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Until its environmental impact is understood, decision on Parex is premature

October 16, 2021

It is crucial for all of us — even for San Miguel Corp. (SMC) and its shareholders — to understand the environmental impact of the Pasig River Expressway (Parex). Parex should not go forward unless it has undergone the same environmental and economic due diligence that major public and private infrastructure projects are subject to.

Many experts believe that the negative impacts of Parex far outweigh any temporary benefits. The harm that Parex could bring might even exceed SMC’s financial capacity. No final decision on Parex should be made unless its environmental and other impacts are well understood. It is good practice, it is the policy of the government and it is the right thing to do.

There are many potential harmful impacts that stakeholders, the public and decision-makers know very little about, such as: the additional heat, noise and air pollution that will affect the physical and mental health of people in neighboring communities; the reduced access of Metro Manilans to green public space along the banks of the Pasig; the “urban heat island effect” of the expressway’s large concrete slabs, which will cast a shadow on the river; the possible damage to priceless built heritage on both sides of the Pasig; the increased disaster risk for structures on the riverbed and along the riverbanks due to heavy vibrations during construction and operation of the expressway; the impact of increased motor vehicle use due to induced demand; the impact of the expressway structures and the pollution from its motor vehicles on the ecology of the Pasig River and Manila Bay; the diminished attractiveness and accessibility of tourism resources along the Pasig River; and the “urban blight” that would affect neighborhoods sitting in the shadow of elevated expressway structures. The project should not proceed if Parex’s harmful impacts are found to be significant or if they outweigh the projected benefits of Parex.

Let’s look at what Philippine environmental policies require. Under the directives of both Malacañang and the Department of Environment and Natural Resources (DENR), major infrastructure projects need to conduct an environmental impact study at the same time as the preparation of the project feasibility study. Moreover, DENR guidelines on the conduct of the environmental impact assessment, which is mandatory for all projects considered environmentally critical, specify that the approval/clearance of concerned agencies and local governments should come only after the issuance of an environmental compliance certificate (ECC).

Malacañang Administrative Order 42 on the Environmental Impact Statement (EIS) System instructs in Section 2.A that: “Project proponents are hereby directed to simultaneously conduct the environmental impact study [as required for ECC application] and the feasibility study of the proposed project.”

The Revised Procedural Manual for DENR Administrative Order 30 Series of 2003 (DAO 03-30) explains in Section 4 the rationale for conducting the Environmental Impact Assessment (EIA) study simultaneously with the preparation of the feasibility study: “It is during the feasibility study (FS) stage when a proponent defines its range of actions and considers project alternatives; thus, it is the most ideal stage in the project cycle wherein the EIA study will have most added value… During the preparation of the project FS, the proponent initiates the detailed EIA. The formulated Environmental Management Plan and corresponding costs and benefits are then inputted into the FS as a basis for decision-making of the proponent on the final project option, siting and design.”

Essentially, an EIA study prepared during the feasibility study stage ensures that environmental concerns are considered in project design and that environmental impacts and costs are included in the project feasibility analysis prior to any major decision on the project.

Under the Environmental Impact Statement System, approvals by concerned government agencies should follow only after an EIA has been completed by the Project Proponent and after an ECC is issued by DENR-EMB. The DENR Revised Procedural Manual in Section 3 (Purpose of the EIA Process) discusses the proper sequence of EIA, ECC and project approval: “As a basic principle, EIA is used to enhance planning and guide decision-making… A positive determination by the DENR-EMB results in the issuance of an ECC document, to be conformed to by the proponent and represents the project’s ECC. The release of the ECC allows the project to proceed to the next stage of project planning, which is the acquisition of approvals from other government agencies and local government units (LGUs), after which the project can start implementation.”

In the chronology of the Parex project, the Toll Regulatory Board (TRB) approved the technical and financial aspects of Parex on July 14, 2021, the same day that the initial project scoping meeting with stakeholders (the first step in the preparation of an EIA study) was conducted by SMC. As of Oct. 14, 2021, DENR’s online ECC/EIS Monitoring System still showed “Under Scoping/Screening” as the status of the Pasig River Expressway Project. This means that an EIA study for Parex is still at an early stage (public hearings are yet to be scheduled) and an ECC has not yet been issued.

Accordingly, SMC’s technical and financial proposal on Parex (the basis for TRB’s decisions) was prepared and submitted to TRB prior to public hearings with stakeholders, prior to the completion of an EIA study and prior to any guidance and feedback from DENR on the project’s environmental impacts. Without the benefit of a completed EIA study or feedback from DENR’s ECC process, the TRB approved the draft Supplemental Toll Operation Agreement for the Parex Project on Sept. 8, 2021.

At this time, Parex’s details remain unclear and are not well understood by stakeholders. Public hearings are yet to be conducted. The Parex that SMC has described in recent weeks is markedly different from the project description of Parex presented to the TRB and to stakeholders on July 14, 2021. Project components continue to evolve. A significant change in project design might require SMC to go back to TRB with a new application. Because the ECC process remains pending, any earlier project feasibility analysis for Parex has likely excluded some crucial environmental costs and impacts. With all of these concerns, there should be no decision on Parex until the knowledge and procedural gaps on Parex are filled.

Major infrastructure projects, including those that are implemented by government agencies, are required to comply with the procedures under the EIS System of DENR. The system works to protect all of us. Private sector projects, such as Parex, should be held to the same or a higher standard. With no clear picture of Parex’s components, with limited understanding of its environmental impacts, with an incomplete analysis of project feasibility, without an accounting of all project benefits, impacts and costs, any decision on Parex appears premature.