ADDITIONAL INFORMATION REQUEST FROM EIARC

FIRST AI √ SECOND AI

Project Title : Coto Chromite Project

Project Location : Sitio Coto, Brgy. Taltal, Masinloc, Zambales
Proponent Name : Consolidated Mines, Inc.
Date & Venue of : 21 November 2022 at 1pm
Meeting

Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
Rehabilitation/Construction and operation Kindly separate the phases of the project (pre-construction, construction, operation, and abandonment)
Land
Kindly specify Landslides and Installation of traffic measures 100% No
specific activity deteriorating bridges to minimize accidents and loss Erosion
and its impacts due to access road of life and property
and rehabilitation.
corresponding
mitigating
measure -EMB
Dust/ particulate • Frequent watering/ 100% Compliant Kindly indicate
matter from the all- dampening of access road to RA the frequency
weather type of access • Minimize hauling activities 8749 in terms of and scheduling
during periods of strong wind air of the watering
• Provide covers for haul trucks quality standards
• Impose speed limits Specify the
speed limit

Move this
Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
impact in air
module– EMB
Unstable slopes and • Determine angle of repose 100% No
possibility of landslides and the best engineering Erosion and
due to road widening structure to be built when Erosion
cutting through slopes
• Increase factors of safety in
all engineering/ geotechnical
designs
• Thorough geological mapping
• Implement appropriate
ground failure plan
• Train mine personnel in
recognizing various ground
failure modes, hazards,
warning signs and procedures
during events of ground failure
• Train personnel to recognize
signs of potential instability
problems e.g., tension, cracks,
abnormal water flow/
seepages presences of
overhang
Soil Erosion • Establish sediment control 100% No For the siltation
facilities and siltation ponds Erosion ponds, kindly
• Revegetation of exposed indicate the
areas capacity and
• Conduct construction phase geographical
activities during dry season coordinates.
Include
justification of
Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
the capacity (for
the surface silt
ponds and
underground silt
sumps) -EMB
Generation of solid • Construct a waste disposal 100% Kindly indicate
waste that might lead to facility compliance the capacity of
soil contamination • Develop and implement waste with the the MRF
management plan following:
• Designate a solid waste • RA 9003
disposal area • DAO 1992-29
and DAO 2013-
22 and
its Revised
Procedural
Manual
Hydrocarbon leaks and • Establishment of appropriate 100% No Soil
spills and surface run- disposal facility for HC wastes Contamination
off • Establishment of motor pool
area
• Establishment cemented work
area with provisions of proper
drainage to contain washings
to prevent soil contamination
• Train workers in proper
handling and implementation
of good housekeeping
practices for petroleum and
other hazardous materials
• Installation of collection
sump
Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
for direct effluents
• Installation of oil-water
separator
Mass Movement, • Locate new tailings pond 100% No Indicate geo-
flooding, soil taking into consideration Erosion and coordinates of
erosion and run- the stability and eventual No Flooding the tailings
offs associated to siltation of the Sur Lewis facility-EMB
tailings storage River
facilities • Proper management of the
tailing’s discharges and
treatment of effluents
Possible land • Implement proper support
subsidence due to and backfill of mined-out
instability of mine area shall be implemented
area • Conduct geotechnical
studies to determine
appropriate infrastructure
and support system.
Loss of vegetation • Incorporate buffer zones 100% No Tree
and localized and spare portions of Cutting
displacement of existing-forested stans without Permit to
more sensitive • Establish seeds banks and Cut
faunal species tree nurseries for replanting Trees
areas,
• Plant native trees to attract
diverse assemblage of
wildlife
• Establishment of
