December 5, Question or Issue Raised or Suggestion Made

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1 Red Sea - Dead Sea Water Conveyance Study Program Matrix of Comments on Terms of Reference for the Feasibility Study and Environmental and Social Assessment December 5, 2007 Theme I. Governance of Study Process Sub-theme A: Absence of government environmental authorities on the Study Technical Steering Committee 1. Given the Terms of Reference (TOR) statement that the project purpose is primarily environmental, it defeats the purpose that the head of the Steering Committee for each Beneficiary Party (TOR section 15) is not a representative of the Environment Ministry/Authority. The World Bank is requested to encourage beneficiary governments to appoint their respective Environment Ministries to be the lead agency for the project Technical Steering Committee. The Governments of the three Beneficiary Parties Jordan, Israel and the Palestinian Authority appoint their members to the Study Technical Steering Committee (STSC). These appointments are not made by the World Bank. 2. In fact it is not clear what role the Environment Ministries are playing at all. The membership of the STSC includes representatives of the Ministry of Environment of Jordan and the Palestinian Authority. The Head of Unit for Environmental Policy at the Ministry of Environmental Protection has permanent observer status in the STSC delegation of Israel. 3. The initial consultations between Jordan, Israel, the World Bank and the donor countries did not involve the Palestinians at any level. After the objection of the Palestinians and the Arab countries and with the support of Jordan, the TOR was revised with the mention of the Palestinians as beneficiaries and riparians. 4. Palestinian participation should be expanded to include representatives from the Ministry of Planning, Water Authority and Environment Authority. However, in the Palestinian Authority, the Environment Minister has made public statements that he is against the project and refuses to be involved. The project should be placed under the umbrella of the PLO, since it affects all the Palestinians in the occupied territories and the Diaspora. 5. In Israel, the Technical Steering Committee team is led by the head of the Water and Sanitation Authority. The Israeli Environment Ministry representative has only observer status and is not even one of the four Israeli Steering Committee representatives. The Palestinian Authority is one of the three Beneficiary Parties and will take an active role in the undertaking of the Study Program. The TOR was prepared with the input of experts representing the Palestinian Authority. The Palestinian Authority is a Beneficiary Party and appoints the Palestinian members of the STSC. The Palestinian Authority members of the STSC are senior level experts from the following organizations: Negotiations Support Unit, Palestinian Water Authority, Environmental Quality Authority and Energy Authority. The Israeli members of the STSC are supported by a representative of the Ministry of Environment who serves as an advisor to this group. 6. In Jordan the whole process is being led by the Jordan Valley Authority under the The Jordanian members of the STSC are senior level experts from the following 1

2 auspices of the Ministry of Water and Irrigation. 2 organizations: Ministry of Planning and International Cooperation, Ministry of Water and Irrigation, Jordan Valley Authority and Ministry of Environment. 7. We should ensure a democratic, professional and transparent process. The members of the STSC are committed to following a democratic, professional and transparent process. Sub-theme B: Absence of UNEP and UNESCO representatives on Study Technical Steering Committee 1. In order to strengthen the credibility of the process, there is a need to appoint two additional representatives to the Technical Steering Committee (TOR section 15) one from UNEP and the other from UNESCO. Both UN agencies have representatives in the region either in Amman or Ramallah and are the leading UN agencies dealing with environmental issues. 2. UNESCO representatives should be nominated to serve on the Steering Committee and should be involved in the process, including conducting additional studies and not just review the results. The STSC is a technical committee overseeing the implementation of the Study Program. Its composition was determined by the TOR and is composed of the representatives of the Beneficiary Parties and the World Bank only. The Consultants will have the ability to consult with third parties on an as needed basis and as appropriate. See response to I.B.1, above. Sub-theme C: Potential conflict of interest where the government members of the Technical Steering Committee appoint the Panel of Experts 1. In order to ensure independence of decision making the proposed two UN agency representatives to the Steering Committee should first make a recommendation for the Panel of Experts, to then be approved by the Steering Committee as a whole. (TOR section 17.1). 2. The World Bank should have greater representation on the steering committee due to the political situation. 3. There should be another team added from the World Bank to address other alternatives to the proposed project including the Mediterranean Sea and the northern alternatives. The appointment of the members of the Panel of Experts will be made by the STSC. The World Bank has two representatives on the STSC and believes that this is an appropriate number of members. Alternatives to the proposed project will be addressed as part of the TOR. See response to V.A.4, below. Sub-theme D: The tasks of the Panel of Experts need to be further defined in the TOR to include deciding on whether new studies and/or extension of study time are required 1. Currently (TOR section Sub-studies), the prescribed process is decided by the Technical Steering Committee which is made up of project proponents. Since some government representatives have already stated that the study process of 24 months is too long, there is a clear conflict of interest in having them also determine if and what new studies may be required and any associated extension of time. This task should therefore be transferred to the Panel of Experts which is not only an independent body, but is also better placed to make such determinations in the first place. The STSC is responsible for the overall management of the Study Program. The Panel of Experts will serve in an advisory role and will provide independent views on a number of issues for consideration by the STSC.

