A Welcome Pause — But One That Exposes a Deeper Contradiction

The recent announcement of a moratorium on upland development is, at first glance, a welcome development. It signals an overdue recognition that what happens in the uplands does not remain confined there. Upland activities—slope cutting, land conversion, quarrying, and hillside construction—directly affect runoff, sedimentation, and flood risk downstream. After years of recurring floods, this acknowledgment matters.

But a pause alone is not the same as reform. And taken together with the current planning situation, the moratorium exposes a serious institutional contradiction that cannot be ignored.

At present, the Cebu City Comprehensive Land Use Plan and Zoning Ordinance (CLUP–ZO) 2023–2032 remains pending review and approval by the Department of Human Settlements and Urban Development (DHSUD). This is important. A CLUP is supposed to be the city’s definitive spatial framework—one that integrates land use, environmental constraints, hazard data, and long-term development direction.

Declaring a moratorium while allowing the CLUP to continue through the approval process sends mixed signals. On one hand, the City is saying that upland development policies, zoning ordinances, and risk assessments require comprehensive review. On the other, it is permitting a plan—prepared under those same assumptions—to move forward as if those concerns did not exist.

These two positions are institutionally inconsistent.

A moratorium is not merely a pause in permitting; it is an implicit admission that something in the existing planning framework is flawed or incomplete. Allowing the CLUP–ZO to proceed while simultaneously questioning its foundations risks locking in the very policies now being reconsidered. If the review is serious, the planning document built on those policies cannot be treated as settled.

More importantly, the value of the moratorium will depend entirely on what happens during the pause.

A meaningful review must go beyond surface-level policy checks or inventorying existing regulations. It must confront the structural causes of flooding, which did not arise overnight. This includes revisiting historical zoning amendments enacted without adequate technical studies, particularly those that incrementally intensified upland development. It also requires a cumulative assessment of upland impacts on downstream flooding, rather than treating each project or permit as an isolated case.

For decades, zoning decisions were often made in fragments—project by project, amendment by amendment—without basin-wide hydrological analysis or long-term carrying capacity studies. The downstream consequences of those decisions are now visible in flood-prone communities. Any review that fails to reckon with this history risks becoming procedural rather than corrective.

Finally, all findings from the moratorium review must be anchored to an EO 72–compliant Comprehensive Land Use Plan. Executive Order No. 72 was designed precisely to prevent piecemeal land-use decisions by requiring that zoning be subordinate to a comprehensive, technically grounded plan. Flood risk, hazard exposure, and environmental limits must be integrated at the CLUP level—not appended as afterthoughts.

If the moratorium results in a genuine reassessment of upland policies, a review of past zoning decisions, and meaningful revisions to the CLUP before it is resubmitted for approval, then the pause will have served its purpose.

If not, the moratorium risks becoming a symbolic gesture—a temporary halt that leaves the underlying planning framework unchanged, while flood risks continue to accumulate downstream.

A pause is welcome.
But integrity in planning demands consistency, accountability, and correction—not just restraint.

A Brief Context: Years of Zoning Without a Comprehensive Plan

To understand why the moratorium has become necessary, it helps to revisit how Cebu’s land-use rules evolved.

For much of the past three decades, zoning ordinances and amendments moved ahead in the absence of a fully EO 72–compliant Comprehensive Land Use Plan (CLUP). Instead of zoning being the implementing tool of a comprehensive plan, the process was effectively reversed: zoning became the primary mechanism through which land-use decisions were made.

Beginning with the 1996 Zoning Ordinance, and continuing through numerous subsequent amendments, land-use classifications were adjusted incrementally—often in response to specific proposals, developments, or economic pressures. These amendments were typically stand-alone actions, not products of basin-wide hydrological studies, cumulative flood modeling, or carrying-capacity analysis.

Over time, this resulted in:

Incremental intensification of upland and slope areas, approved project by project;
Fragmented land-use decisions, evaluated individually rather than cumulatively;
Absence of technical backup studies linking upland approvals to downstream flood risk.

Each amendment, taken alone, may have appeared manageable. But collectively, they reshaped watersheds, increased surface runoff, and weakened natural flood-regulating functions—without those impacts ever being fully measured or accounted for.

The flood overlay zones now reflected in the CLUP 2023–2032 are, in many ways, a delayed recognition of this history. They acknowledge risks that accumulated gradually through years of zoning decisions made without a unifying, science-based framework.

Seen against this backdrop, the current moratorium is not a sudden shift in policy. It is a corrective response to a long period of planning through amendments rather than through a comprehensive, EO 72–compliant CLUP.

Bringing PENCAS to Cebu: A Legal Challenge to the City’s New Land Use Plan

Environmental planner and economist Gus Agosto has taken a significant step in Cebu City’s ongoing land‑use debates by filing a formal notice and reservation of objection with the Department of Human Settlements and Urban Development (DHSUD). The notice focuses on the review of the Cebu City Comprehensive Land Use Plan (CLUP) 2023–2032 and raises an issue that has been largely absent from local public discussion: compliance with the Philippine Ecosystem and Natural Capital Accounting System (PENCAS) Act, or Republic Act No. 11995, and its Implementing Rules and Regulations.

At the heart of the filing is a simple but powerful question: can Cebu City still afford to plan growth as if its ecosystems, watersheds, and floodplains are external to the economy? For Agosto, the clear answer is no. RA 11995 declares that “natural capital” – including land, ecosystems, and the services they provide – is a measurable economic asset of the State and its political subdivisions. This is not a mere policy preference. Under PENCAS, natural capital accounting must be integrated into planning and decision‑making, particularly where long‑term land use, infrastructure, and public‑private partnerships are involved. In practice, this means a CLUP can no longer be just a map of zones and a bundle of sectoral plans; it must demonstrate how land‑use allocations respect ecological thresholds, risk patterns, and the economic value of environmental services.

