1. Rapu-Rapu is an island ecosystem which has steep slopes, is located within a typhoon path and has Type II climate: no dry season with very pronounce wet period from November to January. Its steep slopes facilitate the movement of contaminated water downhill towards the sea. Any pollutant generated by mining operation will end up in Albay Gulf and surrounding areas.
   
   
2. Its largest and longest river is Binosawan River which is located near the mining area. Mining activities uses a lot of fresh water, thus will not only deplete this resource and deprive local communities of their need for this limited resource, but also pollute scarce water supply. There are three barangays in the immediate impact area: Malobago, Pagcolbon and Binosawan.
   
   
3. The island comprised of iron sulfide rocks capable of generating acid mine drainage (AMD) when exposed to oxygen, water and sulfide bacteria. There is no available remediation world wide in the present technology (Environmental Management Council of British Columbia) since this is only in the experimental stage. We must not allow the Philippines to be the testing site considering the fragility of our island ecosystems. AMD can go on and on for hundreds and thousands of years until all sulfide rocks have been dissolved by acid.
   
   
4. AMD dissolves heavy metals such as arsenic, cadmium and lead associated with gold, silver, copper and zinc. These metals are carried by acidic water into the sea and contaminate Albay Gulf and its fishery resources. A brown seaweed (Padina sp.) has already shown high levels of arsenic contamination (Regis, et al, 2001). These metals, once they have accumulated above critical levels, can kill fishes and also cause human diseases such as cancer, leukemia, mental disorder, bone deformation among others.
   
   
5. Heavy metals do not disappear even if acid water is neutralized (Jones, 1998). They are still deposited in surface soil and carried by water into the sea when exposed and loosened by mining. Heavy metals transfer from tiny plankton and aquatic plants to animals such as mollusks and fishes through the food chain/pyramid where they are concentrated in top carnivores. Examples are Tuna and Butanding. If this happens, Some communities in Sorsogon and Camarines Sur will be contaminated with heavy metals through the food chain. Organisms important to ecotourism such as Butanding, a whale shark, will also be affected.
   
   
6. Rapu-Rapu is part of the Marine Conservation Priority Areas selected by scientists (Ong, Afuang and Rosell-Ambal, 2002). This project was proposed by the DENR in 1997. The participating agencies are: Conservation International, DENR-PAWB, BCP-UPCIDS and FPE. Partners and donors are PCARRD, ESSC, WCSP. PNM, CABS, Haribon, PCAMRD, CEPF, USAID, ADB, UNDP, ARCBC, SIEMENS, FPCI, FPHC and Intel Corp. Priority classification of this site and its adjacent areas is extremely high. Indicators of the unique biodiversity of Rapu-Rapu (Hixbar mining area) which might be very important in the future is shown in the INECAR study (Regis, et al., 2001)
   
   
7. Rapu-Rapu is also included in specific conservation priority areas for Reef fishes and Conservation priority area for whale sharks, elasmobranchs, and turtles. The participating agencies that determined these and their donors are the same as those mentioned earlier.
   
   
8. Contrary to claims of mining companies of uplifting poverty, mining can actually cause poverty of local communities due to destruction of the environment resulting to loss of productivity of agricultural land (Regis et al, 2001) and fisheries of aquatic/marine resources. One of the many examples in the Philippines is Sta. Barbara just three kilometers from the Lafayette mining site. The open pit of Hixbar mining company was abandoned 27 years ago, yet no vegetation has colonized the place to this day due to heavy metal pollution and removal/erosion of whatever top soil has started to develop.
   
   
9. The tailings dam to be constructed by Lafayette has an impounding capacity of 5 million metric tons. (ECC Provision No. 23) while the open pit has the production capacity of one million metric tons per annum (ECC Provision No. 2). However, only a small fraction of the precious metals will be generated from the ores. Mine wastes include not only waste rocks but also overburden soil and rocks. Lafayette is allowed to mine the area with starting date of operation but no termination date. Thus, tailings dam will overflow, including erosion of loosened overburden rocks and soil adding to the contamination of Albay Gulf and some parts of Lagonoy Gulf.
   
   
10. Contrary to the claim of Mr. Watt of Lafayette that they have already answered the issues I raised, this company was not able to answer the major issues I pointed out: These are: a) iron sulfide rock that generates Acid Mine Drainage (AMD) since they could not even demonstrate how to remediate AMD; b) rainy nature of the place aside from being within a typhoon path that facilitates movement of pollutants towards the sea; c) steep slopes that facilitates movement of water and erosion of loosened soil during heavy rainfall; d) fragile island ecosystem that houses rich biodiversity of terrestrial and aquatic/marine life; e) contamination of Albay Gulf.
    
    
11. Mining Ombudsman Annual Report 2001-2002 of Oxfam Community Aid Abroad based in Victoria Australia specifically states Precautionary Principle to include: “…mining of high sulfide ore-bodies should only proceed if adequate steps have been taken to prevent acid mine drainage, and if this is impossible, mining should not proceed, given the permanent environmental implications” (p. 62).
    
    
12. Sustainable development means “a development that meets the needs of the present generation without compromising the ability of future generations to also meet their needs” (Brundtland, 1987). Mining is extractive and pollutive, thus, given the condition of Rapu-Rapu, there is no way in which it can restore the productivity of the land and water once it has started.
    
    
    It is within this premise that the INECAR recommends no mining in Rapu-Rapu by any individual nor mining company. The present condition and capabilities of the mining company (Lafayette or others) cannot warrant safe, clean and sustainable mining in island ecosystems.

Prepared by:

Emelina G. Regis, Ph.D.
Director
February 9, 2003

References:

1. Brundtland Report 1987: “Our Common Future”. http://www.doc.mmu.ac.uk/arc/eae/Sustainability/Older/Bundtland_Report.html
2. Environmental Compliance Certificate (ECC) granted to Lafayette Philippines, Inc.
3. Environmental Management Council of British Columbia http://www/miningwatch.org/emcbc/library/amd_water.htm
4. Jones, David. 1998. Treatment: Dealing with an Acid Problem. Australian Minerals and Energy Environment Foundation.
5. Mining Ombudsman Annual Report 2001-2002 of Oxfam Community Aid Abroad based in Victoria Australia
6. Ong, Afuang and Rosell-Ambal, 2002. Philippine Biodiversity Conservation Priorities: A second iteration of the National Biodiversity Strategy and Action Plan (NBSAP). DENR-PAWB, Conservation International Philippines, Biodiversity Conservation Program (BCP)- UP Center for Integrative and Development Studies (UPCIDS) and the Foundation for the Philippine Environment (FPE). Quezon City, Philippines
7. Regis, Emelina G., Irma Medrano, Ma. Aurora Azurin-Conde and Melanio Regis. 2001. Some Impacts of Mining on the Island Ecosystem of Rapu-Rapu, Province of Albay. Gibon. Vol. 1 No. 1 pp. 43-77.