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TOWARDS A COMPREHENSIVE ENVIRONMENTAL POLICY:

SOME OPTIONS FOR POLICY INTEGRATION

Sustainable use of natural resources warrants more holistic, comprehensive management


strategies that take into account the interconnectedness of different biological ecosystems,
as well as their cascading effects on the economy and society as a whole. The Philippine
government has claimed to embrace sustainable development as an overarching framework
for its policies, including those dealing with environmental conservation and protection.
However, current management practices and policies in the Philippines are highly delimited
by conceptual, thematic and territorial divisions stemming from the traditional consumerist
worldview that society, economy and the environment are distinct entities.

This paper

identifies a number of gaps and issues in the current environmental policy framework in the
Philippines, focusing on the sectoralization and fragmentation of different policies.
Consequences of these policy gaps for the management of different resource areas (e.g.
forests, fisheries, biodiversity, resource extraction, etc.) will also be discussed. Lastly, the
paper will propose some options and possibilities for cooperation, coordination and
integration of different sectoral policies to pave way for a more comprehensive, integrative
environmental policy framework.

Introduction
In the recent decades, the paradigm shift from economic development to sustainable
development has been widely recognized. The Brundtland Report (Brundtland, et al., 1987)
first articulated and promoted the concept of sustainable development, which involves
addressing the needs of the present without forgoing the needs of the future generations
(p.16).

The report stressed the need for integrating political action and adopting shared

responsibilities to achieve such a goal. Since then, governments around the world have
begun refocusing their development priorities from economic growth to human security.

Quental, Lourenco, & da Silva (2011) described the emergence of sustainable development
policies, which identified sustainable goals, targets and strategies promulgated by cycles
upon cycles of political activities. In the environmental policy arena, this involved a shift from
pollution control and resource conservation, to a more integrative outlook and approach that
focuses on human development (Quental, et al., 2011).
The interest in sustainable environmental management corresponds to the growing
awareness of the multiple uses and values of the environment.

Ecological benefits or

services include provision of basic needs, regulation of biological and nutrient cycles,
preservation of ecological balance, and strengthening of culture and heritage, among others
(Malayang, 2004).

Moreover, the said paradigm shift is also parallel with the growing

realization of the devastating, and often long-term impacts that environmental degradation
has especially on the poor, who largely depend on the countrys natural resources for
survival. Among those included in the long list of environmental problems are: pollution in
urban areas, solid waste problem, water scarcity, deterioration of land quality, threatened
biodiversity, threatened coastal and marine resources, and uneven distribution of benefits
derived from mineral resource extraction. There is also the ever-increasing threat of climate
change impacts, especially on communities with poor adaptive capacities (NEDA, 2011).
These concerns transcend social, economic and political boundaries, thus making it more
imperative to move towards integrated environmental management policies.
The need for a comprehensive environmental policy had long been acknowledged by
the Philippine government, even before the Brundtland Report came into being. By way of
the Philippine Environmental Policy (Presidential Decree (PD) 1151) and the Philippine
Environmental Code (PD 1152) enacted in 1977, the government recognized the link
between society and the environment, and the importance of coordinating and integrating
environmental conservation efforts. Consequently, the said policies provided legal framework
to address long-term resource needs and ensure environmental quality essential for survival
and welfare of the present and future generations. These policy goals were carried over to

and elaborated by succeeding strategic plans of the government, such as the Philippine
Agenda 21 and the current Philippine Development Plan (PDP). At present, one of the main
development outcomes being targeted by the Philippine government through the PDP 20112016 is the attainment of sustainable and climate-resilient environment resources,
particularly by building the adaptive capacities of communities to climate change impacts;
promoting sustainable natural resource management; and further ensuring environmental
quality (NEDA, 2013, p. 207). Then again, the greater challenge of the government is how
to integrate different interconnected environmental processes that are more or less
geographically or temporarily separate from one another. Aside from this, of course, the
government has to accommodate conflicting interests of the policy stakeholders, which
would be difficult, if not nearly impossible, under the current institutional and technical setup.
As promising as policy pronouncements are on environmental management, the
existing context under which current Philippine environmental policies are being
implemented does not make for a comprehensive approach. The mid-term assessment of
PDP 2011-2016 considered policy fragmentation as one of the main policy challenges in the
environment and natural resources arena.

In particular, the report highlighted, among

others, the lack of comprehensive land use policy, inadequate sustainable use policies, and
conflicting government mandates (NEDA, 2013).
Owing to geographical and temporal limitations, environmental policies in the
Philippines have been characterized as highly sectoral, localized and island-based (Revilla,
2014). Environmental laws have mainly been designed to tackle environmental concerns
per sector, e.g. forestry, fisheries, minerals, biodiversity, solid waste, air and water quality,
among other areas. Aside from this, social policies that pertain to people and environment
are also highly differentiated (Malayang, 2004).

The effects of resulting policy fragmentation tend to trickle down into the specific
programs and projects, which adopt different conservation requirements, user rights,
environmental plans, and management strategies, among others.

This is where

fragmentation becomes a problem. Cagalanan (2015) explained that there are a wide range
of institutions operating at different hierarchical levels. These include transnational
funding/conservation organizations, the central government, provinces, protected areas,
local government units (LGUs), barangays, peoples organizations, and households.
Because each of them is managed differently, there is a tendency for environmental policies
emanating from these agencies to overlap with one another and complicate or dampen
environmental management efforts on the ground. Malayang (2004) and La Via (2014)
both asserted that while sectoral policies on environment and natural resources have had
considerably addressed a number of environmental problems, such as deforestation and
mining, these developments were rather sporadic, localized, and in pockets. This had been
attributed to unclear mandates and avenues for coordination of policies, agencies and
stakeholders; disconnected priorities and action plans; inconsistent targets; and loss of
political potency (La Via, 2014).
Steurer (2007, p. 206) further enumerated a number of factors that make integration
of different sectoral policies difficult, as follows:
1) Difficulties in communicating the relative abstract and complex concept of
sustainable development to politicians and to the public;
2) Serious lack of high-level political will, leadership and sustained commitment;
3) Common dominance of economic interests over environmental and social
interests;
4) Lack of interest and ownership in non-environmental and social ministries or
departments; and
5) Lack of personnel and budgetary resources for achieving the objectives
formulated in sustainable development strategies.

