Case Study by Farah Sevilla, Alyansa Tigil Mina

Palawan: Mining and Biodiversity

Executive Summary

Palawan is a biodiversity hotspot in the Philippines: its abundant forest and rich
cultural heritage are the main reasons for exempting it from mining. Few places on
earth can match the distinction of the province, home to seven protected areas, a
declared “Game Refuge and Bird Sanctuary” since 1967, and a “Mangrove Reserve”
since 1981. UNESCO declared the whole Province a Man and Biosphere Reserve in
1990. Included are two World Heritage Sites: The Tubbataha Reef Marine Park and
the Puerto Princesa Subterranean River National Park.

The expansive reserves of metal ores particularly nickel and chromite, which lay
underneath old growth forests, attracts mining investments into the province. The
354 approved mining applications all over Palawan constitute a major threat to
Palawan with extensive remaining forest cover and related biodiversity.

Palaweños fears that damage to Palawan’s biodiversity will become irreparable if

mining increases the threat to the ecosystem and to a booming eco-tourism industry
of the province. Many feel that the costs of mining far outweigh its benefits.

Dr. Gerry Ortega, an environmental advocate and broadcast journalist who was very
vocal against mining in Palawan was killed on January 24, 2011 after his morning
radio broadcast. He has been receiving death threats due to his strong opposition to
mining and exposed bribery in the government in endorsing of mining through his
radio program “Ramatak” over DWAR, a local affiliate of Radyo Mo nationwide.

The Philippines has suffered many disastrous environmental impacts from mining
including the Marinduque/Boac River mining disaster in 1996, recurrent pollution
problems caused by the Atlas mine in Toledo City, Cebu, and the Rapu-rapu mine
tailings spills in Albay in 2005 were among the many tragedies which offer lessons of
the enormous human and environmental costs brought by mining.

These factors should require the Philippine government to exercise extreme caution
in authorizing mining operations in Palawan. Social awareness of this problem is of
widespread and government actions to prevent damage to the environment have led
to the enactment of laws such as the Republic Act No. 7611 otherwise known as the
Strategic Environment Plan for Palawan Act or SEP Law directed towards the
prevention of activities and events that may adversely affect the environmental
sustainability of the province. A resolution passed in November 2008 by the
Provincial Board secures a 25-year moratorium on small-scale mining in Palawan.
However, this is not enough to prevent large-scale mining corporations from
plundering the Island.

Here the picture is clear that people appears to be overwhelmingly made worse off
because of environmental degradation and human rights violations attendant to
mining operations in the province. Government statistics attest that only a small

1|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

fraction are benefitting from the employment generated by the mining operations 1
and the occasional company-sponsored community outreach programs. As things
stand, the economic benefits of mining in Palawan remain so unclear, with adverse
effects appearing to be at least as likely as clear-cut beneficial ones, it is important to
focus on the impact of mining in the local communities and on the environment.

The Island Province of Palawan

Palawan is the largest province in the Philippines with a total land area is 1,489,655
hectares; 690,000 hectares of which are terrestrial forest and 44,500 hectares are
mangrove forests. It is located 7º47' and 12º22' north latitude and 117º00' and
119º51' east longitude, generally bounded by the South China Sea to the northwest
and by the Sulu Sea to the east. The main island is nearly 278 miles long (about 435
kilometers) and has a width of forty kilometers at its widest part. It is surrounded by
1,767 islands and islets. Its steep mountainous terrain and the very thin topsoil,
makes the island prone to erosion and even landslide.

Palawan has a population of approximately 892,600 in 2007 2 distributed in its

twenty three municipalities and Puerto Princesa City where almost 20 percent are
indigenous peoples belonging to three main ethnic groups: Tagbanua, Pala’wan,
Batak (on the main island) and Molbog (Balabac island). The primary source of
livelihood and income are fishing, agriculture, collection of non-timber forest
products (NTFPs) and tourism. Logging was also once a thriving industry in the
province. Meanwhile, the province is also known for its rich natural gas reserves- the
Malampaya gas field located 80km off the coast of Palawan with capacity of
2,700MW and the Galoc oil field.

