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Environmentalists, local political leaders, Non-Governmental Organizations (NGOs), Civil Society Groups, students, professionals, stakeholders, and ordinary citizens have spoken about the negative and devastating effects of coal-fired plants. They have voiced their concern regarding marine and forest ecology destruction, acid rain, biodiversity imbalance, mercury in food, health and welfare of future generations, depleting seafood source, global warming and climate change, destruction of famous tourism attraction sites, alternate and renewal energy options, economics of running a coal-fired plant and many other related issues.

Let me add and count more reasons why the ECC of RP Energy must be cancelled immediately:

1. COAL PLANT SITE IS EARTHQUAKE PRONE

Based on their own Environmental Impact Statement, RP Energy Admits:

“Tectonic features of Philippine archipelago indicate that the Manila trench is found west of the proposed project site. A north-south trending belt of volcanoes, which include Mt. Pinatubo, Mt. Natib and Mount Mariveles are found east of the proposed project site. Recently, PHIVOLCS has declared Mount Natib as a potential active volcano, while the east Zambales Fault, which separates the mountain range of Zambales from the Central Luzon Basin, has been declared as an active volcano.”

“Moderate seismic activity has been detected in the area since the project site is near three prominent seismic faults as published by PHIVOLCS.  These are the Iba Fault situated north of Subic, the East Zambales Fault parallel to Zambales Coast line and the Philippine Fault Zone.”

Just recently, strong earthquake rocks Zambales and Metro Manila. A magnitude 5.9 earthquake that rocked the province of Zambales was also felt in Metro Manila and other parts of Central Luzon and Northern Luzon, the Philippine Institute of Volcanology and Seismology (Phivolcs) said.

Therefore:

1.    Why build the coal plant in a geologically active location?
2.    What if a strong earthquake strikes and damages the ash ponds and leak million tons of coal ash to Subic Bay?

2.    NO STUDY ON GROUND WATER RECHARGE

RP Energy admits:

"Spring water and groundwater will be utilized during the operation to supply the water requirement of the plant which is estimated at 800 cu. m/day (or 33 cu.m/hr or 145 GPM). At this rate, spring water as sole source of water supply will not be feasible.  In addition, extraction of spring water may require the construction of a reservoir as natural channels may not have the required depth for the construction of intake structures.  Therefore, the best option is for a water supply source would be groundwater.”

 “However, recharge rates should be studied to minimize risk of saltwater intrusion as a result of over-extraction, where would occur if the extraction rate is greater than the aquifer recharge rate".

Questions:

1.    When will the recharge rate be studied, when the plant is already operating?
2.    What if it turns out there is less water to support the coal plant?

With increased capacity to 600 MW this means, 800 cubic meters per day or 292,000 per year, doubled to 594,000 cubic meters per year!

3. COAL PLANT SITE IS FLOOD PRONE

RP Energy admits:

“A network of natural drainage channels have been identified that pass through the project site and drain eastward into Subic Bay within the catchment basin where the project site is located.  All stream flows are being fed by spring waters originating from the upper slopes between the elevations 600 and 800 masl of Mt. Silangin-Cinco Picos situated northwest of the project site.”

Questions:

1.    Why build the plant where three active creeks flow through the site?
2.    How about La Nina phenomenon and extreme weather events like massive and extended rain?

4.    THERMAL DISCHARGE WILL CAUSE CORAL BLEACHING AND DEATH TO MARINE LIFE

RP Energy admits:

“Although the assumptions used in the modeling are more likely to overestimate the impact from the thermal discharge, there is uncertainty in the size and location of the areas to be affected by the cooling water discharge, particularly during weak flow.  These uncertainties raise the importance of monitoring as a component of environmental management not only to facilitate compliance with water quality standards, but also to determine whether any sensitive marine habitats are being affected by thermal discharge.”

“However, no actual validation of the model against measured current data was undertaken due to lack of field data.”