3 Sub-theme A: Need for additional public meetings 3 Theme II: Public Consultation Process to Date 1. The attempts of August 2007 to hold public hearings in Amman, Ramallah, Jericho and outside Jerusalem have been less than satisfactory. Therefore, a public hearing process on the draft TOR has not occurred and needs to be attempted again in a professional manner. The objective of the public meetings held in August 2007 in Jordan, Israel and the Palestinian Authority was to provide an opportunity to discuss the Study Program and to receive comments from a range of stakeholders. A large number of persons attended the public meetings and a significant number of comments were received orally and in writing as summarized in this matrix. The TOR for the Study Program provides for addition public meetings to be held at a number of points during the study process with a diversity of stakeholders. The TOR was posted on the website for the Study Program on July 18, Information on the public meetings was posted on the same website on August 2, 2007 and on the Israeli Water Commission website at the same time. The World Bank also advised the Friends of the Earth Middle East (FOEME) through an e- mail on August 2, 2007 of the dates, times and locations for the meetings. The FOEME was also asked to assist the public meeting process by forwarding this information to other stakeholders it believed would be interested. Notices were also placed in local newspapers in Jordan, Israel and the Palestinian Authority; however, these could have been posted further in advance of the meetings. 2. Public participation is crucial before the TOR is closed and we need to hear the opinion of the residents. Sub-theme B: Notification of general public and interested stakeholders 1. Minimal efforts, if any, were made in all beneficiary countries to alert the general public and to specifically notify interested stakeholders. The Israeli invitation to the public was published in a small advertisement 48 hours prior to the meeting and did not include any reference to the meeting objectives. 2. Civil society has not been adequately prepared to participate in the Amman hearing; and an advertisement in the newspaper is not sufficient for this purpose. 3. Specific requests for notification, agenda and relocation to a more central location in the case of Israel were either ignored or denied. Notices for future public meetings will be made earlier on both the website and through notification in newspapers and other means of communication. See response to II A1. above. See to II.A.1, above See to II.A.1, above See to II.A.1, above

4 4. The lack of notice and timing of the hearing in the midst of August holidays has meant that many interested parties and leading academics that had wanted to be present at the hearings were absent. 5. Palestinian representation at the Jericho public hearing consisted of 50% Consultants; there was no local government representative present due to the short notice for hearing. There is a need for a second meeting. 6. Due process standards are not being maintained for the public hearings. As of August 25, it was not possible to find the World Bank presentation and contact details and proposed protocol of the public meeting on the World Bank or the Israeli Water Authority websites. 7. The public process lacks basic principles of stakeholder responsibility management: stakeholder engagement, transparency and accountability. 8. The World Bank characterized the August 12, 2007 process as a public meeting, whereas the Israeli government called it a public hearing. Please clarify the correct characterization as there is a fundamental difference between the two processes. Sub-theme C: Document translation 1. Failure to translate the TOR documents to Arabic and Hebrew has meant that local communities remain ill-informed. Sub-theme D: Stakeholder identification and participation 4 See to II.A.1, above Additional meetings will be held during the course of the Study Program in Jordan, Israel and the Palestinian Authority. Information on the public meetings and written comments will soon be posted on the website of the Study Program. See to II.A.1, above The objective of the meetings held in August 2007 in Jordan, Israel and the Palestinian Authority was to provide an opportunity to discuss the Study Program and to receive comments from a range of stakeholders. The use of two different terms was not intentional and does not change the basic objective of the sessions. The STSC is reviewing the provisions in the Study Program related to translation of documents in Arabic and Hebrew. Information on the Study Program for use at the community level will soon be available in both languages. Consultations will be undertaken at a number of locations during the course of the Study Program that should allow for effective engagement of local communities. See Clarifications, Task Added and Guidance for the Study Program, dated December 3, There is no clear definition of the stakeholders. As noted in the TOR different stakeholders have different interests and rank the potential benefits of the project in different ways. (1.3) The World Bank considers stakeholders to include, but not be limited to, a diversity of parties: national government, local government, special governmental organizations, academic and applied research institutes, private sector, professional organizations, civil society organizations, nongovernmental organizations, and individual citizens. 2. Stakeholders appear to be carefully selected from among government agencies with an interest that takes preference over fundamental and long-term environmental issues. There was no selection of stakeholders made for the public meetings, the broad range of participants at the public hearings demonstrates that stakeholders are largely self-selected and represent a diversity of interests.

