2

A. THE SUBJECT APPLICATIONS FOR WATER PERMITS SHALL AND WILL ADVERSELY AFFECT THE ECOLOGICAL BALANCE OF LAGUNA LAKE. B. THE SUBJECT APPLICATIONS FOR WATER PERMITS SHALL AND WILL ADVERSELY AFFECT THE AGRICULTURAL LANDS OF MAJAYJAY. xxx J. xxx xxx

SINABAK SPRING, PATAK-PATAK SPRING AND MANGULILA SPRING ARE EXISTING GROUNDWATER SOURCES AND THERE IS NO WATER PERMIT FROM NWRB ATTACHED TO THE SUBJECT APPLICATIONS FOR WATER PERMITS AS REQUIRED UNDER THE IRR-LLDA.

K. THERE IS NO PROPER NOTICE TO THE BARANGAY CHAIRMAN WHERE PATAK-PATAK SPRING IS LOCATED AS THE LATTER IS NOT SITUATED IN BRGY. AMONOY BUT IN BRGY. BALAYONG, MAJAYJAY, LAGUNA.
L.

THE SUBJECT APPLICATIONS FOR WATER PERMITS WILL CAUSE ADVERSE EFFECT TO PUBLIC AND/OR PRIVATE INTEREST.

M. THE SUBJECT APPLICATIONS FOR WATER PERMITS WILL AFFECT THE PRESENT BRGY. WATER SYSTEM. xxx xxx xxx

Q. THE APPLICATIONS FOR WATER PERMITS SHALL AND WILL PUT IN DANGER THE LIVES AND HEALTH OF THE PEOPLE OF MAJAYJAY AS THEY WERE MADE IN VIOLATION OF SECTION 13 OF THE IRR-LLDA WHICH PROVIDES THAT NO CONSTRUCTION WORK OR PRIVATE SECTOR PROJECT SHALL COMMENCE UNTIL THE PLANS,

SPECIFICATIONS AND IMPLEMENTING SCHEDULES ARE DULY APPROVED. It is of utmost importance to conduct the appropriate

1.

ocular inspection of the location, source and natural flow of as well as the agricultural lands and public and private interests affected by the three (3) Springs subject matter of the questioned water permit applications to enable the oppositors to establish the aboveenumerated grounds in their Opposition.
2.

Similarly, there is a necessity to conduct an ocular

inspection to establish that the questioned water permit applications were made in violation of Section 13 of this Honorable Office Implementing Rules and Regulations (IRR) which provides that no construction work or private sector project shall commence until the plans and specifications for the diversion works, pump structure, water measuring device and other required structures, and the implementing schedules of construction are duly approved by this Honorable Office.
3.

The oppositors would like to manifest to this Honorable

Office that in gross and open violation of Section 13 of the IRR of this Honorable Office and even while its questioned applications for water permits are still pending for processing, the applicant has started and

continues to make construction work for the excavation and laying of water pipes in Majayjay, Laguna (Majayjay for short) for its intended water distribution system which will put in danger the lives of the people in Majayjay because the construction work was made without approval by this Honorable Office of the aforesaid plans and specifications and implementing schedules. Copies of the pictures of the excavation and the laying of water pipes are hereto attached as Annexes A, B, C and D, respectively.
4.

For instance, it is reported that the water pipes being used

by the applicant are sub-standard water pipes for potable water and/or water pipes not designed for distribution of potable water. Worse, the water pipes were installed and joined in violation of the accepted engineering practice for the installation and joining of such water pipes as shown from the fact that installation of the water pipes was made without the required sand cushion of at least six (6) inches of sand beneath the water pipes and another six (6) inches of sand atop of the water pipes.
5.

Such kinds of construction works will certainly put in

danger the health and lives of the people as the materials for the substandard water pipes and the irregular installation of the water pipes will most likely absorb or seep into the water pipes the water or soil

moisture outside of the water pipes, thereby contaminating the potable water passing thru the water pipes.
6.

In other words, the materials for the sub-standard water

pipes and the irregular installation and joining of the water pipes will contaminate the potable water passing thru the water pipes which will pose clear and present danger to the health and lives of the people of Majayjay as the potable water will be used for drinking and cooking of foods of the people of Majayjay. This clear and present danger to the health and lives of the people of Majayjay can be prevented if this Honorable Office will strictly implement the mandates of Section 13 of its IRR.
7.

Accordingly, oppositors respectfully submit that the

appropriate ocular inspection must be made to accord due process of law to them and to compel respect and compliance with the IRR of this Honorable Office. This Honorable Office should not allow the applicant to violate with impunity the IRR of this Honorable Office, otherwise, it will render ineffective and inutile the powers granted by law to this Honorable Office.
8.

Section 13 of IRR of this Honorable Office is not mere

formality but it serves as a precautionary measure or safeguard to protect the health and lives of the people who are supposed to be

given water services by the applicant for water permit.

In other

words, the lives of the consumers of a water system depend on the strict implementation by this Honorable Office of the said approved plans and specifications and implementing schedules for the intended water distribution system. Thus, in order to protect the health and lives of the people of Majayjay, the oppositors respectfully submit that this Honorable Office should strictly enforce the mandates of Section 13 of its IRR especially considering the fact that the water permit applications of the applicant are still pending for adjudication and approval by this Honorable Office. WHEREFORE, the oppositors most respectfully pray to this Honorable Office that an ocular inspection be made on the location, sources and natural flow of as well as the agricultural lands, public and private interests affected by the three (3) Springs, Sinabak, PatakPatak and Mangulila Springs, subject matter of the instant applications for water permit and an ocular inspection of the excavation and lay outing of water pipes made by the applicant, including the water pipes used therein. Other reliefs just and equitable in the premises are likewise prayed for.