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Personally received by:

Ms. Cara Michelle Daquep


Provincial Administrator
Joint position paper of the Ilocos Network for the Environment, the Social Action Commission
of the Archdiocese of Nueva Segovia and the Ilocos Sur Ecumenical Movement. Page 1 of 7

JOINT POSITION PAPER ON THE


PROPOSED DREDGING OF THE ABRA RIVER
Background
The subject of this paper is the Flood Control and Riverbank Protection & Environmental
Enhancement of Abra River Project that cover the municipalities of Santa, Caoayan & Bantay with the
objective of mitigating the flood & bank erosion by increasing the discharge capacity of the river by
declogging & desilting of Abra River & its distributaries. Resolution No. 92 Series of 2012 of the
Provincial Board of Ilocos Sur operationalized the project.
The project came into being in 2009, with the Provincial Government of Ilocos Sur applying for
an Environmental Compliance Certificate (ECC) on May 5 to dredge the silted mouth of the river. An
ECC was awarded by the Department of Environment and Natural Resources through the
Environmental Management Board Regional Office No. 1 (EMB-I) on June 05 of the same year certifying
the eligibility of the PGIS to proceed with the project.
Dredge vessels arrived and anchored at Brgy. Pantay-Tamurong on December 2011. The vessels
composed of one steel dredger and two barges. The vessels (Tommy 101, MV Hug Long 14 & MV Hung
Long 15) belong to Hung Lung Transport & Trade Joint Stock Company and managed by Isla Verde
Mining & Development Corporations (Isla Verde) based on documents from the Maritime Industry
Authority.
On December 21, the Philippine Coast Guard stopped the vessels previously mentioned for
failing to show the necessary documents for their magnetite concentrate cargo and mining operation of
the coast of Caoayan. The same vessels were the subject of protest by officials and residents of Brgy.
Villamar in the same municipality in January 2013. When members of the Philippine National Police and
broadcast media boarded the ship, the crew only presented an ECC dated June 2009 issued for PGIS.
In March 2015, Isla Verde proceeded in the construction of their crushing and magnetic
separation facility in Brgy. Pantay-Tamurong. The company also started its dredging operation,
depositing dredged aggregates to reclaim some areas in Poro Island. The company undertook these
activities in the absence of an ECC and area clearance from the DENR to conduct a reclamation project.

Joint position paper of the Ilocos Network for the Environment, the Social Action Commission
of the Archdiocese of Nueva Segovia and the Ilocos Sur Ecumenical Movement. Page 2 of 7

Our Concerns
1. Dredging is not a long term and economical solution that may create more negative impacts
than good. Metro Vigan or the communities comprising the area sits on a natural flood plain of
the Abra River, thus, desilting and declogging the channel may provide enough space to contain
or allow moderate floods to immediately subside but will not provide significant protection in
case of major flood events considering the size and capacity of the Abra River Basin.
Furthermore, whatever space provided by dredging is quickly lost because of the huge amount
of sediments and aggregates carried downstream from denuded mountains and mining
operations upstream.

Dredging creates a deeper and steeper channel that allows faster flow of water. Faster current in
big river systems means greater energy that causes scouring and tears in the riverbank
increasing bank erosion. High velocity river flow during heavy rains increases the overall severity
of the flood and the danger and damages that goes with it. The 2 meters to 6 meters excavation
depth designed by Isla Verde for the project will not only increase water velocity but will create
higher river banks that are prone to slumping (erosion). This may also increase tidal current
resulting to greater saltwater intrusion in the estuary.

Studies also points to biodiversity loss caused by dredging operation. Excavation of the riverbed
increases the suspended sediments (bottom & surface plume) that adversely affect the
breathing mechanisms of fishes and mollusk. Suspension of organic detritus lowers dissolve
oxygen while settling sediments may cover sea grass beds and corals that will lead to their death
and destruction. Increased water velocity and tidal currents, and altered ecology that may result
to fish migration and habitat destruction. This will definitely produce negative impact to the
livelihood of the communities that are mainly dependent on fishing.
2. Isla Verde Mining & Development Corporations credibility and intent in undertaking the
project if questionable. The companys propensity to violate Philippine Environmental Laws are
very apparent in its conduct from arrival up to the present. Its barges were caught illegally
transporting magnetite that indicates extraction operation during the period it was docked and
afloat the coast of Caoayan. Isla Verde conducted environmentally critical activities without the
Joint position paper of the Ilocos Network for the Environment, the Social Action Commission
of the Archdiocese of Nueva Segovia and the Ilocos Sur Ecumenical Movement. Page 3 of 7

