Metro Cebu’s Urbanization Crisis: Land Economics, Upland Development, and the Need for Development Control

The recent warning raised by Architect Yumi Espina regarding the mounting urbanization pressures confronting Metro Cebu deserves serious consideration. His observations on climate vulnerability, infrastructure limitations, environmental degradation, and the need for metropolitan coordination highlight the increasingly complex challenges facing Cebu’s urban development.

I’d extend the discussion beyond the conventional argument that rapid urbanization is threatening the survival and livability of Metro Cebu.

Urbanization, by itself, is not the problem. The more fundamental issue is how land is allocated, developed, and regulated under competing economic, social, and environmental demands.

Urbanization is an economic process. It reflects the concentration of population, employment, capital, infrastructure, and productive activities. When properly managed, it generates economies of scale, improves access to services, and creates opportunities for growth. The difficulty arises when the expansion of urban development exceeds the capacity of infrastructure and natural systems to support it.

Consider two residential developments in Metro Cebu. The first sits within an established urban area with adequate drainage, transportation access, water supply, and public services. The second occupies sloping upland terrain, where extensive land grading, vegetation clearing, and construction may alter natural drainage patterns. Both contribute to economic activity and accommodate housing demand. Their environmental consequences, however, can differ considerably — the second may increase surface runoff and sedimentation, particularly where downstream drainage systems are already inadequate. The extent of these effects depends on the site’s physical conditions, development design, and mitigation measures, and has to be established through proper technical assessment.

This illustrates a basic principle in land economics: a development may be financially profitable to its owner while imposing environmental and social costs on surrounding communities. These are negative externalities — they arise when the full consequences of a private economic activity are not borne by the party undertaking it.

Architect Espina’s warning about Metro Cebu’s environmental pressures is particularly significant because he previously headed the Cebu City Planning and Development Office and helped lead the preparation and advancement of the CLUP for 2023–2032.

This places him in a position to contribute meaningfully to the continuing evaluation of the plan.

The CLUP identifies flood control, environmental conservation, and sustainable urban development among its planning objectives. These are important commitments. However, identifying such objectives does not, by itself, establish that the resulting land-use allocations, zoning classifications, and development controls are sufficient.

The question is whether the plan’s provisions can effectively manage the environmental risks associated with future development. For example, how are upland development intensities determined? What environmental thresholds govern land conversion? How are downstream flood impacts considered? Are infrastructure limitations adequately incorporated into development decisions?

These are substantive planning questions that deserve technical examination.

Given Espina’s recent warnings, I believe it would be constructive for him to support an independent and comprehensive review of the CLUP, including appropriate amendments where technical evidence establishes deficiencies.

Such a position would reinforce, rather than diminish, his contribution to Cebu City’s planning process.

Upland Development and the Watershed Problem

The work of Dr. Ramon C. Sevilla on Cebu’s urban development and watershed governance offers an important perspective here. It draws attention to the relationship between upland development, watershed conditions, drainage infrastructure, and the governance challenges confronting Cebu City.

The significance of upland development extends beyond the boundaries of a single property. Watersheds operate as interconnected systems — changes in land cover, soil permeability, slope conditions, and drainage in one location can affect water movement elsewhere in the catchment. A development proposal, then, can’t be evaluated solely on its economic feasibility or its compliance with a given zoning classification. It also has to be examined for its cumulative effect on the watershed and on the communities that depend on it. This matters especially in Metro Cebu, where upland and downstream communities are connected through river systems that cross administrative boundaries.

Flooding, in other words, shouldn’t be understood exclusively as an engineering problem solved by larger canals, better drainage, or flood-control structures. It’s also a land-use allocation problem. Engineering interventions remain necessary, but their effectiveness is constrained if land development keeps altering runoff conditions or occupying areas essential to natural drainage and floodwater storage.

Why Development Control Matters

This brings us to a fundamental function of urban and environmental planning: development control.

Land-use planning determines how land is allocated among competing uses. Development control regulates how those opportunities may actually be exercised. A property classified for residential development shouldn’t automatically be treated as suitable for unrestricted construction. Depending on site characteristics, development controls may limit building density, land coverage, slope disturbance, vegetation removal, impervious surfaces, and stormwater discharge — and may require drainage facilities, retention systems, and environmental buffers. The goal isn’t necessarily to prohibit development, but to keep its intensity and physical characteristics consistent with the environmental and infrastructural capacity of the site.

