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PROBLEMS, PRACTICES AND OPPORTUNITIES


Concept

Functions of natural resources do not meet society's requirements for many reasons. Some are found in adverse user practices (e.g. field irrigation practices), some in the limited availability of a resource (e.g. availability of agricultural land per household). Most problems, however, are rooted in an imperfect institutional and management system.

Complex systems of institutions, management arrangements and hardware infrastructure should bring the supply and demand of functions for natural resources into a satisfying equilibrium. The irrigation and drainage sectors in Egypt are complex systems that attempt to maintain the balance between the ever-growing demand for water and the almost fixed supply of water from the river Nile.

Table B.1.5 Structuring problems, inadequate functions and issues (not exhaustive)

First order problems for water users

Inadequate water related functions

Adverse practices

Limited natural resources

Institutional imperfections

Low income for large groups of farmers

- Agricultural productivity
- Maintenance of groundwater and salts

- Subsistence agriculture
- Inefficient water use
- Inadequate drainage

- Small landholdings
- Irrigation water


Inequity of farmers' income

- Inequity in access to water

- Inequitable distribution of water
- Rice cultivation in upper reaches


Enforcement of rice regulation;
Technical infrastructure

Fisheries income

- Access to water low quality of water

- Over-fishing

- Lake area

Water rights

Low status of public health

- Water-borne diseases

- Garbage dumping
- Untreated sewage

- No space for official dumping

Waste management

Insecure and limited provision of local drinking-water

- Water quality problems

- Sewage and solid waste dumping
- Reuse of drainage water


Waste management

Housing problems

- Depth of groundwater


- Limited land resources

- Inadequate drainage provisions
- Lack of rural sanitation

Degradation of land and water resources

- Waterlogging- Salinization
- Pollution
- Sedimentation

- Agricultural practices
- Reuse of drainage water


- Lack of maintenance
- Waste management

Agricultural productivity

Problem

Large numbers of small-scale to very small-scale farmers in the study area produce wheat, broad beans, berseem, rice, cotton and maize as their main crops and a selection of small crops, vegetables and animal products. The yields per unit area of these crops are high, thanks to a favourable soil, climate, irrigation and drainage services. Yet, the income level of many of these farmers is low, and a considerable portion of the population can no longer subsist on agricultural production. The main cause is the very small area of land per household, which results in low per farm revenue in terms of food and cash. Many households need additional off-farm employment to provide for a minimum income. A farm of one hectare, cultivating the average cropping pattern at average variable cost and rent, could expect a net revenue of about LE 5 000 or US$500 per year (Agricultural Statistics 2003). The average landholding in Al Mahmoudia district is about 1.2 hectare. The agricultural revenue of irrigation water is roughly estimated at LE 0.36/m3. It is higher for the winter crops of berseem and wheat (LE0.60/m3); and lower for the summer crops rice and cotton (LE0.20/m3). These figures show that there may be scope (from a macro-economic viewpoint to increase the productivity of Nile water by shifting part of the production to high-yielding cash crops. This is, of course, against the interest of the local farmers on the old land and it does not take into account the social value of their summer cropping on the old lands.

In general there are two relevant questions. To what extent can changed water management practices:

Taking the first question, the potential for increased productivity of land through improved irrigation seems limited, as yields are already quite high. In general, the amounts of water applied are sufficient, drainage controls the soil's groundwater and salinity levels to the satisfaction of the farmers. Unfortunately, no data were found showing the monitored effect of IIP interventions on agricultural productivity. There is scope for improvement in parts of the area. Under the prevailing conditions, they are badly served because of their diverse properties; lower land tracts, tail-ends, etc. Problems faced are local; therefore, adaptations to general water management practices should be site-specific. The next section deals with this opportunity, otherwise, improved agricultural productivity must be driven by agronomic rather than by new water management interventions (new varieties, other crops). On the cost side, there is scope to increase net agricultural revenues. For example, the cost per unit of water delivered to the farm can be decreased. The pumping cost into improved mesqas reportedly has fallen by 30 percent (Report Socio-economist). The cost of water conveyance and distribution at the main system level should be critically reviewed.