“Faunal Rescue Plan” that
will consider documentation,
rehabilitation and release of any
 Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
trapped/ injured wildlife
• Proactively monitor
changes on biodiversity
The Water
Water Resource • Use of river water and not 100% No
depletion groundwater to avoid Groundwater
groundwater depletion Extraction.
• Proper impounding of used Allowable
wash water shall be Ambient
implemented Criteria or 100%
• Conduct studies om recycling Compliant to RA
wash water back into the loop 9275 and DAO
for use a washing media for 2016-08
chromite ore standards outside
the silt curtain
area.
Possible contamination Test and treat underground Allowable
of water bodies through mine flood water and if it Ambient
discharge of water from contains elevated levels of Criteria or 100%
mine dewatering acids/ metals Compliant to RA
9275 and DAO
2016-08
standards outside
the silt curtain
area.
Siltation and • Prevent accumulation of Allowable For the siltation
sedimentation of materials for stockpile near Ambient ponds, kindly
drainage systems due to steep slopes or near natural Criteria or 100% indicate the
possible run-off of tributaries Compliant to RA capacity and
stockpile materials • Construct temporary barriers 9275 geographical
around stockpiles to prevent and DAO 2016- coordinates.
 Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
release of loose materials 08 Include
• Construct silt traps or small standards outside justification of
dam across waterways or the the capacity (for
gullies silt curtain area. the surface silt
• Cover loose materials during ponds and
rain events to prevent run-off underground silt
sumps) -EMB
How about
impacts of
hazardous waste
generation?
How about
impacts of
domestic waste
generation
The Air
Sox and NOx Regular maintenance of heavy 100% Compliant
emissions for heavy equipment and motor vehicles to RA 8749 in
equipment used in terms of
site rehabilitation air quality
standards
Increase in sound • Regular maintenance of 100% Compliant
levels from motor vehicle mufflers with Noise
construction • Provision of barriers and Standards
activities shielding for stationary
vibrating equipment
• Provisions of ear mufflers
for workers
• Proper scheduling of noisy
activities during day time
• Inform community when
Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
activities will generate
excessive noise
Noise and • Monitor noise and vibration 100% Compliant
Vibration levels (during) with Noise
• Require the use of hearing Standards
Vibrations protective equipment in
affecting noisy areas
surface • Regularly maintain all
infrastructure. machinery, equipment and
Disturbance vehicles and fitted with
to local noise attenuation devices
community where feasible
and animals
Possible risk of • Monitor dust levels 100% Compliant Indicate
respiratory diseases • Require workers in dusty to frequency and
(employees working area to wear protective dust RA 8749 in scheduling of
in dusty areas) masks terms of watering
• Spraying water on road air quality
Dust contamination surface, rehabilitating standards
around project closed areas of the tailings
facilities dam and waste rock dump and
by maximizing the
wetted surface of the
tailings dam as feasible
TSP, Sox and Nox • Regular maintenance of 100% Compliant
emissions from standby generators to
standby generators • Regular compacting of RA 8749 in
unpaved access roads terms of
• Formulation and air quality
implementation of a motor standards
vehicle maintenance
 Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
program including emission
testing
Air quality effects due • Provision of appropriate 100% Compliant
to fugitive dust control devices to
particulates and • Regular maintenance of RA 8749 in
gaseous emissions crushing equipment terms of
from the milling • Provision of adequate air quality
process standards
enclosure for dust-
generating equipment
Air quality effects due • Require contractors to 100% Compliant Will there be
to fugitive provide tarpaulin cover on to construction of a
