On the Integration of the PENCAS Act in Current CLUP Approvals

Today, Gus Agosto, a licensed Environmental Planner, sent his formal reply to the Department of Human Settlements and Urban Development (DHSUD), signaling a continuing exchange on the review of the Cebu City Comprehensive Land Use Plan (CLUP) 2023–2032.

The exchange brings into focus a critical issue in Philippine land use planning: the alignment of existing planning practices with Republic Act No. 11995, or the Philippine Ecosystem and Natural Capital Accounting System (PENCAS) Act.

Gus Agosto, a former ADB Consultant, stressed that “the law is already in force.” Consequently, its requirements—especially the integration of environmental and natural capital considerations into planning and decision-making—are neither prospective nor optional, but are binding elements of the existing legal framework governing land use.

While the Department has emphasized the need for technical readiness, including the development of standardized datasets and frameworks, it is important to underscore that institutional readiness does not suspend legal obligation. A clear distinction must be made between full technical implementation and minimum compliance. Even at present, there are sufficient tools—such as hazard mapping, watershed delineation, and environmental constraints analysis—to begin integrating ecological limits into planning decisions.

Deferring integration to the “next CLUP cycle,” which may span nearly a decade, risks allowing land use decisions to proceed under frameworks that do not reflect current legal and environmental realities. In a region like Cebu, which continues to face recurring disasters and environmental stress, such delay raises serious concerns about the adequacy of planning safeguards.

Recent events—including the Binaliw dumpsite collapse in January 2026 and the widespread devastation caused by Typhoon Tino in 2025—underscore the real-world consequences of land use decisions that fail to fully account for environmental risks. These incidents highlight the urgency of ensuring that planning frameworks evolve in step with both law and lived experience.

“The issue is not whether we can fully implement PENCAS today, but whether we can justify continuing to approve land use decisions that ignore a law already in force. We already know where the risks are. The responsibility now is to ensure that planning decisions reflect that reality—before the next disaster forces the correction.” Consultant Agosto said.

The objective is not to disrupt planning processes, but to strengthen them. A transitional approach—where PENCAS principles are integrated to the extent practicable while full systems are being developed—offers a balanced and legally sound path forward.

The question is not whether we are ready to implement the law, but whether we can afford not to.

Following is my letter reply to the DHSUD:

HON. ATTY. RAMON QUINTIN CLAUDIO C. ALLADO
Undersecretary
Department of Human Settlements and Urban Development (DHSUD)
Kalayaan Avenue, Diliman
Quezon City

CC : DIRECTOR, LEGAL SERVICE

Re: Response to DHSUD Letter dated 16 February 2026
On the Review and Implementation of the Cebu City CLUP 2023–2032

Dear Undersecretary Allado:

I acknowledge receipt of your letter dated 16 February 2026 concerning the review and implementation of the Cebu City Comprehensive Land Use Plan (CLUP) 2023–2032 in relation to the Philippine Ecosystem and Natural Capital Accounting System Act (PENCAS, Republic Act No. 11995).

While I appreciate the Department’s recognition of natural capital accounting’s role in land use planning, I respectfully register strong reservations regarding the proposal to defer its integration until complete frameworks, datasets, and guidelines are issued—or to limit it to the next CLUP cycle.

1. Immediate Binding Effect of the PENCAS Act

Republic Act No. 11995 is in full force and binds all government agencies, including DHSUD, in their administrative functions. The absence of complete technical frameworks or datasets does not suspend this obligation; administrative convenience cannot supersede a statutory mandate.

2. CLUP Approval as a Continuing Administrative Act

CLUP review and approval constitute an ongoing administrative function that must align with laws in effect at the time of the decision. Approving a CLUP without incorporating PENCAS requirements undermines its substantive legal validity, irrespective of procedural compliance.

3. Impropriety of Deferral to the Next Cycle

Deferring the integration of PENCAS to the “next cycle”—effectively a decade from the current 2023–2032 planning horizon, especially in a context marked by historical delays in plan updating—is untenable in the face of recurring and intensifying disasters in Cebu. Recent events, including the January 2026 Binaliw dumpsite collapse that claimed 36 lives, and Typhoon Tino (2025), which left at least 158 fatalities, dozens missing, and thousands injured across Compostela, Liloan, Balamban, Danao City, and Cebu City, underscore the grave consequences of inadequate land use planning.

These incidents are not isolated occurrences, but manifestations of systemic vulnerabilities—many of which may be linked to outdated or insufficiently responsive planning frameworks. In this light, a policy of deferring compliance with the PENCAS Act risks perpetuating land use decisions that fail to reflect environmental constraints and hazard realities. This, in turn, increases foreseeable risk and undermines the duty of planning authorities to align land use regulation with existing legal mandates and evolving environmental conditions.

4. Distinction Between Full Implementation and Minimum Compliance

Full technical implementation may await standardized systems, but minimum transitional compliance is feasible now using available tools like hazard mapping, watershed delineation, and environmental constraints analysis. Ecological limits can thus inform planning without full PENCAS operationalization.

5. Request for Clarification

In view of the above, I respectfully seek clarification on:

i. Whether DHSUD plans to approve CLUPs omitting PENCAS requirements;

ii. Whether interim or minimum compliance measures apply to LGUs pending full PENCAS rollout; and

iii. Whether the Department contemplates transitional guidelines to align current planning with legal mandates.

6. Reservation of Rights

This letter is without prejudice to further actions to ensure land use planning complies with the law and addresses environmental and developmental imperatives.

7. Closing

My intent is not to hinder planning but to affirm that natural capital integration is now a legal imperative, not mere policy.

Thank you for your attention.

Respectfully yours,

Augusto B. Agosto, JD

Environmental Planner

Monterrazas and the Tragedy of the Commons

Why System Thinking Requires Stricter Development Standards

Recent public discussions have reflected different perspectives on the Monterrazas development in Cebu City, including system-level explanations, precautionary considerations, and calls for regulatory review. These illustrate the complexity of decision-making in such contexts.

At first glance, the issue may appear as a familiar tension between development and environmental protection. However, it may be more accurately understood through a different lens.

From an economic perspective, what this situation reflects is a form of the Tragedy of the Commons.