Palawan: a biodiversity hotspot

Palawan is home to endemic species—both flora and fauna that cannot be found
anywhere else in the world. It is home to 30% of the country’s coral reefs, has 17 key
biodiversity areas3 (KBAs), and 8 declared protected areas. The province is host to
one of the areas in the country with intact old growth forests. 4

Critical Ecosystem Partnership Fund Identification of Biodiversity Hotspot recorded

that Palawan comprises the following biodiversity:

1
Based on the CSO Assessment of Medium Term Philippine Development Plan (MTPDP) for 2004-2010 in
mining, as of 2008, the government reported that only 13,462 jobs were created by the mining industry or a mere
5.36% of its intended projection of 239,000 indirect and direct employment.
2
Statistics from National Statistics Office website http://www.census.gov.ph/data/census2007/index.html date
accessed: April 4, 2011.
3
Key Biodiversity Areas are “sites of global significance for biodiversity conservation, identified using globally
standard criteria and thresholds, based on the needs of biodiversity requiring safeguard at the site scale.“ They
cover 70% of the world’s natural resources. (Ruth Grace Ambal, Conservation International-Philippines)
4
2000 Data from HARIBON Foundation 2003 based on ESSC 1999 cited there are only 18.3% total forest cover
in the Philippines and only 3% remaining old growth forest.

2|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

 15 lakes, 42 ponds, 44 waterfalls, 72 natural springs, 9 mineral springs, 28

principal rivers, 43 streams and 165 creeks identified as potential sources of
water for domestic consumption and irrigation;
 13 out of the 16 sea grasses that can be found in the country;
 42,500 hectares of mangrove forests, having 31 species and 90% of the known
mangrove species in the country;
 approximately 690,000 hectares of terrestrial forest;
 8 of the 11 amphibians endemic to the Philippines are found only in Palawan;
 279 species of birds are found in Palawan and 27 are endemic to the country;
 15 of the 25 marine mammals in the Philippines are found in Palawan;
 58 species of terrestrial mammals are recorded and 19 or 33% are endemic to the
country and 16 are restricted to the Mt. Mantalingahan Range;
 24 endemic reptiles and 69 species are found in the Mt. Mantalingahan corridor;
 4 of the 5 marine turtles are found in Palawan; and
 379 species of corals found in Palawan and 82% of the total coral species
recorded in the country.

The UNESCO declared two areas in Palawan as World Heritage sites: The Tubattaha
Reed Marine Park in 1993 which covers 332 square kilometers north and south reefs
with very high density of marine species and the North Islets are the nesting site for
birds and marine turtles; and Puerto Princesa Subterranean River National Park in
1999 hosts some of the most important forests in Asia, and is a site that contains a
full ‘mountain to sea’ ecosystem.

In 1992, Republic Act No. 7611 also known as the Strategic Environment
Plan for Palawan Act (SEP Law) was passed establishing a framework of
development for the province that support and promote its sustainable
development growth.

The law especially addresses regulations referring to the environmentally

critical areas networks (ECAN) of the province composed of the terrestrial or
forestlands, marine or coastal area, and ancestral lands.

Unfortunately, even the law recognized the presence of “mine sites in major
catchments or are dangerously close to fragile shore and in-shore of marine
zones.”

The SEP Law endorses the Palawan Council for Sustainable Development
(PCSD), which is in charge of governance, implementation and policy
direction of SEP Law.

However, the biodiversity of Palawan is under very high threat. Conservation

International has identified Palawan as a site for threatened amphibians, mammals,

3|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

birds, reptiles, and freshwater fish, as well as for restricted-range and congregatory
birds, using confirmed locality data for each target species.

Geo-tagging5 has also found the province and its biodiversity under threat due to
some 354 mining tenements encroached in almost 50% of its total land area,
covering forest ranges of Mt. Bulanjao which is a protected area and falls under ‘core
zones’6 which should not be open to any development activity, and 90% of ancestral
lands.

History of mining in Palawan

Mining has been done in Palawan at least since the 1970s. The island province is
endowed with minerals resources including gold, nickel, copper, cobalt, chromite and
even mercury. To date, the resource-rich Palawan has mining applications, and
various mining permits issued as presented in Table 1 below.

