Republic of the Philippines: Emergency Assistance for ......Philippine EIA system. The purchase of...

Initial Environmental Examination

Project Number: 52313-001

July 2020

Republic of the Philippines: Emergency Assistance for Reconstruction and Recovery of Marawi

Output 3: Restoring Water Utilities and Health Infrastructure

(Health Component)

Prepared by the Department of Health, Government of the Philippines for the Asian Development Bank

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CURRENCY EQUIVALENTS

(as of 15 May 2020)

Currency unit - Philippine Peso (PhP)

PhP1.00 - $ 0.01964 $1.00 - PhP 50.92

ABBREVIATIONS

ADB - Asian Development Bank

CCC - Climate Change Commission

CFC - chlorofluorocarbon

CITES - Convention on International Trade in Endangered Species of Wild Fauna and Flora

DENR - Department of Environment and Natural Resources

DO - Department Order

DOH - Department of Health

ECA - Environmentally critical area

ECC - Environmental Compliance Certificate

ECP - Environmentally critical project

EMB - Environmental Management Bureau

EMP - Environmental Management Plan

EMOP - Environmental Monitoring Plan

GRC - Grievance Redress Committee

GRM - Grievance Redress Mechanism

IEE - Initial Environmental Examination

INDC - Intended Nationally Determined Contribution

LGU - Local government unit

LLW - Lanao Lake Watershed

NSWMC - National Solid Waste Management Commission PHIVOLCS - Philippine Institute of Volcanology and Seismology

PIU - Project Implementation Unit

PMC - Project Management Consultant

POPS - Persistent Organic Pollutants

ROW - Right-of-way

SAICM - Strategic Approach to International Chemicals Management

SPS - ADB Safeguard Policy Statement 2009

TB DOTS - Directly observed treatment, short-course for tuberculosis

TSeKaP - Tamang Serbisyo sa Kalusugan ng Pamilya

UNCSD - United Nations Convention on Sustainable Development

UNFCCC - United Nations Framework Convention on Climate Change

UCCRTF - Urban Climate Change Resilience Trust Fund

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WEIGHTS AND MEASURES

dB (A) - A-weighted decibel

ha - hectare

km - kilometer

km2 - square kilometer

m - meter

NOTE

In this report, $ refers to US dollars.

This initial environmental examination is a document of the borrower. The views expressed

herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section of this website.

In preparing any country program or strategy, financing any project, or by making any designation

of or reference to a particular territory or geographic area in this document, the Asian

Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

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Contents LIST OF FIGURES ..................................................................................................................... 6 LIST OF TABLES ....................................................................................................................... 6 EXECUTIVE SUMMARY ............................................................................................................ 8 I. INTRODUCTION ...............................................................................................................12

A. Project Background .....................................................................................................12 B. Project Objectives .......................................................................................................12 C. Purpose of the IEE Study ............................................................................................12 D. Extent of the IEE Study ...............................................................................................13 E. Methods Used for the IEE Study .................................................................................13

1. Site Assessment and Public Consultation ...................................................................13

2. Primary and Secondary Data Collection ......................................................................13

3. Other Tools, Additional Surveys and Studies ..............................................................13

4. Assessment of Potential Impacts ................................................................................14

5. Preparation of the Environment Management Plan .....................................................14

E. IEE Report Content .....................................................................................................14 II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ................................................15

A. International Environmental Agreements .....................................................................15 C. Regulatory Framework on Operationalization of Local Health Systems ......................23 D. Environmental Regulatory Framework Applicable to DOH ..........................................24 E. Regulatory Framework in Autonomous Region in Muslim Mindanao ...........................24 F. Asian Development Bank Safeguard Policies .................................................................25 G. Other Applicable Regulations ......................................................................................26

III. DESCRIPTION OF THE PROJECT ................................................................................27 A. Project Locations .........................................................................................................27 B. Typical Plan of Local Health Unit .................................................................................31

IV. DESCRIPTION OF THE ENVIRONMENT ......................................................................35 A. Physical Environment .................................................................................................35

1. Geographic Location ...................................................................................................35

2. Topography and Slope ................................................................................................36

3. Seismicity and Related Hazards .................................................................................37

4. Watershed ..................................................................................................................40

5. Climate .......................................................................................................................40

6. Soil .............................................................................................................................41

7. Water Quality ..............................................................................................................43

a. Drinking Water ............................................................................................................44

b. Receiving Body of Water.............................................................................................45

8. Air Quality ...................................................................................................................46

9. Noise Level .................................................................................................................46

B. Biological Environment ...............................................................................................47 1. Biogeography ..............................................................................................................47

2. Lake Lanao Watershed Reserve .................................................................................48

3. Key Biodiversity Area ..................................................................................................48

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4. Flora ...........................................................................................................................49

5. Fauna .........................................................................................................................49

6. Biodiversity Assessment Using IBAT ..........................................................................50

C. Socio-economic Environment .....................................................................................52 1. Demography ...............................................................................................................52

a. Population ...................................................................................................................52

b. Education ....................................................................................................................53

c. Major Occupation Group .............................................................................................54

d. Morbidity and Mortality ................................................................................................55

2. Health Services ...........................................................................................................56

3. Water and Power Supply ............................................................................................56

V. IMPACT ASSESSMENT AND MITIGATING MEASURES ..............................................57 A. Impact Assessment .....................................................................................................57 B. Evaluation of Impacts ..................................................................................................57 C. Potential Beneficial Impacts ........................................................................................65 D. Potential Adverse Impacts ..........................................................................................65

VI. CONSULTATION, PARTICIPATION AND INFORMATION DISCLOSURE .....................68 A. Consultation and Participation ....................................................................................68 B. Information Disclosure ................................................................................................71

VII. GRIEVANCE REDRESS MECHANISM ..........................................................................72 VIII. ENVIRONMENTAL MANAGEMENT PLAN.....................................................................73

A. Environmental Management Plan ...............................................................................73 B. Environmental Monitoring Plan ...................................................................................73 C. Organizational Set-up .................................................................................................74

IX. CONCLUSION AND RECOMMENDATION ....................................................................79 BIBLIOGRAPHY .......................................................................................................................80 APPENDICES ...........................................................................................................................82 Appendix 1. Rapid Environmental Assessment (REA) Checklist ...............................................82 Appendix 2. Summary of Meeting .............................................................................................90 Appendix 3. Site Assessment Report (18 December 2019) .......................................................93 Appendix 5. DOH Site Inspection Report (28-29 May 2019).................................................... 101 Appendix 6. Guidelines for Climate Change and Green House Resilience Design .................. 107 Appendix 7. Laboratory Analyses ............................................................................................ 109 Appendix 8. Permit to Cut Trees ............................................................................................. 121 Appendix 10. Grievance Intake Form ...................................................................................... 125 Appendix 11. Environmental Management Plan ...................................................................... 126

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LIST OF FIGURES

Figure 1. Map of Lanao del Sur .................................................................................................28 Figure 2. City Engineering Office building, Government Center of Marawi ................................30 Figure 3. General Services Office building, Government Center of Marawi City ........................30 Figure 4. Master Development Plan of Government Center of Marawi, including the proposed City Health Unit .........................................................................................................................30 Figure 5. Proposed location of Lumbayanague RHU.................................................................31 Figure 6. Proposed 2-storey Rural Health Unit Ground Floor Plan ............................................33 Figure 7. Proposed 2-storey Rural Health Unit Second Floor Plan ............................................34 Figure 8. Rural Health Unit with Birthing Home and TB DOTS Service Mode ...........................34 Figure 9. Lake Lanao Watershed Reserve Area ........................................................................35 Figure 10. Slope Map of Lake Lanao Watershed Reserve Area ................................................37 Figure 11. Topographic Map of Lanao del Sur ..........................................................................37 Figure 12. Active Faults and Trenches in Mindanao ..................................................................38 Figure 13. Landslide Susceptibility Map of Marawi City .............................................................39 Figure 14. Landslide Susceptibility Map of Lumbayanague .......................................................39 Figure 15. Modified Coronas Classification of Climate of the Philippines...................................41 Figure 16. Sampling locations for soil, Marawi City ...................................................................42 Figure 17. Sampling locations for soil, Lumbayanague .............................................................43 Figure 18.Sampling locations for drinking water and receiving body of water, Marawi City .......44 Figure 19. Sampling locations for drinking water and receiving body of water, Lumbayanague .44 Figure 20. Philippine Biogeography Zone, DENR (2002) ..........................................................48 Figure 21. PAs and KBAs within the 10-km and 50-km buffer zone, Marawi City Health Unit ....50 Figure 22. PAs and KBAs within the 10-km and 50-km buffer zone, Lumbayanague Rural Health Unit ...........................................................................................................................................51 Figure 23. Population Density of Lanao del Sur (Philippine Statistics Authority, 2015). .............53

