To: Department of Environment and Natural Resources (Denr) Cc: Energy Development Corporation Municipal Environmental And
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TO: DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES (DENR) CC: ENERGY DEVELOPMENT CORPORATION MUNICIPAL ENVIRONMENTAL AND NATURAL RESOURCES OFFICE (MENRO) OF VALENCIA PROVINCIAL ENVIRONMENT AND NATURAL RESOURCES OFFICE (PENRO) ! LGU-NEGROS ORIENTAL SP COMMITTEE ON ENVIRONMENT ! PETITION OPPOSING THE ISSUANCE OF ENVIRONMENTAL COMPLIANCE CERTIFICATE FOR THE PROPOSED SOUTHERN NEGROS GEOTHERMAL PLANT ! 60 MW EXPANSION PROJECT Mt. Talinis or Cuernos de Negros mountain range in Negros Oriental has been identified as a Key Biodiversity Area (KBA) spanning 23, 565 hectares covering the municipalities of San Jose, Sibulan, Dauin, Zamboanguita, Siaton, Sta. Catalina, Pamplona, Amlan and Valencia. It has been identified as one of the top on the list of conservation priority areas due to its high endemism and severity of threats. Old growth forest still surrounds the peak and lakes covering an area of about 4800 hectares. About 3000 hectares is classified as close natural forest while about 1800 hectares is secondary natural forest. This remaining forest patch is not only a habitat to wildlife but also serves !as water source for the entire southern part of Negros. This mountain is not only home to rich biodiversity of flora and fauna with high endemism but it is also our identified watershed providing water to about 15 municipalities and cities in the southern part of Negros Oriental. It is the remaining 1% !natural forest of Negros Oriental, our last frontier. The Energy Development Corporation (EDC) is yet again proposing their second expansion project in Mt. Talinis with project capital cost of PHP 27 Billion applying an Environmental Compliance Certificate (ECC) for Southern Negros Geothermal Project (SNGP) in its 5,163 hectares development block. Currently the EDC’s geothermal power plant’s capacity is at 222.5 MW supplying energy to Negros, Cebu and Panay Islands. Their proposed expansion seeks to add 60 MW in their total steamfield capacity to 282.5 MW which includes addition of 43 wells (production and injection wells), 11 well pads, new pipelines and corridors (roads), additional Fluid Collection and Reinjection System (FCRS) and additional support and temporary facilities. As stated in their project summary, the drilling of new geothermal wells and construction of the aforementioned !facilities will be done also to prepare for possible future developments. We, the petitioners in representation of others, including minors and generations yet unborn, directly or indirectly affected by the proposed project, invoking divine assistance and uphold and protect the constitutional right to a balanced and healthful ecology, hereby submit an opposition to the issuance of an Environmental Compliance Certificate (ECC) to Energy Development Corporation (EDC) 60MW expansion project !in their proposed 5,163 hectares development block because of the following reasons: 1. The Public Hearing conducted on March 10, 2016 at Yeva Gymnasium, Valencia, Negros! Oriental was non-compliant as it was a mockery due to the following: a. Numerous individuals, groups or representatives from NGO’s present were not given a chance to air their concerns, comments, questions and opposition because the time they allotted for the open forum is limited and was not open to all who attended. b. It was not clear if DENR/EDC had invited all those that will be directly or indirectly affected by the proposed project base on the fact that Mt. Talinis is the source of water of over 15 municipalities and cities in the southern part of Negros Oriental. c. Some questions were not addressed properly taking into account that many of the individuals who stood in front of the microphone were not throwing questions but endorsement of the expansion project. d. Majority of the attendees were brought by EDC to make the Public Hearing appear successful with overwhelming approval as justified by their uniformly prepared cartolinas with captions of praise for EDC. e. The powerpoint presentation of the proposed 60megawatt expansion project was blurry and was not clear. f. The speaker from EDC tasked to explain the project, its impacts and proposed mitigation measures sounded so incompetent since his way of delivering the presentation to his audience was haphazardly done and treated the audience like children. (Ex. He did not explain the chemical substances especially its nature because anyway we don’t understand it.) g. There was no presentation on how much percentage of their mitigation measures compared to the long-term damage it will bring to the environment, communities and people that will be affected – as mitigation is an admission of injury to environs. h. DENR-EMB as if was an agency representing EDC. There was bias in the undertaking. We believe that the proponent should be the one to address concerns of the impacts of the project and not DENR as they are the agency to review the project vis-à-vis the response of the communities and affected !parties. 2. The proposed development block of SNGP is an Environmentally Critical Project (ECP) in an Environmentally Critical Area (ECA) and requires the conduct of Environmental Impact Statement (EIS) System. However, while it is stated in the letter from DENR-EMB that their EIA report is downloadable at EMB’s website, it confused us that during the public hearing one of the speakers/panelist called the report! an EPRMP. 3. EDC is applying an ECC for an already on-going economic undertaking. While EDC has not yet addressed their first expansion issues involving the cutting of 576 trees, here comes the second one seeking to apply for an Environmental Compliance Certificate! (ECC) that also covers the former. ! 4. In 2011, Typhoon Sendong washed away people’s lives and properties along the Banica River which connects to the lush forests of Mt Talinis. With the 576 trees being previously cut and more for this proposed expansion excluding their “possible future developments,” people downstream of Okoy and Banica rivers are highly susceptible to the impacts of the climate crisis that will bring about floods and other disasters.! 5. EDC-SNGP summary of impacts indicates that the proposed additional steam production will exposed household to high H2S concentration, noise pollution during well testing, displacement that will also threaten their livelihood and landslides that is already happening. There are no safety measures that humanity including the unborn is secured of their land holdings, health risks and hazards of unstable! ground. 6. There is no stipulation on the extent of sacrifice the surface rights owners have in the event the project is abandoned for any reason. If abandonment happens, who still benefits from the usage of the surface? What is the assurance and insurance that there! is no technical land grabbing? 7. There is no full disclosure of the parameters of engagement, to mention the equity of the community where EDC is investing 27 Billion. How much is the community equity and ROI (Return of Investment)? And how much is EDC’s ROI? The enormity of the investment alarmed us on the extent of its impact to the environment and to the people around the geothermal plants as well as those far but will be affected because of the vast extent of Mt. Talinis’ reach. We know geothermal energy is identified as a renewable energy source but extensive development will make Mt. Talinis suffer in the future and that will include us the ! present generation and the generations yet unborn. We are with you in protecting the environment. May you help us protect our last remaining natural forest, a key biodiversity area in the Philippines, by ensuring there will be no more expansion project in a critically fragile ecosystem at the Mount Talinis Range. We hope to get your support in protecting our last remaining natural forest of Negros Oriental..