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Position Paper of the Paglaum Sa Sugbo (Inc.) on the process of revising the
CLUP (Comprehensive Land Use Plan) of Cebu City, Philippines
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The Paglaum Sa Sugbo (Inc) express our concern on the lack of planning and development controls in
Cebu City that in the recent past has resulted in rapid growth under chaotic land use patterns and a
corresponding worsening of traffic. This untenable urban form of scattered, unpredictable land use
development will require a major effort not only to ameliorate the bottlenecks, improve mobility and
accessibility, reverse further deterioration in the overall urban fabric but also a major rethinking of the
guiding principles for future growth to better the quality of urban life for the residents. The breadth
and scope of our analysis and recommendations is limited by the little information we have access to,
relying mostly on the urgent urban issues of the day that are discussed in the news and mostly as a
synthesis of recent reports on proposed developments for our city. We also recognize the limitations of
a planning approach based on a individual city basis when growth has already created spillovers into a
metropolitan area with several autonomous local governments where development planning is difficult
to coordinate in the absence of a strong and effective metropolitan wide authority.
We present first the background information (context) in Part A, and in Part B, we propose a set of
general principles or development philosophy to guide the formulation of the CLUP (comprehensive
land use plan) for Cebu City.
Part A - Background
1. Recognize the physical limits of Cebu City’s expansion. This reality should be the starting point
for planning and be emphasized to all, not only decision makers, but to business, and the
general public given that the major constraint stems from the fact that:
of the 315 sq. km land area of Cebu City [1] only 8% or 23 square kilometers is flat land
[2]. Given the distinctive topography of the coastal plain that is being urbanized,
growth pressures have exerted a linear north-south configuration that extends beyond
the city’s boundaries.
Yet, according to JICA report, urbanization in Cebu City covers 49.7 sq. km ha or 15.2%
of the total land area of the city. This implies that there is already spillover on “lowland
or hilly terrain”. If the 23 sq. kms. area considered flatland in the city is accurate (this
figure from Cebu City website), that means (49.7-23=) 26.7 sq. km is already in the
lowland or hilly terrain of the city’s land area. According to JICA, of the total urbanized
land, 811 hectares or 8.1 sq. kms, 30.3% of the 26.7 sq.km in the lowland or hilly terrain
is considered hazardous [3].
Since almost all lands suitable for urban use have been developed, according to JICA
there are only 3.65 sq. km of land remaining that is available for future urbanization [3].
Where that suitable land for urban use is located is not specified.
1a) Simply put, there is little or no more room for expansion on the flat lands of the city, unless
a land use inventory proves otherwise that shows further potential “infill” areas. An
examination of the “Composition of Added Area” of Cebu City comparing the periods 1993-
2000 and 2000-2014 based on sophisticated algorithm analysis (on a pixel by pixel basis) of
satellite data in the Atlas of Urban Expansion
1b) Continued pressures for housing close to urban core has led to a proliferation of subdivision
development that has already begun on the flat to lower hilly north barangays on the
northern boundary of Cebu City which is still relatively accessible via Talamban Pit-os Road.
Growth rates overall are relatively high for 2010-15, especially in Barangays Binaliw (4.42%),
Pit-os (3.6%), %), Agsungot (2.8%), Lusaran (2.84%), Mabini (2.83%), and to a lesser extent
in Cambinocot (2%), Pulangbato (1.48%). This should be a source of concern given the
limited number and size of the access roads to these areas. There are no specific arterial
roads existing or planned to provide improved access to these fast growing growth areas.
1c) 9 of the 27 barangays (33.3%) identified to be located in “hilly”terrain have growth rates
(2010-15) over 2.5% . Binaliw (4.42%), Pit-os (3.6%), Taptap (3.57%), Kalunasan (3.15%),
Lusaran (2.84%), Mabini (2.83%), Agsungot (2.8%) %), Busay (2.71%), and Buhisan (2.68%).
1d) CPDO should make detailed inspections and determinations on the patterns of growth in
these hilly barangay areas, i.e., adequacy of service provision and unmet needs (water,
electricity, schools, market places, public transport, cell sites, etc.); densities; conformance
to building regulations, particularly slope provisions according to NIPAS Law [4] and HLURB
guidelines, and the impact of planned/unplanned development on drainage, resource
depletion (vegetative cover) on pollution, exacerbation of geohazards by developments; and
impacts on existing road capacity.