The concern lies in understanding how multiple developments interact within a shared system, and how each contributes to cumulative impacts over time.

Cebu’s upland areas perform essential ecological functions. They absorb rainfall, regulate runoff, and contribute to the stability of downstream communities. These functions do not operate within the boundaries of individual properties. They extend across space, linking different parts of the city through continuous hydrological processes.

In this context, the question of whether a particular development lies within or outside a defined watershed boundary, while relevant in technical terms, does not fully resolve the issue. Environmental systems do not operate as isolated compartments. Their behavior reflects interaction rather than separation.

The scale of that interaction is often difficult to grasp in abstract terms.

Evidence from watersheds within Metro Cebu further clarifies how this system operates—and how development must be understood within it.

Studies of the Mananga watershed show that land-use and land-cover changes—particularly in upstream areas—affect infiltration, surface runoff, and the movement of water across the system. As vegetation is reduced or land is altered, less water is absorbed and more becomes surface flow.

A similar pattern is observed in the Butuanon River watershed. The river originates in upland areas of Cebu City and flows through increasingly urbanized zones before reaching the coast. Upstream areas are already characterized by agricultural and altered land uses, while downstream sections are densely developed. This configuration illustrates how water accumulates as it moves across elevations, shaped by both upstream conditions and downstream constraints.

Altogether, these cases point to a consistent principle:

The watershed is the system within which individual projects must be considered, as runoff is generated across the entire catchment while its behavior is shaped by land-use conditions across different elevations.

This framing is critical. It does not assign causation to any single location. Rather, it defines the proper unit of analysis.

A project is not evaluated in isolation, but in relation to the system it enters—where each intervention contributes to cumulative pressures and must therefore be assessed with reference to the system’s capacity.

It is often observed that flooding in Cebu is multi-causal. Infrastructure limitations, watershed conditions, land-use changes, and rainfall patterns all contribute. This observation is correct.

However, its implication must be properly understood.

If multi-causality is interpreted to mean that no single development can be meaningfully evaluated, then responsibility becomes diffused. Multiple factors contribute, yet accountability becomes less clearly defined.

But the correct implication is the opposite.

If risk is systemic, then evaluation must also be systemic—and correspondingly more rigorous.

The system is not an excuse—it is the basis for stricter evaluation.

This requires a shift in how development decisions are made.

The relevant question is not whether a particular project can be shown to cause a specific flooding event. Rather, it is whether the addition of that project contributes, in combination with others, to increasing pressure on a system that may already be approaching its limits.

The concern lies in the combined effects within a shared system, and in how each individual project contributes to those cumulative impacts.

This leads to a central question:

What is the capacity of the system?

How many developments are already present within a given environmental zone?
To what extent has land use already been altered?
At what point does additional development begin to significantly affect the system’s ability to absorb rainfall and regulate runoff?

Without a clear understanding of these limits, development decisions are made incrementally, without reference to cumulative thresholds.

The Monterrazas issue, therefore, should be viewed in terms of how development decisions are made when each additional project contributes to a system with finite capacity.

In such a context, compliance at the project level is no longer sufficient. Each additional intervention must be evaluated in relation to the condition of the system as a whole.

This has significant implications for urban development.

First, evaluation must move beyond individual projects toward system-level analysis.

Second, development must be aligned with capacity. Growth is no longer simply a matter of feasibility or compliance, but of whether the system can sustain additional pressure.

Third, planning must shift from reactive to anticipatory. Addressing impacts only after they occur is both inefficient and costly.

Fourth, institutional coordination must ensure that decisions reflect a consistent understanding of cumulative risk.

The Monterrazas issue is not resolved by determining whether it falls within a particular boundary, nor by isolating it from broader conditions.

It must be understood as part of a system where effects accumulate, capacity is finite, and each development contributes to increasing pressure on that system.

It shows that outcomes in shared systems are shaped not only by individual decisions, but by how those decisions accumulate—and whether they are governed by a clear understanding of limits.

Ultimately, the question is not whether a particular project should proceed or not.

It is whether each project is evaluated in light of the system it enters—and whether that system can sustain the additional burden it brings.

Because in such systems, urban development is no longer simply about what can be built.

It is about how each development contributes to a shared environment—and whether the whole remains within its capacity to endure.

Natural Capital Accounting and the Apo Quarry Case

The recent tax dispute between the Province of Cebu and Apo Land and Quarry Corporation (ALQC) has highlighted the legal limits of provincial taxation authority over quarry operations. The initial assessment of approximately Php1.218 billion was reduced to a proposed Php211 million compromise settlement, now under review by the Provincial Board. While the legal aspects of the dispute revolve around statutory limits on quarry taxation, the case also raises a broader question: how should the economic value of natural landscapes affected by quarry extraction be measured?

The Philippines has recently institutionalized ecosystem and natural capital accounting through Republic Act No. 11995, commonly referred to as PENCAS. This law recognizes ecosystems as economic assets whose value should be reflected in national and local policy decisions. When applied to quarry operations, natural capital accounting allows policymakers to estimate the economic value of ecosystem services that may be affected by extraction activities.

Under the PENCAS framework, the economic value of a natural resource landscape can be expressed as the Total Economic Value, which combines both market output and ecosystem services.

Component	Description
Market value	Commercial value of extracted minerals
Natural capital value	Ecosystem services such as watershed protection, slope stabilization, and flood mitigation

While traditional taxation captures only the market value of extraction, natural capital accounting attempts to quantify the value of ecosystem functions that support environmental stability and community resilience.

The Apo quarry operations cover an estimated 406 hectares under mining agreements. However, quarry sites typically disturb only a portion of the concession area at any given time. International mining and quarrying studies suggest that active disturbance commonly affects 30–40 percent of the concession area. Applying a mid-range estimate of 35 percent disturbance, the approximate area of affected landscape may be calculated as follows:

Indicator	Value
Total concession area	406 hectares
Estimated disturbance ratio	35%
Estimated disturbed area	142 hectares

Global watershed valuation studies—including the The Economics of Ecosystems and Biodiversity (TEEB) Initiative and the widely cited work of Costanza et al. (2014) Changes in the Global Value of Ecosystem Services—estimate the bundled value of ecosystem services such as watershed protection, flood regulation, erosion control, and groundwater recharge at approximately US$3,000 to US$20,000 per hectare per year depending on ecosystem type.

