Performance Audit Report

PAO-2023-01

SOLID WASTE
MANAGEMENT PROGRAM

Progress in the Achievement of

the Goals of the Ecological Solid
Waste Management Act Needs
Stronger Support and the
Cohesive Efforts and Strategies
of All Stakeholders
 April 2023
Audit Highlights SOLID WASTE MANAGEMENT PROGRAM
Why COA did this Study Progress in the Achievement of the Goals of the Ecological Solid Waste
The country’s waste generation continues to rise Management Act Needs Stronger Support and the Cohesive Efforts and
with the increase in population, rapid economic Strategies of All Stakeholders
growth, and industrialization. Hence, Republic
Act No. 9003 (RA 9003), otherwise known as the What COA found
Ecological Solid Waste Management (ESWM) Despite the continuous efforts of the NSWMC, the DENR through its EMB, and the LGUs
Act of 2000, was enacted in January 2001. It in implementing RA 9003 to ensure the protection of public health and the environment,
creates the National Solid Waste Management the program still needs collective and robust efforts from the implementing agencies to
Commission (NSWMC) to address the growing address the challenges prompted by the increasing trend of waste generation and to
solid waste problem. The NSWMC, chaired by progress in attaining its goals and objectives.
the Secretary of the Department of Environment
and Natural Resources (DENR), shall oversee The government has endeavored to improve its solid waste management by passing RA
the program’s implementation. 9003. It mandated the DENR to provide secretariat support to the NSWMC in the
implementation of the solid waste management plans, and prescribes policies to achieve
More than 20 years after the passage of RA the objectives of the National Ecology Center (NEC), which is in charge of information
9003, solid waste generation in the country has dissemination, consultation, education, and training of various LGUs on ecological waste
steadily increased from 9.07 million metric tons management. In addition, the SWMP is expected to assist the LGUs in implementing RA
in 2000 to 16.63 million metric tons in 2020. The 9003 particularly in developing their 10-year SWM Plan, closure and rehabilitation of
situation may be attributed to the frail dumpsites, and establishing Materials Recovery Facilities (MRFs), and the
enforcement and compliance with the law due to implementation of an environmentally sound disposal system. However, after two
political, financial, and technical limitations of decades of implementation, the program may not be seen as progressively achieving its
the local government units (LGUs) and goals and objectives, as manifested by the steadily increasing volume of generated solid
implementing agencies. Many LGUs have yet to waste, including the many gaps noted in the program implementation.
comply with establishing local SWM Boards,
submission of SWM Plans and establishment of Access to MRFs by Barangays and SLFs by LGUs vis-à-vis Number of Established
MRFs. SWM Facilities

The COA assessed the (a) extent to which the

Solid Waste Management Program (SWMP)
achieves its goals and objectives; (b) challenges
in its implementation; and (c) the extent to which
the NSWMC, the DENR through the
Environmental Management Bureau (EMB), and
other concerned agencies administer the
program following established policies and
procedures.

COA reviewed the program documents,

accomplishments, and status reports; gathered
information through surveys from the LGUs, Source: DENR-EMB and NSWMC Data (CYs 2017 to 2021)
waste facility workers, households, students,
and teachers; interviewed key agency officials, Instead of reducing solid waste generation, it steadily increased through the years. We
municipal and city environment and natural identified key challenges that led to this scenario, such as: the inconsistent
resources officers (M/CENROs), non- implementation of waste segregation and waste diversion, wherein the significant
government organizations (NGOs), and presence of mixed wastes was found in landfills. This condition reduced the capacity of
barangay heads; and assessed the extent of the MRFs for diversion, causing the waste volume in landfills to exceed capacity and
coordination with other stakeholders. shorten serviceable lifespans. In addition, there were no sufficient waste facilities and
landfills to service the LGUs and barangays nationwide. As at CY 2021, the country has
What COA recommends 11,637 total MRFs only servicing 16,418 (39.05 percent) out of 42,046 barangays; and
245 total operational Sanitary Landfills (SLFs) only servicing 478 (29.25 percent) out of
COA recommends, among others, that 1,634 LGUs. Due to the limitation in disposal facilities, the operation of the illegal
NSWMC: (a) conduct massive and continuing dumpsites could not be avoided in some LGUs. Further on the noted challenges was the
information, education, and communication non-establishment of the Solid Waste Management Fund, a special account in the
(IEC) campaign, particularly on understanding National Treasury intended to fund the approved solid waste management plans of LGUs.
the provisions of RA 9003 to improve Lastly, there were fragmentations in the program implementation causing the non-delivery
compliance; (b) ensure the operationalization of of important interventions to generate reliable and accurate data and ensure proper
MRFs, including waste diversion and effective operationalization. Hence, it is also notable that progress in attaining Sustainable
record management; (c) ensure the prohibition Development Goal (SDG) 12.5, which aims to substantially reduce waste generation
on the use of open dumpsites or similar through prevention, reduction, recycling, and reuse by CY 2030, has not yet been
uncontrolled facilities; (d) coordinate with monitored and tracked by the government.
concerned agencies on the establishment of the
Solid Waste Management Fund; and (e) On a positive note, we recognize the efforts of the DENR-EMB, which successfully
coordinate with concerned agencies to help decreased the number of illegal dumpsites in CY 2021. Likewise, establishing NEC in CY
LGUs institutionalize an Environment and 2021 was an important step to move forward on the key administrative functions crucial
Natural Resources Office. to the program’s implementation. Its absence (or non-establishment thereof) for 20 years
formed a vast gap in the effective and efficient administration of the program.

PAO-2023-01
 Solid Waste Management Program

Contents

Background ...................................................................................................... 3
For more than 20 years since the enactment of RA 9003, waste
management has remained an issue as waste generation continues to
increase .......................................................................................................... 11
Solid waste generation is continually increasing and is projected to
increase further in future years ................................................................... 11
Delay in LGUs’ implementation of 10-year SWM plans .............................. 18
Waste diversion accomplishments were far from the targets ...................... 22
The total number of MRFs was not sufficient to service all barangays
nationwide ................................................................................................... 26
The total number of SLFs was not sufficient to service all LGUs
nationwide ................................................................................................... 36
While serving as a short-term alternative, RCAs have potential risks if
operated longer than intended .................................................................... 54
Mandated closure, transition, and prohibition of dumpsites were not met .. 60
Achieving SWM objectives will promote relevant SDGs ............................. 68
Challenges encountered that prevented the NSWMC and LGUs from
effectively and efficiently implementing solutions ..................................... 75
Inconsistent implementation of waste segregation nationwide ................... 75
Inconsistent implementation of waste collection nationwide ....................... 93
Some EMB-funded MRFs, including several units/sets of equipment,
were neither established nor operational .................................................... 95
Lack of Recording Mechanism in MRFs Resulting in Unreliable and
Incomplete Data on Waste Diversion ........................................................ 104
Uncollected and unprocessed waste materials are accumulating in
MRFs......................................................................................................... 104
The overwhelming work of EnMOs affects the reliability of data and
delivery of services to the LGUs ............................................................... 109
Non-Establishment of M/CENRO .............................................................. 112
Unequal distribution of men and women in SWM and leadership ............. 114
Examples of Best Practices Observed during Validation .......................... 116
Gaps in the planning, implementation, and monitoring of the program 123
Non-Establishment of SWM-Mandated Funding Sources ......................... 123
Non-Establishment of NEC ....................................................................... 125
Overlap in Beneficiaries Due to Lack of Coordination Among
Implementing Agencies ............................................................................. 129
Non-Establishment of Standard Tipping Charges by NSWMC ................. 132
Non-Preparation of the list of NEAPs from 2001 to 2020 .......................... 133
Ratification of Basel Ban Amendment remains in progress ...................... 135
Conclusions ................................................................................................. 139
Recommendations....................................................................................... 141
Agency Comments ...................................................................................... 143

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Contents

Appendix I: Objectives, Scope and Methodology .................................... 144

Appendix II: Survey and Interview Results ............................................... 146
Households Survey................................................................................. 147
Worker Survey ......................................................................................... 149
Teachers and Students Survey.............................................................. 150
LGU Survey.............................................................................................. 150
Barangay Interview ................................................................................. 151
Appendix III: Summary of Significant Technical Findings by TSO ......... 153
Materials Recovery Facilities (MRFs) .................................................... 153
Sanitary Landfills (SLFs) ........................................................................ 158
SWM Equipment ...................................................................................... 161
A. MRF .................................................................................................... 161
B. SLFs ................................................................................................... 165
C. Dumpsites ......................................................................................... 166
D. Residual Containment Areas (RCAs) ............................................. 166
Appendix IV: Solid Waste Management on SDGs Achievement ............. 167
Appendix V: COA Contact and Staff Acknowledgments ......................... 167

List of Figures
Figure 1: Revised NSWMC Organizational Framework .................................... 4
Figure 2: Reported Waste Generation for CYs 2000, 2010 and 2020 ............... 5
Figure 3: SWM Hierarchy .................................................................................. 6
Figure 4: Materials Recovery Facility (MRF) ..................................................... 7
Figure 5: Typical SLF System............................................................................ 7
Figure 6: SWM System .................................................................................... 14
Figure 7: Percentage Distribution of Municipal Solid Wastes by Source from
CYs 2008 to 2013 ............................................................................ 15
Figure 8: Percentage Distribution of Composition of Municipal Solid Wastes
from CYs 2008 to 2013 ................................................................... 15
Figure 9: Projected Waste Generation for CYs 2010 to 2045 ......................... 17
Figure 10: Submission and Approval of 10-yr SWM Plans from
CYs 2003 to 2021 ............................................................................ 20
Figure 11: MRFs Established from CYs 2010 to 2021 .................................... 27
Figure 12: Percentage Distribution of Barangays With and Without Access to
MRF for CY 2021............................................................................. 27
Figure 13: Prescribed Layout for EMB-funded MRFs ...................................... 29
Figure 14: Prescribed Layout for Central MRF ................................................ 30
Figure 15: Inspection of Municipal MRF in Barangay Tagodtod,
Lagangilang, Abra ........................................................................... 31
Figure 16: Inspection of Various MRFs in Barangay Lote Pto Rivas,
Balanga, Bataan .............................................................................. 32
Figure 17: Examples of Caged MRFs.............................................................. 33
Figure 18: Examples of MRS ........................................................................... 34

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Contents

Figure 19: Comparative Number of LGUs using Dumpsites, SLFs, and RCAs
from CYs 2012 to 2021 ................................................................... 37
Figure 20: Comparative Trends on the Number of Disposal Facilities by Type
from CYs 2012 to 2021 ................................................................... 37
Figure 21: Distribution of LGUs With and Without Access to Operational SLFs
from CYs 2017 to 2021 ................................................................... 38
Figure 22: Major Reasons for the Low Number of Operating SLFs ................. 39
Figure 23: Absolute and Conditional Landfill Site Identification Criteria .......... 40
Figure 24: Elements of SLF ............................................................................ 45
Figure 25: Inspection of SLF in La Trinidad, Benguet, CAR ............................ 46
Figure 26: Inspection of SLF in Norzagaray, Bulacan, Region 3 ..................... 47
Figure 27: SLFs without Required Leachate HDPE Liner ............................... 48
Figure 28: Inspection of SLF in Navotas City, NCR ......................................... 49
Figure 29: Inspection of SLF in Iriga City, Camarines Sur, Region 5 .............. 50
Figure 30: Inspection of SLF in Navotas City, NCR ......................................... 51
Figure 31: Inspection of SLFs with No Regular Daily Soil Cover..................... 52
Figure 32: Inspection of SLFs with No Daily Soil Cover .................................. 53
Figure 33: Ratio of Worker Survey Respondents on Presence of COVID-19-
Related Waste in Navotas SLF ....................................................... 54
Figure 34: Final Disposal Options of LGUs ..................................................... 55
Figure 35: Criteria of RCA ............................................................................... 56
Figure 36: Examples of RCAs from Team Validation ...................................... 57
Figure 37: Comparative Number of Open, Controlled, and Illegal Dumpsites
from CYs 2010 to 2021 ................................................................... 61
Figure 38: Trend in the Numbers of Illegal Dumpsites from CYs 2004 to 2022
........................................................................................................ 61
Figure 39: Operating Illegal Dumpsites during Validation................................ 62
Figure 40: Open Dumpsite in Pili, Camarines Sur ........................................... 65
Figure 41: Solid Waste Exposure Pathway ..................................................... 66
Figure 42: Distribution on the Status of Submission and Implementation of
SCRPs of Closed Dumpsites from 16 Regions .............................. 67
Figure 43: SWM Cuts Across All SDGs ........................................................... 68
Figure 44: Philippines’ Greenhouse Gas Emissions by Sector in 2019 ........... 72
Figure 45: Philippines’ Methane Emissions by Sector in 2019 ........................ 73
Figure 46: Household Survey Results – Open Burning ................................... 73
Figure 47: 5R’s of Waste Management ........................................................... 74
Figure 48: Distribution of LGU Survey Respondents With and Without
Segregation-at-Source Ordinance ................................................... 76
Figure 49: Distribution of Barangay Survey Respondents With and Without
Segregation-at-Source Policy .......................................................... 77
Figure 50: Percentage of Household Survey Respondents Who are Aware
of Waste Segregation ...................................................................... 78
Figure 51: Variation of Waste Bins .................................................................. 79
Figure 52: Waste Type and Container Identification by Select Group ............. 80
Figure 53: Presence of COVID-19-Related Wastes in SLF per Respondent
Workers ........................................................................................... 81
Figure 54: Mixed Wastes Present in SLFs ...................................................... 83

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Contents

Figure 55: Percentage of Worker Survey Respondents Who Found Used

Face Masks and Gloves in SLFs ..................................................... 85
Figure 56: Distribution of SLF Worker Survey Respondents by Type of
Disease Caught or Experienced While at Work .............................. 86
Figure 57: Distribution of SLF Worker Survey Respondents Who
Caught/Suffered Injuries Caught While at Work .............................. 86
Figure 58: Percentage of Household Survey Respondents Using Yellow
Plastic Bag or Yellow Ribbon for COVID-19-Related Waste ........... 87
Figure 59: Establishments within a 200-Meter Radius of SLFs and Dumpsites
........................................................................................................ 91
Figure 60: Percentage Distribution of Household Survey Respondents on
Establishments within 200-Meter Radius from Dumpsites and SLFs
........................................................................................................ 92
Figure 61: MRF in Bohol Damaged by Super Typhoon Odette ..................... 100
Figure 62: Accumulated Recyclable Wastes in MRFs and RCAs ................. 105
Figure 63: Accumulated Recyclable Wastes in MRF in Barangay
Poblacion, Ginatilan, Cebu ............................................................ 106
Figure 64: Distance between Barangay Poblacion MRF and Sea Shore ...... 108
Figure 65: LGU Assignments per EnMO ....................................................... 110
Figure 66: Number of Male and Female M/CENROs .................................... 115
Figure 67: Number of Male and Female EnMOs ........................................... 115
Figure 68: Collecting and Selling of Recyclable Materials by Mintal
Resource Collectors Association (MIRCA) .................................... 117
Figure 69: Limadol’s Food and Kitchen Waste Management Partnership ..... 118
Figure 70: Mother Earth Foundation SWM Support to Barangay San
Rafael, Navotas City ...................................................................... 120
Figure 71: Mother Earth Foundation in Barangay San Rafael Village,
Navotas City .................................................................................. 120
Figure 72: Accomplishments of NEC through DENR-EMB ........................... 126
Figure 73: Inspection of MRF in Barangay Poblacion, Ginatilan, Cebu,
Region 7 ........................................................................................ 127
Figure 74: Sample Units of SWM Equipment Donated by DA and DOST
in MRFs ......................................................................................... 131
Figure 75: NEAP and Microplastics Explained .............................................. 134

List of Tables
Table 1: Distribution of Waste Generated per Region in CY 2000 .................... 3
Table 2: SLF Categories .................................................................................... 8
Table 3: Sample Government Agencies Budget for SWMP .............................. 9
Table 4: Waste Generation Formula................................................................ 11
Table 5: Waste Generated per Capita ............................................................. 12
Table 6: Philippines’ Waste Generation per Capita ......................................... 12
Table 7: Metro Manila’s Estimated Waste Generation Report ......................... 13
Table 8: Comparison of Population, Established MRFs, and SLFs from
CYs 2010 to 2021 ............................................................................ 17
Table 9: CY 2021 Status of Submission and Review of 10-yr SWM Plans ..... 19

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Table 10: No. of Active Barangay, City/Municipal and Provincial SWM Boards
........................................................................................................ 21
Table 11: Average Percentage of Waste Diversion Targets per 10-yr
SWM Plans from CYs 2015 to 2021 ................................................ 22
Table 12: PDP Targets for Solid Waste Diversion ........................................... 23
Table 13: CY 2019 Operational EMB-funded MRFs with Complete Data ....... 23
Table 14: CY 2020 Waste Diversion Target vis-à-vis Actual Accomplishment 24
Table 15: Number of Barangays with Access to MRFs in CYs 2020 to
August 2022 .................................................................................... 26
Table 16: PDP Targets, DENR-EMB Reported Actual Number of Barangays
Served by MRF, and Actual Percentage ........................................ 26
Table 17: Reasons for Non-Operation of EMB-funded MRFs ......................... 28
Table 18: MRF Validation Findings – Not Established .................................... 28
Table 19: Fabrication of Caged MRF............................................................... 35
Table 20: DENR Fund Support Options for LGU Beneficiaries ....................... 36
Table 21: Disaggregated Data on Percentage of LGUs with SLF Access by
Region in CY 2021 and September 2022 ........................................ 38
Table 22: Example of LGUs with Land Condition Limitations .......................... 42
Table 23: Comparative Cost of SLF by Category ............................................ 43
Table 24: Advantages and Benefits of Clustering to LGUs ............................ 44
Table 25: Number of Operating RCAs ............................................................. 54
Table 26: Sample RCA Observations from the Technical Inspections of
COA Engineers ............................................................................... 58
Table 27: No. of LGUs With No Segregation Ordinance and No. of
Operational MRFs ........................................................................... 76
Table 28: Annual Foreign Tourist Arrivals and Regional Travelers from
CYs 2012 to 2020 ............................................................................ 82
Table 29: Computation of Waste Disposed at La Trinidad Cell 3 SLF
Exceeding its Capacity .................................................................... 89
Table 30: Number of SLFs Exceeding their Capacity by Region..................... 89
Table 31: Total Tipping Fees Paid by the LGU La Trinidad, Benguet from
CYs 2018 to 2021 ............................................................................ 90
Table 32: Comparison of Morbidities Between the Exposed Group and
Non-Exposed Group in Dumpsites .................................................. 93
Table 33: Distribution of Barangay Survey Respondents on Waste Collection
Responsibilities by Activity .............................................................. 94
Table 34: Annual Barangay Budget vis-à-vis SWM Budget of Sample LGUs
by Region ........................................................................................ 94
Table 35: DENR-EMB’s MRF Assistance to LGUs from CYs 2012 to 2021 .... 96
Table 36: DENR-EMB’s Financial Assistance to LGUs for the
Establishment of MRF and Fabrication of SWM Equipment
from CYs 2012 to 2019 ................................................................... 96
Table 37: Outstanding Balances of Financial Assistance to LGUs for the
Establishment of MRFs as at December 31, 2021, and June 30,
2022 ................................................................................................ 97
Table 38: Aging of DENR-EMB Outstanding Financial Assistance to LGUs
for the Establishment of MRFs as at June 30, 2022........................ 98

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Table 39: Fund Transfers to LGUs With No Liquidation Since Grant Year
as at June 30, 2022 ......................................................................... 98
Table 40: LGUs with Full Refund of Financial Assistance as at
June 30, 2022 .................................................................................. 99
Table 41: Fund Support for SWM Equipment from DENR-EMB Central Office
by Region from CYs 2016 to 2021 ................................................ 101
Table 42: Total Value of Equipment Reported as Not Operational by Region
from CYs 2016 to 2021 ................................................................. 101
Table 43: Distribution and Value of Not Operational Equipment by Cause ... 102
Table 44: Distribution of Not Operational SWM Equipment by Cause and
Source ........................................................................................... 103
Table 45: No. of MRFs Without Daily Records and Weighing Equipment ..... 104
Table 46: Functions, Targets, and Deliverables of EnMOs ........................... 110
Table 47: SWEEP and EnMOs Accomplishments......................................... 112
Table 48: LGUs with M/CENRO Position ...................................................... 112
Table 49: Diverted Recyclable Waste Materials through Partnership with
PHINLA and Limadol from 2nd Quarter 2021 to 1st Quarter 2022
(in kilograms) ................................................................................. 118
Table 50: Income Generated from Diverted Recyclable Materials through
Partnership with PHINLA and Limadol from 2nd Quarter of CY 2021
to 2nd Quarter of CY 2022 .............................................................. 119
Table 51: Examples of Private Companies Accepting Wastes from LGUs ... 121
Table 52: Various Funding Requests from NSWMC ..................................... 123
Table 53: NSWMC Accomplishments............................................................ 124
Table 54: NEC Guidelines ............................................................................. 126
Table 55: Comparison of NEC under RA 9003 and Amendments in
RA 11898 ...................................................................................... 128
Table 56: Barangays or LGUs with Multiple and Similar Units of SWM
Equipment from EMB, DA, and DOST .......................................... 129
Table 57: Comparison of EMB, DA, and DOST SWM-Related Programs..... 129
Table 58: Tipping Fees Charged to LGUs from CYs 2019 to 2021 ............... 132
Table 59: Summary of the Costs and Benefits of the Basel Ban Amendment
...................................................................................................... 136
Table 60: Reported Illegal Waste Imported to the Philippines ....................... 137

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Acronyms

3R Reduce, Reuse, Recycle

5R Refuse, Reduce, Reuse, Recycle, Recover
ADB Asian Development Bank
AQM Audit Query Memorandum
BARMM Bangsamoro Autonomous Region in Muslim Mindanao
BOC Bureau of Customs
BSWM Bureau of Soils and Water Management
BTr Bureau of Treasury
CAR Cordillera Administrative Region
CDO Cease and Desist Order
CFDF Categorized Final Disposal Facilities
CHB Concrete Hollow Block
CLUP Comprehensive Land Use Plan
CO2eq Carbon Dioxide Equivalent
COA Commission on Audit
CRERDEC Coastal Resources and Ecotourism Ecosystems Research and
Development Extension Center
CSWMP Coalition of Solid Waste Management Providers
CY Calendar Year
DA Department of Agriculture
DAO DENR Administrative Order
DBM Department of Budget and Management
DENR Department of Environment and Natural Resources
DFA Department of Foreign Affairs
DILG Department of Interior and Local Government
DOH Department of Health
DOST Department of Science and Technology
DTI Department of Trade and Industry
ECC Environmental Compliance Certificate
EMB Environmental Management Bureau
EnMOs Environmental Monitoring Officers
EPR Extended Producer Responsibility
ERDB Ecosystems Research and Development Bureau
ESWM Ecological Solid Waste Management
FNRI Food and Nutrition Research Institute
FTA Foreign Tourist Arrival
GAA General Appropriations Act
GAD Gender and Development
GI Galvanized Iron
GIA Grants-in-Aid
GMA General Mariano Alvarez
GWP Global Warming Potential
HDPE High Density Polyethylene
HUCs Highly Urbanized Cities
IEC Information, Education and Communication
IPPU Industrial Processes and Product Use
IRR Implementing Rules and Regulations

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Acronyms

ISSAI International Standards of Supreme Audit Institutions

LGU Local Government Unit
M/CENRO Municipal/City Environmental and Natural Resources Officer
MC Memorandum Circular
MGB Mines and Geosciences Bureau
MIRCA Mintal Resource Collectors Association
MMDA Metro Manila Development Authority
MOA Memorandum of Agreement
MRF Materials Recovery Facility
MRS Materials Recovery System
NCR National Capital Region
NEAP Non-Environmentally Acceptable Products/Packaging
NEC National Ecology Center
NGO Non-Government Organization
NHA National Housing Authority
NOAP National Organic Agriculture Program
NOV Notice of Violation
NSW New South Wales
NSWMC National Solid Waste Management Commission
OECD Organization for Economic Cooperation and Development
PD Presidential Decree
PDP Philippine Development Plan
PEZA Philippine Economic Zone Authority
PPP Public-Private Partnership
PRO Producer Responsibility Organization
PSA Philippine Statistics Authority
RA Republic Act
RCA Residual Containment Area
RT Regional Traveler
SCRP Safe Closure and Rehabilitation Plan
SDG Sustainable Development Goals
SEPO Senate Economic Planning Office
SET-UP Small Enterprise Technology Upgrading Program
SLF Sanitary Landfill
SWEEP Solid Waste Enforcement and Education Program
SWM Solid Waste Management
SWMD Solid Waste Management Division
SWMP Solid Waste Management Program
TSO Technical Services Office
TWG Technical Working Group
ULABs Used Lead Acid Batteries
ULAP Union of Local Authorities of the Philippines
UN United Nations
UNIO United Nations and International Organizations Office
VMLS Vitas Marine Loading Station
WACS Waste Analysis and Characterization Studies
WEEE Waste Electrical and Electronic Equipment

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REPUBLIC OF THE PHILIPPINES

COMMISSION ON AUDIT
Commonwealth Avenue, Quezon City

April 11, 2023

Honorable MARIA ANTONIA YULO LOYZAGA

Secretary, Department of Environment and Natural Resources, and
Chairperson, National Solid Waste Management Commission
Quezon City

Dear Secretary Loyzaga:

In line with the Commission on Audit’s (COA) vision to become an enabling

partner of the government in ensuring a better life for every Filipino, we
conducted performance audits to help government agencies better perform
their mandates and achieve program goals and objectives more economically,
efficiently, and effectively.

For CY 2021, COA identified the Solid Waste Management Program (SWMP)
as one of the priority programs for audit due to its significance and projected
impact on the Filipino people and the environment. The Republic Act (RA) No.
9003 or Ecological Solid Waste Management (ESWM) Act, which establishes
a systematic, all-encompassing, and ecological waste management program to
assure the protection of public health and the environment, was passed into law
in January 2001 as part of the efforts to enhance solid waste management. The
ESWM Program is anticipated to support Local Government Units (LGUs) in
putting RA 9003 into effect, particularly in the creation of their 10-year Solid
Waste Management (SWM) Plan, the closure and rehabilitation of dumpsites,
the establishment of Materials Recovery Facilities (MRFs), and the
implementation of an environmentally sound disposal system.

The national government has identified this program as one of the key programs
that primarily contributes to achieving Sustainable Development Goal1 (SDG)
12 Target 12.5 which aims to substantially reduce waste generation through
prevention, reduction, recycling, and reuse.2 It is also reported that achieving
SWM objectives will promote other SDGs, including SDG 11: Sustainable Cities
and Communities and SDG 13: Climate Action. Based on the Philippines’
Adjusted CY 2010 Greenhouse Gas Inventory for Industrial Processes and
Product Use (IPPU) and Waste Sectors, emissions from solid waste account

1
The SDGs are a collection of 17 interlinked global goals designed to be a "shared blueprint for peace and
prosperity for people and the planet, now and into the future". The SDGs were set up in 2015 by the United
Nations General Assembly and are intended to be achieved by 2030.
2
Implementation of Ecological Solid Waste Management Regulations. Retrieved September 7, 2022, from
https://sdg.neda.gov.ph/implementation-of-ecological-solid-waste-management-regulations/

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for about 25 percent or about 6.5 million CO2-eq3, which is mainly from the
decomposition of organic waste in the disposal facilities. Other sources of
emissions in the solid waste sub-sector are methane resulting from the
biological treatment of organic waste (i.e., composting and anaerobic digestion
of waste) and open burning of waste.

However, despite the enactment of the ESWM Act more than two decades ago,
solid waste generation in the country steadily increased from 9.07 million metric
tons in CY 2000 to 16.63 million metric tons in CY 2020. This problem worsened
further due to the increased production of hazardous and infectious wastes
caused by the COVID-19 pandemic. Due to this, stakeholders, including but not
limited to legislators and non-governmental groups, have voiced the same
concern and called for action regarding our increasing waste generation.

This audit aims to determine the (a) extent the program achieves its goals and
objectives; (b) challenges in implementing the program; and (c) the extent the
program implementers administer the program following established policies
and procedures.

We reviewed the program documents, accomplishments, and status reports;

gathered information through surveys from the LGUs, waste facility workers,
households, students, and teachers; interviewed key agency officials, municipal
and city environment and natural resources officers (M/CENROs), non-
government organizations (NGOs), and barangay heads; and assessed the
extent of coordination with other stakeholders. To enhance stakeholder
relations, we adopted a Citizen Participatory Audit approach. This involved
engaging a Citizen Partner who is a former COA Auditor with extensive
knowledge and experience in the field. She assisted us in collecting information
and evidence from CSOs/NGOs and specific barangays. The collection of
information was done through the conduct of surveys and interviews.

The audit scope covers program implementation from CYs 2001 to 2021, with
some information extending until September 15, 2022, to provide timely and
relevant data to stakeholders. We used non-generalizable samples, hence the
data only indicates the presence but not the extent of the condition in the
population.

We conducted our performance audit from June 2021 to September 2022

following the International Standards of Supreme Audit Institutions (ISSAI) 3000
– Standard for Performance Auditing. The standard requires that we plan and
perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit
objectives. We believe the evidence obtained provides a reasonable basis for
our findings and conclusions.

3
Carbon dioxide equivalent (CO2eq) stands for a unit based on the global warming potential (GWP) of different
greenhouse gases. The CO2eq unit measures the environmental impact of one tonne of these greenhouse
gases in comparison to the impact of one tonne of carbon dioxide.

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Background The Republic Act (RA) No. 9003 or the Ecological Solid Waste Management
Act (ESWM) of 2000 provides for adopting a systematic, comprehensive, and
ecological SWMP. This act aims to protect public health and environment;
encourage resource conservation and recovery; promote greater public
participation in the formulation and implementation of the SWM programs;
encourage the private sector in SWM to be complemented by greater use of
market-based instruments and strict enforcement of the provisions of the law;
supporting research on effective technologies and techniques for efficient
SWM and the promotion of environmental awareness.

History. In CY 2000, estimates show that the Philippines generated 19,700

tons of garbage daily (see Table 1). In the same year, the Payatas dumpsite
landslide happened, A large pile of garbage collapsed and went up in flames,
destroying about 100 informal settlers’ houses, killing 2,018 people, and
leaving another 300 people missing under the rotting garbage. This incident
prompted the passage of RA 9003 which mandates the closure of open
dumpsites in the Philippines by 2004 and controlled dumpsites by 2006.

Table 1: Distribution of Waste Generated per Region in CY 2000

Region CY 2000
Tons/day Percentage
National Capital Region 4,953 24.6
(NCR)
Cordillera Administrative 223 1.11
Region (CAR)
1 873 4.33
2 271 1.35
3 2,729 13.56
4 3,935 19.55
5 654 3.25
6 969 4.81
7 1,607 7.98
8 336 1.67
9 417 2.07
10 748 3.72
11 986 4.9
12 432 2.14
Autonomous Region in 253 1.26
Muslim Mindanao
Caraga 314 1.56
PHILIPPINES 19,700 100

Source: National Solid Waste Management Framework 2004

Stakeholders and their respective roles and responsibilities. The National

Solid Waste Management Commission (NSWMC) headed by the Secretary of
the Department of Environment and Natural Resources (DENR) is tasked to
oversee the implementation of SWM plans and prescribe policies to achieve
the objectives of RA 9003 (see Figure 1).

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Figure 1: Revised NSWMC Organizational Framework

Source: RA No. 11898 also known as the Extended Producer Responsibility (EPR) Act of 2022

On the other hand, the Commission shall comprise eight members from the
government sector and five from the private sector. The government sector
shall be represented by the heads of the Department of Science and
Technology (DOST), Department of Health (DOH), Department of Agriculture
(DA), Department of Interior and Local government (DILG), Department of
Trade and Industry (DTI), Metro Manila Development Authority (MMDA), and
the Union of Local Authorities of the Philippines (ULAP). The private sector
shall be represented by three NGO representatives with a track record in SWM
or waste reduction, recycling, and resource recovery, one from Recycling,
Composting, or Resource Recovery and Processing, and one from
Manufacturing, Packaging or Obliged Enterprises.

The RA 9003 also highlighted that local governments (i.e., from provincial,
municipal/cities, and barangay levels) are responsible for enforcing and
implementing the law in their respective jurisdictional areas.

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RA 9003 also established the National Ecology Center (NEC) under the
NSWMC, tasked to collect, prepare and distribute information and conduct
educational and training programs to help implement the SWMPs. The NEC
is also expected to inform the public of the relationship between the generation
of different types of wastes and quantities of solid wastes, alternatives
available to handle these wastes and the implementation of the SWM
hierarchy.

Present situation. More than 20 years after the passage of RA 9003, solid
waste generation in the country has steadily increased from 9.07 million metric
tons in CY 2000 to 16.63 million metric tons in CY 2020 (see Figure 2).

Figure 2: Reported Waste Generation for CYs 2000, 2010 and 2020

Source: NSWMC Status Report 2008-2018, Case Study of RA 9003 Implementation

SWM Hierarchy. The RA 9003 promotes SWM following a hierarchy of

options covering waste management activities, from volume reduction to final
waste disposal. In line with this, the hierarchy also corresponds to the levels
of governance, starting from the households to the province or metro-wide
level of government.

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Figure 3: SWM Hierarchy

Source: National Solid Waste Management Framework 2004

As shown in Figure 3, at the base of the hierarchy are avoiding and reducing
waste. The objective is to reduce the amount of materials and products
entering the waste stream. The basic approach to volume reduction covers
avoidance, product reuse, increased product durability, reduced material uses
in production, and decreased consumption. The next level of the hierarchy is
recycling and recovery, which differs from volume reduction since it involves
the recovery of products from the waste stream. At this level of the hierarchy,
a critical aspect is the MRF, which will separate, clean, and prepare the
recyclables for marketing or segregate only the biodegradables for commercial
composting. These five levels, from volume reduction to recycling and
recovery, constitute the first preferred options under the waste management
hierarchy. The last two levels of the waste hierarchy considered the last
preferred option under the waste management hierarchy is treatment and
disposal.

Mandated Waste Facilities. The RA 9003 has mandated the establishment

of MRF in every barangay or cluster of barangays to enable waste diversion
at the local level. An MRF shall be designed to receive, sort, process, and
store compostable and recyclable material efficiently and in an
environmentally sound manner (see Figure 4).

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Figure 4: Materials Recovery Facility (MRF)

Source: RA 9003, Section 33 - COA Analysis

The MRF shall receive mixed waste for final sorting, segregation, composting,
and recycling. The resulting residual wastes shall be transferred to LGU’s
long-term storage or disposal facility or sanitary landfill (SLF).

Figure 5: Typical SLF System

Source: Technical Guidebook on Solid Waste Disposal Design and Operation

An SLF is a disposal site designed, constructed, operated, and maintained in

a manner that exerts engineering control over significant potential
environmental impacts arising from the development and operation of the

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facility (see Figure 5). The basic operational controls include the following:
leachate collection and treatment systems, landfill gas management, waste
compaction, application of soil cover, all-weather primary and access roads,
trained labor force, and a ban on waste pickers, among others. Site design is
based on Hydrogeological considerations, while site preparation includes
surface run-off control and containing earth movements.4

Some qualities of an SLF include a natural impermeable lower layer to block

the movement of leachate into ground water; a leachate collection system;
gravel layers permitting the control of methane; and daily covering of garbage
with soil. In sanitary landfilling, wastes are compacted and covered at the end
of each day.

DENR Administrative Order (DAO) No. 10, Series of 2006 refers to Guidelines
on the Categorized Final Disposal Facilities (CFDF) into four categories (see
Table 2) based on net residual waste generation, after considering the waste
diverted through composting, recycling, and recovery efforts as well as the
environmental, financial, and socio-economic conditions of the LGUs,
including its hydro-geological dimensions. These guidelines comply with
Sections 37, 40, 41, and 42 of RA 9003 and its Implementing Rules and
Regulations (IRR).

