Environmental planning positions require Environmental Planners.

17 July 2026

Full and Immediate Implementation of Republic Act No. 10587 in Local Planning and Development Offices

HON. SECRETARY OF THE INTERIOR AND LOCAL GOVERNMENT
ALL PROVINCIAL GOVERNORS, CITY MAYORS, AND MUNICIPAL MAYORS

Dear Secretary and Local Chief Executives:

The Philippine Institute of Environmental Planners, Inc. (PIEP), together with the broader environmental planning community, respectfully calls for the full and immediate implementation of Republic Act No. 10587, otherwise known as the Environmental Planning Act of 2013, in all local government units.

PIEP and the environmental planning community are alarmed by continuing reports that persons who are not registered and licensed Environmental Planners are being designated, assigned, or allowed to serve in acting, officer-in-charge, concurrent, or similar capacities as heads or assistant heads of local planning and development offices.

These personnel arrangements cannot be justified merely by describing them as temporary, acting, or administrative. The law governs the position and the functions actually performed—not simply the label placed upon the personnel order.

Section 34 of Republic Act No. 10587 provides that, after the statutory transition period, only registered and licensed Environmental Planners may be appointed as heads and assistant heads of government groups, departments, divisions, offices, agencies, provinces, cities, and municipalities, and to other positions requiring the knowledge, skills, competence, and qualifications of registered and licensed Environmental Planners. The statute expressly declares appointments made in violation of this requirement null and void. Sections 5 and 31 likewise prohibit unlicensed persons from offering or rendering services falling within the statutory scope of environmental planning. Section 33 affirmatively requires all government officials to assist the Professional Regulatory Board of Environmental Planning and the Professional Regulation Commission in enforcing the Act.

To implement this mandate, Civil Service Commission Memorandum Circular No. 10, series of 2017, dated 29 March 2017, amended the qualification standards for Provincial, City, and Municipal Planning and Development Coordinator positions. It prescribed Republic Act No. 1080 Environmental Planner eligibility and made the amended standards the basis for CSC action on appointments and other human resource actions. The circular allowed temporary appointments only until 21 June 2018, in the absence of a qualified eligible as properly certified by the appointing authority. That accommodation has long expired.

DILG Memorandum Circular No. 2018-43, dated 26 March 2018, reiterated Republic Act No. 10587 and CSC Memorandum Circular No. 10, series of 2017. It enjoined governors and mayors to ensure that concerned LGU functionaries secure the requisite Environmental Planner license and emphasized that the CSC qualification standards would govern appointments and other human resource actions involving the subject positions.

The 2025 Omnibus Rules on Appointments and Other Human Resource Actions has removed any remaining doubt concerning designations. Section 13(c)(2) categorically provides:

“Designees shall meet the QS of the positions to which they are designated.”

This rule applies whether the duties are performed concurrently or on a full-time basis and whether the person is called “Acting,” “Officer-in-Charge,” or by some other description. Agency human resource officers must report designation orders to the CSC every semester. If a designation violates the rules, Section 13(c)(11) requires written notice to the agency and an order directing the designee to cease performing the duties of the invalid designation. The official or employee who issued or caused the invalid designation may also face administrative sanction.

Local autonomy and the appointing discretion of Local Chief Executives do not include authority to dispense with statutory qualifications. The Constitution requires civil service appointments to be made according to merit and fitness. In Civil Service Commission v. Binay, the Supreme Court stressed that an appointing authority’s discretion is conditioned upon the appointee possessing the qualifications required by law; otherwise, the appointment may be declared invalid in the interest of merit and fitness in the civil service. (Civil Service Commission v. Jejomar Erwin S. Binay, Jr. and Gerardo Kangleon San Gabriel, G.R. No. 232168, 17 October 2022.)

Accordingly, PIEP respectfully but firmly calls upon all Local Chief Executives to:

1. Immediately review all appointments, designations, acting assignments, officer-in-charge orders, concurrent assignments, and similar arrangements involving heads and assistant heads of local planning and development offices;
2. Terminate invalid designations and assignments and direct unqualified designees to cease performing the duties reserved by law for qualified and licensed Environmental Planners;
3. Appoint or designate only persons who meet all applicable qualification standards, including a valid Environmental Planner license and the corresponding Republic Act No. 1080 eligibility;
4. Examine actual duties, not merely position titles, when determining whether a position requires the professional knowledge, skills, competence, or services falling within Sections 4 and 5 of Republic Act No. 10587;
5. Require LGU human resource offices to comply fully with the semestral reporting requirements under Section 13(c)(9) of the 2025 ORAOHRA; and
6. Fill vacancies through transparent and merit-based recruitment of qualified Environmental Planners instead of resorting to informal assignments that evade professional qualification requirements.

PIEP likewise respectfully calls upon the Secretary of the Interior and Local Government to issue a renewed nationwide directive requiring all LGUs to comply with Republic Act No. 10587, CSC Memorandum Circular No. 10, series of 2017, DILG Memorandum Circular No. 2018-43, and the 2025 ORAOHRA; to require a national compliance inventory; and to coordinate enforcement with the CSC, PRC, and Professional Regulatory Board of Environmental Planning.

This appeal does not seek to prevent members of other legally recognized professions from performing functions lawfully belonging to their professions. Section 39 of Republic Act No. 10587 expressly protects such practice. It seeks only to enforce the positions and professional functions that Congress has expressly reserved for registered and licensed Environmental Planners.

Noncompliance is not a harmless personnel irregularity. Unauthorized practice may result in criminal liability under Section 36 of Republic Act No. 10587, while invalid appointments or designations may result in administrative sanctions and appropriate corrective action by the CSC.

PIEP remains prepared to cooperate with the DILG, CSC, PRC, local government leagues, and individual LGUs in compliance verification, professional recruitment, and capacity-building. Nevertheless, documented violations cannot be ignored indefinitely. Where necessary, PIEP will refer such matters to the appropriate regulatory, civil service, administrative, and prosecutorial authorities.

The transition period ended years ago. Full compliance is no longer a future objective; it is a present legal duty.