Table 1. Mining permits in Palawan7

Current
Corporation/ Permit No.,
Mineral Resources activities/
Permitee Area coverage, location
stage
Rio Tuba Nickel MPSA8 No. 114-98-IV issued in June 4, Nickel Commercial
Mining Corporation 1998 covering 990 hectares (has) in Operation
Bataraza, Palawan
Central Palawan MPSA No. 171-01-IV issued in January 16, Limestone Exploration
Mining and Industrial 2001 covering 4896.1000 has in Quezon,
Corporation Palawan
Palawan Star Mining MPSA No. 172-01-IV issued in January 16, Limestone Exploration
Ventures Inc. 2001 covering 5234.2079has in Quezon,
Palawan
Pyramid Hill Mining MPSA No. 173-01-IV issued in January 16, Limestone Exploration
and Industrial 2001 covering 5149.9000has in Espanola,
Corporation Narra and Quezon, Palawan
Rio Tuba Nickel MPSA No. 213-2005-IVB issued in April 28, Limestone Development
Mining Corporation 2005 covering 84.5364has in Bataraza,
Palawan
MacroAsia MPSA No. 220-2005-IVB issued in Nickel, chromite, iron, Exploration
5
In a photographic context, geotagging is the process of associating photos with specific geographic locations
using GPS coordinates. ALDAW geo-tagging findings are available through the following reports:
http://participatorygis.blogspot.com/2010/01/counter-mapping-in-philippines-gantong.html
http://participatorygis.blogspot.com/2010/01/bulanjao-geotagged-report.html
http://www.facebook.com/Aldaw.network.palawan.indigenous.advocacy?v=wall

6
Core zones according to the SEP Law are “areas above 1,000 meters in elevation, virgin forests or primary
growth forests, areas with steep gradient (above 50% slope), and critically threatened/endangered habitats and
habitats of rare endangered species or habitats of Palawan local endemic species of flora and fauna”. This zone,
according to the SEP law, shall be fully and strictly protected and maintained free of human disruption.
7
Data from Department of Environment and Natural Resources - Mines and Geosciences Bureau (DENR-MGB),
as of March 2011.
8
Mineral Production Sharing Agreement (MPSA) is an agreement wherein the government shares in the
production of the contractor, whether in kind or in value, as owner of the minerals and the contractor gets the rest.
(DENR-MGB Description)

4|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

Corporation December 1, 2005 covering 1113.9836has and other associated

in Brooke’s Point, Palawan mineral deposits
MacroAsia MPSA No. 221-2005-IVB issued in Chromite, nickel, copper Exploration
Corporation December 1, 2005 covering 410has in and other associated
Brooke’s Point, Palawan mineral deposits
Citinickel Mines and MPSA No. 229-2007-IVB issued in January Nickel, chromite and Exploration
Development 3, 2007 covering 2176has in Narra, other associated mineral
Corporation Sofronio Espanola, Palawan deposits
Berong Nickel MPSA No. 235-2007-IVB issued in June 8, Nickel, iron, cobalt, Exploration
Corporation 2007 covering 288has in Quezon, Palawan chromite and other
mineral deposits
Lebach Mining MPSA No. 285-2009-IVB amended into Nickel, chromite, cobalt, For registration
Corporation Exploration Permit No. 00001-2009-IVB copper, gold and other
amended in November 19, 2009 covering mineral deposits
2573.3300has in Brooke’s Point, Palawan
Celestial Nickel MPSA No. 017-93-IV issued in September Nickel Exploration
Mining Exploration 18, 1993 covering 2835.0600has in
Corporation Brooke’s Point, Palawan
Narra Nickel Mining FTAA 9No. 05-2010-IVB issued in April 12, Nickel, cobalt and other On-going
and Development 2010 covering 12381.72has in Rizal, associated minerals exploration
Corporation, Tesoro Bataraza, and Narra, Palawan
Mining and
Development
Corporation and
McArthur Mining Inc
Berong Nickel EP10 No. IVB-60 issued in February 12, Nickel and cobalt On-going
Corporation 2010 covering 1069.41has in Quezon and exploration
Aborlan, Palawan
Source: Mines and Geosciences Bureau (MGB) as of March 2011

Today, different large-scale mining permits cover a total of 38, 202.2749 hectares of
Palawan, while mining applications cover almost the whole of the island province.

