PHILIPPINES: ESTABLISHING AN INDUSTRIAL WASTEWATER EFFLUENT FEE PROGRAM, LAGUNA DE BAY CASE #82

PHILIPPINES: ESTABLISHING AN INDUSTRIAL WASTEWATER EFFLUENT FEE PROGRAM, LAGUNA DE BAY CASE #82 ABSTRACT To increase the effectiveness of water pollution control efforts, a market-based policy instrument an environmental user fee was implemented to complement existing regulatory mechanisms. The user fee system was designed to reduce pollutant loading into Laguna de Bay and its tributary rivers by requiring dischargers of liquid waste or wastewater to internalize the cost of pollution prevention and abatement into their business decisions or actions. Brief Description Industrial water pollution had significantly degraded a large watershed near Manila. Following the polluter pays principle, an industrial wastewater effluent fee program was developed to create economic incentives for industry to reduce wastewater discharges and raise revenues to finance local government management of the program. The effluent fee system was developed for the Laguna de Bay watershed, which includes Laguna de Bay and over 20 feeder rivers. The Laguna Lake Development Authority (LLDA) is a government agency that is responsible for protecting and managing the largest freshwater body in the country. It was the pilot district for the program, covering more than 500 industrial dischargers within 45 industry sectors. The effluent fee system was designed to reflect the quantity of discharges, the costs of environmental externalities created by industrial discharges, and the budget requirements to administer the program. Following hands-on training of personnel, the program was implemented by the LLDA, with portions handled by surrounding municipalities. After LLDA implemented the effluent fee in 1997, industries responded by changing production processes and implementing other measures to reduce the volume of effluent and pollutants in discharges to Laguna de Bay. The pilot test of this effluent fee program resulted in reduction of 88 percent of BOD from direct discharges between 1997 and 1999. In addition, during the first two years the government collected over P28,000,000 from Metro Manila firms discharging wastewater into the Laguna de Bay watershed. The regulatory monitoring and enforcement components of the program led to closure of around 50 companies by LLDA between 1998 and 1999 for significant violations. Lessons learned Water pollution charges provided incentives for industrial polluters to reduce the impacts of wastewater discharges to a large freshwater watershed and raised revenues for program management. Institutional design was important to ensure that the government had the most appropriate organizational structure, personnel qualifications, training, and budget requirements to administer the program. It was also important to integrate the pollution charges with the regulatory and enforcement program. Importance for IWRM Until recently, most governments relied primarily on direct regulation in water resources management. This case demonstrates that economic instruments offer several advantages such as providing incentives to change behavior and raising revenue to contribute to the financial sustainability of water authorities. Main Tools Used C7.2: Pollution and environmental charges C7.1 Pricing of water and water services A1.2: Policies with relation to Water Resources B2.3: Regulatory Capacity Wastewater Effluent Fee Program Case #82 1

MAIN TEXT 1 Background and problems The World Bank s Philippines Environmental Sector Study (1993) recommended that the Philippines adopt a system of economic incentives to promote water pollution prevention and abatement, particularly for biological oxygen demand (BOD) and total suspended solids from domestic and selected industrial sources. The Philippines Department of Environment and Natural Resources (DENR) therefore commissioned a study to design a pollution charge program that integrates economic incentives with existing water quality and wastewater treatment permitting programs. A pollution charge is a fee that is levied on each unit of pollution discharged by a source, such as an industrial plant or municipal treatment facility. The purpose of a pollution charge is to provide price signals for industry to allocate their pollution prevention and abatement resources efficiently. By charging a fee for using environmental resources to dispose of wastes, the government encourages firms to factor into their overall production costs the costs of using these resources and, in turn, encourages them to reduce their resource use to a socially acceptable level. The DENR s study recommended that a pollution charge program be implemented nationwide using a phased approach. Phase 1 of the program was implemented for Laguna de Bay, a shallow freshwater lake located about 15 kilometers southeast of Manila. The watershed area, called the Laguna de Bay Region, is about 3,800 square kilometers and includes Manila, many smaller cities and around 360 square kilometers of urban and industrial area that spread outward from Manila. Twenty-one rivers flow into the 90,000-hectare lake, which is the second largest inland body of water in Southeast Asia. Laguna de Bay is the receiving water body for the entire watershed and is important for inland fishery production, irrigation uses, power generation, industrial cooling, and its potential as a domestic water supply source for Manila and adjacent areas. The Laguna de Bay Region had experienced