5 3. Representatives of affected industries should participate in various forums to present industry concerns about the project and to share long industry experience in the Dead Sea region. Sub-theme A: Comprehensiveness of Feasibility Study 5 The Study Program includes additional public meetings and specific provisions for analysis of both positive and negative impacts on potentially affected industries. Theme III: Relationship between Environmental and Social Assessment Study and Feasibility Study 1. The EA should be used to decide not only whether the project is feasible, but also whether it is environmentally sound and sustainable when analyzing the project and other alternatives. This is even more the case as the TOR itself states that it is designed to be carried out within a comprehensive development framework (TOR section 1.4, last paragraph) and that it is being promoted as an environmental project with potential water supply benefits (TOR section 1.3). 2. The current draft TOR deals in a comprehensive fashion only with the needs of building the proposed conduit. Institutional issues mentioned in the TOR are limited to ownership, operations and legal aspects of running the proposed conveyance and any desalination or energy plant to be built. The Environmental and Social Assessment will provide information to decision makers and stakeholders about the potential environmental and social impacts of the proposed Red Sea Dead Sea Water Conveyance. The Environmental and Social Assessment is a study prepared by Consultants and will not decide whether the project or alternatives are feasible, this is a decision that rests with the representatives of the Governments of the Beneficiary Parties. The TOR focuses on the institutional issues associated with the management and operation of the proposed Red Sea Dead Sea Water Conveyance and associated facilities. Broader institutional arrangements for water management between and/or within the three Beneficiary Parties are not within the scope of the Study Program. 3. What will be done if the proposed project is not feasible? The Feasibility Study and Environmental and Social Assessment will provide decision makers and stakeholders information concerning the feasibility of the proposed Red Sea Dead Sea Water Conveyance, taking into account all relevant aspects (see TOR Section 1.4). Any decision concerning the proposed project or alternatives rests with the Governments of the Beneficiary Parties. 4. The World Bank should ensure that the term Environment appears as a vital component of the feasibility study whenever the name of the TOR is used in presentations. Theme IV: Applicability of World Bank Operational Safeguard Policies STSC agrees that environment is a vital component of the feasibility study, as reflected in the formal title of the TOR, Feasibility Study and Environmental and Social Assessment. The Bank will use the full title consistently in its presentations. Sub-theme A: Need for clarification concerning the application of the World Bank policies and guidelines, including safeguard policies, to the Study Program 1. World Bank staff has repeatedly stated verbally that World Bank operational guidelines and safeguard policies will not apply to this project since they have described the role of the World Bank as only coordinating donor support and managing the study, rather than it being an actual World Bank project using World Bank funds. 2. A legal opinion (obtained by FOEME) concludes that World Bank safeguard policies do apply. 3. World Bank staff has also stated in writing that the beneficiary governments have This is correct. This assertion is not correct. The World Bank Study Program website homepage states that The World Bank agreed to manage the Study in accordance with its established policies and guidelines. These policies and guidelines include all applicable World Bank safeguard policies. Independent of any legal opinion from an external party, the World Bank is committed to application of the relevant safeguard policies to the Study Program.

6 agreed to the governance of World Bank operational guidelines. 4. The World Bank project website homepage further states that The World Bank agreed to manage the Study in accordance with its established policies and guidelines. 5. Indications that the Bank is committed to following its safeguard policies (for EA) in the TOR includes the following: The Bank has committed to a full Environmental and Social Assessment per (TOR section 1.4). The Bank is undertaking a public hearing on the TOR, prior to the issuance of an RFP to external Consultants. The TOR creates an Independent Panel of Experts (TOR section 17.1) to serve as independent reviewers of the Feasibility Study and Environmental and Social Assessment, in recognition that the project is a Category A project, highly complex and will present major irreversible decisions. 6 This is correct. Theme V: Need for Broader Alternatives Assessment The World Bank is committed to application of the use of relevant safeguard policies to the Study Program. Sub-theme A: Applicable law, World Bank guidelines, U.S. regulations and common sense/good practice dictate the need for an independent and comprehensive alternatives assessment carried out by an independent Consultant and not an interested party 1. Jordanian, Israeli and Palestinian environmental laws also require that as part of conducting an environmental assessment of a major project, alternatives to the project be studied. 2. World Bank guidelines require that alternatives to the given project be compared and that studies of these alternatives be carried out by independent experts (OP 4.01 Environmental Assessment). 3. The regulation that governs the analysis of alternatives in environmental assessment under U.S. law declares that the alternatives section is the heart of the environmental assessment (40 C.F.R. sec ). 4. The TOR document shows that the World Bank also acknowledges the need to examine the alternatives and to check whether they comply with the principles of sustainable development. On page 25 of the TOR document, it is written: review of all the alternatives considered in the past and any new ones that may emerge is essential to help guide the selection of a set of preferred alternatives for a detailed feasibility study. The provisions of World Bank Operational Policy 4.01 on Environmental Assessment provide for the analysis of alternatives to be undertaken as part of an environmental assessment for a large and complex proposed project. The safeguard policies of the World Bank apply to the Study Program, not the provisions of 40 CFR of the United States. The TOR for the Environmental and Social Assessment provides for the examination of both the no action alternative and other reasonable alternatives to the proposed project. This is correct.

