Laguna Lake Development Authority

LLDA Environmental
Policies and
Regulatory Processes

Clearances and Permits Division

Environmental Regulations Department
370 = 1320
 How much water is there on, in, and
above the Earth?
Fresh liquid water in the
All Earths water ground, lakes, swamps, and
rivers

Fresh-water in
lakes and rivers

Credit: Howard Perlman, USGS; globe illustration by Jack Cook, Woods Hole Oceanographic
Institution (); Adam Nieman.
 Outline of Presentation
I. Laguna de Bay Region
II. Existing Lake Uses
III. LLDA Clearances/Permits
IV. Environmental User Fee System
V. LLDA Monitoring/Inspection Protocol
VI. Environmental Compliance Rewards
I. Laguna de Bay Region
The largest and
one of the most
vital inland
bodies of water
in the
Baras
Taguig

no Pililla

Philippines. Muntinlupa

San Pedro
 GEOGRAPHICAL JURISDICTION
Laguna whole province
Rizal whole province
Cavite Silang, Carmona,
GMA, Tagaytay
Batangas Malvar, Sto. Tomas,
Tanauan
Quezon Lucban
Metro Manila:
Caloocan Manila
Marikina Muntinlupa
Pasay Pasig
Pateros Quezon Taguig
 II. EXISTING LAKE USES

It is the major source of

freshwater fish in the
surrounding provinces,
municipalities, and
cities.
Hydro power
generation Transport Route Irrigation

Flood Water Industrial Recreation

Reservoir Cooling
Domestic water supply
Water Sink
III. LLDA CLEARANCES/PERMITS
LLDA Clearance (LC)
Discharge Permit (DP)
Water Permit (surface water)
Annual Fishpen/Fishcage Permits
Barging Clearance
Tugboat Clearance
Shoreland:
* SDC
* SOP/SLA
 BOARD RESOLUTION NO. 408,
Series of 2011

Revised Definition of Developmental

Activities Required to Secure LLDA
Clearance and its Implementing Rules
and Regulations, and for this purpose
Amending BR. 223 Series of 2004 and
BR. 286 Series of 2006
PRESCRIBED DEVELOPMENTAL ACTIVITIES
REQUIRED TO SECURE LLDA CLEARANCE

RESOURCE EXTRACTION INDUSTRY

 AGRICULTURE INDUSTRY
100 heads or 1000 birds > 10 animals or 100
10 sow level birds slaughtered per day

w/ total area of
1,000 sq. m Multiple pass process
and/or 1 ton/hr capacity
MANUFACTURING / INDUSTRY
SERVICE INDUSTRY
SITE DEVELOPMENT / INFRASTRUCTURE PROJECTS
SITE DEVELOPMENT / INFRASTRUCTURE PROJECTS

With total floor and facility area (including parking

and developed spaces) of 1,000 sq m.
SITE DEVELOPMENT / INFRASTRUCTURE PROJECTS
WASTE MANAGEMENT PROJECTS

Except with <12 cubic

meters per day domestic
wastewater

Except MRF and

junkshops
LLDA CLEARANCE REQUIREMENTS
Duly accomplished and notarized
application form (www.llda.gov.ph
www.llda.gov.ph))

Environmental Compliance
Certificate (ECC) or Certificate of
Non--Coverage (CNC)
Non

SEC Cert
Certificate
ificate of Reg
Registration
istration &
Articles
Art icles of Incorporation or DTI
 Project Description, or Engineers Report or
Environmental Impact Statement (EIS)

Plans (Site dev

developmen
elopment,
t, vicinity,
sewer/drainage plans, plant layout)

Shoreland Certification from the Shoreland

Section--LLDA if the site is within shoreland
Section
barangays of Laguna de Bay
 LLDA Clearance Fee Structure*
Processing Fee: Php1,600 to recover
administrative cost
Regulatory Fees: Industrial & infra projects
Capital investment Php 5.0M
& below: Php 1,800.00
More than Php 5.0M: Php 360.00/M
Php 1.80/square meter