The adage "more crop per drop" is easier said than done. In the first place, it should be replaced by the adage "more value per drop". To illustrate this, one may compare the net revenue per hectare of irrigated rice and maize in the MCA with the net revenue per cubic metre of these summer crops.

Table B.1.6 Revenues per hectare and unit of water


Net revenue/ha (LE/ha)

Net revenue/m3 (LE/ m3)

Rice

2 341

0.23

Maize

1 962

0.36

* Provisional figures

Moreover, the value of a certain agricultural product is not only expressed in economic terms, for example wheat production has a strong social dimension for small-scale farmers on Egypt's old lands as it provides them with food security. Changes in cropping pattern are, therefore, sometimes difficult to realize. Nevertheless, there is still scope for improvement in water productivity. Crops with a high consumptive use (evapotranspiration plus leaching requirements), such as rice, can be replaced by more water efficient crops. However, rice cultivation's function, in suppressing salinity levels in certain lowlying areas should not be overlooked. New on-farm water application techniques can be promoted and controlled drainage could limit the water consumption of rice, for example. Mixed cropping pattern makes it difficult to apply this to rice fields alone. Consequently, conflicts may arise between rice growers and others. Location specific technologies are needed to solve such problems. This is being made possible with stakeholder participation organized through water boards.

There should be a critical review of the consequences of more efficient water application (not to be confused with distribution efficiency). Water not used in one field, because it spills into a drain, will be used in another downstream, through official or unofficial reuse. In addition, the leaching requirement, which comes out of the subsurface drains, is reused. At the lower end of the MCA, the effluent is still worth something as fish farms, fisheries in the coastal lakes and vegetable growers use this water directly and indirectly with success. The results are not only quantitative, they also relate to water quality, especially salinity. If there is an overall decrease in the water supply from the Nile to the MCA, water will be used more efficiently and less water will leave the area. Generally speaking, the levels of salinity and pollution in the remaining effluent will increase. The SIWARE model (DRI/SC-DLO, 1995) can probably simulate this intervention and set safe margins for the level of efficiency sought.

Inequitable access to water

One of the reasons for suboptimal agricultural production is that some farmers still lack adequate access to irrigation, the so-called "tail-end" problem. This is a common feature in almost all large irrigation schemes throughout the world. Farmers in head-reaches have earlier access to water than tail-enders. This is valid for branches as well as for mesqas. Even in situations where there is an overall water shortage, the head reaches manage to fulfil their water requirements and more. There is a general tendency for head-reach farmers to shift their cropping pattern to more water consuming crops, often rice, thus aggravating the situation. The tail-enders, if they are located in the right spot, may compensate their water shortage by pumping from drainage canals. This increases their pumping costs, their land is more saline and yield reduction, resulting from water stress, is more likely to occur. The head-reach farmers, lacking confidence in the water supply, over irrigate, which in turn, causes a reduction in yield. Improving the situation of inequitable water supply is probably one of the most promising opportunities to increase overall water productivity and improve income distribution. Experiences around the world indicate there is a strong need for institutions to deal with this problem, rather than for a self-regulating technical infrastructure. The IIP project intends to improve this situation with a package of interventions. The change from rotational to continuous supply in the branch canals is one measure. The difficulty of changing the function of the irrigation canal system is illustrated by the fact that after seven years of project activities, only one branch canal was switched to continuous supply during the mission.

Water quality

Problem

WQMU (2003), partly based on World Bank (2002) information, provides an estimate of the economic damage from impaired water quality (see Table below). This is based on an approach that translates water resources into a multifunctional asset, somewhat similar to the approach followed in the present study.