Table 2: SLF Categories

Features Category 1 Category 2 Category 3 Category 4

(< 15 tons/day) (> 15 tons/day to 75 (> 75 tons/day to 200 (> 200 tons/day)
tons/day) tons/day
Daily and Intermediate ✔ ✔ ✔ ✔
Soil Cover
Embankment / Cell ✔ ✔ ✔ ✔
Separation
Drainage Facility ✔ ✔ ✔ ✔
Gas Venting ✔ ✔ ✔ ✔
Leachate Collection ✔ ✔ ✔ ✔
Leachate Treatment Pond System Pond System Pond System Combination of
physical, biological &
chemical
Leachate Recirculation At a later stage of At a later stage of At a later stage of Treatment
operation operation operation
Clay liner At least 60 cm thick At least 75 cm thick
and has a permeability and has a permeability
of 10-5 cm/sec of 10-6 cm/sec
Clay liner and/or Clay liner at least 75 Synthetic liner at least
synthetic liner cm thick and has a 1.5mm thick HDPE
permeability of 10-7 membrane over at
cm/sec or better. If not least 60 cm thickness
available, an of compacted clay
equivalent materials with
replacement would be permeability no more
a composite liner than 10-7 cm/sec
consisting of at least
1.5mm thick High
Density Polyethylene
(HDPE) membrane

4
Technical Guidebook on Solid Waste Disposal Design and Operation

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Features Category 1 Category 2 Category 3 Category 4

(< 15 tons/day) (> 15 tons/day to 75 (> 75 tons/day to 200 (> 200 tons/day)
tons/day) tons/day
over at least 60 cm
thickness of
compacted fine
materials with
permeability no more
than 10-6 cm/sec

Source: DAO No. 10

On the other hand, RA 9003 prohibits the use of open dumpsites and promotes
the conversion or upgrading of such into a controlled facility within three years
upon effectivity of RA 9003, provided that controlled dumpsites shall no longer
be allowed five years following the effectivity of RA 9003.

Budget and Resources. To finance SWM, RA 9003 mandated the creation

of the SWM Fund to be administered by the NSWMC. This Fund shall finance
products, facilities, technologies, and processes to enhance proper SWM,
awards and incentives, research programs, information, education,
communication and monitoring activities, technical assistance, capability
building activities, and approved SWM plans of LGUs. Overall, this Fund shall
be made available to the NSWMC, the NEC, and LGUs to achieve and perform
their roles and responsibilities for achieving the goals of SMWP. However,
according to DENR-EMB, this Fund was not yet established. Hence, the
budget for SWMP was spread through various agencies and LGUs. Also, it
varies per agency and LGU. At this point, there was no document
consolidating all SWMP-related expenditures.

Available data shows that the total accumulated funds allocated for SWMP
were at least ₱47.997 billion as at CY 2021 (see Table 3).

Table 3: Sample Government Agencies Budget for SWMP

Year DENR-EMB MMDA 250 LGUs5 TOTAL

2001 / / / /
2002 ₱261,795,000 ₱665,564,000 / ₱927,359,000
2003 / / / /
2004 / / / /
2005 193,775,000 665,564,000 / 859,339,000
2006 / / / /
2007 215,154,000 775,564,000 / 990,718,000
2008 264,957,000 1,302,709,000 / 1,567,666,000
2009 352,935,000 1,302,709,000 / 1,655,644,000

5
We requested all LGUs to submit relevant SWM information through Google Forms. However, only 591
out of 1,634 LGUs have responded, and only 250 LGUs submitted budget information for CYs 2019 to 2021.

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Year DENR-EMB MMDA 250 LGUs5 TOTAL

2010 494,954,000 1,076,599,000 / 1,571,553,000
2011 458,165,000 518,621,000 / 976,786,000
2012 502,931,000 793,068,000 / 1,295,999,000
2013 735,816,000 898,538,000 / 1,634,354,000
2014 1,215,589,000 898,538,000 / 2,114,127,000
2015 712,631,000 993,538,000 / 1,706,169,000
2016 591,921,000 1,048,538,000 / 1,640,459,000
2017 944,551,000 993,538,000 / 1,938,089,000
2018 910,096,000 1,003,960,000 / 1,914,056,000
2019 733,142,000 933,926,000 6,221,402,145 7,888,470,145
2020 1,471,978,000 1,989,973,000 6,427,670,103 9,889,621,103
2021 632,922,000 2,549,016,000 6,245,277,465 9,427,215,465
TOTAL ₱10,693,312,000 ₱18,409,963,000 ₱18,894,349,713 ₱47,997,624,713
/Data is not available

Source: General Appropriations Acts (GAA) and LGU data

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For more than 20

years since the
enactment of RA
9003, waste
management has
remained an issue
as waste generation
continues to
increase
Since the passage of RA 9003 more than 20 years ago, waste management
has continued to be an issue of concern, made even more pronounced by a
projection that annual solid waste generation will rise from 16.63 million metric
tons in CY 2020 to 19.76 million metric tons in CY 2030 and 24.50 million tons
in CY 2045 with the increase in population, rapid economic growth, and
industrialization. Also, our audit found delays in the preparation and approval
of LGUs’ 10-yr SWM Plan, and the total number of MRFs and SLFs was
inadequate to service all barangays and LGUs nationwide. As a result, a
number of LGUs were also left with no other resort but to reopen or establish
new illegal dumpsites.

Solid waste One of the primary goals of RA 9003 is to reduce waste to benefit the
environment and public health. Similarly, this is also in line with SDG Target
generation is 12.5, which aims to substantially reduce waste generation through prevention,
continually reduction, recycling, and reuse. However, more than 20 years after the
increasing and is enactment of RA 9003, the municipal solid waste generated has been
projected to projected to increase from 9.07 million metric tons in CY 20006 to 16.63 million
metric tons in CY 2020. Therefore, assuming a steady rate of waste generation,
increase further in solid waste production shall continue to increase in future years, negating its
future years goal of reducing waste.

By definition, waste generation is the act or process of producing solid waste.

For every waste generated, there exist two pathways (see Table 4). A
significant amount of the waste is aimed to be diverted through reuse,
recycling, composting, and other resource recovery activities. The remaining
waste not diverted must be safely disposed of in a final disposal facility.

Table 4: Waste Generation Formula

𝑊𝑎𝑠𝑡𝑒 𝐺𝑒𝑛𝑒𝑟𝑎𝑡𝑒𝑑 = 𝑊𝑎𝑠𝑡𝑒 𝐷𝑖𝑣𝑒𝑟𝑡𝑒𝑑 + 𝑊𝑎𝑠𝑡𝑒 𝐷𝑖𝑠𝑝𝑜𝑠𝑒𝑑 (𝑖𝑛 𝑡𝑜𝑛𝑠)

Source: New South Wales (NSW) Environment Protection Authority

6
Case Study on RA 9003 Policy Implementation

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On the other hand, for a specific economic area, the waste generated per
capita is used to evaluate the intensity of waste generation in an area that has
varying economic activities from another (see Table 5).

Table 5: Waste Generated per Capita

𝑊𝑎𝑠𝑡𝑒 𝐺𝑒𝑛𝑒𝑟𝑎𝑡𝑒𝑑
𝑊𝑎𝑠𝑡𝑒 𝐺𝑒𝑛𝑒𝑟𝑎𝑡𝑒𝑑 𝑝𝑒𝑟 𝐶𝑎𝑝𝑖𝑡𝑎 =
𝑃𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛

Source: NSW Environment Protection Authority

To compute the previously mentioned projected waste generation, the DENR-

EMB used the 2010 waste generation per capita as a base.7 The waste
generation per capita for the Philippines is 0.4 kg/capita per day (weighted
average). However, the distribution of waste generation differs from urban to
rural. More waste was produced in densely populated cities and municipalities,
which was traced to Metro Manila, the capital of the Philippines, with a rate of
0.61 kg/capita per day. Moreover, if other highly urbanized cities (HUCs) were
included, the rate would increase to 0.69 kg/capita per day. On the other hand,
compared to the urban areas, the rural areas produce significantly lesser
waste, as shown, with a rate of 0.31 kg/capita per day (see Table 6).

Table 6: Philippines’ Waste Generation per Capita

Sample size (as % Range Weighted Average

Scope/ Coverage
of demographics) kg/ capita/ day
PHILIPPINES (Nationwide) 79% 0.10-0.79 0.40

Metro Manila (NCR) 100% 0.27-1.00 0.61

Metro Manila and some
Not available 0.27-1.00 0.69
HUCs
Other cities and provincial
capitals (excluding Not available 0.29-0.64 0.50
NCR/HUCs)
All LGUs in the country,
76% 0.10-0.71 0.34
excluding Metro Manila
Municipalities (cities and
some capital towns Not available 0.10-0.64 0.31
excluded)

Source: DENR Data

Hence, using the 0.4kg/capita per day (weighted average) waste generation
rate in the Philippines, the total estimated waste generation increased from
CYs 2010 to 2020. From 13,481,326 metric tons in CY 2010, the volume has

7
National Solid Waste Management Status Report 2008-2018, published by NSWMC

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been projected by NSWMC to grow to 16,628,026 metric tons in CY 2020 (see

Figure 2).

However, even the calculated waste generation per capita computed by the
DENR-EMB was not fixed. In a 2012 paper, the World Bank also estimated
that solid waste generation will double to 0.9 kg/capita per day by CY 2025,
an increase of 400 grams of waste produced per person daily8.

In Metro Manila alone, the estimated waste generation report9 from the MMDA
shows that in CY 2015, the amount of waste estimated to be generated was
16,499,825.00 cubic meters. After five years, in CY 2020, it has increased to
22,003,784.58 cubic meters (see Table 7). Based on the six-year period from
CYs 2015 to 2020, the total estimated waste generation grew by 33.36
percent, or at a rate of 5.56 percent annually.

Table 7: Metro Manila’s Estimated Waste Generation Report

Budgeted Waste Actual Waste

Estimated Waste
Year Requirement Based on Disposed of
Generation (cu.m.)
55% EWG (cu.m.) (cu.m.)
2015 16,499,825.00 9,074,903.75 10,269,460.15
2016 19,212,602.70 10,566,931.49 10,720,031.08
2017 19,740,973.90 10,857,535.65 10,334,449.28
2018 20,449,260.05 11,247,093.03 11,608,753.54
2019 21,210,993.15 11,666,046.23 11,950,709.90
2020 22,003,784.58 12,102,081.52 12,054,818.89
January -
22,774,711.55 12,526,091.35 6,169,334.55
June 2021

Source: Metro Manila Waste Disposal (2015-2021), MMDA

8
Hoornweg, D. and Bhada-Tata, P. (2012, March). What a Waste: A Global Review of Solid Waste
Management. Retrieved January 4, 2023, from https://www.researchgate.net/publication/306201760_
What_a_waste_a_global_ review_ of_solid_waste_management
9
Metro Manila Waste Disposal, 2015-2021, Metro Manila Development Authority Report

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What are the sources of all these wastes? According to RA 9003, the
computation of estimated solid waste generation and projection in the
Philippines is referred to by source, such as residential, market, commercial,
industrial, construction/demolition, street waste, agricultural, agro-industrial,
institutional, and other wastes. On the other hand, according to the NSWMC
Framework, the primary source of waste comes from the household level and
the institutional/commercial level (see Figure 6).

Figure 6: SWM System

Source: NSWMC Framework 2004

Based on the latest available data summarizing the composition of waste in

the Philippines using the Waste Analysis and Characterization Studies
(WACS)10, presented in Figure 7, are the sources of municipal solid wastes in
the Philippines. Residential wastes form the majority of the waste at 56.7
percent, followed by commercial waste at 27.1 percent. The commercial waste
was further classified as commercial market waste at 18.3 percent and other
commercial waste at 8.8 percent. This was followed by institutional waste at
12.1 percent, and the least source of waste was an industrial waste at 4.1
percent.

10
Composition and sources of municipal solid wastes in the Philippines, 2008-2013, NSWMC Status Report
2008-2018

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Figure 7: Percentage Distribution of Municipal Solid Wastes by Source

from CYs 2008 to 2013

Source: NSWMC Status Report 2008-2018

As to the composition (see Figure 8), most were biodegradable wastes at 52.3
percent, followed by residual wastes at 18.0 percent. Special wastes comprise
1.9 percent of the waste composition, while the remaining 27.8 percent were
accounted for as recyclable wastes. The recyclable wastes were broken down
as follows: the majority comprises plastics at 10.6 percent, followed by paper
and cardboard at 8.7 percent. Although small in contribution, metals also
composed the recyclables group at 4.2 percent, glass at 2.3 percent, textile at
1.6 percent, and leather and rubber at 0.4 percent.

Figure 8: Percentage Distribution of Composition of Municipal Solid

Wastes from CYs 2008 to 2013

Source: NSWMC Status Report 2008-2018

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We identified at least seven major causes attributed to the failure to reduce

waste over the years substantially. Some will be discussed further in the
succeeding chapters.

1. Interventions to reduce the waste generators (e.g., households and

industrial/commercial), starting with IEC campaigns.
2. Increasing population, with challenges in family planning, especially in
urban areas.
3. Lack of studies on materials with reusability/ recyclability that can be
promoted.
4. Dependence on single-use items without exception to Non-
Environmentally Acceptable (NEAP) Products, especially in urban
areas.
5. Waste imports from developed countries were still enforced in the
absence of ratification of the Basel Ban Amendment
6. Prevalence of COVID-19 household and healthcare waste since 2020.
7. Insufficient solid waste facilities to help divert and safely dispose of solid
wastes.

To highlight one of the identified causes, waste avoidance is also given little
importance in the waste management programs of LGUs, even as it was the
first preferred option in the waste management hierarchy (see Figure 3).
Avoidance refers to an action to reduce the amount of waste generated by
households, industries, and all levels of government. It is also the waste
management hierarchy's most important but challenging component.
However, despite different IEC campaigns or information dissemination to
communities, implementing waste prevention or avoidance remains
challenging, according to LGUs. We gathered from LGU interviews that
changing people’s attitudes were critical to a successful waste avoidance
program. However, shifting towards positive social acceptance and
responsibility has also remained challenging for them.

Unless the above causes are addressed, furthering the extent of waste
generation’s effect will result in the projected annual waste generation11 of
19,764,384.95 metric tons in CY 2030 to 24,499,946.53 metric tons in CY
2045 (see Figure 9). With this scenario, the Philippines is yet to come closer
to achieving SDG Target 12.5 of substantially reduced waste generation by
2030.

11
Because of the absence of actual data on waste generation, we used the projections of NSWMC to
forecast the future waste generation, provided that no interventions are made.

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Figure 9: Projected Waste Generation for CYs 2010 to 2045

Source: COA Extended Waste Projection for CYs 2030 to 2045, from DENR Waste
Projection for CYs 2010 to 2020.

Moreover, we compared the projected increase in waste generation12 with the

manner of growth of SWM facilities that were expected to receive all residual
and special wastes after solid waste diversion (see Table 8). At the rate the
waste generation continues to increase, there is also a need to increase the
rate at which these facilities need to be established and remain operational to
ensure that the amount of solid waste can still be treated in an environmentally
safe and sound manner. If left unsolved, this looming amount of waste is
susceptible to more problems as it goes into the waste stream, causing stress
to public health and increasing waste management costs, which will be further
discussed in the following chapters.

Table 8: Comparison of Population, Established MRFs, and SLFs from

CYs 2010 to 2021
Established MRFs for Established SLFs for
Year Population
Solid Waste Diversion Solid Waste Disposal
2010 94,636,700 6,957 33
2011 96,337,913 7,312 34
2012 98,032,317 7,713 44
2013 99,700,107 8,486 55
2014 101,325,201 8,656 86
2015 103,031,365 9,335 101
2016 104,875,266 9,883 118
2017 106,738,501 10,052 135
2018 108,568,836 10,340 165
2019 110,380,804 10,722 187
2020 112,190,977 11,546 241
2021 113,880,328 11,637 245

Source: Macrotrends LLC and DENR Data

12
Projected without COVID-19 household and healthcare waste.

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Lastly, the addition of COVID-19 household and healthcare wastes, as well as

imported wastes coming from developed countries (to be discussed in the
succeeding chapters), shall also contribute to the growing waste situation, with
all its challenges and setbacks.

Delay in LGUs’ The development of 10-year SWM Plans13 is mandated in RA 9003 to serve
as the blueprint for LGUs to implement SWM. However, over two decades after
implementation of adopting the law, gaps remain in various areas, starting with the delay in the
10-year SWM plans submission, review, and approval of the 10-yr SWM Plans, and the absence of
active SWM Boards at the provincial, city/municipal, and barangay levels.

According to the National Solid Waste Management Framework published by

the NSWMC in CY 2004, RA 9003 placed particular importance on planning
as a basis for the rational implementation of the SWM strategy. It was
reiterated that preparing the national framework and the requirement for LGUs
to prepare their respective 10-yr SWM Plans emphasizes the indispensability
of planning in the entire spectrum of strategy implementation. The 10-yr SWM
Plan shall ensure the long-term management of solid waste.

Hence, the submission of SWM Plans by the local government was mandated
at the provincial, city, and municipal levels by the respective SWM Boards
instituted at the provincial level and at the city and municipal level per Sections
11(1) and 12(1) of RA 9003, respectively. The Provincial SWM Boards shall
develop the provincial SWM Plan from the submitted 10-yr SWM Plans of the
respective City and Municipal SWM Boards. Similarly, the City and Municipal
SWM Boards shall develop the city or municipal SWM Plan by integrating the
various SWM plans and strategies of the barangays in its area of jurisdiction.

On the other hand, as part of the powers and functions of the NSWMC in
fulfilling its oversight arrangements, per Section 5(b) of RA 9003, they are
mandated to approve local SWM Plans following its rules and regulations.
Moreover, the NSWMC shall develop a model provincial, city, and municipal
SWM Plan to establish content and format prototypes.

Delay in submission, review, and approval of the 10-yr SWM Plans. As at

December 2021, out of the 1,716 expected 10-yr SWM Plans to be enforced
by the LGUs nationwide, 96.27 percent or 1,652 were prepared and submitted
by the LGUs (see Table 9). The remaining 3.73 percent (64) were still for
submission, with the majority coming from Bangsamoro Autonomous Region
in Muslim Mindanao (BARMM) Region.

13
Hereinafter shall be referred to as the “10-yr SWM plan”

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Table 9: CY 2021 Status of Submission and Review of 10-yr SWM Plans

Submitted
Not yet Grand
Region Under Total Plans submitted Total
Approved
Evaluation Submitted (D) (E=C+D)
(A)
(B) (C=A+B)
NCR 17 0 17 1 18
CAR 77 6 83 0 83
1 76 53 129 0 129
2 69 28 97 1 98
3 123 14 137 0 137
4A 106 41 147 0 147
4B 38 40 78 0 78
5 39 81 120 0 120
6 118 21 139 0 139
7 90 46 136 0 136
8 77 71 148 1 149
9 54 21 75 0 75
10 92 6 98 0 98
11 48 6 54 0 54
12 45 8 53 0 53
13 78 0 78 0 78
BARMM 44 19 63 61 124
TOTAL 1,191 461 1,652 64 1,716
% 69.41% 26.86% 96.27% 3.73% 100.00%

Source: DENR-EMB Data

Of the 1,652 submissions, 69.41 percent or 1,191 10-yr SWM Plans were
approved by the NSWMC, while the remaining 28.86 percent (461) were under
review and evaluation. A 10-yr SWM Plan under review and evaluation covers
those with pending submission of additional data, mostly involving budgetary
requirements and specifics on proper final disposal facilities.

Based on the review of documents and interviews conducted, we found delays

in submitting, reviewing, and approving the 10-yr SWM Plans. Figure 10
shows that submissions started as early as CY 2003, while the review and
approval process of the NSWMC commenced only in CY 2010. The bulk of
the submissions ranged from CYs 2014 to 2019, while the plans’ approval
started to gain traction from CYs 2015 to 2017. Without a timely prepared and
approved SWM Plan, the local governments lack a basis for planning their
SWM activities and the required budget for implementation.

According to NSWMC, they do not approve submissions from LGUs with an

operating open dumpsite unless there is evidence of closure and a Safe
Closure and Rehabilitation Plan is in place. On the other hand, if they see that
the site proposal for SLF establishment and institutionalization of
Municipal/City Environmental and Natural Resources Officer (M/CENRO) are
in the plan but will commence beyond the incumbent mayor’s term, they will
ask them to move it within the current term, before approval.

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Figure 10: Submission and Approval of 10-yr SWM Plans from CYs 2003 to 2021

Source: COA Analysis of Submitted and Approved 10-yr SWM Plans

According to DENR-EMB, the NSWMC has only released an Annotated

Outline14 to LGUs to guide them in developing their respective 10-yr SWM
Plans. This was contrary to Section 5(f) of RA 9003, which mandates NSWMC
to develop a model SWM Plan that provinces, cities, and municipalities can
use to meet the 10-yr SWM Plan requirement. Accordingly, this resulted in the
delay of submission to the NSWMC, with the bulk of submissions only
occurring in CY 2014, 14 years after RA 9003 was enacted. This failure of
NSWMC to provide a model SWM Plan highlighted the lack of national policy
to guide the local governments in preparing the 10-yr SWM Plans as
mandated under the law.

Furthermore, personnel and evaluation process limitations were among the

challenges in fast-tracking the review and approval of submitted plans.
According to DENR-EMB, approval takes time as the 10-yr SWM Plans
undergo first and second-level reviews from the DENR-EMB Regional Offices
up to the DENR-EMB Central Offices, which takes up to 30 days maximum for
each level according to the guidelines.15 And once the bulk of submissions
came through, NSWMC shouldered the expedition of review and approval of
the submitted plans as part of their mandate based on the said law.

In CY 2018, the NSWMC established an Executive Committee16 to expedite

reviewing and deliberating the submitted 10-yr SWM plans to mitigate those

14
This Annotated Outline consists of 13 parts, namely: Executive Summary, Introduction, City Profile,
Current Solid Waste Management Conditions, Waste Characteristics, Legal/Institutional Framework, Plan
Strategy, SWM System, Implementation Strategy, Institutional Aspects, Social and Environmental Aspects,
Cost Estimates /Financial Aspects, and Plan Implementation.
15
NSWMC Resolution No. 39, Series of 2009: Resolution Amending NSWMC Resolution 8 re: Guidelines
on the Review and Approval of the 10-Year Solid Waste Management Plans of Local Government Units
(LGUs)
16
NSWMC Resolution No. 1081, Series of 2018: Resolution Establishing the Executive Committee for the
Review and Deliberation of the 10-Year Solid Waste Management Plans

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delays. This resulted in a commendable increase in the number of plans

approved. As at the latest figures, 27.7 percent (476) of the 1,716 submissions
are awaiting approval. This commitment of the NSWMC to expedite the
approval of the 10-yr SWM Plan submissions following its rules and
regulations will grant the local government basis for properly implementing
their SWM activities with the appropriate budget required.

Absence of active SWM Boards at the provincial, city/municipal, and

barangay level. Another gap resulting in the delay of submission of the 10-yr
SWM Plan was the insufficiency of active SWM Boards for the provincial, city,
or municipal levels that will ensure the preparation of SWM Plans. In a 2017
report by the Senate Economic Planning Office (SEPO)17, only 67.1 percent
of SWM Boards were instituted and remained active at the provincial level,
37.6 percent at the city/municipal level, and 13.2 percent at the barangay level
as presented in Table 10.

Table 10: No. of Active Barangay, City/Municipal and Provincial SWM Boards

Province-Level City/ Municipal-Level Barangay-Level

% % % % % %
Region No. of Created Active No. of Cities/ Created Active No. of Created Active
Provinces SWM SWM Municipalities SWM SWM Barangays SWM SWM
Boards Boards Boards Boards Boards Boards
NCR 1 100 100 17 100 100 1,710 88.20 No data
CAR 6 100 100 77 100 100 1,178 99.70 99.70
1 4 100 100 125 7.20 7.20 3,267 No data No data
2 5 80 60 93 68.80 52.70 2,311 39.7 20.50
3 7 100 42.90 130 100 26.10 3,102 3.40 3.40
4A 5 100 100 142 86.60 60.60 4,019 80.80 16.90
4B 5 100 100 73 100 47.90 1,460 99.80 39.40
5 6 100 100 114 50 50 3,471 5.10 4.60
6 6 100 16.70 133 92.50 72.90 4,051 99.70 0.70
7 4 100 100 132 No data 3.80 3,003 No data 0.50
8 6 50 50 143 66.40 36.40 4,390 21.10 6
9 3 100 100 72 83.30 69.40 1,904 68.30 44.60
10 5 60 No data 93 5.40 No data 2,022 2.40 No data
11 5 80 60 49 93.90 57.10 1,162 99.10 69.40
12 4 80 75 50 88 No data 1,195 74.10 No data
13 5 100 100 73 100 24.60 1,311 99.90 32
BARMM 5 No data No data 118 No data No data 2,490 No data No data
Total 82 85.40 67.10 1,634 61 37.60 42,046 43.40 13.20

Source: NSWMC CY 2010 Data

There is a significant gap in the number of active SWM Boards, especially at

the barangay level, that will ensure that the planning of SWM activities and
development of the SWM plans are followed through up to the provincial level.
Moreover, this affected the data collection and monitoring, given that the gap
in active SWM Boards involved the local government’s sufficiency of human
resources to ensure that implementation of the SWM Plans is followed.

17
Philippine Solid Wastes At A Glance. (2017, November). Retrieved January 4, 2023, from
https://legacy.senate.gov.ph/publications/SEPO/AAG_Philippine%20Solid%20Wastes_Nov2017.pdf

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Waste diversion One of the mechanisms in place to assess the goals and objectives of RA 9003
was establishing mandatory solid waste diversion targets by each LGU.
accomplishments However, aside from the limited availability of reliable and complete data to
were far from the measure the success of waste diversion nationwide, LGUs were also finding
targets difficulty in attaining their targets.

RA 9003 defines waste diversion as activities that reduce or eliminate the

amount of solid waste from waste disposal facilities. Reusing, recycling,
composting, and other resource recovery activities can achieve this. Each
LGU is required to divert at least 25 percent of solid waste within five years
from the adoption of RA 9003, and this goal shall increase every three years
thereafter.

The law also mandates each LGU to include an implementation schedule for
waste diversion targets to prepare their respective 10-yr SWM Plans. Table
11 shows the consolidated regional waste diversion targets gathered by the
DENR-EMB from the Waste Analysis and Characterization Study (WACS) of
all LGUs with approved 10-yr SWM Plans.

Table 11: Average Percentage of Waste Diversion Targets per 10-yr SWM Plans from CYs 2015 to
2021
Region 2015 2016 2017 2018 2019 2020 2021
NCR 44.3 50.4 53.6 56.8 60.1 62.7 66.0
CAR 46.8 52.8 56.7 59.4 63.2 67.1 70.4
1 47.7 53.4 58.3 61.6 64.9 68.4 71.3
2 66.8 60.9 64.6 65.0 67.6 69.2 71.3
3 55.2 59.5 60.9 64.1 68.1 71.6 75.4
4A 41.8 52.2 57.2 60.7 64.6 68.2 71.6
4B 37.9 42.6 47.4 52.1 54.7 58.5 63.3
5 39.0 36.7 43.3 50.0 58.3 66.7 77.7
6 47.0 52.0 54.5 58.1 62.1 66.1 69.4
7 41.0 49.9 56.8 61.1 66.5 70.1 73.7
8 52.1 58.2 56.5 62.0 65.1 68.4 71.4
9 55.0 62.7 71.3 76.3 79.3 82.0 84.3
10 48.0 55.7 62.6 59.9 62.3 62.1 68.2
11 54.3 64.0 66.4 68.4 70.9 75.1 80.7
12 66.5 68.3 67.7 69.2 71.7 73.9 76.1
13 53.1 58.3 62.3 65.7 69.0 72.1 74.8
BARMM No data 50.0 57.9 60.1 63.2 66.0 69.0
Average 49.8 54.6 58.7 61.8 65.4 68.7 72.6

Source: DENR-EMB Data

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At the national level, the solid waste diversion targets per the Philippine
Development Plan (PDP) 2017-2022 increased from 55 percent in 2017 to 80
percent in 2022 (see Table 12).

Table 12: PDP Targets for Solid Waste Diversion

Year 2017 2018 2019 2020 2021 2022
Nationwide Percentage Targets 55% 60% 65% 70% 75% 80%

Source: PDP 2017-2022

Limited visibility of the nationwide accomplishments on waste diversion.

There was no overall visibility of the nationwide accomplishments on waste
diversion because DENR-EMB’s recording and monitoring were limited to
EMB-funded MRFs from CYs 2012 to 2019. However, this will be reduced to
only operational MRFs with proper documentation and record-keeping
systems. Hence, waste diversion accomplishments from LGUs with or without
MRF, if recorded and maintained, were not readily available from DENR-EMB.
Table 13 shows the number of operational EMB-funded MRFs with complete
data per DENR-EMB. Based on this, only 750 out of 1,171 (64.05 percent)
operational EMB-funded MRFs have maintained and reported complete data.
Provided that only these MRFs produced complete data, any reported total
accomplishments of the regions were only a fraction of the nationwide
population.

Table 13: CY 2019 Operational EMB-funded MRFs with Complete Data

Operational EMB-funded MRFs
EMB-
Operational MRF with Percent of MRF
Region funded
MRFs complete data with complete data
MRFs
(A) (B) (C=B/A)
NCR 133 53 31 58.49
CAR 104 82 11 13.41
1 99 75 74 98.67
2 140 70 64 91.43
3 113 82 70 85.37
4A 110 76 58 76.32
4B 120 50 9 18.00
5 109 60 7 11.67
6 132 88 42 47.73
7 121 90 72 80.00
8 116 90 59 65.56
9 88 79 79 100.00
10 129 77 67 87.01
11 113 64 17 26.56
12 114 67 43 64.18
13 99 68 47 69.12
Total 1,840 1,171 750 64.05

Source: COA Analysis of MRF Summary Report

Further, the Philippines has 42,046 barangays but the DENR-EMB has reliable
data from only 750 MRFs, indicating the deficiency in monitoring data resulting
in the limited visibility of the overall statistics. In addition, deeper causes were

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noted at the micro level regarding the barangay level (see Lack of Recording
Mechanism in MRFs Resulting in Unreliable and Incomplete Data on Waste
Diversion on page 104). These deficiencies validated the constituents’ lack of
data production and collection as performance indicators. Furthermore, SDG
12.5 is classified as Tier 218 by the Philippine Statistics Authority (PSA).
Therefore, unless the corresponding SDG indicator has been included in the
monitoring and follow-up by the PSA, no progress can be tracked on attaining
the SDG target until CY 2030.

Without the necessary record-keeping and data monitoring, data visibility

decreases, and decision-making by government leaders becomes strained.
Thus, there is a need for institutionalized data production and collection
methodology to measure the accomplishments of solid waste diversion.
Without it, the Philippines will remain deprived of timely and relevant data
analysis to aid sound decision-making. Such decision-making involves the
local government’s planning and implementation and the national
government’s estimation of targets.

Non-attainment of solid waste diversion targets for operational MRFs

with acceptable data completeness. The data on waste diversion
accomplishments submitted by the DENR-EMB to us was limited only to data
recorded by EMB-funded operational MRFs and had varying percentages of
data completeness.

To ensure reliable data, we used 85 percent and above as the threshold for
data completeness to support the reported solid waste diversion
accomplishments. Only five out of 16 regions have passed the data
completeness threshold. Among those five, no region has met its target based
on the average rates from the 10-yr SWM Plans. Further, the PDP 2017-2022
national target for CY 2020 is higher than the averaged targets indicated in the
10-yr SWM Plans of 10 out of 16 regions. Therefore, considering the data
completeness threshold, no region could meet the national target of 70 percent
diversion for CY 2020, as shown in Table 14.

Table 14: CY 2020 Waste Diversion Target vis-à-vis Actual Accomplishment

% of MRF Waste Waste % Waste % Waste % Waste

with Generation Diversion per Diversion Diversion Diversion
Region
complete per day (kg) day (kg) Actual Target Variance
data (A) (B) (C=B/A) (D) (E=D-C)
NCR 58.49 1,148,128.83 543,172.64 47.31 62.70 15.39
CAR 13.41 814,813.48 618,416.54 75.90 67.10 -8.80
1 98.67 408,859.92 234,360.92 57.32 68.40 11.08
2 91.43 677,128.00 330,584.00 48.82 69.20 20.38
3 85.37 912,696.07 584,617.71 64.05 71.60 7.55
4A 76.32 1,161,789.00 435,390.00 37.48 68.20 30.72
4B 18.00 77,849.70 44,964.37 57.76 58.50 0.74
5 11.67 18,370.00 11,759.81 64.02 66.70 2.68

18
An SDG performance indicator classified as Tier 2 means it is conceptually clear and has an
internationally established methodology and standards available, but countries do not regularly produce
data.

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% of MRF Waste Waste % Waste % Waste % Waste

with Generation Diversion per Diversion Diversion Diversion
Region
complete per day (kg) day (kg) Actual Target Variance
data (A) (B) (C=B/A) (D) (E=D-C)
6 47.73 61,019.30 23,475.50 38.47 66.10 27.63
7 80.00 209,159.40 103,209.24 49.34 70.10 20.76
8 65.56 349,808.50 258,194.00 73.81 68.40 -5.41
9 100.00 246,855.28 164,586.57 66.67 82.00 15.33
10 87.01 404,153.63 91,019.21 22.52 62.10 39.58
11 26.56 1,142,878.40 14,372.09 1.26 75.10 73.84
12 64.18 478,565.39 175,868.74 36.75 73.90 37.15
13 69.12 407,545.00 183,937.00 45.13 72.10 26.97
TOTAL 64.05 6,910,521.81 3,222,313.67 46.60 68.70 22.07

Source: COA Analysis of Waste Diversion Target and Accomplishment

According to DENR-EMB, the common factors of non-attainment of solid

waste diversion targets were the availability of funds and LGU’s strong support
for implementation. We further noted that the mechanism to implement waste
diversion was strained by the delay in submitting and approving 10-yr SWM
Plans, which should have included those targets (see Delay in LGUs’
implementation of 10-year SWM plans on page 18). In addition, there was a
lack of rewards and incentives to promote waste diversion (see Non-
Establishment of SWM-Mandated Funding Sources on page 123).

Although RA 9003 mandated at least an initial 25 percent waste diversion

within five years after the effectivity of the law and an increase every three
years thereafter, the specific percentage or value of such subsequent increase
was not provided in the said law and its IRR. Hence, since CY 2003, the LGUs
have determined their waste diversion target.

As for meeting the national targets per PDP, the targets presented in Table 12
are considered estimates only to meet the commitment to improving the
management of solid wastes. On the contrary, LGUs were not consulted about
these estimates, resulting in a disparity between the LGUs’ targets and those
from the PDP 2017-2022. By CY 2020, the national target for solid waste
diversion reached 70 percent, which the majority, if not all, of the LGUs have
not attained.

As more waste enters the waste stream, the opportunity for waste diversion
increases. However, not meeting waste diversion targets will result in more
waste being transported to disposal facilities. Consequently, this extra waste
will increase the demand for more disposal facilities resulting in more costs to
the government. In addition, to a greater extent, this extra waste that was not
diverted has the potential to form mixed waste and can harm the environment
and the health of the public.

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The total number of Currently, the Philippines has 42,046 barangays that were mandated to have
access to an MRF, whether solely or clustered with other barangays. However,
MRFs was not based on interviews and validation, the goal of local governments to provide
sufficient to service accessible MRFs for barangays was met with financial, logistical, and technical
all barangays issues. Hence, as at CY 2021, only 16,418, or 39.05 percent of barangays
nationwide nationwide, are being served by an MRF (see Table 15). The total established
MRFs have yet to comply with RA 9003 to provide access for every barangay
or cluster of barangays. It also has yet to surpass the targets by the national
government in the PDP 2017-2022.

Table 15: Number of Barangays with Access to MRFs in CYs 2020 to

August 2022
Total with MRF without MRF % with MRF
Year Barangays access access access
(A) (B) (C) (D=B/A)
2020 42,046 14,450 27,596 34.37
2021 42,046 16,418 25,628 39.05
August
42,046 17,047 24,999 40.54
2022

Source: DENR-EMB Data

Aside from the RA 9003, there was also the national government’s target
number of barangays that MRFs should serve for the CYs 2017 to 2022.
Based on the PDP, the national government targeted a five percent annual
increase in the barangays that should be serviced by an MRF in pursuance of
the total service target. However, the percentage targets set in the PDP were
not met with a growing disparity, ranging from -3.3 percent as at CY 2017, to
-19.45 percent as at August 2022, respectively. As of latest data, there are
8,174 barangays which are still not yet served by an MRF against the CY 2022
target as at August 2022 (see Table 16).

Table 16: PDP Targets, DENR-EMB Reported Actual Number of

Barangays Served by MRF, and Actual Percentage
Percentage Barangays
Target No. Percentage
Percentage of Actual Actual No. of Served,
of Difference,
Target per No. of Barangays Actual
Year Barangays Actual Less
PDP Barangays Served by an Less
Served by Target
(A) Served by MRF (D) Target
an MRF (B) (E=C-A)
an MRF (C) (F=D-B)
2017 34.99 14,712 31.69 13,324 -3.3 -1,388
2018 39.99 16,814 32.37 13,612 -7.62 -3,202
2019 44.99 18,916 33.28 13,994 -11.71 -4,922
2020 49.99 21,018 34.37 14,450 -15.62 -6,568
2021 54.99 23,119 39.05 16,418 -15.94 -6,701
2022 59.99 25,221 40.54 17,047* -19.45 -8,174
*Data as at August 2022 only

Source: PDP 2017-2022, DENR-EMB Data

Although nationwide MRF coverage has yet to be achieved, the goal to provide
barangays access to MRFs is still supported by the continuous increase in the
establishment of MRFs. MRF establishments increased steadily between CY

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2010 and CY 2021. Since CY 2010, MRFs have increased by 67.27 percent,
going from 6,957 to 11,637 MRFs (see Figure 11).