LIST OF TABLES

Table 1. Summary of Environmental Legislations Applicable to the Proposed Project ...............19 Table 2. Project Thresholds for Coverage Screening and Categorization in Philippine EIS System ......................................................................................................................................23 Table 4. Area by Slope Category .............................................................................................36 Table 5. Water Body Classification and Usage of Freshwater ...................................................40 Table 6. Details of Soil Sampling in Marawi and Lumbayanague ..............................................41 Table 7. Soil Analyses Result ....................................................................................................42 Table 8. Details of Water Sampling in Marawi and Lumbayanague ...........................................43 Table 9. Drinking Water Result .................................................................................................45 Table 10. Receiving Body of Water Results ..............................................................................45 Table 11. Air Quality Sampling Results, Barangay Bubong, Saguiaran, Lanao del Sur .............46 Table 12. Noise Level Sampling Results, Barangay Bubong, Saguiaran, Lanao del Sur ...........47 Table 13. IUCN Red List for Marawi (Mammals and Reptiles) ..................................................50 Table 14. IUCN Red List for Marawi (Birds) ..............................................................................51 Table 15. IUCN Red List for Lumbayanague (Mammals and Reptiles) .....................................52 Table 16. IUCN Red List for Lumbayanague (Birds) .................................................................52 Table 17. Age Group for Marawi and Lumbayanague, 2015 .....................................................53 Table 18. Highest Grade / Year Completed, Marawi City ..........................................................54 Table 19. Major Occupation Group, Marawi City and Lumbayanague .......................................54

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Table 20. Morbidity Statistics in the Philippines .........................................................................55 Table 21. Mortality Statistics, Marawi City and Lumbayanague .................................................55 Table 22. Summary of VECs for the Proposed Construction of Health Units in Marawi City and Lumbayanague, Lanao del Sur .................................................................................................58 Table 23. Intensity, Duration and Scope Classification of Impacts.............................................59 Table 24. Multi-criteria Analysis to Determine the Potential Environmental Impacts ..................59 Table 25. Matrix Showing the Relationship Between VECs and Project Components and Activities for the Construction of Health Units ............................................................................60 Table 26. Analysis of Environmental Impacts ............................................................................61 Table 27a. Summary of Consultations with Relevant Agencies on May 28-29, 2019 ................68 Table 27b. Summary of Consultations with Relevant Agencies on December 18, 2019 ............70 Table 28. Proposed Environmental Monitoring Plan ..................................................................73 Table 29. Roles and Responsibilities of Offices in Project Implementation ................................76 Table 30. Organizational Set-up for Environmental Management Plan and Environmental Monitoring Plan Implementation ................................................................................................78

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EXECUTIVE SUMMARY

1. This Initial Environmental Examination (IEE) was prepared for the health component of Output 3 of the Emergency Assistance for the Reconstruction and Rehabilitation of Marawi (ERRM)1. Output 3 of the ERRM, which includes water supply and health components, will be financed by a $5 million grant under the Urban Climate Change Resilience Trust Fund (UCCRTF). UCCRTF, as a multi-donor trust fund was created to enhance resilience. 2. The health component consists of construction of two local health units, procurement of mobile health units, and institutional and operational support (the Project). The grant will finance the construction of 2 local health units, which comprised the City Health Unit (CHU) in Marawi and Rural Health Unit (RHU) in Lumbayanague. The health units will incorporate climate resilience measures (solar powered refrigeration), be well equipped, have birthing facilities and have provisions for water supply and sanitation. The grant will also finance the procurement of mobile health facilities (3 mobile health clinics, 2 ambulances, 2 patient transport vehicles and 1 monitoring vehicle) for the Integrated Provincial Health Office (IPHO) and the City Health Office (CHO). 3. The Project is categorized as “B” for environment based on the Safeguard Policy Statement (SPS) 2009 since the anticipated impacts are site-specific, few if any are irreversible, and mitigation measures can be readily designed. As per SPS, the Project requires the preparation of an initial environmental examination (IEE), which covers the assessment of the Philippines’ legal framework applicable to the Project, the description of the proposed Project and the environment where the buildings will be located. Based on these assessments, potential environmental issues and impacts were identified and mitigating measures were proposed and institutionalized as Environmental Management Plan, which will be part and parcel of bidding document for the contractors who will build the two health units. The anticipated environmental impacts of the procurement of mobile health units, as well as institutional and operational support, are negligible. The construction of clinics, including rural health units is not covered by the Philippine Environmental Impact Statement (EIS) System. Hence, there is no requirement for the Project to secure Environmental Compliance Certificate (ECC) from the Department of Environment and Natural Resources (DENR).

4. The IEE also proposed the mechanisms for grievance redress for the Project, as well as the disclosure of the IEE contents. All the information gathered for this IEE were based from site assessment of the two sites, consultations with Marawi and Lumbayanague stakeholders, and review of available literature from past studies. ADB subscribed as well as open sourced climate screening and biodiversity softwares, were also utilized.

5. The legal framework covering the project was assessed, including the country’s legal framework, the applicable international legal agreement where the Philippines is a member and, other regulations governing the health sector. The Project is governed primarily by the Philippine environmental impact statement (EIS) system and laws related to management of water (drinking water and receiving body of water), air, noise, solid wastes (including hazardous wastes), and protected areas system. Construction of clinics, including rural health units is not covered by the Philippine EIA system. The purchase of mobile health units is also not covered under the EIA system of the country. 6. The proposed location in Marawi City will be the present City Engineering Office (CEO)

1 The ERRM comprises of four outputs: (i) fiscal support (Output 1); (ii) reestablishing connectivity in Marawi by building back better public infrastructure (Output 2); (iii) restoring water utilities and health infrastructure (Output 3); and (iv) improving social services and livelihoods to affected persons (Output 4).

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building and portion of the General Services Office (GSO) building. Both CEO and GSO buildings will be demolished as part of the greater masterplan for the Government Center of Marawi. The proposed location is about 3 meters away from the current City Health Unit, which will also be rehabilitated to serve as Executive Building of the city. The proposed location in Lumbayanague, Lanao del Sur, on the other hand, will be in a vacant lot at the back of the municipal hall. 7. The proposed Project will be equipped to meet the 4:1 service delivery requirement, comprising (i) Tamang Serbisyo sa Kalusugan ng Pamilya (TSeKaP, a primary health care package under the Philippine Health Insurance Corporation); (ii) Maternal Care Package; (iii) Directly observed treatment, short-course for tuberculosis (TB DOTS) and (iv) Animal Bite Services. The health units will also incorporate climate resilience measures, including installation of solar powered refrigeration. 8. Both Marawi City and Lumbayanague are part of Lake Lanao Watershed Reserve (LLWR) established as a Watershed Reservation under Presidential Proclamation No. 871 in February 26, 1992 to protect, maintain or improve its water yield for hydroelectric power production, irrigation and other ecological enhancement purposes. Both sites for local health units are located in alienable and disposable (A& D) lands, which means that these lands are of the public domain and declared as not needed for forest, mineral purposes or national parks.2

9. The province of Lanao del Sur, and the Lake Lanao Watershed (LLW), is characterized by rugged terrain. Marawi City CHU site is about 700 meters above sea level (MASL), while Lumbayanague site is about 746 MASL.

10. Central Mindanao, including Lanao del Sur, is one of the seismically active areas in the country because of the presence of the western extension of the Mindanao Fault (Cotabato-Sindangan Fault), an active fault that runs from Sarangani province to northwest of Zamboanga Peninsula. Based on the landslide susceptibility map from the Mines and Geosciences Bureau, the proposed city health unit in Marawi and rural health unit in Lumbayanague are both located in low susceptibility to landslide areas.