In addition, policy fragmentation may also result when policymakers feel an urgent
need to address an immediate problem, but have limited time and resources to carefully
coordinate and negotiate policy actions among different implementing agencies (Waisman
Center, 2014). Cruz (2014) opined that it would be very difficult to harmonize policies when
there are no mechanisms to ensure synergy and coordination of different policies and
programs.
From a philosophical perspective, according to Salvador (n.d.), environmental
governance in the country has continued to assume a worldview that man prevails over the
environment, and is rationally driven by the tendency to consume and develop. As such,
instead of adopting a holistic view that links the environment with politics, society and
economics, most policies in reality maintain a divide between these supposedly interrelated
elements, with economy dominating all others (Giddings, Hopwood, & OBrien, 2002). In
their study on wetland conservation in Europe, Amezaga & Santamaria (2000) likewise
pointed out that, by treating natural resources as conceptually and territorially distinct from
the non-natural sphere, the government is actually encouraging the divide between
supposedly interrelated social and environmental processes that affect ecological systems.
This approach to environmental policy weakens legal protection and enhances
environmental degradation (Amezaga & Santamaria, 2000).
The problem with this outlook is that negative externalities and losses resulting from
environmental degradation may not be compensated for by economic gains alone.

As

Giddings, et al. (2002) wrote:


How does money compensate an animal for its loss of habitat or a tree for
acid rain? In a similar way there are many social externalities that
business does not pay for, such as unemployment, a loss of community
and damage to health . . . material reality is that economy is dependent
on society and the environment (p.190-191)

The following section shall make a case that even with adequate legal protection,
conflicting and overlapping policies as well as implementation mechanisms could undermine

existing initiatives to protect and manage natural resources. A review of the current status in
Protected Areas (PAs) as well as the policy framework protecting these areas will be
discussed, and how policy conflicts and overlaps indirectly affected conditions in
(theoretically) protected natural landscapes.

Degradation amid legal protection: The case of the protected areas (PAs)
A number of policies offer legal protection for much of the countrys forests and seas. This is
mainly through RA 7586 or the National Integrated Protected Areas System (NIPAS) Act of
1992. Aside from this, thirteen PAs have been further protected via specific RAs that follow
the NIPAS mandate, while others had been granted protection through Presidential
Proclamations, and LGU- or community-level proclamations (NEDA, 2011). On top of these
policies, a set of executive issuances and administrative orders have been issued to lay
down the guidelines for implementation of the national mandates on protected areas
management (NEDA, 2011).
As of date, there are around 240 PAs under NIPAS, five of which were named as
Association of Southeast Asian Nations (ASEAN) Heritage Natural Parks. In sum, these
protected areas account for around 5.45 million hectares (or 14.20%) of total area. Recently,
additional NIPAS sites were declared, such as the Mt. Mantalingahan Protected Landscape,
Aliwagwag Falls Protected Landscape and Caracand Watersheds (DENR-BMB, 2014).
Around 26% of forestlands in the country are situated within PAs, while marine PAs cover
around 22,540 square kilometers (NEDA, 2011; DENR-BMB, 2014).
Despite the considerable level of protection given to these protected areas, the
impact of such legal protection on the conservation and sustainable management of natural
resources remains wanting. The 2012 Philippine Forestry Statistics noted a decrease in
closed canopy forests from 2.56 million hectares in 2003 to 1.93 million hectares in 2010,
indicating that despite a plethora of environmental policies, forest ecosystems still face

threats by human activities such as logging, slash-and-burn agriculture or kaingin. These


validate the results of a 2014 study of DENR-BMB and GIZ GmbH on protected areas in the
country, which highlighted the poor management of protected areas. Assessment of 61
terrestrial PAs revealed an overall rating of only 58% (Guiang & Braganza, 2014). Worse,
none of the PAs complied with international standards for protected area management.1
Meanwhile, only 10-15% of the 1,300 MPAs in the country were considered effective,
with the rest either unmanaged or nonfunctioning MPAs were largely determined by LGUs,
and almost half of the nine key marine corridors in the country were not designated as
protected areas. As such, initiatives for coastal/marine resource management were mainly
localized and sporadic (NEDA, 2011). The lack of a well-coordinated data gathering and
monitoring mechanism was also pointed out by La Via (2014), making it difficult for the
government to oversee conditions and implement evidence-based policies to further protect
MPAs.
The 2014 DENR-BMB and GIZ GmbH report pointed out uneven levels of legal
protection for the sites studiedonly four were protected by Republic Acts, while 57 were
only protected by Presidential Proclamations.

This indicates that not all PAs receive

adequate funding. Most PAs were not incorporated into the Comprehensive Land Use Plans
(CLUPs) of LGUs that have political jurisdictions over the said areas. The Protected Area
Management Bureaus (PAMBs) were also faced with the challenge of harmonizing the
overlapping uses, claims and boundaries of land and resource use within the PAs. Morover,
the report noted that local conservation efforts contributed only little to economic growth
(Guiang & Braganza, 2014).
The case of protected areas management is but one of the indications that
sectoralized and fragmented policies would fall short of attaining a sustainable and climate1 PHL protected areas are poorly managed, intl study reveals. GMA News
Online. 16 January 2014. Retrieved 6 December 2015 from
http://www.gmanetwork.com/news/story/344152/scitech/science/phl-protectedareas-are-poorly-managed-int-l-study-reveals

resilient environment and natural resources, as espoused by the government through the
Philippine Development Plan 2011-2016. This example provides that simply delineating
protected areas is not enough, and that other interrelated policies that govern physical and
biological factors, sustainability of resource extraction practices, careful planning and proper
use of funds, social participation, and valuation of natural resources, among others, need to
be considered to ensure a more sustainable, comprehensive environmental policy.

Overview of environmental policies in the Philippines


A rundown of past and present environmental protection in the Philippines reveals that
policies have inherently been fragmented and sectoralized.

In the past, no single

government agency handled environmental protection and conservation in the Philippines.


This was rather part of the mandate of different agencies (e.g. health, agriculture, natural
resources, public works, housing, etc.). In 1964, the National Pollution Control Commission
(NPCC) was established to regulate air and water quality (Pascual, 2005). Meanwhile, the
Philippine Environmental Policy and the Philippine Environmental Code (PD 1151, PD 1152)
finally articulated the need for a comprehensive law for environmental conservation and
management. The former created the National Environmental Protection Council (NEPC) as
the main policymaking body, and first initiated standards for Environmental Impact
Assessment (EIA) in the country. Meanwhile, the Philippine Environmental Code included
specific guidelines and standards for air and water quality management, land use
management, natural resources management and conservation, waste management and
cross-cutting strategies that tackled education, research, information dissemination,
incentives, and funding, among other functions.
While these two policies provided for a comprehensive framework on environmental
management, much of the provisions were generic and specific legal rights were not detailed
in the said policies. In 1996, the Congress began revising the Philippine Environmental Code

to clarify how a comprehensive approach could be implemented. Initially, an alternative was


to assimilate regulatory requirements for EIA, Air and Water Quality Management, Waste
Management,

Environmental

Adjudication

Commission

and

Natural

Resources

Management. However, lack of funds and the considerably large scope of the proposed
Code stalled policy integration efforts, and instead led the government to formulate several
Acts, according to sector (Pascual, 2005).

