[Appeal] An open letter to the Senators of the Philippines on the proposed Senate Bill No. 3326


29 May 2013

Dear Senators,


This is with reference to the proposed Senate Bill No. 3326, “An Act Providing for the Delineation of the Specific Forest Limits of the Public Domain and for Other Purposes” also entitled “Forest Limits Act of 2013” and which, we understand, is up for voting on its third reading on 5 or 6 June 2013.

We respectfully request that the concerns listed below are taken up in the process of deliberation, having had no opportunity to share these during the public consultations and technical working group (TWG) meetings undertaken for this proposed bill.

1. We understand that the spirit and intention of the proposed bill are not to limit forest lands, but rather to enact a law that legalizes the identification and demarcation of the country’s permanent forest line beyond which the land may not be utilized for other purposes. Hence, the proposed title is inappropriate. It may be a matter of nuance but in this case, nuance is all. We emphasize that the title as well as references to forest limits in several parts of the bill convey the idea that forest may not be expanded beyond the line. We believe that the line should indicate the minimum, not the maximum, extent of forest.

2. As reported, the Department of Environment and Natural Resources (DENR) completed the forest line demarcation last year, totaling 79,245 kilometers. It would be good to understand where this “forest line” runs across the country’s landscape and how this “forest line” will impact on existing land uses and watershed situation, as part of the deliberation for this proposed bill. What areas does this forest line encompass and will this forest line ensure the percentage of forest cover needed by our country to ensure sustained ecological services, especially water?

3. Areas within the “forest line” are to be classified as permanent forest lands (Section 9) and further sub-classified into protection and production forests. In this proposed bill, the definitions for forest lands (Sec. 3, d), production forest (Sec. 3, e), protection forest (Sec. 3, g), and tenured migrant (Sec. 3, h) beg for more appropriate operationalization that should go beyond the usual DENR definitions and that reflect the present forest and social conditions. As a reference, we wish to refer you to the extensive definitions developed for these terms when the proposed “Forest Resources Act of 2010” was deliberated at both the Senate (Senate Bill No. 2822) and House of Representatives (House Bill No. 3485).

4. The forest line definition and the ensuing demarcation of protection and production forests are primarily undertaken for the sustained ecological services, especially fresh water supply that our country and our people need now and for the years to come. The economic expectations will have to take a backseat in this critical and urgent action that will greatly assist in arresting the continued degradation and deforestation in the country’s remaining forest areas. Much care and critical reviews need to be undertaken in determining protection and production forest areas and cannot just be left for when the Implementing Rules and Regulations will be drafted.

We appreciate and do laud this effort and action from government, specifically DENR, and even if this is a very delayed response to a constitutional mandate since 1987, this is still very relevant, timely, and much needed. We also thank President Benigno Simeon C. Aquino, III for the inclusion of forest bills in his priority legislative agenda. No genuine comprehensive land use in the country can be drafted without a demarcated forest line. The impact of extreme climate events from drought to heavy rainfall to typhoons, the loss of biodiversity, the growing encroachment of agriculture crops such as bananas, pineapples, and genetically modified maize in upland areas, the persistent marginalization of communities in many upland areas are some of the realities that we need to integrate in the forthcoming discussions and decisions.

The proposed bill, as it is now stands, will not fully serve its intention and engender the support from government and the private sector, along with civil society stakeholders. We therefore request for the active engagement of environmental groups, other civil society organizations and academics in further consultations before this bill gets to a final reading and approval.

Thank you.



Sylvia Miclat
Executive Director
Environmental Science for Social Change (ESSC)

Angelina Galang, Ph.D.
Lead Convenor
for Safe Food, Healthy Environment, and Sustainable Economy

Patria Gwen M.L. Borcena, M.A.
GREENRESEARCH Environmental Research Group

Ma. Belinda E. de la Paz
Haribon Foundation

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