Also, ecosystem service valuation studies conducted in watershed environments worldwide estimate the value of environmental services such as flood regulation, erosion control, and groundwater recharge at approximately US$10,000–US$20,000 per hectare annually. Converting this range into Philippine pesos results in an estimated Php500,000 to Php1,000,000 per hectare per year.

Using a conservative midpoint estimate of Php900,000 per hectare annually, the potential ecosystem service value associated with the affected landscape may be estimated as follows:

Calculation	Value
Disturbed area	142 hectares
Estimated ecosystem value per hectare	Php900,000/year
Estimated ecosystem service value	Php127.8 million per year

This estimated ecological value offers a useful point of comparison with the proposed compromise settlement in the Apo tax case. If the Php211 million settlement is distributed across the approximate 16-year coverage period of the assessment, the provincial fiscal recovery corresponds to roughly Php13.2 million per year.

The comparison between fiscal recovery and estimated ecosystem value may be illustrated as follows:

Indicator	Estimated Value
Ecosystem services value	Php127.8 million / year
Provincial fiscal recovery	Php13.2 million / year
Fiscal capture ratio	≈10% of ecosystem value

It is important to emphasize that this comparison does not imply a legal liability on the part of the quarry operator. Rather, it illustrates the difference between the fiscal instruments currently available to local governments and the broader environmental value associated with landscapes affected by extraction activities.

Mining agreements in the Philippines typically operate within a 25–30 year timeframe. If the estimated ecosystem service value were projected over a 30-year operational horizon, the cumulative value of ecosystem services associated with the affected landscape could be estimated as follows:

Projection	Value
Annual ecosystem value	Php127.8 million
30-year horizon Estimated ecosystem value	Php3.8 billion

This simplified natural capital ledger helps place the Apo quarry case within a broader economic context.

Component	Estimated Value
Limestone production value (Cebu quarry sector)	~Php225 million/year
Ecosystem service value	~Php128 million/year
Estimated 30-year ecosystem value	~Php3.8 billion
+ Carbon sequestration	+Php8 million
Proposed tax settlement	Php211 million

From a policy perspective, the significance of this analysis lies not in assigning additional financial liability but in recognizing the economic importance of ecosystems within resource governance.Carbon sequestration offers a strong “alternative use” valuation for quarry-disturbed lands like Apo (upland Cebu forests), quantifying foregone climate benefits as an opportunity cost in your natural capital ledger.

The Apo case illustrates the structural characteristics of the Philippine mining governance framework. Mineral resources are owned by the State and administered by the national government, while environmental impacts and land-use implications are often experienced locally. As a result, local governments may face environmental management responsibilities while having limited taxation authority over extraction activities.

Natural capital accounting offers a complementary tool that allows policymakers to understand the broader economic landscape within which resource extraction occurs. Instead of relying solely on traditional taxation mechanisms, governments can use ecosystem accounting to guide policies such as watershed restoration programs, rehabilitation funds, and long-term land-use planning.

In this sense, the Apo quarry case highlights an important shift in public policy thinking. While taxation measures the financial revenue generated from extraction, natural capital accounting helps quantify the environmental assets that support economic activity and community resilience.

As Cebu continues to grow as an economic center in the Visayas, integrating natural capital accounting into resource governance may provide a more comprehensive framework for balancing development, environmental stewardship, and long-term sustainability.

The purpose of this estimation is to illustrate how ecosystem accounting can complement traditional fiscal metrics. While tax assessments measure the financial revenues associated with extraction activities, natural capital accounting helps quantify the environmental services that landscapes provide to surrounding communities.

In this sense, the Apo quarry case underscores the potential policy relevance of ecosystem accounting under Republic Act No. 11995, PENCAS. By recognizing ecosystems as economic assets, natural capital accounting allows policymakers to better understand how natural landscapes contribute to long-term environmental resilience and sustainable development.

The Apo Quarry tax dispute reveals a critical gap in Philippine resource governance: while provincial taxes capture only a fraction (~10%) of extraction’s market value, natural capital accounting under PENCAS quantifies the far broader ecological ledger—Php128 million/year in ecosystem services plus Php8 million/year in foregone carbon sequestration across 142 disturbed hectares.

Integrating these metrics exposes structural imbalances, where local governments bear environmental burdens from nationally administered mining without commensurate fiscal tools. This analysis demonstrates NCA’s power not as a liability hammer, but as a policy compass—guiding watershed restoration bonds, progressive rehab fees, and land-use plans that align development with Cebu’s natural assets.

Beyond the Apo Tax Settlement: What the Case Reveals About Quarry Governance in Cebu

Every day in Cebu, the equivalent of 500 dump trucks of limestone leaves the province’s quarry sites. Over a year, that amounts to roughly 3.6 million tons of limestone—enough trucks lined up bumper to bumper to stretch from Cebu to Manila and back.

Yet a recent tax dispute between the Province of Cebu and Apo Land and Quarry Corporation ended with a compromise settlement of Php211.56 million, far lower than the original Php1.218 billion assessment. The tax dispute arose from differing interpretations of the province’s authority to impose quarry extraction taxes.

At first glance, the reduction appears dramatic. But the outcome reflects an important legal reality: the taxing powers of local governments are limited by national law and Supreme Court jurisprudence.

Understanding the Apo quarry case therefore, requires looking beyond the headline numbers. It reveals how law, economics, and natural resource governance intersect in a rapidly developing province like Cebu.

According to reports, the Province of Cebu initially assessed Apo Land and Quarry Corporation approximately Php1.218 billion in quarry-related taxes, fees, penalties, and interest covering operations from around 2006 to 2022. After legal review, the assessment was recalculated and reduced to a proposed Php211.56 million compromise settlement, leaving a difference of roughly Php1.006 billion. When this proposed settlement is spread across the coverage period, the provincial recovery corresponds to roughly Php13.2 million per year. The compromise, however, is not yet final and is currently under review by the Cebu Provincial Board, which must decide whether the negotiated settlement should be approved.