The Cebu City CLUP 2023–2032, as currently framed, does many things right on paper. It outlines sectoral strategies for housing, commerce, industry, transport, and water supply. It references hazard maps and acknowledges flooding and slope risks. But, as Agosto points out, these elements remain largely compartmentalized. The plan stops short of weaving them into a cohesive, risk‑sensitive spatial strategy that clearly shows how development is constrained by carrying capacity, hazard exposure, and environmental limits. The result is a document that appears procedurally complete—boxes ticked, chapters present—but substantively misaligned with the integrated, law‑driven planning model now required under Executive Order No. 72, DHSUD’s own guidelines, and PENCAS.

This critique matters because Cebu City is not planning on a blank slate. It is a dense, highly constrained urban area, bounded by steep uplands and a vulnerable coastline, with a well‑documented history of flooding, traffic bottlenecks, and informal settlements on marginal land. In such a context, “sectoral” planning without genuine spatial integration is not a minor technical flaw; it can translate into very real, very costly risks for communities. If new commercial or residential intensities are allowed in upland or mid‑slope areas without full accounting of downstream flood impacts, the city effectively subsidizes risk—transferring the costs to low‑lying barangays that will experience deeper and more frequent inundation.

PENCAS adds another layer. By requiring natural capital accounting, RA 11995 insists that decisions about where to build, what to conserve, and how to structure public‑private partnerships must be informed by quantified assessments of ecosystem services and environmental limits. Watersheds, coastal zones, and floodplains do not merely host development; they regulate water flows, buffer storms, and sustain fisheries and livelihoods. When these are degraded or overbuilt, the “loss” is not just aesthetic or ecological—it is economic, measurable in damage to infrastructure, loss of productive days, and increased public spending on disaster response. Natural capital accounting is a way of making these hidden costs visible before, not after, decisions are taken.

Agosto’s filing is also a reminder of DHSUD’s central role in ensuring that local planning complies with national law. Executive Order No. 72 designates the CLUP as the primary basis for zoning, infrastructure provision, and land development decisions, and gives national agencies like DHSUD the responsibility to review local plans for conformity with national standards. With PENCAS already in effect, DHSUD is now expected not only to check format and basic legal compliance, but to ask whether plans show evidence of natural capital accounting: have ecosystems been valued, thresholds identified, and risks internalized into zoning and land‑use regulations? Approving a CLUP that treats PENCAS as optional would weaken the law at precisely the moment it is meant to change planning practice on the ground.

Crucially, the notice is not framed as an attempt to stop development or to delegitimize Cebu City’s efforts to adopt a long‑term land‑use plan. Instead, it positions itself as a rights‑based and policy‑grounded reminder to strengthen the CLUP. Agosto emphasizes that the objective is to align Cebu’s growth strategy with three converging realities: the legal obligations under RA 11995 and EO 72, the ecological constraints of a flood‑ and hazard‑prone city, and the long‑term public welfare of residents who will live with the consequences of today’s zoning maps and infrastructure decisions. In other words, the call is not “no development,” but “no development that pretends nature and risk do not count.”

For local stakeholders, planners, and advocates, this intervention offers a preview of what the PENCAS era will look like in practice. Formal plans, joint ventures, and big‑ticket infrastructure will increasingly be assessed not only on their financial terms and engineering feasibility, but also on whether they recognize natural capital as part of the economic equation. Cebu City’s CLUP review is an early and important test case. Whether DHSUD chooses to treat Agosto’s filing as a technical annoyance or as an opportunity to put PENCAS into meaningful operation will say much about the future of urban planning and environmental governance in the Philippines.

Environmental Rights Are Human Rights: Why Cebu Must Defend Its Constitutional Right to a Balanced and Healthful Ecology

HUMAN RIGHTS DAY MESSAGE

Today, the world commemorates International Human Rights Day, marking the anniversary of the Universal Declaration of Human Rights.

But in Cebu, this day carries a deeper, more urgent meaning. In our island—where critical watersheds are shrinking, fragile slopes are carved for profit, rivers are choked with silt, and communities drown in entirely preventable floods—one fundamental human right is under unprecedented threat:

The Right to a Balanced and Healthful Ecology.

This is not a political slogan or an aspirational ideal. It is a constitutional mandate, enshrined in Article II, Section 16 of the 1987 Philippine Constitution:

“The State shall protect and advance the right of the people to a balanced and healthful ecology in accord with the rhythm and harmony of nature.”

This right is further affirmed by the Supreme Court in the landmark case of Oposa v. Factoran (1993), which established that environmental rights are intergenerational, enforceable in court, and impose a mandatory duty on all government officials to protect the environment for present and future generations.

I. Environmental Neglect is a Human Rights Violation

Human Rights are not solely civil and political; they are inextricably environmental, social, and economic.

Cebuanos cannot fully enjoy their right to life, security, livelihood, or safe housing if their communities are systematically placed in harm’s way by governance failures, including:

Scientifically unsound land-use decisions.
Approval of upland developments in known hazard-prone areas.
Zoning ordinances that ignore hydrological and watershed limits.
Failure to integrate mandatory hazard maps and natural capital accounting.
Non-compliance with national laws such as RA 11995 (PENCAS) and RA 11038 (E-NIPAS).

When a city tolerates policies that exacerbate climate risks and disaster intensity, the resulting flooding and landslides cease to be “natural disasters.” They become human rights violations caused by official negligence, abuse of authority, and systemic disregard for public safety.

The government, by transferring disaster risk from developers and decision-makers onto the most vulnerable communities, violates the people’s constitutional right to: Health, Security, Safety, Due Process, Life, and Environmental Equity.

II. The Human Cost of Environmental Injustice in Cebu

Recent disasters, such as the flash floods caused by Typhoon Tino and similar weather events, tragically revealed the truth Cebuanos have felt for years: Catastrophic flooding is not inevitable. It is the direct consequence of human decisions—of upland reclassification, politically influenced zoning, weak enforcement, and the dangerous disregard for the island’s carrying capacity.

