Comments on revised IER

 Assessment criteria pertain to compliance with regulatory requirements only and provide no
incentive or recognition to facilities implementing programs beyond compliance (e.g. pollution
prevention, waste minimization, environmental management system). It is not fair for facilities
that has maintained minimum compliance with regulatory requirements to receive the same
prestigious rating (green, silver, or gold) as those facilities who implemented programs far
beyond compliance. Additional criteria should be included to achieve rating above green to set
apart those who are committed to protect/preserve the environment beyond regulatory
compliance.
 It will take at least three consecutive years for a facility to achieve a GOLD rating. Given the
resource limitation of EMB, how can it sustain the program to motivate facilities to aim GOLD
rating? Will physical assessment be done for a facility for three consecutive years, or just mere
status reporting by the facilities after the first year of assessment already sufficient for the
succeeding years?
 Issues on Rating System
o Rating is not consistent with other environment modules for equally important
requirements. For Clean Air Act, securing permit (PTO) and complying with its conditions
has maximum score of 15 (5 + 10) and % weight of 10.7% (15/140) for the module.
Meanwhile, for Clean Water Act, securing permit (DP) and comply with its conditions is
given maximum score of 35 (10 + 25) or 19.44% (35/180).
o Rating gives weight on permit and reportorial requirements only and not on actual site
conditions. For module on title 3 (hazardous waste management), if a facility has
complied all requirements but proper storage and labeling it can garner a maximum
score of 100/110 (91%) or a blue rating. However, the potential impact of the improper
storage (e.g. leaks/spill of hazardous waste that cause ground contamination) is not
accounted for. A facility with visible signs or has significant ground contamination due to
hazardous waste spills in its premises can still achieve a very high rating (91%).
o What parameters should be considered in determining if effluent is <20% of standard?
BOD or TSS depending on the nature of wastewater? Or all parameters? How about pH?
o Rating criteria for some parameters are subjective. In the case of solid waste
management, the standard of rating for the criteria “appropriately and properly
maintained” would depend on how strict or lax the assessor is. More detailed guidelines
should be provided to enable an impartial and objective rating.
 Rating criteria failed to include requirement on pollution control officer.
 Will EMB include Clean Water Act module for areas under the jurisdiction of LLDA?
 Implementation of Solid Waste Management is under the jurisdiction of the Local Government.
EMB may not just assess an establishment for a regulation that it has no jurisdiction. Unlike
hazardous waste management, there is no official prescribed guideline issued by EMB on proper
solid waste segregation and storage. Therefore, EMB cannot make a uniform and impartial
assessment for solid waste management without a standard for which a facility should adhere
or follow.

Comments on revised SMR reporting

 Compliance Monitoring Report (CMR) should be integrated as part of the Self Monitoring Report
(SMR) to reduce reports being prepared by the PCO.