Table 1 lists important policies dealing with

different subsectors in the environment and natural resources arena, as well as the present
strategies and challenges for each policy response.
As what can be gleaned from Table 1, there is rather a huge set of environmental
policies tackling different subsectors, and each of these subsectors confront various policy
gaps. However, aside from these policy gaps, an even more daunting task for the
government is how to tie piecemeal policies together to address broader and more complex
environmental problems. The Philippine Development Plan 2011-2016 recognized that a
number of environmental policies are indeed conflicting and overlapping with each other and
with other non-environmental policies.
A case in point is between forestry laws, on one hand, and the Agriculture and
Fisheries Modernization Act (AFMA) on the other. While forestry laws, specifically the
Revised Forestry Code (PD 705), serve to protect forestlands from further degradation,
AFMA encourages agricultural expansion, even into the uplands, by creating Strategic
Agriculture and Fisheries Development Zones (SAFDZs) that encourage cultivation of highvalue crops. This creates negative externalities for the forest ecosystems that PD 705 is
trying to conserve (NEDA, 2011).

Table 1. Philippine environmental policies across different subsectors


Subsector
Policy Responses
Strategies/Outputs

Challenges

Solid Wastes

Technical assistance on closure, rehab


of dumps (1,325 LGUs), and on
establishment of sanitary landfills (236
LGUs)

Inventory of chemical substances


developed (PICCS) listing 38,000 legally
allowable substances

97 EPEPs, 23 FMR/DPs, 387 SDMPs


Around 400 five-year SDMPs
benefitting 700 barangays
Mining forest program (79 mining
companies reforesting/afforesting 10,319
ha of disturbed areas)
More than PhP330 m royalty payments
to IPs
Assessment, rehab of eight (8) inactive
mines nationwide
Reforestation of 78,000 ha of forest
lands from 2004-2010 (60% of target
130,000 ha)
Contribution of NGOs in reforestation
amounts to 30%
Forest boundary delineation completed
for more than half (41/78) of target
provinces
11.6 million ha of forest with forest

Toxic Wastes

Mineral
resource
extraction
(mining)

Degradation of
forest lands

RA 9003 (Ecological Solid


Waste Management Act of
2000)

RA 6969 (Toxic
Substances and
Hazardous and Nuclear
Waste Control Act of
1990)
RA 7942 (Philippine
Mining Act of 1995), PD
1899, RA 7076(Smallscale mining programs),
EO 79 (2012) (Policies
and guidelines for
responsible mining,
creation of Mining Industry
Coordinating Council)

PD 705 (Revised Forestry


Code), reforestation
programs (e.g. NGP), EO
263 (CBFM), IPRA

838 open dumpsites, 396 controlled


disposable facilities need closure,
rehab
20.9% of LGUs with solid waste
management plans
Lack of equipment, expertise to
handle toxic wastes
Regulation and enforcement
responsibilities yet to be defined
Mining Act overlaps with other
national and local policies
Parameters for assessing economic
valuation of environment and natural
resources (for cost-benefit analysis of
mining projects) are being questioned
by different sectors, groups
Lack of transparency in mining
contracts
PD 705 is obsolete
No policy for sustainable forest
management has yet been legislated
Few protected areas declared by
communities even with available
forest tenurial instruments
Challenge of sustainability after
planting trees under NGP
(maintaining planted trees)

Subsector

Policy Responses

Strategies/Outputs

Challenges

tenurial instruments (2010)


350,321 ha under NGP as of 2012

Table 1 (continued).
Subsector

Policy Responses

Strategies/Outputs

Challenges

Biodiversity

RA 7586 (NIPAS Act of


1992), RA9147 (Wildlife
Resources Conservation
and Protection Act), RA
9072 (Cave and cave
resources management),
National Wetlands Action
Plan 2011-2016, DENR
MC 2007-04 (cave
classification), Cave
Strategic Action Plan
2011-2016, Coral Triangle
National Plan of Action,
issuances detailing
procedures for the
biodiversity laws
RA 8749 (Clean Air Act),
PD 1586 (EIA)

240 protected areas covering 5.4 million


ha declared as PA, 113 of which
proclaimed under 1992 NIPAS Act as
terrestrial (TPA) and marine (MPA)
protected areas (2012)
6,138 ha declared as critical habitats
(2012)
38 caves with potential as ecotourism
sites (2012)
Sulu-Sulawesi Marine eco-region and
West Philippine Sea designated as areas
for sustainable management

27 additional monitoring stations with


greater capacity for monitoring
particulate matter
Higher emission standards for vehicles
Bantay Tambutso (anti-smoke belching)
and Bantay Tsimneya (control of
emissions from industries)

Air Quality

Some protected areas proclaimed by


LGUs and POs, but lack of capacity to
self-manage
Only 10-15% of 1,300 Marine
protected areas (MPAs) were
considered effective; most are
nonfunctioning
Sporadic development of MPAs due
to local initiatives than a national
strategy

Additional monitoring stations still


needed
Monitoring mainly focused in urban
areas, thus activities that violate Clean
Air Act go unnoticed in provinces

Subsector

Policy Responses

Strategies/Outputs

Challenges

Water Quality

RA 9275 (Clean Water


Act), PD 1586 (EIA)

19 rivers prioritized for water quality


management in preparation for rehab
and maintenance under the Sagip-Ilog
Program

11 priority rivers do not meet BOD


requirements
Slow progress in rehabilitating Manila
Bay

Table 1 (continued).
Subsector

Policy Responses

Strategies/Outputs

Challenges

Fisheries

RA 8550 (Fisheries
Code), amended on 27
Feb 2014 to include
stricter penalties, vessel
monitoring systems,
hosting of fisheries
observers from BFAR

RA 10121 (Philippine
Disaster Risk Reduction
and Management Act of
2010); RA 9729 (Climate
Change Act of 2009),
Strategic National Action
Plan on DRR (SNAP)

Vulnerability
to Climate
Change
Impacts

Community-based law enforcement


(e.g. Bantay Dagat groups, fisherfolk
communities)
Delineation of municipal waters for 928
municipal LGUs (2011)

EO 888 delineating priority programs on


DRR and agency responsibilities
Permissible uses of calamity fund
established under RA 10121
Risk transfer instruments
(microinsurance, health insurance)
Vulnerability assessments of 43 priority
watersheds
Adaptation tools, climate change
scenarios and projections developed

Lack of data on fisheries resources


and fishing activities (to monitor
exploitation)
DENR mandate (DAO 17) and NIPAS
conflicts with Fisheries Code
(delineation of municpal waters)
Only 285 coastal LGUs (30.71%)
certified by neighboring LGUs (2012)
Need to review consistency of SNAP
with RA 10121
What DRR measures need to be
funded by the annual calamity fund?
Yearly budget reserve for calamities
(PhP 2B) does not coincide with value
of damages during disasters
Problems in accessibility, uptake of
health insurance and microinsurance
in communities

Subsector

Policy Responses

Strategies/Outputs

Challenges

IEC campaigns

More attention given to adaptation


than mitigation
Unclear implementing rules and
regulations, responsibilities among
stakeholders involved
How to mainstream climate change in
other policies?
Source: Siason, Ferrer, & Monteclaro, n.d.; Pulhin, 2002; Carandang, 2005; NEDA, 2011; NEDA, 2013; La Via, 2014; Rappler.com, 2015.