The Cebu Quarry Ledger

One way to understand the Apo quarry case is to view it through a simple economic ledger that compares physical extraction, economic value, and fiscal recovery.

Category	Indicator	Approximate Value
Physical extraction	Limestone production	~3.6 million tons per year
Logistics equivalent	Dump truck loads	~180,000 trucks per year
Daily extraction	Truck equivalent	~500 trucks per day
Production value	Quarry output	~₱225 million per year
Provincial recovery	Settlement equivalent	~₱13.2 million per year
Fiscal capture ratio	Provincial share	~6%

The reduction of the assessment was largely driven by the legal limits of provincial taxation powers. Provincial governments derive their authority to levy quarry taxes from the Local Government Code of 1991, which allows provinces to impose taxes on sand, gravel, and other quarry resources extracted from public lands or public waters. Apo Land and Quarry Corporation operates limestone quarries under Mineral Production Sharing Agreements (MPSAs) issued by the national government pursuant to the Philippine Mining Act of 1995. The Supreme Court clarified the limits of provincial quarry taxation in Province of Bulacan v. Court of Appeals (G.R. No. 126232, 1998), ruling that provinces cannot impose quarry extraction taxes on minerals extracted from private lands covered by mining agreements. Because part of the original Cebu assessment involved such extraction taxes, those components could not be legally sustained. Once they were removed, the remaining obligations consisted mainly of monitoring fees, environmental charges, penalties, and interest.

To appreciate the scale of quarry operations in Cebu, it helps to examine limestone production data. According to records of the Mines and Geosciences Bureau, Cebu produces roughly 3.6 million metric tons of limestone annually. Production reached about 3.91 million tons in 2022, 3.47 million tons in 2023, and 3.62 million tons in 2024, for a total of roughly 11 million tons of limestone extracted over three years.

Apo’s reported production value has been approximately:

Php225 million per year.

Compared with the provincial recovery under the proposed settlement:

Indicator	Amount
Annual production value	~Php225 million
Average provincial recovery	~Php13.2 million
Estimated fiscal capture	~6%

It should be noted that other taxes—such as corporate income tax and excise tax on minerals—are collected by the national government, not by the province.

The Apo case highlights a structural feature of Philippine resource governance.

Numbers of this scale can be difficult to visualize. If a typical quarry dump truck carries 20 tons of limestone, Cebu’s annual limestone production would require approximately 180,000 truckloads per year. Spread across the year, this corresponds to roughly 500 dump trucks of limestone leaving quarry sites every single day. If these trucks were lined up bumper to bumper, the line would stretch approximately 1,440 kilometers, roughly the distance from Cebu to Manila and back.

The production value associated with these operations is also significant. Apo’s reported quarry production value has been approximately Php225 million annually. When compared with the proposed provincial recovery under the compromise settlement—about Php13.2 million per year—the province’s fiscal capture represents roughly six percent of the reported production value. It should be noted, however, that other taxes such as corporate income taxes and mineral excise taxes are collected by the national government, not by the province.

The Apo case illustrates a structural feature of Philippine resource governance. Mineral resources are owned by the State and administered by the national government through mining agreements and permits. While extraction activities occur within provinces and municipalities and may have local environmental and land-use implications, the authority to regulate mining operations and collect major fiscal revenues largely rests with the national government. As a result, extraction occurs locally, environmental impacts are experienced locally, but taxation authority may be limited locally.

The compromise settlement in the Apo case therefore highlights a broader issue in how the economic value of natural resources is measured and governed. Taxes capture only part of the economic activity associated with extraction, and they often do not reflect the environmental systems that support development. This is precisely the gap addressed by the Philippine Ecosystem and Natural Capital Accounting System Act, which institutionalizes ecosystem and natural capital accounting in the Philippines. Natural capital accounting provides a framework for recognizing ecosystems—such as watersheds, forests, and karst landscapes—as economic assets that contribute to long-term development.

For provinces like Cebu, where quarrying occurs in upland landscapes and watershed areas, natural capital accounting can provide a more comprehensive understanding of the economic context in which resource extraction takes place. While taxation remains an important fiscal tool, ecosystem accounting helps policymakers recognize the value of environmental systems that sustain communities and economic activity.

As the Provincial Board reviews the proposed compromise settlement, the decision involves more than simply approving a negotiated amount. The board must weigh the legal sustainability of the original assessment, the fiscal risks of continued litigation, the potential precedent that a settlement may create for other cases, and the broader need to strengthen governance of natural resources within the province.

The Apo quarry tax case is therefore not merely about the reduction of a tax assessment from Php1.218 billion to Php211 million. It reflects the complex interaction between national control of mineral resources and local responsibility for land use and environmental management. As Cebu continues to grow as an economic center in the Visayas, the challenge will be to ensure that resource extraction contributes to development while maintaining responsible stewardship of the landscapes that sustain communities and ecosystems.

The lesson of the Apo case is that while taxes measure the revenue generated from extraction, natural capital accounting helps us understand the value of the landscapes from which those resources are taken.

The dynamics of quarry extraction also raise a broader political-economic question. While limestone extraction generates private economic returns for firms and supports industrial production, the environmental risks associated with landscape modification—such as altered drainage patterns, erosion, and increased flood vulnerability—are often experienced downstream. In many resource economies, economic gains from extraction are concentrated at the site of production, whereas environmental risks, such as flooding, may be borne by downstream communities.

This article analyzes publicly available information and policy issues related to quarry governance and natural capital.

An Open Letter to the Honorable Members of the Cebu Provincial Board

I have written an open letter to the Honorable Members of the Provincial Board of Cebu to share an economic perspective on the province’s mineral and quarry sector and to encourage a broader discussion on how natural resources are governed in the context of long-term development.

Over the past three years, Cebu has generated more than PhP56 billion in mineral production, including nearly Php4 billion in quarry and non-metallic minerals used for infrastructure and construction across the region. These figures highlight the significant role that mineral resources play in supporting economic growth and development in the province.

At the same time, many quarry operations occur in upland areas that also serve as critical watersheds and ecological systems. The purpose of the open letter is to respectfully invite the Provincial Board to consider how emerging policy tools—particularly natural capital accounting under **Republic Act No. 11995—can help ensure that Cebu’s development continues in a manner that recognizes both the economic value of mineral resources and the environmental systems that sustain communities.

