol Manufacturing Plant Project to
provide an environmentally-friendly, energy efficient and cost effective petroleum
fuel additive. The project will be located in a 17.6 hectares of idle land in Barangay
Mambuaya in the City of Cagayan de Oro, Misamis Oriental. The project is classified
as Non Environmentally Critical Project (NECP) by the DENR.
Components of the processing plant include the Milling of the Cassava Feedstock,
Fermentation, Distillation, Dehydration, Storage Facilities and Instrumentation and
Control. Other support facilities include Combination of Coal Biogas Biomass
Fired Steam Boiler, Water Supply and Distribution System, Fire Protection System
and Extraction of water supply from Munigi River. To ensure mitigation of pollution
effects, the following measures are instituted such as Air Pollution Control Devices
(APCDs) to offset pollution effects on air, Waste Water Treatment Plant Zero
Effluent Technology, to ensure that water are recycled and re-used, and,
Solids/Slops Management System, to ensure the proper disposal of solid waste.
The project is estimated to cost 2.6 billion pesos with manpower complement of 300
500 during construction peak and down to 115 personnel during full commercial
operation.
THE PROJECT
Section 2 of the Biofuels Act of 2006 states that, It is hereby declared the policy of
the State to reduce dependence on imported fuels with due regard to the protection
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of public health, the environment, and the natural ecosystems consistent with the
country's sustainable economic growth that would expand opportunities for
livelihood by mandating the use of biofuels as a measure to:
a) Develop and utilize indigenous renewable and sustainable-sources clean energy
sources to reduce dependence on imported oil.
b) Mitigate toxic and greenhouse gas (GSG) emissions;
c) increase rural employment and income; and
d) Ensure the availability of alternative and renewable clean energy without any
detriment to the natural ecosystem, biodiversity and food reserves of the country.
The projects aims to support the Governments thrust that encourages the use of
ethanol blend which is an environmentally friendly fuel additive on petroleum
products to reduce the effects of pollution and improve the prices of fuel products
while effectively balancing pollution effects. It will generate employment
opportunities in the area and be able to take advantage of technology transfer. This
will eventually benefit the whole economy as it will reduce the dependence on
imported petroleum products.
During construction, the land shall be converted from agricultural to industrial-
agricultural classification in order to comply with the requirements of land
classification. Necessary permits shall be applied from the DENR and comply with all
its requirements in the cutting of few trees and terrestrial flora/fauna clearing.
Domestic sewage shall be an engineered sceptic vault to ensure effective holding of
waste water. In order to comply with domestic waste disposal, Solid Waste
Management Law, RA 9003 and its implementing rules shall be adopted.
Construction wastes shall be handled by a third party disposal team and those that
can be re-used shall be recycled.
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During operation, process water shall be sourced out from the Munigi River and
discharge shall be through the use of Zero Effluent Technology. Excess waste water
from waste water technology shall be used to irrigate the plantation during non-
rainy days. Operations shall comply with the Clean Water Act and its implementing
rules and regulations. Air pollution will be mitigated by the use of coal combustion
design and technology that will control the carbon dispensing in the air. Coal usage
shall be in accordance with the specification that is consistent with the clean air
program set by the project. Air pollution control devices shall also be put in place to
help mitigate what the preceding plans cant control. Emission shall also be subject
to engineered emission stack. Handling of coal and its storage shall be under
prescribed safety requirements.
Environmental Impact Assessment (EIA) is being conducted to obtain an
Environmental Compliance Certificate from the DENR. EIA is being conducted by a
team of technically and environmentally experienced individuals who has prepared
approved EIA reports for various Environmentally Critical Projects (ECAs). General
approach to the assessment shall follow the usual format used by previous EIA
reports. First level scoping shall be done to serve as basis for the content/format of
the EIA report. Second level scoping shall be done swerving as basis for identifying
and addressing the environmentally-related concerns of the stakeholders.
ENVIRONMENTAL IMPACT ASSESSMENT
The Environmental Impact Assessment Team cosists of a Team Leader who is in
General Consultancy for other bioethanol and coal fired boiler projects, who, also is
an Industry Sector representative to EIA Systems Review with the Environmental
Management Bureau EMB. The assistant Team Leader has wide experience and
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exposure to EIA preparation and EIA Systems Review with the EMB. Eight other
members of the EIA team are in the field of Sociology, Sociology, Terrestrial Faunai
Ecology, Terrestrial Floral Ecolgy, Chemical Engineers, learned in Air Quality/Air
Dispersion Modelling, Site coordinator and a site investigator.
The methodology instituted is reasonably within the ambits of the regulations on EIA
preparation and have been performed well as presented by the Environmental
Impact Statement EIS. The result of the EIA shows no major environmental risk
unmitigated. Wastes dispersed in the air are captured by its process and other air
pollution control devices. Water wastes are controlled because water used are 70%
converted to steam which will just evaporate. The 30% shall be extracted from the
solids and will pass through its waste water treatment facility so that it can be
recycled and re-used in its operation thus minimize the dependence to river water
source. The rest of the recycled waste water shall be used for irrigation of cassava
plantation.