environmental degradation caused by rapid urban and industrial growth and weaknesses in the traditional water pollution control regulations. Industry was a special concern because the watershed had a high concentration of industries, rapid industrial growth was expected to continue, and the region s industry was important to the country s gross national product growth. The Laguna Lake Development Authority (LLDA) is a regional agency whose environmental functions included carrying out surveys and inventories on the water basin, conducting ambient water quality monitoring, issuing and enforcing permits, and responding to complaints related to industrial water pollution. According to LLDA, 1,481 factories occupied about 20% of the region s land area in 1994 with most plants using the lake or its tributary rivers and streams as a sink for waste. Industry accounted for about 30% of the lake s pollution, while agriculture (including livestock producers and feedlots) contributed 40% and domestic sewage about 30%. The LLDA study found that only about 69% of the wet industries in LLDA s jurisdiction in 1994 had wastewater treatment facilities. Institutional Issues The pollution charge study commissioned by DENR, with assistance from the World Bank, was conducted by a consulting team led by Hagler Bailly (now PA Government Services). The study recommended that a pilot program (Phase 1) for the pollution charge system be implemented by LLDA and the program could later be expanded to the national level. LLDA had a unique legal authority and institutional structure that gave it the ability to implement the proposed pollution charge program without further enabling legislation. LLDA is also administratively attached to DENR, which would facilitate transferring experience with Phase 1 of the pollution charge program if it were expanded nationwide. The institutional issues are summarized below. Wastewater Effluent Fee Program Case #82 2

Legislative Authority Legal requirements often present the greatest challenge to implementing a pollution charge system. In terms of legislative authority, the primary legal requirement is that the institution be legally authorized to assess, collect and earmark funds from all regulated water pollution point sources within its jurisdiction. Because of previous difficulties and delays in passing environmental legislation in the Philippines, it was important to work within the existing legal framework if possible. The consulting team reviewed existing law and legal issues related to imposing a pollution charge and earmarking revenues. Then the team evaluated the legislative authority for four existing institutions that represented different models: 1. A national environmental regulatory agency (DENR); 2. A regional development authority (LLDA); 3. A water resources regulatory board (National Water Resources Board); and 4. Local government units. On the national level, water use and wastewater discharge are regulated by separate entities. The DENR regulated wastewater discharges and the National Water Resources Board (NWRB) regulated water use. A review of these entities legal authority indicated that additional authority would be needed to assess a fee or charge on surface water use and effluent discharge. Under the 1976 Water Code (Presidential Decree 1067), NWRB regulated water use and coordinated all water resources development and use activities. Because the Water Code effectively separates the regulation of water use from regulation of wastewater discharges, the NWRB does not have any authority for pollution control activities. Under the 1976 National Pollution Control Law (Presidential Decree 984) and Executive Order 192 (1987), DENR has ample authority to assess water quality needs across the country and to regulate discharges under its permitting authority, but it lacked the authority to use economic instruments for environmental management. Executive Order 192 reorganized the DENR and charged it with regulating sewerage and wastewater discharges through its regional offices, except within LLDA s jurisdiction. The DENR s authorities under P.D. 984 are the basis for the Authority to Construct (A/C) and Permit to Operate (P/O), which are the wastewater discharge permits that DENR issues, and for regulating industrial sources of water pollution. P.D. 984 also authorized DENR to impose fees and charges for those permits to cover the processing costs of permit issuance. Based on the legal review, however, DENR appeared to need additional authority to assess a fee on effluent discharge or water use. Also DENR had no authority to retain revenues collected through fees, as the agency must rely on the budget process for its funds. National authority existed for issuing permits and regulating water quality, but not for a pollution charge system for water quality management. 2 Decisions and actions taken LLDA was created by Republic Act 4850 in 1966 with the authority to evaluate development potential and review and approve development plans and programs in the Laguna de Bay area. In 1975, Presidential Decree 813 authorized LLDA to issue permits for the use of lake waters, impose necessary safeguards for lake quality control and management, and collect necessary fees for these activities. LLDA had other functions and powers defined in 1988 by Executive Order 927, which elaborated LLDA s authority to issue, renew or deny permits for the prevention and abatement of pollution, discharge of sewage or industrial waste, or installation or operation of treatment plants. A review of LLDA s legal authority identified that within its well-defined jurisdiction, 1 LLDA is authorized to collect a fee on both the intake and discharge of water and to issue permits for effluent discharges provided that the lake is the source and the ultimate receiving body for the effluents. 