I hope that the letter contributes constructively to ongoing discussions on how Cebu can balance economic progress with environmental stewardship for the benefit of present and future generations.

PB Open Letter R Download

Cebu’s CLUP and the Problem We Refuse to Map: Waste Disposal

Today, I attended a meeting where solid waste disposal finally took center stage. At one point, a lawyer asked me a direct question: If we are against the use of Binaliw as the city’s final disposal site, then where should Cebu put its waste?

I was a bit surprised—not because the question was hostile, but because it reflected a familiar assumption in our planning conversations: that an unsafe site somehow becomes acceptable simply because there is no immediate alternative.

My response was straightforward. If Binaliw is geologically unsafe, environmentally prohibited, or legally non-compliant, then it must be closed or phased out—even if there is no instant replacement yet. The absence of an alternative does not legalize a dangerous site. It only exposes the failure of long-term planning.

That exchange captures the heart of Cebu’s waste dilemma. We are repeatedly forced to choose between maintaining a risky status quo and confronting the harder task of planning properly. In truth, solid waste disposal is not merely an operational problem—it is a land-use problem. And unless it is clearly integrated into the city’s Comprehensive Land Use Plan (CLUP), we will keep asking the same question every time a crisis occurs: If not here, then where?

Waste Is Not a Side Issue. It Is a Planning Constraint.

Every land-use decision produces waste. Higher density means more garbage. Commercial expansion means more packaging waste. Mixed-use zones mean round-the-clock waste generation.

Despite this, solid waste management in Cebu has often been treated as a sectoral concern, discussed in a separate plan, handled by a different office, and enforced at the barangay level—while the CLUP proceeds as if waste were invisible.

This separation is a fundamental planning error.

Under Philippine planning law, solid waste is not optional, operational, or secondary. It is a land-use issue that must be integrated into the CLUP itself.

What the Law Already Recognizes

Republic Act No. 9003, the Ecological Solid Waste Management Act, is explicit: solid waste management must be integrated into local development and land-use planning.

This is not theoretical. The Department of Human Settlements and Urban Development (DHSUD) enforces this principle every day.

A subdivision cannot be approved without:

a Materials Recovery Facility (MRF),
a waste management plan,
and a clear disposal arrangement.

If DHSUD requires this level of scrutiny for a single subdivision, then it follows logically—and legally—that a city-wide CLUP must meet a higher standard, not a lower one.

Yet many CLUPs, including Cebu’s, expand urban development without clearly mapping:

where MRFs will be located,
where transfer and processing facilities will go,
how buffer zones will be enforced,
or how increased waste volumes will be safely handled.

The Inayawan Closure and the Illusion of Disposal

Cebu City once relied on the Inayawan Sanitary Landfill. That facility is now closed following environmental and legal challenges.

What replaced it is not a new landfill within the city—but dependence on external disposal arrangements.

There is nothing inherently wrong with regional disposal. In fact, for a dense island city like Cebu, regional solutions often make sense.

But here is the planning problem:

The CLUP does not clearly acknowledge or spatially integrate this dependency.

If waste is transported out of the city, the CLUP must still plan for:

transfer stations,
waste logistics corridors,
processing and diversion facilities,
environmental safeguards along the way.

Ignoring these realities does not make them disappear. It simply pushes them into unsafe locations.

Binaliw and the Cost of Planning Silence

The presence of waste-related facilities in upland barangays like Binaliw—and the landslide incidents associated with them—should be a wake-up call.

These are not isolated operational failures. They are predictable outcomes of weak land-use integration.

RA 9003 prohibits waste facilities in environmentally critical and geologically unstable areas. Cebu’s own studies identify upland zones as landslide-prone and ecologically sensitive.

When waste facilities end up there, it is not because the law is unclear. It is because the CLUP failed to make waste a binding spatial constraint.

Barangay Conflicts Are Symptoms, Not Causes

Recent disputes between barangays and City Hall over waste segregation and collection protocols highlight another consequence of poor integration.

Barangays are asked to enforce “no segregation, no collection” policies—but without:

sufficient MRFs,
zoning support,
land reserved for facilities,
or clear citywide spatial guidance.

This creates friction, confusion, and inconsistent enforcement. It also undermines public trust.

A CLUP that integrates waste properly does not leave barangays to improvise. It provides spatial clarity and institutional backing.

Regional Solutions Require Local Responsibility

Some argue that final disposal should be regional, not city-based. That may be true.

But regional scale does not excuse local planning.

Even if the landfill or waste-to-energy facility is outside Cebu City, the CLUP must still:

prohibit unsafe siting within the city,
reserve land for waste processing and transfer,
link development intensity to waste system capacity,
and protect watersheds and communities from downstream impacts.

Planning ends not at jurisdictional boundaries, but at impact pathways.

The Real Question the CLUP Must Answer

A credible CLUP must be able to answer this simple question:

As Cebu grows denser and more complex, where—and how—will its waste be safely managed?

If that answer is not visible on the zoning map, then the plan is incomplete.

Urban resilience is not built only with roads and buildings. It is built by managing what cities produce—especially what they discard.

Closing Thought

Garbage is not glamorous. It does not attract investors or ribbon cuttings. But it is one of the most honest indicators of whether a city’s planning is grounded in reality.

If waste management is mandatory at the subdivision level, it must be central at the city level.

Because in the end, a land-use plan that cannot account for its waste is not planning for sustainability—it is planning for crisis.

Cebu City’s CLUP as a Regional Economic Instrument:

Why Land Economics Must Anchor Urban Planning

Urban land use planning in Cebu City cannot be treated as a purely local spatial exercise. As the primary economic anchor of Central Visayas (Region VII), Cebu City performs metropolitan and regional functions that extend far beyond its administrative boundaries — economically, socially, and spatially.

Cebu City in the Regional Economic Structure

Central Visayas remains one of the fastest-growing regional economies in the Philippines. In 2024, the region’s gross regional domestic product (GRDP) reached about ₱1.28 trillion, expanding at 7.3 percent — higher than the national average — and maintaining its position as the largest economy in Visayas and Mindanao.