7 And on page 26: the previously considered and rejected alternatives should be compared in terms of potential sustainability for both environmental impact and economic costs. 5. For the tasks in section 8.4.1, dealing with the Economic and Financial Analysis of Restoring the Dead Sea, common sense would dictate that comparisons need to be made with other reasonable alternatives to the project and not only the without project situation. The same alternative comparisons are missing in section as regards Water Supply and Energy Options for the project and for section as regards a Financing Plan. Without the study of reasonable alternatives and their comparison with the project, section of the TOR, Integrating Findings into a Coherent Decision Support Framework is incapable of being carried out by the Consultant in any meaningful manner. 6. The conveyance proposal is the result of political prejudgment and not a real alternative for the desired objectives. 7. The World Bank stated that all the alternatives will be checked which is not happening. 8. There are no independent Consultants that are called to check all options, including the northern alternative. The public is being denied the required information. 7 This is correct. The TOR for the Environmental and Social Assessment provides for the examination of both the no action alternative and other reasonable alternatives to the proposed project. The proposal was first presented at the Johannesburg Summit on Sustainable Development in 2002 as a means to address the decline of the Dead Sea. See response to V.A.4, above. Sub-theme B: Written clarification from the World Bank is required as to the approach to be used for the analysis of alternatives 1. Why is an independent assessment of all reasonable alternatives not being carried out as part of the Feasibility Study and Environmental and Social Assessment, contrary to established World Bank policies and guidelines, in particular why in Part E Environmental and Social Assessment of the TOR, (section ) is there no task that requires the independent Consultant to study alternatives to the project at the regional level? This is contrary to all other tasks defined in the TOR where the independent Consultant plays an active role. In Sub-Task 2, dealing with alternatives at the regional level, the role of the Consultant becomes passive, accepting a report provided by no other than the three governments, who are the proponents of the RSDS project. 2. We are glad to hear from the World Bank s representative about the need to study the alternative options as part of the key issues to be addressed. We expect this to be a published formal decision by the World Bank and the very first stage of the process. Sub-theme C: Criteria for examination of alternatives 1. Alternatives should be considered based on potential sources of water available to An independent team of Consultants will be selected to examine all reasonable alternatives to the proposed project. See Clarifications, Task and Guidance for the Study Program, dated December 3, The analysis of alternatives will be carried out by an independent 3-member team of highly qualified experts. The team of three independent consultants, not otherwise affiliated with the Study Program, will undertake the analysis in a manner consistent with the provisions of Section of the TOR. The consultants report will be incorporated into the Environmental and Social Assessment Report, which will be reviewed by the Independent Panel of Experts and disclosed as part of the public consultations process. The TOR for the Environmental and Social Assessment provides for the examination of both the no action alternative and other reasonable alternatives to the proposed project. The statements made by the World Bank representative in the public meetings are consistent with the TOR.

8 meet the cm/year deficit that is responsible for the decline in Dead Sea water levels. 2. Alternatives should be examined on the basis of a clear definition of objectives, including: Rehabilitation of the Dead Sea and its surrounding environment. Increasing the water availability in the region by added new resources. Prevention and reduction of environmental pollution (both local and global). Advancement of regional trans-boundary cooperation. Optimal management of water resources in the region. 8 Theme VI: Specific Alternatives That Should Be Considered Sub-theme A: The Jordan River alternative needs to be the key focus of a study of alternatives 1. A study which seeks to address the declining levels of the Dead Sea without addressing what constitutes the root cause of the decline (i.e., degradation of the Jordan River) is grossly flawed. The TOR fails to mention that Israel has degraded the Red Sea in violation of international law. 2. Although the TOR includes a requirement that The Technical Steering Committee shall provide the Consultant with a report on alternatives/options that have been proposed, studied and/or are being undertaken under a variety of initiatives to arrest the Decline of the Dead Sea including whether the option of increasing Jordan River flows to the Dead Sea is or will be attainable taking into account all considerations it is in fact the Beneficiary Parties themselves who will be wholly responsible for preparing information on the Jordan River alternative. tying the hands of the independent Consultant to accept government findings and integrate them into the report without any questions asked. 3. Key professionals knowledgeable of the issues in both Israel and Jordan have made statements in favor of a study of the Jordan River option. Stabilization of the Dead Sea water level by renewing the flow of the Jordan River is the best solution since it is closest to the natural situation. It lacks environmental risks and provides additional benefits which do not exist in any sea water diversion alternative. 4. An objective study of alternatives to the project, a feature deficient in many areas of the present version of the TOR, would likely reveal that a peace dividend from the Jordan River alternative will be of much greater economic benefit to the region. The Study Program will review the causes of the declining levels of the Dead Sea; however, the focus will be on the technical, economic, environmental and social evaluation of the proposed Red Sea Dead Sea Water Conveyance as a proposed option. The Study Program is not designed to address broader issues related to international relations and law concerning the Beneficiary Parties. See response to Section V, B, 1 above which addresses this issue. 5. According to a study issued by the Royal Scientific Society of Jordan: [A] simple

9 and direct idea to save the Dead Sea would be to implement an integrated, cooperative plan between the three parties (Jordan, Israel and Palestine) to efficiently manage the Dead Sea basin and distribute the surrounding water resources equally assuring that considerable amount of fresh water flows back to the Dead Sea. If this plan is well studied analyzed and skillfully managed then it will be much easier, more feasible and with very low impact on the environment compared with other solutions. 6. Former Israeli Water Commissioner Professor Dan Zaslavski has estimated that regenerating the flow of the Jordan River to bring water to the Dead Sea will cost no more than $800 million, substantially less than the $5 billion it is estimated that will be required to complete the RSDS project. 7. In addition to the comparatively low cost, the regeneration of the Jordan River will in itself deliver hundreds of millions of dollars worth of benefits each year as the Jordan River has immense historical, cultural and natural values and its unexploited value for tourism is significant. 8. It is indeed possible that the southern Jordan River alternative will present different problems, which will not occur with the Peace Conduit or any other alternative; however, only an organized working method will enable the examination of the alternatives according to grading of the criteria. Examining only one alternative is not acceptable as a logical working method or as a method that responds to the requirements of sustainable development. 9. The southern Jordan River alternative (according to which water from the Kinneret will flow through the southern Jordan River to the Dead Sea) avoids the potential problems associated with the Red Sea-Dead Sea option such as: The impact of extracting massive volumes of water from the head of the Gulf of Aqaba. Conveying salt water through the Arava, which is an area of high seismic vulnerability. Changing the chemical composition of the Dead Sea, as a result of mixing Red Sea waters with Dead Sea waters Other benefits in rehabilitating the Jordan River include: Rehabilitating the Jordan River is a commitment of the Peace Treaty signed in 1994 between Jordan and Israel. Opportunities would be created for joint tourism development among Israelis, Jordanians and Palestinians, which will further reinforce any Peace Dividend. A Jordan River option would safeguard the cultural, religious and historical

