Training Base: risk surveys

 
On September 14, 2009, the special sub-committee of the Southern District Planning & Building Committee heard responses to the environmental risk survey ordered by the Supreme Court as a result of IUED’s appeal in the Training Base City (“Ir Habahadim”) case.
 
IUED presented its objections to the risk survey as detailed below and the Ministry of Environmental Protection, Tahal Consultants and the Ministry of Defense made their responses.
 
“Importantly, this is the first time that a planning procedure of the Ministry of Defense is being conducted within the transparent forum of the national planning framework,” notes Tzipi Iser Itzik, IUED’s executive director. Usually, planning of the Defense Ministry is reviewed by a special committee on the grounds that all army construction is security-related.
 

IUED’s team of attorneys, air pollution specialist and urban planner pressed the special committee to include IUED’s recommendations within its conditions for issuing planning approval for Training Base City. The Ministry for Environmental Protection, together with consulting firm Tahal, clarified issues relating to stench episodes and the boundaries of the area around Ramat Hovav that will serve as safety margin.  The Ministry of Defense informed the hearing that as a result of the survey, the target date for populating the base had been delayed until 2014.

The Southern District Planning & Building Committee will release its decision shortly. 

IUED's Response to the Environmental Risk Survey

The survey was intended to deliver a comprehensive assessment of the environmental conditions and current and future risks posed by soil contamination, air pollution and other environmental problems to human health.
 
Our review of the report shows us that the survey’s authors have premised their findings on the assumption that pollutant emissions from industries and facilities at Ramat Hovav will be reduced by 70-90% by the time Training Base City is populated (in 2012).
 
In our opinion, the assumption that pollution from Ramat Hovav will post no health risks whatsoever to the soldiers, civilian workers and others who will live at the base is unrealistic and unfounded.  Moreover, the survey sets an aspiration for the future but does not indicate how the pollution reduction goals will be attained. In effect, it presents a ‘let’s wait and see’ scenario.
 
Although our IUED’s capacity to assess the survey is compromised by the absence of relevant professional data, we submitted a detailed document relating to the faulty assumptions and outlining additional flaws of the survey, including the following:

• The air quality projection model and computer simulations used in the survey are inclined toward underestimation and lacks adequate safety margins. It is possible that all the survey’s estimations are in fact erroneous.
• The assumption that pollutant emissions can be reduced by 70-90% is not validated by any indication of steps to be deployed to achieve this target.
• While assuming a reduction in emissions, the survey does not address the possibility of any increases in pollutant emissions arising, for example, from the projected expansion in capacity of the hazardous materials incinerator at Ramat Hovav.
• The survey does not relate to the findings of a commissioned report that dealt with industrial accidents causing dangerous pollution incidents at Ramat Hovav or evaluate how future incidents might impact on soldiers at Training Base City. Thus it fails to fulfill the Court’s ruling that explicitly required that it address the issue of hazardous materials.
• The survey revealed five materials that currently deviate from standards and from the Almog Commission’s reference values for Training Base City. Even in the unlikely case of significant reductions in Ramat Hovav emissions assumed by the survey’s authors, at least one industrial chemical is likely to exceed reference values. We refer to carbon disulfide, a colorless, odorless and highly volatile chemical compound ranked as one of the most hazardous compounds to ecosystems and human health, and which widely used at Ramat Hovav.

In our submission to planning authorities, we urged that the survey not be approved as a basis for allowing construction of Training Base City to go forward at this point.

We repeated our call for the Environment Ministry and other state authorities to set specific, detailed timetables for reducing emission at Ramat Hovav and that emissions reduction schedules be integrated within specific phases of the Training Base City construction plan. We recommended specific targets for emissions reductions to serve as benchmarks to be met before construction can continue.   

Summer 2009: IUED's planning objection elicits declaration confirming that construction is on hold

IUED has appeared before the Southern District Planning & Building Committee to present formal objections to aspects of the Ministry of Defense’s (MoD) detailed plans for Training Base City. The deposit of plans by the MoD within the national planning framework is in itself a milestone in how the MoD handles planning of army installations. This change is the direct result of IUED’s ongoing legal intervention relating to the construction of the first of a series of major new army bases planned for the Negev. Until now, the Ministry of Defense has conducted all of its planning and construction activities through a special committee that limits public access to its deliberations and findings on the grounds of national security.

In our presentation to the Southern District Planning & Building Committee, we cited insufficient detail on plans for handling environmental impacts of the future base, which will house over 11,000 soldiers plus attendant services. The MoD took the opportunity of depositing the detailed plans to add a gas filling station and a commercial center outside of the base’s boundaries, further confirming that the Training Base will function in effect as a new town.

IUED also pointed out to planning authorities that the opportunity to build the new base according to green building standards was being lost as the MoD had deleted from the plans several green building elements it had previously publicized. WIth the Negev slated for massive new development, the MoD should be leading the way by introducing green building as a means to conserving energy and water and reducing greenhouse gas emissions in all of its buildings.