Within this context, Cebu City continues to serve as the regional engine:

In 2024, Cebu City’s economy expanded by about 7 percent, with a total output of roughly ₱334.48 billion, driven by trade, finance, and professional services.
According to recent Provincial Product Accounts, Cebu City accounted for about 22.6 percent of Central Visayas’ regional economy in 2023, second only to the entire Province of Cebu.

Cebu City’s economic footprint is not contained within city boundaries: it affects employment patterns, investment flows, infrastructure utilization, and land markets across multiple provinces and cities in the region.

Zoning as a Regional Economic Decision

Urban economic theory explains that development rights — created and modified by zoning — are capitalized into land values and development incentives.

In Cebu City:

The IT Park–Lahug corridor drives strong agglomeration effects.
The CBD–Port core remains a critical commercial and logistics hub.
The South Road Properties (SRP) influence is reshaping coastal development patterns.
Fringe and upland barangays are facing conversion pressures with implications for peri-urban growth.

These dynamics produce a complex land value gradient that must be recognized and regulated in the CLUP.

Regional Spillover Effects

When land values in Cebu City rise due to zoning changes, the pressure is felt in neighboring LGUs:

Housing demand spills over into Consolacion, Lilo-an, and Talisay.
Commuter flows cross city boundaries, stressing transport corridors.
Agricultural land conversion accelerates in fringe municipalities.

This illustrates that Cebu City’s land use decisions are not isolated. They shape regional patterns of growth and require a planning perspective consistent with broader regional development strategies — including the Central Visayas Regional Development Plan.

Why RLUC and DHSUD Review Cebu City’s CLUP

The institutional review structure reflects this regional reality.

The Regional Land Use Committee (RLUC), operating within the regional planning structure of the Department of Economy, Planning, and Development (DEPDev), conducts technical assessment of CLUPs to ensure consistency with regional spatial strategy and economic coherence.

Meanwhile, the Department of Human Settlements and Urban Development (DHSUD) serves as the national approving authority — guaranteeing alignment with national urban development policy, hazard integration, infrastructure standards, and housing obligations.

This layered review is not bureaucratic duplication. It is recognition that Cebu City’s land use decisions have regional repercussions, and thus must be evaluated not only for local coherence but for their impact across the metropolitan and regional system.

Infrastructure and Fiscal Discipline

Allowing density increases without aligning them with infrastructure capacity produces:

Higher capital expenditure demands
Road and drainage system overload
Greater disaster risk exposure

A responsible CLUP must factor in not just spatial demand but also infrastructure load-testing and projected fiscal impact. Growth may increase revenue — but it may also create unfunded liabilities if infrastructure and risk costs are excluded from the analysis.

Climate Risk as an Economic Variable

Hazard-prone areas — floodplains, landslide slopes, coastal lowlands — are not merely environmental concerns. They are economic risk multipliers that, if developed without restraint, impose long-term costs on public budgets and private livelihoods.

To address this, the CLUP must define:

Net Developable Land =
Gross Land – Hazard Constraints – Easements – Protected Zones

This adjusted baseline must inform density decisions.

Housing Affordability and Land Cost Capitalization

In high-demand corridors of Cebu City, land cost often represents a major portion of overall housing price. If land value increases faster than housing supply expands, zoning changes alone will not yield affordability — they may worsen it.

This underscores the need for inclusionary mechanisms and spatial strategies that place housing close to jobs, infrastructure, and hazard-safe areas.

Cebu City as Metropolitan Steward

The CLUP of Cebu City must operate as:

A regulator of land value winds
A coordinator of infrastructure investments
A climate risk filter
A promoter of equitable housing outcomes
A mediator of regional economic stability

When Cebu City adjusts density and land use rules, the regional economy adjusts with it.

Planning for Value and Region

Cebu City’s CLUP must transcend the narrow framing of zoning colors on paper. It must be anchored in land economics and regional economic logic — because spatial decisions in this city do not stay within its borders. They shape the future of Central Visayas and influence conditions well beyond.

Beyond the City: Carbon Market and Regional Development

When we speak about Carbon Market, the conversation is often framed as a city-level redevelopment issue. But from an economist’s and urban planner’s perspective, that framing is incomplete.

Carbon Market is not just a Cebu City asset.
It is a regional economic node embedded within:

The Cebu City Comprehensive Land Use Plan (CLUP)
The broader Central Visayas food system
Inter-municipal agricultural and fisheries value chains

Understanding this connection is essential. Because what happens in Carbon Market does not stay in Carbon Market.If the Cebu City CLUP provides the spatial framework within the city, regional development provides the functional framework beyond it.

Carbon Market does not operate within the administrative boundaries of Cebu City alone. Its economic reach extends to:

Vegetable-producing upland municipalities
Coastal fishing communities
Neighboring provinces supplying agricultural and marine products
Informal and micro-enterprise processors embedded in peri-urban zones

In regional economic terms, Carbon Market is a growth linkage node. It performs three critical functions:

Market Access for Peripheral Producers

Regional development theory emphasizes that urban centers must provide stable demand anchors for rural economies. Without reliable access to urban markets, smallholder farmers and fishers face:

Price instability
Dependence on trader-lenders
Higher transaction costs
Reduced bargaining power

Carbon Market shortens this chain. It allows producers from outside Cebu City to plug directly into an urban demand center with high turnover and price transparency.

Weakening that node without creating an equivalent alternative risks pushing producers back into fragmented, less competitive arrangements — deepening regional inequality rather than reducing it.

Cost Distribution Across the Region

When a central distribution hub functions efficiently, it:

Reduces duplication of logistics
Concentrates transport routes
Facilitates bulk aggregation
Lowers spoilage rates

Research on vegetable supply chain losses in Central Philippines shows that inefficiencies in aggregation and storage significantly increase losses before produce reaches consumers. Likewise, studies on Cebu’s fish trade highlight how centralized nodes stabilize pricing and reduce uncertainty in time-sensitive transactions.

