DENR decision unscientific, haphazard, and fraught with technical loopholes’ Experts Find No Scientific Basis for Rapu-Rapu Mine Re-opening


A four-person panel of independent experts recently scrutinized the basis of the Department of Environment and Natural Resources (DENR’s) for allowing the resumption of full commercial operations of the Lafayette mine in Rapu-Rapu, Albay and found it “unscientific, haphazard, and fraught with technical loopholes” at the very least.

The panel was convened last February by the Center for Environmental Concerns-Philippines (CEC-Phils) and is composed by four scientific and environmental experts who reviewed and critiqued the reports that have informed the DENR’s decision to reopen the RRPI mine to full commercial operations: Dr. Carlito R. Barril, retired Professor of Chemistry at University of the Philippines (UP) in Los Banos, mining engineer Efren Favila, Dr. Emelina G. Regis, Director for the Institute for Environmental Conservation and Research (INECAR) of the Ateneo de Naga University and UP National Institute for Geological Sciences research associate and geologist Ricarido M. Saturay, Jr.

During a forum so-sponsored by CEC-Phils, nationwide scientists organization AGHAM, and Defend Patrimony last March 22, the four experts identified major deficiencies and inadequate action on four respective areas of immediate concern, all of which were not considered in the DENR evaluation.

These are:

a. Acid Mine Drainage (Dr. Barril, et al)

b. Biological Effects of Toxic Heavy metals (Dr. Regis)

c. Geological Hazards (Mr. Saturay)

d. Mine Structures (Engr. Favila)

The four issued separate reviews of various DENR documents evaluating the test runs. Dr. Barril reviewed the Final Report of Carlos Primo c. David and Rustica G. Romero on The Evaluation of RRPI’s Acid Mine Drainage (AMD) Abatement And Control Strategies. Mr. Saturay reviewed the 2006 Test Run of the Rapu-Rapu Polymetallic Project. Dr. Regis reviewed the Evaluation Report of the Mines and Geosciences Bureau (MGB), on the Rapu-Rapu Polymetallic Project under the test run conditions (dated Dec. 19, 2006).

These studies formed the basis for Environment Sec. Angelo Reyes to issue a Permanent Lifting Order (PLO) last February, despite vehement objections from Rapu-Rapu folk, Church leaders, international non-government organizations (NGOs) and environmental and peoples organizations.

CEC-Philippines convened the panel shortly after the DENR issued the PLO based on the test run evaluation this February, and refused to approve requests from NGOs and people’s organizations to launch an independent probe in the mine site.


The experts noted various technical inconsistencies as well as conceptual and methodological flaws in the studies.

For instance, Dr. Barril, who reviewed Dr. David’s final report in terms of their objective, study design, and how the study was carried out, reported, and discussed, pointed out that there were “haphazard, superficial and indiscriminate AMD prediction tests and in-situ measurements, limited monitoring scope, sweeping concluding statements that were inconsistent with the data presented, and premature and ill-advised recommendations”.

“We find the study made by Dr. David and his partner as unscientific, carried out haphazardly and superficially, and fraught with technical loopholes and shortcomings, so much so, that the results generated are not only so limited but also of doubtful and unreliable quality,” Dr. Barril said.

Saturay noted that the test run evaluations also failed to take into account the geological factors that may adversely affect land areas surrounding the mine site and water supply systems, while Dr. Regis added that the studies do not take into account the mining operation’s projected effects on existing bio-physical conditions in the small island’s ecosystem.

Dr. Barril was taken aback at the lack of technical expertise that the study displayed.

Baka matapon ko lang sa basurahan ang study na ito. Nakakahiya,” (I would have thrown this study into the trash can. It’s shameful) he commented during the forum.

Acid Mine Drainage: the biggest threat

All the experts concluded that—contrary to the reports—Lafayette to date lacks the capability to effectively manage, abate, and remediate the damage caused by Acid Mine Drainage (AMD) in Rapu-Rapu.

Dr. Barril took note of several deficiencies in the report, among these, the “lack of a clear study design, lack of basic principles, absence of AMD’s description and control strategies, absence of an evaluation of AMD control strategies, a faulty and indiscriminate AMD prediction study, and the absence of any calculations of potential acid production”.

He warned of the tendency towards “cyclic acceleration” of AMD. “Once AMD starts, hindi na ito mapipigilan dahil yung mismong produkto nito ay nagiging catalyst,” (It cannot be stopped because the product becomes the catalyst.) he said.