These figures are based on national data and are difficult to translate for the study area, though some remarks can be made. Water-based recreation refers to the immediate Cairo area, the coast near Alexandria and the Red Sea, indicating that a large proportion of the estimated damage of LE 200 million refers to the project area. Health issues, relate to child morbidity and mortality (through the calculation of "disability adjusted life years") resulting from bad water quality. This specifically applies to the lower delta area. For example, the environmental assessment for the Bahr Bagar drain noted an increase of 5-40 percent for various forms of cancer and heart disease in areas that irrigate with drainage water.

Regarding the economic damage caused by poor water quality, the clearest conclusion is that health impacts from water pollution appear to outweigh all other damage or costs by far. This suggests that the most important areas for water quality improvement lie in actions to:

Table B.1.7 Estimated economic loss resulting from water-related health problems

Category of loss

Estimated value in year 2003 (LE million)

Recreation

200

Non-user benefits

0 - 400

Fisheries

400

Health

5 600 - 60 000

Municipal treatment cost

0 - 400

Industrial supplies

400

Agriculture

400 - 2 000

Tourism

200 - 1 000

Total impact

7 280 - 64 880

Rural areas in the study area largely continue to be without effective and environmentally sound systems for the disposal of liquid waste. Improper management and removal of sewage lowers the quality of life and leads to the premature death of thousands of people every year, with high costs to society and the economy.

Industrial activities in the lower reaches of the Nile, the drains and around Lake Maryut lead to serious pollution. Existing regulations are not always enforced and industries are allowed to dump their waste into open water. The negligence with which industrial waste is dumped into the water, and the obvious lack of enforcement of regulations and licenses, gives the impression that water is not valued as a precious resource in Egypt. Obviously, everyone knows this is not the case, so the actual situation is astonishing.

Opportunities

The WQMU (2003) report summarizes a number of the most promising water quality management instruments at the national and local/regional level:

Our own observations show that some water boards have already taken up the task of producing local action plans at the branch canal level. A number of actions related to canal cleaning and creation of safe washing places have already been implemented. Constraints often lie with the limited resources of local government that in many cases need to follow up on local initiatives (for example in the case of garbage collection). Scaling-up such practices under the umbrella of IIIMP, with the involvement of water boards, is worth considering.

Other opportunities for water quality management, though somewhat remote from the original IIIMP objectives, lie in the use of the natural cleansing capacities of wetlands in the coastal lakes area. A study is needed of the actual cleansing capacity of reed swamps and an economic use for the reeds needs to be identified to create a sustainable activity. Removal of reeds will lead to removal of pollutants and have an additional positive effect on lake fisheries.

Water quantity

The FAO case study on drainage water reuse in Egypt concludes that currently the salt balance in the delta is stable and reuse does not contribute to accumulation of salts (Kielen, 2002). The report also states that maintenance of freshwater fisheries requires additional water, but this is questionable since brackish water fisheries may be economically more interesting - the lake has always been characterized by a fresh to saltwater gradient. With the presence of an effective drainage system, the perceived loss of irrigation water resulting from spills at the tail-ends of canals or because of over irrigation, in reality is not a loss. This water is returned to the irrigation system through the mechanism of drainage water reuse. Moreover, a water spill may enhance the quality of drainage water, simply by diluting the pollutants, and may better prevent intrusion of saline groundwater.

Moreover, the study has shown that in the lower reaches of the delta effective use is made of drainage water by applying well-adapted soil management and irrigation techniques, by fish culture and a highly productive fisheries sector. All these benefits are obtained by making use of water that is considered wasted in the official irrigation language. A better economic, social and environmental appreciation of these mechanisms may provide a somewhat different picture of the so-called waste of irrigation water.

Any activity that aims to reduce water use in the delta should take into consideration that a reduction in drainage flow may lead to increased water quality problems in the lower delta, unless effective pollution control is in effect. At the same time, the needs of the established economic activities should be taken into account. A careful balancing act is required that will make full use of all functions provided by the water resources system in the Nile Delta. In this respect, one should not focus on the maximization of one function (for example irrigation), but on the optimization of all functions to maximize the combined value of all functions in a way that can be maintained in the future (sustainability).