1f) By contrast, growth in the inner core of the city (i.e. flatland, central) is relatively low. Of
the 30 barangays identified to be in the flatland, central portion, 11 barangays (36.7%) have
experienced negative population growth from 2010-15 compared to previous decade, 2000-
2010. Core densities are therefore shrinking in relative terms. This phenomenon may be
due to conversion of former low residential zones and thus, loss of housing stock (R1/R2) to
higher density commercial developments (C1, C2), hotels (high rise) (R3, C1, C2, C3) or
condominiums (R5) considered as private speculative investments that have at present, low
building occupancy. This has to be studied in more detail to understand the actual
transformation process happening in the core. The remaining 19 barangays in the flatland,
central portion have 2010-15 growth rates below 1% to 2.6% with the exception of
Kalubihan (8.54% ) and Pahina, San Nicholas (16.81%).
1g) The 3 flatland, northern portion, Barangays Luz (1.51%), Kasambagan (0.09%), Mabolo
(0.14%) show even much lower growth rates for 2010-15 than the flatland, central a trend
no doubt related to conversion of former low density residential (R1) zoning categories to
hotels (e.g. Mabolo) and commercial development.
1i) Land constraints as expressed in rising land values (we don’t have specific comparative time
series data to support this, but CPDO should have) may be a strong explanatory factor why
of all the big Highly Urbanized Cities (HUC) in Region 7, Central Visayas, Cebu City has the
lowest rate of annual population growth in the last 20 years. Note that in Table 4 below,
increasing scarcity of land (as expressed in rising land values - income data as well as
geographical distribution needed for detailed analysis) has manifested in Cebu City growth
dynamics that already showed much lower rates even during the 2000-2010 growth period
(1.88%). This rate went down even further during the period 2010-2015 (1.21%), indicating
that we have reached the limits of expansion, unless as suggested in the barangay analysis
above, we allow uncontrolled and unplanned urbanization (by default?) in the hilly
barangays particularly in the northern boundary of Cebu City above Pit-os where growth is
relatively high. Even under conditions of controlled development, government must take a
lead in opening up these “greenfield” sites and guide growth. This however will entail
enormous costs in setting up basic infrastructure (e.g., access roads, drainage, reliable water
supply, schools, public markets and other amenities, etc.) as well as mitigating infrastructure
(e.g., slope stabilization/protection) to reduce environmental damage in the event that
NIPAS and HLURB provisions are overlooked. It is doubtful too that the present setup of
CPDO has the required institutional resources to undertake such pro-active development
strategy by the city government.
Source: https://psa.gov.ph/content/population-region-vii-central-visayas-based-2015-census-population
Source: Japan International Cooperation Agency (JICA) (2014), Metro Cebu Development and
Coordination Board (MCDCB) (2014), The Roadmap Study for Sustainable Urban Development, INTERIM
– III REPORT, Volume II: Main Text, December, page 4-24.
2a) “Draft Urban Spatial Plans”(above) indicate land use is to be heavily biased on commercial
development along major arteries: strip development along N. Bacalso, northern part of
V.Rama in Guadalupe, as well as Bantal Rd; as well as cluster commercial development in
Osmena Blvd, Ayala, IT Park in Lahug, Gorordo/Salinas intersection and in the old core area
of Colon/Magallanes. We don’t have detailed information on the depth of this strip
commercial development along these roads (draft plans above appear to encourage strip
development pattern rather than the more efficient cluster development), nor the finer
categorization of both commercial (C1,C2) and residential (R1, R2, R3, R4, R5) areas.
2) We should emphasize however that the crafting of the new CLUP and its realization must at
the same time be cognizant of the need for development of more professional and effective
institutions within the city government. According to JICA:
“Land use planning and control is very weak, and will remain so for a very long time.
Although LGUs are required to enact their own Comprehensive Land Use Plans and
corresponding ordinances, these are considered suggestions rather than prescriptions to be
2c) The DoTC has also recognized the land constraints of Metro Cebu’s urban growth stating
that further growth will result to an “uncomfortable high population density” and therefore
should be managed through:
intensive land-use, for an orderly high dense urbanization;
Large up-hill urbanization should be controlled; and
Urbanization should be directed towards the north and south corridors and Mactan
Island rather than to the hilly and mountainous area [6].