necessary documents and sufficient consultation with the affected residents and concerned
organizations. The feasibility study undertaken by the company and work plan submitted for the
dredging operation did not include measures to mitigate the possible impacts (such as those
mentioned in #1) to biodiversity, fishery and the livelihood of the communities.

Furthermore, as a government project, the Flood Control and Riverbank Protection &
Environmental Enhancement of Abra River Project should have passed the regular bidding
procedure and public consultation prior to its implementation. While we appreciate the public
consultation conducted by PGIS last September 2, we consider it as an offshoot of the vigilance
of residents, church institutions and different organizations since the company has already
started to implement parts of its plan even before the stakeholders dialogue. The entire
operation is marred with profit-driven interest rather than providing service for PGIS and the
people.

3. Flooding caused by the Abra River must be looked at a larger perspective at the
CATCHMENT SCALE and on the CONTEXT OF CLIMATE CHANGE, and not merely on the
siltation problem downstream. The overflow of the Abra River and subsequent flooding of
nearby areas are result of interconnected factors such as historical siltation caused by extractive
industries upstream and surface runoffs, heavy rainfall, forest denudations, etc. This means that
dredging alone cannot solve the annual flooding experienced by communities in the mouth of
the river. Deepening the channel cannot guarantee that Abra River will not overflow in case of
extreme weather conditions where rainfall may exceed previous volume (such as what
happened to Ineng & Lando).

IN CONCLUSION, we recognize that dredging has a place in flood control and management as well as
river rehabilitation. However, it is not the practical and immediate solution. It present risk that may
amplify the impacts of flooding and negatively affect biodiversity and livelihood. Increasing the
adaptive capacity of the communities and response capability of local governments in times of flooding
and related disasters should remain the foremost answer to the flooding woes of Metro Vigan.

Joint position paper of the Ilocos Network for the Environment, the Social Action Commission
of the Archdiocese of Nueva Segovia and the Ilocos Sur Ecumenical Movement. Page 4 of 7

Our Recommendations
1. Put the dredging plan on hold while:
(a)

Commission an in-depth study both on the geological and biological considerations


of the projects. We appreciate the initiative of the PGIS to commission a geological
study (currently conducted by EDASS), we thus urge the concerned officials to put the
plan on hold while the study is undertaken. Dredging plan should be in accordance with
the recommendation of the study. A separate impact assessment on biodiversity and
livelihood must also be undertaken and mitigating measures must be in place before any
operation commenced. Any adverse impact that the company fails to provide
appropriate measure is sufficient to stop and abandon the operation.

(b)

Increase the adaptive capacity of the communities. Most if not all LGUs the river
traverse have copies of the flood risk assessment conducted by the Mines & Geosciences
Bureau. Officials should utilized this material to project scenarios and plan appropriate
actions to be undertaken. Flood forecasting and early warning systems, and evacuation
procedures must be in place. Local government should invest in disaster preparedness
trainings (response, relief and rehabilitation), and necessary facilities and equipment for
such events. Develop policy and governance mechanism to improve disaster risk
mitigation such as guidelines for preemptive evacuations, disaster preparedness
committees (DPCs) at the barangay/community level and appropriate security for
properties left behind by the residents. Craft engineering and architectural guidelines
based on the delineated and/or flood-prone areas and waterways, and strictly implement
said guidelines.

2. Create a comprehensive and strategic plan that includes flood control, environmental
management, and housing and resettlement to ensure sustainable river and flood plain
management. Local governments must undertake careful planning to identify appropriate
flood control measures such as rock berms, ripraps and concrete dikes. The engineering and
environmental officers must prioritize the institution of natural flood barriers and soil
protections (afforestation utilizing bamboo and mangrove). Restore and clear other
distributaries of the Abra River to allow more exit for excess water. Implement a combination of

Joint position paper of the Ilocos Network for the Environment, the Social Action Commission
of the Archdiocese of Nueva Segovia and the Ilocos Sur Ecumenical Movement. Page 5 of 7

engineered and natural flood measures to create a more effective protection against massive
and destructive floods.