10 value of the Jordan River Valley and the Dead Sea while the RSDS project ignores the Jordan River. The financial cost of rehabilitating the Jordan River could be significantly less than the cost of the RSDS project. There would be a sizeable net environmental gain from rehabilitating the Jordan River and the Dead Sea with no negative environmental implications. This must be compared to the significant risks associated with the RSDS project. There might also be a sizeable financial gain from rehabilitating the Jordan River in terms of tourism revenue in both the Jordan Valley and the Dead Sea. It would be possible to irrigate the Jordan Valley on both sides. 10 Sub-theme B: It is clear that it is not possible to reduce water usage in the Dead Sea and Jordan River watersheds to historical levels 1. The option of stopping use of water in the Dead Sea watershed by the three countries utilizing this water supply is not a viable means of transferring water to the Dead Sea, unless an alternative supply to these countries is presented. 2. The Bank [itself] has effectively ruled out consideration of the Jordan River alternative in making the following unequivocal statement in the Introduction to the TOR: the natural flow of the Jordan River is fully appropriated for what is considered essential use by the various water sectors. No degree of reform and change in management of freshwater resources in the region is likely to keep pace with the demand, attain even the minimum standard of water availability or significantly contribute to the restoration of the Dead Sea. 3. Stopping human consumption from the Sea of Galilee drainage basin in order to rehabilitate the Dead Sea would cause desertification of the Upper Galilee and the Jordan River Valley and discontinuation of human activity (agriculture and urban consumption) in the settlements in the basin. This option is not acceptable. 4. It cannot be expected that Jordan will give up part of the flow of Yarmuk waters which are 50% of the total water resources in the country. Sub-theme C: Purchase of water from Turkey 1. Peace Canal Plan : Purchase of 2 billion cubic meters per year (cm/y) from Ceyhan and Seyhan rivers for distribution of about million cm/yr each to Syria, Jordan, Palestine and Israel via closed canal and pipelines. Additional water could be purchased and conveyed through the Peace Canal to revitalize the Jordan River and thereby slow the rapid decline of the Dead Sea. 2. Purchase of water in bulk containers from the Manavgat River in Turkey to Haifa and by pipeline to the Dead Sea. This is not correct. The TOR (1.2) notes that there is significant demand already for the available water in the Jordan River Basin and that much of the water has been appropriated for use by various water sectors. It also notes that the projected growth in demand, even with sound water management and conservation measures, will continue to increase rapidly in the future. This future growth in demand will further complicate the restoration of the Dead Sea.

11 3. Consider a proposal to replace the Red - Dead Conduit by a system transporting from Turkey to Haifa, Israel, a quantity of fresh water sufficient to raise the elevation of the Dead Sea surface by one meter p.a. The cost of this water reaching the Dead Sea will be significantly lower than that of desalinated sea water. The estimated cost of the transport from Turkey to the Dead Sea is only is between US 7 and US 15 per cubic meter of fresh water 11 This point is noted Sub-theme D: Consideration should be given to the alternative of refilling the Dead Sea by canal or tunnel via the Valley of Esdraelon into the Jordan River 1. There are no fresh water aquifers below the valley to be jeopardized by an outbreak from a canal or tunnel conveying seawater. 2. Considering the topographical, political and potential aquaculture projects along the Jordan Valley this northern alternative is more attractive and cheaper than the Red-Dead Sea alternative. 3. Allows a pilot project with large diameter pipes before a canal-tunnel is begun. Sub-theme E: Use of desalinized fossil water 1. The costs of desalinized brackish fossil water under the Negev and Jordan are competitive with imported desalinized sea water. 2. There is enough brine water on both the Jordanian and Israeli sides of the Jordan River to meet anticipated needs. No desalinated water is needed. Sub-theme F: Release of Jordan and Yarmuk water 1. The option of releasing Jordan and Yarmuk river water directly to the Dead Sea is more logical, cheaper and more effective than the Red-Sea Dead Sea proposal. Sub-theme G: Mediterranean Sea-Dead Sea options 1. A relatively short open canal from Haifa Bay to Beisan and the Jordan valley would allow some production of hydropower and desalination plants along the route. 2. There is a plan to convey desalinated water from the Mediterranean to the Dead Sea via a desalination plant south of Haifa, a short tunnel in the Carmel valley to Ramat Zevaim and then to the Naharaim area to generate hydroelectric power. Eight hundred million cm of desalinated water would be delivered to Jordan and the remaining 1,000 million cm would be conveyed to the Dead Sea via (a) the Jordan River or (b) pumped partially into the Sea of Galilee which would serve as an operational reservoir. 3. Alternatively, Mediterranean water could be desalinated in the Naharaim Beit She an area and conducted to the Dead Sea via canal or pipe, with the advantage of