Solid waste

Problem

Solid waste disposal is a widespread problem that hinders the performance of the irrigation and drainage infrastructure. The problem is caused by a combination of:

Opportunities

A solution should be identified to incorporate combined actions at the level of the local community and regional units. Water boards can, in their action programmes, address environmental issues and attempt to organize the local community in the clean up of their immediate environment; the municipality (unit) should organize the collection and safe processing, or disposal, of solid waste. Awareness campaigns are badly needed.

Maintenance of ecological processes and biological diversity

Problem

The present status of biological diversity in the delta is alarming. The two Ramsar wetland sites in Egypt have been listed as problematic for a long time. It is very difficult to maintain the ecological character of these wetlands under the enormous pressure exerted by the water quality and quantity problems listed above. Land reclamation has reduced the size of the lakes significantly.

Opportunities

Wetlands have good restoration potential. Around the world restoration projects are being launched to restore natural processes for the maintenance of coastal wetland systems. This is because these systems appear the most productive. Human interventions in these complex and dynamic systems are usually unsustainable and require continuous adaptation and investment.

In Egypt, reclamation activities of coastal lakes have been downscaled because of salinity problems. In order to at least maintain the restoration potential of the coastal wetland system, further largescale interventions should be avoided. There probably will come a day when Egypt will appreciate the value of maintaining some of the processes that keep a delta alive, such as maintaining an active interaction between the delta, the open sea and other areas in the world (for example migrating fish and waterfowl).

Further economic development of the urbanized area around Alexandria is expected. On a national scale, the importance of economic activities in the urban areas will become increasingly important and the economic value of agriculture reduced. As observed in other areas of the world, this will create an increasing demand for a better quality of life, including healthy recreational and residential areas around cities. The coastal lakes provide an enormous potential in this respect.

The prevailing quality of the lakes depends on the quality and quantity of the drainage water flowing into them. Any activity in the upstream irrigated area that changes water quality and quantity parameters on the downstream side of the drainage system will influence the lakes. Water saving through improved irrigation, for example, will result in reduced water flow into the lake. Without water quality measures, there will be a concentration of pollutants in the lower quantity of water, thus reducing its quality.

The important message here is that measures taken by IIIMP in the upstream irrigation area inevitably affect the coastal lakes. Given their present, and potential values, as indicated above, impacts on the lakes should be taken into account when assessing economic, social and ecological costs and the benefits of IIIMP interventions.

DISCUSSION OF PROPOSED IIIMP INTERVENTIONS

Concept

The IIIMP project foresees that the following main activities will be undertaken to achieve its broad objectives:

The intended IIIMP activities are discussed in the following five sections. Note that some of the components are discussed in detail in the other working papers. This section briefly discusses the different components from the viewpoint of the DrainFrame approach. In this regard, the following questions are relevant:

Developing and implementing integrated water management plans

Project Concept Document: "This component would include support for irrigation, drainage, pumping stations and groundwater MWRI subsectors for piloting integrated plans and coordinated implementation arrangements for the project areas including technical assistance, training and supply of equipment, materials, vehicles and office equipment."

From the description above, it remains unclear what "integration" really would mean for IIIMP. Reference is made to the different subsectors of MWRI, to pilot activities and to funding of these organizations. Much is still to be clarified during the project preparation stage. From the DrainFrame viewpoint, integration should start with a function-stakeholder-value analysis in the landscapes that have been affected by water management changes. Then the beneficiaries/stakeholders can be identified, both those who receive the positive benefits as well as those who experience negative effects. They should really be involved in the development of integrated water management plans from the start. The DrainFrame approach to integrated water management planning is further explained under the heading "Applications of DrainFrame in IIIP" (below). The command area approach selected in that section can be repeated in simpler forms at lower levels, e.g. branch canal level and even the mesqa level.

