Stakeholder Engagement and Management Plan

of the

Philippine Reclamation Authority

1
 TABLE OF CONTENTS

I. Introduction ...................................................................................................... 3
II. Regulatory Framework and Requirements ................................................... 5
III. Rationale and Objectives of the SEMP......................................................... 7
A. Education/Information Awareness ................................................................... 7
B. Consult and Involve Stakeholders .................................................................... 8
C. Ensure project success .................................................................................... 8
IV. Stakeholders Identification and Analysis ................................................... 9
A. Definition of Stakeholders ................................................................................. 9
B. Identification of Stakeholders............................................................................ 9
C. Stakeholder Analysis and Mapping ............................................................... 11
V. Stakeholder Engagement and Management Program ............................... 14
A. Mitigate impact/defend against ....................................................................... 14
B. Collaborate with .............................................................................................. 17
C. Empower, Involve, Secure Interest ................................................................ 21
D. Monitor .......................................................................................................... 24
VI. Resources and Responsibilities ................................................................ 27
VII. Monitoring and Reporting .......................................................................... 29

2
I. Introduction

Originally established as the Public Estates Authority in 1977, the

Philippine Reclamation Authority is the agency of government that has been
tasked to ensure a coordinated, economical and efficient reclamation of lands.
It is governed by a Board of Directors composed of a chairman and five
members, including the General Manager as an ex-officio member (now six
including the GM & CEO; and note that EO 564 provides for the increase of
the number of Board members from five to seven including the GM as an ex-
officio member). All of them are appointed by PRA MANDATES
the President for a one-year term as provided - Regulatory & Proprietary Land
under R.A. No. 10149. A Chief Executive Reclamation
Officer is elected annually by the members of - Infrastructure Development
the board from among its ranks and is - Public Estates Development &
considered the highest-ranking officer. The Management
Source: PRA Website
General Manager manages the day-to-day
operation of the agency. He is assisted by five assistant general managers -
for Reclamation and Regulation; Legal and Administrative Services; Estates
Management; Land Development & Construction Management & Technical
Service; and Finance. In addition, the offices of the Special Projects and Joint
Ventures Department; Subsidiaries and Development and Monitoring
Department; the CORPLAN Department, the Office of the Corporate
Secretary and the Internal Auditor provide support to the operations and
activities of the agency. The organizational chart of the PRA is provided
below.

As a government owned and controlled corporation, the PRA has

corporate and proprietary powers. It can reclaim land, including foreshore and
submerged areas; develop and dispose idle public lands; improve, administer
and/or operate lands belonging to, managed and/or operated by the
Government; enter into contracts and loan agreements with private, public or
foreign entities and exercise the right to eminent domain in the name of the
Republic of the Philippines, among many others.1 Thus, the PRA is a crucial
development arm of the government by creating land assets for the
government and converting them into valuable and income generating real
estate properties. Currently, it is attached to the Department of Environment
and Natural Resources (DENR).

In addition to proprietary functions, the PRA is given regulatory

powers. 2 Presidential Decree No. 1084 intended it to be the primary
clearinghouse for all reclamation projects in the country and, as such, has the
power to issue “such regulations as may be necessary for the proper use by
private parties of any or all of the highways, roads, utilities, buildings and/or
any of its properties and to impose or collect fees or tolls for their use.” 3

1
Sec.2, PEA Charter, P.D. No. 1084, 04 February 1977; see also Executive Order No. 525, 14 February
1975.
2
Sec.3 and 5, PEA Charter, ibid.
3
Sec. 4(k and p), ibid.
3
 Organizational Chart
Office of the Chairman and Board of
Directors

Internal Audit Division Corporate Secretary

Office of the General

Manager

Special Projects and Subsidiaries Devt and CORPLAN Dept

Joint Ventures Dep. Monitoring Dep.

Corp Planning Div

MIS Div

Office of the Asst. Gen.

Office of the Asst. Gen. Manager for Land Devt Office of the Asst. Gen. Office of the Asst. Office of the Asst.
Manager for Reclamation and Construction Mgt Manager for Legal and Gen. Manager for Gen. Manager for
and Regulation and Technical Services Administrative Services Estates Management Finance

Environment
2 Field Technical Land Devt &
Management Admin Estates
Offices Services Construction Legal Marketing
Dept Services Management Accounting Budget &
Dept Mgt Dept Department Department
Department Department Services Treasury
Dept Dept

Design/ Construct
Regulation Human
Planning & Evaluation Div
& Resource Property Business
Evaluation
Implement Mgt Mgt Devt
Div Gen Acctg
Div
Budget Div
Contract Material Div
Mgt Testing & 4
Survey Sales and
Planning & Quality General
Eval
Regulation
Control Services and Titling Docum
Property
Treasury
Inv & Proj
Permitting Implementa Acctg Div Div
& Printing tion
II. Regulatory Framework and Requirements