11. Lake Lanao has been categorized by DENR as “Class A”, which means that the water coming from the lake requires complete treatment to meet the national standards for drinking water. 12. The province, being in the southern Philippines seldom experiences typhoons because of its proximity to the geographical equator. The typhoon frequency in the province is about one (1) in twelve years. Based on Corona’s Classification, the province belongs to the 3rd Climatic Type which is characterized by having no pronounced dry and wet season, where the average annual rainfall ranges from 1,329 mm to 5,235 mm. This Type III climate is a wet climate with a very short dry period lasting only for about two months. The maximum rain period occurs from June to September and the dry period is from March to April. 13. Baseline conditions were assessed for soil, drinking water and receiving body of water (Lake Lanao) for two sites. High level of lead was measured within the vicinity of the proposed CHU site in Marawi. Both drinking water samples from Marawi and Lumbayanague did not pass the Philippine National Standards for Drinking Water (PNSDW) for thermotolerant coliform. Total coliform in drinking water sample from Lumbayanague exceeds the PNSDW standard. Escherichia coli is also present in drinking water sample from Lumbayanague, while lead concentration is a concern in Marawi as it did not pass the PNSDW standard.

2 Revised Public Land Act of the Philippines. Thirteenth Congress of the Philippines. June 30, 2004.

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14. Air quality monitoring conducted on January 28, 2019 in Saguiaran, Lanao del Sur for Output 2 of ERMM showed that TSP, PM10, PM2.5 and SO2 are all within DENR National Ambient Air Quality Guideline Values. Noise levels measured on the same location showed that daytime, noise levels were within the allowable levels of the DENR, while morning, evening and nighttime levels were slightly higher than DENR standard.

15. Using the Integrated Biodiversity Assessment Tool (IBAT) proximity analysis, the tool identified biodiversity features and species which can be found within the 10-km and 50-km buffer from the proposed Marawi City Health Unit and Lumbayanague Rural Health Unit locations. IBAT generated list of species under red list category. The report generated list of species within 50-km range of the designated project site. Most of the species reside in lowland forests which are outside the impact area of the project.

16. In terms of socioeconomic environment, Marawi City has a population of 201,785, making up 19.3 percent of the total provincial population. Lumbayanague, on the other hand has a population of 16,372. Although there are no available morbidity and mortality statistics for the province based on the Philippine Statistics Authority 2015 census, the top ten diseases in the Philippines that can also mirror the situation in Lanao del Sur include acute respiratory infection, hypertension, acute lower respiratory tract infection, bronchitis, influenza, acute watery diarrhea, dengue fever, tuberculosis, and acute febrile illness. 17. Potential impacts on physical, biological and socio-economic environment were identified using modified Leopold matrix. The matrix involves the identification of potential impacts of the Project based on the interactions between valued environmental components (VECs) and project activities. Major adverse impacts are anticipated during demolition of existing CHU in Marawi, tree cutting and debris clearing, mobilization of construction equipment and construction of temporary facilities and construction of health facilities. Among the major impacts identified during the CEO and GSO buildings demolition in Marawi include generation, storage, transportation and disposalof wastes from demolished buildings, which may affect the health of workers and people that might be exposed from passing or by being near the site, contamination of Lake Lanao from sediment transport of demolished buildings, suspension of health and emergency services, increase in particulate matter, noise level, and risk and inconvenience to the community.

18. As there are several trees that might be affected by the Project, land and soil condition will also be affected, in addition to the generation of particulate matter that will expose workers. During mobilization, the movement of vehicles carrying construction materials as well as the construction of temporary facilities will disturb the soil, generate sediments that may potentially contaminate Lake Lanao and Agus River, increase the level of air pollutants coming from emission from vehicle and the disturbance of soil, temporary suspension of health and emergency services, disturbance among the public and difficulty accessing other offices inside the local government units’ compounds.

19. The construction of two health units is anticipated to generate the majority of negative adverse impacts, hence this stage is the most crucial to mitigate environmental impacts. Major impacts at this phase include management of demolition wastes of the CEO and GSO buildings, in the case of Marawi, permanent loss of soil within building footprint, and generation of sediments, liquid and solid wastes that have the potential to pollute Lake Lanao and Agus River. The operation of vehicles carrying aggregates and construction materials may also generate oil, fuel and chemicals from construction site that can be transported to receiving body of water. The exhaust during vehicle movement, both from disturbed soil and from vehicles, will temporarily increase the level of air pollutants. The operation of vehicles will also increase the level of noise, vibration, and traffic congestion in the two sites. The construction of the buildings will likewise increase the risks to health and safety of construction workers that will be hired for the project.

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There will also be safety risks to public such as construction vehicle movement, uneven soil surfaces, pollution from sediments, and potential accident from transporting of construction materials. 20. The operation phase will also be crucial as the City Health Office (CHO) and Integrated Provincial Health Office (IPHO) must ensure the reliability and quality of water to be used for the operation of the health units. It was established that the quality of drinking water in Marawi has high levels of lead and thermotolerant coliform while drinking water in Lumbayanague has high levels of thermotolerant coliform, total coliform, and E. coli. 21. In the proposed Environmental Management Plan (EMP), measures to mitigate negative impacts were proposed, as well as the assignment of institutional responsibilities to ensure that the proposed $ 5 million grant will be sustainable. The Department of Public Works and Highways (DPWH), as the Executing Agency (EA), has the overall strategic oversight of all infrastructure components. The Department of Health (DOH) Central Office Project Management Unit (PMU), as the Implementing Agency will be responsible for the implementation of the health component of the grant financed under the Urban Climate Change Resilience Trust Fund (UCCRTF). The PMU will be supported by procurement, contracts management and health specialists. The Integrated Provincial Health Office (IPHO) will be the project owner for the rural health unit (RHU), 2 mobile health clinics, 1 ambulance, 1 patient transport vehicle and 1 monitoring vehicle in Lumbayanague. The City Health Office (CHO) meanwhile, will be the project owner for the city health unit (CHU), 1 mobile health clinic, 1 ambulance and 1 patient transport vehicle in Marawi City. Both IPHO and CHO will be responsible for confirming specifications for all infrastructure and equipment. They also need to confirm the quality of works during construction. Both offices also need to allocate physical space and necessary infrastructure for mobile health facilities. Both offices also need to allocate resources (staff and budget) for operations and maintenance. Task Force Bangon Marawi (TFBM)3, through the Military Engineering Unit, will provide assistance in the demolition and transport of wastes from demolished CEO and GSO buildings. TFBM is tasked to facilitate recovery efforts and coordinate with development partners. To ensure that the operation of the Project will be environmentally sustainable, monitoring of drinking water, receiving body of water, air quality and noise levels, and soil quality, are proposed during construction and operation phases.

22. As required in SPS 2009, consultations with Marawi and Lumbayanague local government units were conducted on May 28 and 29, 2019, respectively. A team from Asian Development Bank and Department of Health met with stakeholders from the two LGUs, Task Force Bangon Marawi (TFBM), and with affected people. Issues discussed include the final location of proposed CHU in case of Marawi, requirement for certificate of ownership of lots that will be developed for health units and sustainability of the operation of health facilities. Another consultation was conducted on December 18, 2019 in response to the request of the city government of Marawi to transfer the proposed site from the existing CHU to the existing CEO and GSO buildings. Both buildings are located about 3 meters from the CHU.

23. Information disclosure will be guided by ADB’s Public Communication Policy 2011 and Access to Information Policy 2018, and the procedures in ADB SPS 2009 for environment category B projects. The final IEE of the proposed health units in Marawi and Lumbayanague will be posted in ADB website upon receipt. Highlights of the IEE will be disclosed in the local language in Marawi and Lumbayanague. A subproject-specific grievance redress mechanism (GRM) was proposed for the Project to receive, evaluate and facilitate the complaints/grievances of affected persons on the environmental performance of the established health units.

3 Administrative Order No. 3 (28 June 2017) created the Task Force Bangon Marawi, an interagency group tasked to facilitate recovery efforts in Marawi.