Meanwhile there are 11 abandoned mine sites in Palawan as shown in the table
below.

Table 2. Abandoned Mine Sites in Palawan

Mining Company Area of operation Mineral

Palawan Quicksilver Mining Inc. Sta. Lourdes, Puerto Princesa City Mercury

Atlas Consolidated Mining & Sta. Lourdes, Puerto Princesa City Gold
Development Corp.

Palawan Venture or Palawan Irawan, Puerto Princesa City Chromite

Consolidated Mining Co.

Soriano Mining Corporation Aborlan, Puerto Princesa City Nickel

9
Financial or Technical Assistance Agreement (FTAA) is an agreement for the large-scale exploration,
development and utilization of minerals. (DENR-MGB Description)
10
Exploration Permit (EP) allows a qualified person to undertake exploration activities for mineral resources in
certain areas open to mining. (DENR-MGB Description)

5|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

Trident Mining Corporation Narra, Palawan Nickel

Infanta Mining Corporation Brgy. Ipilan, Brooke’s Point Nickel

Celestial Mining Corporation Brgy. Ipilan, Brooke’s Point Nickel

Long Point Mining Corporation/Soriano Berong, Quezon Nickel

Mining

Benguet Company Inc. Balabac Gold ore

Nin Bay Mining Corporation Roxas, Palawan Silica

Republic Glass Mining Corporation Roxas, Palawan Silica

Source: Environmental Legal Assistance Center (ELAC)

Since the early 1970s, the Rio Tuba Nickel Mining Corporation (RTNMC) has been
operating in the municipality of Bataraza in Southern Palawan. Its operations started
when the nickel deposit in Rio Tuba was discovered in 1967. On September 18, 1970,
the company entered into a Mining Lease Contract with the Republic of the
Philippines as lessor, covering 126 hectares of public land or 110 Lode Mining claims
of nickel, iron and other minerals located in Rio Tuba. The RTNMC has a mining claim
of 5,265 hectares of which 353 hectares are currently operated.

Study has shown that the activities of RTNMC do not equitably and efficiently
distribute benefits from mining, and that the impacts on the environment are not
effectively monitored while the environmental costs are undervalued 11. At present,
RTNMC continues to mine and has recently been issued another permit expanding
towards Mt. Bulanjao range, one of the best conserved ultramafic12 forests in
Palawan.13

Further, the exploration permit issued to MacroAsia Corporation 14, Ipilan Nickel
Corporation15 and Lebach Mining Corporation 16 threatens the forests and life in
Brooke’s Point (also located in Southern Palawan) as well as the survival of isolated
Pala’wan communities having limited contacts with the outside world.

11
The Costs and Benefits of Three Decades of Mining in Rio Tuba, Bataraza, Palawan by Antonio G.M. La Viña,
Grizelda Mayo-Anda, Mary Jean A. Caleda, Redempto D. Anda, Katherine Mana-Galido, Loreto L. Cagatulla,
published by ELAC and the Ateneo de Manila University (ADMU), September 2006, pp.1-95]
http://no2mininginpalawan.com/2011/03/21/the-costs-and-benefits-of-three-decades-of-mining-in-rio-tuba-
bataraza-palawan/
12
Ultramafic (also referred to as ultrabasic) rocks are igneous and meta-igneous rocks with very low silica content
(less than 45%), generally >18% MgO, high FeO, low potassium, and are composed of usually greater than 90%
mafic minerals (dark colored, high magnesium and iron content). The Earth's mantle is composed of ultramafic
rocks. http://en.wikipedia.org/wiki/Ultramafic_rock
13
http://participatorygis.blogspot.com/2010/01/bulanjao-geotagged-report.html
14
http://no2mininginpalawan.com/2011/03/25/macro-asia-corporation-certification-of-mpsa-nos-220-2005-ivb-
and-221-2005-ivb/
15
http://no2mininginpalawan.com/2011/04/17/lebach-mining-corporation-brgy-mainit-brookes-point-palawan-ref-
no-ecc-co-0911-0009/
16
http://www.slideshare.net/no2mininginpalawan/lebach-mining-corporation-ecc-located-at-bgy-ipilan-brookes-
point-palawan

6|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

MacroAsia was incorporated in the Philippines on February 16, 1970, originally under
the name Infanta Mineral & Industrial Corporation, to engage in the business of
geological exploration and development. As a mining firm, it had actually mined its
leased areas in Brooke’s Point in the 1970’s. MacroAsia Corp. is a listed aviation
support company owned by Lucio Tan.