Land-use planning allocates development opportunities; development control ensures those opportunities are exercised within acceptable environmental, economic, and social limits.

From the standpoint of land economics, development control also addresses market failure. A developer evaluates a project based on land acquisition costs, construction expenses, anticipated revenue, and financial return. That private feasibility calculation, however, doesn’t necessarily capture increased downstream flood exposure, added infrastructure burden, ecological degradation, or other costs the public ends up bearing. Effective development control is how those wider consequences get accounted for, through standards, conditions, and regulatory requirements.

The CLUP as an Economic Allocation Instrument

This reinforces a position I’ve held for some time: Cebu City’s Comprehensive Land Use Plan needs to be evaluated as more than an exercise in assigning zoning classifications. A CLUP is fundamentally an instrument for allocating scarce land resources among competing economic, environmental, and social uses — it determines not only where development may occur, but how development opportunities are distributed across the city.

This is where the distinction between development capacity and development opportunity becomes essential. Development capacity refers to the legal, physical, environmental, and infrastructural conditions that determine whether land can actually accommodate a particular use and intensity of development. Development opportunity refers to its economic attractiveness — financial feasibility, effective market demand, anticipated returns. The two are related but not interchangeable: a property may command a high market value and attract substantial investment without possessing the environmental capacity to accommodate intensive development. Land that performs an important ecological function, conversely, may carry a low observable market price despite generating real benefits for surrounding communities.

This is precisely why market demand and private profitability can’t serve as the sole criteria for land-use decisions. A sound CLUP has to reconcile economic opportunity with environmental limitations, infrastructure requirements, and broader public welfare.

Natural Capital and the Economic Value of Watersheds

A further weakness in conventional land-use planning is treating undeveloped land primarily as a future construction site. Forests, rivers, wetlands, floodplains, and other natural systems perform economically valuable functions — watersheds regulate runoff, retain water, support groundwater recharge, reduce erosion, and provide ecological services that benefit urban and rural communities alike. These functions constitute natural capital, and their value doesn’t always show up in ordinary real estate transactions even though their loss generates real economic costs.

This is where the Philippine Ecosystem and Natural Capital Accounting System (PENCAS) becomes directly relevant. PENCAS provides a framework for measuring the stock and flow of ecosystem services — water regulation, carbon storage, erosion control, and similar functions — in terms that can sit alongside conventional economic accounts, rather than treating them as externalities invisible to planning and investment decisions. Folded into a CLUP, this kind of accounting gives planners a basis for weighing a parcel’s ecosystem contribution against its development value, instead of defaulting to whichever use generates the higher observable price.

This doesn’t mean all environmentally sensitive land must remain undeveloped. It means land-use decisions need a more rigorous accounting of the trade-offs involved. The highest financial return from a property is not necessarily the highest economic benefit to society — and a planning framework that can’t see natural capital will systematically undervalue it.

Beyond Cebu City: The Regional Dimension

The emphasis on metropolitan coordination matters because urbanization doesn’t stop at political boundaries. Metro Cebu functions as an interconnected economic and environmental region — its labor markets, housing demand, transportation networks, infrastructure systems, watersheds, and investment activity extend across several local government units, and in fact beyond Metro Cebu into the wider Cebu region. A development decision made in one locality can affect traffic, infrastructure demand, water resources, and environmental conditions in a neighboring one.

But regional coordination shouldn’t be reduced to standing up another administrative body. The more fundamental question is whether the instruments and institutions that already exist — comprehensive land-use plans, zoning ordinances, environmental assessments, watershed management programs, development permitting systems — are being coordinated and enforced effectively. Metro Cebu doesn’t suffer primarily from an absence of planning mechanisms; it suffers from inconsistent technical rigor, weak enforcement, and limited accountability across the mechanisms it already has. Adding a new coordinating body without resolving those underlying weaknesses risks adding another layer of process rather than more effective outcomes. Regional planning should integrate the instruments already in place, while recognizing that the economic and environmental systems they’re meant to govern don’t respect jurisdictional lines.

Rethinking Cebu’s Development Model

Metro Cebu’s urbanization challenges call for more than additional infrastructure, new planning institutions, or blanket restrictions on development. They call for a clearer understanding of the economic forces driving land conversion and urban expansion, and of the environmental limits those forces operate within.