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I. INTRODUCTION

A. Project Background

1. The Government of the Philippines has requested ADB to provide emergency assistance combining a $400 million Emergency Assistance Loan (EAL) and $8 million in grants to support the reconstruction of Marawi. The Emergency Assistance for the Reconstruction and Recovery of Marawi Project (ERRM) is structured to provide the Government of the Philippines (Government) with immediate and flexible financing to implement programs, projects and activities (PPAs) included in the Bangon Marawi Comprehensive Rehabilitation and Recovery Program (BMCRRP), as may be updated from time to time. The ERRM comprises of four outputs: (i) fiscal support (Output 1); (ii) reestablishing connectivity in Marawi by building back better public infrastructure (Output 2); (iii) restoring water utilities and health infrastructure (Output 3); and (iv) improving social services and livelihoods to affected persons (Output 4). 2. Output 3 of the ERRM will be financed by a $5 million grant under the Urban Climate Change Resilience Trust Fund (UCCRTF). It will include a water supply component and a health component. These two sectors have been identified as critical components for the recovery of the city. Hence, UCCRTF as a multi-donor trust fund created to enhance resilience, particularly of the poor and vulnerable, is directing its support towards the provision of these key urban services.

B. Project Objectives

3. The health component under Output 3 of the ERRM will finance the construction of two local health units, procurement of mobile health facilities, and institutional and operational support (the Project). The grant will finance the construction of 2 local health units (an Urban Health Unit or City Health Unit in Marawi; and a Rural Health Unit in Piagapo4) as model health units that meet or exceed national standards. The health units will incorporate climate resilience measures (solar powered refrigeration), be well equipped, have birthing facilities and have provisions for water supply and sanitation. The grant will also finance the procurement of mobile health facilities (3 mobile health clinics, 2 ambulances, 2 patient transport vehicles and 1 monitoring vehicle) for the Integrated Provincial Health Office (IPHO) and the City Health Office (CHO). The provision of mobile health facilities will enable the restoration of essential health services, including reproductive health services, to Marawi City (through the City Health Office) and surrounding areas hosting internally displaced persons (IDPs), through the Integrated Provincial Health Office. 4. As a UCCRTF grant, the design of the proposed interventions have to embed climate change and disaster resilience and must demonstrate transformative elements (i.e. building back better). The grant will also provide institutional and operational support related to the above activities.

C. Purpose of the IEE Study

5. The IEE has the following objectives: (i) identify the environmental issues that should be taken into account due to project interventions (ii) determine the magnitude of potential environmental concerns and to ensure that environmental considerations are given adequate weight at planning/design stage (iii) identify need for further environmental studies and (iv) propose enhancement measures, if any. The IEE report will include the following major elements:

4 It was later decided that the rural health unit will be constructed in Lumbayanague, Lanao del Sur because of land availability.

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(i) executive summary, (ii) project description, (iii) description of the environment, (iv) anticipated environmental impacts and mitigation measures, (v) analysis of alternatives, (vi) environmental management plan, (vii) grievance redress mechanism, (viii) consultation and information disclosure, and (ix) conclusion and recommendation.

D. Extent of the IEE Study

6. The Project is categorized as “B” for environment based on the Safeguard Policy Statement (SPS) 2009, which means that the anticipated impacts of the project on the environment are site-specific, few if any of them are irreversible, and most often mitigation measures can be readily designed. This necessitates the preparation of an initial environmental examination (IEE), which covers the identification of environmental issues in all phases of the project, specifically during construction phase. The IEE report also covers the general environmental profile of the study area and includes an overview of the potential environmental impacts and their magnitude on physical, ecological, economic, and social and cultural resources within the project’s influence area during design, construction, and operation stages. An Environmental Management Plan (EMP) is also proposed as part of the IEE, which includes mitigation measures for significant environmental impacts during implementation of the project, environmental monitoring program, and the responsible entities for mitigation and monitoring.

E. Methods Used for the IEE Study

7. The initial environmental examination reviewed the legal framework applicable to the project and the technical details of the proposed local health units. Other methods used in the assessment include the following:

1. Site Assessment and Public Consultation

8. Site assessment and public consultations were conducted in Marawi and Lumbayanague to gather baseline conditions, determine the valued environmental components (VECs), and to solicit information from the public regarding the proposed project. Consultations were also conducted with the Department of Health, the Integrated Provincial Health Office (IPHO) of Lanao del Sur, and the City Health Office (CHO) of Marawi City. The information gathered from these consultations were incorporated in the IEE.

2. Primary and Secondary Data Collection 9. Primary and secondary data were collected for the physical, biological and socio-economic environment of Lanao del Sur in general, and Marawi City and Lumbayanague in particular. Primary data were collected for soil, drinking water and receiving bodies of water in the two local government units. Geological information, data on river basin, flora and fauna as well as socio economic data were all sourced from secondary sources. These include published government reports, journals, and relevant websites.

3. Other Tools, Additional Surveys and Studies 10. Climate risk screening identified Lanao del Sur as one of the provinces most at risk to temperature increase and El Niňo induced drought5 which may adversely impact the local health unit components. Climate resilient design will be incorporated to the project to mitigate the induced impact of temperature increase and El Niňo induced drought.

5 http://vm.observatory.ph/cw_maps.html

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4. Assessment of Potential Impacts 11. The assessment of the type, nature, direct, indirect, cumulative or induced impacts and their significance to the physical, biological, and socio-economic components of the environment has been done to ascertain whether the project is environmentally sustainable or not. Nature of impacts has been classified as significant, insignificant, short-term, long-term, reversible, irreversible etc. After identification of nature and extent of impacts, mitigation measures have been proposed.

5. Preparation of the Environment Management Plan 12. The Environment Management plan has been proposed with the objective of avoiding, reduction, mitigation, or compensation for adverse environmental impacts/risks and proposal for enhancement measures. This includes (i) mitigation of potentially adverse impacts (ii) monitoring of impacts and mitigation measures during project implementation and operation (iii) institutional capacity building and training (iii) compliance to statutory requirements (iv) and integration of EMP in the design during pre-construction phase, and implementation of EMP provisions during construction and operation phases.

E. IEE Report Content

13. The IEE has been prepared based on ADB Safeguard Policy Statement (SPS), 2009. The content covers following eight chapters, including this introduction chapter:

Chapter – 1: Introduction Chapter – 2: Policy, Legal and Administrative Framework Chapter – 3: Description of the Project Chapter – 4: Description of the Environment Chapter – 5: Impact Assessment and Mitigation Measures Chapter – 6: Public Consultation and Information Disclosure Chapter – 7: Environmental Management Plan Chapter – 8: Grievance Redress Mechanism Chapter – 9: Conclusion and Recommendation

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II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

14. This section reviews all the relevant international agreements and commitments, existing institutions and legislations, both at the national and local levels. The environmental assessment process needs to adopt environmental regulations and guidelines of the Government of the Philippines (GOP) and ADB’s safeguard requirements. 15. The Philippines is a member of various international agreements, conventions and treaties for conservation of the environment at global level. Some of the international agreements where the Philippines is a party and applicable to the proposed projects are discussed in the following sections.

A. International Environmental Agreements

16. Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). As a party to the convention, the Philippines is required to submit an annual report on CITES trade and a biennial report on legislative, regulatory, and administrative measures taken to enforce the Convention.

17. Convention on Biological Diversity, 1992. Under the Convention, Parties are required to develop national biodiversity strategies and action plans which are to be mainstreamed into the broader national plans for environment and development particularly for the forestry, agriculture, fisheries, energy, transportation and urban planning sectors. 18. Strategic Approach to International Chemicals Management (SAICM). The Strategic Approach to International Chemicals Management (SAICM) is a policy framework that aims to promote chemical safety throughout their life cycle, so that by 2020, chemicals are used in ways that minimize significant adverse impacts on human health and the environment. This "2020 goal" was adopted by the World Summit on Sustainable Development in 2002 as part of the Johannesburg Plan of Implementation. 19. United Nations Convention on Sustainable Development. Also known as Rio+20 or Earth Summit 2012, the UNCSD is the third conference on Sustainable Development. It followed the 1992 Earth Summit/United Nations Conference on Environment and Development (UNCED). UNCSD is the key forum for the consideration of issues related to the integration of the three dimensions of sustainable development: economic development, social inclusion and environmental protection. As such, its mandate is not limited to environmental issues.