Figure 11: MRFs Established from CYs 2010 to 2021

Source: DENR-EMB Data

On a larger scale, while there are 11,637 MRFs all over the country servicing
16,418 (39.05 percent) barangays by the end of CY 2021, there are still 25,628
(60.95 percent) barangays nationwide that do not have access to an MRF.
Even though DENR-EMB extends financial assistance to LGUs for MRF
establishment, this covers only a fraction of the targets. Thus, the goal of RA
9003 still has a long way to go before full service can be achieved at this rate.

Figure 12: Percentage Distribution of Barangays With and Without

Access to MRF for CY 2021

Source: DENR-EMB Data

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To identify the reasons or causes for the gap highlighted in Figure 12, we
interviewed the DENR-EMB and validated selected LGUs. Based on the
interview, the challenges the local governments faced in establishing MRFs
were lack of funds, available land, and the technical know-how on the setup
and operation procedures.

On the other hand, there were three main reasons revealed by the DENR-
EMB as to why 669 (36.3 percent) of the 1,840 MRFs funded from CYs 2012
to 2019 became non-operational (see Table 17).

Table 17: Reasons for Non-Operation of EMB-funded MRFs

Reason for Non-Operation Count Percentage

Already been constructed but has not yet 340 50.82
operated
Still in the construction/ procurement stage 313 46.79
Financial issues (e.g., stale checks, 16 2.39
unreleased funds, funds returned to the
National Treasury)
Total 669 100.00

Source: DENR-EMB Data

Moreover, during our validation, it was subsequently found that some EMB-
funded MRFs tagged as operational were not established due to financial and
logistical challenges (see Table 18).

Table 18: MRF Validation Findings – Not Established

Location Observation
Barangay Poblacion Funds were unutilized and remained unliquidated for
East, four years up to the present
Pidigan, Abra
Barangay Mintal, Davao LGU cannot locate a site for the MRF. Funds became
City, idle and, thus, were returned to the Bureau of Treasury
Davao del Sur (BTr)
Barangay Bua, Itogon, Funds were not yet transferred/ turned over by the
Benguet LGU to the barangay, thus, the establishment of an
MRF did not materialize.

Source: COA Validation

Further review disclosed that there were more unutilized and unliquidated
funds similar to Pidigan, Abra, to be discussed in detail in Chapter 2. On the
other hand, Barangay Mintal in Davao City and some LGUs were able to
resolve their lack of land or MRF site and still have good diversion (see
Examples of Best Practices Observed during Validation on page 116). This
includes Masinloc, Zambales, where the barangay (North Poblacion) secured
land for their MRF through a Deed of Usufruct, permissible per RA 9003.

Without access to an MRF, the opportunities for waste diversion become

limited for barangays, and the risk for mixed waste collection and disposal
increases. Hence, the remaining 60.95 percent (25,628 out of 42,046) of

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barangays nationwide that do not have access to MRF must be resourceful in

finding ways to divert waste. Otherwise, these barangays are more prone to
practicing mixed waste collection, the presence of dumpsites, or increased
disposal to SLFs.

MRF Design and Usage. While the local government and the barangays are
responsible for establishing MRFs, DENR-EMB also provided technical and
financial support to the LGUs to implement their 10-yr SWM Plans. Part of this
support was the provision of financial assistance to LGUs in establishing or
upgrading MRFs from CY 2012 to CY 2019. Moreover, complementary to the
establishment of MRF was the provision of shredder and composter that would
reduce the volume and size of biowaste for composting at the MRF as well as
hasten the decomposition process (see Some EMB-funded MRFs, including
several units/sets of equipment, were neither established nor operational on
page 95).

Figure 13: Prescribed Layout for EMB-funded MRFs

Source: DENR Data

The prescribed layout for EMB-funded MRF (see Figure 13) ensures that the
facility can receive, sort, process, and store compostable and recyclable
material efficiently and in an environmentally sound manner. The DENR-EMB
also released a sample layout and dimension of a centralized MRF as a
component of an SLF, as shown in Figure 14.

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Figure 14: Prescribed Layout for Central MRF

Source: DENR Data

To validate how the MRFs were established and operated following the
minimum requirements of RA 9003 and the prescribed layout for EMB-funded
MRFs, we validated a total of 45 MRFs from nine regions, namely: NCR, CAR,
Regions 1, 3, 4A, 5, 7, 9, and 11. In addition, engineers from the Technical
Services Office (TSO) of COA also conducted the technical inspection
accompanied by focal persons from DENR-EMB Regional Offices and LGUs.

A number of EMB-funded MRFs were compliant with DENR-EMB

guidelines on financial assistance. In addition, most of the MRFs we visited
complied with the layout prescribed by the DENR-EMB following Section 33 of
RA 9003 (see Figure 15).

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Figure 15: Inspection of Municipal MRF in Barangay Tagodtod, Lagangilang, Abra

External façade Enclosed area for recyclable raw materials

Enclosed area for waste processing of unsellable bottles Designated area for finished Concrete Hollow Blocks (CHBs)
using crusher/pulverizer equipment made from pulverized unsellable bottles mixed with concrete

Source: COA Validation in the Municipal MRF in Barangay Tagodtod, Lagangilang, Abra, CAR

In Barangay Tagodtod, Lagangilang, Abra, there were portioned areas for raw
residual and recyclable materials and work-in-process materials from working
equipment such as pulverizer, crusher, and molder. In addition, there was also
an area dedicated to the processed residuals.

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Figure 16: Inspection of Various MRFs in Barangay Lote Pto Rivas, Balanga, Bataan

Barangay Lote Pto Rivas, Balanga, Bataan Barangay Poblacion, Maragusan, Davao de Oro

Barangay Pingit, Baler, Aurora Barangay Poblacion, Bucloc, Abra

Source: COA Validation of MRFs in Bataan, Aurora, Davao de Oro and Abra

In Barangay Lote Pto Rivas, Balanga, Bataan, enclosed areas were reserved
for segregating types of waste such as plastic, metal, paper, glass bottle, and
special waste. Highlighted in Figure 16 were some of the validated MRFs that
we found to comply with RA 9003 and the guidelines set by the DENR-EMB
for EMB-funded MRFs.

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On the other hand, we and the TSO engineers found that a number of MRFs
not funded by DENR-EMB did not possess the required waste processing
capabilities (see Appendix III for the other TSO observations).

1. Cage-Type MRFs (hereinafter referred to as “Caged MRF”). Based

on their appearance, these caged MRFs were not designed to process
the waste they can receive (see Figure 17). Instead, the caged MRFs
found in some barangays serve as a receiving area for recyclables,
pending its collection and transfer by the LGU to a bigger and more
centralized MRF. The caged MRFs were located in a barangay
purok19, which formed part of an arranged network and was coined by
the locals as the purok system. In the purok system, a purok leader
was assigned to manage the wastes in their purok and ensure that the
residents could deliver recyclable materials to nearby designated
caged MRFs. The operation of caged MRFs illustrated in the purok
system was beneficial, especially for barangays with narrow and
impassable roads. It is also easier for the LGUs to collect waste
because the pick-up points are lessened when considering these purok
MRFs instead of going house-to-house.

Figure 17: Examples of Caged MRFs

Barangay Cabinuangan, Davao de Oro Barangay Poblacion, Bucloc, Abra

Source: COA Validation of MRFs in Davao de Oro and Abra

According to DENR-EMB, the minimum requirements for the operation

of an MRF follow Section 33 of RA 9003, which states that MRFs shall
be designed to receive, sort, process, and store compostable and
recyclable material efficiently and in an environmentally sound manner.
However, we found no equipment inside or nearby these caged MRFs
to process the received wastes.

19
Purok – (English: district or zone) is a division within a barangay in the Philippines. While not officially
considered a local government unit, a purok often serves as a unit for delivering services and administration
within a barangay.

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As for accounting these MRFs in their monitoring, the DENR-EMB said

that as long as it meets the minimum requirements, they have included
the caged MRFs in their reporting of total MRFs nationwide. Further,
they ascertained that they may still monitor these caged MRFs’ proper
segregation, storage, data recording, and overall implementation.

Given the absence of processing equipment nearby or inside these

caged MRFs, we considered these as floating and unmonitored if they
were not accounted for by the DENR-EMB, despite their imminent
contribution to the SWM Program of the barangays.

2. Materials Recovery System (MRS). Apart from centralized and caged

MRFs, we also found Materials Recovery Systems present only in the
NCR. These were monitored and accounted for by the DENR-EMB
separate from the compliant MRFs (see Figure 18).

The MRS only addresses a single type or classification of waste in a

limited scope or manner, contrary to an MRF that was supposed to
handle multiple types or classifications of waste. According to DENR-
EMB, there were currently no existing guidelines for implementing
MRS. The implementation of MRS was informally conceptualized such
that it may be tied up or a component system to other programs or
activities on SWM, specifically addressing segregation and recovery.

Figure 18: Examples of MRS

Source: COA Validation of MRFs in Barangay Corazon de Jesus, San Juan, Metro Manila

For example, an LGU operates a centralized MRF, and the MRS in-
place was a partnership with a junk shop operator or a temporary
storage area that caters to a specific sitio, purok, or barangay, thereby
mitigating the need for the LGU to collect recyclable wastes from the
said area daily. For example, in Barangay Corazon de Jesus, San Juan
Metro Manila, the MRS resulted from a Memorandum of Agreement

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(MOA) between the barangay and a junk shop named Prixidio

Junkshop due to the absence of identified sites for a barangay MRF.
Therefore, although not complying with Section 33 of RA 9003, the
MRS was still separately accounted for from the MRFs in the NCR.

Caged MRFs and MRS were the products of the local government’s difficulties
in logistics and financing.

Due to the absence of identified sites for a barangay MRF, the MRS, in
partnership with a junk shop, was conceptualized, as illustrated in Barangay
Corazon de Jesus, San Juan Metro Manila. The highly urbanized location and
high population density in barangays like Barangay Corazon de Jesus made
it difficult for them to locate a space to construct an MRF. We also visited
Barangay 71, Manila, and found similar MRS’s near the mayor’s office,
surrounded by a basketball court and households filled with vast crowds.

Further, setting up cage structures as MRF costs less than building a

compliant MRF. The indicative costing of the cage MRFs we visited ranged
from ₱20,000 to around ₱60,000 (see Table 19).

Table 19: Fabrication of Caged MRF

Location Detailed Unit Price Analysis

Barangay Gairan, Bogo, Cebu ₱ 20,106.46
Barangay Poblacion, Bucloc, Abra 20,205.78
Barangay Lonor Sur, Inabanga, Bohol 41,787.71
Barangay Cabinuangan, Davao de Oro 60,252.13

Source: Detailed Unit Price Analysis conducted by COA TSO Engineers

Comparing these costs with the DENR-EMB Terms of Reference

specifications for financial assistance revealed higher setup requirements.

In the DENR guidelines for financial assistance to establish MRFs (see Table
20), the minimum components required to operate manual and semi-
automated MRFs include but are not limited to the following:
a. Working area for shredding and compost media preparation
b. Storage for recyclables
c. Composting area (Windrows and/or Vermicomposting) with
Leachate Management
d. Safe storage area for Special Waste
e. For a medium MRF, requirement of one (1) fabricated
equipment estimated at ₱150,000.00
f. For a small MRF, requirement of two (2) fabricated equipment
estimated at ₱150,000.00 each for a total of ₱300,000.00

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Table 20: DENR Fund Support Options for LGU Beneficiaries

Option Description Floor Area MRF Estimated Equipment

(in sqm) Cost Cost
Anywhere
Large MRF
1 between 76 to ₱ 600,000.00 ₱ -
(No equipment)
100 sqm.
Medium MRF Anywhere
2 (With between 50 to 75 450,000.00 150,000.00
equipment) sqm.
Small MRF
Minimum of 50
3 (With 300,000.00 300,000.00
sqm.
equipment)

Source: DENR Fund Support Guidelines CY 2019

On the other hand, MRF validation also revealed underperforming MRFs that
affected the effective and efficient operations of MRFs and, ultimately, the low
waste diversion. These MRFs were either not operating, with repairable
defects, or unutilized equipment. And worst, some MRFs were turned into a
dumpsite (see Chapter 2).

The total number of Due to the prohibition of the use of illegal dumpsites and to ensure the safe
disposal of residual wastes, RA 9003 has provided the development of an SLF
SLFs was not as an alternative. At the same time, the operation of the Residual Containment
sufficient to service Area (RCA) has been approved by the DENR while LGUs are awaiting the
all LGUs construction of the SLF or finalization of the MOA with the SLF operator.
nationwide Therefore, while there was an evident decrease in dumpsites and an increase
in the number of SLFs, the problem remains that the total number of SLFs was
insufficient to service all LGUs nationwide.

In the Philippines, SLF is defined as a waste disposal site that has been
designed and engineered to accept municipal residual waste, while ensuring
minimal negative impact on the environment; or a specially engineered site for
disposing of solid waste on land, constructed in such a way as to reduce the
hazard to public health and safety.

LGUs were transitioning from the use of dumpsites to SLFs or RCA. Over
the years, LGUs using dumpsites have significantly decreased as LGUs
transition to using either SLF or RCA. Figure 19 highlights this transition, as
reported by 591 LGUs when asked what kind of disposal facility was utilized
from CYs 2012 to 2021.

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Figure 19: Comparative Number of LGUs using Dumpsites, SLFs, and

RCAs from CYs 2012 to 2021

Source: COA Analysis of LGU data

Similarly, this was confirmed with the reported disposal facilities by DENR-
EMB from CYs 2012 to 2021, showing a downward trend for dumpsites and
an upward trend for SLFs, as represented in Figure 20.

Figure 20: Comparative Trends on the Number of Disposal Facilities by

Type from CYs 2012 to 2021

Source: DENR-EMB Data

The total number of SLFs was insufficient. DENR-EMB's data shows that
SLFs were serving 293 (17.93 percent) out of 1,634 LGUs in CY 2017. By CY
2021, the number of LGUs being served by SLFs had increased to 478 (29.25
percent) as shown in Figure 21.

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Figure 21: Distribution of LGUs With and Without Access to Operational

SLFs from CYs 2017 to 2021

Source: NSWMC and DENR-EMB Data

However, further analysis of the latest available data showed that only LGUs
in NCR have 100 percent access to SLF, and Regions 1, 2, 3, 4A, and 12 have
at least 50 percent of its LGUs with access to SLF. However, for the remaining
regions, only 0.85 to 36.36 percent of its LGUs were served by SLF, as shown
in Table 21.

Table 21: Disaggregated Data on Percentage of LGUs with SLF Access by Region in CY 2021 and
September 2022

As at December 31, 2021 As at September 15, 2022

No. of
No. of LGUs % of LGU No. of LGUs % of LGU
Region LGUs No. of No. of
Served by SLF Served Served by SLF Served
(A) Operational SLF Operational SLF
(B) (C=B/A) (D) (E=D/A)
CAR 77 10 16 20.78 9 15 19.48
NCR 17 1 17 100.00 1 17 100.00
1 125 31 41 32.80 51 65 52.00
2 93 41 46 49.46 41 47 50.54
3 130 12 111 85.38 15 114 87.69
4A 142 43 93 65.49 44 102 71.83
4B 73 12 12 16.44 13 13 17.81
5 114 7 12 10.53 9 34 29.82
6 133 13 20 15.04 15 32 24.06
7 132 15 46 34.85 16 48 36.36
8 143 6 6 4.20 10 11 7.69
9 72 1 1 1.39 2 2 2.78
10 93 19 23 24.73 20 24 25.81
11 49 9 9 18.37 8 8 16.33
12 50 21 21 42.00 21 29 58.00
13 73 4 4 5.48 4 4 5.48
BARMM 118 0 0 0.00 1 1 0.85
TOTAL 1,634 245 478 29.25 280 566 34.64

Source: NSWMC and DENR-EMB Data

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To determine the reasons for the insufficient number of SLFs servicing the
LGUs, we conducted various interviews with DENR and selected LGUs.
Results of interviews revealed at least five major reasons (see Figure 22).

Figure 22: Major Reasons for the Low Number of Operating SLFs

Source: COA Various Interviews

LGUs with certain land characteristics are not suitable for SLF operation.
During an interview, DENR confirmed that not all LGUs could construct an
SLF. For example, in densely populated LGUs like Metro Manila, the
availability of land with a large surface for landfilling is often limited or scarce.
Moreover, some LGUs cannot just construct an SLF because of underlying
characteristics in their area or available land.

According to LGUs and DENR, the approval for establishing an SLF follows a
very stringent process. All waste disposal facilities, regardless of category,
shall satisfy the criteria for siting an SLF as stated in Section 40 of RA 9003
and Rule XIV of its IRR. Moreover, in CY 2013, NSWMC adopted modified
guidelines to climate-proof the siting criteria and assessment procedure for
SLFs to integrate disaster-risk reduction and other safety nets from the
changing climate.20 Included in these modified guidelines were two categories,
the Absolute and Conditional Criteria (see Figure 23). Absolute Criteria refers
to the requirements that must be fully satisfied during the initial screening of
proposed landfill sites. On the other hand, the Conditional Criteria refers to
parameters for second-tier evaluation that may render a site suitable, provided
that its corresponding siting considerations were complied with or applicable
only in cases where the implementation of mitigating measures were within
the capacity of project proponents. To satisfy the Conditional Criteria,
modifications may be done through engineering interventions.

20
NSWMC Resolution No. 64, Series of 2013. Adoption of Modified Guidelines on Site Identification Criteria
and Suitability Assessment Procedure for Sanitary Landfills

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Figure 23: Absolute and Conditional Landfill Site Identification Criteria

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Figure 23: Absolute and Conditional Landfill Site Identification Criteria

(cont.)

Source: NSWMC Resolution No. 64, Series of 2013

While the above guidelines provide the necessary precaution, LGUs, on the
other hand, find the Absolute Criteria in the SLF Siting challenging to comply
with and thus prevent them from establishing an SLF all the same. According
to LGUs, non-compliance with a single absolute criterion automatically
eliminates the proposed site from being considered a prospective SLF
location. Moreover, unlike the Conditional Site Identification Criterion, an
engineering intervention can be applied to the proposed area to establish an
SLF.

To illustrate, one absolute criterion is that an SLF shall not be located in areas
with underlying rocks characterized as jointed, fractured, or fissured;

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carbonate (limestone or dolomite); karst, and other porous rock formations; or

in areas with sinkholes and cavern. However, during interviews and
validations, we learned that some LGUs could not comply with the minimum
requirements for constructing SLF due to land conditions detailed in Table 22.

Table 22: Example of LGUs with Land Condition Limitations

Location/ Proposed SLF Land Condition

Benguet Province Lies on top of the Cordillera Mountains, with

rugged and sloping terrain and deep valleys.

Proposed SLF Site at Sitio Based on the Geological Assessment of the

Candait, Barangay Dampas, proposed SLF, the area is underlain by coralline
Tagbilaran City, Bohol porous limestone, and numerous sinkholes
surround the proposed site.

Proposed Mabuhay SLF located Based on the Site Suitability Assessment

at Barangay Catipan Mabuhay, Report, the area is in a Karst environment. The
Zamboanga Sibugay entire municipality of Mabuhay is underlain by
the Pliocene to Pleistocene Olutanga
Limestone.

Proposed Olutanga SLF located Based on the Site Suitability Assessment

at Purok 3, Barangay Report, Olutanga island is composed of coralline
Kahayagan, Olutanga, limestone, and the surface materials within the
Zamboanga Sibugay proposed site are prone to slumping and
erosion.

Source: PSA and DENR-EMB Data

The land condition of the Benguet Province restricts the LGUs from
constructing SLF. Although landfilling is feasible on steep slopes, it demands
higher costs in engineering, and precautions must be taken to reduce disaster
risks in steep slope areas. The results of the MGB’s Subsidence Hazard
Mapping in Bohol after the 2013 Mw 7.2 earthquake show that the proposed
site was within an area with high susceptibility to land subsidence and located
on an identified sinkhole, thus, does not meet one of the absolute criteria.

The proposed Mabuhay SLF also failed to satisfy one absolute criterion
because it was situated in a Karst environment, which might threaten the
environment and negatively affect the municipality’s residents.

Like the land condition in Tagbilaran City, Olutanga Island is composed mainly
of coralline limestone. When NSWMC was asked about the options available
for the LGUs in limestone areas, they responded that there are expensive
engineering methodologies that can be considered options for LGUs to comply
with proper SWM.

In addition to the above conditions, the DENR-EMB also mentioned that

Cotabato City was below sea level and thus could never be suitable for
establishing an SLF.

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LGUs with insufficient or no budget for establishing an SLF. The

construction and operation of SLF require significant financial investments to
meet RA 9003 for public safety and reduced environmental impact. Table 23
shows the costing of SLF by category.

Table 23: Comparative Cost of SLF by Category

Designed
Category 1 Category 2 Category 3 Category 4
Landfill
Capacity 60,000 cu.m. 164,655.56 cu.m. 1,451,185 cu.m. 840,400 cu.m.
Total site
2.1 hectares 5 hectares 20 hectares 6.6 hectares
area

Lifespan 16.76 years 10 years 10 years 5-10 years

Total
Capital ₱43,329,813.46 ₱67,046,620.00 ₱319,399,765.10 ₱195,792,556.88
Cost

Source: DENR-EMB Data

Moreover, the overall cost depends on the proposed site’s topography and
area, wherein NSWMC can only provide technical assistance. DENR-EMB
also stated instances wherein LGUs want to build SLF but could not pass the
criteria or will require engineering measures which means additional costs for
the LGUs when assessed by the Mines and Geosciences Bureau (MGB) or
DENR-EMB. As a result, LGUs resort to loans from reputable banking
institutions, financial assistance from government entities, endorsement from
politicians, and loans from the private sector.

Social acceptability of residents. Social acceptance by the local community

was considered a major challenge in establishing an SLF within a municipality
or city. An example was in Cuyapo, Nueva Ecija, where residents petitioned
their LGU government to turn down a 10-hectare landfill project at Barangay
Simimbaan last 201321, saying they did not want their town to be known as the
“garbage town”. Recently, the residents of Langkaan I in Dasmariñas City,
Cavite, strongly objected to constructing an SLF in their area in 2021.22
Similarly, finding a host LGU for clustering was also affected by strong
resistance from the community or the not-in-my-backyard (NIMBY)
phenomenon.

Clustering was not easily attainable. Usually, LGUs with their own SLF
restrict their operation within their jurisdiction only and opt not to share their
SLF with other LGUs. Nevertheless, the clustering of LGUs was greatly
encouraged.

Section 13, Article X of the 1987 Constitution allows LGUs to group

themselves, consolidate, or coordinate for purposes beneficial to them and in

21
Roque, A. (2013, January 27). Nueva Ecija townsfolk protest landfill project. Inquirer. Retrieved
November 10, 2022, from https://newsinfo.inquirer.net/347673/nueva-ecija-townsfolk-protest-landfill-
project
22
Pulso ng Bayan. Dasmariñas City News. Retrieved November 10, 2022, from https://www.facebook.
com/DasmaCityNews/posts/pfbid02grZmmGwB993zcT2rnRPGQdhVjd11FrQ3mwtoiUUzYr1HLpA4b6WK
Bs9KuMb522W3I

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accordance with the law. Similarly, Section 17 of the Local Government Code
authorizes LGUs to exercise such power as “necessary, appropriate, or
incidental” to the efficient and effective provision of basic services and
facilities, including solid waste disposal systems or environmental
management systems and services or facilities related to general hygiene and
sanitation. Furthermore, RA 9003 mandates LGU coordination for jointly
addressing: (a) common SWM problems; and/or (b) establishing common
waste treatment and disposal facilities. Accordingly, clustering has various
advantages and benefits to LGUs, as outlined in Table 24.

Table 24: Advantages and Benefits of Clustering to LGUs

Advantages of Clustering Benefits to LGUs

Preservation of common heritage and Scarce resources to implement projects
identity will be supplemented by other members’
shares
Development needs easier to identify High possibility of funding assistance
and address and approval of proposals from donor
agencies/financial institutions
Serves as a tool in establishing growth Equipment needed for infrastructure
centers in the Province/Region development and waste management
will be supplemented by other members
Ensures greater benefits thru equitable Wider market for services will be
sharing established
Allows wider area jurisdiction to achieve Increase in employment opportunities
desired economies of scale for constituents

Source: National Solid Waste Management Strategy; P. Maceda, Jr., August 2006

According to a research project report, one of the success stories of inter-LGU

collaboration was the Surallah Cluster SLF in South Cotabato.23 The South
Cotabato Provincial Office started this because the financial resources needed
to construct an SLF facility were too high for a single LGU; instead, it would
be more practical for LGUs to cluster together. According to the report, a
cluster SLF was more cost-effective than an individual SLF in terms of
economies of scale. For example, six LGUs would need to invest ₱54 million
to construct their SLF facility, excluding human resources, equipment, and
operational costs. However, with the cluster SLF, the required investment was
only ₱15 million with a capacity of 30 tons per day, excluding human
resources, equipment, and operational costs. Thus, the LGUs can make
significant savings using the cluster SLF, which they can use to provide other
public services to the community.

In CY 2013, the NSWMC issued Resolution No. 68 for clustering LGUs on a

common ecological SWM system. It is an option in which small LGUs can pool
their resources into setting up common solid waste disposal facilities. It also
enables them to attain large economies of scale and reduce the cost of solid

23
Regional Waste Management – Inter-municipal Cooperation and Public and Private Partnership. (2020,
July 2). Economic Research Institute for ASEAN and East Asia - ERIA. Retrieved January 4, 2023, from
http://www.eria.org/research/regional-waste-management--inter-municipal-cooperation-and-public-and-
private-partnership/

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waste disposal per unit. Furthermore, since the volume of waste is too small
for most LGUs, alliance building regarding the clustering of municipalities for
SLF construction and operation can result in economies of scale.24
On February 22, 2022, the NSWMC issued Resolution No. 1505, Series of
2022, empowering the Coalition of Solid Waste Management Providers
(CSWMP) by adopting and implementing the SWM solution to optimize waste
recovery and utilization in the SLFs prior to disposal. Through this, the
CSWMP will cooperate and collaborate with the government to review, assess
and propose strategies to support the implementation of the Total Solid Waste
Management Solution concept that aims to ensure optimum utilization of solid
wastes that enter the SLFs, by integrating processes before disposal thereby
extending the life of the disposal facility. Previously, the NSWMC issued
Resolution No. 1452, Series of 2021, wherein the DENR mobilized the group
of SWM service providers to organize themselves to support the government
in expanding the number of LGUs with access to approved SLFs through
Public-Private Partnerships (PPPs). Therefore, CSWMP will act as a catalyst
in addressing the SWM and disposal in the country by formulating various
programs and initiatives which will cater to the development and availability of
SLFs for all LGUs.
Standards on SLF were not fully complied with, increasing risk to health
and the environment. SLF is an essential component of effective SWM.
Accordingly, it is necessary to establish standards and proper engineering in
establishing and operating SLFs to minimize or avoid the negative impacts on
the environment. As mandated in RA 9003, the essential elements of SLF
include gas vents, a leachate collection system, a ground monitoring well,
liners, and earth cover to lessen the possibility of wastes seeping beneath to
the groundwater and generation of landfill gasses (see Figure 24).

Figure 24: Elements of SLF

Source: DENR Data

24
National Solid Waste Management Strategy 2012-2016

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We visited 12 SLFs to inspect their compliance with the minimum standards

provided in RA 9003, its IRR, and other relevant guidelines. Accompanying us
were engineers from the COA TSO, and focal persons from DENR-EMB
Regional Offices and LGUs. We noted various observations during the
inspection, including but not limited to the absence of a leachate system, daily
soil cover, groundwater monitoring wells, and a separate containment area for
household hazardous wastes (see Appendix III for complete observation).

1. According to Section 1 (k) Rule XIV, RA 9003 IRR, an SLF must have a
leachate collection and removal system. Although the SLF in La Trinidad,
Benguet, has a leachate collection and removal system, it is not well
maintained (see Figure 25). The leachate collected was not treated and
stocked in the drainage. At the time of inspection, the leachate pond has
soil and vegetation. Moreover, one worker shared that the leachate
overflows when raining, damaging nearby plants or crops. The drainage
was clogged, preventing the leachate from Cells 1 and 3 from flowing
straight to the leachate pond.

Figure 25: Inspection of SLF in La Trinidad, Benguet, CAR

Requirement: Leachate collection and removal system

Actual: Leachate collection and removal system is not well maintained.

Source: COA Validation in La Trinidad, Benguet, CAR

2. The leachate collection of the SLF in Norzagaray, Bulacan, was also

through the leachate pond (see Figure 26). However, when the pond is full,
it discharges untested leachate to the nearest river, about 75.90 meters
away. No discharge permit has been issued by the DENR-EMB. This has
caused the DENR-EMB to issue the Cease and Desist Order (CDO) to the
operating LGU, as it will detrimentally affect the river.

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Figure 26: Inspection of SLF in Norzagaray, Bulacan, Region 3

Requirement: Leachate collection and removal system

Actual: Leachate collection and removal system is not well maintained

Source: COA Validation in Norzagaray, Bulacan, Region 3

3. We found no leachate collection system at the SLF in General Mariano

Alvarez (GMA), Cavite. Moreover, no leachate pond was constructed
based on the Monitoring/Inspection Report of DENR Regional Office No.
IV, dated October 8, 2021. As a result, the leachate was retained inside the
cell or waste-filling area.

4. Section 1 (l) Rule XIV, RA 9003 IRR provided that leachate storage shall
be designed with containment systems and shall include a geomembrane
liner system for leachate impoundment ponds. Leachate ponds in six SLFs
were made of concrete/CHB wall; however, there was no HDPE liner (see
Figure 27). Leachate may seep through the concrete if it is impounded or
not discharged. The lack of HDPE liners should have been validated before
the operation of the landfills. A review of the Monitoring and Inspection
Reports of the DENR-EMB showed that it was not reported.

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Figure 27: SLFs without Required Leachate HDPE Liner

Requirement: Leachate storage shall be designed with containment systems and liner
Actual: Leachate ponds made of concrete/CHB wall without HDPE liner

Location: Maragusan, Davao de Oro, Region 11 Location: Alaminos City, Pangasinan, Region 1

Location: Aringay, La Union Region 1 Location: Pugo, La Union, Region 1

Source: COA Validation in Regions 1 and 11

5. Section 1 (m.1) Rule XIV, RA 9003 IRR requires that an SLF be at least 50
meters away from any perennial stream, lake, or river. However, the SLF
in Navotas City was on a separate island surrounded by bodies of water
(see Figure 28). It was located in Manila Bay with nearby fish ponds.
However, except for the mangroves planted around it, we did not observe
any additional measures taken to operate the SLF when bodies of water
surround it. This has made the approval of the construction and operation
of the SLF questionable, knowing that many environmental consequences
to Manila Bay may occur in its current set-up. In a news report in 2017, the
DENR investigators discovered that Phileco’s Vitas Marine Loading Station
(VMLS) violated its Environmental Compliance Certificate (ECC) for letting
the untreated wastewater flow directly into Manila Bay while solid waste

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piled up along the shoreline.25 In 2017, a Navotas Case Story was

conducted by Ibon International.26 It noted that the landfill has contributed
to the death of nearby mangroves and damaged the marine ecosystems.
Local fishermen within the community claim that their average daily catch
has decreased from at least 10 to 15 kilograms in 1981 to only 2 to 3
kilograms in 2017. Furthermore, the EcoWaste Coalition has called for
government officials to stop dumping wastes27 in the environmentally-
critical area of Manila Bay and immediately shut down all operating
dumpsites and landfills within the area.

Figure 28: Inspection of SLF in Navotas City, NCR

Requirement: Minimum of 50 meters away from any perennial stream, lake, or river
Actual: Surrounded by a body of water

Source: Google Earth and Google Maps

25
DENR suspends waste facility on Manila Bay. (2017, October 8). ABS-CBN News. Retrieved November
10, 2022, from https://news.abs-cbn.com/news/10/08/17/denr-suspends-waste-facility-on-manila-bay
26
P. (2017, August 11). Development for Whom? How Navotas fisherfolk resist the displacement of their
people and livelihood. IBON INTERNATIONAL. Retrieved November 10, 2022, from
https://iboninternational.org/2017/08/11/development-for-whom-how-navotas-fisherfolk-resist-the-
displacement-of-their-people-and-livelihood/
27
Close the Dumps to Ensure Manila Bay Rehab, Say EcoGroups. (2009, August 29). EcoWaste
Coalition. Retrieved November 10, 2022, from http://ecowastecoalition.blogspot.com/2009/08/close-
dumps-to-ensure-manila-bay-rehab.html

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6. Another example was the SLF in Iriga City, Camarines Sur, where the
nearest Waras River was only about 30.20 meters away (see Figure 29). A
pumping station was built to prevent the overflowing of leachate or for the
recirculation process. However, this will not guarantee that leachate will not
be discharged without a permit from the DENR-EMB, which may
contaminate the nearest/connected river.

Figure 29: Inspection of SLF in Iriga City, Camarines Sur, Region 5

Requirement: Minimum of 50 meters away from any perennial stream, lake, or river
Actual: Surrounded by a body of water

Source: Google Earth and COA Validation in Iriga City, Camarines Sur, Region 5

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7. In addition to being surrounded by water, the SLF in Navotas City was also
at a low altitude ranging from 1.30 meters to 16.30 meters which could be
prone to flooding since the country has weather patterns of southwest and
northeast monsoon and is frequented by typhoons that can cause heavy
rainfall (see Figure 30). Furthermore, storm surges may occur during strong
typhoons, which may cause flooding to the island, and trash can be swept
away due to its waterfront location, causing marine pollution. Therefore, this
contradicts Section 1 (m.2) Rule XIV, RA 9003 IRR that the site shall be
evaluated for the presence of geologic hazards, faults, unstable soils, its
foundation stability, and hydrological character, and shall not be located in
a floodplain.

Figure 30: Inspection of SLF in Navotas City, NCR

Requirement: The site shall be evaluated for the presence of geologic hazards, faults, unstable
soils, its foundation stability, and hydrological character. The site shall not be located in a
floodplain
Actual: Surrounded by a body of water

Source: COA Validation in SLF in Navotas City, NCR

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8. Section 1 (m.1) Rule XIV, RA 9003 IRR requires a daily cover to be applied
at the end of each workday. In two cases, a daily soil cover was not applied,
which caused some light wastes to be carried by the wind and scattered
nearby or within the facility. In the sample photo taken in Asturias, Cebu, it
can be seen that layers of waste were still exposed, similar to Maragusan,
Davao de Oro (see Figure 31).

Figure 31: Inspection of SLFs with No Regular Daily Soil Cover

Requirement: Daily soil cover

Actual: Without regular soil cover

Location: Asturias, Cebu, Region 7 Location: Maragusan, Davao de Oro, Region 11

Source: COA Validation of SLFs in Regions 7 and 11

9. Two SLFs do not apply soil cover which may lead to a faster generation of
landfill gasses such as methane and carbon dioxide that will harm the
people and the environment (see Figure 32). In addition, the exposed waste
generated a bad odor that affected the people at the facility. In connection
with this, waste workers at the SLF in La Trinidad were confirmed to
experience dizziness, cough, and colds.

10. Nine SLFs have establishments within its 200-meter radius (see
Inconsistent implementation of waste segregation nationwide - Extended
risks to the people and environment on page 90), contrary to the prohibited
acts of RA 9003. Hence, the risks posed by landfills, if not appropriately
managed, are higher for these establishments within the 200-meter radius.

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Figure 32: Inspection of SLFs with No Daily Soil Cover

Requirement: Daily soil cover

Actual: Without soil cover

Location: La Trinidad, Benguet, CAR Location: Aringay, La Union, Region 1

Source: COA Validation of SLFs in CAR and Region 1

11. Section 1 (v) Rule XIV, RA 9003 IRR requires the groundwater monitoring
well to be placed at the appropriate location and depth for taking water
samples. However, inspection revealed that three SLFs in (a) La Trinidad,
Benguet; (b) GMA, Cavite; and (c) Asturias, Cebu, do not have groundwater
monitoring wells on site. Hence, the effect of landfill on the groundwater
cannot be monitored if it is being affected.