The relevant question isn’t whether Cebu should continue developing — economic growth, housing production, and infrastructure expansion remain necessary. The question is where development should occur, what intensity of use the site can support, what environmental services may be affected, and who ultimately bears the costs. These are the questions that should guide the preparation and implementation of comprehensive land-use plans and development controls, and they require stronger integration of land economics, watershed science, natural capital accounting, and environmental planning.

Urbanization is an economic reality. Sustainable urbanization is a matter of deliberate land allocation, effective development control, and environmental accountability. The livability and long-term economic productivity of Metro Cebu will depend not on how much development it accommodates, but on whether its scarce land and natural resources are allocated and managed in a way that balances private investment, public welfare, and ecological sustainability.

Beyond Land and Infrastructure: Rethinking the Valuation of Water-Dependent Enterprises

By Augusto B. Agosto, JD, EnP, Economist, Consultant

When most people think of property valuation, they picture land, buildings, machinery, and infrastructure—tangible assets that can be easily inspected, measured, and compared in the marketplace. For water-dependent enterprises, however, a more fundamental question often arises: What is the value of the resource that makes the entire enterprise possible?

A water treatment plant without water has little utility; pipelines without water cannot generate revenue; and reservoirs without water are merely empty storage facilities. Yet, traditional valuation approaches often focus heavily on physical assets while giving limited attention to the underlying resource and the legal rights that govern access to it.

Recent professional engagements involving bulk water supply systems, utility infrastructure, and water-related enterprises prompted me to revisit a question that sits precisely at the intersection of law, economics, environmental planning, and valuation: Can the value of a water enterprise be fully explained by land and physical improvements alone? The answer is considerably more complex than conventional appraisal practice suggests.

Who Owns the Water?

The starting point of any discussion on water rights in the Philippines is the Regalian Doctrine. Under Article XII, Section 2 of the Constitution, all natural resources—including waters—belong to the State. The Water Code of the Philippines (Presidential Decree No. 1067) further reinforces this by declaring that private entities may acquire only the right to appropriate and utilize water, subject to strict state regulation.

This distinction is critical for valuation professionals: private entities generally do not own the water itself. Instead, they acquire the legal authority to access, extract, treat, distribute, and utilize water for beneficial purposes. While a water permit is merely an administrative authorization from a legal perspective, from an economic perspective, that authorization represents a monumental source of value.

Water Rights as Economic Assets

Economics teaches us that value arises from scarcity. Although the Philippines is traditionally viewed as an island nation rich in water resources, many regions face acute water stress driven by population growth, rapid urbanization, watershed degradation, groundwater depletion, and climate-induced seasonal variability. As access to reliable water becomes premium, the economic significance of water rights increases proportionally.

Water rights act as economic catalysts by providing:

  • Access to a Scarce Resource: Guaranteed entry into a restricted natural market.
  • Security of Supply & Legal Certainty: Risk mitigation against operational disruptions and litigation.
  • Priority of Use & Investment Opportunities: The baseline confidence required to deploy heavy capital for infrastructure development.

In effect, water rights serve as the operational bridge that converts unpriced natural resources into productive, revenue-generating economic assets.

Lessons from Practice: Beyond Tangible Assets

Several recent valuation assignments involving watershed-based bulk water supply systems and utility infrastructure projects forced a departure from standard real estate appraisal. These engagements required an evaluation that looked beyond physical infrastructure to assess raw water sources, regulatory authorizations, off-take contractual arrangements, and long-term hydrological sustainability.

One particular assignment involving a watershed-based bulk water supply system raised several non-traditional questions:

  • What precise portion of enterprise value is truly attributable to land versus physical improvements?
  • How should the raw, productive capacity of the surrounding watershed be quantified?
  • What is the isolated economic value of the right to abstract and distribute water?
  • How does the long-term reliability of the water source impact overall enterprise risk and value?
  • To what extent do administrative permits and contractual off-take agreements contribute to the ongoing economic viability of the operation?

Answering these questions required moving past conventional property appraisal and venturing into resource economics, institutional rights, environmental planning, and natural capital accounting. The valuation ultimately demonstrated that the economic performance of the enterprise could not be explained solely by its tangible assets. A massive portion of its utility and income-generating capacity was inherently tied to the underlying water resource and the institutional frameworks safeguarding access to it.

Two Paths to Water Production

Observation of water enterprises in Cebu reveals an interesting operational dichotomy. Different enterprises produce marketable water through completely different asset profiles:

Production TypologyResource ReliancePrimary Value Driver
Natural Capital-DependentWatersheds, springs, and deep groundwater systems.High reliance on natural replenishment and ecological health.
Technology-DependentDesalination plants and advanced treatment systems converting seawater or brackish water.High reliance on produced capital, energy inputs, and technological investments.