20. Stockholm Convention, 2004. The Stockholm Convention is a global treaty to protect human health and the environment from the adverse effects of persistent organic pollutants (POPs). Adopted in 2001 and entered into force in 2004, the convention requires its parties to take measures to eliminate or reduce the release of POPs into the environment.

21. United Nations Framework Convention on Climate Change, 2003. The United Nations Framework Convention on Climate Change (UNFCCC) is an international treaty focusing on what countries could do to limit average global temperature increases and the resulting climate change. The ultimate objective of the convention is the stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system. In 2013, both non-Annex (including the Philippines) and Annex I members to the UNFCCC were requested to prepare their Intended Nationally Determined Contributions (INDCs). Activities/Goals set under the INDC, regardless of the legal nature of the contributions, will serve as the first Nationally Determined Contribution of the respective parties for the period beyond the Doha Amendment, upon ratification of the Paris Agreement.

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22. Kyoto Protocol, 2003. The Kyoto Protocol is an international treaty under the UNFCCC. Adopted in 1997, the protocol commits 43 Annex I countries to limit their greenhouse gas emissions for the period 2008-2012 below or equal to the level of their emissions in 1990. By 2012, the Doha Amendment to the protocol was proposed to extend the protocol to a second commitment period for 2013-2020. However, only 37 countries have committed to binding targets. Binding targets for Kyoto Protocol are applicable only to Annex I (developed countries), and will end in 2020.

23. Vienna Convention for Protection of the Ozone layer, 1991 and Montreal Protocol on Substances Depleting the Ozone layer, 1991: The Vienna Convention outlines states’ responsibilities for protecting human health and the environment against the adverse effects of ozone depletion, and established the framework under which the Montreal Protocol was negotiated. The Montreal Protocol stipulates that the production and consumption of compounds that deplete ozone in the stratosphere chlorofluorocarbons (CFCs), halons, carbon tetrachloride, and methyl chloroform) are to be phased out by 2010. The project does not envisage production and consumption of ODS.

B. Country’s Legal Framework and Regulatory Requirements 24. Presidential Decree (PD) 1151, enacted on June 6, 1977, established the Philippine Environment Policy to address the need to formulate an integrated program to protect the environment. The policy mandates the government, in cooperation of concerned private organizations and entities to use all practicable means to promote the general welfare of the people through safe, decent, helpful, productive and aesthetic environment. All agencies and instrumentalities of the national government, including all government owned and controlled corporations, as well as private companies and entities with projects or undertakings that can significantly affect the quality of the environment, are required to prepare a detailed statement on the environmental impact of the proposed action, project or undertaking. 25. Presidential Decree 1586, which became effective on June 11, 1978, established the Philippine Environmental Impact Statement System. Section 4 of the decree empowers the President or his duly authorized representative to grant or deny the issuance of environmental compliance certificates (ECCs) for environmentally critical projects (ECPs) and projects within environmentally critical areas (ECAs).

26. Presidential Proclamation No. 2146 (Proclaiming Certain Areas and Types of Projects as Environmentally Critical and Within the Scope of the Environmental Impact Statement System Established under Presidential Decree No. 1586), proclaim certain areas and types of projects as environmentally critical, and hence within the scope of the EIS system.

27. Environmentally critical projects (ECPs) include the following:

a. Heavy industries i. Non-ferrous metal industries ii. Iron and steel mills iii. Petroleum and petrochemical industries including oil and gas iv. Smelting plants

b. Resource extractive industries

i. Major mining and quarrying projects ii. Forestry projects

1. Logging

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2. Major wood processing projects 3. Introduction of fauna (exotic animals) in public / private forests 4. Forest occupancy 5. Extraction of mangrove products 6. Grazing

iii. Fishery Projects 1. Dikes for/and fishpond development projects

c. Infrastructure Projects i. Major dams ii. Major power plants (fossil-fueled, nuclear fueled, hydroelectric or

geothermal) iii. Major reclamation projects iv. Major roads and bridges

28. Environmentally critical areas (ECAs) include the following:

a. All areas declared by law as national parks, watershed reserves, wildlife preserves and sanctuaries;

b. Areas set aside as aesthetic potential tourist spots; c. Areas which constitute the habitat for any endangered or threatened species of

indigenous Philippine Wildlife (flora and fauna); d. Areas of unique historic, archaeological , or scientific interests; e. Areas which are traditionally occupied by cultural communities or tribes; f. Areas frequently visited and/or hard-hit by natural calamities geologic hazards,

floods, typhoons, volcanic activity, etc. g. Areas with critical slopes; h. Areas classified as prime agricultural lands; i. Recharged areas of aquifers; j. Water bodies characterized by one or any combination of the following conditions:

i. tapped for domestic purposes; ii. within the controlled and/or protected areas declared by appropriate

authorities; iii. which support wildlife and fishery activities.

k. Mangrove areas characterized by one or any combination or the following conditions:

i. with primary pristine and dense young growth; ii. near or adjacent to traditional productive fry or fishing grounds; iii. which act as natural buffers against shore erosion, strong winds and storm

floods; iv. on which people are dependent for their livelihood.

l. Coral reef characterized by one or any combination of the following conditions: i. with 50% and above live coralline cover; ii. Spawning and nursery grounds for fish; iii. Which act as natural breakwater of coastlines.

29. Administrative Order No. 300 (Further Strengthening the Philippine Environmental Impact Statement System and Clarifying the Authority to Grant or Deny the Issuance of Environmental Compliance Certificates), signed in 1996, confirm the power of the Secretary of the Department of Environment and Natural Resources and the DENR Regional Executive Directors to grant or deny the issuance of environmental compliance certificates (ECCs). 30. Section 3 of PD 1586 mandates the National Environmental Protection Council (NEPC), to review and evaluate the environmental impact statements on declared ECPs and ECAs. The NEPC and National Pollution Control Commission (NPCC) were merged in June 1987, and by virtue of Executive Order 192, became the Environmental Management Bureau (EMB). The EMB

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became a line bureau of the DENR pursuant to Republic Act 8749 (Philippine Clean Air Act) in 1999. The DENR is tasked to administer the EIS System through the EMB and its regional offices (ROs). The DENR-EMB central office reviews and processes ECPs while the DENR-EMB ROs review and approve projects considered to be located in ECAs, as well as projects outside the EIS system purview.

31. DENR Administrative Order No. 30, series of 2003 categorized single projects into three major groups:

a. Group I: ECPs in either ECAs or Non-ECAs

i. Golf course ii. Heavy industries iii. Fishery iv. Logging v. Grazing projects vi. All projects introducing exotic fauna in public and private forests vii. Major wood processing viii. Major mining and quarrying projects ix. Major listed infrastructure projects

b. Group II: Non-ECPs in ECAs;

i. Agriculture industry ii. Buildings, storage facilities and other structures iii. Chemical industries iv. Cottage industries v. Demonstration and pilot projects vi. Environmental enhancement and mitigation projects vii. Food and related industries viii. Packaging materials and miscellaneous products industries ix. Pipeline projects x. Textile, wood and rubber industries xi. Tourism industry xii. Transport terminal facilities xiii. Waste management projects xiv. Water supply, irrigation or flood control projects xv. Treasure hunting in National Integrated Protected Areas System (NIPAS) xvi. Wildlife farming or any related projects as defined by PAWB

c. Group III: Non-ECPs in Non-ECAs – All Group II project types outside ECAs

32. Environmentally critical projects require the completion of an EIA and the submission of an EIS report (Group I) while projects in ECAs (Group II) require the preparation of an Initial Environmental Examination (IEE) Report. DENR determines if a project is an ECP or if a project will be implemented in an ECA. If either or both of these conditions apply, the proposal is required to secure an ECC. Otherwise, DENR – EMB or the ROs can issue a Certificate of Non-Coverage (CNC) certifying that the project will not significantly affect the environment (Group III). 33. Since the proposed local health units will be constructed in already built-up areas, the proposed projects are not within Environmentally Critical Areas, hence no requirement for securing ECC. 34. Table 1 contains the summary of environmental legislations applicable to the construction of health units in Marawi and Lumbayanague, Lanao del Sur.