Another example is the conflict between the Fisheries Code (RA 8550) and the
NIPAS Act (RA 7586), which set out different standards for determining municipal water
boundaries within protected areas.

Both policies are also in conflict with the Local

Government Code of 1991, which had its own basis for jurisdiction of LGUs within protected
areas (Siason, et al., n.d.). Meanwhile, coastal areas and marine resources suffer continued
degradation due to the fact that conservation policies protecting these areas had overlooked
external factors, such as unregulated inland development and reclamation of coastal zones.
Due to the lack of a compliance mechanism, the integrated coastal management framework
espoused by the national government is largely not followed at the local level (La Via,
2014).
In addition, a number of local ordinances that regulate mining activities do not
correspond with the Mining Act (RA 7942). For instance, the Provincial Environment Code
implemented by the provincial government of South Cotabato, which banned open-pit mining
as a matter of precautionary principle, was deemed inconsistent with RA 7942. The glaring
inconsistency became more apparent when a conflict ensued between the provincial
government and the national government over the still uncertain future of the Tampakan
Copper-Gold Mining Project (ASOG, n.d.).
Policy fragmentation is also evident in the forestry sector, which is rather governed
by an outdated forestry policy in the form of the Revised Forestry Code (PD 705). Many new
forestry policies have emerged, most of which do not coincide with the provisions of PD 705
(La Via, 2014). Carandang (2005) elaborated that instead of coordinating forestry policies,
agencies have resorted to band-aid solutions that merely covered up past weaknesses in
guidelines and regulations. This resulted in what Carandang called a maze of guidelines
that restricts activities of forestry stakeholders. Pulhin (2002), on the other hand, highlighted
efforts to establish a comprehensive law that would replace PD 705. However, lack of
legislative and political support hampered the passage of bills in Congress.

Instead,

changes have been made at the administrative level and were thus prone to revisions by

subsequent administrations. These administrative mandates and decrees were also rather
prone to many different interpretations at the regional and local level (Pulhin, 2002;
Carandang, 2005).
In the field of biodiversity, the 5 th National Report to the Convention on Biological
Diversity reflected improvements such as increase in mangrove cover, discovery of new
wildlife species, refinement of river basin master plans, and identification of additional
protected areas. But the report also acknowledged that gains have yet to impact other
sectors, such as agriculture, genetic resources, and urban development (DENR-BMB, 2014).
Meanwhile, in the area of biosafety, increasing scientific and regulatory complexity made it
more difficult for government regulators, scientific research agencies, and civil society
groups to review and refine biotechnology policies and protocols (STEPS Centre, n.d.).
Mainstreaming of climate change adaptation and mitigation had also been both a
compelling and challenging task. The Climate Change Act of 2009 (RA 9729) provides for
mainstreaming of climate change component in different sectoral policies. It also mandated
the creation of Strategic National Action Plans on Disaster Risk Reduction (SNAP).
However, with the emergence of the Philippine Disaster Risk Reduction and Management
Act of 2010 (RA 10121), the government still has to review the consistency between SNAP
and the said policy (NEDA, 2013). In addition, despite the existence of a national law,
climate change-related policies remain disjointed and independent of one another (La Via,
2014).
The abovementioned policy conflicts show that, at the status quo, the existing
environmental policy framework, consisting of highly sectoralized and fragmented policies
without any clear cross-cutting policy instruments to integrate or at the very least coordinate
these mandates, would leave unaddressed the a number major policy challenges identified
in the PDP 2011-2016 Midterm Assessment report, especially the following: 1) lack of a
harmonized land use policy; 2) inadequate policies to ensure sustainable management of

minerals and wastes; and 3) conflicting and overlapping government mandates (NEDA,
2013). Problems of environmental degradation are becoming inextricably linked with climate
change and other natural hazards. Multiple actors, technological advancements, greater
focus on human security and public participation, and the complex power dynamics between
and among stakeholders involved in crafting environmental policiesthese factors hinder
policy integration, yet make it more imperative at the same time.

Policy integration: opportunity for improved environmental policies


As mentioned in the preliminary sections of this paper, different ecological processes in the
environment are physically and socially interconnected with one another and are also linked
with the population and the economy.

Integrating different environmental policies that

highlight these linkages may pose a number of difficulties. As in the case of protected areas,
several environmental policies protect and conserve the countrys natural resources, but
when taken as a whole, these policies do not offer substantial support to the ENR sector.
The trend towards sustainable development as envisioned by the Philippine government
implies that one of the ways by which environmental protection and conservation would be
effective is by integrating relevant environmental policies into a comprehensive framework.
To do this, however, would require, at the very least, cooperative action within and among
implementing agencies across different ENR subsectors.
Works of scholars such as Dominic Stead and his associates (Geerlings & Stead, 2003;
Meijers & Stead, 2004; Stead, 2008), Challis, et al. (1988), Ling (2002), and Briassoulis
(2004), looked into the nature and scope of policy integration, barriers and facilitators, as
well as the costs and benefits involved in policy integration.

Many definitions of policy

integration abound in literature, but for the purpose of this paper, the term is defined in view
of intersectoral policies within the ENR sector.

There are two policy integration approaches that could be operationalized. First is the
vertical or intrasectoral approach, which aims to increment on existing sectoral policies,
incorporating issues that were not included in its original content, leading to an integrated
policy (Lafferty & Hovden, 2002, as cited in Briassoulis, 2004). In the field of environmental
policymaking, emerging environmental goals and concerns are simply incorporated into the
sectoral policies; the main focus of vertical integration is the consistency of policy goals,
guidelines and mechanisms at all hierarchical levels. Subsequently, the complexity or ease
of vertical policy integration depends on the hierarchical level at which policies are
integrated. Policy integration is easier to attain at the higher levels (e.g. central government,
head offices, etc.), while getting local authorities and other groups at the lower end of the
organizational hierarchy to integrate guidelines and rules would be much difficult. If linkages
between organizational levels do not exist or are nonfunctioning, policy integration may
never be possible (Briassoulis, 2004).
Horizontal or intersectoral approach takes a more rational-comprehensive view to
policymaking. Briassoulis (2004) referred to this as the more effective means for policy
integration, particularly in addressing ENR concerns. Here, the aim is to define relationships
among policies to environmental protection, conservation and management as well as other
interlinked policy concerns. The definition of policy integration by Meijers & Stead (2004)
mainly implies this approach.