While both typologies generate revenue by delivering the same end product, their underlying asset structures differ fundamentally. One depends heavily on natural ecosystems; the other depends on engineered physical infrastructure. Yet, both share the same economic reality: without access to the baseline water resource (whether raw fresh water or raw seawater), neither infrastructure nor technology can generate revenue.

Natural Capital and Water Resources

The emerging field of natural capital accounting provides a precise framework for modernizing valuation practice. Natural capital refers to natural assets capable of generating flow-of-resource economic benefits. In this context, it encompasses:

  • Watersheds, aquifers, and natural springs.
  • Rivers, recharge areas, and critical forest ecosystems that regulate hydrological cycles.

Without healthy watersheds and functioning hydrological systems, physical water supply infrastructure loses its utility. Consequently, the comprehensive valuation of water enterprises demands that we look upstream at the sustainability and ecological health of the resource provider.

Beyond Valuation: Understanding How Water Creates Economic Value

The appraisal of water-dependent enterprises often begins as a valuation exercise. However, the analysis quickly extends beyond traditional questions of market value and into a broader examination of how value is created.

Water enterprises derive their economic significance not merely from land, infrastructure, or equipment, but from the interaction of natural resources, institutions, and markets. Watersheds generate water resources. Legal and regulatory systems allocate access through water rights and permits. Infrastructure transforms the resource into a usable product. Markets create demand. Together, these elements produce economic value.

Viewed from this perspective, water rights valuation is not simply an appraisal problem. It is fundamentally an economic inquiry into how natural capital is transformed into productive capital through institutional arrangements and investment.

The valuation question therefore becomes a gateway to a broader understanding of resource economics, natural capital, and economic development.

Recent developments—including the enactment of the Philippine Ecosystem and Natural Capital Accounting System (PENCAS), the Philippine Statistics Authority’s Water Accounts, and ongoing national water resource assessments—reflect a growing recognition that natural resources are not merely environmental assets but fundamental contributors to economic development and national wealth.

These initiatives have significantly advanced the measurement of water resources, ecosystem services, and natural capital. However, an important gap remains. Much of the existing literature focuses on water availability, water use, allocation, pricing, and conservation. Far less attention has been devoted to understanding how water resources create economic value and how institutional arrangements governing access to those resources influence investment, enterprise development, and wealth creation.

In particular, limited research has examined the role of water rights as institutional mechanisms that transform water resources into productive economic assets. The interaction between natural capital, legal entitlements, infrastructure investment, and economic production remains largely unexplored in the Philippine context. Understanding this relationship is increasingly important as water scarcity, climate risks, and competing resource demands place greater emphasis on the economic significance of water resources.

These questions form the foundation of the author’s ongoing research, which seeks to examine how scarcity, institutions, and water rights interact to create economic value within water-dependent enterprises and, more broadly, within the Philippine economy.

Conclusion

The discussion on water rights ultimately leads to a broader question than valuation itself. While appraisal seeks to measure value, economics seeks to understand how value is created. In the case of water-dependent enterprises, the answer extends beyond land, buildings, treatment facilities, and infrastructure.

The experience of examining bulk water systems suggests that economic value originates from the interaction of natural capital, institutions, and investment. Watersheds, aquifers, springs, and other water resources provide the physical foundation. The State, through the Regalian Doctrine and the Water Code, establishes the institutional framework governing access and allocation. Water rights and permits create certainty, enabling investment in infrastructure, treatment systems, and distribution networks that transform natural resources into economic output.

Viewed from this perspective, water rights are more than regulatory instruments. They serve as institutional mechanisms that connect natural capital to economic production. Understanding their role requires moving beyond traditional discussions of water use and toward a deeper examination of how water resources contribute to enterprise value, regional development, and national wealth.

Recent initiatives such as PENCAS, the PSA Water Accounts, and national water resource assessments signal a growing recognition of the economic importance of natural assets. Yet important questions remain. How do watersheds create economic value? How do institutions influence the allocation of scarce water resources? How do water rights support investment, productivity, and long-term development? These questions remain largely unexplored within Philippine literature and present opportunities for future research.

