November 15, 2015
Long P. Pham
Viet Ecology Foundation
45272 Omak
Street
Fremont, CA 94539
Fremont, CA 94539
Email Address: vefmedia@vietecology.org
The overall goal as stated in the report is to safeguard the
Mekong Delta and ensure the continued well-being of communities and their
livelihoods in the Delta region through informed and scientifically justified
decision-making on the use and exploitation of the river resources.
The objective of the MDS is to define and evaluate changes
in the hydrological processes due to the construction and operation of the LMB
dams and assess their impacts the human and environment in the downstream flood
plans of Cambodia and Vietnam.
The Study
The MDS evaluates three Scenarios:
SC1:
Mainstream hydropower cascade
SC2: SC1
plus tributary dams.
SC3: SC2
plus water diversions
The MDS establishes baseline conditions for indicators for
the drivers and assess their impacts on the six resource areas through model
simulations.
The drivers are:
1. Hydrology.
2. Sediment.
3. Water quality.
4. Movement barriers.
The resources areas are:
1. Fisheries.
2. Biodiversity.
3. Agriculture.
4. Navigation.
5. Social Impacts (Livelihood).
6. Economic Impacts.
The models incorporate the linkages between the forces of
change or drivers to their effects or causative factors and then to the
resources areas.
The Linkage
between Causes and Effects
Reference: DHI - MDS
October 2015 Volume 1 and Volume 2
General Comments
We appreciate the depth of the
analysis, the complexity of the linkage and the extensive gathering of
historical and new data this MDS has accomplished within the scope of the study.
The comments submitted herein are
in support of the ultimate goal, that is to safeguard the Mekong Delta; it is
therefore necessary that the public and decision makers review this MDS in a
context of a river ecosystem and full perspective as described below.
1. Model for Average Year 2007
The MDS in its hydrology and
hydronic simulation selects data year 2007 as a representative hydrological or average
year of the period from 1985 to 2013. The average year model represents a “snap
shot” picture of a combination of conditions that is all normal in every
aspect. There is no scientific evidence that the projected impacts from an
average year study would be equal to the average impact over a long period.
In reality, the Mekong already experiences
frequent sudden water level fluctuations, prolonged droughts, degrading environmental
conditions. Biased studies, poor dam design-construction, poor maintenance and
reservoir miss-management have resulted in disasters and they weigh heavily on the
mind of the Mekong people and policy makers.
The average simulation is important
to the MDS, but towards the end goal that is to safeguard the Mekong, the people
and the decision makers need to know the impacts over the entire spectrum, non-average
years and especially all the worst cases. Therefore, model simulations for a
period of 50 years as the minimum should be conducted and reported.
2. Evaluation in Full Context and what the MDS excludes
This MDS is a comprehensive and
scientific study, respectable work within its defined scope of work. The scope
of the MDS, however focuses primarily on the cumulative impacts of the LMB
projects on the MDS Impact Assessment Area. Therefore, the MDS intentionally excludes
other cumulative impacts already fell on and are expected to fall on the Mekong
Delta areas.
The first group of other impacts excluded
from the MDS are:
The followings are human activities
which impacts are excluded from the MDS:
3. Priority of Impacts Assessment
The first group includes natural
forces of change, such as climate, sea level rise, salt intrusion, natural
drought or flood. We as human and community of Mekong nations cannot act to
prevent or cannot do much more about this Group in the short term.
The second group and the LMB
projects under the MDS are all man made forces of change; except for the done
impacts of Chinese dams in the UMB and Laos tributary dams in the LMB, the
Lower Mekong people and governments together can control them to safeguard the
Delta.
The practical assumption should be
to accept the impacts from the first group and the existing Laos and Chinese
dams and as given; and from here on, no additional impact from any future
projects or human activities can be permitted to cross the red lines that is to
add its cumulative impacts to any of the above resources to endanger the Mekong
Delta, her people’s vital water and food supply and significant impact on the
environment.
4. Transboundary Impacts /Maximum Limit on Cumulative Impact on Resource Levels
This ultimate goal is towards safeguarding the Mekong
that also means to identify risks and prevent future deterioration. It is
imperative that the maximum limits on cumulative impacts (maximum tolerable
level) be established and metered for each resource, above which no more impact
will be tolerated by any future project. Towards that goal, nothing short of a
Lancang – Mekong International River Treaty could make it happen.
5. Non Technical Summary
This October 2015 version of the
MDS is massive and has been written in highly technical language from experts
to experts, and it requires a team of experts to interpret its meanings. The
MDS team seems to make no effort to write this MDS report readable to an
average Mekong public (and policy makers) given their education level stated in
the report. Therefore, it is strongly recommended that the MDS team prepare a
non-technical version of this report and release it as soon as possible for the
public to have the chance to participate in the process that impacts their
future and their life.
References
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