Finally, IUED pointed out that while the deposit of plans within the civil planning framework is a welcome first move towards transparent planning by the MoD, the act was premature given that the MoD and other State authorities are due to report in June on the series of environmental impact surveys it is obliged to conduct as a result of IUED’s appeal to the Supreme Court.

May 2008: Supreme Court orders comprehensive environmental surveys

The Supreme Court ruled on May 14, 2008 that the Ministry of Defense must postpone construction any buildings at the complex until the completion of a comprehensive environmental survey, which are to be submitted to the Court by June 2009.  It allowed for limited construction (initial earthworks and infrastructure) to go ahead at the future site of Training Base City, pending the results of an analysis of soil contamination.

The Supreme court was ruling on the appeal of IUED and others against the Beersheba District Court's ruling in January 2008.

IUED executive director Tzipi Iser Itzik: "We are pleased that the Supreme Court accepted IUED's position on the need for comprehensive environmental surveys prior to construction of Training Base CIty. The Court's decision confirms that the public has a right to participate in planning decisions that affect the health not only of young soliders at the base but also of all residents of the Negev."

Iser Itzik added that the Supreme Court's decision further confirmed IUED's claims that the preliminary surveys were an inadequate basis for going ahead with construction. "We will closely monitor implementation of the surveys and will continue to represent the public interest in all matters relating to development in the Negev." The Court dictated in its decision the scope of environmental and health risk surveys in line with IUED's requests in the case. Surveys must include examination of air pollution, waste, sewage and toxic materials emanating from the nearby Ramat Hovav industrial zone and hazardous waste treatment site. The environmental surveys are expected to take about 12 months to complete. The Court further noted that approval to begin full construction is conditioned upon the survey results.

January 2008: District Court's decision based on partial findings: IUED to appeal in Supreme Court

IUED will appeal the January 3 2008 decision by the Beersheba District Court allowing construction to go ahead on a large military complex dangerously close to the Ramat Hovav hazardous waste treatment site in the Negev. In its December administrative petition to the Beersheba District Court, IIUED attorneys stated that the 'Training Base City' project was approved without ensuring that soldiers' health would not be endangered by pollution from Ramat Hovav, a scant few miles away.

The judge based her decision to reject IUED's petition to suspend construction of the project on an air quality assessment carried out by the Dutch company DHV before the plan was approved. Insufficient data IUED's case centered on the belief that there was insufficient data for definitively assessing the threat from Ramat Hovav.

The DHV study confirmed that there was too little data on emissions at Ramat Hovav to draw any definitive conclusions, and hence did not constitute a genuine environmental risk survey. The Environmental Protection Ministry insists that if the industrialists of Ramat Hovav institute pollution control measures and the European standard IPPC, toxic emissions will be cut by 90 % within three years and no threat to the training base will remain.

The ministry based its assessment on computer simulations to predict the spread of 12 potent pollutants, but admitted that the measurements relate only to the release of chemicals during normal business days, and not in the event of an explosion or accident. Furthermore, hundreds of other potentially dangerous chemicals in use at Ramat Hovav factories were not included in the analysis. The governmental Committee for Security Installations, that planned the complex and is overseen by the Defense Ministry, has access to the relevant data but has not released what is considered 'secret information.' Moreoever, an in-depth report into the environmental risks has been in the works since 2005, it has yet to be released in its

Background: Ramat Hovav - a threat to the health of everyone in the Negev

Ramat Hovav houses 17 chemical companies -- over half the chemical companies in Israel -- and produces at least nine major air pollutants, several of which are classified as poisons. In August 2007, an explosion involving hazardous materials at the Makhteshim factory in Ramat Hovav released noxious fumes into the surrounding air, forcing the nearby highway to Beersheba to be closed for several hours. The 4,000-acre military complex, scheduled to be completed by 2012, is intended to house over 11,000 personnel and centralize military training in one area, replacing the veteran Tzrifin base near Rishon Lezion. Defense officials have repeatedly stressed that the new complex will not be populated until it is clear that industrial pollution from Ramat Hovav poses no threat to soldiers' health. Meanwhile, the bulldozers wait. The defense establishment announced in December that if IUED's petition was rejected, it would immediately begin construction, creating irreversible facts on the ground.

IUED supoports Negev development

IUED is not opposed to the army base complex, which will bring much-needed economic opportunities to the underdeveloped region. However, the defense establishment effectively sidestepped the planning laws that normally govern construction, including not conducting an extensive investigation of potential environmental hazards and damages.

IUED: "We are the real Zionists"

In a 2008 interview with the Jerusalem Post, IUED Executive Director Tzipi Iser Itzik rejected criticism that environmentalists are interfering with former prime minister David Ben-Gurion's Zionist vision to settle the Negev.

"We are the real Zionists who are making sure the Negev is developed with full consideration for the environment and with thought for future generations," she said. The association's main concern is that the personnel who would eventually live on the base would be exposed directly to severe health hazards, as the residents of the Negev have for a long time. The IUED has welcomed the base as a lever for putting pressure on Ramat Hovav to improve.

Iser Itzik added. "Construction of Training Base City is a great opportunity to clean up one of Israel's biggest environmental disasters and to set the standard for future development throughout the Negev."