Dr. Barril also warned that millions of tons of acid are expected to be generated in the mine as a result of AMD.

“Based on the results of the static tests, one (1) kilogram of copper ore can potentially generate more than 1 kilogram of acid,” Dr. Barril said. And yet the studies recommended that costly lime dosing technology and open limestone drains to manage and neutralize AMD be discouraged.

AMD occurring in the open-pit mine was also overlooked, Dr. Barril said. This is a dangerous development as the pit will go down below the water table, he said. Mr. Saturay estimated that the mine pit is expected to go as far down as 50 meters below the sea level.

Acid and toxic heavy metals may reach the groundwater through cracks in the earth caused by strong dynamite blasting, he added.

Toxic threats to life a “criminal offense”

Next to AMD, Dr. Regis stressed that the unmonitored and unregulated presence of physico-chemical and trace metals (particularly toxic heavy metals) in the mining-affected areas, waterways, and ground has an adverse effect on marine species and will continue to pose a threat to marine and human life in the small island ecosystem.

“The study failed to consider that AMD dissolves metals lodged in the rock, such as cadmium, zinc, copper, most of which pose health hazards to people and biota (living organisms). For example, cadium, which is very high already even in their monitoring, is a carcinogenic substance,” Dr. Barril explained. Dr. Regis agreed, noting that the monitoring and evaluation by the DENR was only concerned about water testing and leaks, without including the possibility of heavy metal contamination of soil and sediments.

The fish kills, diseases affecting the community, and mysterious deaths among the island’s marine mammals are expected to dramatically rise once the heavy metals in AMD takes its toll on the ecosystem. However, the DENR has failed to address this problem, Dr. Regis said.

“The DENR said that the documented deaths of marine animals could be addressed by monitoring the water until its pH level normalizes. It also stated that the normal condition of pH is achieved through lime dosing. But the problem is that lime dosing only neutralizes acid. It does not neutralize the heavy metals in water which causes toxicity and contamination,” Dr. Regis explained.

Dr. Regis demonstrated the danger of heavy metal contamination through sampling bio-indicators, or living organisms that respond to particular environmental conditions. She collected field samples from metal-affected weeds and grasses in Brgy. Pagcolbon (a mining-affected area) and other Rapu-Rapu communities located far away from the mine site.

An examination of their cell structures revealed that metal-contaminated biota contained significantly less starch and had their structures altered. “Wala nang nutrients ang kinakain ng mga livestock, tulad ng baka, sa mining-affected areas,” (There were no more nutrients in the grass eaten by livestock in mining-affected areas.) Dr. Regis said.

The heavy metals present in mine tailings and AMD, such as arsenic, cadmium, chromium, copper, lead, and zinc, can be threatening to life once humans and biota are exposed to it in large amounts, Dr. Regis said.

Some effects of toxic heavy metals on the peoples’ health include increased risk for cancer, kidney pneumonitis, osteomalaise, and hydrocephaly. While chromium, copper and zinc are essential to the body in small doses, these are poisonous in large doses, Dr. Regis said.

Dr. Regis denounced the mine reopening as a “criminal offense” because of the long-term fatal effects that it would cause to human life and to the ecosystem of Rapu-Rapu.

Dr. Regis also disputed the DENR’s claims that the Sorsogon fishkills and other fish kill incidents near the mining site could not be attributed to the Rapu-Rapu mine spill.

“Sorsogon is only 12 kilometers away from the mine site. In the Guimaras oil spill, debris flowed as far as 200 kilometers away due to the habagat (southwest winds) winds,” she said, saying that the mine spill has brought about fish kills, loss of livelihood, loss of potential tourists, and the diseases as well. Contaminated tailings, mud, and silt flowing out to sea are killing Rapu-Rapu’s coral reefs, she added.

Dr. Regis and her team also experienced repeated harassment by fully-armed men accompanied by attack dogs and agents in civilian clothing while conducting the study. They reportedly refused to let Dr. Regis’ team any closer to the mine site.

When they were collecting sea grasses, she recalled, the team also experienced harassment from guards on two patrol boats and surveillance from suspicious-looking “fishermen”.

Nag-fifishing daw sila…kahit umaalon,” (They said they were fishing, even though the waves were strong at that time) Dr. Regis commented.