2 Unlike DENR, LLDA was authorized (by P.D. 813, 1 LLDA covered the whole province of Laguna, thirteen Rizal municipalities, Metro Manila (Manila, Pasay, Caloocan, Quezon City, Muntinlupa, Marikina, Pasig, Taguig, Pateros), Cavite (Tagaytay, Silang and Carmona), Lucban, Quezon, and Batangas (Tanauan, Sto. Tomas, and Malvar). 2 Under Section 4-13 of Republic Act 4850 and Section 3 of Executive Order 927, LLDA is empowered to collect annual fees for the use of the lake waters and its tributaries for all beneficial purposes, including waste disposal purposes. Wastewater Effluent Fee Program Case #82 3

Section 6(g)) to retain the revenues collected and earmark them for management and development of the lake and its watershed areas. Under the Local Government Code (R.A. 7160), local government units (LGUs) also have legal authority to issue permits and impose reasonable fees or charges for services rendered. Although the LGU s authority to impose a fee on the intake and discharge of water may be limited by the national agencies, broad authority appeared to exist for local ordinances that could establish and enforce such programs and retain the revenues collected. Regulatory Guidance Even when adequate legislative authority exists, rules and regulations are also necessary to provide regulatory guidance to implement a pollution charge program. Both DENR and LLDA regulated water quality under DENR Administrative Orders No. 34 and 35. DAO 34 defines beneficial use classifications and ambient water quality standards. Laguna de Bay, like most water bodies in the Philippines, was classified as Class C waters. Class C water is suitable for the propagation and growth of fish, non-contact recreation, and industrial water use following treatment. DAO 35 defined effluent or discharge standards and applied to all industrial and municipal wastewater effluent. The effluent standards are intended to keep water bodies within their designated beneficial use classifications. DENR s permits, however, usually did not impose limits on total wastewater discharge or pollutant loading but focused on the operation of pollution control equipment. Nevertheless, DAO 35 provided authority for certain aspects of a pollution charge program including imposing loading-based limits and establishing limits to reduce the cumulative impact of multiple sources. One aspect of a pollution charge program lacking in DAO 35 was how to establish permit fees with respect to discharge levels. DENR s A/C and P/O permits were essentially permits to operate that regulated the use of specified and approved pollution control equipment. LLDA s Interim Rules and Regulations Implementing R.A. 4850, as amended, require discharge permits that regulate actual pollutant loading. Consequently, the regulatory guidance for LLDA would require fewer revisions to define the basis for calculation of permit fees based on discharge levels under a pollution charge system. Effluent Fee Design Issues A pollution charge system can be designed to meet a range of environmental and economic objectives. Through discussions with the Government of the Philippines, the consulting team recommended that a pollution charge program be implemented nationwide after a pilot program (Phase I) in the Laguna de Bay Region. After the pilot program was implemented, a 5-year implementation period was planned for the proposed national program (Phase II) to allow time for necessary changes to the legal and regulatory framework. The consulting team also recommended that the charge be calculated to provide companies a financial incentive to reduce the amount of pollution produced. If the charge were set at a level higher than the cost of pollution abatement, then it would not be cheaper for industries to continue polluting and just pay the charge. Pollution abatement cost analyses provided the basis for setting pollution charges at levels that would induce plant managers to cut pollution significantly. A pollution charge model was implemented for Phase I based on the Laguna de Bay, industrial sources, and a single pollutant, BOD. The Phase I model was applied to a synthesized data set of 535 industrial facilities discharging into Laguna de Bay or its tributaries and run using different variations of a two-part fee structure based on wastewater discharge volume and BOD concentration. The higher the charge, the more firms will choose to invest in pollution reduction measures versus paying the charge. The model suggested that loadings reductions would continue to increase until the variable fee reached about P50/kg of BOD. Based on the model results, two criteria were used to set the initial charge: 1. Provide incentives for firms to install appropriate wastewater treatment to comply with DAO 35 water quality standards for Class C water bodies; and 2. Reduce total industrial BOD loading by a set amount in the first year. Wastewater Effluent Fee Program Case #82 4