They refer to it as the management of cross-cutting

policymaking concerns that go beyond boundaries of different policy fields, as well as the
existing roles and responsibilities of individual implementing agencies (Meijers & Stead,
2004). In this aspect, a single integrated policy may not necessarily be the policy instrument
(Briassoulis, 2004). This paper shall focus on intersectoral policy integration to address
policy fragmentation in the ENR sector.
Briassoulis (2004) highlighted the raison detre for environmental policy integration,
which is to secure the long-term, coherent functioning of human-environment systems
(p.3). Policy integration addresses unexpected and unwanted externalities that were not

previously considered in the policymaking process. It also helps avoid fragmented policy
and decision making (Meijers & Stead, 2004). In particular, the following are some of the
practical reasons for horizontal/intersectoral policy integration (Stead, 2008, p. 140):
1) Promoting synergies (win-win solutions) between sectors;
2) Reducing duplication in the policy-making process, both horizontally and
vertically;
3) Promoting consistency between policies in different sectors (horizontal) and at
different levels of decision making (vertical);
4) Improving the achievement of cross-cutting goals or objectives;
5) Giving more focus to the achievement of a governments overall goals rather than
the achievement of narrower sector-oriented goals;
6) Helping to promote innovation in policy development and implementation; and
7) Encouraging greater understanding of the effects of policies on other sectors.
A comparison

of

the

two

approaches

to

policy

integration

entails

that

horizontal/intersectoral integration may more effectively address policy fragmentation in the


Philippine ENR sector than vertical integration.
integrated?

But to what extent should policies be

However, weighing in on the costs and benefits of integration, as well as

facilitators and barriers, may determine the degree and nature of policy integration that
should be enforced.
Levels of policy integration
Stead (2008) provided a hierarchical framework of approaches with respect to the horizontal
management and integration of sectoral policies. These are, from the lowest to highest level
of intersectoral policy integration: 1) policy cooperation; 2) policy coordination; and 3)
integrated policymaking (Figure 2).
At the bottom of the hierarchy is policy cooperation. This involves better informing
policymakers and implementing agencies working on different ENR sectoral policies and
encouraging them to a dialogue. The main goal here is not quite on integration but more on
increased efficiency of sectoral policies. This is attained by determining avenues for the joint
accomplishment of individual sectoral goals (Meijers & Stead, 2004; Stead, 2008).

Policy coordination is more far-reaching than cooperation, because there is


deliberate adjustment of sectoral goals and guidelines to meet higher-level collective goals
(Meijers & Stead, 2004).

The key to effective policy coordination is consistency and

coherence among sectoral policies, in terms of the policy content, implementation and
outcomes (Challis, et al., 1988). Because considerable adjustments in sectoral policies are
needed to make them more coherent and consistent with one another relative to the
overarching goals, more resources are mobilized to affect policy coordination. There is also
increased interdependence among sectors, which requires that certain agencies give up part
of their autonomy. In addition, joint decisions and/or actions may lead to joint outcomes that
in turn may be different from that which policymakers initially intended (Meijers & Stead,
2004).

Figure 2. Integrated policymaking, policy coordination and cooperation (Stead, 2008)

At the apex of the hierarchy is integrated policymaking, which requires more


interaction and interdependence among policy stakeholders and implementing agencies. It
is also characterized by the need for more formal institutional arrangements and resources,
and because of the degree of interdependence needed, agencies may have to give up a
certain level of autonomy. The difference between policy coordination and integrated
policymaking lies in the outcome/goalwhile coordination aims for more effective and well-

adjusted (i.e. coherent and consistent) policies, the outcome of policy integration is a new
joint policy with objectives that cut across different sectors (Meijers & Stead, 2004).

Facilitators and barriers to policy integration


The figure above denotes that policy integration requires more and more of the policy
actors as they aim for higher levels of policy integration (i.e. policy coordination and
integrated policymaking). Challis, et al. (1988) and Ling (2002) explained that, aside from
administrative and temporal costs, process factors as well as cost and benefit considerations
play an important role in the success of policy integration initiatives. Ling (2002) elaborated
that policy integration, up to a certain extent, may require policymakers to define:
1) New types of organization (e.g. culture and values, information and training);
2) New accountabilities and incentives (e.g. shared outcome targets and performance
measures);
3) New ways of delivering services (e.g. joint consultation and involvement); and
4) New ways of working across organizations (e.g. shared leadership, pooled budgets,
merged structures and joint teams).
Below are some of the common costs and benefits that entail policy integration
(Table 2). While integrated policy making allows for a holistic perspective in looking at
issues such as environmental degradation, policymakers may face the challenge of
monitoring or assessing effectiveness and impact across different interrelated subsectors. A
considerable amount of resources may also have to be spent to establish cross-cutting
mechanisms (Cabinet Office, 2000).

Table 2. Policy integration: potential benefits and costs


Costs
Benefits
Less clear lines of accountability for
Helping to convey the big picture for
policy and service delivery
strategic issues
Greater difficulty in measuring
Helping to realize synergies and

effectiveness and impact, because of


the need to develop and maintain more
sophisticated performance
measurement systems
Direct and opportunity costs of
management and staff time spent
establishing and sustaining crosscutting working arrangements

maximize effectiveness of policy and/or


service delivery
Exploiting economies of scale
Improving customer/client focus and
thus the quality and user-friendliness of
services
Providing a framework for resolving
potential conflicts and making tradeoffs
Improving service delivery for particular
groups

Aside from this, policy makers have to consider other potential factors that may
inhibit or facilitate policy integration, specifically horizontal/intersectoral integration. Peters
(1998) grouped these factors into four dimensions, namely:
1) Pluriformity (uniformity or autonomy of departments) governments may either
consist of integrated agencies, or they may be composed of autonomous
departments. If the policies and programs are developed separately and with no
relation to any overall goals, then policy integration is less likely to happen.
2) Interdependence (connectivity of departments) government agencies may be linked
together via formal networks, or through a coordinating body that will manage
horizontal relationships between sectors.