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Table 1. Summary of Environmental Legislations Applicable to the Proposed Project

No. Legislation Number

Legislation Title Relevance to the Project Responsible Institution

1 Presidential Decree 1151 (1977)

Philippine Environmental Policy

Project proponent is not required to prepare an environmental impact statement or initial environmental examination of proposed action, project or undertaking.

Ministry of Natural Resources (1974-1987)


Philippine Environmental Impact Statement System

Establishment of Philippine environmental impact statement (EIS) system based on Section 4 of Presidential Decree 1151


3 Presidential Proclamation 2146 (1981)

Proclaiming Certain Areas and Types of Projects as Environmentally Critical and Within the Scope of EIS Established under PD 1586

Proclamation of areas and types of projects as environmentally critical and within the scope of Philippine EIS system



Creating the National Environmental Protection Council

Creation of the National Environmental Protection Council as a central authority that will oversee, unify and integrate the planning, management, and implementation of the government’s environment program

National Environmental Protection Council (1977 – 1987)

5 Executive Order No. 192 (1987)

Reorganization Act of the Department of Environment and Natural Resources

Providing for the reorganization of the Department of Environment, Energy and Natural Resources, renaming it as the Department of Environment and Natural Resources and for other Purposes

Department of Environment and Natural Resources (1987 – present)

6 DENR Administrative Order No. 2002-17

Defining the Organizational Structure and Major Responsibilities of the Environmental Management Bureau as a line Bureau by virtue of Section 34 of the Philippine Clean Air Act of 1999 (RA 8749)

Strengthening the enforcement and implementation of major environmental laws such as Presidential Decree 984 – Pollution Control Law; Presidential Decree 1586 – The Environmental Impact Assessment Law; Republic Act 6969 – Toxic Substances and Hazardous and Nuclear Wastes Control Act; Republic Act 8749 – Philippine Clean Air Act of 1999; and Republic Act 9003 – Ecological Solid

DENR and EMB

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Wastes Management Act, among others

7 DENR Administrative Order No. 30, (2003)

Implementing Rules and Regulations for the Philippine Environmental Impact Statement System

Incorporation of environmental considerations into the Environmental Impact Assessment (EIA) process at an early stage to streamline the current procedure in the conduct of the EIA process to improve the effectiveness as a planning, regulatory and management tool, and enhance maximum public participation

DENR and EMB

8 Republic Act 6969 (1990)

Toxic Substances and Hazardous and Nuclear Wastes Control Act

Mandates control and management of import, manufacture, process, distribution, use, transport, treatment and disposal of toxic substances and hazardous and nuclear wastes in the country

DENR and EMB


Philippine Clean Air Act of 1999

Comprehensive air quality management policy and program with the objective of achieving and maintaining healthy air for all Philippine citizens

DENR and EMB


Ecological Solid Wastes Management Act

Provides guidelines for ecological solid waste management program and creating the necessary institutional mechanisms and incentives as well as prohibitions and penalties

National Solid Waste Management Commission (NSWMC) and EMB


Philippine Clean Water Act of 2004

Applies to water quality management in all water bodies. Primarily applies to abatement and control of pollution from land-based sources.

DENR and EMB


National Integrated Protected Areas System Act

Establishment of a

comprehensive system of

integrated protected areas

within the classification of

national park to secure the

present and future

generations the perpetual

existence of all native plants

and animals

DENR

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13 DAO 08, series of 2016

Water Quality Guidelines and General Effluent Standards of 2016

Amended DAO 34 and 35

series of 1990. Classifies

Agus River as Class C6,

which is appropriate as

fishery water for propagation

and growth of fish and other

aquatic resources,

recreational water class II fit

for boating, and industrial

water class I for

manufacturing process after

treatment.

DENR and EMB

14 Republic Act 10066 (2009)

National Cultural Heritage Act of 2009

Provides for the protection

and conservation of the

national cultural heritage,

strengthening the National

Commission for Culture and

the Arts (NCCA) and its

affiliated cultural agencies

National Commission for Culture and the Arts (NCCA)

15 Republic Act 10752 (2016)

The Right-of-Way Act Aims to streamline the basis for valuation, as well as the process for the negotiation and acquisition of right-of-way for government infrastructure projects

DPWH

16 Presidential

Decree 953

(1976)

Requiring the planting of

trees in certain places and

penalizing unauthorized

cutting, destruction and

damaging and injuring on

certain trees, plants and

vegetations destruction,

damaging and injuring of

certain trees, plants and

vegetation

Guidelines on planting of

trees and penalty for cutting

and damaging of trees

Bureau of

Forest

Development

(BFD)

17 Republic Act 11058 (2018)

An Act Strengthening Compliance with Occupational Safety and Health Standards and Providing Penalties for Violations thereof

Aims to ensure a safe and healthful workplace for all workers by affording them full protection against all hazards in their work environment. Rules apply to contractors and subcontractors including projects in the public sector

Department

of Labor and

Employment

(DOLE)


Climate Change Act of 2009

Mainstreaming climate

change into government

policy and establishing

Climate Change

6 Lake Lanao has been classified as “Class A”, which means that waters coming from the lake require complete treatment to meet the national standards for drinking water (https://www.officialgazette.gov.ph/2014/03/13/denr-classifies-21-more-water-bodies/).

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framework strategy and

program for its

implementation

Commission (CCC)

19 Executive Order 174 (2014)

Institutionalizing Philippine Greenhouse Gas Inventory Management and Reporting System

Institutionalization of GHG

inventory management and

reporting system in relevant

government agencies to

ensure transition towards a

climate-resilient pathway for

sustainable development.

Climate Change Commission (CCC)

20 Administrative Order 2013-24

Chemical Control Order (CCO)

Set a 90ppm total lead content limit in paint. The CCO provided for a three-year phase out period from 2013 to 2016 for lead-containing paints used for architectural, decorative and household applications.

Department of Environment and Natural Resources

35. Project Screening. To determine project coverage, the proposed projects in Marawi and Lumbayanague shall be screened based on the following EMB classification: 36. Category A. Projects or undertakings which are classified as environmentally critical projects (ECPs) under Presidential Proclamation No. 2146 (1981), Proclamation No. 803 (1996) (Annex A). Proponents of these projects implemented starting 1982 are required to secure an Environmental Compliance Certificate (ECC).

37. Category B. Projects or undertakings which are not classified as ECP under Category A, but which are deemed to affect the quality of the environment as these are located in an environmentally critical area (ECA) as declared under Proclamation No. 2146. Proponents of these projects implemented starting 1982 are also required to secure an Environmental Compliance Certificate (ECC).

38. Category C. Projects or undertakings not falling under Category A or B which are intended to directly enhance the quality of the environment or directly address existing environmental problems.

39. Category D. Projects or undertakings that are deemed unlikely to cause significant adverse impacts on the quality of the environment. These projects are not covered by the Philippine EIS System and are not required to secure an ECC.

40. Based on Annex A (Project Thresholds for Coverage Screening and Categorization – (http://119.92.161.2/portal/Portals/21/Downloads/Annex%20A%20Project%20Thresholds%20for%20Coverage%20Screening%20and%20Categorization.pdf)) of the Revised Guidelines for Coverage Screening and Standardized Requirements in the Philippine EIS System, clinics, including rural health units is not covered by the Philippine EIA system.

