A penalty for violations, according to Section 28, Chapter 5 of the Philippine

Clean Water Act of 2004 (RA 9275), is set to Php 10,000.00 – Php 200,000.00 per day
per stipulation violated. For the proceeding calculations, the minimum fine is assumed
to be applicable should the wastewater treatment facility violate any stipulation in the
Environmental Compliance Certificate (ECC).
Listed below are the possible conditions that the treatment facility may violate. A full
list of the stipulations the ECC requires can be found in Appendix 9.4.
 The plant operations shall conform with the following provisions: RA 6969 (Toxic
Substances and Hazardous and Nuclear Wastes Control Act of 1990); RA 8749
(Philippine Clean Air Act of 1999); RA 9003 (Ecological Solid Waste Management Act of
2000); RA 9275 (Philippine Clean Water Act of 2004); and
Other relevant policies
 That the proponent shall ensure proper handling and disposal of hazardous
waters like used oil and batteries to avoid contamination of affected water body and soil.
The proponent should submit to this Office copy of the signed MOA between the
proponent and the third party TSD facility operator for the treatment of generated
hazardous wastes materials;
 The sludge generated from the WTF/ septic vaults shall not be disposed of to any
water body or public drainage. The proponent shall provide adequate treatment of
sludge generated from the WTF/ septic vaults or hire a third party treater for hauling and
treatment of generated sludge. If the sludge will be treated thru a 3rd party treater, a
MOA between the proponent and the third party treater shall be submitted to EMB4A
before project operation and a Certificate of Treatment (COT) shall likewise be
submitted within one (1) week after each hauling event. If the sludge will be treated
onsite, disposal of sludge to any water body shall still be avoided, but instead same be
used as fertilizer or soil conditioner or any other purpose as long as it will not cause any
negative environmental impacts;
 That a Material Recovery Facility (MRF) should be constructed within the project
area within ninety (90) days from the start of construction stage. The MRF should
accommodate the solid waste generated inside the facility. Composts shall be utilized
as soil conditioner or fertilizer and recyclable materials shall be collected by private
contractor. A zero waste management scheme shall be adapted to minimize disposal of
garbage to LGU’s disposal site.
 The proponent should establish a cistern tank or rainwater catchment after 6
months from the issuance of this ECC. Rainwater collected shall be utilized for flushing
toilets and plant watering to prevent storm run-off water overflowing to nearby areas or
road networks.
The calculation of the penalty fee will be based on the assumption that all the
stipulations above are violated. There are five stipulations stated giving a total penalty of
Php 50,000.00 per day. This penalty will be counted as benefit if all the stipulations are
complied. This can be counted as disbenefit when the standards are not complied.
Another benefit of the wastewater treatment facility is the possibility of reprocessing and
selling the spent adsorbents and sludge as raw materials for ceramics production
(Verbinnen, Block, Caneghem, & Vandecasteele, 2015).