Lebach Mining Corporation is a domestic registered company with registered address

Silangan House, 7606 Guijo Street, San Antonio Village, Makati City, Philippines.
Lebach’s Chairperson and Chief Executive Officer is Edgar L. Rodrigueza.

According to joint reports by Ancestral Lands Domain Watch in Palawan (ALDAW) and
the Center for Biocultural Diversity (CBCD) of the University of Kent, the exploration
activities there allow the three companies to illegally enter ‘core zones’ and well-
developed agricultural lands including wet rice fields and coconut plantations, tribal
sacred sites and ancestral lands.17

MacroAsia Corporation and Ipilan Nickel Corporation have permits intruding the Mt.
Matalingahan Protected Landscape. Further reports said Environmental Compliance
Certificates were issued then by PCSD despite the lack of social acceptance. As of
now, also the Palawan branch of the National Commission on Indigenous Peoples
(NCIP) has bluntly violated all required procedures leading to transparent and
genuine FPIC processes, siding instead with the mining companies.18

Impacts of mining in Palawan

In January 2010, through geo-tagging technology and participatory audio-visual

documentation19, it was found that mining tenements had intruded into identified
‘core zones’ of protection in Palawan. These activities will damage the province’s
water supplies, soils, forests, rivers, corals and marine environments. The efforts to
protect and conserve Palawan are now being put in danger and erode by the
circumventing laws and encroachment even in the core protected zones is a clear
violation of laws by mining companies. These widespread abuses further put the
island at higher risk to the different potential impacts of climate change.

Anda and Galido (2006)20 identified several socio-cultural, economic and

environmental impacts of mining in Palawan in the thirty years of mining activities
there. Identified environmental impacts include the following:

17
“The Mt. Gantong/Brooke’s Point 2010 Geo-Tagged Report”, Mining Threats to Watersheds, Core Zones and
to the Ancestral Domain of Isolated Indigenous Communities, Palawan Island (The Philippines)
http://www.iapad.org/publications/ppgis/aldaw_gantong_2010_report.pdf
18
http://www.iapad.org/publications/ppgis/aldaw_gantong_2010_report.pdf
19
http://www.youtube.com/user/ALDAWpalawan
20
The Cost and Benefits of Three Decades of Mining in Rio Tuba, Bataraza, Palawan, pp. 27-66, Sharing Natural
Wealth for Development – Case Studies from Palawan Province, Philippines, ELAC and Ateneo De Manila
University, September 2006.

7|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

 Deforestation and loss of wildlife habitat for ecologically important flora and
fauna in the mined out areas and the Gotok limestone quarry area;
 Decrease in quantity and quality of water supply;
 Adverse impact on the irrigation system and decrease in agricultural production;
 Erosion and flash floods;
 Threats to coastal resources brought by erosion and effluents;
 Water and air pollution; and
 Health impacts such as skin lesions.

These are the very reasons why the SEP Law was passed in 1992. The rationale
behind the law being,

“The destruction of Palawan’s forests would trigger a chain reaction that would bring
destruction to the entire environmental and ecological fabric of the province. The
resulting soil erosion and loss of top soil would dry up underground and surface
water resources, nullifying the efficiency of irrigation systems and waterworks…
There is an urgent necessity to stop this deterioration. It is not enough to rely on a
network of Parks in the conventional sense, for this would be too limited in area and
arouse distrust in local communities.”

It seeks to prevent further environmental degradation in the islands. However,

violations of environmental and other national laws and policies make mining a
bigger threat to Palawan, its resources and its people.