PRA’s regulatory power to approve reclamation projects is shared with

the Department of Environment and Natural Resources (DENR) and other
agencies of government. While the PRA gives the initial authorization on all
reclamation projects, subject to the final approval of the NEDA Board, it is the
DENR that issues, upon PRA request, the required permit for clearing the
proposed site of the reclamation project (area clearance). After reclamation,
the DENR, together with PRA, likewise undertakes the survey of the
reclaimed land and endorses the matter to the Office of the President for the
issuance of a Presidential Proclamation declaring the reclaimed land as
alienable and disposable land of the public domain, as well as for the eventual
issuance of special patent and title.4

More importantly, the DENR is the agency that processes applications

for the issuance of the Environmental Compliance Certificate (ECC), a
mandatory requirement before any environmentally critical project can
proceed. The country’s Environment Policy requires all agencies and
instrumentalities of the national government, including GOCCs like the PRA,
as well as private corporations firms and entities, to prepare, file and include a
detailed Environmental Impact Statement in every action, project or
undertaking that significantly affects the quality of the environment.

Major reclamation undertakings have been identified by law as

environmentally critical and, thus, require the conduct of environmental impact
assessment (EIA), which is a process that involves predicting and evaluating
the likely impacts of a project (including cumulative impacts) on the
environment during construction, commissioning, operation and
abandonment. More relevantly, it includes designing appropriate preventive,
mitigating and enhancement measures addressing these consequences to
protect the environment and the community's welfare.5 Hence, during the EIA
process and the conduct of hearings for the issuance of an ECC, the PRA is
legally mandated to engage with its stakeholders particularly the communities
that might be affected by a proposed project.

The PRA likewise consults, as a matter of policy, with various

departments of the national government, as well as with affected local
government units (LGUs) and relevant government agencies. 6 Clearances
and other permits are also required to be secured from the Department of
Public Works and Highways, Department of Tourism (DOT), Department of
Health (DOH), Philippine Ports Authority (PPA) and Bureau of Fisheries and
Aquatic Resources (BFAR), to name some, to enable the PRA to continue
with the implementation of proposed projects. A more detailed illustration and
explanation of the roles of various stakeholders is provided under the section
on Stakeholder Identification and Analysis.

4
Executive Order No. 672 (October 19, 2007).
5
Revised Procedural Manual for DAO 2003-30.
6
PRA website, http://pea.gov.ph/hide5/83-mandates-and-functions.
5
 These consultations, however, are primarily driven by regulatory
requirements and tend to become a one-time set of public meetings typically
revolving around environmental, technical and social concerns. As such, it
rarely extends in any meaningful way beyond the project-planning phase
(unless it concerns post-reclamation remedies for communities or sectors)
and is seldom integrated into PRA’s policy making processes or measured in
terms of its effectiveness in building constructive working relationships with
PRA’s stakeholders.7

Thus, despite previous efforts to “consult” stakeholders, PRA currently

does not have a well-established system for engaging and managing
stakeholders. Functionally, it does not have a unit, whether ad hoc or
independent, particularly in charge of this task, as evidenced by the
organizational chart above. While consultations have been held in the past,
engagement with stakeholders had been desultory and oftentimes ad hoc.8

7
Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging
Markets, International Finance Corporation (2007).
8
Interviews with PRA officers and staff. Note, however, that this has not always been the case. Prior
to its reorganization, the PRA (then PEA) had a department and public relations unit that had been
specifically tasked to interface with stakeholders and the public in general.

6
III. Rationale and Objectives of the SEMP

The absence of an institutionalized approach to stakeholder

engagement has affected public perception of the PRA and its mandate,
creating and propagating a widespread but mistaken belief that PRA exists
primarily for profit and is not concerned about the impact of its projects to the
environment, the affected communities and some sectors of the society (e.g.
fisher folk and urban/rural poor). To a large extent, this was triggered by the
negative publicity generated by the PEA-Amari controversy,9 the highly critical
statements of certain political personalities and civil society organizations and
certain groups that identify themselves as cause oriented but whose main
agenda is in reality to block, oppose and publicly campaign against any
reclamation project, regardless of its merits. A major contributor, however, to
this negative public perception is the absence of a system for engaging,
consulting and informing the PRAs stakeholders.

It is for this reason that this Stakeholder Engagement and Management

Plan (SEMP) was developed. It is envisioned that the SEMP will enable the
PRA to determine stakeholders’ concerns, issues and feedback and integrate
them into PRA’s decision-making process – i.e. all throughout the project
identification, implementation and post-reclamation stages. In addition, the
adoption of this SEMP is in line with PRA's commitment under the
Performance Agreement that it entered into with the Governance Commission
for GOCCs (GCG). 10 Part of said commitment is to integrate stakeholders’
concerns regarding reclamation projects, with the corresponding performance
indicator and institutional mechanism to determine said concern.11 The PRA
articulates its rationale for engaging stakeholders, as follows:12