The inquiry that began as a valuation problem has therefore evolved into a broader economic question: how does a water resource become economic value? Exploring that question may not only improve valuation practice but also contribute to a deeper understanding of water governance, natural capital, and sustainable development in the Philippines. As water scarcity and climate-related challenges become increasingly significant, the ability to understand and account for the value created by water resources may prove essential to both economic policy and resource management in the decades ahead.

SFLMA and the Future of Environmental Asset Governance in the Philippines

I. Introduction

The implementation of the Sustainable Forest Land Management Agreement (SFLMA) under DENR Administrative Order No. 2025-22 marks a transformative shift from traditional, defensive forestry toward active environmental asset governance. This reform takes place against a complex legal backdrop where approximately 15.81 million hectares—over half of the Philippines’ total 30-million-hectare landmass—remain classified as public forest lands under the constitutional mandate of the Regalian Doctrine.

Historically, this system has suffered from institutional inertia, leaving official land boundaries largely unchanged since 2006 and creating a severe mismatch between legal designations and actual land use on the ground. However, the rise of the modern carbon economy has fundamentally reframed these spaces. Rather than treating forests merely as passive timber reserves or off-limits ecological zones, the SFLMA framework targets 1.2 million hectares of degraded public land—distributed across roughly 1,700 mapped parcels—to serve as climate infrastructure, carbon reservoirs, and natural capital assets.

Ultimately, this initiative places Philippine land governance at a critical intersection. The central challenge moving forward is balancing market-driven climate investments and carbon governance with the enduring constitutional principles of stewardship, social justice, and intergenerational responsibility.

II. The Carbon Economy and Legal Consolidation

One of the most consequential dimensions of the SFLMA is its architectural role in the emerging carbon economy. As international compliance and voluntary carbon markets mature, the framework provides the administrative and tenurial foundation required to host land-based carbon projects, verify forest carbon sequestration, and generate tradable carbon credits.

By offering long-term tenurial security, the SFLMA lowers the political and regulatory risk for institutional investors looking to fund nature-based solutions (NbS). Reforestation projects under this framework are uniquely positioned to serve as high-quality carbon sinks capable of issuing verified offsets for both domestic and international transfer.

Furthermore, this framework serves a critical state interest in regulatory streamlining. The SFLMA replaces and consolidates older, fragmented forest tenure systems, officially retiring:

  1. Industrial Forest Management Agreements (IFMA)
  2. Socialized Industrial Forest Management Agreements (SIFMA)
  3. Select commercial components of Community-Based Forest Management Agreements (CBFMA)

By collapsing these disparate instruments into a single governance mechanism, the DENR aims to eliminate conflicting land-use mandates, minimize institutional red tape, and lower transaction costs for clean-energy and conservation proponents. As the DENR noted during its rollout, the framework is explicitly designed to simultaneously generate rural employment, stimulate local economies, and boost the national gross domestic product (GDP) through sustainable forest enterprises.

III. Operationalizing SFLMA through the PENCAS Act

To properly realize its potential, the SFLMA framework must be linked directly to Republic Act No. 11995, otherwise known as the Philippine Ecosystem and Natural Capital Accounting System (PENCAS) Act. Passed to institutionalize the internationally accepted System of Environmental-Economic Accounting (SEEA), PENCAS provides the statutory framework that turns the theory of “environmental asset governance” into measurable fiscal and physical data.

┌────────────────────────────────────────────────────────┐
│ R.A. 11995 (PENCAS Act) │
│ National Macroeconomic & Data Standards │
└───────────────────────────┬────────────────────────────┘
│
▼ (Provides Baselines & Metrics)
┌────────────────────────────────────────────────────────┐
│ DENR DAO No. 2025-22 (SFLMA) │
│ Project-Level Allocation & Concessions │
└────────────────────────────────────────────────────────┘

1. The Data Engine for Asset Valuations

While the SFLMA identifies 1.2 million hectares of Potential Investment Areas (PIAs) for carbon sequestration and ecosystem services, establishing their baseline value without a standardized legal methodology invites speculation. The PENCAS Act solves this challenge by mandating the collection and compilation of official statistics on the depletion, degradation, and restoration of natural capital.

  • Asset Accounts: Under PENCAS, the state must maintain strict physical and monetary accounts of timber and land assets, which directly inform SFLMA baseline data. This guarantees that carbon sequestration projects calculate genuine additionality rather than relying on unverified corporate metrics.
  • Quantifying Ecosystem Services: PENCAS legalizes the valuation of “regulating services”—such as carbon storage, water filtration, and flood protection—giving SFLMA proponents a government-sanctioned data framework to back up ESG investments and carbon-credit accounting.