12. Section 1 (t) Rule XIV, RA 9003 IRR also requires a separate containment
area for household hazardous wastes. However, the three SLFs visited do
not have a separate containment area for household hazardous wastes.
For example, in Navotas SLF, workers that we surveyed confirmed that
gloves and face masks were sometimes mixed in the general waste (see
Figure 33). This can put waste workers at high occupational risk as they
are the most susceptible to infectious diseases.

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Figure 33: Ratio of Worker Survey Respondents on Presence of COVID-

19-Related Waste in Navotas SLF

Source: COA Survey Results

While serving as a With the prohibition and closure of dumpsites and the inadequate number of
short-term operating SLFs, DENR has allowed using RCA as a temporary disposal site.
Based on the latest available data, DENR reported that 534 RCAs were
alternative, RCAs operating nationwide as at October 2022 (see Table 25). However, RCAs pose
have potential risks potential risks if operated longer than intended since there are no formal
if operated longer guidelines and minimum requirements for their establishment (i.e., no liner, no
than intended leachate pond, etc.) to contain the effects of the wastes.

Table 25: Number of Operating RCAs

Region CAR NCR 1 2 3 4A 4B 5 6 7 8 9 10 11 12 13 Total

No. of
58 0 36 28 16 22 15 56 58 18 22 13 63 33 27 69 534
RCAs

Source: DENR-EMB Data

According to DENR-EMB, the RCA is intended to temporarily store residual

wastes while LGUs are awaiting access to a final disposal facility, such as the
construction of an SLF or finalization of an agreement with an SLF operator
(see Figure 34).

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Figure 34: Final Disposal Options of LGUs

Source: DENR-EMB Data

However, an interview with DENR-EMB revealed no established and signed

guidelines for establishing these temporary RCAs. And the only available
criteria were verbally instructed to LGUs (see Figure 35).

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Figure 35: Criteria of RCA

Source: DENR-EMB Data

However, during validation, we and the TSO Engineers noted observations

contrary to the draft criteria of RCA. The first observation concerns the
purpose of RCAs. The RCA in Kibungan, Benguet, receives residual wastes
and recyclables because the facility also serves as an MRF. No RCA was
found accepting biodegradables (see Figure 36).

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Figure 36: Examples of RCAs from Team Validation

Location: CAR – Kibungan, Benguet

Location: Region 3 – San Luis, Aurora

Location: Region 7 – Calape, Bohol Location: Region 11 – Monkayo, Davao de Oro

Source: COA Validation

The second observation concerns the material condition of the RCAs. Some
of the RCAs were found without concrete flooring. For example, in San Luis,
Aurora, and Monkayo, Davao de Oro, wastes touched the ground and were
exposed to the floor prone to wetness when exposed to rain (see Figure 36).

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Table 26: Sample RCA Observations from the Technical Inspections of

COA Engineers

Kibungan, San Luis, Calape, Monkayo,

Benguet Aurora Bohol Davao de Oro
Operation June 2020 2018 2011 June 2020
Started
Operating 1 year and 10 4 years 11 years 1 year and 10
Years (as at months months
April 2022
validation)
Operating MENRO MENRO MENRO MENRO
Office
Waste Recyclables Residual Residuals Residual with
Collected and Residual Wastes potential for
Wastes recycling/
diversion
Floor Area 160 sqm. 18 sqm. 96 sqm. 45.15 sqm.
Materials Two-storey Reinforced Open storage Open storage
Used reinforced Concrete made of made of wood
concrete Facility with concrete columns and
building CHB Wall and columns and GI Sheet
enclosed by GI Sheet GI Sheet Roofing in the
CHB Wall and Roofing. Roofing in the wood truss.
Galvanized wood truss.
Iron (GI) Sheet
Roofing
Status Operational Operational Operational Operational

Source: COA Technical Inspection Report

The third observation concerns capacity. The RCA in San Luis, Aurora has a
floor area of 18 sqm, significantly smaller than the other RCA sites visited.
However, we observed some wastes stored in the facility were exposed to rain
due to full capacity. Since the RCA has inherently no concrete flooring, a GI
sheet was used as an alternative to protect the waste from the ground.

The fourth observation concerns the operating timeline of the visisted RCAs
(see Table 26). They all operated beyond six months to one year, violating the
minimum requirement verbally instructed by the DENR-EMB. Some have been
operating for over a decade, for example, in San Luis, Aurora, and Calape,
Bohol. Per an interview with the officials, they have been resetting the
operating timeline once the RCA has been emptied of residual wastes for
transfer to an accredited SLF. However, we were not furnished with monitoring
records to validate this practice.

In an interview with DENR-EMB official, we discovered that RCAs were

already been operating since 2006, meant to be temporary storage areas.
However, when asked about the differences between the RCAs that were
already established a long time ago and the temporary RCAs as an alternative
to those whose dump sites have closed and without access yet to an SLF,

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another official said that there was no distinction yet that was officially
disseminated.

In hindsight, establishing and operating an RCA should have a minimum

requirement similar to an SLF because the types of waste that should be
received are residual. Most RCAs we visited served as temporary storage
areas or transfer stations for recyclable wastes or residuals with potential,
similar to an MRF.

However, we did not find other residual wastes, such as napkins and diapers,
which have a foul smell. In addition, no septic holes or vaults were shown to
us by the LGUs operating RCAs that can handle such wastes. Given that more
than half of barangays, or 64.73 percent nationwide (see Figure 12), still lack
access to an MRF, there may be LGUs whose RCAs will not only receive
residual with potential and recyclable wastes, but also residual and harmful
wastes as well.

No formal guidelines on the establishment and operation of RCA. While

the temporary RCAs were meant to serve as an alternative to local
governments’ pending access to SLF, this instruction was only verbalized by
NSWMC during technical conferences, because the guidelines on RCA did
not reach resolution by the members of the Commission.

The draft Policy on the Guidelines on the Establishment and Operation of

Residuals Containment Area was presented and discussed in the Consultation
on Support Policies for the implementation of the ESWM Act and
Training/Workshop on the Greenhouse Gas Inventory and Mitigation options
of Solid Waste Sub-Sector last March 14, 2017. According to DENR-EMB, it
was also agreed that the said draft Guidelines would be disseminated to the
participants for further review, input, and comments. Unfortunately,
confirmation with DENR-EMB on the status revealed no recent development
on this Policy.

NSWMC admitted that there are RCAs that are indeed mismanaged and
agreed on the need to revisit and review the guidelines for managing RCAs.

Prolonged Lifespan of RCAs. As for the reasons and implications of

prolonging the operation of their RCAs, the officials from the visited LGUs had
the following reasons:

• Kibungan, Benguet, has a proposed SLF awaiting approval from the

DENR-EMB.
• Monkayo, Davao de Oro already has its own SLF and uses the
established RCA.
• San Luis, Aurora, has an ongoing MOA with a private SLF operator to
dispose of residual wastes. The purpose of their RCA is to serve as a
holding area for accumulating residual wastes before collection and
delivery to private SLF. The LGU officials disclosed that they already
had an approved ECC last November 2020, and the SLF was already
due for construction.
• Calape, Bohol, has a MOA with another LGU, the Municipality of
Alburquerque, as a disposal site. The purpose of their RCA is also to

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serve as a holding area for the accumulation of residual wastes before

transfer to the SLF.

Given that the RCAs visited have already been established using government
funds, the DENR-EMB said that with proper management and operation, the
RCA could be an integral part of the SWM and/or the SLFs once access to an
SLF is already available, as it can be used for the processing of the residual
waste that has the potential for recycling and fuel.

Cement factories in cement production can use residual waste with a high
calorific value. Also, there are established markets where the residual wastes
are mixed with sand and cement to produce construction materials.

The DENR-EMB also mentioned that LGUs who invested money in their RCAs
have plans for their use in the long run. For example, some LGUs use the
structure that they have previously operated as an RCA to be a transfer
station, sorting station, or in many cases, an MRF. Hence, the structure itself
can serve other purposes planned by the LGUs. Such was the case in the
LGUs of San Luis, Aurora, and Calape, Bohol. With plans to have access to
an SLF long-term, they were already utilizing the RCA as a prerequisite in
managing residual waste before transfer to an accredited SLF.

We noted that the DENR-EMB did not yet have a national policy on the
recommended use of established RCA for those LGUs already finished with
its temporary use.

Potential Risks of Prolonged Operation of an RCA. According to the

DENR-EMB, one of the potential risks of an RCA being operated for a longer
span is that an RCA is only limited in capacity. Once that capacity is reached,
and the LGU fails to anticipate it, it often ends up being operated as an Open
Dumpsite. Since the RCA will operate similarly to an SLF temporarily, there is
no minimum requirement for its establishment (no liner, no leachate pond, etc.)
to contain the effects of the wastes. The risk is that as wastes undergo
decomposition, they produce methane and leachate. If the leachate is not
properly contained, it could contaminate the surface and groundwater.
Likewise, methane is produced and may cause spontaneous combustion.

Mandated closure, Section 37 of RA 9003 prohibits the establishment and operation of open
dumps or any practice or disposal of solid waste which constitutes the use of
transition, and open dumps. The law also states that all open dumps shall be converted into
prohibition of controlled dumps until 2004 and that no controlled dumps shall be allowed until
dumpsites were not 2006.28 However, this legally mandated transition was not fully realized, as
met many open and controlled dumps or illegal dumpsites were still operating after
2006 (see Figures 37 and 38).

28
According to Section 37 of RA 9003, all open dumps shall be converted into controlled dumps within three
(3) years after the effectivity of the Act, and that no controlled dumps shall be allowed five (5) years follow
the effectivity of the Act.

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Figure 37: Comparative Number of Open, Controlled, and Illegal

Dumpsites from CYs 2010 to 2021

Source: DENR-EMB Data

On the other hand, data reported by DENR-EMB revealed that the number of
operating dumpsites reached as high as 1,232 in CY 2009.

Figure 38: Trend in the Numbers of Illegal Dumpsites from CYs 2004 to
2022

Source: DENR Data

In CY 2021, DENR announced the successful closing of all dumpsites

nationwide.29 However, our validation from March to April 2022 revealed that
not all dumpsites were successfully closed (see Figure 39). We found eight

29
DENR shuts down 100% of all illegally operating dumpsites nationwide. (2021, May 2023). DENR.
Retrieved January 3, 2023, from https://www.denr.gov.ph/index.php/news-events/press-releases/2606-
denr-shuts-down-100-of-all-illegally-operating-dumpsites-nationwide

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illegal operating dumpsites during validation. According to the LGUs, they had
to reopen or establish a new dumpsite due to a lack of capacity to construct
their own SLF and/or lack of funds to enter into an agreement with an SLF
operator and pay tipping fees. The NSWMC later attested that there were
occurrences of the reopening of dumpsites, especially when the LGU had
nowhere to dump its waste. Mother Earth Foundation commented that DENR
did not give support when it closed the LGUs’ dumpsites. Thus, LGUs
encountered problems when they disposed of their waste.

Figure 39: Operating Illegal Dumpsites during Validation

Location: Barangay Bagong Sirang, Pili, Camarines Sur (Reopened dumpsite)

Status after validation: Technical Conference was held last June 22, 2022.

Location: Barangay Poblacion, Guipos, Davao Del Sur (Reopened dumpsite)

Status after validation: CDO dated June 20, 2022

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Figure 39: Operating Illegal Dumpsites during Validation (cont.)

Location: Barangay Caidocan, Medellin, Cebu (Reopened dumpsite)

Status after validation: CDO dated May 18, 2022

Location: Barangay Kal-anan, Tabogon, Cebu (Reopened dumpsite)

Status after validation: CDO dated May 18, 2022

Location: Barangay Tabunok, Tabuelan, Cebu (Reopened dumpsite)

Status after validation: CDO dated May 18, 2022

Location: Barangay Kangdampas, Barili, Cebu (Reopened dumpsite)

Status after validation: CDO dated July 11, 2022

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Figure 39: Operating Illegal Dumpsites during Validation (cont.)

Location: Barangay Sikatuna, Guipos, Davao Del Sur (Newly established dumpsite)
Status after validation: CDO dated July 24, 2022

Location: Barangay Caduan, Mabini, Davao de Oro (Newly established dumpsite)

Status after validation: Closed with Ongoing/Partial Rehabilitation as of October 7, 2022

Source: COA Validation

Out of the eight dumpsites, the one in Barangay Bagong Sirang, Pili,
Camarines Sur, remains operational during the latest validation of DENR-EMB
Region 5 on October 3, 2022 (see Figure 40). According to DENR-EMB
Region 5, in the late months of 2020 and early quarters of 2021, the LGU of
Pili had initially undertaken closure and rehabilitation activities by applying soil
cover and constructing fences, including the operation of a central MRF.
However, during their March 2022 monitoring, DENR-EMB Region 5 found
that LGU Pili utilized the open dumpsite in Barangay Bagong Sirang as the
final disposal site for the municipality’s solid waste. As a result, a technical
conference was conducted on June 2022, where LGU Pili committed to cease
operating the open dumpsite and initiate an RCA operation in one of its
barangays. However, the limited space and capacity of the RCA to
accommodate the daily collected residual waste and some other inherent

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issues have hindered the development of an SLF. Thus, the open dumpsite
was re-utilized as the final disposal site for solid waste.

Figure 40: Open Dumpsite in Pili, Camarines Sur

Taken: April 26, 2022

Left: Municipal MRF adjacent to disposal area; Right: Active area of the disposal site

Taken: October 3, 2022

Left: Municipal MRF adjacent to the disposal area. The piled sacks are carbonized rice hulls for composting; Right: Active
area of the disposal site

Source: COA Validation and MENRO Pili Photographs

Since the operation of an open dumpsite lacks the safety measures of a

landfill, the leachate produced from solid waste can contaminate groundwater
and surface waters. Methane gases emitted by dumpsites also harm the
health of those exposed to them and contribute to global warming. This can
also cause increased flooding and infrastructure destruction due to clogged
waterways (see Figure 41).

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Figure 41: Solid Waste Exposure Pathway

Source: National Solid Waste Management Report (2008-2018)

Safe Closure and Rehabilitation Plan (SCRP). Regarding the closure of

illegal dumpsites, the DENR has issued guidelines to ensure the proper order
of closing and rehabilitation of open and closed dumpsites by requiring the
concerned LGUs to submit an SCRP for review, approval, and immediate
implementation.

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Figure 42: Distribution on the Status of Submission and Implementation

of SCRPs of Closed Dumpsites from 16 Regions

Note: According to DENR-EMB CAR, no dumpsites have been operated in the region.
On the other hand, data from BARMM was not submitted.

Source: DENR-EMB Regional Offices

Since DENR did not maintain a database for monitoring the rehabilitation
plans, we requested DENR-EMB RO to submit the latest status. Data from 16
regions revealed that only 74 percent, or 458 of the 620 dumpsites, had
completed their SCRP implementation, 18 percent, or 113 with plans but
without implementation, and 8 percent or 49 had no plans established yet (see
Figure 42). The data gathered on the 620 dumpsites were only 50.32 percent
of the reported 1,232 dumpsites that operated in CY 2009 (see Figure 38).
Data or progress on the safe closure and rehabilitation of the remaining 612
dumpsites was still unknown.

However, it could not be denied that LGUs disregarded the deadline set by RA
9003, notwithstanding the series of Notices of Violation (NOVs) issued by the
Commission and capability-building assistance provided by DENR-EMB. The
nonattention was attributed to a lack of political will, technical know-how, and
financial capability to implement the mandates of the law.

Open and controlled dumpsites continue to be sources of methane gas

emissions; hence, failure to close these facilities exacerbates greenhouse gas
emissions. Conversely, their proper closure and rehabilitation will significantly
contribute to greenhouse gas reduction.

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Achieving SWM From a broader perspective, the SWMP spans activities that directly and
indirectly affect the achievement of SDGs. Moreover, it is irrefutable that the
objectives will SWM process concerns not only public health and the environment but also
promote relevant energy sustainability, human capital and labor, economic impact, aided by
SDGs institutional mechanisms.

Figure 43: SWM Cuts Across All SDGs

Improving economic conditions of waste Merging formal and informal SWM sectors
pickers to promote social and economic inclusion

Raising the quality of city life through

Managing and recycling organic solid
integrated and sustainable solid waste
waste for agricultural productivity
management

Adopting the green circular economy model

Proper handling of waste from collection to for responsible consumption and production
disposal patterns (5Rs)

Reducing emitting rates of pollution and

Providing technical and vocational
greenhouse gases through avoidance of
education related to the solid waste
garbage open burning and safe disposal of
management system
solid waste

Reducing the exploitation of women in the Reducing pollution resulting from dumping
informal system, and proper job solid waste into water bodies to preserve
opportunities marine life and decrease ocean acidification

Reducing pollution caused by dumping

plastic and hazardous wastes into or near Reducing the need for land in the sanitary
waterways increases access to higher burying of waste to avoid land degradation
water quality

Supporting the provision of a new and Supporting the organization of the

affordable source of energy through the relationship between the central authority
use of solid waste in energy production and local administrations through a clear
processes institutional framework

Recycling technology provides more Supporting the participation of multiple

opportunities for higher levels of economic parties for an integrated and sustainable
productivity SWM system

Recycling to stimulate innovation

processes in various fields of industry

Source: COA Analysis

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As shown in Figure 43, several general and specific activities30 contribute in

one way or another to all 17 SDGs in a global sense (see Appendix IV for the
complete details).

Consequently, our analysis disclosed an evident relationship between

achieving SWM objectives and the SDGs, as discussed below:

Not improving the economic conditions of waste workers

(e.g., pickers, sorters, machine operators, and
administrators) has not helped them to lift themselves from
poverty. Local governments enable and accept the informal
sector to manage their solid waste. Thus, the demand will remain
for the waste workers who want to work for a decent living to
provide for their families.

Non-collaboration with implementing stakeholders results

in overlapping programs and unnecessary use of
government resources. The connection between diverting and
recycling organic solid waste and its purpose in the agricultural
industry is undeniable. Yet, the duplicate equipment we observed
also speaks of duplicate efforts and resources that could have
been avoided if an integrated approach had been employed by
member agencies in the implementation of their programs,
projects, and activities. For example, biowaste shredders were
both provided by DENR and DA. An integrated approach
combining purposes of solid waste diversion for disposal and
agricultural processing will minimize the duplication of costs and
resources spent by the government.

Proper handling of solid waste and medical waste from

COVID-19 and safe collection, transportation, and disposal
supports a healthy and disease-free environment. As a
result, COVID-19 has been an urgent health matter recently.
However, this does not set back other communicable diseases,
such as malaria and hepatitis, which can be transmitted through
water and other means.

Opportunities for women are present from the ground up.

However, female representation in the SWM industry is
unequal, as observed. Out of the total number of M/CENROs
nationwide, excluding BARMM, only 28 percent are females (see
Unequal distribution of men and women in SWM and leadership
on page 114).

30
Elsheekh, K. M., Kamel, R. R., Elsherif, D. M., & Shalaby, A. M. (2021, September 15). Achieving
sustainable development goals (SDG) from the perspective of solid waste management plans. Journal of
Engineering and Applied Science, 68(1). Retrieved November 10, 2022, from https://doi.org/10.1186/
s44147-021-00009-9

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The solid waste industry has not yet realized the goal of
increasing the share of renewable energy in the energy mix.
Pending the negotiations of different stakeholders on the future
of Waste-to-Energy, implementers can turn to other methods for
new and affordable energy sources.

Adopting the green circular economy model was

challenged because the 3Rs (reduce, reuse, recycle)
promotion is lackluster. No recycling markets have been
established to encourage innovative solutions in ensuring
sustainable and responsible consumption and production
patterns.

Access to adequate, safe, and affordable housing services

for communities living in slums was continually affected by
dumpsites’ lingering presence. Despite the 100 percent
closure order last May 2021, discovering open dumpsites nearby
communities hounds their safety and health.

The environmental impact of waste was more felt in urban

areas than in rural areas. All LGUs have chances for an
integrated SWM system through the preparation of 10-year
plans. Carefully planned systems shall help reduce the negative
environmental impacts of solid waste, most especially for urban
centers.

Dumpsites converted to green and public spaces are

replicable and encouraged for a sustainable city and
community. Degraded land from buried wastes still has a
chance of utilization. Selected dumpsites converted into eco-
parks that we validated are a replicable opportunity for other
LGUs in the same situation.

Achieving the target of substantially reducing waste

generation through prevention, reduction, recycling, and
reuse is still far from what is envisioned. The current
orientation of the 3Rs is not as efficient as preferred. Waste
generation continues to increase, waste diversion has gaps in
implementation and monitoring, and waste disposal continues to
have challenges from being built. In addition, the demand for
waste disposal facilities increases as the lifespans of existing
ones are shortened due to problems in the waste stream.

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Integrating climate change measures into the planning and

implementation of SWM is important as they are greatly
interrelated. From open burning emissions of carbon monoxide,
carbon dioxide, greenhouse gases, nitrogen oxides,
hydrocarbons, and other particulate matter, up to the solid waste
disposal facilities’ emissions of methane and carbon dioxide from
leachate, the effects of solid waste mismanagement translate to
our growing concerns over climate change. Moreover, these
pose a greater need to build adequate knowledge and capacity
to institutionalize education of SWM with climate change. By
improving the curricula of our primary, secondary, and tertiary
education systems and multi-sectoral IEC campaigns, raising
awareness on the effects of solid waste and climate change will
help us better mitigate, adapt, and reduce its impacts.

Dumping solid waste into water bodies increases marine

pollution and will affect the lives of marine organisms and
humans in the long run. For example, an SLF on an island
surrounded by water and voluminous sightings of solid wastes
discovered in oceans harm organisms living underwater. Studies
have also already emerged detailing the effects of micro plastics
on these organisms that we, in turn, consume.

There is a relationship between the government and non-

government entities, such as the formal private sector, the
informal sector, the local community, and donors. Albeit
imperfect, efforts to encourage and promote effective public,
public-private, and civil society partnerships were made through
consultations and meetings. When civil society organizations file
cases, the intention is to mobilize and persuade government
leaders to take action.

To provide a closer perspective on how the Philippines is fairing in achieving

SDGs31, we identified for comparison the SDG Targets 11.6, 12.5, 13.2, and
13.3.32

There was a low probability of achieving the SDG target of substantially

reducing waste generation through prevention, reduction, recycling, and
reuse by 2030. As discussed earlier, this Program has been identified by the
national government as one of the key programs which primarily contributes
to the achievement of SDG 12 Target 12.5, which aims to substantially reduce
waste generation through prevention, reduction, recycling, and reuse.
However, based on the projections of NSWMC to forecast future waste
generation, waste is projected at 19,764,384.95 metric tons in CY 2030.
Therefore, with this scenario, the Philippines is not yet in a position to
achieving SDG Target 12.5 of substantially reduced waste generation by
2030. In addition, this SDG indicator has yet to be monitored by the PSA since

31
The only SDG Target adopted in the Philippines with direct relation to SWM is SDG Target 12.5, however,
this target is in Tier 2 – with established methodology but data is not regularly collected.
32
We focused on selected targets that are directly referenced by observations and validations from physical
inspections and data analysis.

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it is still under Tier 2, or data are not regularly collected even with established
methodology.

Climate change accelerated the need to find measures to reduce and

manage the waste we create. But, ultimately, waste also contributes to
climate change. Poor waste management practices, such as open burning,
dumping in creeks and bodies of water, using open and unmanaged
dumpsites, and non-segregation of waste, have contributed to greenhouse
emissions. According to Our World in Data33, waste is the 6th largest sector
producing greenhouse gas emissions in CY 2019 (see Figure 44).

Figure 44: Philippines’ Greenhouse Gas Emissions by Sector in 2019

Source: Our World in Data

As mentioned earlier, majority of the municipal wastes in the Philippines were

biodegradable at 52.3 percent. However, due to a lack of segregation, the
accumulated biodegradable wastes in landfills and dumpsites enter the
decomposition stage, producing carbon dioxide and methane emissions,
which are about 23 times stronger at warming the atmosphere than carbon
dioxide. According to reports, methane was a strong greenhouse gas, mainly
produced through agricultural activities followed by waste activities (see Figure
45).

33
Hannah Ritchie, Max Roser and Pablo Rosado (2020). CO₂ and Greenhouse Gas Emissions. Published
online at OurWorldInData.org. Retrieved September 14, 2022, from https://ourworldindata.org/co2-and-
other-greenhouse-gas-emissions

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Figure 45: Philippines’ Methane Emissions by Sector in 2019

Source: Our World in Data

Similarly, the open burning of biodegradable waste produces methane and

carbon dioxide emissions. However, the survey revealed an information gap,
wherein households confirmed the occurrence of open burning. At the same
time, some were unaware that open burning should not be done and is illegal
(see Figure 46). Thus, there was also a need to strengthen knowledge and
capacity to meet climate change solutions.

Figure 46: Household Survey Results – Open Burning

Source: COA Survey Results

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Although governments will be responsible for creating laws and institutions to

address the growing garbage nationally, individuals and communities may
contribute to lowering waste output (see Figure 47).

Figure 47: 5R’s of Waste Management

Source: Secretariat of the Pacific Regional Environment Programme Factsheet No.

PYCC-004 (Published in July 2009)

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Challenges
encountered that
prevented the
NSWMC and LGUs
from effectively and
efficiently
implementing
solutions
While LGUs were consistently provided with technical assistance, capability
support, and information dissemination on SWM, LGUs were still burdened
with challenges that hamper the effective and efficient implementation of their
10-yr SWM Plans. These challenges include inconsistent waste segregation
and collection implementation, non-establishment of MRFs and unutilized
SWM equipment, lack of recording mechanism in MRFs, recyclable wastes
overwhelming some MRFs, non-establishment of M/CENRO, and unequal
distribution of men and women in SWM. Hence, these challenges show that
while a national policy was available, the coherence and integration across
levels of government were not maintained and supported. These same
difficulties have also hindered the NSWMC in attaining the goals of RA 9003,
thus resulting in mixed waste collection, unnecessary hazards to workers in
landfills, and SLFs and MRFs exceeding capacity levels. On the other hand,
we also note some best practices observed during the validation.

Inconsistent Segregation plays a vital role in ensuring that the mandated waste diversion is
achieved and that the landfills receive less waste than the actual waste
implementation of generated. However, segregation was also a critical concern of LGUs, resulting
waste segregation in mixed waste collection, hazards to workers in landfills, and SLFs exceeding
nationwide capacity levels.

Mother Earth Foundation emphasized the importance of source segregation

in all households, with the LGUs as the focal point for its implementation.
According to RA 9003, segregation at source refers to an SWM practice of
separating, at the point of origin, different materials found in solid waste to
promote recycling and re-use of resources and to reduce the volume of waste
for collection and disposal. At the local level, LGUs prescribe a no-
segregation, no-collection policy as an ordinance that aims to prevent violating
prohibited acts indicated in Section 48 of RA 9003, which disallows the
collection of non-segregated or unsorted wastes.

However, decades after, the inconsistent waste segregation implementation

across the country was continually criticized. Likewise, in a press release by
Senator Win Gatchalian on February 11, 202034, it was revealed that only 30
percent (12,614) out of 42,045 barangays segregate solid waste, based on
data from the DENR.

34
‘Reduce, reuse, recycle’ a failure says Gatchalian; pushes for Waste-to-Energy technology. (2020,
February 11). Retrieved November 10, 2022, from https://legacy.senate.gov.ph/press_release/2020/
0211_gatchalian1.asp

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To help with this, the DENR also issued a statement in March 2021
encouraging the LGUs to establish ordinances instructing barangays to
undertake waste segregation at source and to act against those who will not
comply.35

Results of the survey conducted by the audit team on sample LGUs also echo
the same concern. For example, when asked whether an ordinance on
segregation-at-source had been passed and put into effect, 12 percent or 71
of the 591 LGU respondents were found to have no segregation ordinance36,
which emphasizes the issue further (see Figure 48 and Table 27).

Figure 48: Distribution of LGU Survey Respondents With and Without

Segregation-at-Source Ordinance

Source: COA Survey Results

Further analysis revealed that this issue might affect at least 1,160 MRFs if no
segregation is implemented, and MRFs may be underperforming, if not
overwhelmed, due to unsegregated wastes received.

Table 27: No. of LGUs With No Segregation Ordinance and No. of

Operational MRFs

No. of LGUs
Total No. of Total No. of
Region with No Segregation
Barangays Operational MRFs
Ordinance
CAR 2 132 4
NCR 2 48 2
2 8 184 185

35
DENR pushes for at-source waste segregation through local ordinances. (2021, March 9). Retrieved
November 10, 2022, from https://www.denr.gov.ph/index.php/ news-events/press-releases/2264-denr-
pushes-for-at-source-waste-segregation-through-local-ordinances
36
Based on survey results, 557 LGUs confirmed implementing an ordinance on segregation. However, only
520 LGUs have submitted a copy of the said ordinance.

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No. of LGUs
Total No. of Total No. of
Region with No Segregation
Barangays Operational MRFs
Ordinance
3 9 214 46
4A 2 81 26
4B 13 256 299
5 6 226 149
6 6 138 116
7 10 231 23
8 1 24 25
9 5 114 117
11 3 49 51
12 4 101 117
Total 71 1,798 1,160

Source: COA Survey Results

During validation, we confirmed the survey results and found that of the 45
barangays interviewed, nine confirmed they do not have a policy on “no
segregation, no collection” in place. On the other hand, 27 barangays have a
segregation policy, while four adopted their LGU segregation policy (see
Figure 49).

Figure 49: Distribution of Barangay Survey Respondents With and

Without Segregation-at-Source Policy

Source: COA Interview Results

However, even with an appropriate policy to enforce segregation, LGUs still

need their people’s active participation to succeed. This also necessitates that
LGUs properly educate their communities. Based on our household survey,
88 percent of respondents confirmed that they were required to segregate
waste (see Figure 50). On the other hand, 34 percent responded that they
have not yet attended any awareness program on SWM conducted by either
their barangay or LGU.

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Figure 50: Percentage of Household Survey Respondents Who are Aware

of Waste Segregation

Source: COA Survey Results

On the other hand, applicable to public places was another segregation

requirement in RA 9003, requiring a separate container for each type of waste
from all sources. In addition, for each solid waste container, there should be
proper markings or identifiers for on-site collection depending on its use, such
as “compostable,” “non-recyclable,’ “recyclable,” or “special waste,” or any
other classification as may be determined by the NSWMC.

However, it was only in CY 2020 that the NSWMC released guidelines

prescribing the color coding of waste bins/ bags according to its classification
as follows: green for “biodegradables,” blue for “recyclables,” red for
“household special waste,” and black for “residual waste.” The NSWMC
Resolution No. 1380, Series of 2020, prescribed the color coding to help all
stakeholders (e.g., households, tourists, business establishments, and waste
collectors) prevent the formation of mixed waste in handling and managing
solid waste.

Hence, with the two-decade gap, it was only expected that waste bins
implemented in LGUs vary in color, quantity, and labels (see Figure 51).

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Figure 51: Variation of Waste Bins

Source: COA Validation

The expected differences were reflected in various policies and memoranda

the local and regional governments implemented. For example, in one
municipality, the Municipality of San Isidro, Province of Nueva Ecija, their
ordinance on segregation and collection was enforced by using three
containers: one collected by a green truck was for “all scrap paper, plastic,
metals, glass, and plastic bottles,” the second collected by a red truck was for
“food, animal wastes, and garden wastes,” and the third collected by a blue
truck was for “everything not in the first and second categories such as
“disposable sanitary napkins and diapers, toy and flashlight batteries,
upholstery, pentel and ballpen, hazardous household wastes such as
dressings and bandages, expired medicines, shoes and slippers, mats, rags
upholstery.”

On the other hand, we conducted surveys of households as well as teachers

and students to determine their perception and knowledge of solid waste
segregation. As the primarily responsible for conducting segregation-at-
source, we validated whether segregation can succeed based on their
understanding and perception of colors and labels of waste containers.

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Figure 52: Waste Type and Container Identification by Select Group

Households
Students
Teachers

Source: COA Survey Results

Based on survey responses on waste type identification and waste container

identification, we found that households, students, and teachers have mostly
answered correctly in determining the waste types (see Figure 52). However,
the survey found a similar color and label recognition disparity among
households, students, and teachers.

What will happen when segregation is not consistently implemented?

Numerous papers describe the effects of lack of segregation on general waste,
including mixed waste collection and disposal and landfills at overcapacity
levels. Additionally, because households were disposing of healthcare waste
during this pandemic, the absence of segregation was more apparent.

When the pandemic affected the country in March 2020, segregation was
further impacted with the addition of segregating COVID-19-related waste
(e.g., used face masks, cotton, tissue papers, testing kits, etc.) which were
considered infectious and contaminated healthcare wastes per Section IV (c)
of NSWMC Resolution No. 1364. Per guidelines, COVID-19-related waste
should be segregated by using yellow plastics/ribbons as visual markers.
However, the survey revealed that 55.6 percent (200) of household survey

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respondents do not use yellow plastics/ ribbons as a sign of COVID-19-related

waste.

This lack of segregation was the most serious concern now that the country
was dealing with the pandemic. According to surveyed SLF workers,
healthcare wastes such as gloves and face masks were mixed with the
residual waste, contrary to NSWMC COVID-19 guidelines (see Figure 53).

Figure 53: Presence of COVID-19-Related Wastes in SLF per Respondent

Workers

Source: COA Survey Results

On the other hand, there was also a concern about tourists’ movement, which
can be a great source of solid waste. An interview with local officials from LGU
Baler, Aurora, revealed that prior to the pandemic, the public had frequently
been moving in and out of the country, as well as within the regions of the
Philippines. Traveling, especially in tourist hot spots has become the concern
of these LGU officials who manage the SWM in their jurisdiction. Further, an
interview with local officials from Balanga, Bataan, revealed that people, also
called “transients”, have moved indefinitely from one place to another to stay
longer. This has happened a lot during the lockdown period of the COVID-19
pandemic.

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To validate, we extracted data on the annual movement of tourists37 in the

Philippines, including Foreign Tourist Arrivals (FTAs)38 and Regional Travelers
(RTs)39 from the CYs 2012 to 2020 (see Table 28).

Table 28: Annual Foreign Tourist Arrivals and Regional Travelers from
CYs 2012 to 2020
FTA Growth RT Growth
Year FTAs RTs
Rate (%) Rate (%)
2012 4,272,811 9.07 23,858,406 -9.06
2013 4,681,307 9.56 26,566,834 11.35
2014 4,833,368 3.25 30,967,024 16.56
2015 5,360,682 10.91 37,842,030 22.20
2016 5,967,005 11.31 42,482,420 12.26
2017 6,620,908 10.96 47,049,242 10.75
2018 7,168,467 8.27 53,373,577 13.44
2019 8,260,913 15.24 56,766,370 6.36
2020 1,482,535 -82.05 11,873,332 -79.08
Total 48,647,996 330,779,235

Source: COA Analysis

The information provided above can help infer that the sheer number of tourist
movements reflects different knowledge and awareness levels among the
public regardless of whether they ascertained their segregation abilities.

Although the pandemic has badly hit the tourism industry since CY 2020, the
numbers are slowly picking up by 202240, as quarantine protocols were
relaxed to accommodate tourists again. These were tourists from different
backgrounds and places of origin with different understanding, knowledge,
and awareness of waste segregation.

Thus, without a streamlined mechanism on how the public can segregate solid
waste for collection, coupled with the movement of the public coming from
different places of origin for transient, tourism, and other purposes, waste
segregation will remain a problem for the majority of program implementers
and the environment.

Mixed Waste Collection. When proper segregation is not implemented, this

leads to mixed waste collection. Once the mixed waste is present in the
stream, it will take additional resources (e.g., time, labor, and money) to
segregate, clean, and decontaminate before it reaches the disposal facilities.
If left untreated, the probability of mixed waste approaching an SLF becomes
high, and final segregation, if still possible, is covered by waste sorters hired
by the SLF operator or LGU. Examples of mixed wastes reaching final disposal

37
Visitor Arrivals to the Philippines, and Regional Travelers. Retrieved November 10, 2022, from
http://www.tourism.gov.ph/tourism_dem_sup_pub.aspx
38
Foreign tourist arrivals (FTA) are foreign persons admitted under tourist visas (if required) for purposes
of leisure, recreation, holiday, visits to friends or relatives, health or medical treatment, or religious
pilgrimage.
39
Regional travelers (RT) consist of domestic travelers, foreign travelers, and overseas Filipinos travelling
from one region to another inside the Philippines.
40
PANTI. (2022, August 31). Department of Tourism: Philippines received 1.3M foreign tourists so far in
2022. GMA News Online. Retrieved November 10, 2022, from https://www.gmanetwork.com/news/
topstories/nation/843316/ dot-philippines-received-1-3m-foreign-tourists-so-far-in-2022/story/

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facilities were found in SLFs in La Trinidad, Benguet, Norzagaray, Bulacan,

and Navotas City, Metro Manila (see Figure 54).