12 augmenting the water supply to the Palestinian Authority. 4. Many of the potential adverse ecological impacts on the Dead Sea associated with the RSDS option also apply to the alternative of water conveyance from the Mediterranean. 5. Desalination on the Mediterranean Sea coast is superior from the engineering perspective, much less costly, and much less risky (from environmental, engineering and financial perspective) in comparison to desalination on the Dead Sea coast. 6. All Israeli experts consider that the RSDS option is much inferior to any project based on the Mediterranean Sea or possibilities of modular desalinization on the Mediterranean coast, taking into account that the distance between Hadera and the Abdalla Canal is 70 km and the distance between the Haifa bay and the Sea of Galilee, from which the State of Jordan receives water, is only 50 km (and that desalination plants can be constructed in Hadera or Haifa and the desalinated water easily conveyed the short distances to the Abdalla Canal or the Sea of Galilee). 7. A desalination alternative in Hadera-Hamadia can provide to Jordan the water it requires within a short time, at much lower economic and environmental costs in comparison to the RSDS project. It can also resolve the problem of the decrease in the Dead Sea water level by abolishing pumping in the Tabha Pumping station (translator s observation: this means changing the concept of water supply in Israel, abolishing the current concept of use of Sea of Galilee water and moving to use of desalinated water, while letting the Sea of Galilee water overflow to the Jordan River and reach the Dead Sea). 8. Desalination on the Mediterranean Sea coast also has an environmental cost, but it is much smaller and well known (since two large desalination plants are already under operation). 9. Israel began to excavate the Mediterranean canal in Gaza in The international community told it could not have not have two canals; so the Israeli government then adopted the RSDS proposal as an alternative. 12 Sub-theme H :Find a renewable and cheap source of power to provide all of the needs for desalination and other needs in Israel 1. Solar energy can provide a cheap source of energy for these purposes. 2. The proposed Energy Towers project can provide sufficient solar electricity for desalination of Mediterranean Sea water and replace 200 million cm of water from Lake of Galilee. Theme VII: The No Action Alternative

13 Sub-theme A: There is a need to question the assumption that the low level of the Dead Sea is an environmental catastrophe 1. Recent surveys carried out by the Geological Survey of Israel and the Geological Department of the Hebrew University of Jerusalem, have shown that during historical warm and dry periods, the level of the Dead Sea also fell, causing the drying up of the southern part. One of the last drying up events occurred during the Arab conquest of the Middle East, the lowest level occurred at ca. 800 AD. 2. This observation added to the understanding of the formation of the potholes, calls for an examination of the assumption that the level of the Dead Sea has to be restored. 3. The damage caused by the retreating sea level, for example the potholes, can be corrected by a dike to maintain an adequate level along the coast line. 4. Under current circumstances, the water level will continue to drop from its current level of 418 meters below sea level and stabilize at 550 meters below sea level. 5. The allegation that the decline of the Dead Sea surface level hurts tourism has never been proven. In fact, the Deputy Director General of the Israeli Ministry of Tourism has denied this allegation. 6. No groundwater has been lost as a result of the sinking of the Dead Sea. Israel s Hydrological Service has just issued a brochure to this effect. Sub-theme B: The No Action Alternative is not an acceptable outcome 1. The Government of Israel studied the no-action alternative and found the impacts to be very serious. 2. The damages to the environment, tourism and roads are estimated at $90 million per year The default alternative leaves the water shortage of Jordan without a solution. 4. The development of about 2,000 bolanim (huge potholes resulting from unstable soils) is causing significant damage. 5. Anticipated time needed to reclaim the Dead Sea is an important issue. Due to the continuing drop of one meter per year, if the work is executed 20 years from now, the level will be 20 meters lower than the present level and stopping further decline will have a different meaning than the one obtained today. Sub-theme A: Precautionary Principle This is one of the major reasons the three Beneficiary Parties are undertaking the Study Program. This point is noted and the Study Program will examine the financial impact of the existing and projected situation on the environment, industry, infrastructure and tourism. This point is noted, it is agreed that the development of these features is causing significant damage. Theme VIII: Environmental Impacts