2. Macroeconomic Integration vs. Project-Level Finance

Under R.A. 11995, natural capital statistics are integrated directly into the country’s macroeconomic indicators, meaning major environmental accounts are co-released with traditional economic indicators like GDP. This creates a dual-layered governance system: PENCAS operates at the macro-level to track nature’s aggregated wealth, while the SFLMA operates at the micro-tenurial level. The SFLMA serves as the contractual vehicle allowing private and community actors to manage specific plots of land using the uniform accounting standards established under PENCAS.

3. Verification and Safeguards Against Greenwashing

One of the primary critiques of the SFLMA is the high risk of greenwashing and corporate regulatory capture. The PENCAS Act introduces a critical check on this through its institutionalized accounting metrics. If an SFLMA concessionaire causes ecosystem degradation or implements biodiversity-poor monoculture plantations under the guise of carbon offsets, the localized reduction in ecosystem asset accounts provides public interest litigants with actionable, government-backed data to support petitions for environmental remedies, such as a Writ of Kalikasan.

IV. Constitutional Boundaries: The Public Trust Intersection

Despite its market-oriented mechanics, the SFLMA operates within rigid constitutional boundaries. Under Section 2, Article XII of the 1987 Philippine Constitution, all lands of the public domain and natural resources belong to the State under the Regalian Doctrine (Jura Regalia). Because public forest lands are inalienable, the SFLMA does not transfer ownership. Instead, it grants restricted stewardship and management rights, explicitly conditioned upon the continuous fulfillment of environmental obligations.

This arrangement operationalizes the constitutional philosophy that property bears a social function, meaning the right to utilize natural resources is inherently subordinated to the welfare of the common good. Consequently, the SFLMA sits at a complex legal intersection:

Under the Public Trust Doctrine, the State serves as the perpetual trustee of the nation’s natural wealth, while private and community actors function as temporary, fiduciary stewards. Every SFLMA project must therefore operate within legally defined ecological limits, ensuring that the exploitation of the asset does not impair the underlying public trust.

V. Systemic Risks, Drawbacks, and Structural Critiques

While structurally ambitious, the SFLMA framework exhibits several vulnerabilities, regulatory gaps, and socio-ecological risks that require rigorous mitigation.

1. The Commercialization of Ecospace and Greenwashing

By treating forests as natural capital, there is an immediate risk that environmental governance becomes subordinated to market incentives. If forests are valued primarily for their carbon credit yields and commercial ESG returns, biodiversity and deep ecological integrity may take a backseat.

This commercial focus invites structural greenwashing. Without robust, third-party verification protocols and data-driven carbon audit registries, corporate actors might exploit SFLMA concessions as cheap corporate branding vehicles. Weak state oversight could lead to speculative carbon banking, double-counting of offsets, and the generation of low-integrity carbon credits that fail to achieve genuine additionality.

2. Corporate Concession Dominance and Elite Capture

The framework permits large-scale corporate participation, allowing single entities to hold management rights over extensive tracts of land—in some instances up to 40,000 hectares. This high ceiling raises significant concerns regarding elite capture and land concentration. If large conglomerates dominate the competitive allocation of Potential Investment Areas (PIAs), smaller cooperatives, local civil society organizations, and marginalized upland communities may be priced out of the environmental asset market entirely.

3. Overlaps with Ancestral Domains and IP Exploitation

Spatial mapping data from the DENR indicates a critical geographic tension: approximately 85% of identified SFLMA parcels partially overlap with roughly 15% of ancestral domains occupied by Indigenous Cultural Communities (ICCs) and Indigenous Peoples (IPs).

While the law mandates compliance with the Free and Prior Informed Consent (FPIC) process under the Indigenous Peoples’ Rights Act (IPRA), there is a structural risk that this participation becomes merely transactional or symbolic. If indigenous communities lack equal bargaining power or sophisticated legal representation, they may find themselves excluded from meaningful benefit-sharing mechanisms and long-term project governance.

4. Ecological Conversion and Monoculture Risks

From an ecological standpoint, carbon-sequestration math often favors fast-growing, non-native commercial species over complex, slow-growing native silviculture. Policy research from the University of the Philippines warns that if regulatory safeguards are weak, the SFLMA could inadvertently incentivize the conversion of remaining natural secondary forests into simplified agroforestry or monoculture plantation systems, compromising local biodiversity and watershed resilience in the name of carbon maximization.