Flood management includes environmental management programs and projects that can
minimize water runoffs, slows water flow and increase the holding capacity of catchment areas.
These measures include preserving and increasing the forest cover, minimize activities that
increases sediment load such as mining, strict regulation of quarry operations and the likes.
Regular clearing of waterways or narrow distributaries of the river can also mitigate flooding.

Finally, local government in all levels must consider and strategically plan on possible
resettlement program especially for the communities lying in danger zones. Based on the
projection of UP National Institute of Geological Sciences, the Abra River flood plain main
experience a flashflood similar to the one experienced in Iligan City during Typhoon Pablo.
Taking this information seriously put the communities of Dammay, Oribi and Poro in a
hazardous position. However, such plan to resettle communities must have a democratic and
inclusive consultation, and consider the provision of durable, humane and affordable (if not free)
housing, and sufficient and familiar livelihood for the people.
3. Institute mechanism to promote shared responsibility with other local governments (Abra &
Benguet) to stop siltation and pollution caused by mining operation upstream. The
management of the Abra River System is not the sole responsibility of PGIS but all the provinces
traversed by the river. Sediments comes mainly in the upland areas where mountains and forest
are strip of trees and the soil loosened because of mining activities. Thinning forest cover also
increases surface runoffs and decreases the water holding capacity of the basin that results to
the huge volume of water draining to the river. Thus, PGIS must also engage the leaders/officials
of adjacent provinces regarding their shared responsibility in managing the river system.

The PGIS must also take into consideration the historical accountability of Lepanto
Consolidated Mining Company (LCMC) for the massive siltation of the river. Thus, we urge the
officials to reaffirm or renew their previous resolutions against the operation of LCMC and

Joint position paper of the Ilocos Network for the Environment, the Social Action Commission
of the Archdiocese of Nueva Segovia and the Ilocos Sur Ecumenical Movement. Page 6 of 7

pursue appropriate actions to hold the company responsible in undertaking rehabilitation


measures in areas and communities traversed by the Abra River.
4. We express our appreciation for the trust and confidence of Gov. Ryan Singson to our group
as reflected by his offer to become part of the Multipartite Monitoring Team (MMT) but we
regret that we have to decline the offer. We believe that the MMT will limit our monitoring
work and may compromise our independence. The MMTs framework is based on a flawed
environmental policies administered by the same offices that allowed blatant violations of
environmental laws to take place for a long time in the province. Based on our actual experience,
concerned government offices only undertook dialogue, consultations and legal actions only
after public pressure became strong. Thus, our work will focus on empowering the communities
and organizations able to assert their rights for a healthy and balanced ecology. We will
continue our independent monitoring and hope that PGIS will provide our group with copies of
the reports from the MMT and other related undertakings. In the spirit of principled
engagement and working for the common good of the people, we will keep the PGIS abreast
with our views and observations for its consideration.
5. Finally, in case the dredging program proceeds despite our appeal to put it on hold, then we
propose the following:
(a)

Before any commercial undertaking, dredge materials will be utilize first for the
construction of flood and erosion control structures, and deposited in identified areas to
increase elevation.

(b)

Dredge aggregates will only be limited for domestic market and utilize free of charge for
government projects to lower construction cost.

(c)

PGIS will market the aggregates and will pay the company providing the dredging
service from the proceeds. The proceeds less the payment for the company is to be
classified as trust fund allocated for the development programs and DRRM fund of
affected barangays. Financial records will be open for scrutiny of interested parties.

(d)

PGIS must disqualify Isla Verde for its previous violations of Philippine Environmental
Laws and undertake a transparent bidding or selection process for companies that will
provide the dredging service for the project.

Joint position paper of the Ilocos Network for the Environment, the Social Action Commission
of the Archdiocese of Nueva Segovia and the Ilocos Sur Ecumenical Movement. Page 7 of 7

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