Microsoft word - wb red sea dead sea hearing june 16 2010 _2_

IUED Comments to the Public Hearing held on June 16, 2010
Introduction
Adam Teva V'Din - the Israel Union for Environmental Defense (IUED) is a non-governmental organization of lawyers, scientists, urban planners and environmental specialists dedicated to protecting Israel's natural resources and public health. Since its founding in 1990, IUED has amassed a long record of achievements that include precedent-setting legal cases and landmark legislation. IUED is active in a wide variety of environmental issues that include protecting water resources, air quality, solid waste and recycling, land use and open spaces conservation, climate change, and environmental justice. The Israel Union for Environmental Defense greatly objects to the proposed Red Sea Dead Sea Conveyance Project, considering the potential disastrous environmental impacts it may have on the entire region, the exorbitant costs associated with its implementation, the innumerable uncertainties and risks accompanied with infrastructure projects of this dimension and the irreversible impact it will have on unique environments of international The root causes to the decline of the Dead Sea and the lack of water in the region should
be addressed as the main solution to the problems
The proposed Red-Dead project was originally proposed to solve two separate problems: 2) The need for additional potable water in the region, mostly in the Kingdom of In order to identify the most cost-efficient, effective and environmentally conscientious solution/s to these problems, the root causes must first be established. As was presented by IUED in previous public hearings to the World Bank, and as is well known, the declining level of the Dead Sea is due to two main factors: 1) The mismanagement of water resources in the region, and the diversion of up to 2) The extensive use of Dead Sea water on behalf of the chemical industry both in Israel and Jordan – attributing 35 – 40% to the decline of the water level in the Therefore, the first and most logical approach to solving the issue of the declining level of the Dead Sea would be to inspect the water management practices in all the beneficiary parties of the Jordan River (the main source of water to the Dead Sea), and to determine if these management practices can be altered, in order to free-up water that can then be allocated to the Jordan River and from there to the Dead Sea. The organization Friends of the Earth – Middle East recently undertook such a task and published two reports that show that in fact mismanagement of water resources in Israel, Jordan and the Palestinian territories has led to the misuse of over a billion cubic meters of water a year12. Solutions such as water saving devices, fixing leaks in water distribution systems, grey-water and reclaimed sewage water reuse, changes in water pricing, modifications to the crop types being grown and to the extent of agriculture in local economies, and more, are all solutions that would make large amounts of water available to the respective water economies. This in turn would decrease demand for additional water resources as well as allow for the partial rehabilitation of the Jordan River, which in itself brings considerable benefits to the region, in addition to alleviating the rate of decline of the Dead Sea. These solutions were found to be cheaper than standard sea-water desalination, which is currently the marginal The second cause for the declining level of the Dead Sea is the use of its waters for industrial mineral production. While the mineral production industry is an important part of both Israeli and Jordanian economies, this does not go to say that the current extent of the industry and its implications on the environment can be justified. Less water-intensive technologies such as use of membranes to extract the minerals, should be researched intensely in hopes to implement such a solution in the near future. Until then, minimizing the industrial activity and especially the water extraction from the Dead Sea should be The proposed solutions to the aforementioned problems should evolve from these root causes. Therefore, we propose that the solution to the declining level of the Dead Sea involve partial rehabilitation of the Jordan River as the main water source of the Dead Sea, 1 Gafny, Sarig, S. Talozi, B. Al Sheikh and E. Yaari, "Towards a Living Jordan River: An Environmental Flows Report on the Rehabilitation of the Jordan River", Friends of the Earth, Middle East, May 2010. 2 EcoPeace/Friends of the Earth Middle East, "Towards a Living Jordan River: An Economic Analysis of Policy Options for Water Conservation in Jordan, Israel and Palestine – Draft Report for Discussion as well as changes in the management practices of the water resources both in Israel and Jordan in order to make both water economies more efficient. The fact that the World Bank has chosen to examine a mega-infrastructure project of unprecedented proportions rather than the root causes as a solution to the problem at hand exhibits imprudent behavior on behalf of the World Bank. Adoption of the precautionary principle will most likely prevent implementation of the
