December 20, 2019

HON. TOBIAS “TOBY” M. TIANGCO

Mayor
City of Navotas

Dear Mayor Tiangco:

This refers to Executive Order No. TMT-029 Series of 2019 issued by your good
office on November 28, 2019 implementing a limited truck ban on C-3 Road, R-10
Road and North Bay Boulevard, from 6AM to10AM and 4PM to 8PM effective
January 01, 2020.

The Association of International Shipping Lines, Inc. (AISL), whose membership

consists of thirty-six (36) international container liners calling Philippine ports, is
among the several stakeholders taken by surprise by such move especially so when
the E.O. was issued without going through the process of public consultation. With
the ongoing construction of the NLEX Harbor Link-Segment 10 C-3 to R-10 Section,
we understand that the City decided to impose a limited truck ban to avert the
anticipated worsening of traffic condition once the DPWH Malabon-Navotas District
Engineering Office Reinforced Concrete Box Culvert Flood Control Project goes
underway in January 2020.

While the E.O. is geared towards preserving the comfort and convenience of the
Navotas residents, AISL would like the City government to take a closer look at the
important role played by the C-3 Road, R-10 and North Boulevard when it comes to
the movement of cargo trucks and the economic implications to business and
production centers in the event the supply chain is disrupted. C-3 Road, R-10 and
North Boulevard are highly critical arteries in the delivery of goods in Luzon and
implementing a truck ban in these areas albeit for a limited period, will significantly
constrict the flow of trade and deflate the economic momentum gained in the past
months. The truck ban will affect an estimated 8,600 trucks moving around the port
area everyday. These include truck movements to and from the Manila International
Container Terminal (MICT), ATI-South Harbor, Manila North Harbour Port
(NorthPort) and off-dock empty container depots situated within the CAMANAVA
area.

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At this time of the year, yard utilization at MICT and ATI-SH are well within the
manageable level of 75% , a stark contrast to the port situation experienced by all
stakeholders in 2014 and late 2018 where yard utilization at the terminals and off-
dock empty container depot facilities leapt past 100%. With import volume growing
at an annual rate of 5%-6% and the expected spike in import shipments before the
start of the Chinese New Year in January 25 , a repetition of the chaotic situation
that marred the years 2014 and 2018 is likely to happen unless E. O. No.TMT-029
Series of 2019 is recalled by your good office. Under the given scenario, the Manila
terminals, both international and domestic, will be congested resulting to massive
delays in the delivery of shipments. The return of empty containers to off-dock will
also pose a very serious problem for local shippers whenever they need empty
containers to stuff their export shipments. All of these taken together will give rise to
increases in logistics costs which the ultimate consumer has to bear.

The grave ramifications of a limited truck ban imposed in such sensitive areas such
as C-3, R-10 and North Bay Boulevard cannot be ignored. While it may ease up the
traffic flow along those areas because of the limited truck ban, economic activity in
many parts of Luzon will grind to a halt. In the meantime, containers, laden and
empty, continue to pile up at the ports until yard utilization reaches unmanageable
proportions. This brings back memories of 2014 and 2018 when the situation
spiraled out of control and in complete disarray thus forcing the national government
to step in.

As we all look forward to a prosperous 2020 for the Philippines, we need to avoid the
same misfortunes that afflicted the country in 2014 and 2018. Stakeholders have
bitterly learned the lessons of the past. Port congestion is a painful experience,
something that should not be allowed to recur before it becomes a disaster to the
economy of the country as a whole.

We look forward to your favorable consideration.

Yours truly,

Cc: Secretary Eduardo Año, DILG

Secretary Ramon Lopez-DTI
Secretary Carlos Dominguez III-DOF
Secretary Arthur Tugade-DOTr

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