WUAs and water boards

Project Concept Document: "Establishment and expansion of water user associations (WUAs) and the water boards in line with the government policy of integrated irrigation and drainage water management. This would include support for WUAs at the tertiary level, up-scaling them to the branch canal level and their incorporation in the water boards at the district level."

In view of what has been said in the previous section on representation of stakeholders in planning and decision-making, the establishment of WUAs and water boards is imperative for integrated water resources management. These associations should be active in the operation of irrigation and/or drainage systems and should be involved in the planning and design of the mesqas. The same holds for water boards that function at the branch canal level. As a result, of stakeholder involvement, the planning processes become problem-oriented instead of technology driven. This may result in considerable deviation from standard solutions. The package of interventions at both levels may become broader than irrigation improvement alone. For example, at mesqa level, a need for drainage of settlement areas may exist; sewagmesqa sewage management may become part of the water management package; rehabilitation of subsurface drainage systems may be coordinated with irrigation improvement. Currently, WUAs are only involved in irrigation matters, and they are not (yet) equipped to deal with other water management issues that may arise in their area of activity. Water boards are geared towards integrated water management; the disadvantage may be that a water board is active at a higher level. Under IIIMP, if the option is present, the division of roles and responsibilities among WUAs and water boards should be given due attention.

Improvement and modernization of irrigation and drainage infrastructure

Project Concept Document: "This component would include the implementation of improvements, modernization of main, branch canals, tertiary systems, drains, irrigation and drainage pumping stations, implementation of new, and rehabilitation of existing sub-surface field drainage systems, their subsurface collectors and open drains, covering a total area of about 50 000 feddans".

Since the description of the various components in the Project Concept Document is not detailed, this report refers to some technical measures for the interventions as having already been implemented by EPADP and IIP projects. The working paper of the Irrigation and Drainage Specialist will discuss in detail what can be expected from these improvements and what can not. Here the planning and design process will be discussed.

The EPADP and IIP projects both have a very limited choice of technical solutions that can be provided. This is because of the variability of water management situations; this narrow choice is likely to offer suboptimal solutions in most situations (see Box B.1.5).

Box B.1.5 On diversity and multi-functionality of water management situations

From: Reclaiming drainage: Toward an integrated approach (Abdel-Dayem, et al. 2004)

Integration will mean different things in different contexts. In all contexts drainage would benefit from being viewed from an integrated perspective, which would mean:

  • Acknowledgement of the multiple objectives served by the management of shallow water tables and the disposal of excess surface water, and the need to maintain the resource system over time (resource sustainability).

  • Adapting drainage interventions to the natural resources system, taking into account the diversity of drainage situations and trying to optimize the goods and services produced by the natural resources system (planning and managing diversity and multi-functionality).

  • Instituting inclusive forms of (drainage) governance and decision-making with representation of the different stakeholders (democratization).

  • Improving the scientific knowledge base through a major shift in the focus of the scientific community towards the fields of sustainability, multi-functionality and stakeholder representation in governance and decision-making.

A basic implication of such an integrated, rather than a sector, perspective is that drainage is seen as part of the whole natural resources management system.

If the design of these interventions is carried out together with the stakeholders in place, fine-tuning of the interventions can result in more effective and probably more cost-efficient solutions. A second improvement could be obtained if a systematic impact assessment is made for each intervention. The steps as described in the section on "Application of DrainFrame in IIMP" can be followed.

Environmental management plans

Project Concept Document: "GEF support would be sought to address environmental assessment and mitigation measures focusing on water quality for integrated irrigation and drainage in the three regional project areas that have distinctive ecological systems, and would build on site-specific pilots under the ongoing IIP, NDPII, and Pump III projects. The GEF component would be fully developed during project preparation".

If the PCD phrase is well understood, during the project preparation phase environmental plans will be developed for each of the three project areas. These plans will consider water quality problems, and indicate measures to mitigate the adverse effects of low quality water in the areas.