5. Regulatory Capture and Institutional Capacity Gaps

Simultaneously managing and auditing more than one million hectares of geographically dispersed forest lands demands an unprecedented level of technical, technological, and regulatory oversight. The DENR currently faces significant budgetary, staffing, and technological constraints. Without advanced remote sensing, real-time drone monitoring, and corruption-resistant auditing platforms, the SFLMA framework remains vulnerable to regulatory capture, illicit land conversions, and enforcement failures on the ground.

VI. Conclusion: Anchoring the Future Framework

The SFLMA brings a foundational tension in modern environmental law to the forefront: Should nature be governed primarily as an inviolable public trust, or as a quantifiable economic asset?

The doctrinal significance of DAO No. 2025-22 lies in its attempt to merge these two paradigms. It demonstrates that the Philippines is actively transitioning from a legacy of reactive environmental regulation to a proactive strategy of environmental asset governance.

The policy challenge moving forward is not whether the Philippines should participate in global climate finance or build domestic carbon markets; rather, it is whether these market mechanisms can remain firmly anchored to constitutional stewardship, social justice, and the principle of intergenerational responsibility (Oposa v. Factoran).

The ultimate success of Philippine carbon governance will depend on the state’s ability to develop a comprehensive legal framework that balances private economic utilization with robust public accountability, ensuring that all environmental assets are managed to serve the common good. The SFLMA has opened the door to market-based conservation; the onus is now on the state, civil society, and private sector to build the governance architecture required to walk through it responsibly.

Selected references and links:

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

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.

ComponentDescription
Market valueCommercial value of extracted minerals
Natural capital valueEcosystem 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:

IndicatorValue
Total concession area406 hectares
Estimated disturbance ratio35%
Estimated disturbed area142 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:

CalculationValue
Disturbed area142 hectares
Estimated ecosystem value per hectarePhp900,000/year
Estimated ecosystem service valuePhp127.8 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:

IndicatorEstimated Value
Ecosystem services valuePhp127.8 million / year
Provincial fiscal recoveryPhp13.2 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:

ProjectionValue
Annual ecosystem valuePhp127.8 million
30-year horizon Estimated ecosystem valuePhp3.8 billion

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

ComponentEstimated 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 settlementPhp211 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.

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.

Why Cebu City Must Revisit Its 2025 CLUP: Lessons from the Binaliw Upland Landfill

The collapse of the Binaliw landfill in Cebu City has been explained away in familiar terms. It has been called an accident. An operational failure. An unfortunate convergence of circumstances. Some have even framed it as a force majeure—an event no one could have reasonably foreseen.

But when examined through the lenses of land-use planning, environmental governance, and disaster risk management, these explanations do not hold.

Binaliw was not an accident.
It was a foreseeable outcome of a planning decision—one that ignored a fundamental principle already embedded in Cebu City’s own Comprehensive Land Use Plan (CLUP) and the JICA Roadmap for Solid Waste Management:

No engineering solution can outweigh an inherently risky upland location.


The Real Frame

Public discussion has focused heavily on whether Binaliw was an “engineered sanitary landfill.” That framing misses the point.

Even a perfectly designed landfill cannot defeat gravity, slope instability, rainfall concentration, and watershed dynamics inherent in an upland area. Engineering can only mitigate risk within the limits set by geography—it cannot erase those limits.

The correct question is not whether Binaliw was engineered.
The correct question is why an upland, risk-sensitive area was assigned a high-intensity waste function in the first place.

That question leads us directly to the CLUP and the JICA study.


The CLUP: Risk Was Acknowledged—Then Overridden

Under the Cebu City Comprehensive Land Use Plan, barangays like Binaliw are identified as part of the City’s upland and environmentally constrained zones. These areas are characterized by:

  • Slope and landslide susceptibility
  • Sensitivity to saturation and runoff
  • Strong influence on downstream flooding and disaster amplification

The CLUP recognizes that such areas require low-intensity, risk-compatible land uses, with infrastructure treated as conditional and transitional, not permanent or intensifying.

Yet in practice, Binaliw was allowed to operate as a major disposal site for metropolitan waste, accumulating mass far beyond what an upland area can safely bear over time.

This was not an oversight.
It was a planning contradiction.


Mixed-Use Zoning: Where Risk Became a Policy Choice

The most critical vulnerability in the CLUP lies in its allowance of mixed-use or conditional development in upland areas.