*Pursuant to Board Res. No. 224, S. 2004 dated

April 29, 2004
 ADMINISTRATIVE FINES
Classification of Violation Amount
Without Notice PhP 5,000.00
of Violation
Establishment (NOV)
developing/
constructing/ PHP 5,000.00 per
operating without year reckoned from
LC With NOV the receipt of NOV

Violation of PhP 5,000.00 per

Clearance violation of any
Condition condition
HOW TO COMPLY WITH LLDA LEGAL CASE?
Operating without LLDA Clearance

Attend to the Alternative Dispute

Resolution/Public Hearing set by Legal and
Adjudication Division

Proceed to Clearances and Permits Division

for LC application form and checklist of
requirements

Comply with LLDA requirements

 LEGAL BASIS
Board Resolution No. 33, Series of 1996-
Implementing the Environmental User
Fee System in the Laguna de Bay Region
as amended by BR 322, series of 1997

Board Resolution No. 404 Series of 2011-

Adopting the Fines and Penalties
Imposed under Section 28 of R.A. 9275
(Philippine Clean Water Act of 2004)
SOURCES OF POLLUTION
Water Pollution is any change in the
water that makes it unsuitable for its
intended use.
 Priority Pollutant Parameters

Biochemical Oxygen
Demand (BOD)

Total Suspended Solids (TSS)

Biochemical Oxygen Demand (BOD)

Oxygen Depletion = BOD

O2

Dissolved
Oxygen in Water

Biodegradable matter (i.e. left-

left-over food, vegetables,
animals, plants, washings, sewage, etc.)
 Effects of Biochemical Oxygen Demand (BOD)

Accelerate bacterial
growth and consume the
oxygen levels in the river
and lakes

depletion of dissolved oxygen in

water can kills fish and other
forms of oxygen-using aquatic
life
 Effects of Total Suspended Solids (TSS)

makes the water turbid thus

light cannot penetrate and
plant growth is suppressed
obstruct shipping channel

obstruct shipping channel

makes water purification

very expensive
Distribution of Enterprises in the Laguna De Bay Watershed
IV. ENVIRONMENTAL USER FEE SYSTEM
EUFS is a market-based instrument that
applies the polluters pay principle

EUFS serves as an economic means to

force polluters to reduce/abate water pollution
while instituting remedial measures within their
establishment

EUFS was initially implemented in the Laguna

de Bay Region in 1997
ENVIRONMENTAL USER FEE SYSTEM

LLDA MODEL

EUFS

MARKET BASED
REGULATORY INSTRUMENT
PD 984 RA 4850
DAO 35 PD 813
EO 927
 EUFS COVERAGE
INTRO PHASE (1997):
Top 5 Polluting Industries beverages, food
processing, pulp & paper,
piggeries/slaughterhouses & textiles
SECOND PHASE (1998-
(1998-1999):
All industries with wastewater, subdivisions
& commercial establishments including food
chains & restaurants
ON--GOING IMPLEMENTATION:
ON
EUFS was adopted as a long term
Environmental Management Plan
Who are covered by this EUFS?
All development projects, installations,
activities that discharge liquid waste into
and pose a threat to the environment of
the Laguna de Bay Region:

industrial
commercial
domestic
agricultural
 WHO ARE EXEMPT
EXEMPTED?
ED?
Single residential buildings w/ total
domestic sewage generation of 12
cubic meters/day
meters/day;;
Dry industrial establishment 12 cubic
meters/day of domestic sewage or with
maximum of 212 workers;
Industrial or commercial establishment
interconnected to central wastewater or
sewage treatment plant or facility.
facility.
 USERS FEE STRUCTURE
Fixed Fee - cost of compliance
monitoring, laboratory analysis, etc.
Conventional
Q < 30 cu.m/d - P 8,000
Q > 30 - 150 cu.m/d - P16,000
Q > 150 cu.m/d - P24,000

Heavy Metals

Q < 150 cu.m/d - P16,000

Q >150 cu.m/d - P24,000
 VARIABLE FEE = Ln* x Rate
Formula for the Net Waste Load, Ln:

Ln (PPP) = [(Cf Ca) (Qf x Nf )] x 0.001

Where:
Ln = Net Waste Load, kg/yr
PPP = Priority Pollutant Parameter
Cf = ave. concentration of PPP in the effluent (mg/l)
Ca = ave. concentration of PPP in the abstracted water
(mg/l)
Qf = ave. Daily Volumetric Flow Rate of the (final)
effluent or wastewater discharged
Nf = Number of discharge days per year, days/year
 Variable Fee depend on the strength or
concentration of the discharge
Charging parameter depends on industry category:
either Biochemical Oxygen Demand (BOD) or Total
Suspended Solids (TSS)

Variable Fee Rate

For complying with the Effluent Standards - P5 per kg BOD/TSS
For non-complying with the Effluent
Standards - P30 per kg BOD/TSS

Pollution case shall be filed against firms discharging

wastewater exceeding the effluent standards prescribed at
DENR Administrative Order No. 35
DISCHARGE PERMIT (DP) REQUIREMENTS

New Application:
Duly accomplished and notarized application
application form
(www.llda.gov.ph)

Water bills/reading registered in the name of

applicant (last 3 months)

Water Treatment Facility Lay-

Lay-out with complete
specifications of the treatment process

Engineers Report/Technical
Report/Technical Paper

Schedule of wastewater discharge, if by-

by-batch
Renewal :
Duly accomplished and notarized
application form

DP PROCESSING TIME :
thirty (30) working days
Exemption:
Duly accomplished and notarized application
application form
(www.llda.gov.ph)

Letter request under oath by the CEO

LLDA Clearance or LLDA Clearance Exemption

Non
Non--refundable Fee (Php
(Php 5,000.00)

Water bills/reading registered in the name of

applicant and/or Certificate of Interconnection
 DISCHARGE PERMIT CONDITIONS
Compliance to Effluent Standards
Submission of Quarterly SMR
Submission of DENR ID Number as
Hazardous Waste Generator
Logbook containing records of the
operation of the treatment facilities
Provision of flow measuring device
Submission of Pollution Control Officers
accreditation/certificate of at least 4
hours of relevant training/seminar
or workshop
NOTE:
Discharge Permit is NOT A LICENSE TO
POLLUTE
Pollution cases will be filed if the
establishments do not conform with the
effluent standards, and penalties will be
imposed accordingly
Establishments may be closed for continued
violation after due process
 V. L L D A
MONITORING/INSPECTION
PROTOCOL
 Objectives of Effluent Quality Monitoring
Ensure compliance by the industries and
commercial establishments with the effluent
standards
Evaluate the effectiveness of
effluent treatment & control
Identify potential environmental
problems and evaluate the need
for remedial actions or mitigating
measures
 Objectives of Effluent Quality Monitoring
Support permit revision and/or renewal based on new
data;
Detect, characterize and
report unplanned
releases by the facility
or establishment;
 Objectives of Effluent Quality Monitoring
Determine the impact to the receiving media
(water body, groundwater and land); and
Determine the effectiveness of the waste
minimization/cleaner technologies adopted by the
facility.
 TYPES OF INSPECTIONS
LLDA Clearance (LC)/Discharge Permit
(DP) Application
Routine/Compliance Monitoring
Investigation
Survey/Saturation
Compliance to Legal Orders
 STAFF DEPLOYMENT

Regular Inspection Team Composition:

1 Inspector-
Inspector-Engineer
1 Driver Aide

If situation warrants, especially during overnights,

investigation of complaints, fish kill/oil spill, additional:

1 Inspector-
Inspector-Engineer or
1 Inspector Aide or with Chemist
 Identification Documents
Inspectors I.D. or Employees I.D.
Valid Mission
Order (M
(M..O)

Note: Effective January 6, to

Note:
June 30
30,, 2015
OFFICIAL LLDA VEHICLE

Only LLDA Official

vehicles (RED PLATE) are
used in all inspection
activities
 Access to Premises
The permit holder shall provide immediate,
safe, and adequate access to authorize
representatives of the authority or inspectors after
showing proper LLDA Inspectors ID and Mission
Order. (Board Resolution 33 Article 3 Section 22)

Failure to comply may result to REFUSAL OF

ENTRY CASE
Refusal of Entry (LLDA MC 2015-
2015-01)
Evidence:
failure to provide LLDA Inspector/s
immediate ingress to the premises
of the establishment w/in 30
30mins
mins..