14 1. The precautionary principle must be accepted and incorporated into the TOR. Due to the potential reliance on computer modeling on the mixing of the waters of the Red Sea in the Dead Sea and on the impact of water extraction at the head of the Gulf of Aqaba a level of uncertainly must be taken into consideration that the computer models might fail. Since the impact of building the proposed project could lead to irreversible negative consequences for the Dead Sea, Arava and Gulf of Aqaba the precautionary principle requires that the real possibility that models fail be given extra weight in any final analysis. The alternative proposed here brings more damage than has already been done. 2. The Israeli Ministry of Infrastructure studied the initial Jordanian proposal for the RSDS and found it highly inferior to other alternative studies conducted in the past by Israel. However as a result of his drive to strengthen peace, Minister Shimon Peres convinced the government of Israel to ignore previous decisions to undertake serious professional studies comparison of alternatives and support the initiative of Jordan without studying other alternatives 3. The Japanese trade commission, JERTO, intended to finance the project but withdrew after finding in unworthy. Sub-theme B: Groundwater, soil impacts and biodiversity 1. The project poses a potential danger to existing renewable fresh water resources, in the form of aquifers in the alluvial gravels and continental sandstone layers under the Arava valley. A Canal conveying sea water along this active tectonic line could be damaged by earthquakes, which could in turn cause irreversible damage to the Arava valley aquifers. This resource is used for irrigation by Israeli and Jordanian farms and feeds the Cretaceous aquifer in the southern Arava; its water is a future potential for ameliorating the large quantities of brackish fossil water found under the Negev. 14 The STSC recognizes that risk assessment, including the risk that computer models may not be fully reliable, is an integral part of the Feasibility Study and Environmental and Social Assessment. For example, the TOR recognizes that the outcome of mixing waters from the Red Sea and the Dead Sea over a time scale of decades is not known and extremely difficult to model and predict (6.2.1). At an even more fundamental level it is noted in the TOR that it remains to be demonstrated that the solution of adding seawater to the Dead Sea will have the desired effect on the Dead Sea (12.3.5). As part of the Environmental and Social Assessment, the Consultant will review past and current studies/research related to modeling the dynamic limnology of the Dead Sea (Task 9, 13,1.9). The Consultant team will include regional specialists from national level institutions that have been involved in previous and ongoing studies concerning this and other complex issues. There is no such determination by the Israeli Ministry of National Infrastructures. As noted above, the TOR for the Environmental and Social Assessment provides for the examination of both the no action alternative and other reasonable alternatives to the proposed project. The STSC is not aware of any information in the public record of a finding on the part of JERTO with respect to the proposed project. These matters will be studied in the course of the Study Program. See Sections and of the TOR. 2. There are risks of soil and ground water contamination by salt. These matters will be studied in the course of the Study Program. See Sections and of the TOR. 3. A significant land area will be needed for the pumping station and conduction system, in a place where the shore line is limited and short. The TOR recognizes that the proposed site for the pumping station and conduction system is located in a populated coastal ridge and that there will be resulting ecological and social impacts from the construction and operation of these facilities. (12.3.2). The TOR further notes that coastal zone management in the upper Gulf and Aqaba/Eilat is complex due to the high intensity and

15 15 4. What is the impact on natural springs when the water level of the Dead Sea is raised? competing uses made of this area, which include commercial, industrial, military, recreation and tourism uses along a limited area of coastline (4.1.1.). These matters will be studied in the course of the Study Program. See Section of the TOR. 5. The Arava Valley is of great interest to scientists; three years were spent mapping biodiversity, sensitivity; agriculture has already had an impact; nine new species of insects have been discovered. 85% of Jordanian bird species use the area as a migratory flyway. 6. Representatives of the Arava region sent a petition to President Hon. Shimon Peres expressing concern about the potential salinization of the aquifer, which is the region s main water source. Salinization could terminate agriculture in the Arava settlements and threatens the existence of the community. Task 4 of Sub-Study B is designed to identify and address the environmental impacts of construction and operation of the project in the Wadi Araba/Arava, including impacts related to the loss of ecological connectivity across the conveyance and associated risks to natural habitats and biodiversity (TOR ). See Clarifications, Task Added and Guidance for the Study Program, dated December 3, See response to VI.B.4, above. 7. The problem of sinkholes cannot be solved by raising the level of the Dead Sea. As noted in the TOR (6.2.1), the soil matrix around the Dead Sea is collapsing as the water level falls, causing sinkholes and other structural damage. Although raising the level of the Dead Sea may not repair the existing sinkholes, it is expected to prevent the formation of additional sinkholes. The Environmental and Social Assessment (Task 9), will include an evaluation of the impact of sinkholes in underground water flows (13.1.9). Sub-theme C: Potential impacts on Dead Sea ecology 1. Potential increase in concentration of heavy metals in Dead Sea due to increase in solubility of trace elements. The TOR (6.1) recognizes that the inflow of Red Sea waters into the Dead Sea could have adverse impacts on the composition of Dead Sea waters. It also recognizes that the outcome of mixing these two water bodies over a time scale of decades is unknown and extremely difficult to model and predict (6.2.1). 2. Potential emissions of malodorous, toxic hydrogen sulfide gas from Dead Sea. See response to VIII.C.1, above. Note that the TOR for the Environmental and Social Assessment will clarify that gaseous emissions from the Dead Sea will be included among the potential ecological impacts to be investigated. See Clarifications, Task Added and Guidance for the Study Program, dated December 3, The mixing of ocean water, containing high concentrations of sulfates, with the waters of the Dead Sea will result in the creation of calcium sulfate crystals that may remain suspended in the water and alter the character of the Dead Sea. 4. The contact of Dead Sea water with ocean water creates supersaturation and risks both the solubility and precipitation of gypsum (depending on the size of the See response to II.C.1 above. See response to II.C.1 above.