The ECC application was hounded by oppositions from various sectors including the
residents, barangay officials, government dignitaries, the Catholic church and the
media. These sectors have rallied toward the disapproval of the ECC application for
grounds that the site is within close proximity to Tagpangi River and the Iponan
River which are both within the 3000 ha. watershed zone of Cagayan de Oro City.
Through such oppositions, the oppositors succeeded in halting the proposed project
as Alsons had scrapped the project.
A newspaper reports the stoppage of the project by Alsons as such:
MANILA, Philippines--Alsons Consolidated Resources Inc. has scrapped its planned
bioethanol project in Cagayan de Oro City, citing certain ambiguities in the
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implementation of the Biofuels Law and difficulties in dealing with some
government agencies as reasons.
In a disclosure submitted to the Philippine Stock Exchange Monday, ACR chief
financial officer and compliance officer Luis Ymson Jr. said that during Fridays board
meeting, the companys board decided to junk the project due to deterrents
stemming from various fronts, including the government, the Catholic Church and
even nongovernment organizations.
ACR regrets having taken this action, which has stemmed from, among other
deterrents, its perception of the current ambiguities in the implementation of the
Biofuels Act, its experience of unjustifiable delays in the issuance of an
environmental clearance certificate by the [Department of Environment and Natural
Resources] regional office, the congressional intervention into the executive branch
functions over the issuance of the projects ECC, and the Catholic Churchs and the
NGO sectors apparent lack of genuine concern for the plight of the poor," he said.
The project just died of natural causes through withdrawal of proponent. Although,
the concerns of the oppositions are outlined, the EIS does not answer the concerns
at hand. It does not consider the location as a matter of a risk factor to the
watershed area and its effects on it. How much of a risk does the project can impact
the watershed if any, even with the mitigations instituted to suppress pollution.
There has been no quantification as to the risk involved. The EIS may be useful if it
can anticipate the equivalent impact of a per day failure of any of such mitigations
because conduit to highly delicate resources surrounding the location of the project
are directly adjacent. The opposition is basically maintaining that the project is just
within the area of the watershed which is not suitable for industrial operations.
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The Clean Air Act of 1999 shows the intention of the legislators to protect the right
of each citizen to a healthful ecology as such:
SEC. 2. Declaration of Principles. - The State shall protect and advance the right of
the people to a balanced and healthful ecology in accord with the rhythm and
harmony of nature.
The State shall promote and protect the global environment to attain sustainable
development while recognizing the primary responsibility of local government units
to deal with environmental problems.
The State recognizes that the responsibility of cleaning the habitat and environment
is primarily area-based.
The State also recognizes the principle that polluters must pay
Finally, the State recognizes that a clean and healthy environment is for the good of
all and should, therefore, be the concern of all.
Excerpts from the "Ecological Solid Waste Management Act of 2000." states its
policies:
Sec. 2. Declaration of Policies. - It is hereby declared the policy of the State to adopt
a systematic, comprehensive and ecological solid waste management program
which shall:
(a) Ensure the protection of the public health and environment;
(b) Utilize environmentally-sound methods that maximize the utilization of
valuable resources and encourage resource conservation and recovery;
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(c) Set guidelines and targets for solid waste avoidance and volume reduction
through source reduction and waste minimization measures, including composting,
recycling, re-use, recovery, green charcoal process, and others, before collection,
treatment and disposal in appropriate and environmentally sound solid waste
management facilities in accordance with ecologically sustainable development
principles;
(d) Ensure the proper segregation, collection, transport, storage, treatment and
disposal of solid waste through the formulation and adoption of the best
environmental practice in ecological waste management excluding incineration;
(e) Promote national research and development programs for improved solid
waste management and resource conservation techniques, more effective
institutional arrangement and indigenous and improved methods of waste
reduction, collection, separation and recovery;
(f) Encourage greater private sector participation in solid waste management;
(g) Retain primary enforcement and responsibility of solid waste management
with local government units while establishing a cooperative effort among the
national government, other local government units, non- government organizations,
and the private sector;
(h) Encourage cooperation and self-regulation among waste generators through
the application of market-based instruments;
(i) Institutionalize public participation in the development and implementation of
national and local integrated, comprehensive, and ecological waste management
programs; and
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(j) Strength the integration of ecological solid waste management and resource
conservation and recovery topics into the academic curricula of formal and non-
formal education in order to promote environmental awareness and action among
the citizenry.
CONCLUSION
The environmental policies and laws provide for mechanism to control pollution but
do not answer directly all questions surrounding a number of issues. It assigns the
responsibility to certain government agencies for its implementation which
depending on the strength and direct concern of each agencies, can be ineffective
in addressing the issues at hand. The law does not pinpoint the process that will
address issues and bring about specific environmental concern. It just prescribed
the agency responsibility.
In some ways, having the ECC as a pre requisite to project approval, somehow
performs the essence of the law being that the approval is anchored with public
consultations and discretion of the government agency vested with approving
rights. The strong opposition from the different sectors, made it very difficult for
the DENR to hastily make any findings and approval of the project. I should expect
that the law should by itself sufficient to address environmental violation and issues
with independent consideration of its rules and not by pressures of oppositions or
by a mob.