A. Education/Information Awareness
 to inform the public of the benefits of reclamation projects
 to create/raise stakeholders' awareness and understanding of the
mandate of PRA
 to generate informed and positive opinion about PRA activities
 to build stakeholders' trust in the PRA
 to educate stakeholders on PRA processes when undertaking land
reclamation

9
In 2002, a case was filed against the PRA (called Philippine Estate Authority then) questioning the
Joint Venture Agreement it entered into with a group of foreign investors. The Supreme Court
declared that the land deal on and around Freedom Island in Manila Bay was null and void because it
was unconstitutional. The full text of the law can be found in Chavez vs. PEA and Amari Coastal Bay
Development Corporation G.R. No. 133250 (July 9, 2002).
10
The GCG is the central advisory, monitoring, and oversight body with authority to implement and
coordinate policies for the GOCC sector. See http://www.dbm.gov.ph/wp-
content/uploads/GAA/GAA2015/GAA%202015%20Volume%20I/OEO/K.pdf
11
Performance Agreement between the PRA and the GCG for CY 2015 (January 12, 2015).
12
PRA Stakeholder Engagement Workshop, October 13-14, 2015.
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B. Consult and Involve Stakeholders
 to determine/ find-out their concerns/issues about a project, and to
address these concerns/ issues
 to better understand stakeholders' interests regarding PRA’s
undertakings and consider them in the preparation of plans (e.g.
relocation plan, ground surveys, marketing plan and estates
management plan)
 to involve stakeholders in the decision process and other relevant
activities to establish a sense of shared responsibility in ensuring that
the project is socially, environmentally, technically and financially sound
 to enable the PRA to produce well informed policies and decisions
 to institutionalize stakeholder engagement both as a mindset and as a
mechanism
 to establish better working relations with the stakeholders and in the
long term win their support
 to integrate stakeholders' views/perspectives in reclamation projects

C. Ensure project success

 to mitigate, minimize, and reduce, if not totally eliminate, opposition to
reclamation projects
 to facilitate a more expeditious approval process/avoid delays in project
approval and implementation
 to determine at the soonest possible opportunity the feasibility of the
project given the various issues of the stakeholders
 to address the concerns of stakeholders for a smooth and speedy
implementation of the project

In the implementation of the SEMP, the PRA will be guided by the

principles of commitment, integrity, respect, transparency, inclusiveness and
trust.13

PRA SEMP Guiding Principles

 Commitment is demonstrated when the need to understand, engage
and identify the community is recognized and acted upon early in the
process.
 Integrity occurs when engagement is conducted in a manner that
fosters mutual respect and trust;
 Respect is created when the rights, cultural beliefs, values and
interests of stakeholders and neighboring communities are
recognized;
 Transparency is demonstrated when community concerns are
responded to in a timely, open and effective manner;
 Inclusiveness is achieved when broad participation is encouraged
and supported by appropriate participation opportunities; and
 Trust is achieved through open and meaningful dialogue that
respects and upholds a community’s beliefs, values and opinions.

13
Stakeholder Research Associates Canada Inc, 2005, The Stakeholder Engagement Manual Volume 1:
The Guide to Practitioners’ Perspectives on Stakeholder Engagement,
www.StakeholderResearch.com.
8
IV. Stakeholders Identification and Analysis

A. Definition of Stakeholders
For purposes of this SEMP, a stakeholder is any group or individual
who can affect, or is affected by, an organization or its activities. It includes
any individual or group that can help define value propositions for the
organization.14 In identifying its stakeholders, PRA includes all locally affected
communities or individuals and their formal and informal representatives,
national or local government authorities, politicians, religious leaders, civil
society organizations and groups with special interests, the academic
community, or other businesses.15

B. Identification of Stakeholders

The following have been identified as PRA stakeholders because of one or

all of the following reasons:
a. they are affected directly or indirectly by reclamation and related
projects of the PRA;
b. they have interests in a PRA project or activity
c. they have the ability to influence the project’s outcome, either positively
or negatively.

Priority Stakeholders of the PRA

Stakeholder Reason/s
1. The Office of the  Can influence outcome as it gives the final
President/ NEDA approval to a reclamation project
Board
2. DENR  Has interests in reclamation projects' compliance
with environmental laws and regulations
 has the power to issue clearances, permits and
licenses in the pre, during and post reclamation
phase of a reclamation project
 can influence project outcome

3. Clearance  The timely or delayed issuance of license can

Agencies (DOT, affect the outcome of the project
DOH, BFAR, PPA)
4. LGUs  They are proponents of reclamation projects
most of the time.
 Can support or oppose a reclamation project
located in their territorial jurisdiction.
 Can greatly affect project timetable and outcome

14
The Stakeholder Engagement Manual Volume 1: The Guide to Practitioners’ Perspectives on
Stakeholder Engagement, UNEP and Stakeholder Research Associates Canada Inc, (2005)
www.StakeholderResearch.com.
15
Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging
Markets, International Finance Corporation (2007).
9
5. Government  Delay in funding has impact on project
Financial construction and implementation and in meeting
Institutions financial obligations of PRA

6. Informal Settlers/  Lives and livelihood are affected directly or

Affected indirectly by reclamation projects of the PRA;
Communities/  Can delay project through the filing and pursuit of
Fisher folk court actions – e.g. application for Writ of
Kalikasan

7. COA  Adverse audit findings can delay the

implementation of a project

8. Media, political  Can shape/affect public opinion and generate

personalities and public support or opposition to a proposed or
Opinion makers ongoing reclamation project.

