The first ecozones in the country were established in ancestral domains. As in the case of the Mining Act, new and more powerful governance structures and planning modalities were put in place, which supplanted the existing traditional leadership structures and resource management arrangements of the affected indigenous communities. Moreover, these new ecozones did not recognize the rights and ownership of the IPs of their ancestral domains. The Philippine Export Zone Authority (PEZA) has declared that it will pursue the establishment of at least 300 new ecozones Philippines. These ecozones will have an area ranging from 1,000 hectares up to 4,000 hectares. A cursory review of the proposed sites of ecozones shows the potential impact these will have on the land tenure of indigenous peoples. Climate change impacts on ancestral domains. The ancestral domains of the indigenous peoples are in places marked by extreme physical and ecological conditions, covering areas from mountain ridges to reefs. Most of these areas are in high-risk zones with ecosystems that are highly sensitive to the slightest changes in climate. Over the past decade, indigenous communities have noticed extreme changes in the weather patterns that have affected their livelihoods. Traditional indicators for the start of the planting seasons have gone into disarray. The prolonged droughts and sometimes very early rains coupled with extreme typhoons have had a serious impact on the lives of many indigenous communities in the country. Expansion of investments and mining. The bulk of the last remaining forests, natural resources and environmentally critical areas, which provide essential ecosystem services such as watersheds, are within ancestral domains. These resource-rich areas are often targeted for exploitation by investors. The staggering number of mining applications in ancestral domains attests to this fact. The emergent trend of large-scale agricultural investments in Palawan and Central Mindanao also threaten the tenurial security, access and control of indigenous communities over their ancestral domains. While some indigenous communities may have the wherewithal to engage big business, an overwhelming majority of communities do not have the capacity to actively challenge and engage those who have interest over their lands. 2015 Supreme Court decision. The 2015 Supreme Court (SC) decision on the Aberasturi vs. Unduran et.al. case could have a profound impact on the implementation of IPRA. The SC decision has effectively clipped the ability of the Asian NGO Coalition for Agrarian Reform and Rural Development (ANGOC) 85