proposed mega-project
A project the size and scope of the Red Sea-Dead Sea Conduit is likely to have ecological consequences that cannot be predicted and has the potential to be disastrous to the region. The proposed projects aims to flip nature upside down, connecting water bodies that throughout history have been separate. This project will instantaneously change what took millions of years for nature to create – the unique mineral content of the Dead Sea, which not only serves human kind with its unique healing properties and industry with a lucrative mining business, but also provides the world with a one-of-a-kind geochemical feature. Destroying it would be preventing current and future generations from the potential benefits that coincide with such unique ecosystems – such as scientific research and discovery, medicines, and a better understanding of our world. The exorbitant cost of the Red-Dead Conduit is a wasteful allocation of resources that
could otherwise be used to solve serious global health and environmental issues
In light of the fact that alternative water resources can be made available in the region at a cost less than the current marginal cost of water, a project such as the proposed Red-Dead Conduit that is expected to greatly increase the marginal cost of water, perhaps as much as three-fold, would result in a waste of World Bank funds. The exorbitant estimated cost for implementation of the project would be a dire waste of taxpayer monies in both donor and beneficiary countries, money that could otherwise be spent providing basic human needs to populations around the world. For instance, according to the World Health Organization, around 2.6 billion people lack access to adequate sanitation globally. In Africa alone, 115 people die every hour from diseases linked to poor sanitation, poor hygiene and contaminated water. Studies show that proper sanitation can reduce cases of diarrhea by one-third, a disease that is responsible for 1.5 million deaths every year. Moreover, for every US$ 1 invested in improved sanitation, shows an average of US$ 9 return in value. Lastly, The Millennium Development Goals set by the WHO target 75% global sanitation coverage by 2015. The cost to reach the milestone is estimated at US$ 14 billion annually through the
period3. This amount is strikingly similar to the cost of construction of the Red-Dead Conduit 3 World Health Organization, http://www.who.int/features/factfiles/sanitation/facts/en/index8.html (estimated at $15 billion). Instead of building a mega-infrastructure project with potentially disastrous environmental repercussions, wouldn't the money be better spent funding a year's worth of reaching global sanitation goals, thus saving the lives of millions of people? There are numerous flaws in the Environmental and Social Assessment (ESA) process and
Interim Report
Despite the fundamental flaw underlying the consideration of the proposed Red-Dead Conduit project as the central solution to the aforementioned problems, I will nonetheless present the reservations and objections of IUED to the studies and the examination process currently undertaken by the World Bank teams. First and foremost of the numerous defects of the environmental assessment process is the lack of adequate time given to prepare a comprehensive study of alternatives to the
proposed project. Each alternative should be examined to the same degree of seriousness as the project itself, especially due to the fact that a number of the alternatives will prove to be more cost-efficient with more positive environmental effects. In order to properly weigh the proposed Red-Dead project vis-à-vis each proposed alternative, the full financial, environmental, social, geopolitical and implementation feasibility of each alternative must be well defined. The fact that the study was commissioned just recently and that the results are due by the end of this year is a set-up for failure. There is no feasible way that a team of three experts will be able to produce a serious assessment of the many alternatives to the project in such a limited time period. The experts will not have the time or resources to provide new information, research or models in regards to the potential effects of the alternatives, posing a great impediment to the ability to compare the potential alternatives to the proposed project. This in addition to the limited time and resources allotted towards the completion of the entire environmental and social assessment. Less than a year and half was given to create models of the Red Sea and the Dead Sea that will be used to assess the potential impact of the project. Creation of accurate models that take into account the numerous variables of these complex aquatic systems require much more time. The validity of models produced in under a year and a half is questionable, a fact which raises concerns as to the accuracy of the environmental assessment in its entirety. The environmental assessment does not include a model for groundwater flow in the Arava Valley (similar in scope to the models being created for the Dead and Red Seas). The transport of high-salinity seawater over 180 kilometers of the Arava aquifer, via pipelines, tunnels and/or channels that will eventually leak, will most likely pollute an aquifer which is the sole water supply for the many communities in the Arava region. An accurate groundwater flow model needs to be presented in the framework of the ESA in order to assess the potential risk and ways to mitigate this problem. Beyond the problem of the time allowed to complete various elements of the ESA and the lack of depth of certain studies as referred to above, the current ESA as submitted in the Revised Initial Assessment Report lacks reference to some of the potential adverse environmental and health effects of the project. 1) Health issues that may arise from the quality of water supplied by the proposed