3) Yet, in spite of the absolute population growth trends 2010-15, and their specific geographical
incidence, population growth trends in the past have led to very high density rates in some of
the barangays, particularly in the flatland, central area. Although, I have not been able to
obtain additional income data, it seems likely that high densities are correlated with lower
income barangays that would indicate a clear pattern of segregation of poor communities in the
city, and thus, glaring urban spatial inequality. Therefore, a planned revitalization (urban
renewal) is needed in these barangays to improve the well being of these communities. We
recommend these areas should be rezoned to reflect higher densities, allow mixed use and FAR
(floor area ratio) with appropriate (tax) incentives in order to encourage the building of mixed
use medium to high rises in these areas with special emphasis on those areas traversed by the
BRT and planned mass transit systems.
(NOTE: data for the two tables below were obtained from Dr. Connie Gultiano of the Office of
Population Studies, University of San Carlos Talamban, (using PSA data). Density per hectare
(persons/ha.) values are translated to per square kilometer. The ranking of Dhaka as number
one most dense city comes from http://www.demographia.com/db-worldua.pdf (2016
edition). In the 2017 edition (same link) Table 3 BUILT-UP URBAN AREAS BY URBAN
POPULATION DENSITY, page 53, the population density of Bangladesh (rank #1) has increased to
45,700 per sq. km.)
4) By 2040, which is the approximate end of the effectivity of the new CLUP, there will be an
238,000 more people that will be added to Cebu City based on projected population by 2020
(see Table 6.2.15 below from the JICA report). This should be the basis for estimating the
amount, location and distribution of higher density areas R3 and above in consideration of road
capacity of traffic and mass transit alignments. This is done by working back using assumptions
of projected household sizes by income, housing floor area standards for low and middle income
households, and building height limits in order to reclassify existing lower density zoned
residential areas. It is clear that the meager amount of land available for future urbanization of
only 3.65 sq. km. as mentioned in (1) is insufficient for these additional populations especially if
4a. Projecting land use needs in the next 10 years will require some idea of economic
development strategies to be pursued. Will Cebu City continue to rely on the BPO and KPO
sectors? Please consult with CIPO (Cebu Investment Promotion Office) what sectors they
plan to promote and why, and whether their assumptions are realistic that the new
population growth (across all labor segments) will be absorbed, how much is due to local
growth in employment demand and how much due to in-migration? What is the projected
housing supply stock required (both owner owned and for rent)?
Source: Japan International Cooperation Agency (JICA) and Metro Cebu Development and
Coordination Board (MCDCB) (2014), The Roadmap Study for Sustainable Urban Development in
Metro Cebu, INTERIM – III REPORT, Volume II: Main Text, December, page 6-15.
5) A key input to the planning of the new CLUP for Cebu City is to consider the planned and
committed mass transit projects. There is the soon to be implemented BRT. Its loan has already
been approved and signed. To date the BRT is the only project where the fix route alignment is
known, and recent information has indicated the specific locations of its stations.
Source: Power Point Presentation File: Cebu Bus Rapid Transit, Stakeholders Consultation, Department
of Transportation and Communications, TransCebu, kunhwa Engineering and Consulting, May 2017
The focus on higher density land use for Cebu City based on the previous background above of
population growth rates and densities would suggest that a Transit Oriented Development (TOD)
would be the most logical alternative to reduce job-housing imbalance and adapt to the serious
land constraints of the city unless the city is determinedly able to pursue a more selective
growth or slower growth strategy. The TOD concept will be reflected as mixed use, high density
development (residential, commercial, employment) in the immediate surroundings of mass
transit stations. However, in addition to the BRT, we are aware of more recent studies: an LRT
(by Singaporean consultants that is preferred by Presidential Assistant Dino and his announced
preference to cancel BRT) which appear to follow the alignment of the JICA proposed MRT
Central Line (Talisay = Consolacion) along N.Bacalso within Cebu City and following the
provincial highway.