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Table 2. Project Thresholds for Coverage Screening and Categorization in Philippine EIS System

Category Philippine EIA Coverage

Project Category Required Environment

Document Yes No

Primary, secondary, tertiary hospitals or medical facilities

B (Non-ECP) IEE Checklist

Clinics (outpatients, health centers, dental clinics), including rural health units, X-ray clinic, diagnostic laboratory, assay laboratory

D (Not covered) Project Description

i) Under Annex A (Project Thresholds for Coverage Screening and Categorization) of EMB Memorandum Circular (MC) 005, series of 2014, screening must be done to determine what document type the proponent will prepare and submit to EMB for environmental compliance certificate (ECC) application.

ii) Based on the same MC, screening must be done to determine whether the project is located within an environmentally critical area (ECA) as enumerated in Section 3-b of the guideline.

iii) To determine the type of environmental report the proponent needs to prepare to secure environmental compliance certificate (ECC), Annex A of the guideline details the project thresholds for coverage screening and categorization.

iv) Clinics, including rural health units, are not covered by the Philippine EIS System. v) Purchase of mobile health units are not covered by the Philippine EIS System. vi) Tree cutting permit from DENR Community Environment and Natural Resources

Office (CENRO) is required for infrastructure projects if there will be affected vegetation

C. Regulatory Framework on Operationalization of Local Health Systems

41. The Local Government Code (Republic Act No. 7160) was enacted in 1991, which changed the health system by giving LGUs the responsibility and autonomy to manage local health facilities and services. As mandated by law, provincial governments are tasked with providing primary and secondary hospital care, while city and municipal governments are tasked with providing primary health care, promotive and preventive health programs and basic ambulatory clinical care. In this set up, the DOH, as the national health agency, is mandated to lay down national policies and plans, develop technical standards, enforce health regulations, and monitor, evaluate and deliver tertiary and specialized hospital services. 42. In every province, city or municipality, there is a local health board chaired by the local chief executive. Its function is to serve as an advisory body to the local chief executive and the local legislative council (sanggunian) on health-related matters. Under the Local Government Code of 1991, the DOH maintains representation in all local health boards through the DOH representatives (organized most recently as Development Management Officers under the DOH Provincial Health Teams).

43. As a distinct subnational entity created by law (Republic Act No. 6734, as amended by

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Republic Act No. 9054), the ARMM consisting of five provinces has its own regional DOH headed by a Regional Secretary of Health directly responsible to the ARMM Regional Governor. It directly administers the provincial, city and municipal health offices, and the provincial and district hospitals within the autonomous region.

D. Environmental Regulatory Framework Applicable to DOH

44. The Inter-Agency Committee on Environmental Health (IACEH), with the DOH as chair and the Department of Environment and Natural Resources as vice-chair, was created in 1991 by virtue of Executive Order No. 489 as a venue for technical collaboration, effective monitoring and communication, resource mobilization, policy review and development on matters related to the effects of the environment on population health. Collaborative policies and actions within the IACEH are tackled under the five multisectoral task forces on water, solid waste, air, toxic and chemical 44 substances and occupational health to ensure that environmental and occupational hazards and risks are mitigated; and that diseases, disabilities and deaths from environmental factors are prevented (NEHAP, 2010). Related to this, the Climate Change Act of 2009 (Republic Act No. 9729) was enacted to mainstream climate change into Government policies and to establish strategies and programmes on climate change. For this purpose, the Climate Change Commission was established with the President of the Philippines as the Chairperson and three commissioners as members, with the DOH representing the health sector in the advisory board. 45. Another law, the Philippine Disaster Risk Reduction and Management Act of 2010 (Republic Act No. 10121) provided for the development of policies and plans, and the implementation of actions and measures pertaining to all aspects of disaster risk reduction and management (DRRM), including risk assessment and early warning, awareness-raising, reducing underlying risk factors and ensuring preparedness for effective response and early recovery. The law restructured the National Disaster Coordinating Council into the National Disaster Risk Reduction and Management Council (NDRRMC) chaired by the Secretary of National Defense. The active participation of the DOH in the Council ensures that health concerns are taken into account in all policies and decisions.

E. Regulatory Framework in Autonomous Region in Muslim Mindanao

46. Republic Act 11054 (An Act Providing for the Organic Law for the Bangsamoro Automous Region in Muslim Mindanao, Repealing for the Purpose Republic Act No. 6734, Entitled "An Act Providing for An Organic Act for the Autonomous Region in Muslim Mindanao," As Amended by Republic Act No. 9054, Entitled "An Act to Strengthen and Expand the Organic Act for the Autonomous Region in Muslim Mindanao") was signed by President Duterte on July 26, 2018 and became effective on August 2018. Following the plebiscite on January 2019, the following are considered the new composition of Bangsamoro Autonomous Region in Muslim Mindanao (BARMM): 1. Basilan (except Isabela City), Maguindanao, Lanao del Sur, Sulu, Tawi-tawi, City of Cotabato, and 63 barangays from the province of Cotabato. 47. Proclamation No. 453, issued in 1953 (Reserving for Military Purposes a Portion of the Public Domain Situated in the City of Dansalan, Island of Mindanao) reserve for military purposes a parcel of the public domain, situated at Camp Keithley, City of Dansalan, Island of Mindanao and described in Bureau of Lands Plan II-5919. The proposed City Health Unit, to be located at the existing City Engineering Office and General Services Office is within the City Hall compound, which is part of Proclamation No. 453.

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F. Asian Development Bank Safeguard Policies

48. The Safeguard Policy Statement (SPS) was approved by ADB’s Board of Director in July 2009. The consolidated policy framework builds upon the three previous safeguard policies on environment, involuntary resettlement and indigenous peoples. The SPS became applicable for all ADB-supported projects reviewed by ADB management after 20 January 2010. The SPS replaces ADB’s Involuntary Resettlement Policy (1995), Policy on Indigenous Peoples (1998), and Environment Policy (2002). 49. The objectives of ADB’s safeguards are to:

a. Avoid adverse impact of projects on the environment and affected people; b. Minimize, mitigate and/or compensate for adverse project impacts on the

environment and affected people when avoidance is not possible; and c. Help borrowers / clients to strengthen their safeguard systems and develop the

capacity to manage environmental and social risks.

50. The policy requires the borrowers to undertake social and environmental assessments, conduct consultations with affected people and communities, prepare and implement safeguard plans (environmental management plan, resettlement plan, and indigenous peoples plan), monitor its implementation, and prepare and submit monitoring reports, as required in the covenants entered into by the borrower with ADB.

51. The role of ADB on the other hand, is to explain policy requirements to borrowers, help borrowers meet SPS requirements during project processing and implementation through capacity building programs, ensure due diligence and review, and provide monitoring and supervision.

52. For environmental safeguards, projects are classified into the following categories:

i) Category A. The proposed project is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented; impacts may affect an area larger than the sites or facilities subject to physical works. A full-scale environmental impact assessment (EIA) including an environmental management plan (EMP), is required.

ii) Category B. The proposed project’s potential environmental impacts are less adverse and fewer in number than those of category A projects; impacts are site- specific, few if any of them are irreversible, and impacts can be readily addressed through mitigation measures. An initial environmental examination (IEE), including an EMP, is required.

iii) Category C. The proposed project is likely to have minimal or no adverse

environmental impacts. No EIA or IEE is required although environmental implications need to be reviewed.

iv) Category FI. The proposed project involves the investment of ADB funds to, or

through, a financial intermediary.

53. Project categorization has been done using REA checklist following the guidance provided above and the project is categorized as B. As per SPS 2009, Category B projects warrants preparation of an IEE. The SPS includes 11 policy principles on environment safeguards

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on screening, conduct of environmental assessment, alternative analysis, mitigation hierarchy, need for meaningful consultation, public disclosure, environmental management planning, biodiversity protection and conservation, pollution prevention, occupational health and safety, and conservation of physical cultural resources.

G. Other Applicable Regulations

a. DOH – Health Facilities Development Bureau (HFDB) 54. The DOH National Center for Health Facilities Development, now called the Health Facility Development Bureau (HFDB), developed the first Philippine Hospital Development Plan (PHDP) in 1995 to create a more responsive hospital system in the country. The PHDP was further updated in 2000 as a major thrust of the Health Sector Reform Agenda (Asia Pacific Observatory on Health Systems and Policies, 2013; Romualdez et al., 2011). 55. The development of hospitals and other health facilities is planned and designed according to appropriate architectural practices, and technical and operational guidelines established by the DOH. As a framework for health facility development, the DOH issued Administrative Order No. 29 of 2006 (Guidelines for Rationalizing the Health Care Delivery System based on Health Needs), which provides the procedures and requirements for planning health facilities in the crafting of Province-wide Investment Planning for Health (PIPH) and City-wide Investment Planning for Health (CIPH) by the LGUs. The DOH also issued Administrative Order Nos. 2006–0004 and 2006–0004-A (Guidelines for the Issuance of Certificate of Need to Establish a New Hospital) covering both government and private hospitals, specifying the requirements for establishing new hospitals, and upgrading, converting or increasing the bed capacity of existing hospitals. The guidelines established the basic criteria for a proposed health facility such as the catchment population, location and the commitment of LGUs to fund and maintain the health facility.

b. National Historical Institute and National Museum

56. In case of chance find of important historical and cultural properties during the construction phase, the National Historical Institute shall be responsible for significant movable and immovable cultural property that pertains to Philippine history, heroes and the conservation of historical artifacts and the National Museum shall be responsible for significant movable and immovable cultural and natural property pertaining to collections of fine arts, archaeology, anthropology, botany, geology, zoology and astronomy, including its conservation aspect.