Figure 54: Mixed Wastes Present in SLFs

Location: SLF in La Trinidad, Benguet

Left: Landscape view of SLF; Right: SLF workers sorting wastes

Location: SLF in Norzagaray, Bulacan

Left: Tipping area; Right: Central MRF and volunteer “sorters”

Location: SLF in Navotas City, Metro Manila

Source: COA Validation

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According to the MENRO in Norzagaray LGU, the Sangguniang Bayan

Ordinance requiring waste segregation-at-source was already in place.
However, LGU Norzagaray claims that the problem was that dump trucks
continue to receive mixed waste from households and barangays.

Similar to Norzagaray, LGU La Trinidad, Benguet also mandates segregation

at source and allows the issuance of citation tickets to violators. However, LGU
La Trinidad claims that the problem was the lack of segregation and limited
waste diversion since their Centralized MRF does not service all barangays.
In CY 2017, this SLF in La Trinidad was also reported to be nearly filled due
to a lack of segregation. According to reports, despite having personnel
assigned at trading posts to segregate waste, sacks, baskets, plastics, and
other unnecessary waste can still be found in the landfill

Therefore, even though policies demand segregation, the compliance of waste

generators was still necessary for the policy to be successful.

To resolve the mixed wastes for disposal to landfills, the Norzagaray LGU
allows volunteers to conduct sorting at the centralized MRF beside the SLF’s
tipping area/residual waste cell. On the other hand, LGU La Trinidad, Benguet
hires sorters to conduct the final sorting of the mixed wastes disposed of in the
SLF tipping area.

However, both efforts seem lacking because mixed wastes remained after
final sorting. Moreover, those workers or sorters are also at risk of scavenging
through the waste. For example, in Cell No. 3 in the SLF in La Trinidad, the
mountain of garbage measures as high as 5 to 6 meters.

Hazards to Workers at Landfills. Workers that deal directly with solid waste
were either involved in waste collection, sorting, recycling, or disposal at the
end of the process. However, additional occupational risks come with this kind
of labor that workers rarely acknowledge in order to survive. Thus, to protect
them, it was mandated, through the IRR of RA 9003, that all collectors and
other personnel directly dealing with the collection of solid waste shall be
equipped with personal protective equipment and paraphernalia such as, but
not limited to gloves, masks, and safety boots, to protect them from the
hazards of handling solid wastes.

However, during the validation of SLFs, we found that workers were not
equipped with personal protective equipment and paraphernalia, contrary to
RA 9003. For example, as shown in Figure 54, La Trinidad and Norzagaray
SLFs have sorters to conduct final segregation. However, these sorters were
found sorting waste materials with their bare hands. This was despite the fact
that 88 percent of the workers surveyed, in the three SLFs accepting mixed
waste had found used hospital gloves and face masks in the area where they
were gathering recyclable waste (see Figure 55). On the other hand, these
workers answered that they were provided with protective equipment but
opted not to wear it due to the hot weather.

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Figure 55: Percentage of Worker Survey Respondents Who Found Used

Face Masks and Gloves in SLFs

Source: COA Survey Results

The inadequate use of personal protective equipment in such a work

environment will negatively impact the health conditions of the workers as they
are highly susceptible to infectious diseases, injuries, and accidents.
According to the International Journal of Occupational Safety and Health,
waste workers suffer from diseases and face many health problems. Runny
nose, sneezing, coughing, respiratory symptoms, frequent headache, and
musculoskeletal symptoms like tiredness, backache, and body pain were
common symptoms they faced. Similarly, skin rashes, vomiting, and diarrhea
were common problems waste pickers experienced.41

Based on the survey conducted on 39 workers from nine SLFs, we noted that
most had a cold, fever, and cough, while others have experienced eye or nasal
irritation, skin disease, gastrointestinal problems, cholera, and pulmonary
disorder (see Figure 56).

41
Baral, Y. R. (2018, December 31). Waste Workers and Occupational Health Risks. International Journal
of Occupational Safety and Health, 8(2), 1–3. Retrieved October 5, 2022, from https://doi.org/10.3126/
ijosh.v8i2.23328

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Figure 56: Distribution of SLF Worker Survey Respondents by Type of

Disease Caught or Experienced While at Work

Source: COA Survey Results

In addition, some of these workers suffered from insect bites, sprains,

contusions, and lacerations (see Figure 57). Needles or syringes wounded
three workers, and nine were injured by sharp objects like broken glass mixed
with residual and biodegradable wastes, which can lead to infections such as
COVID-19 that can be contagious and endanger everyone.

Figure 57: Distribution of SLF Worker Survey Respondents Who

Caught/Suffered Injuries Caught While at Work

Source: COA Survey Results

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Their experiences show that wearing personal protective equipment was

crucial in ensuring their safety. This will protect workers from bacteria,
contaminated objects, and hazardous chemicals and pathogens by acting as
a barrier and reducing transmission. This will also lower their risks of injuries
caused by falling objects, sharp objects, and accidents.

COVID-19 Healthcare Waste. As mentioned in the survey conducted in three

SLFs accepting mixed waste (Figure 55), 88 percent of the workers had
observed hospital gloves and face masks where they gathered recyclable
waste. This maybe the case because used masks were usually disposed of
as general waste mixed with the municipal waste stream. Aside from face
masks, COVID-19 requires everyone to wear face shields to prevent disease
transmission. Hence, the NSWMC released an interim guideline on managing
COVID-19-related healthcare waste to avoid this further on April 25, 2020.
This guideline covers proper handling and managing of the said waste
generated by households, offices, and the like because these are potentially
infectious and contaminated. In congruence, DILG also issued Memorandum
Circular (MC) No. 2020.147 on October 29, 2020, to support the interim
guidelines of the NSWMC to provide comprehensive information on roles,
duties, and responsibilities on the proper handling and management of all
COVID-19-related healthcare wastes within the jurisdiction of the LGUs.

Also emphasized in the NSWMC COVID-19 guidelines was that waste

generators shall strictly implement proper waste segregation at the source and
ensure that COVID-19-related infectious wastes are not mixed with other
domestic solid wastes. Moreover, it required that COVID-19-related infectious
wastes shall be stored in yellow plastic bags/container bins or any storage
bags/container bins properly labeled. But the household survey results
showed that, 56 percent or 200 people were not using a yellow plastic bin or
yellow ribbon for their COVID-19-related waste (see Figure 58).

Figure 58: Percentage of Household Survey Respondents Using Yellow

Plastic Bag or Yellow Ribbon for COVID-19-Related Waste

Source: COA Survey Results

With the rapid increase in consumption of household healthcare wastes such

as masks and gloves, a technical system is needed for segregation, collection,
and transport to proper disposal, including proper storage and treatment.
Moreover, there is also a need to check the condition of our waste workers
since workers are compromising their health, yet they are hardly

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acknowledged and lack support. These workers play a vital role in recovering
recyclable materials at final disposal in SLFs and filling the gaps in managing
solid waste due to the weak enforcement of segregation by the respective
LGUs that led to mixed waste disposal. Without them, the recyclable materials
will mix with other types of waste that fill up the SLFs faster and harm the
environment by increasing carbon emissions.

MMDA reports about challenges due to waste management. There were

also reports of unsegregated solid wastes that did not reach disposal facilities.
These affect the drainage systems resulting in unnecessary flooding in Metro
Manila, the capital of the Philippines. MMDA has reminded the public to be
responsible and disciplined in throwing their waste into legitimate solid waste
containers.42 The agency said that they do cleaning and declogging of the
drainages every day; however, wastes always appear the following days.
Some examples of the solid wastes they found were plastic bags, styro foam,
plastic cups, and plastic bottles, all non-biodegradables, and should be
brought to waste facilities or MRFs for diversion.

SLFs Have Exceeded Capacity Levels. Aside from the survey results
illustrated in Figures 55 and 57, several accounts made by the SLF workers
highlighted the risks looming in their everyday work, including workers’ worries
in La Trinidad SLF over the risk of a “trash slide” accident every time it rains
heavily in Benguet. This concern of workers in the SLF is due to the incident
in Barangay Irisan, Baguio City, wherein the wall of the dumpsite collapsed
after it was flooded at the height of Typhoon Mina last August 27, 2011, in
which at least five people were killed.43

The mountain of mixed waste at Cell 3 in La Trinidad SLF already required its
early closure in September 2018, only 19 months from its inception. This Cell
3, with a 3-year life span, began its operation in February 2017 with an area
of 4,000 m2 and a capacity of an estimated 34,810 cu.m. However, based on
CY 2019 waste data provided by La Trinidad LGU, the LGU’s estimated daily
total solid waste generation per day is 66.99 tons, and only 5.6 tons were
diverted. If the behavior pattern is the same since CY 2017, the LGU would
have accumulated a total of 70,280.87 cu.m. for the 19-month duration of the
operation, which is almost twice the capacity of the SLF (see Table 29).
According to reports44, the local government blamed the lack of segregation
as the culprit and admitted that many plastics were mixed with the residual
waste, which was also evident during our validation.

42
Dahil sa walang disiplinang pagtatapon ng basura. MMDA. Retrieved January 4, 2023, from
https://www.facebook.com/100068612142206/posts/334536202176782
43
Mina triggers fatal avalanche of garbage in Baguio City. GMA News Online. Retrieved January 4, 2023,
from https://www.gmanetwork.com/news/topstories/regions/230808/mina-triggers-fatal-avalanche-of-garb
age-in-baguio-city/story/
44
Alno sanitary landfill full by end of 2017. Sunstar. Retrieved January 4, 2023, from https://www.sunstar.
com.ph/article/165624/alno-sanitary-landfill-full-by-end-of-2017

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Table 29: Computation of Waste Disposed at La Trinidad Cell 3 SLF

Exceeding its Capacity

Particulars Value
Total number of days of SLF operation (February 2017-
607 days
September 2018)
x Average daily tons of waste disposed at Cell 3 x 61.39
= Total tons of waste disposed at Cell 3 (A) 37,263.73
Conversion to metric tons (A x 0.907185) (B) 33,805.10
Conversion to kilograms (B x 1,000) 33,805,096.90
Total accumulated waste disposed at Cell 3
70,280.87
(Converted to cubic meter with 481 density)

Source: COA Analysis using the CY 2019 LGU Waste Data

At the time of validation, the accumulated mountain of waste measured from

5-6 meters in height, which was higher than the maximum designed height
requirement of 2.9 meters from the pavement or road level or 4 meters from
the ground level. According to monitoring reports by EMB CAR, this waste
reached 7 meters high in February 2022 despite its closure in CY 2018
because the SLF was still being used as the staging area.

This case of La Trinidad SLF was not unique, as at least 29 SLFs in September
2022 have already exceeded their capacity level (see Table 30).

Table 30: Number of SLFs Exceeding their Capacity by Region

As at December 31, 2021 As at September 15, 2022

Region Operational Exceeded Operational Exceeded
SLF Capacity SLF Capacity
CAR 10 0 9 0
NCR 1 0 1 0
1 31 8 51 8
2 41 2 41 2
3 12 0 15 0
4A 43 3 44 5
4B 12 1 13 1
5 7 0 9 0
6 13 1 15 1
7 15 0 16 0
8 6 2 10 2
9 1 0 2 0
10 19 4 20 3
11 9 1 8 2
12 21 1 21 5
13 4 0 4 0
BARMM 0 0 1 0
Total 245 23 280 29
% of Exceeded
9.39 10.36
Capacity

Source: NSWMC and DENR-EMB Data

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Similar to La Trinidad SLF, aside from these SLFs exceeding their capacity,
some SLFs were also unable to complete nor maximize their original service
life. Of the 29 SLFs reported to have exceeded capacity in September 2022,
four SLFs only started operating in CY 2019 and have a service life of 10
years, and nine SLFs remain operational despite completing their service life.

Because these SLFs exceeded their capacity, LGUs will have to look for other
means to dispose of their waste. Hence, LGUs will have to find another SLF
or LGU that is willing to accept their waste and incur tipping fees. Otherwise,
they will have to expand their existing landfill or look for another site to
construct another one.

As regards the situation in La Trinidad, LGU had to haul and transport waste
to the SLFs in Urdaneta, Pangasinan, and Capas, Tarlac, using its dump
trucks to reduce its disposal costs. In addition, LGU La Trinidad incurred
tipping fees totaling ₱24.1 million for four years (see Table 31) since Cell 3
had been unserviceable for three years and used only for 19 months.

Table 31: Total Tipping Fees Paid by the LGU La Trinidad, Benguet from
CYs 2018 to 2021

Year Actual Amount Spent on Tipping Fees

2018 ₱ 3,500,000
2019 7,100,000
2020 5,500,000
2021 8,000,000
Total ₱24,100,000

Source: LGU data

Consequently, if the mismanagement and overcapacity of existing SLFs

continue, eventual scouting for the future land availability of new sites will be
necessary. However, establishing a new SLF will be difficult for some
provinces, including Benguet, a mountainous area. Also, the LGUs may be
overwhelmed by the rising need for more waste disposal sites and may face a
scarcity of land in the long run.

Extended risks to the people and environment. Validation revealed that the
situation in some SLFs may pose extended risks to the people and
environment. For example, site visits to nine SLFs and nine dumpsites
revealed establishments within the 200-meter radius of the SLF or dumpsite
(see Figure 59). This is a prohibited act under RA 9003, specifically the
construction of any establishment within 200 meters of open dumps, controlled
dumps, or SLFs.

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Figure 59: Establishments within a 200-Meter Radius of SLFs and Dumpsites

Source: Google Earth

On the other hand, survey results revealed that there were also information
gaps as to whether or not establishments are allowed near landfills and
dumpsites. Of the 360 households surveyed, 33 percent believe
establishments were allowed within 200 meters of SLFs (see Figure 60).

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Figure 60: Percentage Distribution of Household Survey Respondents on

Establishments within 200-Meter Radius from Dumpsites and SLFs

Source: COA Survey Results

According to DENR-EMB, the LGU is responsible for monitoring and ensuring

that no establishments are built within 200 meters of the open dumps,
controlled dumps, or SLFs. When establishments are built, the action or
solution shall be the removal and relocation of the establishment/structure built
within the 200-meter radius of the SLF. The LGU shall coordinate with the
National Housing Authority (NHA), other government agencies, NGOs, and
people organizations concerned to determine the assistance needed in the
possible relocation and alternative livelihood for the families affected by the
disposal site.

On the other hand, there was also an issue with closed dumpsites. Even
though it was legally closed, risks were still present, especially in dumpsites
where the rehabilitation was not yet implemented or the progress was minimal.
Hence, it was also necessary to relocate the community or families living within
the 200-meter radius of the dumpsite until such was closed and fully
rehabilitated.

Overall, exposure to either landfill or dumpsite may lead to health problems

such as pulmonary disorders, eyes/nasal/skin irritation, and gastrointestinal
problems. According to the Oxford University Press in 2016, health is at risk
for those who live within five kilometers of a landfill site. The results showed a
strong association between Hydrogen Sulphide (used as a surrogate for all
pollutants co-emitted from the landfills) and deaths caused by lung cancer, as
well as deaths and hospitalizations for respiratory diseases, which are more
prominent in children. In addition, respiratory symptoms were detected among
residents living close to waste sites due to inhalation exposure to endotoxin,
microorganisms, and aerosols.45

45
Oxford University Press. (2016, May 24). Living near a landfill could damage your health. Retrieved
September 7, 2022, from https://www.science daily.com/releases/2016/05/160524211817.htm

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Moreover, it poses a greater risk for people living near the dumpsites due to
the absence of safety measures that SLFs have, particularly when people are
still disposing of waste despite the reported closure of all the dumpsites. In
addition, nearby water was more prone to pollutants caused by leachate, and
more gases were produced, affecting the air. The Clinical Epidemiology and
Global Health concluded in its study on open dumping sites and health risks
to proximate communities in Mumbai, India, that morbidities’ prevalence was
significantly higher among the exposed group than the non-exposed group
(see Table 32).46

Table 32: Comparison of Morbidities Between the Exposed Group and

Non-Exposed Group Dumpsites

Selected Morbidities Exposed Group v Non-exposed Group

Respiratory illness 23% v 10%
Eye irritation 20% v 9.5%
Stomach problem 27% v 20%

Source: Clinical Epidemiology and Global Health

However, interviews with DENR-EMB Regional Offices showed no consistent

procedure for reprimanding LGUs that disregard the law on the 200-meter
distance. For example, Region 3 sends an NOV to LGU-violators, Region 4A
reminds LGUs of their responsibilities through a letter, while Region 7 has no
record of penalties issued.

Inconsistent According to RA 9003, segregation and collection of solid waste, specifically

for biodegradable, compostable, and reusable wastes, shall be conducted at
implementation of the barangay level. On the other hand, the collection of residual wastes shall
waste collection be the responsibility of the municipality or city. However, during validation, we
nationwide noted that collection assignments and responsibilities differed in actual due to
either limitation at the barangay level or a lack of coordination with their local
government. Thus, LGUs cover and collect all types of waste, or household
wastes were not collected.

Interviews with barangay officials disclosed various ways of waste collection

at the local level. As shown in Table 33, out of the 45 barangays, only 11
collected all wastes from their households, while the remaining barangays
varied from collecting only recyclable wastes to not collecting at all.

46
Shri Kant Singh, et al., (2020, July). Open dumping site and health risks to proximate communities in
Mumbai, India: A cross-sectional case-comparison study. Clinical Epidemiology and Global Health.
Retrieved September 7, 2022, from https://www.researchgate.net/publication/342669314_Open_
dumping_site_and_health_risks_to_proximate_communities_in_Mumbai_India_A_cross-sectional_case-
comparison_study

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Table 33: Distribution of Barangay Survey Respondents on Waste

Collection Responsibilities by Activity

Collection Activity No. of Barangays

All types of wastes 11
Recyclables and Biodegradables 5
Recyclables and Residuals 2
Recyclables only 10
Residuals only 1
None. LGU collects all the wastes 11
None. LGU also does not collect wastes 2
No answer 3
Total 45

Source: COA Interview Results

Moreover, some barangays claim there was no need to collect waste,

particularly biodegradable waste, because residents already use it to generate
fertilizer for their plants. On the other hand, some barangays also raised the
issue of a lack of adequate budget to cover the responsibility of barangays for
SWM, even for collecting household waste. Based on the comparison of the
annual budget of barangays to their budget allocated for SWM, allocation
varies from 0.33 percent to 16 percent in visited barangays in NCR and 0 to
8.75 percent in Regions 1, 3, 4A, 5, 9, 11, and CAR (see Table 34).

Table 34: Annual Barangay Budget vis-à-vis SWM Budget of Sample

LGUs by Region

Total Budget SWM Budget %

Region Province LGU Barangay
(B) (A) (B/A)

Bagong
Quezon City ₱123,000,000.00 ₱ 400,000.00 0.33
Silangan
NCR Metro Manila Pasig Rosario 96,000,000.00 6,800,000.00 7.08
Malabon Panghulo 25,000,000.00 4,000,000.00 16.00
Abra Pidigan Poblacion 3,097,296.00 5,000.00 0.16
CAR
Benguet Kibungan Sagpat 1,560,000.00 25,000.00 1.60
Mangatarem Sapang 2,000,000.00 - 0.00
Pangasinan Bugallon Padilla 4,000,000.00 35,000.00 0.88
1
Alcala Caranglaan 2,219,584.00 46,219.00 2.08
La Union Pugo Maoasas Norte 3,000,000.00 70,000.00 2.33
Zambales Masinloc North Poblacion 4,552,037.00 9,000.00 0.20
San Jose
3 Bulacan Minuyan 3 5,024,455.00 150,000.00 2.99
Del Monte
Bataan Balanga Lote Pto. Rivas 6,573,184.00 270,000.00 4.11
Quezon Atimonan Inaclagan 2,378,600.00 20,000.00 0.84
4A Cavite Kawit Aplaya 5,000,000.00 67,000.00 1.34
Rizal Tanay Tandang Kutyo 73,045,588.45 1,520,000.00 2.08
5 Bula Sto Niño 3,200,000.00 5,000.00 0.16

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Total Budget SWM Budget %

Region Province LGU Barangay
(B) (A) (B/A)

Sagnay Minadongjol 4,100,000.00 10,000.00 0.24

Camarines
Libmanan Bagumbayan 4,600,000.00 35,000.00 0.76
Sur
Pili San Jose 17,000,000.00 210,000.00 1.24

Zamboanga Kumalarang Poblacion 9,700,000.00 20,000.00 0.21

del Sur Lakewood Poblacion 7,400,000.00 120,000.00 1.62
9
Zamboanga
Mabuhay Catipon 2,200,000.00 65,000.00 2.95
Sibugay
Davao del Sur Davao City Mintal 23,000,000.00 200,000.00 0.87
11 New Bataan Cabinuangan 13,666,081.00 340,000.00 2.49
Davao de Oro
Mabini Cuambog 8,000,000.00 700,000.00 8.75
Total ₱449,316,825.45 ₱15,122,219.00 3.37

Source: COA Interview Results

With little to no budget for SWM, some barangays also have no choice but to
make ends meet and collect household waste whenever there is a lack of
coordination or when their local government fails to collect waste from their
jurisdictions. However, if that were not a workable option for a barangay, then
those households, purok, or even a whole barangay would have no one to
collect their solid wastes.

As mentioned earlier, a good practice called the “purok system” was also
observed during validation. Under the purok system, barangays set up
collection points in strategic areas where residents put their waste so that
when the day and time of waste collection comes, the LGU or barangay can
collect their waste more efficiently. According to the barangays implementing
this system, there are two points to make this work. First, there should be a
waste collection schedule to avoid unsegregated waste. Second, this schedule
must be communicated to residents through IEC to ensure they know the
schedule for collecting specific types of waste.

Some EMB-funded Following Section 8 of RA 9003, to support the LGUs in implementing their
local SWM plans, DENR, through EMB, has provided financial assistance to
MRFs, including LGUs to establish MRF and fabricate SWM equipment since CY 2012 (see
several units/sets Table 35). On the other hand, to further increase LGUs’ compliance with the
of equipment, were mandatory waste diversion, starting in CY 2016, DENR-EMB transferred sets
neither established of equipment (shredder and composter) to LGUs as support to existing MRFs.
However, validation revealed that some financial assistance was either
nor operational unutilized or refunded, while several units/sets of equipment were not
operational.

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Table 35: DENR-EMB’s MRF Assistance to LGUs from CYs 2012 to 2021

Establishment of
Establishment MRF and Donation of
Year Total
of MRF Fabrication of SWM MRF Equipment
Equipment47
2012 ₱ 16,000,000 ₱ - ₱ - ₱ 16,000,000
2013 26,350,000 - - 26,350,000
2014 26,000,000 - - 26,000,000
2015 21,500,000 - - 21,500,000
2016 60,000,000 - 40,000,000 100,000,000
2017 53,000,000 - 22,000,000 75,000,000
2018 150,000,000 20,000,000 75,000,000 245,000,000
2019 - 336,000,000 - 336,000,000
2020 - - 490,000,000 490,000,000
2021 - - 320,000,000 320,000,000
Total ₱352,850,000 ₱356,000,000 ₱947,000,000 ₱1,655,850,000
No. of
1,076 600 1,510*
LGUs
*Data on the number of LGU recipients for CY 2017 is unavailable.

Source: DENR-EMB Data

Some EMB-funded MRFs were not yet established or not operational.

DENR, through EMB, has provided total financial assistance of ₱708.85
million and supported 1,676 LGUs nationwide for eight consecutive years to
establish MRFs for LGUs to meet the requirement of RA 9003 on mandatory
waste diversion (see Table 36).

Table 36: DENR-EMB’s Financial Assistance to LGUs for the

Establishment of MRF and Fabrication of SWM Equipment from CYs 2012
to 2019

Establishment of
Establishment of MRF and
Year Total
MRF Fabrication of
SWM Equipment
2012 ₱ 16,000,000 ₱ - ₱ 16,000,000
2013 26,350,000 - 26,350,000
2014 26,000,000 - 26,000,000
2015 21,500,000 - 21,500,000
2016 60,000,000 - 60,000,000
2017 53,000,000 - 53,000,000
2018 150,000,000 20,000,000 170,000,000

47
In CYs 2018 to 2019, LGUs have the discretion to divide the financial assistance between the
establishment of MRF and the fabrication of SWM equipment. Hence, DENR-EMB has no information on
the amount allocated for MRF and equipment and the number of LGUs that opted to fabricate equipment.

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Establishment of
Establishment of MRF and
Year Total
MRF Fabrication of
SWM Equipment
2019 - 336,000,000 336,000,000
Total ₱ 352,850,000 ₱ 356,000,000 ₱ 708,850,000
No. of LGUs 1,076 600 1,676

Source: DENR-EMB Data

However, based on the review of balances, there were at least ₱189.92 million
and ₱124.22 million outstanding balances from the financial assistance to
LGUs as at December 31, 2021 and June 30, 2022, respectively (see Table
37).

Table 37: Outstanding Balances of Financial Assistance to LGUs for the

Establishment of MRFs as at December 31, 2021, and June 30, 2022

Region December 31, 2021 June 30, 2022

CAR ₱ 7,540,911.25 ₱ 6,903,512.81
NCR 17,499,500.00 13,095,000.00
1 1,514,369.34 447,352.38
2 23,103,565.34 16,602,018.57
3 4,644,742.73 2,199,631.20
4A 7,568,452.48 4,895,423.09
4B 14,602,026.87 12,419,742.92
5 11,639,629.54 9,065,754.65
6 5,910,055.69 2,297,593.34
7 1,401,693.17 1,401,693.17
8 16,881,377.30 16,881,377.30
9 29,428,000.00 10,479,298.82
10 29,585,000.00 12,202,414.44
11 322,531.00 291,511.00
12 6,300,000.00 6,300,000.00
13 11,977,402.45 8,738,875.26
Total ₱ 189,919,257.16 ₱ 124,221,198.95
No. of MRFs 612 435

Source: DENR-EMB Data

Further analysis revealed that of this ₱124.22 million outstanding balance as

at June 30, 2022, ₱14.32 million was already outstanding for 6-10 years,
₱45.91 million outstanding for 4-5 years, and ₱63.99 million for three years
(see Table 38).

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Table 38: Aging of DENR-EMB Outstanding Financial Assistance to LGUs

for the Establishment of MRFs as at June 30, 2022

Region 3 years 4 to 5 years 6 to 10 years

CAR ₱ 4,885,462.42 ₱ 1,840,771.10 ₱ 177,279.29
NCR/CO 7,981,500.00 1,465,000.00 3,648,500.00
1 261,349.42 186,002.96 -
2 12,267,043.55 3,673,402.86 661,572.16
3 1,014,321.95 645,309.25 540,000.00
4A 2,947,904.35 1,947,518.74 -
4B 1,977,318.25 8,590,924.67 1,851,500.00
5 4,157,379.12 4,908,375.53 -
6 2,297,593.34 - -
7 - 800,000.00 601,693.17
8 9,076,814.64 7,163,249.65 641,313.01
9 6,275,134.41 1,353,150.70 2,851,013.71
10 2,863,397.24 6,493,623.10 2,845,394.10
11 - 285,000.00 6,511.00
12 2,500,000.00 3,800,000.00 -
13 5,484,078.32 2,754,678.94 500,118.00
Total ₱ 63,989,297.01 ₱ 45,907,007.50 ₱ 14,324,894.44
No. of MRFs 159 221 55

Source: DENR-EMB data

Moreover, of the ₱124.22 million outstanding as at June 30, 2022, fund

transfers to LGUs totaling ₱41.57 million remain outstanding with no
movement or liquidation at all (see Table 39).

Table 39: Fund Transfers to LGUs With No Liquidation Since Grant Year
as at June 30, 2022

Year of Grant Amount Granted/Balance

2015 ₱ 350,000.00
2016 1,440,000.00
2017 2,936,500.00
2018 8,829,000.00
2019 28,010,000.00
Total ₱41,565,500.00
No. of MRFs 89

Source: DENR-EMB Data

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Not surprisingly, some LGUs refunded the full financial assistance to the BTr.
As at June 30, 2022, these refunds were equivalent to at least ₱2.32 million
from six LGUs (see Table 40).

Table 40: LGUs with Full Refund of Financial Assistance as at June 30,
2022

Year Amount Granted/

LGU Recipients
Granted Refunded
Tuguegarao City, Cagayan 2016 ₱ 285,000.00
Bambang, Nueva Vizcaya 2017 260,000.00
Makatao, Aklan* 2018 427,500.00
Lallo, Cagayan 2019 300,000.00
San Juan City, NCR 2019 570,000.00
Talalora, Samar 2019 475,000.00
Total ₱2,317,500.00
* No available MRF area, as disclosed by the LGU

Source: DENR-EMB Data

During validation, we visited some of the LGUs with either outstanding

balances or refunded the financial assistance provided by DENR-EMB.

The MRF in the Municipality of Pidigan was not yet constructed despite
funding in CY 2018. According to the MENRO, the LGU Pidigan initially
intended to establish a centralized MRF with additional funding from the
Development Fund. However, the initially proposed land allocated for the
construction of the MRF was discovered to be privately owned, which the LGU
could not utilize. As an alternative, the LGU planned to allocate a space in the
area where LGU intends to build the hospital and fire station. However, some
LGU officials objected due to the proximity to the hospital, which may cause
health risks. As the LGU Pidigan could not establish the MRF in years passed,
when the pandemic hit the country, the LGU Pidigan realigned the supposed
additional fund allocation for the MRF to build an isolation facility instead.

Aside from the LGUs listed in Table 40, there was also the Barangay Mintal in
Davao City, which refunded a total of ₱358,000 in CY 2020. According to the
barangay, they received the grant in CY 2016 but encountered issues in land
ownership and acquiring legal documents for the proposed site.

Due to the challenges disclosed by these LGUs, the refund and non-
establishment of MRFs only showed that financial grants were transferred
without ensuring that the LGUs could provide available land within their
jurisdiction to qualify as recipients. Likewise, the financial grants that become
idle due to the different issues encountered would have benefited other LGUs
that might have qualified or can establish the MRFs.

On the other hand, there were also those established MRFs that were found
to have damages and thus disrupting the MRF operation and waste diversion.
And since it is already established that LGUs lack funds for SWM, repairs and
replacements of damages in MRFs are not a priority. For example, on

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December 16, 2021, Super Typhoon Odette made nine landfalls in seven
provinces of the Visayas and Mindanao, bringing torrential rains, violent winds,
storm surges, and floods that left devastation across several islands. One of
the provinces affected is Bohol, of which two MRFs we visited were noted to
have been severely damaged by the typhoon (see Figure 61).

Figure 61: MRF in Bohol Damaged by Super Typhoon Odette

Source: COA Validation

Both the MRFs in Barangay Lonor Sur in Inabanga, Bohol, and Barangay
Bolod in Panglao, Bohol, remained in a state of needing repair at the time of
our validation in late April 2022, even after four months since Super Typhoon
Odette hit the province. According to both LGUs, the local government’s efforts
were still focused on the COVID-19 response since the pandemic is still
ongoing. In addition, due to the limited resources of the LGUs, they had to
prioritize renovating other damaged properties, such as healthcare facilities.

Several SWM Equipment were not operational. As mentioned, in CY 2016,

DENR-EMB started providing equipment to LGUs to improve waste diversion
and complement its previous fund assistance in establishing the MRFs since
CY 2012. As shown in Table 41, DENR-EMB targeted to donate equipment to
at least 1,510 LGUs totaling at least ₱947 million (see Table 41).48

48
In CYs 2018 and 2019, DENR-EMB has provided ₱356 million for the establishment of MRF and
fabrication of SWM equipment, however, as noted in Table 36, DENR-EMB cannot determine the amount
allocated for the fabrication of equipment as well as number of LGUs opting to fabricate equipment. Hence,
we opted not to include the amount of ₱356 million in the balance.

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Table 41: Fund Support for SWM Equipment from DENR-EMB Central Office by Region from CYs
2016 to 2021

Region 2016 2017* 2018 2020 2021 Total

CAR ₱ 2,000,000 ₱ 400,000 ₱ 4,650,000 ₱ 8,000,000 ₱ 7,000,000 ₱ 22,050,000
NCR 2,000,000 1,800,000 4,650,000 - 3,000,000 11,450,000
1 2,200,000 1,200,000 4,650,000 47,000,000 27,000,000 82,050,000
2 2,200,000 1,200,000 4,650,000 30,000,000 30,000,000 68,050,000
3 2,800,000 3,000,000 4,800,000 15,000,000 10,000,000 35,600,000
4A 2,800,000 2,600,000 4,800,000 28,000,000 10,000,000 48,200,000
4B 2,200,000 1,400,000 4,650,000 31,000,000 11,000,000 50,250,000
5 2,600,000 600,000 4,650,000 48,000,000 42,000,000 97,850,000
6 2,200,000 800,000 4,650,000 56,000,000 40,000,000 103,650,000
7 2,200,000 1,000,000 4,650,000 47,000,000 39,000,000 93,850,000
8 3,000,000 1,200,000 4,800,000 27,000,000 33,000,000 69,000,000
9 2,200,000 1,000,000 4,650,000 19,000,000 25,000,000 51,850,000
10 2,200,000 1,000,000 4,650,000 34,000,000 24,000,000 65,850,000
11 2,400,000 1,200,000 4,800,000 36,000,000 7,000,000 51,400,000
12 2,400,000 1,400,000 4,650,000 39,000,000 7,000,000 54,450,000
13 2,400,000 800,000 4,650,000 25,000,000 5,000,000 37,850,000
BARMM - - - - - -
Negros Island
2,200,000 1,400,000 - - - 3,600,000
Region (NIR)
Total ₱ 40,000,000 ₱ 22,000,000 ₱ 75,000,000 ₱ 490,000,000 ₱ 320,000,000 ₱ 947,000,000
No. of LGU
200 Not available 500 490 320 1,510*
Recipients
*Data on the number of LGU recipients for CY 2017 is unavailable.

Source: DENR-EMB Data

However, according to data gathered by DENR-EMB Regional Offices, at least

₱555.65 million worth of equipment or at least 635 units or sets of equipment
were reported as not operational as at May 31, 2022 (see Table 42).

Table 42: Total Value of Equipment Reported as Not Operational by Region from CYs 2016 to 2021

Region 2016 2017 2018 2019 2020 2021 Total

CAR ₱ - ₱ - ₱ - ₱ - ₱ 5,000,000 ₱ 7,000,000 ₱ 12,000,000
NCR - - - - 12,740,000 - 12,740,000
1 - - - - 36,000,000 15,000,000 51,000,000
2 - - - - - 29,910,000 29,910,000
3 - - - - - 72,740,000 72,740,000
4A - - - - - 67,000,000 67,000,000
4B - - - - - 5,000,000 5,000,000
5 - - - - 34,000,000 35,100,000 69,100,000

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Region 2016 2017 2018 2019 2020 2021 Total

6 - - - - 41,000,000 26,000,000 67,000,000
7 - - - 478,200 - - 478,200
8 – 1,160,000 3,152,400 237,400 - 33,630,000 38,179,800
9 1,000,000 400,000 3,000,000 - 13,000,000 18,000,000 35,400,000
10 200,000 - 712,500 350,000 - 53,940,000 55,202,500
11 - - - - - 12,200,000 12,200,000
13 400,000 - 300,000 - 23,000,000 4,000,000 27,700,000
Total ₱1,600,000 ₱1,560,000 ₱7,164,900 ₱1,065,600 ₱164,740,000 ₱379,520,000 ₱555,650,500
Units/
Sets of
8 10 54 5 165 393 635
Equip-
ment

Source: DENR-EMB Data

According to the DENR-EMB Regional Offices, the lack of electricity lines

topped why several units/sets of equipment provided to LGUs are not
operational, as presented in Table 43. Surprisingly, two LGUs declined the
donated equipment.

Table 43: Distribution and Value of Not Operational Equipment by Cause

No. of Total Cost of

Reason
Units/Sets Equipment
No electricity line 128 ₱ 104,477,700.00
For installation to an appropriate facility 96 89,188,700.00
For training and demonstration of supplier 85 79,396,000.00
For upgrade of an electrical system or
65 65,350,000.00
procurement of a transformer
Ongoing or delayed MRF construction 48 34,815,400.00
Unutilized 15 13,662,200.00
Lack of manpower 20 13,612,500.00
Damaged/defective 21 12,444,000.00
No collection of biodegradable waste 6 6,000,000.00
LGU declined the equipment 2 1,960,000.00
Unserviceable 4 645,000.00
Total 490 ₱ 419,551,500.00

Source: DENR-EMB Data

During validation, we visited several LGUs with SWM equipment that are not
operational and validated the causes noted above (see Table 44 or Appendix
III for the complete TSO findings).