In areas like Bacayan, Mananga, Compostela, and Subangdaku, lives have been lost, homes destroyed, and families displaced. These are not isolated tragedies. They are symptoms of a profound governance failure, violating both the tenets of environmental protection and the principles of social justice.

III. Accountability Mandated by Law: The PENCAS Defect

The law requires more from our leaders, particularly following the enactment of the Philippine Ecosystem and Natural Capital Accounting System Act (RA 11995).

PENCAS, effective in May 2024, made it mandatory for all government units to:

Integrate natural capital valuation in all planning.
Consider ecological thresholds before approving developments.
Quantify environmental losses and risks to protect critical ecosystems.

However, the recently approved Cebu City CLUP and Zoning Ordinance 2025—passed after PENCAS took effect—demonstrates an alarming failure to integrate these mandatory principles.

This is not only a profound legal defect but, more importantly, a human rights crisis. When planning willfully ignores ecological science and mandatory laws, the people ultimately pay the price with their lives, homes, and livelihoods.

IV. Environmental Justice is Human Rights Justice

The Constitution demands “harmony with nature.” Conversely, our current planning trajectory is in direct conflict with nature.

Scientific data consistently shows that the uplands contribute 55–60% of Cebu’s floodwater runoff. Yet, land-use decisions continue to open these crucial slopes and midlands to:

Excessive reclassification and rezoning.
Expansive subdivisions and commercial sprawl.
Aggressive road cuts and quarrying.

This pattern is not development; it is risk accumulation. Every time a watershed is weakened, a slope is destabilized, or a flood basin is paved over, we fundamentally undermine the people’s rights to safety and a sustainable future.

Environmental Justice demands that:

Those who benefit from development must not be allowed to inflict harm on those downstream.
Government decisions must be based on science and must not endanger the public they swore to protect.
Vulnerable communities must not be sacrificed for private gain and political expediency.

V. A Call for Action and Accountability

On this International Human Rights Day, we stand together to assert that:

Flood safety is a Human Right.
Compliance with environmental law (RA 11995) is a mandatory duty.
Hazard-informed planning is a legal requirement.
No zoning ordinance should contradict science, and no public official has the authority to gamble with ecological security.

We assert our right to demand accountability, transparency, correction of defective plans, and the unwavering protection of our uplands and watersheds.

We look forward to A Cebu That Honors Human Rights: a city built on the right to safe communities, flood resilience, and ecological integrity.

Environmental Rights ARE Human Rights. Justice for Cebu.

CLUP/ZO SERIES – PART 1

Why Cebu City’s Housing Plan Cannot Work: A Critical Look at the CLUP’s Most Serious Weakness

This article begins my multi-part series on Cebu City’s new Comprehensive Land Use Plan (CLUP) and Zoning Ordinance (ZO).
Over the next few weeks, we will look closely at what this plan gets right, what it gets wrong, and how its flaws shape Cebu’s future — for better or for worse.

We begin with the sector that affects all others: HOUSING.

Because where people live determines how they move, how they work, how communities grow, and ultimately whether a city becomes livable — or collapses under its own weight.

And right now, Cebu City’s housing plan is on the wrong path.

The Huge Gap Between Housing Needs and Housing Reality

The City estimates that 865,725 housing units are needed to address the backlog and future demand.
To accommodate that number, the CLUP calculates that Cebu City would need 15,169 hectares of additional residential land.

But here is the problem:

Cebu City does not have 15,169 hectares of buildable land.

It doesn’t even come close.

Cebu is not a flat province like Cavite or Laguna.
It is a mountain city with narrow slopes, rivers, steep terrain, coastal hazards, and protected watersheds.

Only about 25–30% of Cebu’s total land is actually suitable for safe residential development.

In other words:

The very formula used to compute Cebu’s housing demand does not fit Cebu’s geography.

It’s like measuring a mountain with a ruler designed for plains.

And because the method is wrong, the strategies that follow also fall apart.

So Where Will Cebu Build? The CLUP’s Answer: SRP

Because Cebu lacks large, flat, safe tracts of land, the CLUP turns almost entirely to the South Road Properties (SRP) — a reclaimed area exposed to storm surge, subsidence, and liquefaction — as the primary relocation site for the urban poor.

The City actually owns 313 hectares of land across 211 parcels.
But a massive 240 hectares (76%) of this land is in SRP.

This explains the CLUP’s insistence on building:

Temporary housing in SRP
Permanent high-rise housing in SRP
Social housing clusters in SRP

SRP is the easiest to access politically.
But it is also one of the most dangerous places to house the poor.

Relocating families from riverbanks and hazard zones only to place them in a coastal hazard zone is not progress — it is risk transfer.

It moves people out of danger… and into another kind of danger.

The “Permanent Housing” Plan Is Even Harder to Believe

The CLUP describes an ambitious “South Coastal Urban Development” (SCUD) project:

5-storey, 10-storey, and 20-storey MRBs
Long-term leases “like Singapore”
Thousands of families relocated to high-density towers

But the proposed site is still underwater.
The land does not exist yet — it must be reclaimed first.

Even if the concept is good, the location and timing are not.

It will take years before the land is ready.
And billions upon billions before the buildings rise.

Which brings us to another uncomfortable truth.

The CLUP Claims ₱26 Billion Per Year for Housing — Cebu’s Budget Is Only ₱13 Billion

The CLUP states that the City is allocating ₱26 billion annually for MRB construction.

But Cebu City’s entire 2026 budget is only ₱13 billion.

Meaning:

The housing plan requires twice the city’s entire budget
No one knows where the money will come from
No financing model, PPP structure, or national commitment is presented

It is a beautiful idea with no financial backbone.

Housing towers may be drawn on paper,
but they cannot be built with numbers that do not exist.

So Why Not Use the City’s Other Land?

Outside SRP, the City owns:

66.37 hectares

Used for schools, barangay halls, and urban poor housing.