If Carbon Market’s role as a distribution hub diminishes, costs do not disappear — they are redistributed. Often, they shift:

Upstream to producers (lower farmgate prices)
Downstream to consumers (higher retail prices)
Outward to peripheral municipalities (logistics strain)

Regional development is not simply about growth. It is about where costs and benefits are spatially allocated.

Urban–Rural Integration

The Cebu City CLUP governs land within the city. But urban land-use decisions influence regional integration.

A well-functioning urban core should:

Complement rural production
Support peri-urban logistics
Serve as an accessible convergence point

Carbon Market historically performs this integrative function. It is a bridge — not a barrier — between rural supply and urban consumption.

If the urban core shifts toward higher-value commercial uses without preserving essential economic infrastructure, the result is functional displacement. Wholesale and distribution activities may be pushed outward into areas less prepared to handle them, increasing congestion, transport time, and land-use conflict.

From a regional planning standpoint, that is inefficiency — not progress.

Resilience Beyond Boundaries

The CLUP incorporates resilience planning within city limits. But food systems operate regionally.

During typhoons, port disruptions, or fuel shocks, centralized and accessible aggregation points allow for rapid redistribution and emergency coordination.

Carbon Market enhances:

Supply continuity
Rapid turnover of perishable goods
Network density among traders and suppliers

If that density fragments, regional resilience weakens.

In a climate-vulnerable region like Central Visayas, food-system stability is not optional. It is structural.

The Regional Development Question

Urban redevelopment often focuses on maximizing land value within city boundaries. But regional development asks a broader question:

Does this spatial change strengthen or weaken urban–rural economic integration?

Carbon Market is not simply an asset of Cebu City. It is a component of Central Visayas’ food economy.

Modernization is possible — even necessary. But modernization must:

Preserve small-producer access
Maintain low transaction costs
Strengthen logistics efficiency
Protect affordability for consumers
Align with the CLUP’s structural intent
Support inclusive regional growth

Otherwise, a local land-use adjustment may unintentionally generate regional economic imbalance.

Planning as System Stewardship

Planning is not merely about zoning compliance or real estate optimization.

It is about system stewardship.

Carbon Market sits at the intersection of:

Land-use planning (CLUP)
Inclusive value-chain development
Regional economic integration
Food-system resilience
Spatial equity

Understanding it as regional infrastructure — not merely local property — allows Cebu to evolve without destabilizing the very economic networks that sustain it.

Author’s Note

Agosto is an economist and urban planner, and a practicing real estate professional whose work examines land-use governance, market institutions, and regional economic systems. His analyses engage the Cebu City Comprehensive Land Use Plan (CLUP) in relation to public markets, food-system resilience, and inclusive regional development in Central Visayas.

Carbon Market: More Than a Marketplace — A Critical Node in Regional Food Value Chains

When we talk about Carbon Market, the discussion too often centers on infrastructure — bricks, stalls, modernization, redevelopment. But to understand its true economic role, we have to move beyond the physical structure and look at the value chains that give it meaning. From an economist’s and urban planner’s perspective, Carbon Market is not simply a venue; it is a distribution hub, a transaction institution, and a key node where multiple food supply chains converge.

From Farms and Fisheries to City Plates

Academic research helps explain why this matters.

In the Central Philippines, vegetable supply chains are highly vulnerable to losses. Studies show that up to 30–40% of vegetable produce can be lost before it reaches consumers — losses that occur because of poor transport infrastructure, multiple intermediaries, inadequate cold storage, and fragmented market access. These inefficiencies translate into lost income for farmers and higher prices for consumers. (ResearchGate: “Supply chain losses of vegetables in Central Philippines”)

Separately, research into the fish trade in Cebu City highlights how the flow of seafood from producers to consumers is shaped by a complex web of traders, processors, auction markets, and retail outlets. The study illustrates that fish supply chains are highly relational: small fishers depend on buyers who bring their catch into the city, while consumers depend on urban markets to provide diversity, quality, and affordability. (ResearchGate: “The Dynamics of the Fish Trade in Cebu City”)

These findings are not abstract. They confirm something we see every day: food supply in cities like Cebu depends on efficient, accessible, and well-functioning distribution nodes. Carbon Market is one of the most important of these.

Carbon Market as an Institutional Hub

The UP CIDS study on inclusive agricultural value-chain models makes a central point: markets are not neutral transactional spaces. They are institutions — systems of practices, rules, norms, and networks that shape how producers, intermediaries, and consumers interact. When these institutions function well, they lower transaction costs, reduce uncertainties, and give small producers real access to buyers. When the institutions fail, producers are forced into exploitative arrangements, risk losses, and see declining returns on their labor and investment. (UP CIDS)

This institutional perspective helps us understand Carbon Market not just as a physical place, but as an enabling environment for exchange — a hub where logistics, finance, information, and relationships come together.

Why Changes to Carbon Market Disrupt Food Supply Chains

When the character of Carbon Market changes — whether through redevelopment, commercialization, privatization, or regulatory transformation — the effects are rarely neutral. Instead, they reshape the very value chains that feed the city.

Here’s how the available evidence explains this:

1. Supply Chain Losses Are Real and Costly
Vegetable supply chains in the Central Philippines already experience significant losses before produce ever reaches consumers. Any disruption to a major distribution node like Carbon Market — which serves as a point of aggregation and redistribution — will likely exacerbate these losses unless deliberate efficiency and preservation mechanisms are put in place. (ResearchGate: Vegetable losses study)

2. Fisheries Trade Relies on Complex Networks
Fish traders in Cebu City rely on established channels to bring catch from coastal producers into the urban market. Carbon Market participates in this web of relationships — sanctioning trust, pricing norms, and informal arrangements that help balance risk between fishers, buyers, and sellers. Disrupting these networks without substituting effective alternatives increases uncertainty and costs within the entire system. (ResearchGate: Fish trade dynamics)

3. Institutional Voids Hurt Small Actors
The UP CIDS research underscores that without strong market institutions — whether formal contracts or informal norms — small producers get squeezed by intermediaries who set terms, capture rents, and limit market access. When Carbon Market’s institutional role changes without careful planning, these “institutional voids” can widen, leaving small farmers and fishers worse off. (UP CIDS)

Who Bears the Costs?