9. Business Sector  Business interests may be affected directly or

indirectly by reclamation projects of the PRA

 Can provide support or delay implementation of

projects through legal maneuverings

10. Other government  Can pose jurisdictional issues on who has

agencies’ with authority to reclaim
mandate to  Can make it difficult for PRA to ensure a
reclaim nationally coordinated, economical and efficient
reclamation of lands

11. Church/ Interest  Can effectively shape public opinion

and Environmental  Can delay or stop the implementation of a
Groups reclamation project through legal and political
acts

12. SC and the  Can stop a project through judicial environmental

judiciary remedies such as the issuance of a Temporary
Environmental Protection Order (TEPO) and
ultimately a Writ of Kalikasan

13. Contractors  Can delay completion of project due to non-

compliance or mere partial/sub-compliance with
contractual undertakings

14. DPWH  Can also pose jurisdictional issues against PRA

and compromise efficiency of project
implementation
 Can delay pre reclamation activities

15. DOTC  Can affect PRA’s project targets and income

10
 generation because of projects with a transport-
facility element
 Has interest in specific reclamation components
of infrastructure projects that are within its
mandate

16. GCG  As the central advisory, monitoring, and oversight

body with authority to implement and coordinate
policies for the GOCC sector, can stop or delay
the implementation of reclamation projects;
 Has a major say on the grant of employee
incentives for GOCCs depending on agency
performance

17. Motoring public  Can initiate anti PRA sentiments and file legal
(toll ways) actions.

C. Stakeholder Analysis and Mapping

The PRA conducted stakeholder analysis to examine the extent of

stakeholders’ ability to influence PRA’s process and outcome, especially in
project identification, implementation and post reclamation activities. The
analysis also rated the support or opposition of the stakeholders using the
following criteria:

RATINGS FOR POWER AND SUPPORT

POWER 5: High Capacity to formally and informally instruct change/damage
reputation/disrupt process
4: High Capacity to formally instruct change/damage reputation/disrupt
process or Significant informal capacity to cause change, may have
input/influence to
decision-makers/regulators
3: Some capacity to formally instruct change; must be consulted or has to
approve
2: Significant informal capacity to cause change, may have
input/influence to
decision-makers/regulators
1: Relatively low levels of power; cannot generally cause much change
SUPPORT 5: Active Support: Provides positive support and advocacy for the
plan/decision/company
4: Passive Support: Support but not actively advocating
3: Neutral: Is neither supportive nor opposed
2: Passive Opposition: Will make negative statements/have negative
opinion on
plan/decision/company but will not do anything to affect its success and
failure
1: Active Opposition: Is outspoken against plan/decision/company and
may even
11
 act to promote failure and affect success

Source: Bourne, L. and Weaver, P. Construction Stakeholder Management.

Blackwell Publishing, London, 2010.

Based on the power – support ratings, a stakeholder map was drawn to

provide an easy guide for designing the appropriate stakeholder engagement.
The map is divided into 4 basic engagement strategies – mitigate
impact/defend against (for stakeholders with high power but low support),
monitor (for stakeholders with low power and low support), collaborate with
(for stakeholders with high power and high support) and
involve/empower/secure interest (for stakeholders with low power but high
support).

12
PRA Stakeholder Map

13
V. Stakeholder Engagement and Management Program

The stakeholder analysis presented above was used as the basis for
formulating the appropriate engagement and management strategy. 16

A. Mitigate impact/defend against

The PRA needs to mitigate impact/defend against the affected
communities and sectors such as informal settlers and fisher folk, political
personalities that are known for their stand against the agency and against
reclamation (both project-specific and reclamation in general) and the DOF for
its varying view on the mandate of the PRA. The media and opinion makers
should also be monitored as they can be either an ally or opposition. These
stakeholders are critical because they have high power and yet are perceived
to be not supportive of PRA and of reclamation.