These areas could be transformed into strategic mid-rise communities connected to jobs and transport.
But the CLUP does not propose land consolidation, urban regeneration, or vertical redevelopment.

6.79 hectares

Remain idle — mostly upland, steep, or constrained.

These lands are unsuitable for housing and should remain ecological buffers.

The Housing Plan Is Isolated — Not Integrated With Transport, Jobs, Commerce, or Water

Housing is not a standalone sector.
It must align with:

transportation systems
BRT corridors
commercial centers
industrial zones
water supply
hazard maps
drainage systems

But Cebu’s housing plan exists in a silo.

It does not place housing near jobs.

It does not place housing near BRT stations.

It does not expand residential areas near commercial centers.

It does not address water scarcity for 865,000 new units.

It does not protect uplands from overdevelopment.

It does not calculate relocation impacts on transport or flooding.

It treats housing as if it floats above the city, unaffected by everything else.

That is not how cities work.

What We Are Left With Is a Housing Plan That Cannot Succeed

❌ The method is wrong for Cebu’s geography

❌ The land available does not match the land required

❌ The largest landholding (SRP) is hazard-prone

❌ The permanent housing site is underwater

❌ The budget is twice the city’s capability

❌ The plan does not integrate with transport, jobs, or water

❌ The uplands cannot support more sprawl

❌ The poor are relocated to isolation

This is not simply an imperfect plan.
It is a plan built on structural contradictions.

Cebu needs a housing strategy grounded in:

vertical development
transit-oriented planning
safe, accessible locations
integrated public land redevelopment
financial realism
environmental science
climate resilience

The CLUP does not offer that.

Not yet.

What Comes Next in This Series

In the next articles, we’ll dive into:

Part 2 — Transport & Mobility: Where the CLUP Went Wrong

Why the BRT is disconnected from land use, and how transport planning became an afterthought.

Part 3 — Commercial & Industrial Zones: Misalignment and Missed Opportunities

A look at the political economy of zoning.

Part 4 — Environment, Flooding & Watersheds: The Consequences of Poor Planning

How upland mismanagement worsens lowland floods.

Part 5 — Governance, Variances & Loopholes: How the Zoning Board Can Override Everything

The silent powers shaping Cebu’s future.

This is the beginning of a deeper conversation —
one Cebu desperately needs.

Why Cebu’s CLUP Must Be Reviewed Now:

The Law Has Changed — Our Planning Must Change With It

Urban planning is not just about drawing maps or assigning colors to land. It is about shaping how people live, how cities grow, and how communities stay safe. In a time when flooding has reached catastrophic levels in Cebu, we can no longer pretend that our current land-use system is enough.

The truth is simple: Cebu City’s Comprehensive Land Use Plan (CLUP) is outdated. It no longer reflects the new legal, scientific, and ecological standards that planners are now required to follow. And unless the CLUP is reviewed and corrected, the city will continue to make decisions that worsen flooding, landslides, and environmental collapse.

1. PENCAS Changed the Entire Landscape of Land-Use Planning

The Philippine Ecosystem and Natural Capital Accounting System (PENCAS) Act introduced a revolutionary requirement:
Government must account for the value of ecosystems, watershed functions, water recharge, soil stability, and the economic value of nature itself.

PENCAS was signed into law on May 22, 2024 as Republic Act 11995. Meanwhile, the Comprehensive Zoning Ordinance on June 30,2025.

Before PENCAS, CLUPs mainly focused on land use—where houses, commercial buildings, roads, or industries should go. After PENCAS, that is no longer enough.

A compliant CLUP must now quantify:

How much forest, river, or watershed capacity is being lost
How upland developments reduce water absorption
How much “natural capital” is being depleted when slopes are cut
How these losses translate into economic damage (flooding, disasters, carbon loss, siltation)

Cebu’s current CLUP does not do this. It is operating on an old framework while the law has moved forward.

2. ECCs for Upland Developments Also Fall Short

Environmental Compliance Certificates (ECCs) for subdivisions, commercial estates, and roads in the uplands were issued using pre-PENCAS standards.

Most Environmental Impact Statements focused on:

earthworks
drainage structures
erosion controls
But almost none assessed watershed function, downstream flood risk, cumulative basin impact, or natural capital loss—which PENCAS now requires.

This is why upland developments continue to be approved even if they sit on steep slopes, natural drainage paths, and fragile geological formations.

3. This Is Not Optional Knowledge — Planners Must Know This by Heart

Environmental planners, geologists, engineers, and city officials are now expected to integrate natural capital accounting into every zoning decision. That includes:

development suitability analysis
watershed carrying capacity
runoff modeling
ridge-to-reef planning
accounting for carbon sinks and biodiversity

If planners continue operating with outdated tools, they are making decisions that violate the very law they swore to uphold.

4. A Non-Compliant CLUP Is a Legal Liability

A CLUP that does not integrate PENCAS can be questioned for:

grave abuse of discretion
failure to perform ministerial duties under the Local Government Code and PENCAS
violating the constitutional right to a balanced and healthful ecology

Cebu City cannot afford to implement a plan that is legally vulnerable and scientifically obsolete—especially when thousands of lives and billions in property are at stake.

5. The Consequences Are Measurable: More Flooding, More Damage

Flooding in Cebu is not simply caused by rain.
It is the product of upland disruption:

excessive cut-and-fill
blocked natural waterways
subdivisions and roads acting as mini-dams
forest cover loss
soil compaction
reduced infiltration

When a CLUP does not account for these, the result is predictable: water that should have been absorbed in the uplands rushes violently into lowland communities.

The disaster we saw during Typhoon Tino is not an accident.
It is the output of planning failures.

6. Reviewing the CLUP Is Not Political — It Is a Legal, Scientific, and Moral Responsibility

A CLUP cannot remain static in a time of climate crisis. It must evolve with:

new hazard data
new scientific findings
new national laws
new development pressures
new experiences of disaster

If the city refuses to review its CLUP now, it is refusing to learn, refusing to adapt, and refusing to protect its people.