There is also a proposed MRT Mactan Line (Cebu City–Lapu-Lapu City as well as an AGT-CML
line. The Automated Guideway Transit (AGT) is a medium-capacity LRT system suitable for a
ridership of 5,000–15,000 passengers/hour/direction that will operate on the route between
Cebu City center, Mandaue City center and MCIA. We, do not as yet know the actual locations
of stations of the LRT, nor the route of the Mactan AGT, nor more importantly whether the BRT
project will be cancelled or not, in either case, it will be more difficult to determine the
locational specifics of a land use strategy based on TOD. See below.
Source: JAPAN INTERNATIONAL COOPERATION AGENCY (JICA), METRO CEBU DEVELOPMENT AND
COORDINATION BOARD (MCDCB) (2015), THE ROADMAP STUDY FOR SUSTAINABLE URBAN
DEVELOPMENT IN METRO CEBU, FINAL REPORT, MAIN TEXT, ALMEC Corporation, Oriental Consultants
Global Co., Ltd., June, page. II-51.
Source: JAPAN INTERNATIONAL COOPERATION AGENCY (JICA), METRO CEBU DEVELOPMENT AND COORDINATION BOARD
(MCDCB) (2015), THE ROADMAP STUDY FOR SUSTAINABLE URBAN DEVELOPMENT IN METRO CEBU, FINAL REPORT, MAIN
TEXT, ALMEC Corporation, Oriental Consultants Global Co., Ltd., June, page. II-53.
1) In recognition of the physical limits of Cebu City’s expansion, and the need to (strictly) abide by
the rules and provisions of NIPAS, HLURB and DENR that constrains further expansion to our
hilly lands and ECAs (environmentally critical areas), the only way for Cebu City to accommodate
future growth is through densification or vertical growth. This means a general reclassification
of permissible density standards for all types of residential uses. In other words, at the zoning
ordinance level planning, there should be consideration on how to encourage land consolidation
to build, multi-family dwellings as well as revise the standards for FAR and setbacks for single
unconsolidated lot sizes. To improve further the well being of existing highly dense barangays
is the need to widen the streets to minimum fire safety standards to allow access of fire fighting
vehicles in case of an emergency.
1a. This should also apply to areas surrounding institutional areas such as schools and
commercial areas to encourage or induce the supply of affordable rental housing for
students and workers.
1b. Higher densities should also be encouraged in new housing subdivisions due to land
scarcity but should only be allowed if access roads are commensurate to the increase
traffic flows in case there are no mass transit routes planned in the area.
1c. For this reason we recommend that no warehousing land uses should be allowed in
Cebu City, much like industrial and manufacturing land uses have already been
prohibited in the past.
1d. We recommend that no new institutional areas be allowed in Cebu City (such as
universities, hospitals). However, vertical expansion will be allowed for existing
institutional uses based on government institutional guidelines (e.g. DepEd) of open and
parking spaces.
1e. We recommend that no new high density commercial areas (C3) such as malls be
allowed in Cebu City. Only mixed use developments in principle will be allowed.
2. A key component for increased densities is the construction of mass transit system(s) to service
these higher density areas. Absent that, densification will only lead to an intolerable traffic
congestion that will increasingly worsen over time leading to system gridlocks, and a certain
irreversible deterioration of the overall quality of life and attractiveness of the city. Given the
implementation of the BRT, and in the future, other forms of mass transit modes according to
recent studies and the JICA plan (June 2015) the new CLUP must explicitly commit itself to a TOD
(transit oriented development) strategy in the “Urban Core Development zone”. Therefore,
comparatively higher densities should be allowed along the routes of these mass transit lines,
BRT and planned. The difficulty of specifying location of planned TOD clusters with higher
Land in SRP must be allocated for high density socialized housing incorporated in a TOD
cluster as well as public amenities such as parks.
i. 3) Commercial strip development (C1, C2) along arterial roads should be controlled by clustering
(as in #2 above) with areas designated for mixed use development and by changing standards
for frontage lengths to reduce the problem of frequent curb cuts that give rise to the intractable
problem of left turn conflicts at entrances/exits to these establishments.
5) Further reclamation for land expansion of Cebu City should be avoided for reasons of negative
ecological and environmental impacts, as well as stop the destructive practice of quarrying hills
for filling materials in reclamation.
