which are to govern the implementation of the fund, with more comprehensive implementation and operations guidelines to be promulgated at a later date. The current programme of informal settler relocation has been developed in compliance with the above judicial and executive directives. The Supreme Court decision identifies all informal settlements that are built in danger areas and in contravention of the Urban Development and Housing Act shall be subject to demolition and relocation. This covers all dwellings built on top of any waterway, or within an easement zone three metres from the shore. All of these areas will be classified as danger zones and will therefore also be subject to the President’s disaster risk reduction plan. The first group of communities to be affected by this programme were resettled during August 2013 from sites on the banks of the San Juan River to an NHA-provided resettlement site in San Jose del Monte, Bulacan. To assist with the implementation of community-driven resettlement proposals, the Australian Agency for International Development (AusAID) has provided funding to provide the necessary technical assistance to expedite this process. This has involved professional support to various grass roots NGOs in executing the required documentation with government agencies to ensure community resettlement proposals are complete and comply with all regulatory requirements.104 At the time of publication no community had yet been resettled within the NCR, with all communities receiving resettlement at NHA sites located outside Metro Manila. There have not yet been any communities resettled through community-driven resettlement proposals, notwithstanding 52 such proposals having been registered with the DILG. According to the December 2013 figures from the DILG, a total of 1,604 households have currently been resettled under the government’s present initiative.105 The Government has identified a total of 104,000 households to be affected by the resettlement initiative, with 19,440 households being prioritised for immediate resettlement as they are located on top of waterways.106 7.2 Observations (a) Exercise of Judicial Power Of some initial concern in the current framework is the operation of the decision of the Supreme Court, which directs various agencies to undertake an environmentallypremised cleaning operation of Manila Bay and surrounding waterways. In determining the source of the environmental contamination, the following was observed: The Court can take judicial notice of the presence of shanties and other unauthorized structures which do not have septic tanks along [rivers in the NCR] which discharge their 104 See: The Asia Foundation, Civil Society Support to ISFs (Presentation), 30 November 2013. Department of Interior and Local Government, Oplan Likas Update (Presentation), 2 December 2013. 106 Department of Interior and Local Government, Metro Manila Development Authority, National Housing Authority and Department of Public Works and Highways, NCR ISFs in Danger Zones (Presentation), 6 February 2013. 105 64  Human Rights in the Rubble