Policy integration may be hampered if

there are weak or nil formal linkages (to the point of competition or adversarial
relationships) between sectoral agencies.
3) Formality of relationships this refers to the formal recognition of linkages between
sectors, as one of the important facilitators of policy integration. However, Peters
argued that despite the existence of formal intersectoral relationships, there might be
instances wherein the influence of some sectors may dominate that of other sectors,
e.g. economic growth taking precedence over social and environmental goals. As
such, Peters suggested that policymakers should also take into account the informal
relationships that shape policy integration.
4) Instruments these are mechanisms that contribute to the consistency of policies as
they are formulated and implemented across different sectors.

These include

intersectoral working groups and committees, formalized policy assessment and


auditing procedures (e.g. EIA), formalized financial allocation systems, among others
(Stead and de Jong, 2006, in Stead, 2008). It is important to determine which
instrument best works for a particular policy integration initiative, otherwise ineffective
policy instruments may instead be barriers to integration.
Stead (2008) also cited other institutional barriers to policy integration, such as
resistance to change, lack of incentives, and education or training concerns. He iterated that
for every innovation in policies there is almost always a strong resistance to change, making
it a daunting task for policymakers to promote and justify policy integration. In addition, the
government may find it hard to determine appropriate incentives for intersectoral
collaboration and attainment of multisectoral policy goals. Differences in profession and
specialization across sectors, owing to the diversity of educational or training backgrounds of
staff and unit heads, may also impede policy integration.
Taking into consideration some of the costs, benefits, facilitators and barriers of
policy integration may actually lead policymakers to ask if there is a need to integrate
sectoral policies or if it is practical to do so. As mentioned earlier, policy integration has the
potential to make policies coherent and consistent, thus leading to more improved policy
outcomes. However, Briassoulis (2004, p.24) raised three important questions that should
be considered before planning for policy integration:
1) Is a general, all-purpose and all-encompassing policy integration scheme possible
and desirable or is a case, or issue, specific policy integration scheme more
appropriate?
2) Is horizontal integration sufficient to tackle crosscutting issues or is vertical
integration necessary too, or both?
3) Is policy integration at a given level sufficient or is cross-level policy integration
necessaryor even a grand scheme of full-blown integration on and across levels?

The assessment of the existing Philippine environmental policies earlier made in this
paper suggests a great need to create a policy integration scheme to, at the very least,
make sectoral policies coherent and consistent and to avoid policy fragmentation.
Meanwhile, since the concern of policy fragmentation deals with intersectoral relationships in
the ENR sector, the paper deems it important to focus on horizontal/intersectoral integration.
The third question offered by Briassoulis (2004), on the other hand, provides for the central
idea of this paper.

Problem Statement and Objectives


Figure 1 represents a mini-problem tree analysis on the causes and outcomes of
policy fragmentation in the environment and natural resources (ENR) sector, which this
paper will be trying to address through a given set of policy options and recommendations.
The paper mainly aims to explore options for integrating different ENR sector policies to
address the problem of policy fragmentation and ensure a more comprehensive
environmental policy framework. In particular, it addresses the following questions:
1) What level of policy integration (i.e., cooperation, coordination, or integrated
policymaking) could best address the problem of policy fragmentation in the
environment and natural resources (ENR) sector?
2) What concrete institutional mechanisms or policy instruments could facilitate the
preferred level of policy integration?
William Dunns (2015) criteria for policy prescription: effectiveness, efficiency, equity,
responsiveness, adequacy, and appropriateness, shall be used for evaluating policy
alternatives. Below is the description for each of the criteria:
1) Effectiveness extent to which policy alternative helps attain policy goals or
objectives.
2) Efficiency amount of effort required to produce a given level of effectiveness

3) Adequacy extent to which any given level of effectiveness satisfies a particular


standard
4) Equity distribution of effects and effort among different groups in society
5) Responsiveness extent to which policy satisfies needs, preferences and values
of groups/stakeholders involved
6) Appropriateness value/worth of a policy/program objectives and tenability of
assumptions underlying these objectives
The paper then concludes with the preferred policy option and how this can be
further improved in pursuit of a sustainable, resilient environment and natural resources for
the country in the future.

Figure 1. Problem analysis: fragmentation of environmental policies

Assessment of policy options


Three options are analyzed and evaluated based on Steads (2008) levels of policy
coordination, to determine the level of policy integration (i.e., cooperation, coordination, or
integrated policymaking) that could best address the problem of policy fragmentation in the
environment and natural resources (ENR) sector. These are the following:
1) Policy cooperation promoting dialogue and exchange between different
departments or agencies handling specific ENR subsectoral concerns (e.g.
forestry, coastal management, air and water quality, solid waste management,
etc.);

2) Policy coordination promoting intersectoral dialogue and exchange, as well as


incrementing on existing sectoral policy gaps to improve coherence and
consistency of the different sectoral policies and address conflicting or
overlapping provisions; and
3) Integrated policy making crafting a new, comprehensive environmental policy
that not only encourages dialogue, coherence and consistency of policies, but
also determines ways by which sectoral policies may be jointly applied and
implemented.
Stead (2008) provided a number of concrete institutional mechanisms that help
facilitate each level of policy integration. Meanwhile, it should be noted that while these
three options are potentially effective with respect to addressing the problem of policy
fragmentation in the ENR sector, not all of them are the panacea to the problem.

combination of the three approaches, or perhaps a fourth option, may emerge as a more
optimal solution from the ensuing analysis of the said options.

Option 1: Promoting dialogue and exchange between different departments or agencies


handling specific ENR subsectoral concerns
There are several institutional mechanisms that could promote at least policy
cooperation.

Among them are by establishing organizational arrangements, particularly

interdepartmental committees, commissions, and technical working groups that could help
different sectoral agencies work together in implementing their policies more efficiently.
Human resource development strategies that build capacities of personnel for intersectoral
cooperation, such as changing work arrangements, as well as learning activities, e.g.
workshops, seminars, training activities, could also help promote policy cooperation.
Alternatively, agencies could also conduct benchmarking and share best ENR practices with

other sectors.