6) The lack of planning and strong development controls has resulted not only in sprawl but also
also random growth pattern of high density development and commercial centers that result in
difficulty of predicting system wide traffic impacts. This has led to severe congestion of a limited
number of arterial roads that are not suited for high density development. As for roads where
high rises have already been constructed, we recommend that no new high rises should be
allowed to be constructed unless new building height limits are in place.
7) As for the large number of informal settlers (an estimated 250,000 underprivileged people, or
41,000 families based on the 2010 Census of Population and Housing conducted by the National
Statistics Office, citing an average household size of 6.8 members for Region 7 living in danger
Paglaum sa Sugbo Inc. July 3, 2017
zone areas like riverbanks, creeks and landslide-prone areas, roads, parks and other public
places)[8], only a low to medium rise housing strategy than a horizontal housing strategy will be
able to accommodate them where basic public amenities will be provided. We do not know
what lands are available (and where) for land swapping with other entities such as the provincial
government or purchase in other LGUs, therefore it is difficult to recommend the location of
socialized housing except that it should be as close as possible to their original locations
through some kind of land sharing deal with the landowners (based on other countries’
experience). All relocation sites must be adequately prepared with the required minimum
infrastructure for human settlements as well as social services.
8) As for agricultural lands, we do not have sufficient information on the types of land within the
city boundaries, especially in mountain barangays (or what has now become “peri-urban”
areas) that are being used for agricultural production, nor the types of products being produced.
A survey of land suitablity for such uses should be made before a clear delineation of
agricultural land use can be made. Furthermore, in order to protect our watersheds, lands in
our mountain barangays according to NIPAS law provisions regarding slope and hazardous areas
must be classified as protected land such that even if it were classified as agriculture, conversion
to other urban uses would be strictly prohibited.
Urbanization: It covers 4,968 ha or 15.2% of the total territorial lands (32,610 ha). Among the
urbanized lands, 811 ha. is considered hazardous (hilly terrain or lowland). Since almost all lands
suitable for urban use have been developed, the remaining available lands for future urbanization
are merely 365 ha.
Source: Japan International Cooperation Agency (JICA) (2014), Metro Cebu Development and
Coordination Board (MCDCB) (2014), The Roadmap Study for Sustainable Urban Development,
INTERIM – III REPORT, Volume II: Main Text, December, page 4-24.
Cebu City has 76.3 % of its land covered under the NIPAS or Nationally Integrated Protected Areas
System. These include the Mananga, Kotkot and Lusaran watersheds, the Central Cebu National
Twenty-three of the city’s 80 barangays are totally or partially located in the four watershed areas,
now declared as Central Cebu Protected Landscape (CCPL). (see Protected Area Management Zone
Map)
(Text from the Cebu City, Philippines Profile published by the City Planning and Development
Office ©2007. All maps provided by the Cebu City Government GIS Center © 2010.)
Source: https://www.cebucity.gov.ph/index.php/home-new/about-cebu-city
[5] 5.66 (c) Land use planning and control is very weak, and will remain so for a very long time.
Although LGUs are required to enact their own Comprehensive Land Use Plans and corresponding
ordinances, these are considered suggestions rather than prescriptions to be followed seriously. A
large property developer can always get an exemption from zoning ordinance, if that is an obstacle.
Thus, one can see the phenomenon of high-rise high-density buildings accessed by narrow public
roads designed for low-density dwellings. On the other hand, the many poor who cannot afford
decent housing locate where they can regardless of zoning or building restrictions. Transport and
urban planners often assume (or wish) that land use controls would minimize road-side frictions and
concentrate around transit stations–something nearly impossible to effect in the Philippines.
Source: Japan International Cooperation Agency (JICA) (2014), Metro Cebu Development and
Coordination Board (MCDCB) (2014), The Roadmap Study for Sustainable Urban Development,
INTERIM – III REPORT, Volume II: Main Text, December, Page 5-22 to 5-23
[7] “LRT to solve Cebu’s traffic woes?”, May 13, 2017, Sunstar Cebu,
http://www.sunstar.com.ph/cebu/local-news/2017/05/14/lrt-solve-cebus-traffic-woes-541746
[8] “250T settlers for relocation”, The Freeman, June 10, 2015, http://www.philstar.com/cebu-
news/2015/06/10/1464260/250t-settlers-relocation