Stakeholders to Defend Against/Mitigate Impact

Stakeholder Stage of Level/s of Objectives of Engagement
Engagement Engagement Engagement Strategy
Affected Pre, during  Monitor  To be aware  Engage in
communities and post  Inform of their consultation,
and sectors reclamation  Consult concerns public
(All stages)  To inform meetings and
them of the consensus-
parameters of building
the project  Organize
and to give livelihood
them an trainings and
opportunity to seminars
comply with  At times and
the relevant when able,
laws, rules provide initial
and funding
regulations support for
 To assure livelihood
them that their initiatives
livelihood will  Systematize/I
not be nstitutionalize
detrimentally documentatio
affected n and use of
success
stories and
testimonials in
favor of
reclamation
 Consult best
practices on
parallel CSR
16
For a more detailed explanation of the different levels of engagement, please refer to Annex “A”.
14
 of other
agencies

Political All stages  Inform  To make sure  Public

Personalities they are well consultations,
informed of meetings,
the measures letters,
being conferences,
implemented press
by the PRA to releases
address  Expert studies
environmental
, social and
economic
issues as well
as livelihood
concerns of
affected
communities
 To assure that
PRA
exercises
corporate
social
responsibility
in undertaking
its mandate

Media and All stages  Monitor  To make sure  Monitor media

Opinion  Inform that print and mentions;
Makers broadcast  Accommodat
media are well e interviews
informed of  Release
the measures official
being statements
implemented  Develop an
by the PRA to institutionalize
address d
environmental communicatio
, social, n strategy
economic and
livelihood
concerns
 To assure that
PRA
exercises
corporate
social
responsibility
15
 in undertaking
its mandate
 To seek the
assistance of
the media in
informing and
enlightening
the public
about
reclamation
projects and
their
concomitant
issues

Other Pre  Consult  To ensure  Submission of

government reclamation that the proposals,
agencies with relevant OGA plans,
mandate to complies with specifications,
reclaim all the letters
technical and  Make project
environmenta presentations/
l meetings
requirements  Identify,
for a clarify &
reclamation categorize
project nature of
 To advocate involvement
for legally and authority
required in reclamation
consultation projects
with PRA for  Ask NEDA for
reclamation clear policy
projects/recla direction
mation regarding
components relationship
of a project with OGAs
undertaken that have the
by these right to
agencies reclaim in the
context of
PRA’s role
and mandate
under EO 525
Department of Pre and during  Inform  To inform the  Promptly
Finance reclamation  Transact department submit well-
 Collaborate of the full researched
merits of the letters that
project as are
16
 well as the responsive to
potential any issue/s
revenues/divi that may be
dends raised
 Engage in a
dialogue to
clarify orders
and issues
that have
been and will
be issued
and raised

B. Collaborate with
The PRA has to continue collaborating with the following agencies
because they are fully supportive and have the power and/or influence to
impact PRAs work, either positively or negatively. They include the following –
proponent and affected LGUs, the Office of the President/NEDA, private
sector proponents, DENR and its attached agencies, GCG, LRA, COA, SC
and DOJ and its attached agencies.

Stakeholders to Collaborate With

Stakeholder Stage of Level/s of Objectives Engagement
Engagement Engagement of Strategy
Engagement
LGU All stages  Collaborate  To ensure  Enter into MOA
proponents  Involve that the with LGU
 Transact project  Conduct Public
receives the Hearing in
full support partnership with
of the the LGU
proponent  Meetings
LGU  Consultations
 To ensure  Project
that the Presentation
proponent  Clarify PRA’S
LGU clearly Position on EO No.
understands 146
and shares
the
responsibilit
y for the
successful
implementat
ion of the
project

17
Office of the Pre  Collaborate  To convince  Detailed
President/ reclamation the NEDA presentation of the
NEDA Board Board of the technical merits of
merits of the project and of
PRA’s PRA’s
proposed recommendations
projects and at the ICC and
its INFRACOM level
recommend  Engage in
ations dialogues,
concerning consultations and
said meetings
projects concerning
 To ensure reclamation issues
that all and policies
queries and
issues
raised are
addressed
promptly
and
comprehens
ively

GCG All stages  Transact  To  Meeting

 Collaborate continuousl  Consultation
 Inform y  Negotiation
 Consult demonstrat
e the role
and value of
the PRA in
socio-
economic
developmen
t
 To ensure
that PRA
complies
with its
obligations
under its
Performanc
e
Agreement
with the
PRA
 To ensure
that PRA
employees
18
 are
incentivized
through the
benefits on
time
 To ensure
continuous
operation of
the PRA

DENR All stages  Transact  To convince  Enter into joint

 Involve the DENR issuances/actions
 Collaborate of the (e.g., Orders,
environment MOAs, etc.) on
al and matters of shares
technical responsibility/juris
soundness diction
of the  Undertake more
proposed PR initiatives
project  Ensure the quality
 To assure of technical
DENR that studies submitted
PRA always  Undertake more
complies coordination
with the initiatives, to have
legal, face-to-face
environment meetings
al, technical  Undertake joint
and activities (e.g. joint
regulatory ocular
requirement inspections)
s of  Establish a
reclamation database that
projects contains the
 To find a profile of key
way for the personalities
expeditious
processing
and
issuance of
permits and
clearances

COA Post  Transact  To assure  Undertake pre-

transactions  Consult COA that transaction
 Involve the PRA consultations and
always meetings in line
complies with COA’s
with advisory capacity
19
 government
accounting
rules and
regulations
as well as
with post-
audit
findings of
the body