Final Word: Cebu Deserves a CLUP That Protects, Not Endangers

Cebu does not lack intelligence, science, or expertise. It lacks alignment.
The CLUP must be updated.
ECC processes must be reformed.
Planners must operate using modern standards.
And citizens must demand a planning system that finally honors the value of our uplands, our watersheds, and our right to safety.

A CLUP review is not just a technical exercise.
It is a step toward a safer Cebu, a smarter Cebu, and a Cebu that finally plans with the future—not the past—in mind.

Why Cebu Must Value Both Use and Non-Use Benefits of Its Uplands

Public discussions on Cebu’s upland resources often rely on a narrow and misleading definition of “economic value.” For years, local discourse has focused on equating economic worth with the revenues earned from quarrying and extraction. This creates the persistent and dangerous misnomer that natural wealth is measured solely by use value.

This belief is repeated in public forums, policy pronouncements, and fiscal reports. It suggests that whatever Cebu can extract, haul, crush, or sell represents the true economic contribution of its uplands. In reality, economics does not define wealth this way. Modern environmental economics evaluates natural systems differently. True economic valuation includes use values. It also includes non-use values. Ignoring non-use values results in incomplete analysis. This leads to flawed public policy. It causes environmental decline. It exacerbates climate vulnerability.

Before addressing this conceptual flaw, the scale of Cebu’s mineral economy must be clearly understood. The province is not operating a ₱600-million quarrying industry, as public officials often portray. It is operating a ₱20-billion extraction economy per year. When metallic and non-metallic activities are combined, the actual size of Cebu’s mineral economy becomes undeniable: ₱20.18 billion in 2024, ₱21.53 billion in 2023, and ₱19.32 billion in 2022. This is the real magnitude of extraction occurring in the uplands—far larger than what provincial income statements suggest.

Cebu’s quarry operators, processors, haulers, and construction supply chains transact between ₱7.5–₱12.5 billion annually in non-metallic sales alone, while metallic operations consistently exceed ₱18 billion per year. By contrast, government revenue—₱628 million in 2023—represents only 2–4% of Cebu’s total mineral economy. Thus, a massive private extraction economy generates billions in sales and profit. Meanwhile, public income is thin. It is too small to offset the environmental and social costs borne by the public.

This fixation on quarry revenue—and even the broader ₱20-billion extraction economy—reveals the deeper misconception underpinning current policies. It is the assumption that the value of natural resources lies primarily in what can be extracted from them.

This is not how economics works. Modern environmental economics, natural resource theory, and the Total Economic Value (TEV) framework all provide important lessons. They teach that real economic worth consists of use values and non-use values. Use values include quarrying, water extraction, timber, and agriculture. Recreation and tourism are also included. These activities are easily monetized and prominently appear in financial statements. Yet these represent only a fraction of total wealth.

Non-use values, although invisible in budgets and COA reports, are economically real. They represent the benefit of simply knowing that forests and watersheds exist (existence value). They also include the value of leaving ecosystems intact for future generations (bequest value). Non-use values cover the value of keeping nature available for future or unknown uses (option value). They encompass the value derived from knowing that other communities benefit from intact uplands (altruistic value). These are precisely the values Cebu loses. This happens the moment a mountain is cut, a slope is excavated, or a watershed is bulldozed.

The consequences of ignoring non-use values are visible today in the worsening flooding across Metro Cebu. Cebu’s intense focus on use values and extraction leads to destruction. This destruction affects the non-use values that sustain long-term stability. When uplands are stripped, infiltration declines; runoff accelerates; sedimentation increases; river capacity shrinks; and flood peaks intensify. This is why Metro Cebu now floods even without typhoons and why ordinary rainfall brings cities to a halt. Every ton of aggregates removed from Cebu’s uplands reduces the natural economy. This reduction affects flood mitigation, slope stability, groundwater recharge, biodiversity, and climate regulation.

In short, this is the heart of Cebu’s political economy of flooding:

A ₱20-billion extraction economy drives upland degradation.
A ₱600-million public revenue creates the illusion of fiscal benefit.
A multi-billion-peso ecological loss is imposed on the public.
A non-functioning natural protection system results in chronic flooding.

Short-term extraction is displacing long-term security.

These losses constitute ecological depreciation—the downward adjustment of natural capital from human activity. Government does not record this depreciation. However, households and businesses pay for it. They endure flooded homes. Business districts are paralyzed, and infrastructure is damaged. Transportation is disrupted. There are lost workdays, medical incidents, and increased LGU emergency spending. Against these losses, quarry revenues are negligible.

The core economic argument is simple: Cebu is counting the small gains and ignoring the massive losses. The province records quarry taxes, permit fees, operator sales, and extraction-based employment. However, it does not account for the loss of watershed integrity, slope stability, and infiltration capacity. It also overlooks groundwater reserves, biodiversity, and climate resilience. Social cohesion, cultural heritage, and intergenerational equity are ignored too. This is not just incomplete economics—it is incorrect economics. One cannot claim economic benefit from quarrying while ignoring the far greater economic harm caused by upland degradation. A ₱20-billion extraction economy is running alongside a collapsing natural economy. The outcome is predictable. The province gains short-term financial flows but accumulates long-term environmental debt.

This dynamic lies at the heart of Cebu’s political economy of flooding. A ₱20-billion extraction economy continues to drive upland degradation. A ₱600-million public revenue stream creates the illusion of fiscal benefit. A multi-billion-peso ecological loss is imposed on the public. And a weakened, fragmented natural protection system results in chronic flooding across urban and peri-urban areas. Short-term extraction has displaced long-term security, and the costs are borne disproportionately by downstream communities—not the operators who profit upstream.