This study has revealed that low water quality is one of the overarching problems in the water system of the study area. The effects are, not only felt in the project area itself, but propagate downstream into the coastal zone. In terms of environmental management, pollution caused by solid waste is a significant problem awaiting a definite solution. The looming threat of salinization is continuous. Precise water management remains a pre-requisite in keeping this potential environmental hazard under control. Environmental problems are caused locally and, therefore, in the first instance need local attention. Bad practices affect a number of functions on-site as well as off-site and new interventions may provoke new environmental problems. It is therefore recommended that an environmental assessment be made an integral part of the preparation plan at the levels of command area, branch canal and mesqa. The DrainFrame approach offers a perfect framework, as shown in this study, to identify existing environmental problems (but also social and institutional) inside and outside the project area, and to evaluate proposed mitigating measures on their impacts. The approach may be elaborated during the IIIMP preparation phase. Solutions, in terms of measures, are location-specific and can only be developed together with stakeholder groups. Therefore, the practical environmental management planning and implementation should become part of the project implementation phase.

On-farm demonstration plan

Project Concept Document: "The project would support the establishment of about 50 on-farm demonstrations spread over the five project areas during the five years of project implementation to demonstrate proven technologies for improved water use".

Some remarks need to be made on this item:

APPLICATIONS OF DRAINFRAME IN IIIMP

Applying the DrainFrame methodology during project preparation

The DrainFrame steps are indicated in Figure B.1.1, beginning with an understanding of the various water management issues, on which well-defined interventions in the system are based. The situation in which the mission found it was different as, at the time of the study, IIIMP was formulated only in broad terms in the Project Concept Document (Arab Republic of Egypt, 2003). An integrated analytical approach, such as DrainFrame, had not been used for this first project formulation. The first question, therefore, was to verify if the problems and opportunities (step 0 in Figure B.1.1) related to the water management system in the proposed area. And if the connected upstream and downstream areas had been identifified and described in an integrated manner. To do this, identification of water management issues had to be elaborated (Step 0). This step included the first round of identification of possibly water-connected landscapes (broad definition of the study area's boundaries), and an analysis of their functions, stakeholders and values. This reveals the suboptimal functions of the water system. However, equally important is the identification of bottlenecks in the institutional and management system.

By identifying the problems related to water resources management in this way, an overview of the potential need for interventions is provided, and the relevance of already proposed interventions (physically and institutionally) can be evaluated.

The mission team decided to take one command area as the point of departure. From a hydrological perspective this is a logical unit of analysis in the Nile Delta, as there is one point for the entry of water. The following steps were completed.

Describe affected landscapes

Describe boundary conditions for the entry point. The management of the entire Nile system up to the operational rules of the Aswan High Dam are beyond the scope of the analysis of one command area. Therefore, boundary conditions for the analysis are the (seasonal) availability of water, the design capacity of the canal, and the quality of the water entering the system.

Define the boundaries of the hydrological system (watershed). From a water resources management perspective, the boundaries of the area to be analysed may be larger than a command area, because drainage water flows to downstream landscapes beyond the boundaries of the command area. (In discussion with stakeholders' boundaries may change, depending on the interactions between the hydrological system and functions of the landscapes; this will be dealt with later).

Identify main landscapes within the hydrological system. A landscape is a geographically defined area with a more or less homogenous set of natural resources providing a number of functions. A further refinement in the description of landscapes is needed, based on physical characteristics of the landscapes and valuation of the landscape's functions by groups of stakeholders. For example, delta lands can be subdivided into agricultural land with high groundwater salinity, with low groundwater salinity and residential areas.

Identify functions of the identified landscapes and their stakeholders

In consultation with experts and stakeholders, the functions of landscapes can be defined. Functions can be described as the goods and services provided by the natural resources system. Goods and services can be exploited by humans, preferably in a way that does not jeopardize the future potential of these functions (environmental sustainability).