The P30/kg rate for the variable fee chosen for implementation of Phase I is higher than the cost of installing wastewater treatment systems for existing industries so firms have a strong financial incentive to invest in treatment or pollution prevention. The model was also used to calculate rates predicted to achieve a 50% reduction in BOD load of the lake water within the first year of implementation. Implementation of a pollution charge system requires several integrated functions: identifying who will pay the fees, compiling specific data needed to calculate the fee, validating data provided by the firm, billing the firm for the fee, collecting the charges on a periodic basis, accounting for the collection and use of fee revenues, monitoring and inspecting the firm, enforcing penalties for noncompliance or failure to pay assigned fees, and resolving disputes arising from differences of opinion in terms of the data used to calculate the charge. If revenues are earmarked for a specific purpose, then additional financial management is required to administer the earmarked funds. The technical and institutional design for the proposed national program for these functions would be based on the experience gained during Phase I in the Laguna de Bay Region. 3 Outcomes Regulation of Wastewater Discharge The LLDA Board of Directors approved the Environmental User Fee System under Board Resolution No. 25, Series of 1996, for implementation in the Laguna de Bay Region to enhance the lake s water quality by providing lake users with an incentive to reduce pollution and allocate their prevention and abatement resources efficiently. LLDA formulated the Rules and Regulations implementing the Environmental User Fee System in the Laguna de Bay Region, which were approved by LLDA s Board of Directors under Board Resolution No. 33, Series of 1996. The Rules and Regulations were adopted pursuant to the provisions of Republic Act 4850, as amended by Presidential Decree No. 813, Executive Order No. 927 and Presidential Decree No. 984. For purposes of the Rules and Regulations, LLDA adopted a uniform effluent standard for BOD of 50 mg/l for discharges to Laguna de Bay or its tributary rivers and streams. All dischargers of wastewater into the Laguna de Bay Region must obtain a discharge permit from LLDA. After the permit application is approved and the discharge permit issued, the discharge permit replaces collectively the previous Authority to Construct and Permit to Operate for the wastewater treatment facility. The total annual user fee for a discharger for the first year is assessed based on the data provided by the applicant and any self-monitoring reports for previous years, the Industrial Effluent Guide, and other data available at LLDA. The firm s estimated user fees for the year must be paid before a permit will be issued. For subsequent years when the permit is renewed, a surcharge or credit may be applied depending on the accuracy of previous year s assessments or actual discharge characteristics. The user fee is comprised of the fixed fee, which is based on the volumetric rate of discharge, and the variable fee, which is based on the unit load of pollution. The fixed fee was designed to cover LLDA s costs for administering the permit program and is determined by the following schedule: Volumetric Rate of Discharge Fixed Fee Within 30 cu.m/day P5,000 More than 30 but less than 150 cu.m/day P10,000 More than 150 cu.m/day P15,000 The variable fee is assessed based on the pollution load, which is computed as the product of the volumetric rate of discharge and the effluent concentration. It was designed so that the fee will be higher for a higher volume and concentration of pollution discharged. The two-tier variable fee includes one charge for effluent that meets the legal standard (50 mg/l BOD concentration) and a higher charge for effluent concentration above the standard (this higher Wastewater Effluent Fee Program Case #82 5

charge is in addition to relevant fines and penalties). The variable component of the fee can be paid in full or in equal quarterly installments as specified in the discharge permit. The following schedule applies for the variable fee: Effluent Concentration Within 50 mg/l BOD Above 50 mg/l BOD Variable Fee P5 per kg BOD released annually P30 per kg BOD released annually LLDA eventually may cover other water quality parameters under the user fee system. User fee rates for any additional parameters will be determined by LLDA and approved by the Board of Directors. Any changes in the existing user fee rates are subject to approval by LLDA s Board of Directors. Water Quality Self-Monitoring Under the Rules and Regulations, LLDA requires the permit holder or discharger to submit a quarterly self-monitoring report. LLDA will also conduct periodic monitoring inspections to determine compliance with water quality standards, the Rules and Regulations, or permit conditions. LLDA can impose an administrative fine in an amount not exceeding P5,000 for failure to comply with the Rules and Regulations or permit conditions. Failure to pay the user fee is sufficient grounds for LLDA to suspend or revoke a discharge permit. If actual discharge conditions in terms of loadings and duration significantly exceed those allowed, LLDA can suspend or revoke a permit and/or impose other penalties. The penalty for failure to comply with LLDA s orders or regulations for control or abatement of pollution is a fine not exceeding P5,000 per day while the violation continues after due notice and hearing. Other penalties may be imposed for failure to renew the discharge permit or refusing entry for inspection, and these may also be grounds for suspension or revocation of a permit. LLDA can order closure of the facility for