The outcomes of institutional disruption are not distributed equally:

Smallholder farmers and fishers lose affordable access to markets and often face higher transaction costs.
Vendors and micro-processors face barriers from rising rents, increased compliance costs, or loss of informal financial arrangements.
Consumers — especially low- and middle-income households — face higher prices and reduced access to fresh produce and fish.

This is not speculative. The weight of evidence from multiple studies — in vegetables, fisheries, and institutional economics — shows that food distribution systems are sensitive. They can be improved, but only if redesign respects existing networks and preserves inclusivity.

What Responsible Planning Looks Like

If the goal is to modernize or upgrade Carbon Market — a goal many stakeholders share — it must be guided by principles that reflect its role in multiple value chains:

Maintain space for small producers. Institutional support — from vendor cooperatives to flexible credit arrangements — must remain part of the market’s design.
Invest in logistics and preservation. Cold storage, loading bays, and organized wholesale operations can help reduce supply chain losses.
Strengthen institutions, not dismantle them. Formal contracts, transparent pricing systems, and data-driven logistics can complement — not replace — the informal norms that give small actors agency.
Protect consumer access. Any redevelopment must safeguard affordability and access for regular marketgoers.

Carbon Market as Food-System Infrastructure

Carbon Market is more than a collection of stalls. It is a critical node in the regional food system — an institution that connects farms and fisheries to city plates, mediates relationships and prices, and anchors the everyday flow of goods.

Decisions about its future must go beyond aesthetics or real estate valuations. They must be grounded in economic reality, allied with evidence from supply-chain research, and centered on inclusion. Only then can Carbon Market evolve in a way that strengthens, rather than weakens, the economic ecosystem it supports.

Carbon Market is food-system infrastructure.
Treating it as mere real estate risks undermining Cebu’s food security, livelihoods, and urban resilience.

Agosto is an economist, urban planner, and a practicing real estate professional. His work examines how markets, land, and urban systems shape everyday livelihoods, with a particular focus on public finance, inclusive development, and the public-interest role of urban infrastructure.

“We Got No Answers”: How a Regulated Landfill Killed 36 People—and No One Could Explain Why

When the Binaliw landfill collapsed on January 8, killing at least 36 people, the tragedy did not end with the recovery of bodies. It deepened when environmental regulators appeared before the Cebu City Council and admitted they had “no answers” on regulatory compliance, monitoring, or enforcement.

In environmental governance, the absence of answers after a mass-casualty disaster is not neutral—it is incriminating. It reveals that the systems meant to protect life and the environment were either ignored, unenforced, or reduced to paperwork long before the collapse occurred.

The Moment Accountability Collapsed

The Cebu City Council hearing was supposed to clarify what went wrong. Councilors asked basic questions any regulator must be able to answer after a disaster of this magnitude:

Was the landfill operating in compliance with its Environmental Compliance Certificate (ECC)?
Were inspections conducted?
Were geotechnical risks evaluated?
Were warning signs detected and acted upon?

The response—by the regulators’ own admission—was that they had no clear answers.

That moment matters more than any press release or leadership change. When agencies tasked with protecting life and the environment cannot explain how a regulated facility failed so catastrophically, the problem is no longer technical. It is institutional failure.

This Was Foreseen—And Documented

Binaliw did not fail in ignorance.

As early as 2015, the JICA Roadmap for Solid Waste Management in Metro Cebu warned against continued reliance on upland landfills, citing slope instability, environmental limits, and disaster risk. It called for reducing pressure on upland sites and transitioning to safer, metropolitan systems—treating upland facilities as temporary, not permanent infrastructure.

Nearly a decade later, Cebu remained dependent on upland disposal—turning a stopgap into a structural risk. What happened followed the very chain JICA warned about:

upland overloading → slope instability → collapse → disaster

In fact, the Mines and Geosciences Bureau Region VII conducted detailed geohazard mapping in 2012, later validated in 2013, which identified multiple sitios in Barangay Binaliw — including Sitio Binaliw 3, Mansawa, and Campo — as highly susceptible to landslides due to steep slopes and unstable geology. MGB geologists not only flagged these risks but also advised communities to avoid the area until it was declared stable. Despite this documented vulnerability, such geotechnical warnings did not translate into meaningful land-use controls, zoning restrictions, or regulatory limits on waste facility siting.

A Pattern of Unanswered Environmental Risks in Central Visayas

Binaliw is not an isolated failure. It is part of a pattern of unresolved environmental risks across Central Visayas, where hazards were known, documented, and repeatedly raised—yet left inadequately addressed.

Across the region, the same warning signs have appeared again and again:

Upland and hillside developments, where cumulative slope modification, altered drainage, and increased runoff proceeded without adequate assessment of combined, long-term impacts;
Recurring flooding, increasingly tied to watershed degradation and land-use decisions that ignored natural drainage and topographic limits;
Liquid waste incidents, most notably the industrial wastewater spill in Bais City that contaminated the protected Tañon Strait, triggered fishing bans, and led to a declaration of calamity—exposing gaps in monitoring, containment, and emergency response;
Persistent community complaints about foul odors, leachate seepage, and water contamination near waste facilities—complaints that accumulated but failed to prompt decisive enforcement.

In each case, the laws existed.

The plans were written.

The risks were identified.

What was missing was not policy—but decisive, transparent implementation, sustained enforcement, and—critically—the ability of institutions to explain their actions when things went wrong.

Binaliw did not expose a lack of knowledge. It exposed a failure to act on knowledge.

Why “No Answers” Is the Real Scandal

The most disturbing aspect of the Council hearing was not disagreement—it was silence.

Regulatory agencies exist to anticipate risk, enforce safeguards, and account for decisions when harm occurs. When they cannot do so after dozens of deaths, public trust collapses—and rightly so.

Leadership changes in the DENR may follow, but they are a response to lost credibility, not its resolution. Accountability does not begin with reshuffling names. It begins with answers.

Engineering Cannot Override Geography

One hard truth emerges from Binaliw:

No engineering solution can fully overcome a fundamentally unsafe upland location.
No permit can substitute for ecological limits.

This is not ideology; it is geotechnics and hydrology. Ignoring CLUP cautions and JICA warnings does not make development safer—it postpones the consequences.