Moving forward, Cebu can no longer afford a development model that counts quarry revenue but ignores watershed collapse. The province must make rational, future-oriented decisions. To do so, it must abandon the misnomer that use value alone defines economic wealth. The real economy of Cebu’s uplands includes their role as natural flood buffers. These uplands function as water towers and contribute to climate regulation. They have cultural and identity significance. Their value is also crucial to future generations. Cebu cannot call itself progressive if it treats natural capital as expendable. It cannot claim resilience if it undermines the uplands that protect the lowlands.

Economics is not about extraction. It is the total value—use and non-use, present and future, private gain and public cost. Until Cebu adopts this full accounting, it will continue to profit in pesos. However, it will lose wealth in floods, landslides, and ecological decline.

Why I Wrote to the Senate: Strengthening ECC Governance and Enforcing RA 10587

The recent events surrounding the Monterrazas de Cebu development—and the Senate investigation that followed—have brought national attention. These events have highlighted long-standing weaknesses in our environmental regulatory system. The incident goes beyond the tragic flooding and slope failures. It exposes deeper structural issues in the way Environmental Compliance Certificates (ECCs) are evaluated and approved. This is especially concerning in areas that the law classifies as Environmentally Critical Areas (ECAs).

I work as an Environmental Planner, Real Estate Consultant, and researcher. My fields intersect law, economics, and natural capital. I felt compelled to articulate these systemic concerns. I did this through a formal letter addressed to Senator Risa Hontiveros and the members of the Senate.

My letter emphasizes three core points:

First, Proclamation No. 2146 and Presidential Decree No. 1586 clearly designate steep slopes, geohazard zones, and watershed recharge areas as Environmentally Critical Areas. These areas require the highest level of scientific scrutiny. This must happen before any development is allowed. Despite this, ECCs continue to be issued in areas of high ecological and hazard sensitivity.

Second, the Environmental Planning Act of 2013 (RA 10587) contains mandates. It requires that licensed Environmental Planners prepare and sign environmental planning work. This work includes EIAs, hazard studies, hydrologic analyses, and land-use planning. In the case of Monterrazas, this requirement was not met. Non-enforcement of this law compromises the scientific integrity of ECC submissions.

Third, the Monterrazas incident is not an isolated oversight but a symptom of a broader institutional problem. ECCs are too often granted despite incomplete or inadequate assessments. Clear statutory obligations are in place to safeguard communities and ecological systems, yet they are ignored.

My letter respectfully calls on the Senate to strengthen environmental governance. This can be done by ensuring that legal requirements, particularly RA 10587, are fully enforced. ECCs issued in Environmentally Critical Areas should be thoroughly reviewed. Additionally, DENR’s evaluation systems need strengthening and increased transparency.

This moment provides a crucial opportunity to elevate environmental planning. It also helps restore public confidence in regulatory mechanisms. Additionally, it offers better protection for vulnerable landscapes and communities. I hope this contribution is useful to the Senate’s ongoing inquiry. It is also meant to aid our collective effort to build a more climate-resilient and accountable governance system.

The Political Economy of Flooding in Cebu

Every flood follows the laws of physics—but the damage it brings follows the laws of politics and economics. To understand Cebu’s recurring floods, we must examine not just rivers and drains, but land markets, incentives, and power structures.

A civic group recently released a petition calling for accountability. They demand institutional reforms and immediate interventions after the November 4, 2025 flooding. There is a deeper structural truth behind these recurrent failures—one that cannot be resolved through flood-control works alone. Flooding in Cebu is not simply a hydraulic engineering problem. It is a political economy problem. It is shaped by land markets and governance incentives. It also involves institutional weaknesses and the complex interactions between urban development and ecological systems.

The physical manifestations of Cebu’s flooding are evident. They include overflowing rivers, silted channels, blocked waterways, undersized drainage lines, and deteriorated uplands. These issues are symptoms of underlying drivers embedded in the way land is valued, used, occupied, and regulated. These systemic forces determine where people settle and where capital flows. They dictate how infrastructure is prioritized. They also influence which environmental limits are observed or ignored. Understanding the city’s flood crisis requires a new perspective. We must shift from short-term engineering responses. We should focus on a long-term examination of Cebu’s land governance and socio-economic structures.

The Limits of Engineering-Centered Solutions

For decades, Cebu’s response to flooding has relied on traditional engineering. This includes the expansion of drainage networks. It also involves the construction of embankments and the deepening of rivers. Additionally, there is the installation of floodwalls and diversion channels. These are necessary interventions and form part of any modern urban infrastructure system.

However, the severe flooding of November 4 demonstrated an important fact. Structural measures cannot compensate for degraded watersheds. They cannot make up for constricted waterways either. Additionally, land-use choices that contradict hydrological realities are not offset by these measures.

The core limitations are clear:

Upstream forests have thinned, reducing water absorption.
Urban surfaces have become more impermeable, rapidly increasing runoff.
Natural retention areas have been converted into residential and commercial zones.
Rivers have narrowed due to settlements, obstructions, and encroachments.
Drainage systems designed for past rainfall patterns are now overwhelmed by climate-intensified storms.

Engineering solutions, however well-designed, cannot fully absorb the consequences of decades of unsustainable land use and misaligned development patterns.

Land Market Pressures and Development in High-Risk Areas

Cebu’s flooding problem cannot be separated from the economics of land. As urban land becomes increasingly scarce and valuable, development pressures intensify toward hazard-prone areas:

river easements and riparian buffers,
wetlands and marshes,
floodplains and low-lying coastal areas,
steep upland slopes and watershed zones.

These areas historically served as natural drainage or water retention systems. Yet economic incentives—combined with regulatory concessions—have enabled their transformation into buildable parcels.

This trend reflects a market-driven logic: when prime land is limited, the pressure to develop environmentally sensitive areas becomes stronger. The result is a spatial configuration that maximizes short-term economic gains but increases long-term exposure to floods.

Thus, flooding is not merely caused by extreme rainfall. It is shaped by land scarcity and speculative development. Permissive regulatory environments also play a role in its formation. It is shaped by the interaction between land scarcity, speculative development, and permissive regulatory environments.