non-payment of fines and penalties. If an applicant proceeds to discharge despite disapproval of a permit application or suspension/revocation of a permit, LLDA can issue a Cease and Desist Order (CDO) to stop further discharges, close the discharger s operations, and impose fines and penalties. Changes in Industrial Production Processes After LLDA implemented the pollution charge on January 29, 1997, industries changed production processes and implemented other measures to reduce the volume of effluent and pollutants in discharges to Laguna de Bay. Instead of sporadic administrative actions, plant managers now had price signals that encouraged them to internalize their environmental costs or reduce pollution to the point where the marginal cost of abatement is equal to the pollution charge. The number of firms covered increased from 109 in 1997, to 293 in 1998, to 520 firms in 1999. This pilot program began with industry and in later years was expanded to major commercial and municipal sources of wastewater and housing subdivisions and condominiums. Industries covered in 1997 included the top five polluting industries: food processing, piggeries and slaughterhouses, beverages, dyes and textiles, and pulp and paper. Other major industries covered the following year included grain milling, sugarcane processing, petroleum refining, plastics and synthetics, and thermal power generation. The pilot test of the pollution charge program resulted in BOD discharges from affected plants decreasing 88 percent between 1997 and 1999. Increased Funds for Management and Monitoring Eighty percent of the revenues from the effluent charge are earmarked for LLDA for water quality management and monitoring and enforcement and 20 percent are set aside for a local government share to be spent on environmental projects such as establishment of sewage treatment systems. The revenues from pollution charges are remitted to LLDA and have increased its resources for monitoring and enforcement significantly. During the first three years, LLDA collected over P34,000,000 from Metro Manila firms discharging wastewater into the Laguna de Bay watershed. The regulatory monitoring and enforcement components of the program led to closure of around 50 companies between 1998 and 1999 for significant violations. Wastewater Effluent Fee Program Case #82 6

Addressing Public Opposition to the Fee The pollution charge system has been vulnerable to misinterpretation by some stakeholders who have seen it as providing industry with a right to pollute as long as they pay. Although efforts were made to educate the public about its advantages, the system initially faced strong opposition in the media. Numerous meetings were held with the initial 120-150 firms to inform them of how the environmental user fee would be implemented. The reaction from industry was mixed, with some companies who thought they could not afford to pay the fee showing some resistance and others requesting more time to reduce their discharges. Some plant managers considered moving away from the LLDA jurisdiction, but were informed that the fee would be implemented nationwide in a few years. Other companies were confident that their BOD levels would put them into the P5/kg category and publicly supported the program.4 Lessons learned 4 Lessons Learned and replicability Integrated pollution charges for water quality management efficiently served two objectives environmental and economic. The environmental objective is to maintain a specified water quality standard while the economic objective is to encourage firms to pursue the most cost-effective pollution prevention and abatement measures that would allow them to comply with pollution load limits. In LLDA s pilot program, the user fee was carefully designed to provide economic incentives for industrial polluters to reduce the impacts of wastewater discharges to a large freshwater watershed. Setting the charge at a level higher than the cost of pollution abatement did not make it cheaper for firms to continue polluting and just pay the charge. The system for surcharges allowed LLDA to collect from firms whose actual BOD load was greater than the assumed load in their permit application. More important, the system for credits provided incentives for cleaner production because an industrial firm could reduce their charges and receive a credit from the previous year by demonstrating that its actual discharges were less than assumed levels in the permit application. For example, firms could shift to less pollution-intensive products, make process changes, change their inputs, or install or upgrade pollution treatment facilities to reduce the cost of meeting the water quality standard or reduce their pollution charge liability. The pollution charge system raised revenues for water pollution control program management, especially for monitoring and enforcement, to strengthen the government s regulatory mechanisms. It was very important to integrate the pollution charge system with LLDA s regulatory and enforcement program. Institutional strengthening was important to ensure that the government agency, LLDA, had an appropriate organizational structure, equipment, personnel qualifications and training to administer the program. DENR has since proposed a wastewater discharge permit fee that is structured like LLDA s fee. This proposed fee has two components: 1) an administrative fee covering minimum administrative and inspection costs incurred by the government for each applicant, and 