Private All stages  Remain  To ensure  Hold meetings

sector/ passive that the with affected
Business planning business/industry
proponents process representatives
includes
impact
assessment
concerning
affected
business
community

Supreme All stages  Remain  To  Hold case

Court and passive anticipate conferences within
lower courts legal issues the office and with
concerning partners
a project
and ensure
that the
legal
aspects of
all projects
are
thoroughly
reviewed
 To ensure
that all
pleadings
filed with
the court
are well
researched
DOJ and All stages  Consult  To obtain  Seek official legal
attached official opinions as the
agencies government need arises
guidance on
legal issues
concerning
a project
20
C. Empower, Involve, Secure Interest
The PRA needs to involve or empower or endeavor to seek the interest
of the following stakeholders because they can be effective allies – the
clearance agencies (the DOT, DOH, BFAR, PPA, DPWH), TRB and toll way
operators, MMDA, PAGCOR and the BIR.

Stakeholders to Empower, Involve, Secure Interest

Stakeholder Stage of Level/s of Objectives Engagement
Engagement Engagement of Strategy
Engagement
Clearance Pre and Post  Transact  To assure  Letters
Agencies - Reclamation these  Conduct of joint
DOT, DOH, agencies ocular Inspection
BFAR, PPA, that PRA  Meetings
DPWH always
complies
with
regulatory
and
administrati
ve
requirement
s for the
issuance of
clearance
and permits
 To establish
a good
working
relationship
and rapport
as well as a
good
coordinating
mechanism
with these
agencies
 To make
these
agencies
aware of the
importance
of the
speedy
issuance of
clearance
and permits
21
 for the
timely
implementat
ion of
projects

TRB/ Toll All stages for  Transact  To ensure  Letters

Operators toll road  Collaborate the smooth  Meetings
projects  Meeting operation of  Consultations
toll roads  Surveys
 To avoid
getting the
blame for
TRBs
actions.

DOTC, All stages for  Transact  To ensure  Enter into formal

MMDA, some  Collaborate that the contracts and other
PAGCO projects that  Involve DOTC/MMD agreements
also concern A/PAGCOR  Engage in
these clearly consultations and
agencies understand dialogues
the
mandate
and
authority of
the PRA
 To ensure
that the
DOTC/MMD
A/PAGCOR
understand
and are
prepared to
share the
responsibilit
y for the
successful
implementat
ion of the
project.
BIR Post  Inform  To assure  Submit reports
development the BIR that  Hold meetings
the PRA
complies
with
reportorial
requirement
s and
22
 proper and
correct
taxes are
remitted

GFIs, JV Pre  Transact  To assure  Hold meetings and

Partners, reclamation investors consultations
Banks and other  Enter into formal
sources of contracts and
financing agreements
from the
government
and private
sectors of
the
financial,
technical
soundness
of proposed
project
 To assure
sources of
funding that
PRA is able
to and will
comply with
lending
terms and
conditions
 To assure
that PRA
complies
with
environment
al laws,
rules and
regulations
 To assure
that PRA
exercises
corporate
social
responsibilit
y in
undertaking
its mandate
MMDA, All stages  Transact  To ensure  Hold meetings and
PAGCOR  Collaborate effective consultations
 Involve coordination Enter into formal
23
 for income- contracts and
generation agreements
purposes

D. Monitor
At present they are not considered to be powerful or influential enough
to affect PRAs operations and project. However, the following stakeholders
need to be monitored as they have the potentials for negatively or positively
affecting the operations of the PRA. Some of these stakeholders can also be
negatively or positively affected by PRAs reclamation projects – the church,
interest groups, NGOs, illegal reclaimers and land grabbers/informal settlers.

Stakeholders to Monitor
Stakehol Stage of Level/s of Objectives of Engagement Strategy
der Engage Engageme Engagement
ment nt
Church All stages  Inform  To assure the  Regular and prompt
 Monitor Church that the issuance of press
 Consult PRA takes into releases as the need
account the effect arises;
of its project on  Develop position
affected papers and draft
communities/famil letters to respond to
ies in its planning issues raised and
and present the same to
implementation the relevant
and the forum/fora;
environment.  Conduct informal
 To assure the dialogue with key
Church that the church personalities
PRA implements and officers of the
mitigating Bishops-
measures to Businessmen’s
ensure that the Conference of the
concerns of Philippines (initially)
affected
individuals/sectors
are properly
addressed and
resolved
 To inform and
educate the
Church about the
importance of
PRAs work and
the benefits that
can be derived
24
 therefrom