Reporting strategies that look into the present state of environment and

natural resources and sustainable development indicators can also be tapped to promote
intersectoral dialogue and information sharing (Stead, 2008).
Central steering agencies could also facilitate policy coordination across different
sectors. NEDA as a planning and policymaking agency had already laid out strategies for
intersectoral policy coordination across different sectoral outcomes and policy areas, through
the PDP 2011-2016. Intersectoral programs that allow different departments to cooperate
with one another in policymaking and implementation could also be created to enhance
cooperation. Examples of these are the National Climate Change Action Plan (NCCAP), as
well as the National Biodiversity and Action Plan (NBAP) that delineates the roles and
cooperation of different departments, private sector institutions, NGOs, among other groups.
Moreover, several other policies and administrative mandatesnot just in the ENR
sectorprovide for avenues for consultation and public hearings among different
stakeholders involved in the policy. That this is already part of many of the environmental
policies suggests that the government has the legal/institutional framework to address policy
fragmentation through policy cooperation. However, this is only half the battle.
Policy cooperation can be effective as far as enhancing dialogue and information
exchange is concerned, but in working towards a comprehensive environmental policy, this
kind of response alone may not be adequate. Costs may be incurred for ensuring clarity of
joint accountability for policy and service delivery; and there may also be direct costs on part
of the management and staff in creating and maintaining intersectoral working
arrangements.
While there are possibilities for ensuring equal participation and benefits among
policy actors involved, still, enhancing individual agency/sector goals is the main goal of
policy cooperation. As such, policy coordination may fall short in controlling overlaps or
conflicts between different sectoral policies.

This could lead to conflicts that would

undermine intersectoral cooperation. However, consultation and dialogue inherent in policy


cooperation may help resolve these conflicts, and may also boost its responsiveness and
appropriateness to different sectors. Then again, this depends on the level of participation
and power/sphere of influence by different sectoral groups and players.
Option 2: Promoting intersectoral dialogue and exchange, as well as incrementing on
existing sectoral policy gaps to improve coherence and consistency of the different sectoral
policies and address conflicting or overlapping provisions
Based on earlier discussion, policy coordination ensures coherence and consistency
across different sectoral policies in terms of policy goals and implementation. On one hand,
integrated national strategies that would link different ENR subsectors with one another are
already abound in the Philippine setting.

This includes, of course, the Philippine

Development Plan 2011-2016, which sets out specific goals, targets and indicators that need
to be achieved before the end of the year 2016. Goals set in 2011 have been revised in
2013 through the PDP 2011-2016 Midterm Update, to accommodate necessary changes in
circumstances (e.g. Typhoon Haiyan caused changes in plans and results framework of
ENR sector) (NEDA, 2013).

Figure 2 presents the PDP 2011-2016 updated results

framework. Subsector outcomes were translated into specific end-of-plan (2016) quantitative
targets.

However, national strategic frameworks that are sector-specific (e.g. fisheries,

biodiversity, wetland conservation, climate change adaptation) might still need to be


reviewed to ensure if they follow the nationally-determined targets and outcomes.
Internal consultations within and among the ENR subsectors might help anticipate,
identify and address conflicts between sectoral policies. Environmental impact assessment
(EIA) mechanisms should be tailored to include results and outputs from a wider range of
ENR sectors. Aside from this, multi-sectoral assessment of different ENR policies may help
identify and resolve gaps in policy coordination and consistency.

The Philippine government may also consider conducting inter-ministerial or


interdepartmental conference and meetings from time to time. This is to convene ENR sector
groups and agencies involved in the implementation of various environmental policies,
review their respective results frameworks and action plans, and resolve any conflict
between sectors.
The option of ensuring coherence and consistency of the different sectoral policies
and address conflicting or overlapping provisions can be effective in terms of harmonizing
policies and attaining higher-level joint outcomes among ENR subsectors. Coming up with
national objectives for improving the management of environmental and natural resources
may somewhat help implementing agencies and groups, particularly in the lower levels, to
come up with strategic environmental plans that coincide with the national targets.
Meanwhile, the conduct of joint meetings, policy dialogues and consultation activities would
also help review and revise national mandates and see if these are still applicable given the
situation on the ground. It could also help achieve as much as possible, a win-win situation
for each of the sectors involved.

Figure 3. Strategic framework on sustainable and climate-resilient environment and


natural resources

However, given the complexity of environmental problems and the multiplicity of


actors in the ENR sector, plus the island-based or archipelagic nature of different sectoral
policies (Revilla, 2014), policy coordination is not an easy task. In fact it is much harder to
implement than Option 1 (policy cooperation), given the level of compatibility, accessibility,
and comprehensiveness needed to conjoin and harmonize ENR policies. Different sectors
may be required to give up some of their autonomy and resources to accommodate the
preferences or interests of the other sectors. As such, there are additional costs involved in
getting different sectors to agree upon and commit on collective targets or goals, revising or
harmonizing conflicting policies from time to time. Nonetheless, developing joint outcomes
or goals and ensuring continued support for these outcomes through constant dialogue and
reporting contributes to ensuring that positive impacts of different sectoral policies are
spread across different ENR subsectors.

Option 3: Crafting a new, comprehensive environmental policy that not only encourages
dialogue, coherence and consistency of policies, but also determines ways by which
sectoral policies may be jointly applied and implemented
Creating a comprehensive environmental policy would be highly effective in
addressing changes in the context of ENR policies, attaining collective outcomes, and
detailing specific mechanisms for joint implementation or application of different sectoral
policies. The formulation of joint outcomes, goals and implementation mechanisms would
also ensure that the benefits of the proposed law will be equitably distributed across the
different sectors.
However, there are many ways, but relatively few examples, by which a
comprehensive, integrated environmental policy could be implemented, or at least promoted.
Government budgets be adjusted to help promote integrated policymaking, but this would
entail a lot of debate and consultation. In the General Appropriations Act (GAA) of 2015,

funds for environment and sanitation, environmental protection, environment-friendly


infrastructure and equipment, research and development projects, among other ENR
components are allocated per sector, department or agency. The same is also true for the
allocation of funds to climate change-related infrastructure and capacity-building activities.
In sum, budget allocation in the Philippine government is according to agency or
department. It may be possible to develop joint budgets that relate to the environment and
natural resources (ENR) action plans, and perhaps it would be possible to adjust financial
allocation systems to allot funds based on policy areas rather than department/sectoral
agencies. This would, however, entail major amendments to the GAA and other policies,
and would require approval of the House.
While there are intersectoral or interdepartmental teams working on the
implementation of local environmental policies (e.g. the case of Bantay Dagat or Bantay
Kalikasan groups working with DENR, PNP, and other agencies in monitoring seas and
forests), it is relatively difficult to point out national environmental policies that are actually
being implemented through interdepartmental or inter-agency committees.
Finally, to create a single, comprehensive environmental policy that cuts across
sector is inherently difficult. Based on the experience of the Congress in 1996 (the attempt to
create a single policy), it is difficult and cost-intensive to lobby for and formulate a national
law that covers all ENR subsectoral policies. If anything, due to bounded rationality, the law
would not be inclusive enough to accommodate interests of different sectors and groups.
The most feasible way by which Option 3 can be implemented is to revise the
Philippine Environmental Policy and Philippine Environmental Code. The PD 1151 and PD
1152 provides for sector-specific requirements and standards, which are currently outdated.
While there are already existing policies that are rather in blatant disregard of the two laws,
the PD 1151 and 1152 may be revised to provide for joint implementation or application of
the said laws.