In lowland urban settings, mixed-use zoning can enhance resilience and efficiency.
In upland, environmentally constrained zones, it does the opposite.

Mixed-use zoning in uplands opens the door to intensity creep:

  1. Risk is acknowledged but not prohibited.
  2. Projects are approved individually, each appearing compliant.
  3. Cumulative load is ignored.
  4. Carrying capacity is exceeded.

A landfill in an upland area is not merely a land use—it is continuous mass loading. Waste is heavy, compressible, water-retentive, and constantly increasing. No zoning flexibility or engineering detail can change that physical reality.

By permitting mixed-use development in upland zones, the CLUP effectively treated risk as negotiable, rather than as a hard limit.

A Warning Issued Long Before the Collapse

What makes the Binaliw disaster even more troubling is that this exact risk was already identified more than a decade ago.

As early as 2015, the JICA Roadmap for Solid Waste Management in Metro Cebu had already reached a clear and technically grounded conclusion: engineering solutions have inherent limits in upland terrain. The study did not merely recommend better landfill design; it explicitly framed upland disposal as a temporary and diminishing option, one that must be progressively relieved of waste load as part of a metropolitan transition strategy.

The 2015 JICA study recognized several realities that remain unchanged today:

  • Upland areas are geomorphologically unstable under sustained mass loading;
  • High rainfall and steep slopes amplify saturation and failure risks;
  • Waste accumulation in uplands contributes not only to local instability but also to downstream flooding and disaster amplification;
  • Reliance on existing upland landfills must therefore be reduced over time, not intensified.

In other words, the JICA Roadmap did not assume that better engineering could permanently solve upland disposal risks. It assumed the opposite: that location imposes non-negotiable limits which engineering can only temporarily mitigate.

This is why the roadmap emphasized a phased exit from upland landfill dependence—through waste diversion, metropolitan disposal facilities, and alternative treatment systems. Upland landfills were never envisioned as permanent infrastructure supporting metropolitan waste volumes.

Why the 2025 Cebu City CLUP Must Be Revisited

The collapse of the Binaliw landfill has transformed what was once a technical planning debate into an urgent governance imperative. What is now clear—beyond reasonable dispute—is that the 2025 Cebu City Comprehensive Land Use Plan (CLUP) must be revisited, particularly its treatment of upland areas and mixed-use zoning.

This is no longer a question of preference, ideology, or development philosophy. It is a question of whether land-use policy will continue to contradict geographic reality.

Mixed-use zoning is often defended as a modern, adaptive planning tool. In lowland urban contexts, that is frequently true. In upland, environmentally constrained areas, however, mixed-use zoning becomes a risk multiplier.

It allows:

  • gradual intensification without clear ceilings;
  • project-by-project approvals that ignore cumulative impact;
  • reliance on engineering solutions where geography has already imposed limits.

The CLUP’s mixed-use provision, when applied to uplands, converts known natural constraints into negotiable policy choices. Binaliw demonstrates the cost of that conversion.

What Revisiting the CLUP Should Mean (Not Cosmetic Amendments)

Revisiting the 2025 CLUP must go beyond clarifications or tighter permitting language. It requires structural correction.

At minimum, a revised CLUP should:

  • Remove or strictly prohibit mixed-use zoning in upland, environmentally constrained areas for high-intensity or mass-loading uses;
  • Explicitly classify uplands as protection-priority zones, not development reserves;
  • Treat any allowed infrastructure as transitional, with:
    • volume caps,
    • sunset clauses,
    • mandatory exit timelines;
  • Align land-use zoning with JICA’s metropolitan transition framework, not short-term disposal convenience.

The Central Policy Lesson

Binaliw has delivered a lesson that planning documents can no longer ignore:

When geography says “no,” zoning must listen.

A CLUP that recognizes upland risk but still permits intensification through mixed-use zoning is internally inconsistent—and now demonstrably unsafe.


A Moment for Course Correction

The call to revisit the 2025 Cebu City CLUP is not anti-development. It is pro-safety, pro-governance, and pro-accountability.

Binaliw should be treated as a planning threshold event—the moment when assumptions were tested against reality and found wanting. To proceed as if nothing fundamental has changed would be to accept that similar disasters are an acceptable cost of “flexibility.”

They are not.

The CLUP must be revised—not because plans failed to exist, but because reality has shown which provisions can no longer be defended.