Political Incentives Favor Visible Infrastructure Over Preventive Governance

Flood-control infrastructures are politically compelling projects. They offer:

highly visible outputs,
significant budgets,
recurring maintenance contracts,
and narratives of action and responsiveness.

Because they are technically complex, such projects often escape broader public scrutiny. At the same time, some measures reduce long-term flood risk most effectively. These include watershed rehabilitation, strict easement enforcement, and climate-informed zoning. However, they are politically challenging. They require displacements, long-term planning consistency, and actions that may produce limited immediate political returns.

This imbalance in incentives explains why Cebu sees many flood-control structures. These structures do not always address the underlying drivers of vulnerability. Sometimes, they even worsen the situation.

Flooding persists not simply because engineering solutions are inadequate. It also occurs because political incentives prioritize short-term, highly visible outputs. These outputs are prioritized over structural preventive governance.

The issue is not a lack of technical knowledge among agencies. The problem continues because actions conflict with the interests of those who hold political and economic power.

This is the essence of the political economy argument.

River Degradation and Extractive Activities

Siltation, riverbed changes, and sediment buildup are major contributors to flood severity. These issues are exacerbated by:

sand and gravel extraction,
upland clearing for agriculture or development,
informal excavation,
and poor adherence to environmental safeguards.

These activities are sustained because they are economically profitable and often backed by political or economic influence. Despite their known impacts, they persist due to entrenched interests along the value chain—from local employment to construction demand.

Thus, river degradation is not merely a technical or enforcement issue. It is a governance challenge linked to resource extraction, revenue dependence, and regulatory gaps.

Enforcement Challenges Reflect Institutional Capture and Regulatory Asymmetry

Calls for strict enforcement frequently assume that institutions lack capacity or technical competence. In reality, enforcement failures are often tied to:

local political alliances,
informal settlements that represent vote-rich constituencies,
economic actors with significant influence over land use decisions,
fragmented authority across agencies,
inconsistent application of zoning and environmental rules.

Hazard-prone areas become zones of negotiation rather than regulation. This institutional dynamic contributes to weak compliance, reinforcing land-use patterns that increase flood exposure.

Flooding, therefore, arises not only from natural or physical factors but also from institutional capture and uneven regulatory power.

From Flood Control to Flood Governance

The arguments focusing on removing obstructions, correcting flawed structures, or improving inter-agency coordination are important. Yet they must be integrated into a broader, structural framework of flood governance, one that recognizes the interconnectedness of:

land markets,
watershed systems,
ecological integrity,
urban density,
climate projections,
institutional frameworks,
and political incentives.

A governance-centered approach requires:

climate-sensitive and risk-informed land use planning,
protection and restoration of watershed and riparian systems,
strict implementation of easements and hazard-zone regulations,
upstream retention strategies and nature-based solutions,
green infrastructure that enhances urban permeability,
basin-wide management across LGU boundaries,
resilient zoning and development controls,
and institutional reforms that shield planning from political and economic capture.

Cebu’s long-term resilience depends on integrating these elements into a coherent governance structure.

Conclusion

The November 4, 2025 flood event underscored the limitations of relying primarily on engineering-centric flood control. While structural interventions remain essential, they are insufficient against systemic land-use pressures. Institutional weaknesses and economic incentives drive risky development.

Flooding in Cebu is a political economy issue—rooted in how land is valued, governed, and contested. Meaningful solutions require a transition from reactive flood-control efforts. These solutions must embrace a comprehensive approach rooted in land governance, ecological integrity, institutional accountability, and long-term urban planning.

Cebu can only move toward true resilience through this shift. It will reduce its vulnerability to the increasingly severe impacts of climate and development pressures.

Beyond Compliance: Why the ECC Fails to Capture the True Value of Cebu’s Uplands

Environmental decision-making in the Philippines has long relied on the Environmental Compliance Certificate (ECC). It serves as the ultimate regulatory gatekeeper for development. Yet in a province like Cebu, upland forests stabilize water, climate, and communities. The ECC has exposed its deepest limitation. It measures environmental compliance, not environmental value..

This distinction came into sharp public view in Cebu City’s upland development debates. This was most notable in the case of Monterazzas de Cebu. It is a large mixed-use project built within the ecologically significant ridges of Barangays Guadalupe and Buhisan. It is near the headwaters of the Central Cebu Protected Landscape (CCPL) and the Budlaan–Buhisan watershed system.

A Watershed Is More Than a Development Site

Cebu’s uplands function as critical ecological infrastructure. They supply benefits that are foundational, systemic, and often invisible until lost:

Groundwater replenishment for Metro Cebu’s aquifers
Flood control and runoff regulation protecting low-lying urban districts
Carbon storage and microclimate regulation mitigating urban heat impacts
Soil retention that prevents landslides and downstream siltation
Habitat for endemic species and biodiversity reservoirs
Landscape identity and cultural value for Cebuanos

These benefits fall under what environmental economics calls Total Economic Value (TEV)—a framework that includes not only direct use (e.g., water supply), but also indirect use (flood control, climate regulation), option value (future medicine, ecotourism), bequest value (inheritance for future generations), and existence value (nature’s value simply for being there).

The ECC process, however, recognizes none of these as economic assets requiring valuation. It focuses instead on mitigation plans, engineering controls, and compliance commitments, answering only the question:

“Can environmental impacts be managed within acceptable regulatory limits?”

It does not ask the larger, economically decisive question:

“What is the value of what will be lost, even if mitigation is implemented?”

The ECC is a compliance mechanism. It checks if an Environmental Management Plan (EMP) exists. It also checks if mitigation measures are proposed. Finally, it ensures that pollution thresholds fall within permissible standards. But compliance is not valuation, and mitigation is not the same as replacing lost natural capital. This structural limitation represents a market failure. It converts ecological services into unpriced subsidies for development. This shifts costs to communities, households, local governments, and future generations.