This struggle against mining and towards sustainable development has contributed
to the rise in numbers of environmental and indigenous advocacy organizations and
networks in the province—including the Environmental Legal Action Center (ELAC),
Conservation International (CI), Nagkakaisang mga Tribu ng Palawan, Inc. (NATRIPAL),
Ancestral Land Domain Watch (ALDAW) and many others.

There are local government officials also opposed mining because of its threat to the
treasured environment and to tourism like Puerto Princesa Mayor Edward S.
Hagedorn (first elected in 1992), when he pursued to prioritize tourism over mining
in the capital of Palawan.

In 2010, ALDAW, an environmental group launched a signature campaign signed by

more than 20,000 petitioners from all over the world calling to stop mining in
Palawan Forests. International organizations such as Rainforest Rescue and Survival
International closely partnered with ALDAW in the achievement of this objective 21.

Palaweños who are affected by mining operations and plans of opening up thousands
of hectares of bio-fuel and oil palm plantations supported the launching of the
campaign at the local level. Their primary campaign concerns included the following:

21
http://www.survivalinternational.org/tribes/palawan

8|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

 Objection to RTNMC building roads towards a biodiversity hotspots in the Mt

Bulanjao Range; and
 Opposition to mining permits being issued to MacroAsia Mining Corporation
and Celestial Nickel Mining Exploration Corporation (currently being operated
by Ipilan Nickel Corporation) despite the absence of genuine consultation
processes, and a flawed free, prior and informed consent (FPIC) process.

Furthermore, these mining companies have been allowed to enter forested “Core”
and “Restricted” zones despite all rules and regulations enshrined into the Strategic
Environmental Plan (SEP), also known as Republic Act 7611.

Dr. Gerry Ortega, an environmental advocate and broadcast journalist who was very
vocal against mining in Palawan was killed on January 24, 2011 after his morning
radio show in Puerto Princesa City. In the past months before his death, he has been
receiving death threats because of his opposition to mining and exposed bribery in
the government in endorsing of mining through his radio program “Ramatak” over
DWAR, a local affiliate of “Radyo Mo” nationwide.

Immediately after Ortega’s death, the 10-million signature campaign to stop mining
in Palawan was launched led by Bantay Kalikasan chief Ms. Gina Lopez. The campaign
started with the call to stop mining in the province and evolved to stopping mining
activities in key biodiversity areas and in critical ecosystems. Today, the signature
count has already reached about more than 800,000.

No to mining in Palawan

The main call of Palaweños and organizations on the threat of mining is for the PCSD
to strictly enforce the SEP Law and implement policies that are geared towards
sustainable development, especially respecting the identified policies for the
environmental critically areas network (ECAN). Further, national policies should
respect the rights of indigenous peoples and communities in rejecting mining
applications based on the identified serious adverse impacts it has brought in the
past and will bring in the future if it is allowed to develop further extraction of
minerals in Palawan.

Executive Order (EO) No. 23 issued on February 1, 2011 by President Benigno S.

Aquino III declaring a moratorium on the cutting and harvesting of timber should not
be limited to protecting natural and residual forests. In the case of Palawan, the
whole of Palawan, including its outlying island municipalities, should be spared from
logging and mining. Existing concessioners must no longer be given permits to
expand operations and their activities should be strictly monitored. The exploitation
of its mineral and oil fields, its marine wealth and virgin forests should stop now.

The Philippines is clearly threatened by the effects of climate change. Already there
are increased extremes of weather and increased numbers of typhoon storms per
season as compared to even 20 years ago. Mining particularly strip mining and open

9|Page
Case Study by Farah Sevilla, Alyansa Tigil Mina
Palawan: Mining and Biodiversity

pit operations are particularly vulnerable when affected by extreme storms. Exposed
minerals and toxic residues can be more easily flooded into the environment.

It is already the case that the Philippines cannot reach best international practice on
water and toxic waste management at mining sites. This is due to the already
uncontrollable impacts of tropical seasonal typhoon. These are seen to be getting
stronger and more unpredictable due to climate change effects. The already
disastrous legacy of mining in the Philippines will, it is feared, worsen. The
international community should take stronger action in order to regulate mining
particularly, near sea level mining that might be easily inundated as sea level rises
and all mining in monsoon/typhoon /hurricane affected zones.

10 | P a g e