Gus Agosto, also a real estate consultant, filed a formal notice and reservation of objection in a letter sent to DHSUD Secretary Jose Ramon Aliling dated Dec. 15, 2025 amid its ongoing review with CLUP 2023 t0 2032.
Planning risks flagged
He told InsiderPH that he filed the notice to seek a formal review because the CLUP and the zoning ordinance were not compliant with the provisions of Republic Act No. 11995, or the Philippine Ecosystem and Natural Capital Accounting System (Pencas) Act.
These two measures were passed more than a year after RA 11995 took effect, yet were still based on pre-Pencas baselines, he added.
“In other words, the plan that now governs where people can build, live, and invest was adopted under a framework that systematically underestimates climate, flood, and ecosystem risks, despite a clear, self‑executing national statute already in force,” said Agosto.
Without amending the CCLUP, floods would not only persist but would worsen over time especially in the wake of climate change that would bring high volume of rainfall and cause sea level to rise, he added.
“Climate projections indicate more extreme rainfall and rising seas, which increase runoff, strain already inadequate drainage, and heighten coastal and riverine flooding in topographically constrained cities like Cebu,” said Agosto.
Land-use pressures mount
“If the CLUP continues to treat watersheds, floodplains, and drainage corridors as residual space rather than protected natural capital—and keeps allowing upland and mid‑slope intensification under pre‑Pencas baselines—each new project will compound these climate‑driven stresses instead of buffering them, locking the city into a cycle of recurrent and worsening floods.”
Pencas, which was signed into law on May 22, 2024, institutionalizes the Philippine Ecosystem and Natural Capital Accounting System and mandates its use in policy and decision-making.
This means the law requires the adoption and integration of internationally accepted environmental economic accounting frameworks into the country’s resource management, as well as the establishment of mechanisms for monitoring and reporting to ensure that the country’s ecosystems and environmental resources are protected, conserved, and restored.
Risk-sensitive planning
In his letter to Aliling, Agosto pointed out that the city’s CLUP failed to integrate sectoral solutions for housing, commercial development, industrial land use, transportation, and water supply, instead treating each in isolation.
“The CLUP stops short of integrating these sectors into a binding, risk‑sensitive spatial strategy that clearly reconciles land‑use allocations with hazard exposure, infrastructure capacity, and environmental limits,” he wrote.
Agosto said the CLUP was also not compliant with the Pencas.
He said the plan “lacks a natural capital accounting or valuation framework, does not identify ecological thresholds, carrying capacity limits, or critical ecosystem services as binding planning constraints, and acknowledges environmental and hazard risks in narrative form but does not consistently translate them into determinative land-use and zoning controls.”
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