The Monterazzas Case: Legally Compliant, Economically Incomplete

Monterazzas secured an ECC because it fulfilled its regulatory obligations. These obligations included drainage systems, slope protection, detention ponds, tree replacement, and environmental monitoring plans. From a compliance standpoint, the approval was defensible.

Yet public backlash surged after severe rain events in 2019 and 2021 intensified flooding in downstream Cebu communities. Flooding cannot be attributed to a single development alone. However, the case crystallized a broader reality. The cumulative cost of upland land conversion was never evaluated in economic terms.

No valuation was conducted for:

Reduced aquifer recharge from increased impervious surfaces
Lost flood buffering previously performed by forested slopes
Carbon stock reduction from land clearing
Increased sediment load affecting rivers and drainage systems
Public loss of ecological security and landscape heritage

These are not engineering failures. They are valuation failures—costs borne by communities and future generations, not by project balance sheets.

Mitigation Is Not Valuation

A detention pond cannot replace a mountain’s hydrological function.
Tree replanting cannot immediately restore decades of carbon storage.
Slope stabilization cannot substitute the slow work of root-bound soil ecology.

The ECC system can reduce harm, but it cannot measure the economic magnitude of what is permanently altered or foregone. As a result, developments may be:

✔ legally compliant
✖ economically suboptimal
✖ socially contested
✖ ecologically irreversible

Non-Use Values Matter to the Public—Even If the ECC Cannot See Them

What made the debate over Cebu’s uplands emotionally charged was not only flooding—it was the perception of losing something irreplaceable:

Cebu’s last remaining green ridgelines
Intergenerational access to functioning watersheds
The comfort of knowing nature still exists at scale
A shared ecological identity built into the Cebuano sense of place

These are non-use values—intangible yet real, and entirely absent in ECC assessment.

Toward a New Standard: Valuing Nature, Not Just Regulating It

If Cebu is to balance growth with survival, environmental governance must change significantly. It must evolve beyond impact mitigation. It should also move toward natural capital valuation.

Future upland development decisions should integrate:

Total Economic Valuation (TEV)
Hydrological and carbon loss accounting
Cumulative impact costing
Natural Capital Accounting (aligned with PENCAS)
LGU-level ecosystem service valuation in land use planning
Public trust and intergenerational equity as development thresholds

Because while the ECC may authorize a project, only economics can reveal its true costs—and only ecology pays them back.

The central lesson from Cebu is clear:

Development must not only comply with environmental rules.
It must account for environmental worth.
Otherwise, what is permitted is not always what is sustainable.

What Is Legal Is Not Always Economic

The ECC ensures projects meet environmental regulations. It does not ensure that development decisions make economic sense when nature’s services are fully priced. In rapidly urbanizing regions like Cebu, ignoring this distinction leads to developments that seem profitable in private ledgers. However, they impose hidden public costs that increase over time.

Cebu’s uplands are not free. Their services are not infinite. And their depreciation is not costless.

Nature’s contributions need to be priced, recorded, and defended like any other form of capital. Without these measures, the province will continue approving projects that are technically compliant. However, these projects will remain economically incomplete.

The ECC prevents illegal environmental harm.
Valuation prevents unaffordable environmental loss.
Cebu urgently needs both.

Flood-Control Projects Alone Will Not Save Cebu—Land Use Will

The declaration by experts confirms that infrastructure alone cannot solve Cebu’s flooding crisis. Planners, scientists, and community advocates have long warned this truth. Drainage projects may manage water. However, land use decisions determine where the water goes.

No flood control masterplan, regardless of engineering quality, will succeed while:

Upland forests and recharge zones shrink faster than detention basins are built
Commercial land zones double, increasing impervious surface cover
Core city residential areas are compressed, pushing communities into hazard-prone uplands
Agricultural and green buffer landscapes decline at scale
Critical slope, soil, and watershed protections remain advisory—not mandatory

The problem is not simply inadequate pipes and culverts.
The problem is unregulated sprawl, declining absorption capacity, and the absence of enforceable ecological limits in land development.

The science is clear: Flooding is a land use failure before it is an engineering failure.

A city loses flood resilience when rainfall has nowhere to go. This happens when forests are fragmented. It also occurs when slopes are sealed and floodplains are built over. Additionally, housing is pushed uphill without geotechnical, drainage, or watershed safeguards.

The recently approved Cebu City CLUP and Zoning Ordinance thus arrives at a critical inflection point.
Commercial zones have expanded. Forests have been reduced. Affordable housing provision is minimal. The plan must now integrate mandatory disaster-responsive corrections in its implementation phase. This must happen before more irreversible exposure is built into the urban footprint.

We call on city decision-makers to embed the following as binding implementation requirements:

Slope-based and hazard-based development controls for uplands
Mandatory stormwater detention, permeable surface thresholds, and infiltration standards per project
Watershed and ridge-to-reef protection zones with enforceable buffers
Moratorium on approvals in high-risk upland settlements pending risk audit
Mid-rise affordable housing incentives within safe urban zones to prevent uphill displacement
Integration of Metro Cebu-wide watershed governance beyond city political boundaries
Creation of an independent CLUP implementation oversight body

Development is not the crisis. Ungoverned development is.

No amount of pumping stations, river walks, canal clearing, or floodgates can compensate for lost forests. They cannot compensate for paved watersheds. They cannot address displaced communities and weakened soil absorption systems. Lost forests, paved watersheds, displaced communities, and weakened soil absorption systems.

Cebu must move beyond treating floods as an aftermath problem.
Flood risk must be prevented at the point of land conversion, zoning approval, and building permit. It should not be addressed only by draining after the storm.

“What protects a city is not just how it builds its drainage…

but how it plans its land.”

We urge the City Government to ensure that CLUP implementation corrects the risk drivers of future disasters. National oversight agencies should also ensure corrective measures are taken. It should not institutionalize these risk drivers.

The aspiration should change. It should not be:
“Cebu that survives floods.” It should be:
“Cebu that no longer floods because it was planned correctly.”