causing or committing acts against

the LLDA Inspector/s that delay
or impede monitoring/inspection

other analogous circumstances

Refusal of Entry (LLDA MC 2015-
2015-01)
Grounds:
failure on the part of LLDA Inspector/s
to comply with the minimum PPE
requirement

No valid LLDA ID and Mission Order

Not using LLDA official vehicle during
the visit
Refusal of Entry (LLDA MC 2015-
2015-01)
Penalty:
First Offense Fine of 25
25,,000

Second Offense Ex
Ex--Parte
Cease and Desist Order
 Effluent Sampling Activity

EMB/LLDA Office Sampling Field Testing Making Field Notes

Review Documentation & Preservation, Storage

Reporting Laboratory Testing and Transport
Sampling using intermediate container
 SAMPLE LABELING

Properly Labeled, Signed & Sealed

Sampling Bottles
 S
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 Chain of Custody
The person handling the samples to the laboratory as well as the
Pollution Control Officer (PCO) will sign a Sampling Form as they
both witnessed and acknowledged the sampling.

Once the samples are received by the laboratory, the laboratory

personnel who received the samples will also sign the Sampling
Form and make note of initial observations as to the physical
appearance of the sample particularly in terms of color and turbidity.

SAMPLES
LABORATORY
 Wastewater Sample Collected
For Analysis at LLDA Lab.

Evaluation Endorse to Legal D.

For issuance of
Appropriate Legal
Complying Not Complying Order

Issuance of DP Withhold issuance Request for

(for those w/ of DP Re-sampling
Application)

Can be considered if reasons

Require co. to for re-sampling are valid and
Secure DP & the acceptable
same maybe Issued
upon compliance
of all permit Payment of re-sampling
requirements Fee & cost analysis
 Resolution No. 404, S. 2011

A Resolution adopting the Fines and Penalties

imposed under Section 28 of R.A. 9275, of 2004 and
for this purpose modifying and amending Section 32
of article VI of LLDA B.R. No. 33 S. of 1996.

daily penalty of at least P10,000 reckoned from

the date of initial sampling
 Memorandum Circular No. 03, Series of 2012
Non-complying wastewater samples collected after
June 17, 2011 - 10,000 daily penalty

From the date the ROLA of the wastewater samples

collected was released from the Resource
Management and Development Department-LLDA

For case of oil spills, discharges of related petro-

chemicals and other chemicals - from the date of
sampling
 REQUEST FOR RE-SAMPLING (MC No. 2014-08)
1. Request letter for resampling (grounds for
resampling, remedial measures undertaken, date of
completion, schedule of discharge
2. Proof of payment of resampling fee
3. Latest Results of Laboratory analysis issued by LLDA
or DENR recognized laboratory showing non-
compliance w/ effluent standards
4. When LLDA inspectors were unable to collect
effluent due to reasons attributable to the
proponent, resampling fee shall be forfeited
ENFORCEMENT OF CEASE AND DESIST ORDER
HOW TO COMPLY WITH LLDA LEGAL CASE?

Water Pollution Case

Do immediate remedial measures and

request for a re-sampling

Request for Reconsideration/Reduction on

Daily Penalty
 HOW TO MITIGATE WATER POLLUTION?

Put-up/upgrade wastewater treatment

facilities
Practice Waste minimization/re-use or
recycle/Zero discharge
Interconnect to centralized STP/WTF
Engage services of wastewater hauler,
transporter and treater
 VI. ENVIRONMENTAL
COMPLIANCE REWARDS
COST REDUCTION
Low volume of discharge and/or low pollutant
concentrations will result to low payment of
LLDA fees and charges
REGULATORY FLEXIBILI
FLEXIBILITY
low volume of discharge, less
less Frequency of Analysis
& submission of Self
Self--Monitoring Reports (SMR
(SMR)) and
less compliance monitoring
no imposition of 10,000 per day penalty for
industries complying with the effluent standards

RECOGNITION:
THROUGH PUBLIC DISCLOSURE PROGRAM
 Water, water
everywhere; but we
cannot drink water.

- Anonymous