However, again, to do so would require considerable cost, e.g. in

reformulating, lobbying for, and enacting a revised law. Additional costs would also be
incurred in getting different sectors with originally individual goals and targets to commit to
and comply with the revised law. Nonetheless, in the long run, Option 3 would be more
effective than the former two options in addressing long-term environmental and natural
resource issues, as it possesses a stronger legislative power than an administrative or
executive mandate.
Table 3 provides for a summary of the assessment of the three options offered by this
paper, in terms of effectiveness, efficiency, equity, adequacy, responsiveness and
appropriateness.

Recommendations
As much as integrated policymaking is ideal for addressing the problem of policy
fragmentation, the current institutional set-up and budgeting process may slow down efforts
to craft a comprehensive environmental policy. The process of formulating a new policy and
having it approved may take a long time. Creation of a single, integrated policy requires that
sectors give up considerable level of autonomy, resources and other commitments, which
may be difficult to forgo.
Hence, in the meantime, it may be argued that the second alternativeensuring the
coherence and consistency of policiesmay be the best alternative among the three options
considered.

Gaps between different sectoral policies may first be addressed while a

comprehensive policy is being crafted. While considerable costs are involved in amending
or revising each of the sectoral policies in pursuit of collective ENR goals, it is relatively a
more adequate response than just getting different sectoral agencies to cooperate with one
another (Option 1).

However, if integrated policymaking is extremely necessary, it may be

wise to increment on the existing Philippine Environment Code and Philippine Environmental
Policy.

Figure 3. Assessment of policy options


Alternative
Option 1: Policy
cooperation
Possible
strategies/instruments:
-

Interdepartmental
committees
Human resource
policies that reflect
joint working
arrangements
State of the
environment reports
Benchmarking and
sharing of best
practices

Option 2: Policy
coordination
Possible
strategies/instruments:
- Internal consultation
processes
- Strategic
environmental

Effectiveness
Effective
in
terms
of
making
individual
policies
efficient,
but
may lack in
ensuring
consistency
and coherence
since sectoral
goals are the
target of policy
cooperation

Effective
in
addressing
policy overlaps
and
conflicts
between ENR
subsectors, and
formulation and
attainment
of
joint outcomes

Efficiency
Efficient relative
to the amount of
resources and
little
loss
of
autonomy
involved
in
ensuring
cooperative
arrangements
Costs
are
incurred
in
ensuring
joint
working
arrangements
and
defining
joint
accountability
mechanisms
On top of costs
entailed
by
policy
cooperation,
additional costs
may be incurred
in
revising
sectoral policies
and establishing

Equity
Weak in ensuring
equity
across
ENR subsectors,
since the aim of
policy
cooperation
is
ultimately
the
enhancement of
individual
sectoral
outcomes

Formulation
of
joint
outcomes/goals,
bridging
gaps
between sectoral
policies
helps
contribute
to
ensuring
equitable

Criteria
Adequacy
May not be an
adequate
response
in
terms of making
ENR
policies
more
comprehensive
and integrative

May be sufficient
enough
to
address
joint
needs and make
environmental
policies coherent
and consistent,
particularly
in
the absence of

Responsiveness
May
be
responsive
to
some
sectors
(particularly those
that are willing to
work with other
agencies);
consultations with
other
sectors
may help address
sector-specific
needs
and
interests

Appropriateness
Appropriate,
since
there are ENR policies
that
allow
for
intersectoral
cooperation,
public
hearings
and
consultation, etc.

Regular internal
consultations,
reporting
and
meetings
may
bring up sectoral
needs;
multisectoral
monitoring
of
impacts
and

Appropriate, although
the feasibility of joint
interdepartmental
conferences/meetings
at the national level
are yet to be explored

Alternative
assessment
- Multisectoral policy
evaluation
- Intersectoral
programs
- Central committees
- Cross-cutting units
within departments
- Joint
interdepartmental
conferences
Option 3: Integrated
policymaking
Possible
strategies/instruments:
- Joint
budgeting/financial
allocation
- Intersectoral policy
teams
- Revision of existing
comprehensive
environmental laws
(e.g. PD 1151 and
PD 1152)

Effectiveness
or goals; but
may need to
have legislative
power to be
further effective

Efficiency
joint targets or
objectives
among different
sectors
and
agencies, which
are to be done
on a regular
basis

Equity
distribution
of
policy
benefits
across
ENR
subsectors

Highly effective
in terms of
integrating
different
sectoral
policies, as this
also
has
legislative
power
compared with
the other two
options

May
not
be
immediately
efficient,
considering the
time and costs
involved
in
formulating,
lobbying for and
enacting a new,
comprehensive
policy
and
enjoining
different sectors
to commit to the
said policy

Formulation
of
mechanisms for
joint
implementation
may contribute to
the
equitable
distribution
of
policy
benefits
across
ENR
subsectors

Criteria
Adequacy
an
updated
comprehensive
environmental
law

Adequate
to
address policy
fragmentation

Responsiveness
outcomes
of
sectoral policies
contributes to the
responsiveness
of policies to
different sectors
needs

Appropriateness

Opportunities for
joint policymaking
makes
policy
integration
responsive to the
needs
across
different sectors

Given the existing


framework
and
process of financial
allocation, it may be
inappropriate
to
determine avenues for
joint or intersectoral
budget
implementation
Creation
of
intersectoral
policy
teams and revision of
the existing PD 1151
and PD 1152 may be
more appropriate

Establishing a strategic environmental policy framework helps ensure that different


sectoral policies are consistent with the national goals and priorities of the government.
Existing national frameworks for climate change adaptation, biodiversity, or even the PDP
2011-2016, may already be a good start. However, simply agreeing on national targets and
compliance mechanisms is not enough. Institutional strategies for policy cooperation, such
as formation of central committees and multidisciplinary working groups, are also important
to monitor consistency among different policies, as well as reconciling them with budgetary
imperatives. The latter is a bit more challenging, since budget allocation in the government
is more sectoral-based than issue-based or policy area-based.
Strategic monitoring mechanisms provide policymakers a better insight, clearer
definition and deeper analysis of different but interrelated ENR concerns and issues, and a
better foresight of possible inconsistencies that come along with proposed ENR policies.
Implementation guidelines must also ensure that policies are adjustable amid fast-paced
developments, new information and changing circumstances.
No matter what level of policy integration is being adopted, however, political
commitment is essential to initiate and enhance policy coherence and consistency. In
addition, promoting an administrative environment that engenders intersectoral cooperation,
dialogue, and sharing of information, could also contribute to policy coordination.

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