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Table 44: Distribution of Not Operational SWM Equipment by Cause and Source

SWM Equipment from 4 units of equipment were not operational because of the absence of electricity lines
DENR-EMB: in 2 MRFs
15 units of equipment need upgrading of electrical system or procurement of
39 units of equipment transformer to operate
were found to be not 1 unit of equipment needs a 3-Phase power connection, but the MRF can only support
operational single phase
1 unit of equipment was defective and subject to repair
4 units of equipment were not yet installed
12 units of equipment were waiting for staff training and supplier demonstration
2 units of equipment were unutilized
SWM Equipment from 8 units of equipment were not operational because of the absence of electricity lines in
DA, DOST and LGU: 5 MRFs
14 units of equipment need upgrading of electrical system or procurement of
26 units of equipment transformers to operate
were found to be not 1 unit of equipment was defective and subject to repair
operational
3 units of equipment were unutilized

Source: COA Validation

Aside from the EMB-funded equipment, included in the above observations

were units of equipment donated by DA, DOST, and LGUs (see Overlap in
Beneficiaries Due to Lack of Coordination Among Implementing Agencies on
page 129). On the other hand, there were also 25 units of not operational
equipment. However, the source of funds for these could not be identified by
the personnel at the site.

In addition to the aforementioned, NSWMC commented that certain LGUs had

requested equipment to display in their MRFs as a matter of compliance. While
they conduct capacity development and monitoring, the trained personnel will
be replaced every time elected officials change. Their support for LGUs is also
affected by a political issue when the incumbent mayor refuses to utilize the
equipment because the former mayor requested it.

The noted difficulties of LGUs, such as the insufficiency or lack of electricity or

biowaste, only highlighted the mismatching of the donated equipment
compared to the needs of the LGU recipient. Additionally, when these units of
equipment are left inactive, they risk of needless wear and tear if not used for
an extended period.

On the other hand, the problem to be addressed remains, and waste diversion
target will still not be achieved if these units of equipment are not put into
operation where they are needed. Consequently, this might lead to more
waste in landfills or accumulation of recyclable waste materials in MRFs,
similar to the situation in Ginatilan, Cebu (see Uncollected and unprocessed
waste materials are accumulating in MRFs on page 105). It will also limit the
capabilities of the LGUs to conserve natural resources by composting and
producing recycled outputs that can be used in their respective programs and
projects or generate income.

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Lack of Recording As mentioned earlier, there was limited availability of reliable and complete
data to measure the success of waste diversion nationwide due to the lack of
Mechanism in monitoring of all MRFs. However, there was also the issue that not all
MRFs Resulting in operational EMB-funded MRFs maintain complete data. This issue led us to
Unreliable and validate the cause and found that there was no reliable recording mechanism
Incomplete Data on for the operations of MRF.
Waste Diversion According to IRR of RA 9003, MRFs shall keep and maintain records of daily
weights and volumes of wastes that are accurate and adequate for overall
planning purposes and tracking of the success of waste diversion goals.
Moreover, proper MRF record keeping is an integral part of the preparation and
updating of the LGUs’ 10-yr SWM Plan and their overall waste diversion data,

However, despite the requirement in RA 9003 that MRFs keep daily weight
records, validation revealed that 14 of the 45 inspected MRFs did not have
daily records of weights or volumes of waste (see Table 45). Moreover, only
12 MRFs have weighing equipment; thus, those with records of weights, if
there are any, were just derived from estimates.

Table 45: No. of MRFs Without Daily Records and Weighing Equipment

MRF Checklist With Without

Record of Daily Weight Records 31 14
Weighing Equipment 12 33

Source: COA Validation

According to DENR-EMB, technical assistance to LGUs concerning SWM was

regularly conducted by the DENR-EMB Regional offices, which includes
sustainable MRF operation. Moreover, Environmental Monitoring Officers
(EnMos) constantly inform the DENR-EMB or LGU-funded MRF operators on
proper record keeping. In turn, the LGU must maintain a daily record book of
the MRF and provide such records as daily weights or volumes of waste
received and processed during monitoring.

However, despite the constant assistance provided by DENR-EMB, the LGUs

still have difficulties maintaining MRF records. According to DENR-EMB, this
may be due to a lack of qualified personnel or measuring equipment in the
MRF, which was also confirmed during our validation.

Thus, several MRF operators were still not keeping records or not correctly
recording the MRFs’ operation. Likewise, this gap results in the lack of
accurate data or no data on waste diverting through the MRFs.

Uncollected and One of the major functions of an MRF is to recycle to divert waste. However,
validation revealed that uncollected and unprocessed waste materials
unprocessed waste accumulated in some MRFs due to LGUs’ difficulties in processing, selling, or
materials are disposing of their recyclable wastes. Hence, this accumulation of waste was
accumulating in overwhelming the MRFs and posing a risk to possible environmental hazards
MRFs if not managed soon.

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According to RA 9003, DTI, in cooperation with the DENR, the DILG, and other
concerned agencies and sectors, shall publish a study of existing markets for
processing and purchasing recyclable materials and the potential steps
necessary to expand these markets to stimulate the demand for the production
of products containing post-consumer and recovered materials. Furthermore,
the NSWMC, the NEC, the DTI, and the DOF shall establish procedures,
standards, and strategies to market recyclable materials and develop the local
market for recycled goods.

However, contrary to RA 9003, validation revealed that LGUs had difficulties

processing, selling, or disposing of their recyclable wastes, resulting in the
piling up in their MRFs or RCAs (see Figure 62).

Figure 62: Accumulated Recyclable Wastes in MRFs and RCAs

Location: Lagangilang, Abra Location: Ginatilan, Cebu

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Figure 62: Accumulated Recyclable Wastes in MRFs and RCAs (cont.)

Location: Kumalarang, Zamboanga del Sur Location: Olutanga, Zamboanga Sibugay

Source: COA Validation

To highlight further the dilemma of these LGUs, provided in Figure 63 were

images of the MRF in Barangay Poblacion in Ginatilan, Cebu, including a
Google Earth Image taken in September 2021 and our validation photographs
taken on April 2022. By comparing the pictures, it was evident that the
accumulated waste had indeed piled up and overwhelmed the MRF.

Figure 63: Accumulated Recyclable Wastes in MRF in Barangay Poblacion, Ginatilan, Cebu

The front portion of the MRF structure

Left: Google Earth Image was taken September 2021; Right: COA Validation on April 2022

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Figure 63: Accumulated Recyclable Wastes in MRF in Barangay Poblacion, Ginatilan, Cebu (cont.)

The rear side of the MRF structure

Source: Google Earth and COA Validation

On the other hand, validation revealed that Barangay Poblacion in Ginatilan,

Cebu, also received equipment from DENR-EMB, such as a bio shredder and
bottle pulverizer. However, inspection revealed that both pieces of equipment
remain unutilized due to a lack of skilled personnel to operate the bio shredder
and sufficient electricity voltage in the MRF to operate the bottle pulverizer.
Moreover, there was also an equipment mismatch since most of the waste
outside this MRF was recyclable materials such as glass and plastic collected
by the barangay. Ultimately, as the recyclable waste accumulates in the MRF
and the pandemic limits the transfer of this waste to a more capacitated MRF,
the barangay opted to sell the recyclable waste on its own. However, this
initiative proved challenging, as buyers or junkshops only purchase selected
and limited types of waste, and thus the MRF remained overwhelmed.

Similar to Barangay Poblacion in Ginatilan, Cebu, were Barangays Tagodtod,

in Lagangilang, Abra, Poblacion in Kumalarang, Zamboanga del Sur, and
Kahayagan in Olutanga, Zamboanga Sibugay. Aside from defective
equipment or a mismatch that prevented the barangays from processing their
recyclable wastes, these barangays have a limited number of junk shops or
buyers in their area. Even though junk shops in Barangay Tagodtod buy
recyclable waste, not all recyclable waste is taken; hence, the recyclable
wastes accumulate even more. On the other hand, Barangay Poblacion used
to give the remaining recyclable waste, not bought by junk shops, to schools
for recycling. However, because face-to-face classes were postponed due to
the pandemic, recyclable waste accumulated in Barangay Poblacion. Lastly,
Olutanga, Zamboanga Sibugay’s predicaments were that no one buys
recyclable waste materials, and Region 9 lacks recycling facilities. Therefore,
if they intend to sell them, they must take them to another region, which would
be costlier for a municipal island like theirs.

With the observations noted during the validation, we requested information

on how the NSWMC or its member/s ensure that LGUs will have a market for

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their recyclable waste and the challenges preventing the NSWMC from
effectively developing active markets for recyclable materials. However, we
found no clear answer to the query, and the project, programs, and activities
provided by DTI were not directly related to the Recycling Market
Development. On the other hand, we found that the non-establishment of the
National Ecology Center (NEC), being one of the supposed key implementers,
has also affected this issue (see Non-Establishment of NEC - Non-
establishment of a National Recycling Network on page 127).

Overall, this challenge significantly affects waste diversion, as the barangay

could not effectively perform recycling, which is one of the major functions of
the MRF. This could also limit the barangays in their collection if their storage
areas are nearly full or already full. On the other hand, these barangays may
also have missed opportunities for industry growth that can generate jobs
across LGUs and potential revenue from selling processed or unprocessed
recyclable materials. In addition, waste left in open areas in Ginatilan, Cebu,
could become marine waste during stormy weather since the site is only 261
meters from the shore and where Tañon Strait is located (see Figure 64). The
build-up of waste in an open area can eventually clog drains leading to flooding
during the rainy season since Cebu is one of the provinces often hit by
typhoons. In addition, it can cause adverse environmental impacts, such as
endangering marine life, as plastic materials take thousands of years to
decompose and contaminate bodies of water.

Figure 64: Distance between Barangay Poblacion MRF and Sea Shore

Source: Google Earth

Moreover, there was also a growing concern about microplastics. Based on a

study, Cebu has the highest density of microplastics among the 10 study areas
nationwide, such as Subic Bay, Boracay Island, Tañon Strait Protected

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Seascape, and Davao Gulf.49 To highlight the issue further, the Tañon Strait
in Badian and Moalboal is about 46 kilometers from the LGU of Ginatilan,
Cebu.

Solid waste is one of the primary sources of pollution in oceans. Universal

plastic usage has increased non-biodegradable waste litter in natural
environments, of which, in 2016, the world generated 242 million tonnes of
plastic waste.50 According to the Ellen MacArthur Foundation, if nothing is
done, more plastic will be in the oceans than fish by 2050.51 Consequently, the
Philippines was reported to be the “third-worst polluter into the world’s oceans”
after China and Indonesia.52

The overwhelming The EMB hires EnMOs in the regions to augment the EMB’s capacity.
Generally, the EnMOs assist in inspecting and monitoring SWM facilities, initial
work of EnMOs review and monitoring of 10-yr SWM Plans, information and education and
affects the reliability communication (IEC) campaigns, and enforcement of other environmental
of data and delivery laws. However, the analysis revealed that LGU assignments per EnMO vary in
of services to the numbers, thus, casting doubt on whether EnMOs can handle the assigned
work effectively and efficiently.
LGUs
Analysis revealed that the number of LGUs handled varied from one EnMO to
another (see Figure 65). For example, while one EnMO is reported to be
assigned to monitor 43 LGUs, ten EnMO personnel are handling only one
LGU.

49
CRERDEC’s study confirms presence of microplastics in the Philippine marine waters, highest density in
Tañon Strait Protected Seascape in Badian and Moalboal, Cebu - Ecosystems Research and Development
Bureau - DENR. (2021, October 18). DENR-Ecosystems Research and Development Bureau (ERDB).
Retrieved September 7, 2022, from https://erdb.denr.gov.ph/2021/10/19/crerdecs-study-confirms-
presence-of-microplastics-in-the-philippine-marine-waters-highest-density-in-tanon-strait-protected-
seascape-in-badian-and-moalboal-cebu/
50
Kaza, S., Yao, L. C., Bhada-Tata, P., & Woerden, F. V. (2018, September 20). What a Waste 2.0: A
Global Snapshot of Solid Waste Management to 2050. Retrieved November 10, 2022, from
https://doi.org/10.1596/978-1-4648-1329-0
51
World Economic Forum, Ellen MacArthur Foundation and McKinsey & Company. (2016). The New
Plastics Economy - Rethinking the Future of Plastics. Retrieved September 7, 2022, from
https://ellenmacarthurfoundation.org/the-new-plastics-economy-rethinking-the-future-of-plastics
52
Greenpeace: PH is third worst plastic polluter of oceans. (2017, September 23). Inquirer. Retrieved
September 7, 2022, from https://newsinfo.inquirer.net/932739/greenpeace-environment-water-pollution-
polluter-manila-bay

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Figure 65: LGU Assignments per EnMO

Source: DENR-EMB Regional Offices Data

The hiring of EnMOs started in CY 2017 to accomplish the targets of the Solid
Waste Enforcement and Education Program (SWEEP). The SWEEP was
designed to augment the existing capacity of the DENR-EMB regional offices
to validate, monitor, and improve reported unclean sites, as well as monitor
and inspect SWM facilities such as EMB-funded MRFs and SLFs, among
others.

At the latest guidelines (see Table 46), an EnMO’s responsibilities include the
enforcement and education functions, site suitability assessment of proposed
SLF sites (EnMO Geologists), and design of identified SWM facilities (EnMO
Engineers).

Table 46: Functions, Targets, and Deliverables of EnMOs

FUNCTION TARGET OUTPUT

A. Enforcement Functions
1. Monitor and geotag unclean sites Five (5) to ten (10) sites monitored and Monitoring Report;
geotagged per EnMo per month Map of the geotagged sites.

2. Advise the barangay and Five (5) to ten (10) cleaned-up sites Advice/Letter to the Barangay and city/
city/municipal LGU and facilitate facilitated per EnMo per month municipal government to conduct the
clean-up of unclean sites. Geotag clean-up. Validation Report Map of
validated sites *Same geotagged sites monitored. geotagged validated sites

3. Conduct another site inspection if All sites with no response from the LGU Validation Report (2nd validation)
LGU did not submit any update or if
there was no clean-up done.

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FUNCTION TARGET OUTPUT

4. Draft NOV to LGUs that did not All re Inspected sites without action by NOV Complete Staff Work
comply with the advice from the the LGU
DENR-EMB Regional Office to
conduct clean up.
5. Conduct monitoring of rivers and other All rivers and other water bodies Monitoring Report
water bodies in the HUCs and
Components Cities including siltation
in rivers
6. Assist in the conduct of Technical Based on NOVs. Report on the agreements/
Conferences based on the issued commitments during the technical
NOVs. This can be done virtually or conference(s)
face to face.
7. Monitor SWM Facilities such as SLF; Annex E list of SWM facilities in the Monitoring Report including
MRF; RCA; Biogas Digester, and Region
Transfer Station. 1. Data on waste diversion and
2. Updates on liquidation report on
DENR-EMB downloaded funds
8. Conduct of monitoring of the Annex E list of SWM facilities in the Monitoring Report
rehabilitation of closed dumpsites in Region
compliance with DAO 2006-9 or the
General Guidelines in the Closure and
Rehabilitation of Open Dumpsites and
Controlled Dump Facilities

B. Education Functions
1. Support in the dissemination of Environment Month International Activity Report on the types and
information on Activities and quantity of wastes collected during
Programs during the Environment Coastal Clean-Up clean-up activities
Month and International Coastal
Clean-Up Month

C. Site Suitability Assessment of Proposed SLF Sites by EnMo Geologists

1. Assessment of Proposed SLF Sites 5 proposed sites per Region (except Geological Assessment Report
NCR) (copies to be provided to the DENR-
EMB Central Office)

D. Design of Identified SWM Facilities by EnMo Civil Engineers/Civil Sanitary Engineers

1. Civil Engineers/ Civil Sanitary 5 designs including the site assessment, Inputs in the Design of SLFs, MRF
Engineers costing, operational cost, profitability Biogas Digester, and RCA
analysis of SLF, MRF, Biogas Digester,
and RCA per Region

Source: Guidelines on the Implementation of SWEEP for CY 2022

However, based on the data gathered from DENR-EMB Regional Offices,

some EnMOs have other responsibilities besides RA 9003. These other
assignments include but are not limited to assisting in or conducting
investigation or inspection in compliance with Presidential Decree (PD) 1586,
RA 9275, RA 8749, RA 6969, and RA 9512.

Despite the variety and volume of assignments and responsibilities, DENR-

EMB and its EnMOs have continued to maximize their operation to the extent
of their capabilities. The operation and monitoring conducted by DENR-EMB
and EnMOs nationwide were extensively tested during the pandemic. Despite
the restrictions and challenges brought about by the pandemic, all 326 DENR-

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EMB EnMOs nationwide completed the monitoring of 28,671 sites and

facilitated the cleanup of 23,180 unclean sites in CY 2021 (see Table 47).

Table 47: SWEEP and EnMOs Accomplishments

SWM Activities CY 2020 CY 2021

Monitored sites 22,416 28,671
Unclean sites clean-up 19,751 23,180

Source: DENR-EMB Accomplishments for CYs 2020 and 2021

Both in CYs 2020 and 2021, the EnMOs were also able to assist in the
inspection and monitoring of SWM facilities, such as MRFs and disposal sites,
and review and implementation of 10-yr SWM Plans.

Non-Establishment The Local Government Code, or RA 7160, mandates that LGUs provide basic
services and facilities. These services include providing solid waste disposal
of M/CENRO systems, environmental management systems, and services or facilities
related to general hygiene and sanitation. However, Section 484 of the same
law provides that the appointment of the environment and natural resources
officer is optional for provincial, city, and municipal governments.
Consequently, the provision allows LGUs to create a M/CENRO position (Full-
Fledged), assign the waste management function in any of its different offices
(Designated), or assign no M/CENRO at all. Hence, services for SWM in some
LGUs become fragmented and, therefore, not integrated.

According to the National Solid Waste Management Status Report from 2008-
2018, one of the challenges of the SWM in the country was the
institutionalization of an Environment and Natural Resources Office. As
disclosed in the same report, SWM was not the priority of some Local Chief
Executives; hence, not all LGUs have created their M/CENRO with personnel.

To garner insights into how M/CENRO was institutionalized across LGUs

nationwide, we requested data from all DENR-EMB Regional Offices and
received data representing 1,483 LGUs. Of the 1,483 LGUs, 29 percent have
a full-fledged M/CENRO position, 70 percent designate only the M/CENRO
position, and seven LGUs did not have or did not designate a M/CENRO
position (see Table 48).

Table 48: LGUs with M/CENRO Position

Region Full-Fledged Designated No M/CENRO Total

NCR 14 3 0 17
CAR 4 73 0 77
1 77 48 0 125
2 26 66 0 92
3 36 101 0 137

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Region Full-Fledged Designated No M/CENRO Total

4A 42 100 0 142
4B 13 37 0 50
5 26 85 0 111
6 22 111 0 133
7 25 100 6 131
8 35 106 0 141
9 15 57 0 72
10 19 74 0 93
11 21 23 0 44
12 32 17 0 49
13 25 43 1 69
Total 432 1,044 7 1,483
Percentage 29 70 0 100

Source: DENR-EMB Regional Offices Data

Based on the requested summary of M/CENRO to DENR-EMB, we learned

that these designated M/CENRO were initially assigned from another office
and not necessarily trained for the SWM task (e.g., Municipal Agriculture
Office, Municipal Engineer, Municipal General Service Office, Municipal
Planning & Development Coordinator Office, Municipal Disaster Risk
Reduction and Management Office). Most of them were preoccupied with
other tasks regarding their original department or office and burdened by not
having an adequate budget, if provided, for SWM.
On the other hand, interviews with focal persons from different DENR-EMB
Regional Offices revealed that they, too, have experienced challenges due to
problems in M/CENRO institutionalization. According to them, due to the co-
terminus nature of most designated M/CENROs, previous priorities or ongoing
plans, including SWM implementation, were not always sustained. Moreover,
there was also the issue of training every new designate and its staff if
M/CENRO was provided with a functional office as some designated
M/CENROs work alone. Finally, according to NSWMC, the LGU’s personnel
services budget salary cap is another challenge in the institutionalization of
M/CENRO.

NSWMC stated that whenever LGUs are asked about their capacity, the
typical response is a lack of funding, personnel, and capacity, which explains
why some LGUs struggle to comply. According to them, the capacity of LGUs
decreases due to the 3-year term transitions of LGUs, which results in a loss
of knowledge transfer. This is not just limited to officials being replaced by
every new administration but also involves the personal knowledge acquired
by individuals. Although DILG provides orientation and training programs for
new local chief executives, such programs are unavailable for technical
personnel. As a result, when these individuals retire or are replaced, their

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capacity is lost. To address this issue, continuous capacitation is being

implemented.

NSWMC also commented that the 3-year term of local chief executives is a
systemic problem because changing the local chief executive may result in the
change of the M/CENRO. Another ongoing issue is the lack of a proper
turnover process when changing M/CENRO, which results in a failure to
transfer capacity effectively.

Consequently, the need for institutionalizing M/CENRO or its equivalent was

more reasonable, given that the LGUs were responsible for enforcing and
implementing RA 9003 in their respective jurisdictional areas. The
Environment and Natural Resources Office in every LGU was vital in
formulating measures for the consideration of the sanggunian and in providing
technical assistance and support in carrying out measures to ensure the
delivery of basic services and provision of adequate facilities relative to
environment and natural resources services. This will also ensure that
services are highly efficient through sustained leadership and accountability in
SWM, the environment, and natural resources.

Similarly, DENR still recommends creating or institutionalizing M/CENRO to

address environmental concerns. Accordingly, one of the action plans was to
conduct meetings or workshops with DILG to identify strategies for creating
the M/CENRO position.

Unequal distribution There was an imbalance in the number of male and female M/CENROs and
EnMOs, with men holding 72 percent and 58 percent of the jobs, respectively.
of men and women Therefore, if plans or targets to balance the ratio are not included in the relevant
in SWM and Gender and Development Plans, the country may not attain the nationally
leadership agreed targets for SDG 5.5 to achieve a proportion of 50 percent of positions
held by women.

SDG 5 is aimed to “achieve gender equality and empower all women and
girls”, or simply “Gender Equality”. SDG 5 is focused on pursuing the main
goal of real and sustained gender equality in all aspects of women’s and girls’
lives, which includes ensuring women’s full and effective participation and
equal opportunities for leadership.53 To achieve the 2030 Agenda, the
indicators for the nationally agreed target SDG 5.5 is at a 50 percent proportion
of women.54

In compliance with the Magna Carta of Women, we looked into the sex-
disaggregated data of M/CENROs and found more men than women. Of the
1,498 M/CENRO nationwide, excluding BARMM, about 72 percent, or 1,076,
were men, while 28 percent, or 422, were women. Based on Figure 66, across
the country and every region except BARMM, there were more men in
M/CENRO than women (see Figure 66).

53
Sustainable Development Goal 5
54
2030 Nationally Determined Numerical Targets for the SDGs. Retrieved September 7, 2022, from
https://sdg.neda.gov.ph/2030-nationally-determined-numerical-targets-for-the-sdgs/

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Figure 66: Number of Male and Female M/CENROs

Source: DENR-EMB Regional Offices Data

On the other hand, we also looked into the sex-disaggregated data of EnMOs
and found that there were slightly more men than women. Of the 337 EnMOs
nationwide, excluding BARMM, about 58 percent, or 196, are men, while 42
percent, or 141, are women. Figure 67 shows that while certain regions have
more women EnMOs than men, many regions have more men EnMOs.
Interestingly, the number of men and women EnMOs in Region 8 was the
same.

Figure 67: Number of Male and Female EnMOs

Source: DENR-EMB Regional Offices Data

The M/CENRO is designated by the local chief executive of an LGU. The local
chief executive has the power to appoint all officials and employees whose

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salaries and wages were wholly or mainly paid out of municipal funds and
whose appointments were not otherwise provided for in RA 7160 and those
he may be legally authorized.55 As shown in Figure 66, most of the local chief
executives hired more male M/CENRO.

On the other hand, the hiring of EnMOs for CY 2022 was based on the
Guidelines on the Implementation of the SWEEP for CY 2022. However, upon
desk review of the said guidelines, there was no indication of the ratio of hiring
men and women for EnMO positions. In addition, a review of the GAD Plan
and Budget of DENR-EMB for CY 2022 disclosed no plan nor target to balance
the number of male and female EnMOs.

Examples of Best Despite the noted challenges and limitations, a number of LGUs showcased
resourcefulness in finding ways to divert waste. On the other hand, various
Practices Observed private companies, including non-governmental organizations, have also
during Validation participated in local SWM programs to contribute to waste diversion and
effective waste management.

According to RA 9003, one of the goals of the SWMP is to encourage greater

private-sector participation in SWM. While SWM’s primary enforcement and
responsibility shall remain with the LGUs, RA 9003 also focuses on
establishing a cooperative effort among the national government, other LGUs,
NGOs, and the private sector.

PHINLA and Limadol. As mentioned earlier, Barangay Mintal in Davao City

had problems utilizing its MRF assistance from DENR-EMB due to a lack of
appropriate land suitable for MRF establishment. As a result, the fund
assistance, which remained idle for almost four years, was refunded to BTr,
and no MRF was established. However, this predicament did not prevent
Barangay Mintal from diverting its waste because of its partnership with
PHINLA and Limadol, which started in the 2nd Quarter of 2021 and December
2021, respectively.

PHINLA was a partnership project of the Eco Waste Coalition and World
Vision Development Foundation, Inc, with funding from the German Federal
Ministry for Economic Cooperation and Global Development (BMZ). PHINLA,
coined from the name of the countries where the project is being implemented
(the Philippines, Indonesia, and Sri Lanka), seeks to empower waste workers
and communities affected by poor waste management by using waste as a
resource to create meaningful employment and to earn income while tackling
health and environmental issues associated with waste management.56

55
RA 7160 Chapter 3 Section 444(v)
56
Empowering Waste Workers and their Communities. World Vision. Retrieved September 7, 2022, from
https://www.worldvision.org.ph/news/empowering-communities/

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Figure 68: Collecting and Selling of Recyclable Materials by Mintal

Resource Collectors Association (MIRCA)

Source: COA Interview Results

Through this project, the residents of Barangay Mintal, mostly from indigent
communities, constitute the MIRCA. The members of MIRCA were given a
livelihood by collecting all recyclable materials in the barangay (see Figure
68). This project has also equipped the waste collectors with PPEs, such as
gloves, raincoats, and boots, and donations to the barangay, such as cellular
phones, trisikads, and weighing scales. Ultimately, this has given
“mangangalakal” more support, a more dignified work environment, and better
opportunities to collect more recyclables as they could not afford to shell out a
portion of their earnings to buy the materials mentioned earlier because that
would mean less food on the table.

In addition to PHINLA, Barangay Mintal has a partnership with Limadol to help

the barangay manage its kitchen/ or food waste (see Figure 69). Limadol is a
start-up enterprise aiming to divert food waste from Mindanao landfills, reduce
methane, enrich the soils with natural fertilizers, and replace imported fishmeal
or soya to feed organic livestock.57 According to Barangay Mintal, Limadol
initially agreed with five food establishments to collect food and kitchen waste
thrice a week beginning in January 2022. The collected food and kitchen
wastes are then converted into fertilizers, where black soldier flies consume
food waste and produce a byproduct called frass which is useful feed for
poultry or organic fertilizers58. At the time of validation, Limadol is already
collecting food and kitchen waste from 14 food establishments at the
barangay, Mintal Barangay Hall, and the Mintal Public Market. Barangay
Mintal and Limadol are also targeting to include fruit stands outside the public
market, other non-food establishments, and all the households of the
barangay.

57
About Limadol. Retrieved August 23, 2022, from https://limadol.com/about
58
Davao City waste-to-energy project to fuel climate change, groups warn. (2022, May 15). Philstar.
Retrieved September 7, 2022, from https://www.philstar.com/headlines/climate-and-environment/2022/
05/15/ 2181288/davao-city-waste-energy-project-fuel-climate-change-groups-warn

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Figure 69: Limadol’s Food and Kitchen Waste Management Partnership

Source: COA Interview Results

By implementing these projects through partnerships with PHINLA and

Limadol, Barangay Mintal could divert recyclable waste from households and
kitchens and food waste from food establishments. Based on data provided
by Barangay Mintal, the barangay could divert 32,926.80 kgs of waste as at
the first quarter of CY 2022 (see Table 49).

Table 49: Diverted Recyclable Waste Materials through Partnership with

PHINLA and Limadol from 2nd Quarter 2021 to 1st Quarter 2022 (in
kilograms)

Biodegradable
Recyclable
Period Waste (food/ Total
Waste
kitchen waste)
2nd Quarter of CY 2021 611.80 - 612.00
3rd Quarter of CY 2021 1,606.00 - 1,606.00
4th Quarter of CY 2021 5,937.00 729.00 6,666.00
Subtotal 8,154.80 729.00 8,883.80
1st Quarter of CY 2022 18,378.00 5,665.00 24,043.00
Grand Total 26,532.80 6,394.00 32,926.80

Source: COA Interview Results

The collected recyclable waste materials generated a total income of

₱418,645.01 from the second quarter of 2021 to the second quarter of 2022,
as presented in Table 50. This income benefited 12 to 30 MIRCA waste
collectors.

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Table 50: Income Generated from Diverted Recyclable Materials through

Partnership with PHINLA and Limadol from 2nd Quarter of CY 2021 to 2nd
Quarter of CY 2022

Period CY 2021 CY 2022 Total

1st Quarter ₱ - ₱ 137,465.70 ₱ 137,465.70
2nd Quarter 5,705.00 156,956.96 162,661.96
3rd Quarter 21,347.00 - 21,347.00
4th Quarter 97,170.35 - 97,170.35
Total ₱ 124,222.35 ₱ 294,422.66 ₱ 418,645.01

Source: COA Interview Results

Proper management and reduced kitchen/food waste were effective ways to

protect the environment. According to the Science Research Specialist at the
DOST-Food and Nutrition Research Institute (FNRI) in CY 2018, the food
wastage in the country reached an average of 1,717 metric tons each day, and
the greatest amount of plate waste comes from energy food groups59 such as
rice, corn, and starchy roots. In Metro Manila, 2,175 tons of food are in trash
bins daily, as the World Wildlife Fund-Philippines60 reported. These reports
reflect the challenges of the country in kitchen/food waste that need to be
addressed sooner than later. For example, oil generated from food and kitchen
waste could be chucked into the drainage system, clogging up pipes and later
on, could result to flooding. In addition, the food and kitchen wastes disposed
of in landfills or dumpsites produce methane gas that impacts climate change.

Mother Earth Foundation. During the Pilot Study in Barangay San Rafael
Village, Navotas City, we engaged the Citizen Partner in the conduct of survey
and interview with the Foundation and barangay officials. We noted that the
Mother Earth Foundation helped barangays and LGUs in SWM. This
partnership was their initiative as an NGO to achieve Zero Waste Philippines
(see Figure 70). In addition, the partnership’s objective is to empower
barangays to become self-reliant through holistic environmental education and
community participation by maximally increasing their capacity to comply with
RA 9003 and to divert the barangays' waste from dumps and/or landfills and
help enable them to attain continued compliance with RA 9003.

59
DOST-FNRI eyes evidence-based solutions for food insecurity. Retrieved September 7, 2022, from
https://www.dost.gov.ph/knowledge-resources/news/49-2018/1433-dost-fnri-eyes-evidence-based-
solutions-for-food-insecurity.html
60
Sustainable Consumption and Production. (2022, November 17). WWF-SCP. Retrieved September 7,
2022, from https://wwf.org.ph/what-we-do/food/thesustainablediner/

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Figure 70: Mother Earth Foundation SWM Support to Barangay San

Rafael, Navotas City

Source: Mother Earth Foundation

During the interview in Barangay San Rafael Village, we found that house-to-
house waste collection was conducted by Mother Earth Foundation, including
the segregation of waste if households failed to do it. Mother Earth Foundation
also helps the barangays maintain a record of different types of waste
collected during a given number of days and its corresponding diversion (see
Figure 71).

Figure 71: Mother Earth Foundation in Barangay San Rafael Village, Navotas City

Left: Waste Diversion Record Sheet by Mother Earth Foundation; Right: Representative/s of Barangay San Rafael Village and
Mother Earth Foundation, Victoria Yumang (Citizen Partner) and Marco Crespo (Audit Team Member)

Source: COA Validation

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Aside from collecting and recording waste, Mother Earth Foundation also
helps process segregated biodegradable wastes into compost for use in
gardens where the barangay grows vegetables, such as cabbage. On the
other hand, the segregated recyclable wastes were sold to junkshops, and the
income was divided among themselves. Finally, the residual wastes from the
collection were hauled in the dump truck owned by the barangay for final
disposal in the Navotas SLF.

Apart from actual SWM, Mother Earth Foundation conducts community

information and educational campaign to teach households how to segregate
waste properly. This campaign also includes informing the households of the
collection schedule for different types of waste.

Lastly, they also conduct training for the barangay official on proper SWM. The
training covers the roles and responsibilities of the barangay in implementing
RA 9003. These roles and responsibilities include the proper segregation and
collection at source, operation of MRF where the biodegradable wastes were
processed to make compost, and the recyclables to either use within the
barangay or sell to junkshops to get additional income to be used in the
operation of the MRF.

We revisited the barangay in October 2022 and found that Mother Earth
Foundation had already completed its partnership with Barangay San Rafael
Village. However, this follow-up validation revealed that the barangay did not
continue some of Mother Earth's programs and activities, including
segregating collected waste. Currently, barangay waste collectors only
segregate recyclables that can be sold to junkshops. While biodegradable and
residual wastes were disposed of together at the SLF because the barangay
does not utilize their garden anymore, where they used to put biodegradable
waste to fertilize their crops.

Private Companies Accepting Wastes from LGUs. Several interviews with

LGUs highlighted how private companies helped them further reduce their
residual wastes. Based on information gathered from DENR-EMB Regional
Offices, waste collected and processed by these companies varied from
residual waste with potential, plastics, and recyclables (see Table 51).

Table 51: Examples of Private Companies Accepting Wastes from LGUs

Private Company Type of Waste Accepted

CEMEX Residual wastes
Eagle Cement Residual with potential
FDR Construction Company Inc. Residual wastes
Guun Private Limited Residual wastes
Holcim Mining and Development Corporation Residual wastes
Residual wastes, residual with
Holcim Philippines potential, and qualified non-
biodegradable
Iriga City Plastic Recycling Company Recyclables
Republic Cement Residual with potential
Solid Merchandising Residual wastes

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Private Company Type of Waste Accepted

Starplus/Tamaraw Plastics Recyclable plastics
Villar Sipag Foundation Plastics
Winder Plastic Recycling Company Residual wastes

Source: DENR-EMB Regional Offices Data

As shown in the table above, most of the wastes being diverted by these
partnerships were residual wastes that should have been disposed of in the
SLFs or RCAs. According to LGUs, these residual wastes must be cleaned
and dried, and some need to be shredded before collection by private
companies.

During MRF validation in Barangay Tandang Kutyo in Tanay, Rizal, we

learned about their partnership with CEMEX. Tanay LGU partnered with
CEMEX to have an additional waste diversion for their residual waste that
should have been dumped in landfills. The wastes collected by CEMEX
include plastic wrappers, plastic labo, and other plastic wastes not accepted
by junkshops.

According to their website, CEMEX collects the segregated residual wastes

from communities and properly treats them through co-processing. This
method reduces solid waste and carbon emissions using less fossil fuels for
cement kilns61. According to DENR-EMB Region 4A, the co-processing of
residual waste is being monitored by DENR-EMB through its Air Quality
Section, which monitors different industries, including the cement factory.

As for plastic industries, they collect and use residual wastes such as plastics
to make products such as school chairs, pots, pallets, plastic bottles, laundry
hangers, and other plastic products.

These partnerships between private companies and LGUs can help the
country address the SWM problems for every LGU, especially on waste
diversion. Benefiting both parties, LGUs’ residual wastes that would have been
disposed of in SLFs and RCAs can still be used and processed by private
companies.

61
Waste Management Solution: The CEMEX Way. CEMEX Holdings Philippines. Retrieved January 15,
2023, from https://www.cemexholdingsphilippines.com/-/waste-management-solution-the-cemex-w-1

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Gaps in the
planning,
implementation,
and monitoring of
the program
We noted gaps in the program’s planning, implementation, and monitoring
under RA 9003, mainly due to inadequate institutional mechanisms to kick-
start the program, such as the non-establishment of the SWM Fund and the
NEC. On the other hand, we also found room for improvement in coordination
among implementing agencies to avoid overlap and to maximize sharing of
responsibility, recording, and monitoring of wastes to ensure reliability and
attainment of waste diversion targets, and prioritization of updating the NEAP
to contribute to waste avoidance.

Non-Establishment To kick-start the SWM implementation, RA 9003 mandated the appropriation

of ₱20 million for the initial operating expenses of the NSWMC, the NEC, and
of SWM-Mandated the LGUs to carry out the mandate of RA 9003. Moreover, the law also created
Funding Sources the SWM Fund62 that shall be made available to the NSWMC, the NEC, and
LGUs to achieve and perform their roles and responsibilities to attain the goals
of SMWP. However, according to DENR-EMB, the ₱20 million was not
released, and the SWM Fund has not been established since the adoption of
RA 9003. Thus, the NSWMC and some LGUs cannot cope complying with the
law because of, among others, financial and technical capacity.