“The characteristic circulation patterns in Subic Bay during the northeast and southwest monsoon seasons could restrict the dispersion of pollution loads in some areas of Subic Bay. Dispersion of nutrients away from potential sources such as rivers and discharges tend to be very low, especially in the eastern coastal areas of the bay where a number of semi-enclosed coves are located.  Since the bay itself is also particularly enclosed by the presence of Grande Island, pollutants are generally confined inside the bay.”

MEANING, all the pollutants and hot water to be discharged by the coal plant will just circulate around the bay, thus making Subic Bay waters hotter and hotter (Subic Bay Hot Spring?) while building up all the toxins!

On Corals

RP Energy admits:

“Additional survey should be undertaken to identify coral species that can be removed and transplanted to other sites in the area, limiting the mortality of corals growing in the area. The survival rate of the transplanted corals will also need to be ascertained to identify the benefit of this method.”

“Although the loss of corals from the laying of intake and outfall pies on the seabed will occur, the location and final design of the pipes will be based on the results of thermal plume modeling.”

Yet, RP Energy already said, “the thermal plume modeling was not field-validated for lack of data.”

Thermal discharge will cause coral bleaching and and death to marine life due to increased temperature and waste water pollutants fron the coal plant.

5. THERE WILL BE UNABATED POLLUTION IN SUBIC BAY

On Heavy Metals and other Toxics

RP Energy admits:

“Coal naturally contains traces of heavy metals like mercury. When coal is burned to produce energy, mercury is released into the environment mainly through atmospheric emissions due to its volatile nature. Most heavy metals in the coal remain in coal plant waste products including fly ash and bottom ash. High concentrations of these metals that are released into the environment particularly through migration in soil and water may result to a threat to the marine ecosystem in cases where the potential source is located in a coastal area, such as that of the proposed plant.”

On Radioactive Wastes

RP Energy claims:

“Studies show that coal contains trace quantities of naturally occurring radionuclides including uranium, thorium, their radioactive decay products, and potassium-40 (USEPA, 2008).  A study reports an average uranium and thorium content in coal of 1.3 ppm and 3.2 ppm, respectively (Gabbard, 2008). Most of these radionuclides do not burn, and remain and become concentrated in the ash when coal is burned.  In coal-fired power plants, most the ash is captured (i.e. bottom ash), while fly ash has a potential to become carried away from the source and therefore migration of these traces of radionuclides can occur." But they further states that:

 “Although the effect of radiation due radioactive materials on human health is a concern, studies have shown that radioactive elements in coal and fly ash do not pose a health concern.”

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Facts:

Coal Ash Is More Radioactive than Nuclear Waste. By burning away all the pesky carbon and other impurities, coal power plants produce heaps of radiation

Conclusions from a series of studies showed that the waste produced by coal plants is actually more radioactive than that generated by their nuclear counterparts. In fact, the fly ash emitted by a power plant -a by-product from burning coal for electricity - carries into the surrounding environment 100 times more radiation than a nuclear power plant producing the same amount of energy.

Fly ash uranium sometimes leaches into the soil and water surrounding a coal plant, affecting cropland and, in turn, food. People living within a "stack shadow"- the area within a half- to one-mile (0.8- to 1.6-kilometer) radius of a coal plant's smokestacks - might then ingest small amounts of radiation. Fly ash is also disposed of in landfills and abandoned mines and quarries, posing a potential risk to people living around those areas.


SCRAP STINKING ECC NOW!

The anti-people coal-fired power project, which is being pushed by RP Energy - a mega-profit hungry consortium composed of Manila Electric Co., Aboitiz Power Corp. and Taiwan Cogeneration Corp., runs counter to the people's aspirations for alternative sources of energy that are environmentally viable and sustainable.

The blatant disregard by the profit hungry RP Energy Inc. of the above-mentioned reasons and basic requirements, is an arrogance of capital and the highest height of moral irresponsibility. While they may insist that they had legally secured the said stinking ECC, then we, people would strongly assert, not everything legal is moral.
Scrap ECC now!

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