particulates from trucks loaded with finished RA 8749 in port? Is it
transport of finished products terms of included in the
product from the • Formulate and implement a air quality ECC
mine to the port motor vehicle maintenance standards application?
program including testing Kindly clarify –
• Impose speed restrictions EMB
(15-20 kph); and
• Paving or compacting of
road sections where houses
are concentrated
The People
Uncontrolled in- • Establishment of a 100% Compliant
migration Barangay Migration Center; to
• Make residents the priority SDMP and Local
in job hiring Hirees
Fear of increased • Provision of opportunities 100% Compliant
competition for for employment and to
natural resources alternative sources of SDMP
livelihood
Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
Generation of • Prioritization of local 100% Compliant
employment and qualified applicants by CMI to
livelihood when hiring personnel SDMP and Local
opportunities Hirees
Enhance industrial • Prompt payment of taxes 100% Compliant
development of the and other permits/ licenses to
area and increase in to the municipality Local Permits
local revenues of the
LGUs from their share
of taxes and other
permits and licenses
Increased barangay • Preparation of a 100% Compliant
income and Community Development to
community Plan SDMP
development from
CSR activities
Increased traffic • Proper positioning of 100% Compliant
movement equipment and lay down to
areas Traffic
• Putting up of signage Management
• Formulation of traffic Plan
management plan
Safety issues at work • Conduct of safety training 100% Compliant
areas programs for all new to
workers PPEs and Zero
• Use of PPE by workers accident
• Require contractors to
maintain their heavy
equipment and vehicles in
top condition
• Require contractors to
 Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
implement an ecological
solid waste management
plan and coordinate with
municipality for disposition
of residual waste
• Provision of proper
sanitation and water supply
facilities
Accidents / • Develop a comprehensive 100% Compliant
Risks to underground safety manual to
underground detailing all safety aspects PPEs and Zero
miners relevant to underground accident
mining operations
• Train personnel for the type
of work they are required to
perform
Injury/ fatality due to • Imposes access restrictions 100% Compliant
inadvertent access to where appropriate to
the mine • Provide signs in dangerous Implementation
areas (such as caving areas of
and tailings dams) signages and
• Conducts IEC to inform the Compliant to
public of specific dangers SDMP
and IEC
Abandonment
The land
Soil erosion, • Implement Progressive 100% Compliant
landslides, river Rehabilitation Plan to to
siltation include revegetation at the Progressive
shortest possible time Rehabilitation
• Ensure that all underground Plan
 Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
openings be backfilled and
properly closed and that
appropriate signage be in
place for the safety of local
residents
Generation of Solid • Proper disposal of solid 100%
Waste wastes outside the mine compliance
site with the
• Conduct information following:
dissemination and put up • RA 9003
signage on locations of • DAO 1992-29
underground mines/ and
tunnels DAO 2013-22
and
its Revised
Procedural
Manual
The water
Possible leaching of • Ensure stability of tailing Allowable
heavy metals and containment Ambient
minerals into water Criteria or 100%
bodies Compliant to RA
9275
and DAO 2016-
08
standards outside
the
silt curtain area.
The Air
Reduction of • No mitigation necessary 100% Compliant
generation of to
 Activity Potential Impacts Proposed Mitigating Efficiency of EIARC Module Comments on Responsible
Measures Measures Concerned the mitigating Government
measures and Agency
efficiency
particulate matter RA 8749 in
and noise in the terms of
impact area air quality
standards
The People
Local Benefits • Proper coordination with 100% Compliant
the LGU to enhance local to
benefits SDMP
• Provision of Seminars on
Financial Management in Barangay
the Community