2) a load-based variable fee based on the volume and concentration (or pollutant load) of the effluent discharged by the facility. The load-based fee would cover monitoring and other program costs. The DENR proposes that this fee initially be collected for effluents containing BOD for organic wastes and total suspended solids (TSS) for inorganic wastes. DENR also added a proposed stream factor to computation of the load-based fee to account for differences in ambient water quality of the receiving bodies of water. Indirectly, this stream factor accounts for the environmental carrying capacity of these waters. For permitting purposes, BOD would be the basis for computing the discharge fees for industries discharging organic pollutants and TSS would be the basis for those discharging inorganic pollutants. DENR plans to increase the number and capability of its technical staff to support the system when implemented. Wastewater Effluent Fee Program Case #82 7

Replicability DENR is currently examining ways to revise its permit system by merging the Authority to Construct and Permit to Operate into a single discharge permit that would have a defined time limit (e.g., five years). Needed changes are plant-specific discharge permits that tailor the limits for water quality parameters that a facility must meet on a monthly and annual basis as well as maximum limits that must not be exceeded. These revisions would allow the proposed discharge permits to be priced using a pollution charge system. Several impediments have hindered expanding the pilot program to the national level. There is still no legal provision in the Philippines for DENR to retain and earmark revenues from a tax or charge for special purposes or for its programs and operation. Efforts are being made to revise the laws to introduce provisions for earmarking of pollution charges, but the process has been slow. The DENR is not allowed under current law to levy a pollution tax or charge unless through congressional action. Additionally, pollution charges require a monitoring and revenue collection system that has relatively high institutional and human resource requirements because it calls for specialized knowledge and measurement capabilities. The DENR s enforcement and monitoring capabilities are severely hampered by lack of personnel and laboratory equipment. The budget for monitoring, upgrade of laboratory facilities, and hiring and training of personnel is unable to cope with the increasing number of industries. Unlike LLDA, the DENR must rely on a decision by the Pollution Adjudication Board to impose a fine for noncompliance with P.D. 984 permits. The lack of consistent monitoring and enforcement has created an incentive for noncompliance. Other governments may decide that the introduction of a new policy measure such as a pollution charge at the national level involves an unacceptable degree of political risk. In that case, a local pilot program can be a less risky way of testing stakeholder reaction as well as determining the effectiveness of the policy instrument. A pilot program provides the opportunity for fine-tuning before an attempt is made to extend it to the national level. Successful implementation of a pollution charge system must consider the monitoring and enforcement capabilities and provide for an institutional support system. Where the feasibility of monitoring and enforcement is low and shut-down undesirable, mandatory installation of pollution control equipment may be preferable provided that effective use of the equipment can also be mandated and monitored. Importance of Case to IWRM Until recently, most governments relied primarily on direct regulation in water resources management. This case demonstrates that integrating economic instruments into management plans can offer several advantages such as providing incentives to change behavior and raising revenue to contribute to the financial sustainability of water authorities. 5 Contacts Ken Rubin, PA Government Services (formerly Hagler Bailly), 1750 Pennsylvania Avenue NW, Suite 1000, Washington DC 20006, USA; Tel. 202-442-2377; ken.rubin@paconsulting.com David Wheeler, The World Bank, 1818 H Street NW, Washington, DC 20433, USA; Tel. 202-473-3401; dwheeler1@worldbank.org 6 Organizations and References Batcagan, Sabado T. Proposed Wastewater Discharge Permit Fees. Presented at the International Workshop on Environmental and Economic Accounting, Manila, Philippines, September 18-22, 2000. Hagler Bailly Consulting. 1996. An Action Program for the Introduction of Economic Incentives to Promote Water Pollution Prevention and Abatement in the Philippines: Final Wastewater Effluent Fee Program Case #82 8

Report. Prepared for the Department of Environment and Natural Resources with funding from the Japan Grant Fund administered by the World Bank. Philippines Environmental Sector Study: Toward Improved Environmental Policies and Management. World Bank, Industry and Energy Division, Country Department 1, East Asia and Pacific Region. Report No. 11852-PH. December 8, 1993. United Nations Industrial Development Organization. Industrial Policy and the Environment in the Philippines. Report No. NC/PHI/97/020. July 1999. Wheeler, David et. al. 2000. Greening Industry: New Roles for Communities, Markets and Governments. New York: Oxford University Press for the World Bank. Laguna Lake Development Authority website: environmental user fee system http://www.llda.gov.ph/userfee.htm Wastewater Effluent Fee Program Case #82 9