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III. DESCRIPTION OF THE PROJECT

A. Project Locations

57. Marawi City, formerly called Dansalan, is the capital of Lanao del Sur province. The city is located on the northern shore of Lake Lanao, about 1,100 meters above sea level, is considered one of the Philippines’ largest cities with Muslim population, hence its official name Islamic City of Marawi. Lumbayanague, on the other hand, is located on the southern shore of Lake Lanao ( 58. 59.

60. Figure 1). The municipality was created by virtue of Presidential Decree 1091 circa 1977 from several barangays of Lumbatan and Butig. 61. The proposed local health units will be located inside Marawi City Hall compound at the current site of the City Engineering Office and General Services Office, and inside the municipal compound of Lumbayanague, Lanao del Sur. The proposed health units in the two LGUs will be equipped to meet the 4:1 service delivery requirement, comprising (i) Tamang Serbisyo sa Kalusugan ng Pamilya (TSeKaP, a primary health care package under the Philippine Health Insurance Corporation); (ii) Maternal Care Package; (iii) Directly observed treatment, short-course for tuberculosis (TB DOTS) and (iv) Animal Bite Services. The Rapid Environmental Assessment (REA) Checklist is attached as Appendix 1.

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Figure 1. Map of Lanao del Sur

a. Marawi City

62. The proposed CHU is located inside the city hall compound of Marawi City, where government buildings, including the city hall and the City Health Office (CHO) and Integrated Provincial Health Office (IPHO), are located. The proposed site is about 100 meters from Agus River. During the assessments conducted on 28 May 2019 and 18 December 2019, the ADB team and DOH from the national and regional offices inspected the existing CEO and GSO buildings where the proposed CHU will be built. Appendix 2 and Appendix 3 include the summary of meeting with different Marawi stakeholders and site assessment conducted by ADB consultant on 18 December, 2019. Appendix 4 and Appendix 5 are the site assessment report done by ADB consultant and DOH site inspection report, both on 28-29 May, 2019. 63. Some of the observations during the 18 December 2019 site assessment in Marawi City include:

a. The existing City Engineering Office and General Services Office buildings will be demolished as part of the overall rehabilitation of the Government Center compound of Marawi, as indicated in the Masterplan for the rehabilitation of government buildings of the city.

b. No major impacts are anticipated in the construction of CHU, except for the impacts of demolition, including the management of demolition debris of the existing CEO and GSO buildings and the temporary detention facility for inmates

c. The City Engineering Office and General Services Office will be transferred to a new building, also located within the Government Center compound. Employees are amenable with the relocation of their offices. The inmates will be also transferred to a new detention facility.

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d. The Mines and Sciences Bureau has conducted a geohazard susceptibility study for the whole government center complex and concluded that the area has very low susceptibility to landslide.

e. The demolition of the CEO and GSO buildings shall follow the provisions of RA 9003 in the collection, storage, transport and disposal of demolition debris. Task Force Bangon Marawi, through the Military Engineering Unit will provide assistance in the demolition and transport of wastes.

f. As regards the proof of ownership of the proposed site, the Office of the Mayor assured that the Land Registration Authority has confirmed that Proclamation Nos. 375, 453 and 806 are still in effect, which states that the area occupied by the Government Center is government property.

g. The city has to coordinate with the Department of Environment and Natural Resources (DENR) to assess the two mature diseased trees that might be affected by the demolition of existing buildings and construction of the new CHU.

b. The proposed new city health unit will incorporate climate change resilience interventions, which include the raising of floor level by 2 feet to mitigate flooding. The building will also be equipped with solar panels to supplement the power coming from the grid.

64. As reflected in the EARF and based on the site assessment conducted, potential impacts from the demolition of the old building and construction of new CHU include: (i) generation of solid wastes; deterioration of surface water quality of Agus River and Lake Lanao, soil and groundwater contamination arising from solid wastes from demolition of old building, occupational and community health and safety as the demolition and construction will be inside the government center, and traffic and obstruction concerns, as many people go to the government center to conduct business and access services.

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Figure 2. City Engineering Office building, Government Center of Marawi

Figure 3. General Services Office building, Government Center of Marawi City

Figure 4. Master Development Plan of Government Center of Marawi, including the

proposed City Health Unit

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b. Lumbayanague

65. The proposed rural health unit in Lumbayanague will be constructed in a vacant 800 m2 vacant lot at the back of the municipal hall. The proposed site of the RHU is about 570 meters from Lake Lanao. The proposed building is at the back of the municipal hall and adjacent to Sultan Gunting Central Elementary School.

Figure 5. Proposed location of Lumbayanague RHU B. Typical Plan of Local Health Unit

66. The proposed health facilities in Marawi and Lumbayanague will have similar floor plans. The plans are in accordance to DOH guidelines to service delivery requirements and ADB requirements, as stipulated in the grant agreement and the Project Administration Manual (PAM). 67. The proposed health units will follow DOH guidelines to the following service delivery requirements:

1. Tamang serbisyo sa kalusugan ng pamilya (TSEKUP) services

a. Consultation/treatment room

b. Dental clinic

c. Drug storage d. Laboratory (microscopy)

e. Reception/record/Philhealth section

2. Maternity Care Package (MCP) services a. Birthing room

b. Labor room

c. OB Ward/Family Room

d. Scrub up area e. Sterilization / cleanup room

f. Supervisor's area/staff toilet/ dressing area

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a. Pre-natal

3. TB Dots services a. Consultation area (TB Dots) b. Nurse station TB Dots c. Laboratory (TB Dots) d. Waiting Area 4. Administrative Services a. Lobby b. Nurse working area c. Conference room d. MHO Office e. Sanitary Inspector's office. f. Kitchenette 5. Animal Bite Services

68. The proposed health units will also comply with gender responsive design requirements of ADB, as stipulated in the grant agreement and the Project Administration Manual (PAM). These include foot washing area and worship, prayer room separate for male and female, and four child changing stations and restraint seats. 69. The design of the health units will also incorporate climate resilience measures. These include:

a. Raising finished floor to at least 600mm from finish grade line. b. Provision of area at 2nd floor for future installation of solar panels. c. Provision for rain collection system will be implemented. d. Require Civil Works drawings, to ensure site conditions are properly addressed;

i.e., conduct proper site investigation and corresponding drawings, such as topographic map, storm drainage plan, etc.

e. Provision of water tank, and water collection system. f. Provision of off the gird power supply, i.e., solar power (subject to funds

availability).

70. The proposed local health units will also incorporate solar powered refrigeration to ensure the continuity of health services, specifically on the storage of heat-sensitive vaccines. The solar powered refrigerator that will be incorporated for the Project should be powered directly by the sun (with or without battery) to keep the heat-sensitive vaccines at the right temperature. The World Health Organization (WHO) requires a holdover time of 3 days at 43 °C. Appendix 6 contains the guidelines for climate change and greenhouse resilience design. 71. The indicative area allocations to accommodate the design and space requirements include: 1. Ground Floor - 387.20 m2 2. Second Floor - 179.20 m2 __________

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Total = 566.40 m2

Figure 6. Proposed 2-storey Rural Health Unit Ground Floor Plan

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Figure 7. Proposed 2-storey Rural Health Unit Second Floor Plan

Figure 8. Rural Health Unit with Birthing Home and TB DOTS Service Mode

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IV. DESCRIPTION OF THE ENVIRONME

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