Interest All stages  Involve  To assure them  Hold public

Groups/ that the PRA consultations
Environm takes into account  Issue press releases
entalists in its planning and  Organize public
implementation forum/fora
the effect of its  explore partnership
project on opportunities with
affected identified critics
communities/famil
ies/sectors, as
well as on the
environment
 to assure that the
PRA implements
mitigating
measures to
effectively
address the
concerns of those
affected
 To inform and
educate these
groups about the
importance of
PRA’s work and
the benefits that
can be derived
therefrom
 To make sure
they are these
groups are
properly informed
of the relevant
issues
 To minimize
opposition to
projects and to
prevent delay
caused by
misinformed
opinion about the
merits of the
project

Senate All stages  Inform  To assure  Submit letters,

and Congress that position papers
House of PRA complies  attend congressional
25
Represent with all laws and hearings
atives regulations, that it  Designate a
takes into account legislative liaison
social and officer
environment  Prepare expert
concerns in its studies for possible
planning and presentations
implementation of
projects by
promptly
informing both
Houses of PRA’s
positions,
comments and
recommendations
on issues
affecting the
agency and its
projects

Technical All stages  Involve  To ensure that  Hold meetings

Experts  Collabora they are clear of  Hold consultations
te the importance of  Organize workshops
their work in
ensuring the
technical viability,
feasibility and
acceptability of
projects

Land Pre Passive  To make them  Undertake the prompt

grabbers/ reclamati aware that PRA filing of cases and the
illegal on will not tolerate initiation and pursuit of
reclaimers illegal activities other legal remedies

26
VI. Resources and Responsibilities

The PRAs long-term approach for the implementation of its SEMP is to

establish a unit (Community Relations) within the agency that will be tasked
with this function. It is envisioned that this unit will have properly trained
personnel on stakeholder engagement and management.

Given the urgency of the need to implement the SEMP, the PRA will in
the meantime engage a consultant/s to serve as the manager for stakeholder
engagement responsible for building and maintaining relationships with key
stakeholders. Incumbent personnel of the PRA will assist him in the
performance of the following tasks:
 Ensure that stakeholders are recognized as partners in the
development and implementation of PRA’s SEMP and other strategic
goals.
 Advise the General Manager and his Assistant General Managers on
issues and/or risks to stakeholder relationships as soon as they arise to
ensure that the risks are mitigated or managed properly.
 Implement the PRA SEMP and take an active role in carrying out the
stakeholder engagement activities in partnership with concerned
departments within the PRA (i.e., facilitating forums or consultative
events and liaising with appropriate stakeholder concerned)
 Ensure that the management and staff of PRA understand the value of
– and are committed to – the genuine participation of stakeholders in
the identification and implementation of reclamation projects.
 Develop a system for monitoring and evaluating the effectiveness of
the SEMP.
 Come up with indicators to evaluate the effectiveness of SEMP
strategies and revise them accordingly.
 Prepare and submit monthly, quarterly and annual reports on
stakeholder engagement activities.
 Assist in resolving the concerns and grievances that a stakeholder may
bring to the PRA.

VII. Grievance Mechanism17

The PRA will endeavor to address all the issues and concerns that will
be raised by stakeholders even before they become actual grievances.
Hence, the grievance process that the PRA will establish will not substitute for
its SEMP. When grievances arise, however, PRA will use its grievance
management system to address them. Hence, the SEMP and the grievance
management will be complementary and reinforces each other.18
The grievance mechanism will seek to address the concern or
complaint raised by an individual or group affected by the projects and
17
Patterned after the Grievance Management and Comment Response of the Stakeholder
Management Plan of Dundee Precious Metal (December 2014).
18
Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging
Markets, International Finance Corporation (2007).
27
policies of the PRA. These concerns and/or complaints may either be with
reference to a real or perceived impact of PRA operation/s (e.g. activities of
the PRA contractors, violations of the terms and conditions of the ECC, etc.)
but do not include a question or suggestion given to the PRA or project and/or
appeal or request for financial and other forms of assistance. The PRA is also
cognizant of the fact that some grievances raised by certain sectors cannot be
resolved because of their closed views about reclamation and/or when their
business interests are affected. In these instances, PRA will instead design
and implement a risk mitigation and management plan on case-to-case basis.

In developing the grievance mechanism, the PRA will be guided by the

following objectives:

 To provide stakeholders with a clear process for providing comment

and raising grievances;
 To allow stakeholders the opportunity to raise comments/concerns
anonymously through using the community suggestion boxes to
communicate;
 To structure and manage the handling of comments, responses and
grievances, and allow monitoring of effectiveness of the mechanism;
and
 To ensure that comments, responses and grievances are handled in a
fair and transparent manner, in line with PRAs internal policies,
international best practice and lender expectations.
The indicative steps for submitting and resolving grievance will include
the following:

1. Submission of the complaint/grievance to the PRA

 Submission of grievance will be made easy and accessible
 Can be done during consultation or public hearings
 Appropriate templates for reporting comments, complaints will
be developed and made available
2. Logging the comment and creation of a grievance register
 PRA will establish and maintain a grievance database register
 All grievances that have been filed will be entered into the
database
 The database will be monitored by the General Manager and
regular reports will be submitted to the Board of Directors
3. Determination if it is a valid grievance
 Complaint will then be initially assessed by the SEMP manager
to determine if it is a valid complaint
 Suggestions, comments and requests for financial help are not
considered grievance
 Complaint for damages because of ongoing activities is a valid
grievance
 Non-compliance with the ECC terms and conditions is a valid
grievance
4. Providing the initial response
28
  The person/community/stakeholder that lodged the initial
grievance will then be contacted within 7 days to acknowledge
that the PRA has received his grievance.
 If not considered as a grievance, appropriate response will be
given

5. Investigating the grievance

 Grievance will be investigated, which should be completed
within reasonable period of time from the time of receipt of
complaint and depending on its nature
6. Resolving the grievance
 The person/community/stakeholder of the results of the
investigation and If the investigation warrants it, appropriate
measures will be implemented to address the grievance
7. Taking further steps if the grievance remains open
 If the grievance continues to persist, the SEMP manager will be
tasked further investigation to determine additional steps to be
taken.

VIII. Monitoring and Reporting

The PRA has an existing system for monitoring the implementation of

its projects. Such system will be expanded to include monitoring of the
implementation of the SEMP. In this regard, the PRA will develop measures
and indicators that will take into account the level of understanding of PRA’s
mandate by its stakeholders; the number of grievances it has received and
that have been addressed; and the level of stakeholder involvement in joint
activities, particularly from those that have been directly affected. One of the
major tasks of the consultant to be engaged is the development of the
monitoring and reporting system.

Quarterly and annual reports on stakeholder engagement activities will

be prepared and submitted to the Board and the GCG, if required. The
consultant will prepare and summarize the SEMP results. This report will
provide a summary of all public consultation issues, grievances and
resolutions. It will also provide a summary of relevant public consultation
findings from informal meetings held at community level. Copies of said report
will be provided to the General Manager and the Assistant General Managers,
and will thereafter be presented to the Board of Directors.

29
Annex “A”

Handout on Levels of Engagement19

Level Goal Communication Nature of Engagement Approaches
relationship
Remain No goal. No active No relationship Stakeholder concern expressed through
Passive No engagement. communication protest, letters, media, websites etc., or
pressure on regulatory bodies and other
advocacy efforts.
Monitor Monitor One-way: No relationship Media and internet tracking.
stakeholders’ stakeholder to Second-hand reports from other
views. company. stakeholders possibly via targeted
interviews.
Inform Inform or educate One-way: Short or long term Bulletins and letters. Brochures, reports
stakeholders. company to relationship with and websites. Speeches, conference
stakeholder, there stakeholders. and public presentations.
is no invitation to "We will keep you Open houses and facility tours. Road
reply. informed." shows and public displays. Press
releases, press conferences, media
advertising, lobbying.
Transact Work together in a Limited two-way: Relationship terms ‘Public Private partnerships’ and Private
contractual setting and set by contractual Finance Initiatives,
relationship where monitoring agreement. Grant-making, cause related marketing.
one partner directs performance “We will do what we
the objectives and according to terms said we would” or
provides funding. of contract. “we will provide the
resources to enable
you to do what we

19
The Stakeholder Engagement Manual: Volume 1: The Guide To Practitioners’ Perspectives On Stakeholder Engagement

30
 agree”.
Consult Gain information Limited two-way: Short- or long-term Surveys. Focus Groups. Workplace
and feedback from company asks involvement. assessments. One-to-one meetings.
stakeholders to questions and the "We will keep you Public meetings and workshops.
inform decisions stakeholders informed, listen to Standing stakeholder advisory forums.
made internally. answer. your concerns, On-line feedback and discussion.
consider your
insights, and provide
feedback on our
decision."
Involve Work directly with Two-way, or multi- May be one-off or Multi-stakeholder forums.
stakeholders to way between longer-term Advisory panels. Consensus building
ensure company and engagement. "We will processes.
that their concerns stakeholders. work with you to Participatory decision making
are Learning takes ensure that your processes.
fully understood place on both concerns are
and sides. understood, to
considered in Stakeholders and develop alternative
decision company take proposals and to
making. action individually. provide feedback
about how
stakeholders views
influenced the
decision making
process”.
Collaborate Partner with or Two-way, or multi- Long- term. Joint projects, voluntary two-party or
convene a network way between "We will look to you multi-stakeholder
of stakeholders to company/ies and for direct advice and Initiatives, Partnerships.
develop mutually stakeholders. participation in
agreed solutions Learning, finding and
and joint plan of negotiation, and implementing
action. decision making solutions to shared

31
 on both sides. challenges.”
Stakeholders work
together to take
action.
Empower Delegate decision New organizational Long-term. Integration of Stakeholders into
making on a forms of "We will implement Governance Structure. (eg. As
particular issue to accountability: what you decide.” members, shareholders or on particular
stakeholders. stakeholders have committees etc.)
formal role in
governance of an
organisation or
decisions are
delegated out to
stakeholders.

32