A Disaster Waiting to Happen

Meanwhile, geologist Saturay and mining engineer Favila warned of the potential disaster that Rapu-Rapu would face if inadequate mine infrastructures and geologic hazards were combined. Engr. Favila said that the RRPI mine lacks important emergency infrastructures that are crucial to preventing another disastrous mine spill. The studies also failed to consider geological factors that may adversely affect land areas surrounding the mine site and water supply systems, Mr. Saturay said.

Saturay warned that Rapu-Rapu island’s land composition, steep slopes, and rainy climate make it
naturally predisposed to landslides. This threshold would be further affected and significantly lowered by the massive earth movements caused by the simultaneous dynamite-blasting and open-pit mining.

“Mining is a catastrophic geomorphic event. Mabilis at malakihan ang pagbabago nito sa kalupaan. Malapit ito sa bingit ng pagguho ng mga kalupaan. Anumang idadagdag sa salik sa pagguho ay malamang hahantong sa higit pa o paglapit pa sa bingit ng pagguho, o aktual na pagguho,” (It could swiftly create major changes in the land. As it is, the land here is already near its landslide threshold. Any additional factor brings it closer to the threshold or may actually trigger a landslide.) Saturay warned.

Saturay also noted that studies on slope stability were conducted from rock samples inside the mine pit. There were, however, no studies conducted from samples outside the mine pit, where the mining-affected communities are located and would be primarily affected in the event of any landslide-induced tragedy.

Saturay also expressed concern over the effects of toxic metal contamination seeping into Rapu-Rapu’s limited freshwater supply.

Engr. Favila warned that the mine still lacks emergency facilities that were crucial in preventing more mine spills, such as a spillway and division wall.

“When RRPI started to produce ores, it has no environmental infrastructures in place,” Engr. Favila said, “The RRPI management failed to ensure the construction of emergency infrastructures for the tailings pond management system and moreover, resorted to cost-cutting in the use of neutralizing reagents used to treat cyanide.”

Engr. Favila attributed the lack of crucial infrastructure to negligence on the part of the company and the DENR’s monitoring mechanisms.

AMD will also cause the structural strength of the embankment structure to deteriorate, he added, increasing the risk of breakage.

Engr. Favila warned that previous mining tragedies, such as the Marcopper mine spill which killed the Boac river in Marinduque, were also brought about by the lack of crucial infrastructures.

Cancel PLO, experts urge

On the basis of the existing studies’ technical flaws, methodological shortcomings and inconclusive results, the team strongly recommended a repeat of the DENR study and the pursuit of more detailed studies on the RRPI’s mining operation in Rapu-Rapu.

“The results of the study are inconclusive and unreliable and should not have been used as one of the basis for lifting the suspension order,” Dr. Barril said.

Dapat mag-aral muna ang [DENR]. Wala silang karapatang gumawa ng desisyon dahil wala silang alam,” Dr. Regis said of the issuance of the PLO. (The DENR should study it first. They have no right to issue a decision because they do not know anything about the issue).

“The deficiencies noted by the experts indicate how RRPI and the DENR rushed the opening of the Lafayette mine in Rapu-Rapu. This undue haste to open the mine to commercial operations has put the lives of the island’s residents and its marine and terrestrial ecosystems into more danger than before,” Kalikasan-PNE National Coordinator Clemente Bautista, Jr. said.

Bautista stressed that “the unremediated deficiencies and unresolved problems with the mine (such as the lack of emergency infrastructure noted by Engr. Favila) practically guarantees another mine spill”.

“The people of Rapu-rapu are living next to an environmental time bomb with the mine’s reopening and with the onset of AMD. We could be dealing with another environmental disaster as large if not larger than the Marcopper tragedy in Marinduque in the mid-90s,” Bautista warned.

The experts also recommended further study into the issue. Dr. Barril recommended a repeat of the previous studies done, this time to be undertaken by a technically-competent team.

“[More] detailed studies may be exhaustive and expensive but it is a justified pre-requisite for mining in a small tropical island with a significant population depending on the island’s limited resources,” Saturay added.

Dr. Regis also urged the RRPI’s remediation of the Acid Mine Drainage now seen in waterways in mining-affected areas. He also advised concerned citizens to demand that company officials take responsibility and be held accountable for any mining-related untoward incidents that may occur.

“No mining must ever be allowed in Rapu-Rapu. The government must also rehabilitate the degraded ecosystems, because they issued the PLO,” Dr. Regis said. (

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