Initial Operating Expenses. Over the years, the NSWMC, through DENR-
EMB, has worked on the release of the ₱20 million initial operating expense
through various requests done through the issuance of resolutions and
communications with the various agencies (see Table 52).

Table 52: Various Funding Requests from NSWMC

NSWMC
Brief Description
Resolution/Letter
NSWMC Resolution adopting and endorsing the Ph20M NSWMC
Resolution No. 10, Initial Operating Budget and Work and Financial Plan for
Series of 2008, submission to Department of Budget and Management
dated January 30, (DBM) for inclusion as a line budget item in the succeeding
2008 GAAs

NSWMC Resolution Requesting the DBM to Create Plantilla Positions

Resolution No. 54, for Executive Director, Deputy Executive Director, and Staff
Series of 2010, of the NSWMC Secretariat at the Environmental
dated October 22, Management Bureau, Central Office
2010
NSWMC Resolution for the Institutionalization of the NSWMC and the
Resolution No. 63, Offices Created Under it. Particularly the Secretariat and the
Series of 2013, NEC (The resolution provided for the creation and
dated July 5, 2013 institutionalization of plantilla positions for the NSWMCS and

62
Section 46 of RA 9003 stipulates that a Solid Waste Management Fund shall be created, as a special
account in the National Treasury, to be administered by the NSWMC.

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NSWMC
Brief Description
Resolution/Letter
NEC to effectively achieve the mandated functions and
efficient performance of the said offices)
NSWMC Resolution Adopting the NSWM Comprehensive Plan as the
Resolution No. 82, basis for Budget Proposal. This was developed in line with
Series of 2014, the NSWM Strategy which was adopted through NSWMC
dated June 24, Resolution No. 59, Series of 2013 and was presented to the
2014 NSWM-Technical Working Group (TWG) meeting on June 5,
2014. The objective of the NSWM Comprehensive Plan is to
increase the country’s waste diversion rate from 34% in 2010
to 50% by 2016
NSWMC Letter to Request for (1) Recognition of the NSWMC under the Office
Office of the of the President as provided in Section 4 of RA 9003; (2)
President on April Provision of the initial operating expense for the NSWMC to
15, 2016 carry out mandates of the Act as provided in Section 58 of
RA 9003; (3) Provision of a fund for the establishment of the
National Solid Waste Management Fund as provided in
Section 46 of RA 9003

Source: NSWMC Data

However, more than two decades after the adoption of RA 9003, no initial
operating budget had been released by DBM to the NSWMC despite repeated
submission requests for the budget allocation.

Since CY 2001, DENR-EMB has provided Secretariat support to NSWMC,

following RA 9003. In addition, the NSWMC has been working on a budget
provided to the DENR-EMB for SWM activities. Nonetheless, although the
budget allocation for SWM activities of the DENR-EMB is not solely for the
NSWMC, the Commission has continued to deliver some of its mandates (see
Table 53).

Table 53: NSWMC Accomplishments

o National Solid Waste Management Framework

o National Solid Waste Management Strategy
POLICY
o Approved Local SWM Plans
o Adopted Various SWM Guidelines
o Life Cycle Assessment Study in support of the
TECHNICAL identification of NEAPs
o Recycling Market Development Study
o Participated in the finalization of project proposals
FINANCIAL
endorsed for funding by various development partners
o Filing of complaints to the Office of the Ombudsman
ENFORCEMENT
against 50 non-complying LGUs

Source: DENR-EMB Data

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While the DENR-EMB provided certain budgetary allocations of the NSWMC,

it did not include, however, the realization of some mandates of the NSWMC
that includes, among others, the provision of a fund under the SWM Fund to
finance products, facilities, technologies, and processes to enhance proper
SWM, awards and incentives, research programs, IEC and monitoring
activities, technical assistance, and capability building activities as stipulated
in Section 46 of RA 9003.

SWM Fund. According to the provisions of RA 9003, the SWM Fund shall be
sourced from fines and penalties imposed, proceeds of permits and licenses
issued by the DENR under RA 9003, donations, endowments, grants, and
contributions from domestic and foreign sources, and amounts specifically
appropriated for the SWM Fund under the annual GAA.

This fund, which NSWMC and NEC can access, also extends to LGUs. LGUs
are entitled to avail of the SWM Fund based on their approved 10-yr SWM
Plan. While subject to the availability of funds, the SWM Fund may be made
available to the SWM project/activities of the LGUs based on a set of criteria
formulated through a consultative process. Hence, if available, the SWM Fund
can catalyze full compliance and sustainability of SWM initiatives at national
and local levels.

To date, the SWM Fund has not been established yet nor funded. According
to DENR-EMB, the SWM Fund cannot be established under the current
institutional engagement because the needed human resource of the NSWMC
to manage and administer the SWM fund was not established.

Non-Establishment One of the institutional support mechanisms necessary to implement RA 9003

is the NEC, which shall support the implementation of the Act by making
of NEC available information, consulting, training, and networking services. However,
despite the existing mandate that NEC be established, no organizational
structure, no personnel assigned, and no budget has been allotted for the NEC.
Hence, to implement its mandate, the Secretariat or the DENR-EMB has been
partly functioning as the NEC since CY 2002.63

Under the NSWMC Resolution No. 34, Series of 2009, the Solid Waste
Management Division (SWMD) of DENR-EMB, which also serves as the
Secretariat of the Commission, was formally affirmed to perform the functions
of NEC.

The NEC, through DENR-EMB, was able to release various guidelines (see
Table 54) to perform its mandate; however, these were not fully implemented
due to a lack of resources and an initial operating budget as stipulated in
Section 58 of RA 9003.

63
Based on review of minutes of meetings of the NSWMC, DENR-EMB has been performing the functions
of NEC since CY 2002.

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Table 54: NEC Guidelines

1. NSWMC Resolution Guidelines on the Operation of the NEC as well as

No. 51, Series of 2010 Regional Ecology Center
2. NSWMC Resolution
Resolution Adopting the Guidelines on the
No. 1500, Series of
Establishment of the NEC
2021
3. Guidelines on Establishing Partnership Between the NEC and Government or
Private Sector Owners of Existing Training and Integrated SWM Facilities for
the Conduct of the NEC Training

Source: DENR Data

Despite working with a limited and shared budget, the NEC, through DENR-
EMB, managed to accomplish some, if not all, of the functions mandated to
them (see Figure 72).

Figure 72: Accomplishments of NEC through DENR-EMB

Source: DENR-EMB Data

On the other hand, we identified the two most negative effects in the absence
of fully operating NEC: (1) Inadequate SWM Database and (2) Non-
establishment of a National Recycling Network.

Inadequate SWM Database. One of the issues often raised by stakeholders

was the non-existence of a database that could help synchronize and
coordinate the SWM implementation at all levels.

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For example, the NSWMC currently relies on the 10-yr SWM Plans of LGUs
to determine the waste generation data. However, this data from LGUs were
just waste management estimated generation for 10 years, and therefore not
the actual information on waste generation. Thus, because of the absence of
data on waste generation, the NSWMC may not perceive the actual condition
of the solid waste generation dilemma in the Philippines (a similar discussion
can be found in Projected Waste Generation on page 17).

Non-establishment of a National Recycling Network. Another significant

effect of the absence of a fully operating NEC was the non-establishment of a
national recycling network that will enhance the opportunity to recycle and
facilitate the network of buying and selling recyclable wastes. For example,
one of the MRF locations we visited was in Barangay Poblacion in Ginatilan,
Cebu, where the barangay has concerns about the disposition of its enormous
volume of collected recyclable wastes.

Figure 73: Inspection of MRF in Barangay Poblacion, Ginatilan, Cebu, Region 7

Source: COA Validation in Barangay Poblacion, Ginatilan, Cebu, Region 7

As can be seen in Figure 73, the MRF was full of recyclable wastes. According
to Barangay Poblacion officials, no one was collecting their recyclable wastes,
and they have no information on possible buyers. If a buying-selling network
is established, Barangay Poblacion and similar barangays or LGUs will greatly
benefit in marketing and ultimately diverting their collected wastes.

On the other hand, the mandated multi-sectoral, multi-disciplinary pool of

experts that will significantly help the NEC to accomplish its goals and
objectives has yet to be created. Based on the review of documents, we found
that the NSWMC had been discussing the criteria or qualifications for hiring
the NEC pool of experts as early as CY 2002, yet no pool of experts was
created. Nonetheless, the creation of this pool of experts was reiterated in the
amended provisions in RA 11898 or the Extended Producer Responsibility Act
of 2022. Hence, the NEC was still directed to maintain a pool of experts,
including those from the academe, inventors, practicing professionals,
business and industry, youth, women, and other concerned sectors, who shall
be screened according to qualifications set by the NSWMC.

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In addition to the amended provisions stated in RA 11898, the NEC will now
be headed by the Assistant Director of DENR-EMB under an ex-officio
capacity. Moreover, additional functions are also listed for NEC (see Table
55).

Table 55: Comparison of NEC under RA 9003 and Amendments in RA 11898

RA 9003 Amendments in RA 11898

Head: DENR-EMB Assistant Director (ex officio
Head: DENR-EMB Director (ex officio capacity)
capacity)
Functions: Functions:
Facilitate training and education Facilitate training and education
Establish and manage an SWM information Establish and manage an SWM information
database database
Promote the development of a recycling
Promote the development of a recycling market
market
Provide or facilitate expert assistance in pilot Provide or facilitate expert assistance in pilot
modeling of SWM facilities modeling of SWM facilities
Develop, test, and disseminate model waste Develop, test, and disseminate model waste
minimization and reduction minimization and reduction
Maintain an EPR Registry containing the
Additional functions
registered EPR Programs
Monitor and evaluate the compliance of
obliged enterprises and Producer
Responsibility Organizations (PROs)
Develop and maintain a database, including
digital formats, that is reliable, effective,
secure, transparent, and accessible to the
public
Receive sampling and assessment reports
and undertake the necessary action
Provide an assessment on the volume or
footprint of other generated wastes

Source: Official Gazette

With the additional functions expected from NEC, there is now a greater need
to establish and fulfill its needed staffing and funding resources to fully operate
as intended in its mandate. Currently, the NEC remains under the staffing and
funding from SWMD of DENR-EMB.

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Overlap in As mentioned in Chapter 2, DENR-EMB provided financial assistance to LGUs

in establishing MRFs from CYs 2012 to 2019 and various equipment from CYs
Beneficiaries Due 2020 to 2022 to improve compliance and increase waste diversion of solid
to Lack of wastes nationwide. However, during validation, we found that besides DENR,
Coordination DA and DOST also have a similar waste facilities program providing equipment
Among to barangays and LGUs. Hence, some barangays or LGUs have received
multiple and similar equipment from different agencies (see Table 56). Since
Implementing the programs and their beneficiaries overlap, there was an evident lack of
Agencies coordination among these agencies.

Table 56: Barangays or LGUs with Multiple and Similar Units of SWM Equipment from EMB, DA,
and DOST

Composter Bio Shredder

LGU Recipient
EMB DA DOST LGU EMB DA DOST LGU
1. Barangay Maoa-oas, Pugo, La Union 1 1 - - 1 1 - 1
2. Barangay San Pedro, Alcala, Pangasinan 1 1 - 1 1 1 - -
3. Barangay Puerto Rivas Lote, Balanga, Bataan 1 - - - 1 1 - -
4. Barangay Minadongjol, Sagnay, Camarines Sur 1 1 - - 1 1 - 1
5. Barangay Barubuhan, Sominot, Zamboanga Del Sur 1 1 - - 1 1 - -
6. Barangay Catipan, Mabuhay, Zamboanga Sibugay 1 1 - - 1 - - -
7. Barangay Kahayagan, Olutanga, Zamboanga Sibugay 1 - 1 - 1 - 1 -
8. Barangay Cuambog, Mabini, Davao de Oro 1 1 - - 1 - - -
Note: Highlighted in red are equipment found to be not operational due to insufficient supply of bio waste, staff
having no training, and no source of electricity.

Source: COA Validation

Based on research, we confirmed (see Table 57) that DA has the National
Organic Agriculture Program, which donated rotary composters to LGUs to
help with biodegradable waste.64 On the other hand, DOST donated a
bioreactor, plastic ‘densifier’, and shredder to LGUs under their Small
Enterprise Technology Upgrading Program (SET-UP).

Table 57: Comparison of EMB, DA, and DOST SWM-Related Programs

EMB DA DOST
Financial Support and National Organic Agriculture Grants-in-Aid (GIA)
Program/
Incentive to functional Program (NOAP)/ Composting Program/Establishment of Bioreactor
Project Name
EMB-Funded MRFs facilities for Biodegradable Waste and Vermicomposting Facility
Support the use of organic
fertilizer/compost made from Upgrade the facility through the
Objective Increase LGU
biodegradable market wastes in acquisition of Bioreactor Technology
related to compliance to RA 9003
rural farming and urban communities to further improve the processing of
SWM and waste diversion
to increase net revenue, and lower Biodegradable materials
production costs
Beneficiaries LGUs LGU Any Filipino public or private entity.

Source: COA Analysis

64
Composting Facilities for Biodegradable Wastes. BSWM. Retrieved January 4, 2023, from
http://bswm.da.gov.ph/download/composting-facilities-for-biodegradable-wastes-cfbw/

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Through an Audit Query Memorandum (AQM), DENR-EMB confirmed no

coordination with other agencies, such as DA or DOST, regarding distributing
assistance and equipment to LGUs nationwide. Moreover, DENR-EMB added
that there were no existing guidelines as to the extent the concerned agencies
were ensuring that there was no overlap or duplication.

As far as DENR-EMB was concerned, the data on waste segregation was the
basic information vital to determining the target LGU beneficiaries for
equipment assistance. This data emanating from the WACS will eventually
dictate what kind of SWM equipment is needed to impact waste diversion and
provide livelihood opportunities to residents significantly.

According to DENR-EMB, the prioritization of LGUs receiving equipment was

based on the waste generation data and coordination with its Regional Offices.
Once the recipients are identified, LGUs will receive notices about the
equipment donation. However, one clear criterion about their guidelines was
that the LGU should not have been a recipient or was not yet able to receive
equipment from any DENR-EMB procurement before. Consequently, DENR-
EMB validates whether the LGU recipient already has similar equipment
received from DENR-EMB but not from other agencies.

Additional research revealed that this concern was not entirely new, as this
was already reported in previous SWM dialogues. According to the report, no
existing database can assist in synchronizing and coordinating the SWM
implementation at all levels. Similarly, DENR-EMB confirmed no inventory of
existing solid waste facilities from other agencies, such as DA and DOST,
nationwide. Based on records, inventory was only limited to EMB-funded
equipment.

According to DENR-EMB, several challenges prevent accumulating data from

the LGUs or other agencies providing equipment. These include a lack of
ownership as to who was responsible for the access of needed data, the
reluctance of some stakeholders to share data, and given less priority in lieu
of more important matters, especially pandemic-related issues and concerns,
and connectivity issues, especially from those LGUs in remote locations.

In addition to discovering multiple and similar types of equipment (see Figure

74), we also noted that not all units were being used. The LGUs we interviewed
explained that they already had the necessary equipment, and therefore, saw
no need to use similar equipment. On the other hand, there were also LGUs
or barangays we interviewed that had not yet received equipment from DENR-
EMB and hence, would like to request equipment to increase their waste
diversion. Moreover, based on validation, we identified eight MRFs without
equipment for recycling (see Appendix III for complete TSO findings).

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Figure 74: Sample Units of SWM Equipment Donated by DA and DOST in MRFs

Location: Barangay Maoas-oas, Pugo, La Union (Left: Composter; Right: Shredder)

Location: Barangay Minadongjol, Sangay, Camarines Sur (Left: Composter; Right: Shredder)

Location: Barangay Catipan, Mabuhay, Location: Barangay Kahayagan, Olutanga,

Zamboanga Sibugay Zamboanga Sibugay

Source: COA Validation

However, suppose this lack of coordination resulting in an overlap of

beneficiaries continues, the government’s scarce resources will be divided
further without accounting for whether beneficiaries need the assistance or
whether the different programs cover the entirety of applicable beneficiaries to
ensure no one is left behind.

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Non-Establishment NSWMC had neither established adequate guidelines nor formulas for tipping
charges and rates that SLF operators will charge for managing or disposing of
of Standard residual wastes, among others. Hence, no standard tipping fee was available
Tipping Charges by to LGUs for benchmarking and transparent decision-making.
NSWMC
According to RA 9003, NSWMC shall establish, after notice and hearing of the
parties concerned, standards, criteria, guidelines, and formula that are fair,
equitable, and reasonable, tipping charges and rates that the proponent will
charge in the operation and management of SWM facilities and technologies.

However, confirmation from DENR-EMB revealed that these standards and

formulas were not established. Instead, the private sector was ceded the
power to impose fees based on the stipulated agreement in the contract or
MOA with the LGUs. According to Rule XVII Section 3 of IRR of RA 9003, the
private sector or civil society group shall impose fees for collection, transport,
and tipping in their SLFs. While, receipts and invoices shall be issued to the
paying public or to the government.

Consequently, this resulted in varying tipping fees for LGUs nationwide (see
Table 58).

Table 58: Tipping Fees Charged to LGUs from CYs 2019 to 2021

Tipping Fee per metric ton

LGU
2019 2020 2021
NCR (thru MMDA)* ₱ 356.38 ₱ 534.59 ₱ 534.02
Marikina, NCR 2,272.92 3,145.91 3,090.20
Ballesteros, Cagayan 1,667.36 1,643.66 1,401.79
Bayombong, Nueva Viscaya 1,458.08 2,470.37 2,754.46
Ilagan, Isabela 3,371.23 4,230.96 5,291.06
Aurora, Isabela 837.72 984.95 924.66
Tumauini, Isabela 297.15 307.30 371.69
Bocaue, Bulacan 1,250.00 1,109.78 1,206.65
Guinayanagan, Quezon 5,042.12 5,154.18 5,831.75
Tiwi, Albay 4,999.92 5,000.00 5,000.00
Catigbian, Bohol 1,500.00 1,500.00 1,500.00
Note: Data from MMDA were converted from cubic meters to metric tons using the
equation 1 cubic meter = 481 kgs65

Source: Various LGU data

Moreover, DENR-EMB confirmed that NSWMC does not monitor these tipping
fees. Due to the current condition of the limited SLF in the country, the
NSWMC Secretariat, through the DENR-EMB Regional Office, monitors the
tipping fees charged by the SLF operators for the data-keeping.

65
Weight of Garbage, household rubbish. Retrieved January 3, 2023, from https://www.aqua-
calc.com/calculate/volume-to-weight/substance/garbage-coma-and-blank-household-blank-rubbish

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Over the years, LGUs and MMDA have spent billions of pesos on tipping fees
yearly without adequate standards, criteria, guidelines, and formulas issued
by NSWMC. Although Rule XVII of the IRR of RA 9003 discussed the minimum
factors to be considered in the tipping fees for solid waste disposal, a proper
study and guidelines will ensure that tipping fees are not disadvantageous to
the government.

Non-Preparation of Only two products were listed as NEAP: plastic soft drink straws and plastic
coffee stirrers. These NEAPs were listed only on February 2, 2021, through
the list of NEAPs the NSWMC Resolution No. 1428, Series of 2021.
from 2001 to 2020
One of the provisions of RA 9003 is to prepare, review, and update the list of
NEAPs, provided, however, that NEAP shall not be prohibited unless the
Commission first finds that there are alternatives that are available to
consumers at no more than ten percent greater cost than the disposable
product.

In addition, the IRR of RA 9003 detailed what must be done to decide which
products should be declared as NEAP. According to Section 5, Rule XII of IRR
of RA 9003, prohibiting NEAP and any decision to prohibit certain packaging
types and products must be supported by available scientific, environmental,
technical, and economic information and technical studies through, but not
limited to life cycle assessment and economic analysis. The IRR also requires
the Commission to consult with representatives from affected industries,
subject to public notice and hearing.

As reported by DENR, the consultation from affected industries was one of the
challenges they encountered, resulting in the delay of the NEAP list. In
addition, NSWMC also experienced financial constraints in complying with the
requirement of producing a study supporting the prohibition of products listed
as NEAP. As established earlier, the NSWMC had not received any funding,
including the mandated initial operating expense, and thus, the Commission
has been working on a budget from DENR-EMB.

NSWMC explained that removing plastic from the market would make people
unable to use any products at all. They further elaborated that shifting to
reusable products could lead to a water shortage and worsen the wastewater
discharge problem. These are some of the factors that they are evaluating.
However, they are currently hindered in identifying alternatives unless the law
is amended and the provision is removed, or a wonder product is developed.
Thus, finding alternatives would be a challenge for the Commission.

According to reports, several plastic products may be considered NEAP and,

therefore, could have been avoided. Once listed in NEAP, the prohibition will
ensure this waste will not add to the already occupied SLFs, RCAs, or
dumpsites. These products may include plastic cups lower than 0.2 mm in
thickness, plastic spoons, plastic forks, plastic knives, and plastic labo and
thin-filmed sando bags lower than 15 microns.

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Figure 75: NEAP and Microplastics Explained

Source: COA Analysis

What could have been avoided? NEAP will act as a waste avoidance
strategy and aid in the growing concern over microplastics. In CY 2019, a
study conducted by the Coastal Resources and Ecotourism Research,
Development and Extension Center (CRERDEC) of the DENR-ERDB
confirmed the presence of microplastics in 10 study areas nationwide, with the
highest density found in the Tañon Strait Protected Seascape in Badian and
Moalboal, Cebu66. There was also a study by Negros Oriental State University,
Silliman University, and Arizona State University confirming the presence and
diversity of microplastics in an edible finfish in the Philippines. According to
this study, consuming seafood products contaminated with microplastics can
negatively affect the human body. If microplastics accumulated in human
bodies, this can result in an enhanced inflammatory response, size-related
toxicity of plastic particles, chemical transfer of adsorbed chemical pollutants,
and disruption of the gut microbiome, while microplastics and their chemical
constituents may cause localized particle toxicity.67 Although the primary
sources of microplastics were not specifically identified in the study, the
alarming effects are present, concerning the negative effects on our bodies
from consuming seafood that may be contaminated with microplastics (see
Figure 75).

66
DENR-ERDB, supra note 49, at 109.
67
Microplastics in marine sediments and rabbitfish (Siganus fuscescens) from selected coastal areas of
Negros Oriental, Philippines. (2019, November 6). ScienceDirect. Retrieved November 16, 2022, from
https://doi.org/10.1016/j.marpolbul.2019.110685

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Ratification of Basel The Philippines has yet to ratify the Basel Ban Amendment to ensure that no
illegal waste will be imported. This is despite the overall beneficial impact on
Ban Amendment the Philippines, where the long-term financial, environmental, and social
remains in progress benefits outweigh the short-term costs based on the results of a Cost/Benefit
Study68 and calls from different NGOs to ratify the Amendment.

One prohibited act of RA 9003 is importing toxic wastes misrepresented as

“recyclable” or “with recyclable content”. In addition to the said RA, there is
also the Basel Convention on the Control of Transboundary Movements of
Hazardous Wastes and their Disposal (hereinafter referred to as “the Basel
Convention”), which was adopted on March 22, 1989, and entered into force
on May 5, 1992. The Basel Convention was convened in response to a public
outcry following the discovery, in the 1980s, in Africa and other parts of the
developing world of deposits of toxic wastes imported from abroad.69

In 1995, due to continued challenges faced by developing countries and

countries with economies in transition in controlling imports of hazardous and
other wastes, parties to the Basel Convention adopted the Basel Ban
Amendment.70 The Amendment would restrain the member states of the
European Union, Organization for Economic Cooperation and Development
(OECD), and Liechtenstein from exporting hazardous wastes either for
recovery, treatment, or disposal to developing countries or countries with
economies in transition. This will ensure that developing nations like the
Philippines do not become convenient dumping sites for trash, even those
intended for recycling.

While the Philippines is a party to the Basel Convention, which treaty was
ratified by Congress on October 21, 1993, and entered into force on January
19, 1994, the country has yet to ratify the Basel Ban Amendment, which other
parties have adopted since CY 1995.

The ratification of this amendment is under the responsibility of DENR, as the

Competent Authority and Focal Point to the Basel Convention. Other
stakeholders would be the private sectors that include Registered Importers of
recyclable materials, industry associations, civil societies, and other
government agencies such as the DTI, Philippine Economic Zone Authority
(PEZA), Bureau of Customs (BOC), and Department of Foreign Affairs (DFA).
DENR disclosed that ratifying the Basel Ban Amendment started with
consultations with affected stakeholders from different parts of society. And to
facilitate the consultations, a Socio-Economic Impact Study was
commissioned by DENR focusing on the beneficial impact of ratifying the Ban
Amendment. After the consultations were completed, DENR initiated the
request for a Certificate of Concurrence from other Government Agencies to
inform them of the result of the study and consultations. This Certificate of
Concurrence shall be signed by respective secretaries/heads of the concerned
agencies as the basis of DENR to endorse the Ratification Dossier to the DFA
through the United Nations and International Organizations Office (UNIO). The

68
Cost/Benefit Study relative to the ratification of the Basel Ban Amendment
69
History of the negotiations of the Basel Convention. Retrieved September 13, 2022, from
http://www.basel.int/TheConvention/ Overview/History/Overview/tabid/3405/Default.aspx
70
The Basel Convention Ban Amendment. Retrieved September 13, 2022, from http://www.basel.int/
Implementation/LegalMatters/BanAmendment/Overview/tabid/1484/Default.aspx

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final step will be DFA’s preparation of the Instrument of Ratification to be

endorsed to the Office of the President for approval and signature. Once
approved, the DFA will transmit the said instrument of ratification to the United
Nations (UN) Headquarters in New York for official acceptance.

At present, DENR is still securing approval of the Certificates of Concurrence

from DTI, PEZA, and BOC. On the other hand, NGOs, such as Greenpeace
and EcoWaste Coalition, have expressed their strong support for ratifying the
Basel Ban Amendment so that the Philippines will no longer be a garbage
dump for some foreign countries. According to these NGOs, the government
should address the policy gaps or loopholes in the governing laws exposing
our country to threats of exploitative and unjust trade in hazardous waste and
other wastes.

According to DENR-EMB, the delay in ratifying the Basel Ban Amendment is

the concerns raised by the recycling industries dependent on importing
recyclable materials, either classified as hazardous or non-hazardous wastes.
By ratifying the Ban Amendment, our local recyclers or importers will no longer
be able to import recyclable materials from OECD states. This includes
importing Used Lead Acid Batteries (ULABs) and Waste Electrical and
Electronic Equipment (WEEE) for recycling and recovery.

However, the results of the Socio-Economic Impact Study on Ratifying the Ban
Amendment showed an overall beneficial impact on the Philippines where the
long-term financial, environmental, and social benefits outweigh the short-term
costs per Final Study Report on the Cost-Benefit/Economic Study Relative to
the Ratification of the Basel Ban Amendment commissioned by the DENR-
EMB (see Table 59).

Table 59: Summary of the Costs and Benefits of the Basel Ban Amendment

Scenario A: Increase Imports Scenario B: Increase Imports of Primary Raw

Hazardous Waste
from Non-OECD Countries Materials / No Replacements for OECD Imports

Financial

ULABs (+)$100,822,010.00 (+)$3,269,484.00

(+) ₱5,041,100,500.00 (+) ₱163,474,217.00

Additional Benefit of Increased

Local Collection and Recycling
>= $54,260,006.00

WEEE (-)$17,025,908.00 (+)$1,988,929.00

(-) ₱851,295,400.00 (+) ₱99,446,430.00

Total Financial Benefit (+) ₱6,902,805,400 (+) ₱262,920,647.00

Non-Financial

ULABs None Positive Impacts

● Reduced Lead releases by 121kg
● Less worker exposure from ULAB

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Scenario A: Increase Imports Scenario B: Increase Imports of Primary Raw

Hazardous Waste
from Non-OECD Countries Materials / No Replacements for OECD Imports

recycling

WEEE None Positive Impacts

● Reduced emissions/discharges from
WEEE recycling
● Less worker exposure from WEEE
recycling
● Increased local collection and recycling of
WEEE through EPR

Negative Impact
● Closing of businesses that recycle WEEE
only and only those that are imported
from OECD countries

Source: Socio-Economic Impact Study on Ratifying the Ban Amendment commissioned by DENR-EMB

By ratifying the Ban Amendment, the recycling industry would benefit from
ULABs for $3,269,484.00 or $155,082,016.00 ($100,822,010.00 +
$54,260,006.00) per year, depending on the chosen scenario. While the
recycling industry for WEEE would benefit from $1,988,929.00 per year. There
are also non-monetary benefits for both ULABs and WEEE recycling
industries, such as a reduction of lead releases by 121 kg per year, less worker
exposure from ULAB recycling, reduced emissions/discharges from WEEE
recycling, less worker exposure from WEEE recycling, and increased local
collection and recycling of WEEE through EPR. Lastly, one major
disadvantage to the recycling industry is the closure of businesses that recycle
only WEEE sourced from OECD countries. These non-monetary
benefits/disadvantages will only occur if the country adopts Scenario B.

Since the Philippines has yet to ratify the Basel Ban Amendment, the country
risked accepting toxic or hazardous waste mislabeled or misdeclared as
“recyclable” or “with recyclable content”. Below are some of the reported illegal
waste imported to the Philippines (see Table 60):

Table 60: Reported Illegal Waste Imported to the Philippines

Year Imported and

Volume/Weight of Waste Actual waste found Year and Action Taken
Country of Origin

2014, Canada 103 container vans or 2,400 Plastic bottles, plastic bags, 34 containers were
tons of hazardous waste newspapers, household disposed of in the SLF of
mislabeled as plastic for garbage, and used adult Metro Clark Waste
recycling71 diapers Management Corporation by
a virtue of a Court Order

71
Timeline: Canada garbage shipped to the Philippines. Rappler. Retrieved September 13, 2022, from
https://www.rappler.com/newsbreak/iq/188654-timeline-canada-garbage-philippines/

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Year Imported and

Volume/Weight of Waste Actual waste found Year and Action Taken
Country of Origin

69 containers were shipped

back to Canada72

2018, South Korea 331 container vans of toxic Unsorted plastic materials, All were shipped back to
waste mislabeled as plastic used dextrose tubes, soiled South Korea73
synthetic flakes diapers, discarded
electronics, and household
garbage

2019, Hong Kong 2,561 tons of smashed Shredded gadget parts and All were shipped back to
components of electronic plastic scraps Hong Kong74
devices misdeclared as
assorted electronic
accessories

1999, Japan 122 container vans of Disposable plastic syringes, All were shipped back to
hazardous waste rubber surgical gloves, adult Japan75
misdeclared as 80% waste diapers, candy wrappers,
paper and 20% plastic aluminum foil, rubber soles,
sanitary napkins, plastic
bags, and noodle cups
bearing Japanese
characters

Source: Various sources

While the Philippines has managed the disposal or return of these illegal
wastes to its origin country, our country continues to be exposed to the illegal
waste trade not until the Basel Ban Amendment is ratified and adopted.
Nonetheless, the DENR, in ensuring that illegal waste importation will not
occur again, committed to strengthening and updating environmental laws and
waste importation policies, and capacity building and coordination with border
authorities, particularly the BOC, DENR-EMB Regional Offices, other
government agencies, and international organizations.

72
Canada takes garbage back from Philippines, ending long dispute. GMA News Online. Retrieved
September 13, 2022, from https://www.gmanetwork.com/news/topstories/nation/699354/canada-takes-
garbage-back-from-philippines-ending-long-dispute/story/
73
Philippines Returns 80 Containers of South Korean Garbage. IPEN. Retrieved September 13, 2022,
from https://ipen.org/news/philippines-returns-80-containers-south-korean-garbage
74
E-wastes held in MisOr shipped back to Hong Kong. Philippine News Agency. Retrieved September 13,
2022, from https://www.pna.gov.ph/articles/1071417
75
Japan takes back hazardous waste from Philippines. The Free Library. Retrieved September 13, 2022,
from https://www.thefreelibrary.com/Japan+takes+back+hazardous+waste+from+Philippines.-
a058532706

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Conclusions More than 20 years after the passage of RA 9003, waste management has
continued to be an issue of concern. The projection made it even more
pronounced that annual solid waste creation will rise from 16.63 million metric
tons in CY 2020 to 19.76 million metric tons in CY 2030 and 24.50 million tons
in CY 2045.

While the NSWMC, the DENR-EMB, and the LGUs, have partnered to achieve
the goals of RA 9003, the intended results still need to progress. We found
delays in the preparation and approval of LGUs’ 10-yr SWM Plans, which
affected the budgeting and implementation of LGU’s SWM activities. While
LGUs strived to comply with the mandated waste diversion, results from
available data showed that actual waste diversion is still far from targets.
Further, records showed that the total number of MRFs is insufficient to service
all barangays nationwide, and the total number of SLFs is insufficient to service
all LGUs nationwide. DENR has allowed using RCA as a temporary disposal
site to remedy this gap. However, while serving as a short-term alternative, the
operations of RCAs without formal guidelines have potential risks if operated
longer than intended.

On a positive note, DENR, through EMB, has successfully reduced the number
of illegal dumpsites from 1,232 in CY 2009 to zero in CY 2021. However, our
validation from March to April 2022 revealed that not all dumpsites were
successfully and permanently closed. We found that LGUs had to reopen or
establish a new dumpsite due to a lack of capacity to construct their own SLF
and/or lack of funds to enter into an agreement with an SLF operator and pay
tipping fees. Further, climate change has also accelerated the need to find
measures to reduce and manage the waste generated and to reduce the
greenhouse gas emissions resulting from open burning and biodegradable
wastes in landfills or dumpsites.

Achieving SWM objectives cuts across a number of SDGs. However, at the

rate the waste generation is projected to increase, it will heavily impact SDG
12.5 which is to substantially reduce waste generation, through prevention,
reduction, recycling, and reuse by CY 2030. Unfortunately, the relevant SDG
indicator has not yet been included in the monitoring by PSA; thus, no progress
in attaining the target can be tracked. Meanwhile, even national targets on
waste diversion rate and the number of barangays served by an MRF were not
attained during the audit period.

LGUs are consistently provided with technical assistance, capability support,

and information dissemination on SWM; however, LGUs are still burdened
with challenges that hampered the effective and efficient implementation of its
10-yr SWM Plans and the achievement of the goals of RA 9003. For example,
the inconsistent implementation of waste segregation nationwide inadvertently
resulted in mixed waste collection, hazards to workers in landfills, and SLFs
exceeding capacity levels. Therefore, there is a need for more consistent
implementation of waste collection nationwide. In addition, we found that
collection assignments and responsibilities deviated from RA 9003 due to
either limitations at the barangay level or a lack of coordination with their local
government. Thus, either LGUs cover and collect all types of waste, or
household wastes are not collected.

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Several EMB-funded MRFs, including units/sets of equipment, have yet to be

established or operational. Due to a lack of appropriate land siting or delay of
utilization by the LGUs, there are at least ₱124.22 million earmarked for MRF
establishment and SWM equipment fabrication which remained outstanding
as at June 2022. Likewise, there is at least ₱555.65 million worth of equipment,
or at least 635 units or sets of equipment which are reported as not operational
as at May 31, 2022, due to various reasons, but mainly due to lack of electricity
lines. Further, some MRFs lack the mandated recording mechanism, including
a weighing scale, and thus would result in unreliable and incomplete data on
waste diversion. In addition, uncollected and unprocessed waste materials
accumulate in some MRFs due to LGUs’ difficulties in processing, selling, or
disposing of their recyclable wastes. Hence, this accumulation of waste is
overwhelming the MRFs and posing a risk to possible environmental hazards
if waste is not managed soon. Furthermore, there are noted non-establishment
of M/CENRO positions and overwhelming work of EnMOs.

On the other hand, we gathered several practices that can be replicated or

improved by LGUs. Despite the challenges and limitations of LGUs, there are
still LGUs that showcased resourcefulness in finding ways to divert waste.
Moreover, various private companies, including non-governmental
organizations, have also participated in local SWM programs to contribute to
waste diversion and effective waste management.

Regarding the program’s planning, implementation, and monitoring under RA

9003, we found gaps mainly due to inadequate institutional mechanisms to
kick-start the program. The mandated appropriation of ₱20 million for the initial
operating expense of the NSWMC, the NEC, and the LGUs was not released.
Moreover, the SWM Fund has not yet been established, which would have
been used by NSWMC and LGUs to implement their 10-yr SWM Plans.
Because these mandated funding sources were not realized, NSWMC has
worked only on a budget provided to the DENR-EMB for SWM activities. While
the DENR-EMB has provided certain budgetary allocations of the NSWMC, it
does not include, however, the realization of some mandates of the NSWMC.
This includes the establishment of the NEC, which shall support the
implementation of RA 9003 by making available information, consulting,
training, and networking services. However, no organizational structure,
personnel assigned, or budget has been allotted for the NEC. Hence, to
implement the NEC mandate, the Secretariat or the DENR-EMB has been
partly functioning as the NEC since CY 2002.