Other Comments:
General Comments Provide A3 size maps and figures
Complete the project components and equipment
Complete the tables and figures
Executive Summary
Project Description Dr. Maestrecampo
Figure 1-15: Material Balance Diagram
 Indicate explicitly that the amounts are on per day basis
Figure 1-16: Water Balance Diagram
 No time dimension. I assume it is on a per day basis
 Some of the streams are not balanced
  Include in section 1.4.3 – Pollution Control Facilities the technical details of the dust control devices to be used during milling
process

LGU-Masinloc
Address the flooding in the underground mine.
LGU already secured the water rights in the area of Sur Lawis river
Include environmental rehabilitation measures
Include comprehensive and sustainable SDMP
The port area was already converted by the provincial government
ROW are classified as provincial road and are being developed by the municipalities
Land EMB:
Table 2.1-2A is missing (ECA Table)
Terrestrial Ecology Dr. Moreno:

Page 2.1-60. Please correct how scientific names are written. Also, there is no word specie, only species.

In tabulating result of assessment of species richness, it should be Family, Scientific name then the local name. It should be sorted
out that same families should be lumped so that during description, it will be easier to discuss how many species were found in
one family and so on.

Page 2.1-74. You have a title/ heading but it does not reflect what is being discussed.

Only species richness was presented. How about the result of quantitative assessment.
 Provide a discussion of Table 2.1-22. Vegetation Summary Result of Floral Inventory. What are these threatened species?
Introduced species? Exotic species?

What are the species with the highest Importance value? Relative frequencies? Relative cover?

The area that will be disturbed has not been quantified.

Only conservation status of flora has been discussed, how about fauna?

How are the endangered flora going to be conserved? Will they be affected by the road widening, etc…

Water Dr. Maestrecampo

 Table 2.2-3 is Water Quality Sampling Stations and not the water balance analysis stated in page 2.2.8. Please provide this
table as basis for the Figure 2.2-5.
 Show that Sur Lawis River and other surface water streams have enough capacity to supply water for industrial requirements
and domestic water supply and will not compete with the water usage of the affected community
Freshwater and Marine
Ecology
Air Dr. Maestrecampo
 Correct the typo error on the GHG Mitigation potential equation on page 2.3-7

 Provide technical details of dust control devices to be used during mining and milling operations
Environmental EMB Region 3:
Management Plan Chapter 2.1-6: Site specific slope stability analysis particularly in the mine. On the discussion (e.g., Peak Ground Acceleration),
regional and countrywide data was used. Kindly use the data specific to the project site

Attach in the annex, the geotechnical study in the area so that they can incorporate it in the slope stability analysis
The discussion on the mitigating measures for the soil erosion was generic. Kindly provide specific mitigating measures including
the capacity, location and frequency of desilting. Show the projected volume of silt that would be generated during ground
 preparation and mining operations.
People Dr. Dalisay:
1.  Provide supplemental perception survey covering additional households to make up the required number based on a statistical
formula.  A discussion on the formula used should also be included.  Previous EIS submitted for review even during the height of
the pandemic were able to cover a statistical number of respondents.  Methods used included online methods as well as phone
calls with the assistance of the LGU.  

2.  Complete the barangay level baseline data.  Ex.  Mortality and morbidity rates, etc. 

3.  Ensure that all concerns/issues raised during the public scoping were taken into consideration in the formulation of the SDMP
and the IEC program.
Environmental
Management Plan
ERA
Environmental Dr. Maestrecampo
Compliance Monitoring  Increase the sampling and measurement frequency for wastewater during construction phase from yearly to quarterly

SDP and IEC EMB:

Implementation Include the implementation of all the SDMP of the company
Institutional Plan

Agreements:

Tentative Schedule
 Tentative submission of 1st AI, AI locator,
Revised EIS, public hearing requirements 27 December 2022
(list of invitees, ESP, details, etc.)
 Posting of Notice of PH in EMB Website 27 December 2022
 1 Publication in the Newspaper
st
04 January 2023
 2nd Publication in the Newspaper 11 January 2023
 Tentative date of Public Hearing 19 January 2023

Requested by:
Engr. Zabala Dr. Moreno Dr. Dalisay Dr. Maestrecampo
EIARC EIARC EIARC EIARC

Resource Persons:

Ms. Krizia Tumalad

EMB Region 3 DENR Region 3 MGB BMB

Hon. Arsenia Lim

MPDO- Masinloc

Proponent: Preparer: Prepared by:

Mr. Bernardo Nicolas, Jr. Ms. Nadia Conde Engr. Jason Paolo Esguerra
Consolidated Mines, Inc. CenSe Technical Consultancy EMB Casehandler
Services, Inc.

Attachment: Additional Information Request from Engr. Zabala