16 crystals). 5. Stratification of the Dead Sea could result from the mixture of Red and Dead Sea waters. 6. There is also a risk of algae and bacteria blooms and other unpredictable biological impacts as the Dead Sea becomes less saline and is enriched by phosphorus from the Red Sea. 16 See response to II.C.1 above. The TOR recognizes that in addition to chemical/physical impacts, the proposed inflows to the Dead Sea may have ecological consequences. Over time, inflows of seawater and/or desalination reject brine will alter the salinity gradient and chemical composition and inoculate the Dead Sea with potentially alien species, some of which may survive (TOR 6.2.2). 7. There is a risk of potential genetic discontinuity affecting terrestrial wildlife. This is an issue that will be studied in the Environmental and Social Assessment. See Clarifications, Task Added and Guidance for the Study Program, dated December 3, What is the impact on migratory bird species? This is an issue that will be studied in the Environmental and Social Assessment. See Clarifications, Task Added and Guidance for the Study Program, dated December 3, Not enough has been done regarding the possible impacts on the biological and hydrological impacts on the Dead Sea. See responses to VIII.C.1 and VIII.C.6, above. Sub-theme D: Potential impacts to the Red Sea and Gulf of Aqaba, its tourism industry and unique land and marine habitat 1. The suction system, if not properly designed, must generate currents that will have negative influence on the sensitive coral reef. The potential impact of the proposed project on the current and coral reefs in the Gulf of Aqaba/Eilat is recognized in the TOR (4.1.1) where it is stated that It is essential to minimize alterations in the Red Sea circulation patterns so that possible reef impacts are kept to a minimum. 2. Pumping of water might increase the rate of water exchange in the Gulf. As noted in the TOR (4.2) one of the objectives of Sub-Study A is to assess potential impacts from pumping significant quantities of Red Sea water to the Dead Sea on a long term basis from this ecologically and economically important area. Task 2 of this Sub-Study is to identify and assess oceanographic impacts including the impact of various pumping quantity scenarios on water circulation, at the head of the Gulf of Aqaba (TOR 4.3.2). 3. The required huge pumping station and conduction system might impact the Gulf with gas emissions and noise. Sub-theme E: Impacts of Desalination Plant Among the objectives of Task 3 of Sub-Study A is to identify and assess all project impacts on the terrestrial environment of the Aqaba/Eilat region including air quality impacts from the generation of power, per the TOR (5.4.1). 1. The desalination of 1.5 billion cm is at globally unprecedented scale. STSC recognizes that the proposed project involves the construction of a very large desalination plant. (TOR ). 2. It is an energy intensive project that with existing technologies will emit very Sub-Study D will provide a technical, environmental, social and economic

17 massive amounts of greenhouse gases, contrary to prevailing environmental policy in the world today. 3. The impacts of desalination plant on diversity and landscape conservation need to be considered. Sub-theme F: Climate Change 1. The issue of climate change and its influence on the project is no included in the TOR 17 Theme IX: Need for Broader ( Strategic ) Environmental Assessment) assessment of the proposed desalination facility. Any incremental greenhouse gas emissions resulting from the facility would be included in the environmental assessment. However, it should be noted that the desalination plant would be powered by hydroelectric power, which would generate a much smaller carbon footprint than a conventionally thermal powered desalination facility (TOR 7.1). As part of Task 2 for Sub-Study D the Consultant will identify and assessment the impacts of construction and operation of the desalination plant on the landscape/aesthetic value, cultural values of the region in terms of alternative site locations (TOR 7.3.2). STSC agrees that the overall impact of climate change on water resources and the environment could be significant and warrants consideration as part of this Feasibility Study. Accordingly, tasks for the Consultant will include an assessment of the potential impact of climate change on the proposed water conveyance project and for each alternative configuration under consideration. See Clarifications, Task Added and Guidance for the Study Program, dated December 3, Sub-theme A: The Middle East/North Africa Region of the World Bank has issued a report, Making the Most of Scarcity: Accountability for Better Water Management in the Middle East and North Africa, that argues for a broader approach to the TOR for the Red Sea-Dead Sea Water Conveyance Study Program that is currently proposed. Among other things, the report notes that: 1. The approach of securing supply is reaching its physical and financial limits. This is widely recognized as an issue and presents major challenges for water resources and environmental management. 2. A switch toward a new approach of water management is needed, one which considers the entire water cycle rather than its separate components, using economic instruments to allocate water according to principles of economic efficiency and developing systems that have built-in flexibility to manage variations in supply and demand. 3. The changes include planning that integrates water quality and quantity and considers the entire water system; promotion of demand management; tariff reform for water supply, sanitation, and irrigation; strengthening of government agencies; decentralizing responsibility for delivering water services to financially autonomous utilities; and stronger enforcement of environmental regulations. 4. Rather than making a decision about billions of dollars of investment on a landscape altering construction project on the basis of technical studies supplemented by social and environmental impact studies limited in scope to the immediate area, The World Bank supports a comprehensive approach to the management of water resources. Many of these interventions are being undertaken by the Beneficiary Parties. These types of interventions are recognized by the World Bank and the Beneficiary Parties as approaches and instruments that can be used in water resources management. The Study Program has been designed to allow for an objective examination of the pros and cons of the proposed Red Sea Dead Sea Water Conveyance, no action and other reasonable alternatives. The Study Program will draw upon the