We also noted overlapping LGU beneficiaries due to a lack of coordination

between DENR, DA, and DOST, resulting in barangays or MRFs with multiple
and similar equipment from different agencies. While some barangays or
MRFs benefit from this larger capacity to divert waste, some units/sets of
equipment were also found idle and unused. Additionally, the Basel Ban
Amendment has not yet been ratified despite the commissioned study by
DENR-EMB showing that ratification would have an overall beneficial impact
on the Philippines where the long-term financial, environmental, and social
benefits outweigh the short-term costs. Lastly, we found that the NSWMC
updated the NEAP list only in CY 2021, thus delaying the beneficial effects it
would have accorded the environment.

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Overall, necessary and appropriate steps have to be implemented to improve

the enforcement and compliance with RA 9003, which currently remains a
difficult task because of political, financial, and technical limitations of the
LGUs and other concerned agencies, as observed in our performance audit.

Recommendations Given the opportunities for improvement noted in the performance audit of the
SWMP, COA recommends to NSWMC the following courses of action:

(a) Continue the technical assistance provided to LGUs in the preparation

of timely and relevant SWM plans;
(b) Expedite the review and approval of SWM plans submitted by LGUs;
(c) Institutionalize a robust data system, including collection and reporting
on waste generation, diversion and disposal, and inventory of waste
facilities, to improve monitoring and to enable review of future targets
and plans for the effective, efficient, and economical SWM
implementation, as well as monitoring and assessment in relation to
national targets and SDGs.
(d) Prepare relevant guidelines to ensure the establishment and operation
of MRS, caged MRFs, and RCAs are compliant with Sections 33 and
37 of RA 9003;
(e) Ensure that established MRFs are utilized, and wastes diverted are
recorded;
(f) Ensure that established SLFs adhere to applicable standards and
measures for safe and sustainable operation, especially avoidance of
landfills operating at overcapacity levels;
(g) Review and provide alternative options for LGUs to comply with the
minimum criteria in establishing an SLF;
(h) Assist and encourage LGUs to take advantage of the benefits of
clustering a Common Solid Waste Disposal Facility;
(i) Review the applicable fines and penalties to violators of RA 9003 and
effectively enforce the same through DENR;
(j) Review and strengthen the incentives and penalty mechanisms to
provide clear structures to the public who are the primary implementers
of segregation-at-source;
(k) Facilitate coordination or sharing of responsibility and best practices
among national agencies and local governments to resolve the
financial, logistical, and technical issues encountered by LGUs in
establishing MRFs and to ensure that there is no overlap of
beneficiaries and that all LGUs have an equitable chance to benefit
from the program;
(l) Assist LGUs, in coordination with other agencies, in providing waste
management education and awareness to households and institutions,
particularly waste avoidance, segregation, and proper disposal;
(m) Assist LGUs, in coordination with other agencies, in selling segregated
or processed recyclable wastes to ensure that these wastes are not
accumulated in MRFs or disposed of in landfills;
(n) Coordinate with concerned agencies on the provision of the initial
operating budget mandated in RA 9003 and the establishment of the

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SWM Fund, including the establishment of the necessary institutional

arrangement to administer the fund properly;
(o) Coordinate with concerned agencies to formally operationalize the
National Ecology Center, including the establishment of the
organizational structure, personnel and experts, and budget to deliver
the mandates of NEC;
(p) Coordinate with concerned agencies to review and establish
standards, criteria, guidelines, and formulas for establishing tipping
charges to ensure that tipping fees by proponents or SLF operators
are fair, equitable, and reasonable;
(q) Coordinate with concerned agencies to prioritize the process of review
and approval of submitted and future NEAP proposals;
(r) Coordinate with concerned agencies to help LGUs institutionalize the
Environment and Natural Resources Office, that would ensure that the
objectives and plans for delivering environmental and natural resource
development principles are carried out effectively and efficiently;
(s) Coordinate with concerned agencies and LGUs to ensure an equal
proportion of men and women holding M/CENRO positions; and
(t) Coordinate with NGOs or Private Companies with SWM Partnerships
with national or local governments to ensure that best practices are
recorded for information dissemination and practices are maintained
after partnerships are completed.

On the other hand, COA recommends that the NSWMC coordinate with the
DENR-EMB to take the following actions:

(a) Ensure that recipients of MRF financial assistance and SWM

equipment have the necessary requirements to establish or operate
the MRF and the equipment, including appropriate matching of
equipment to what type of waste needs to be processed;
(b) Monitor the utilization of MRF financial assistance and SWM
equipment provided to LGUs to ensure that MRFs and equipment are
established and utilized as intended;
(c) Ensure that necessary training and demonstration are provided to
beneficiaries after delivery of SWM equipment by the supplier;
(d) Coordinate with concerned agencies to prioritize the ongoing process
of ratifying the Basel Ban Amendment and to continue strengthening
implementation and updating their policy on importing recyclable
materials containing hazardous substances; and
(e) Monitor the assignments of EnMOs nationwide to ensure work viability
and personnel's well-being.

Finally, COA recommends that the NSWMC, through the DENR-EMB,

coordinate with the DILG and ULAP to ensure that LGUs will examine and
provide appropriate actions or measures on the following significant concerns:

(a) Incomplete/Non-recording of waste generation, diversion, and disposal

(b) Inconsistent waste segregation and collection
(c) Mixed waste collection and disposal
(d) Non-compliance of mandatory waste diversion
(e) Non-establishment of MRFs
(f) Non-operational units/sets of SWM equipment

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(g) Accumulated wastes in MRFs

(h) Illegal use of dumpsites
(i) Social unacceptability of SLFs among the residents
(j) Reluctance to clustering for a Common Solid Waste Disposal Facility
(k) Non-enforcement of fines and sanctions to violators of RA 9003
(l) Hazards to workers at landfills, including household healthcare waste
(m) Hazards to establishments or residents within 200m from landfill or
dumpsite
(n) Gender inequality in the hiring of M/CENROs.

Agency Comments We provided a draft of this report to the NSWMC for comment. NSWMC
provided written responses which we incorporated as appropriate in this report.

Contact points for our Performance Audit Office may be found on the last page
of this report. Major contributors to this report are listed in Appendix V.

In addition, the report will be available at the COA website at

https://www.coa.gov.ph.

MICHAEL L. RACELIS
Director IV
Performance Audit Office
Special Services Sector

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Appendix I: Objectives,
Scope and Methodology

COA conducts performance audits to help government agencies better perform

Appendix I: their mandates and achieve program goals and objectives more economically,
Objectives, Scope efficiently, and effectively. It identified the Solid Waste Management Program
and Methodology (SWMP), which implementation is under the supervision of the National Solid
Waste Management Commission (NSWMC) chaired by the Secretary of the
Department of Environment and Natural Resources (DENR), as one of the
priority programs, which will be audited. The audit aimed to determine: (1) the
extent the program achieved its goals and objectives; (2) the challenges in
implementing the program; and (3) the extent the program implementers
administered the program following established policies and procedures.

To determine the extent the SWMP achieved its goals and objectives and the
challenges encountered in implementing the program, we conducted desk
reviews on relevant laws, policies, rules, and regulations related to SWMP. This
includes documentation such as accomplishments and status reports of
established Materials Recovery Facilities (MRFs), Sanitary Landfills (SLFs),
Residual Containment Areas (RCAs), 10-year SWM Plans, and Illegal
Dumpsites. Moreover, validations were conducted on sample LGUs and
barangays with MRF, SLF, RCA, or dumpsite to assess the operation and the
challenges encountered. We also obtained and analyzed relevant
documentation on SWM from the DENR, scholarly articles, and third-party
evaluation reports. Moreover, we also conducted site visits to different Local
Government Units (LGUs) and barangays and took geo-tagged photographs.

To enhance stakeholder relations, we adopted a Citizen Participatory Audit

approach. This involved engaging a Citizen Partner who is a former COA
Auditor with extensive knowledge and experience in the field. She assisted us
in collecting information and evidence from CSOs/NGOs and specific
barangays. The collection of information was done through the conduct of
surveys and interviews.

To determine the extent to which the NSWMC, the DENR, and other concerned
agencies administer the program following established policies and
procedures, we reviewed applicable laws, rules, and regulations related to
SWMP to determine the respective roles of the concerned government
agencies and stakeholders. We also interviewed DENR, LGUs, barangay
officials, and various stakeholders, including NGOs, to determine the actions
taken to implement the program according to the established guidelines.

In the surveys and validations conducted, we used a combination of

generalizable and non-generalizable samples; hence, some data will only
indicate the presence but not the extent of the condition in the population.

We used generalizable sampling to obtain a broad understanding of SWM. We

consulted the NSWMC, DENR-EMB Central and Regional Offices, and other
concerned agencies and gathered LGU survey and summary reports. The
survey and summary reports were inclusive of all Regions. The LGU survey

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Appendix I: Objectives,
Scope and Methodology

provided us with a basic overview of the waste management facilities utilized

by the local government entities. In addition, the summary reports offered
information regarding the progress of SCRPs, EnMO, M/CENRO posts, private
sector contributions, MRF equipment acquisitions, and financial assistance.

Regarding the non-generalizable sample used, we grouped the regions based

on the area's average MRF cost and diversion rate. Then, selecting the location
of interest was based on its data quality by selecting the extremes (high and
low-quality data). Next, we drew a stratified random probability sample of 45
MRFs from the selected regions from the DENR-EMB's data of 978 MRFs. With
that probability sample, each member of the study population had a nonzero
probability of being included, and that probability could be computed for any
member. After drawing a sample, we stratified the population into six (6) groups
based on the MRF's diversion, cost, and data quality, such as High Cost-High
Diversion, High Cost-Low Diversion, High Cost-No Data, Low Cost-High
Diversion, Low Cost-Low Diversion, and Low Cost-No Data. Finally, for clarity,
we calculated the sample size of 45 from the population of 978 using Cochran's
formula for the finite population since the population size is known
(determined). Since each sample could have provided different estimates, we
presented its confidence in the precision of the particular sample with a
confidence level of 80 percent, a margin of error of 9.3 percent, a probability of
success, and failure of 50 percent.

On the other hand, we used a non-generalizable sample again to gather

insights on audit objectives about disposal facilities, such as SLFs, RCAs, and
dumpsites. We selected nine (9) regions that will be used for the validation,
where one SLF, one RCA, and one dumpsite shall be visited per region. On top
of validating the disposal facilities, we interviewed at least five workers in each
facility, if there were any. However, due to various limitations, we used the
convenience sampling method to validate SLFs, RCAs, dumpsites, and the
workers.

Overall, we determined that the data used in this report were sufficiently reliable
to assess the status and condition of the SWMP implemented by the NSWMC,
the DENR, and LGUs.

We conducted the audit from June 2021 to September 2022 following the
Standard for Performance Auditing as embodied in the International Standards
of Supreme Audit Institutions (ISSAI) 3000. The standard requires that we plan
and perform the audit to obtain sufficient and appropriate evidence to provide
a reasonable basis for our findings and conclusions based on our audit
objectives. Accordingly, we believe the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit
objectives.

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Appendix II: Survey and

Interview Results

To gather the additional source of information to answer the audit objectives,

Appendix II: we conducted various methodologies in gathering testimonial evidence from
Survey and relevant stakeholders. The participants of these methodologies, include
Interview Results households, workers, teachers, students, barangays, and LGUs. While the type
of methodology used is highly dependent on the convenience of the
participants or respondents.

Number of Actual
Stakeholder Methodology
Respondents
Households Face-to-face Survey 360

Workers Face-to-face Survey 96

Teachers Google Forms 2,646

Students Google Forms 4,952

LGUs Google Forms 591 out of 1,634

Barangay Structured Interview 42 out of 45

Overall, we targeted to visit and interview 45 barangays and inspect the EMB-
funded MRF in each of that barangay. For every barangay/MRF, we surveyed
eight (8) households. For the other stakeholders, the number of respondents
depended on the availability of workers in inspected MRFs, SLFs, and RCAs
and the submissions received after the cut-off for online surveys for teachers,
students, and LGUs. On the other hand, we could not gather responses from
three (3) barangays due to limitations during the validation.

As to the results of these testimonials, they served as a source of information

for validation of the existence of beneficiaries, processes, and mechanisms the
officials have used to implement the program, level of awareness of
stakeholders on the SWMP, areas for improvement and other data for analysis
in support of the audit objectives.

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Households Survey

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Worker Survey

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Teachers and Students Survey

Waste Red Orange Yellow Green Blue Violet Black Brown Gray Pink White
Biodegradable 1,945 1,142 1,408 4,347 1,497 1,083 1,212 1,534 1,251 1,265 1,379
Non-Bio 2,445 1,551 1,666 1,013 1,858 1,007 1,139 881 980 929 906
Chemicals 1,025 686 1,082 189 509 566 1,355 510 537 370 444
Recyclable 1,089 856 1,426 1,047 1,884 501 484 444 544 567 547
Residual 309 786 874 453 606 537 684 502 483 363 351

LGU Survey

LGUs with submitted

Region LGUs with ordinances LGUs without ordinances
ordinances to the team
CAR 32 0 30
NCR 12 0 10
1 6 0 6
2 81 1 74
3 83 13 87
4A 15 0 13
4B 61 5 53
5 27 3 24
6 41 6 41
7 75 3 68
8 9 0 8
9 36 1 32
10 5 0 5
11 37 1 35
12 32 1 29
13 5 0 5
Total 557 34 520

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Appendix II: Survey and Interview Results

No. of % of
No. of No. of Operational No. of Barangays Operational % of Barangays
Region City Municipality
Barangays MRFs MRFs serviced by MRFs MRFs serviced by MRFs
(A) (B) (C) (D) (C/B) (D/A)
CAR 1 31 523 315 271 449 86 86

NCR 11 1 563 348 304 371 87 66

1 2 4 199 172 172 199 100 100

2 4 78 2,062 1,499 1,377 1,693 92 82

3 10 86 2,331 1,318 1,253 1,987 95 85

4A 0 15 400 232 214 282 92 71

4B 2 64 1,365 1,131 1,055 1,019 93 75

5 2 28 983 782 731 713 93 73

6 2 45 1,269 839 820 864 98 68

7 10 68 1,850 1,194 1,100 1,353 92 73

8 1 8 402 242 196 288 81 72

9 2 35 966 761 642 670 84 69

10 0 5 77 107 97 67 91 87

11 6 32 987 1,420 1,364 817 96 83

12 3 30 788 491 434 559 88 71

13 1 4 88 105 105 62 100 70

Total 591 14,853 10,956 10,135 11,393 93 77

Barangay Interview

No. of Sample
Region
Barangay
CAR 4
NCR 4
Luzon 1 5
3 6
4A 5
5 5
Visayas
7 4
9 5
Mindanao
11 5

Total 43

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Appendix III: Summary of Appendix III: Summary of

Significant Technical Significant Technical
Findings by TSO Findings by TSO

Materials Recovery Facilities (MRFs)

Inspected Site Location

Criteria MRF Observations
Region Province City/Municipality Barangay
Sec. 1 (a) and (b) Out of the 3 MRFs had no CAR Abra Pidigan -
Rule XI, IRR of the 45 MRFs personnel CAR Benguet Itogon Tuding
RA 9003: The inspected, managing the
Camarines
building and/or 10 MRFs facility V Pili San Jose
Sur
layout and are not
equipment must utilized for 1 MRF was used V Camarines Libmanan Bagumbayan
be designed to their only as a Sur
accommodate intended storage for
efficient and safe purpose biodegradable
materials wastes
processing, 1 MRF was VII Cebu San Fernando South
movement and turned into a Poblacion
storage. The “bodega”
building must be 1 MRF is fully VII Cebu Ginatilan Poblacion
designed to allow occupied by the
efficient and safe collected waste
external access generated
and to during the
accommodate pandemic, and
internal flow. some wastes
were stored
outside the
facility and
exposed to any
weather
conditions
3 MRFs had no I La Union Aringay Poblacion
composting and Mangatarem Sapang
segregated
storage IV-A Quezon Atimonan Inaclagan
1 MRF was NCR Quezon City Bagong
flooded and is Silangan
currently not
operational
Out of the 45 MRFs CAR Abra Pidigan -
constructed, 6 MRFs were III Bataan Bagac -
open and not secured
V Camarines Libmanan Bagumbayan
Sur Pili San Jose
VII Bohol Panglao Bolod
Davao de
XI Mabini Cuambog
Oro
Of the 37 EMB-funded MRFs, I La Union Alcala San Pedro
7 MRFs were constructed as Pangasinan Laguit
an extended facility Bugallon
Padilla

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Appendix III: Summary of Significant Technical Findings by Technical Services

Office (TSO)

Inspected Site Location

Criteria MRF Observations
Region Province City/Municipality Barangay
III Bulacan San Jose Del -
Monte City
Bataan Bagac -
Aurora Baler -
VII Cebu Ginatilan Poblacion
South
San Fernando
Poblacion
EMB Fund for the construction CAR Abra Pidigan -
of 2 MRFs was not utilized Davao del
XI Davao City Mintal
Sur
1 MRF is built on private III Zambales Masinloc South
property under a Deed of Poblacion
Usufruct
The roofing of 2 MRFs was VII Bohol Inabanga Lonor Sur
damaged, allegedly due to Panglao Bolod
Typhoon Odette that struck
the Philippines last December
2021
The wire mesh perimeter wall IX Zamboanga Olutanga Kahayagan
of Barangay Kahayagan, Sibugay
Olutanga, Zamboanga
Sibugay MRF was damaged,
allegedly due to corrosion of
metal
Sec. 1 (d) Rule XI, 14 MRFs do not have daily CAR Abra Bucloc Poblacion
IRR of the RA records of weights or volumes Pidigan -
9003, that records of wastes
Benguet Itogon Tuding
shall be kept and
maintained Kibungan Sagpat
Bagong
NCR Quezon City
Silangan
I La Union Aringay Poblacion
Pangasinan Mangatarem Sapang
IV-A Quezon Atimonan Inaclagan
Camarines Pili San Jose
Sur Libmanan Bagumbayan
VII Cebu Ginatilan Poblaction
South
San Fernando
Poblacion
Bohol Inabanga Lonor Sur
IX Zamboanga Mabuhay Catipan
Sibugay
33 MRFs do not have CAR Benguet Itogon Tuding
weighing equipment Abra Bucloc -

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Appendix III: Summary of Significant Technical Findings by Technical Services

Office (TSO)

Inspected Site Location

Criteria MRF Observations
Region Province City/Municipality Barangay
Abra Pidigan -
NCR Malabon City Panghulo
Marikina City Fortune
Bagong
Quezon City
Silangan
I La Union Aringay Poblacion
Pugo Maoas-oas
Pangasinan Laguit
Bugallon
Padilla
Mangatarem Sapang
III Aurora Pingit -
Bataan Atilao -
IV-A Cavite Kawit Aplaya
Ternate Sapang Uno
Quezon Atimonan Tayuman
Infanta Magsaysay
Tandang
Rizal Tanay
Kutyo
V Albay Legazpi City -
Camarines Bula Sto. Niño
Sur Libmanan Bagumbayan
VII Bohol Inabanga -
Panglao Bolod
Cebu Ginatilan Poblacion
San Fernando -
IX Zamboanga Baking
Lakewood
del Sur (Poblacion)
Sominot Barubuhan
Zamboanga Mabuhay Catipan
Sibugay Olutanga Kahayagan
XII Davao de Mabini Cuambog
Oro Maragusan Poblacion
New Bataan Cabinuangan
Davao del Davao City Mintal
Sur Matanao Langa-an
Sec. 4 (a) Rule XI, 1 MRF was sited in an area NCR Quezon City Bagong
IRR of the RA subject to frequent flooding. Silangan
9003, that facility The barangay has an on-going
shall not be sited construction of a new MRF in
in areas subject to a location with high altitude
frequent flooding

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Office (TSO)

Inspected Site Location

Criteria MRF Observations
Region Province City/Municipality Barangay
and allegedly no frequent
flooding
Terms of 23 MRFs have composting NCR Taguig City Katuparan
Agreement of and segregated storage Marikina City Fortune
DENR-EMB for
I La Union Pugo Maoas-oas
the provision of
establishing MRFs Pangasinan Alcala San Pedro
that area is big Alaminos City -
enough for the 2
Bugallon Padilla
MRF components
(composting and III Aurora Baler -
segregated Puerto Rivas
Bataan Balanga
storage) Lote
Bulacan San Jose del -
Monte City
IV-A Tandang
Rizal Tanay
Kutyo
Quezon Infanta Magsaysay
V Albay Legazpi City San Roque
Camarines Bula Sto Niño
Sur Iriga City -
Pili San Jose
Sagnay Minadongjol
VII Cebu Bogo City Poblacion
IX Zamboanga Sominot Barubuhan
del Sur Lakewood Poblacion
Kumalarang -
Zamboanga Mabuhay Catipan
Sibugay
XI Davao del
Matanao Langaan
Sur
Davao de
Maragusan Poblacion
Oro
17 MRFs only have CAR Benguet Itogon Tuding
segregated storage Kibungan Sagpat
Abra Bucloc Poblacion
Lagangilang -
NCR Malabon City Pangulo
Bagong
Quezon City
Silangan
III North
Zambales Masinloc
Poblacion
Bataan Bagac Atilao

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Appendix III: Summary of Significant Technical Findings by Technical Services

Office (TSO)

Inspected Site Location

Criteria MRF Observations
Region Province City/Municipality Barangay
IV-A Cavite Kawit Aplaya
Ternate Sapang I
VII Cebu Ginatilan Poblacion
South
San Fernando
Poblacion
Bohol Inabanga Lonor Sur
Panglao Bolod
IX Zamboanga Olutanga Kahayagan
Sibugay
XI Davao de Mabini Cuambog
Oro New Bataan Cabinuangan
1 MRF has only composting V Camarines
Libmanan Bagumbayan
Sur
4 MRFs do not have NCR Pasig City Rosario
composting and segregated I La Union Aringay Poblacion
storage
Pangasinan Mangatarem Sapang
III Quezon Atimonan Inaclagan

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Appendix III: Summary of Significant Technical Findings by Technical Services

Office (TSO)

Sanitary Landfills (SLFs)

Inspected Site Location
Criteria SLF Observations City/
Region Province
Municipality
Section 1 (b) Rule XIV, RA 1 SLF is accessible by boat NCR Navotas City
9003 IRR, that the site
shall be accessible from
major roadways
Section 1 (m.1) Rule XIV, 1 SLF is surrounded by bodies of water NCR Navotas City
RA 9003 IRR, that the or Manila Bay
facility shall be minimum of The nearest river distance to the Waras V Camarines Iriga City
50 meters away from any River was about 30.20 meters (m). A Sur
perennial stream, lake or pumping station was built to prevent
river the overflowing of leachate or for the
recirculation process.

Section 1 (m.2) Rule XIV, 1 SLF is located in an area surrounded NCR Navotas City
RA 9003 IRR, that the site by bodies of water or Manila Bay
shall be evaluated for
presence of geologic
hazards, faults, unstable
soils, its foundation
stability, and its
hydrological character. The
site shall not be located in
floodplain
Section 1 (j) Rule XIV, RA No photographs before and after the IV-A Cavite GMA
9003 IRR, that landfills construction/ operation of the SLF were
shall be provided with a presented. It was also reported in the
base system consisting of Monitoring/Inspection report of DENR
clay and/or geosynthetic Regional Office No. IV, approved by
membranes Noemi A. Paranada, Regional Director,
(geomembrane) dated October 08, 2021, that there are
no details for HDPE or clay liner within
the cells.

Section 1 (t) Rule XIV, RA 3 SLFs do not have a separate NCR Navotas City
9003 IRR, that designation containment area for household I La Union Aringay
of a separate containment hazardous wastes. Navotas and La VII Cebu Asturias
area for household Union SLFs do not accept such wastes
hazardous wastes
Section 1 (v) Rule XIV, RA 3 SLFs do not have groundwater CAR Benguet La Trinidad
9003 IRR, groundwater monitoring wells on site; hence, the IV-A Cavite GMA
monitoring wells effect of a landfill on groundwater VII Cebu Asturias
cannot be monitored or identified. For
La Trinidad SLF, MENRO staff
explained that it was due to site
geological features which are
terraneous or mountainous

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Appendix III: Summary of Significant Technical Findings by Technical Services

Office (TSO)

Inspected Site Location

Criteria SLF Observations City/
Region Province
Municipality
Section 1 (w) Rule XIV, RA 2 SLFs apply soil cover but not daily VII Cebu Asturias
9003 IRR, daily soil cover XI Davao de Maragusan
Oro
2 SLFs do not apply soil cover CAR Benguet La Trinidad
I La Union Aringay
Section 1 (k) Rule XIV, RA Leachate collected is not treated and CAR Benguet La Trinidad
9003 IRR, Leachate stocked in the drainage. The worker
collection and removal also reported that the leachate
system overflows when raining, damaging
nearby plants or cops

When the pond is full, it discharges III Bulacan Norzagaray

untested leachate to the nearest river
but without a discharge permit from the
DENR-EMB

The SLF has no leachate pond IV-A Cavite GMA

constructed per the
Monitoring/Inspection Report of DENR
Regional Office No. IV, dated October
8, 2021

Section 1 (l) Rule XIV, RA Leachate ponds at 6 SLFs are made of CAR Benguet La Trinidad
9003 IRR, that leachate concrete/CHB wall; however, there is I La Union Aringay
storage shall be designed no HDPE liner. Therefore, leachate Pugo
with containment systems may seep through the concrete if Pangasinan Alaminos City
and shall include a impounded or not discharged. VII Cebu Asturias
geomembrane liner system XI Davao de Maragusan
for leachate impoundment Oro
ponds
Section 2 (a) Rule XIV, RA 1 SLF does not have records of wastes CAR Benguet La Trinidad
9003 IRR, Disposal site disposed of.
records
(15) Section 48, Chapter VI There are establishments within 200 CAR Benguet La Trinidad
of RA 9003 – Prohibited meters from the 9 SLFs I La Union Aringay
Acts, Construction of any Pugo
establishment within 200 Pangasinan Alaminos
meters from open dumps III Bulacan Norzagaray
or controlled dumps or IV-A Cavite GMA
SLFs V Camarines Iriga
Sur
VII Cebu Asturias
IX Zamboanga Zamboanga
Sibugay City
Section 1 (x) Rule XIV, RA Cell 3 of the landfill that has reached CAR Benguet La Trinidad
9003 IRR, that Closure of overcapacity was still operating after its
the landfill shall be designed height. At the time of

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Appendix III: Summary of Significant Technical Findings by Technical Services

Office (TSO)

Inspected Site Location

Criteria SLF Observations City/
Region Province
Municipality
completed within one year inspection, it has reached 5 to 6 meters
of cessation of landfill in height from the pavement/road level.
operation
It was cited in the Monitoring/Inspection IV-A Cavite GMA
Report of the DENR Regional Office
No. IV, dated October 8, 2021, that the
SLF status was operational but on-
going closure since August.

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Appendix III: Summary of Significant Technical Findings by TSO

SWM Equipment
A. MRF

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B. SLFs

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C. Dumpsites

D. Residual Containment Areas (RCAs)

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Appendix IV: Solid Waste Management

Appendix IV: Solid Waste
(SWM) on Sustainable Development
Management on SDGs
Goals (SDGs) Achievement Achievement

Solid Waste Management Program (SWMP)

SDG Target and Indicator Affected
Activity
Processes and Methods
Recycling technology provides more opportunities Goal 8: 8.2 Achieve higher levels of economic
for higher levels of economic productivity Decent work productivity through a focus on high value-
and added and labor-intensive sectors
economic
growth
Recycling material processes in SWM promotes Goal 9: 9.2 Promote inclusive and sustainable
creating opportunities for unlimited industries and Industry and industrialization and significantly raise the
small projects that stimulate innovation processes in Innovation industry’s share of employment
various fields of industry
Integrated and sustainable SWM raises the value Goal 11: 11.1 Ensure access for all to adequate,
of indicators of quality of life for cities and maintains Sustainable safe, and affordable housing and basic
the sustainability of local communities cities and services and upgrade slums
communities
Adopting the green circular economy model Goal 12: 12.1 Implement the 10-year framework of
ensures the sustainability of responsible Responsible programs on sustainable consumption and
consumption and production patterns consumption production
and
production 12.2 Achieve the sustainable management
and efficient use of natural resources
Adopting the extended producer responsibility Goal 12: 12.6 Encourage companies to adopt
policy (EPR) Responsible sustainable practices
consumption
and
production
Human Capital
Incorporating waste pickers and improving their Goal 1: No 1.1 Eradicate extreme poverty for all
economic conditions has improved poverty rates in poverty people everywhere
the developing world
Recycling and reuse of solid waste have great Goal 1: No 1.2 Reduce at least by half the proportion
potential to create jobs and employment poverty of men, women, and children of all ages
opportunities living in poverty
Separating food waste and managing food waste Goal 2: Zero 2.1 End hunger and ensure access by all
supports providing a measure of food for the poor hunger people, in particular, the poor and people
and vulnerable groups, thus supporting the in vulnerable situations, including infants,
reduction of hungry populations to safe, nutritious, and sufficient food all
year round
Recycling organic solid waste produces very good Goal 2: Zero 2.3 Double the agricultural productivity and
organic fertilizers, increases the chances of hunger incomes of small-scale food producers, in
doubling agricultural productivity, and enhances the particular, women, indigenous peoples,
success of agricultural practices for small food family farmers
producers

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Appendix IV: Solid Waste Management on SDGs Achievement

Solid Waste Management Program (SWMP)

SDG Target and Indicator Affected
Activity
Reducing the sorting processes in the informal Goal 3: 3.1 Reduce the global maternal mortality
system by the denomination of pregnant and Good health ratio
postpartum women reduces the maternal mortality and well-
rates being
Preventing waste sorting processes in informal solid Goal 3: 3.2 End preventable deaths of newborns
waste communities that take place indoors and in Good health and children under five years of age, with
the streets, reducing the risk of disease exposure and well- all countries
for children and infants being
Follow the proper management of medical waste Goal 3: 3.3 End the epidemics of AIDS and combat
disposal inside the health facilities and use Good health hepatitis, water-borne diseases, and other
protectors for the hands to prevent injuries, the and well- communicable diseases
transmission of diseases, and hepatitis during the being
collection and sorting processes

Proper handling of solid waste and disposal

methods supports a healthy, disease-free
environment
Reducing child labor, as children are part of the Goal 4: 4.1 Ensure that all girls and boys complete
informal solid waste system, which increases Quality free, equitable, and quality primary and
illiteracy and school dropout rates education secondary education
Providing technical and vocational education Goal 4: 4.3 Ensure equal access for all women and
related to the SWM system supports school Quality men to affordable and quality technical,
enrollment and learning opportunities for garbage education vocational, and tertiary education
collectors’ communities
4.4 Increase the number of youth and
adults who have relevant skills, including
technical and vocational skills, for
employment, decent jobs, and
entrepreneurship
Reducing the exploitation of women in the informal Goal 5: 5.1 End all forms of discrimination against
system, as they play a major role in the waste Gender all women and girls everywhere
sorting stage, making them more vulnerable to equality
diseases
Providing healthy proper job opportunities based on Goal 5: 5.5 Ensure women’s full and effective
solid waste recycling directed at women and girls Gender participation and equal opportunities
equality
5.6 Ensure universal access to
reproductive health and reproductive rights
as agreed
Health and Environment
The efficient orientation of Refuse, Reduce, Reuse, Goal 12: 12.5 Substantially reduce waste
Recycle, and Recover (5Rs) greatly reduces waste Responsible generation through prevention, reduction,
production consumption recycling, and reuse

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Appendix IV: Solid Waste Management on SDGs Achievement

Solid Waste Management Program (SWMP)

SDG Target and Indicator Affected
Activity
and
production
Reducing pollution caused by dumping plastic and Goal 6: 6.3 Improve water quality by reducing
hazardous wastes into or near waterways increases Clean water pollution and minimizing the release of
access to higher water quality hazardous chemicals and materials
The use of solid waste in energy production Goal 7: 7.1 Ensure universal access to affordable
processes supports the provision of a new and Affordable and reliable energy services
affordable source of energy and reliable
energy 7.2 Increase substantially the share of
renewable energy in the global energy mix
An integrated SWM system reduces the individual Goal 11: 11.6 Reduce the adverse per capita
negative environmental impacts of cities Sustainable environmental impact of cities, including
cities and municipal waste management
communities
Full landfill sites could be converted into green Goal 11: 11.7 Provide universal access to safe,
spaces and public spaces Sustainable inclusive, and accessible green and public
cities and spaces
communities
Safe disposal of solid waste and the reduction of Goal 13: 13.2 Integrate climate change measures
open garbage burning and its emitting rates of Climate into national policies, strategies, and
pollution and greenhouse gases are among the action planning
most important measures related to climate change
Reducing pollution resulting from dumping solid Goal 14: 14.1 Prevent and significantly reduce
waste into water bodies, especially plastic, supports Life below marine pollution of all kinds
the chances of preserving the life of marine water
organisms underwater
Environmentally sound management of solid waste Goal 14: 14.3 Minimize and address the impacts of
reduces the spread of carbon dioxide, which Life below ocean acidification
absorbs about a quarter of its emissions by the water
oceans and increases their acidification

The safe disposal of solid waste is one of the Goal 15: 15.1 Ensure the conservation, restoration,
aspects of preserving the ecosystems on Earth Life on land and sustainable use of terrestrial and
inland freshwater ecosystems and their
services

15.9 Integrate ecosystem values into

national and local planning and
development processes
Integrated and sustainable SWM reduces the Goal 15: 15.3 Restore degraded land and strive to
amount of waste and landfill areas, that is, reduction Life on land achieve a land degradation-neutral world
of the need for land utilized for the sanitary burying
of waste

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Appendix IV: Solid Waste Management on SDGs Achievement

Solid Waste Management Program (SWMP)

SDG Target and Indicator Affected
Activity
Economic Impact
Merging the informal SWM system into the formal Goal 8: 8.1 Sustain per capita economic growth in
system ensures an improvement in the informal Decent work accordance with national circumstances
work environment and supports economic growth and
opportunities economic 8.3 Promote development-oriented
growth policies that support productive activities
and decent job creation and encourage the
formalization and growth of micro-, small-,
and medium-sized enterprises
The merge between the formal and informal SWM Goal 10: 10.2 Empower and promote the social and
sectors promotes social and economic inclusion Reduce economic inclusion of all
and reduces inequality in developing countries inequalities
Institutional Mechanisms
SWM within a clear institutional framework that Goal 16: 16.6 Develop effective, accountable, and
supports the organization of the relationship Peace, transparent institutions at all levels
between the central authority and local justice, and
administrations; ensures responsive, inclusive, institutions 16.7 Ensure responsive, inclusive,
participatory, and representative decision-making at participatory, and representative decision-
all levels; and provides tools and methods of making at all levels
transparency, accountability, and monitoring of the
service delivery process
The integrated and sustainable SWM system Goal 17: 17.17 Encourage and promote effective
depends on the participation of multiple parties, Partnerships public, public-private, and civil society
such as the formal private sector, the informal for the goals partnerships
sector, the local community, and donors. This is to
support the system financially and technically

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 Solid Waste Management Program

Appendix V: COA Contact

Appendix V: COA Contact
and Staff Acknowledgments and Staff Acknowledgments

COA Contact Michael L. Racelis (Director IV),

(02) 8952-5700 local 2022 or [email protected];
[email protected]

Dondon P. Marcos (OIC Director III),

(02) 8952-5700 local 2033 or [email protected]

Staff Directors Michael L. Racelis and Roberto D. Mabagos, Jr. provided technical
assistance from planning the audit to developing the report. OIC Director III
Acknowledgments Dondon P. Marcos assisted in the review process. Director Sofia C. Gemora
(Audit Team Supervisor), Janine Joy Ilagan-Valdecantos (Audit Team Leader),
Melody O. Tan, Ria Mae P. Gutierrez, Christopher Alpha R. Bernardo, Marco
Rafael F. Crespo, Engr. Toshio R. Toba Jr., Engr. Ser Louis Paulo P. Cawicaan,
Engr. Gregorio A. Doblas Jr., Engr. Kevin Sherwin B. Aragon, and Victoria R.
Yumang, as citizen partner (All Team Members), conducted the audit and made
key contributions to this report.

Assistant Commissioner Alexander B. Juliano provided invaluable input in

finalizing the report.

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