mega-desalination plant. It is well known that desalinated water is lacking in
essential minerals such as calcium and magnesium and possibly other essential micronutrients required for human health. Consumption of desalinated water may result in magnesium or calcium deficiencies in the receiving populations. The WHO recommends that communities that rely on desalinated water as a main source of their water supply should ensure that the total intake of nutrients is not significantly "Stabilization practices should ensure that the overall process does not significantly reduce total intake of nutrients such as calcium, magnesium and fluoride. Based on local circumstances, public health authorities may wish to set a requirement to further modify final drinking-water composition in light of overall mineral nutrition."4 The ESA should take into account this detrimental effect on water quality and propose mitigation measures. 2) Detrimental effects of backwash water and the brine waste from the desalination
plant. The Interim Report briefly summarized the treatment processes planned for
the desalination plant (p. 46 – 47 of the report) and mentioned the disposal of the concentrated brine in the Dead Sea. No mention was made of use of chemicals such as ferric-chloride as a flocculant during the pretreatment process, or anti-fouling agents containing phosphorus. Both iron and phosphorus are considered nutrients for algae and will most likely exacerbate algal blooms in the Dead Sea as a result of disposal of the brine waste from the desalination plant. This risk must be addressed in the final report including mitigation measures such as land-based disposal of the chemicals used in the pretreatment process. 3) Use of enormous amounts of materials for the hundreds of thousands of
membranes that would be used in the desalination plant and will need to be
replaced regularly. This will not only require consumption of large amounts of
membrane material but will also generate large amounts of waste. This issue should 4 World Health Organization, Calcium and Magnesium in Drinking Water, Public health significance, 2009 4) The negative energy balance of the project. Until now, the project was being
promoted as one that would produce renewable energy for the region. While this is still the case, operation of the project itself requires more energy than that being produced – and thus will require the erection of large power plants in the area. This in turn will increase the greenhouse gas and other air pollutant emissions in the Jordan Valley area. This is yet another problematic aspect of this project. Conclusion
In summary, it remains to be the opinion of the Israel Union for Environmental Defense, that first and foremost, the root causes for the decline of the Dead Sea and the lack of potable water in Jordan must be examined. Those root causes are the mismanagement of the water economies of the beneficiary countries and the intense industrial mineral production from Dead Sea water. The potential solutions to these problems should arise first and foremost from the root causes and work towards alleviating the effects of the root causes. Secondly, the proposed Red-Sea Dead Sea conduit is a project of enormous magnitude, with the
largest pumping station and desalination plant on earth. The mixing of Red Sea water with
Dead Sea water will irreversibly change the chemical composition of the Dead Sea, a one-of- a-kind geochemical feature of our planet. It would be a travesty to destroy such a precious resource. The precautionary principle must guide the planning team, as the actual repercussions of a project of this proportion are unpredictable. In order for the Environmental and Social Assessment to be a useful and informative document, the time allowed to develop models that will predict potential environmental effects or to study alternatives must be sufficient. At the moment this is not the case, far from it. It is unlikely that the alternatives study and many other components of the ESA will provide a sufficient base of data and information to accurately assess the full implications of the project or to allow for proper mitigation measures to be put in place. Lastly, the current draft of the ESA does not address all of the potential impacts of the project, and I mentioned just a few above. Water Scientist, Israel Union for Environmental Defense

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