Some basic rules apply to the identification of functions:

Describe existing institutional arrangements

Functions of the water resources system are managed by humans and by either informal or formalized institutions. Usually, these institutional arrangements are characterized by a number of layers. In the agricultural lands of the delta, the following levels may be identified with examples of formal or informal types of institutional arrangement: field (individual farmers), mesqa (water user association), branch (water board), and command level (district water board). The concept of institution encompasses a wide variety of aspects such as actors, organizations and their interactions, property rights, governance mechanisms, regulation, control, monitoring and enforcement.

Identification of problems and opportunities

In this step, problems and opportunities in water resources management are analysed.

Problems can be prioritized based on values as expressed by stakeholders. An example of an existing mechanism for this approach are the recently established water boards. A water board works on the basis of an inventory of water-related problems and an action plan that defines priorities for intervention.

Identify alternative interventions and define intervention levels

Interventions need to be identified to address the issues raised by stakeholders. Before an intervention can be identified, one needs to know at what level an issue can be better addressed. For example, a water shortage at mesqa level cannot usually be solved at mesqa level, but needs to be solved at a higher level (branch, main canal or even higher).

At this stage it is important to define alternative interventions. In a later stage this will allow for comparison of expected positive and negative effects between alternatives. This provides the basis for discussion with stakeholders and decision-makers about an optimal intervention design.

Describe institutional needs and gaps

Institutional requirements for effective implementation should be defined for the proposed technical intervention and the level at which the intervention is needed.

Based on the analysis in step three of the DrainFrame scheme (see Figure B.1.1), gaps in the institutional arrangements and implementation mechanism need to be defined in order to overcome this gap.

Iterative, transparent and participatory design of interventions

Moving to step one of the DrainFrame scheme (Figure B.1.1), a systematic, analysis of positive and negative impacts of interventions is to be carried out. Consultation should be undertaken with direct and indirect stakeholders to determine whether the proposed interventions will result in the desired impacts and whether undesired impacts can be avoided, mitigated or compensated. If necessary, interventions are to be redefined.

Possible use of DrainFrame during project implementation

If IIIMP is finally designed in an integrated manner, it should leave enough room for flexibility in the implementation of technical and institutional interventions. An overall study, such as this, is not suited to the mapping of local differences in the land and water system, its functional differentiation, making an inventory of all local stakeholders and weighing of all values at stake. A DrainFrame approach is justified if used during project implementation to sort out the details of the localized solutions. The role of stakeholders at this stage will be even more important. An independent well-trained processfacilitating party seems indispensable to the initiation of this type of participatory design processes, where stakeholders, engineers, agriculturalists, local governments and others must cooperate.

Impact assessment: at strategic or project level?

The process, as described above, can be interpreted as a strategic environmental assessment (SEA) for the water resources management sector in a selected area. SEA is a rapidly developing and expanding tool used to assess the social, economic and environmental effects of policies and plans. In the European Union, as of mid-2004, it has become obligatory to assess the impacts of policies and plans using this strategy. SEA has the advantage over traditional project-level environmental impact assessment (EIA) because it can effectively deal with the cumulative impacts of different interventions and strategically develop adequate responses. Instead of deciding where to implement irrigation improvement measures, a tool is provided to decide the type of intervention needed in which location. In its most ideal format, SEA should be an integral part of national or regional planning in countries where planning is not fully functional. This is because SEA can be a parallel process to programme or policy development.

The IIIMP project has many characteristics of a programme that must make strategic decisions, which ultimately result in project interventions. In its present stage, only intervention areas have been identified and not the activities; there is only a listing of potential activities. Before the project embarks on the implementation of activities, an integrated analysis of water resources management issues is needed before an actual intervention can be envisaged. Furthermore, the study needs to be complemented with an analysis of existing institutional arrangements and gaps that need to be addressed by the project. The approach followed in our study could be used for this purpose.

MWRI has contracted a consultant to perform an environmental assessment following the "traditional" EIA procedure (MWRI, 2004). The main objective of the Environmental Assessment (EA) is to identify the impacts of IIIMP implementation and to prepare an Environmental Management Plan (EMP) for the direct impacts.

The approach of the environmental assessment, as described in the TORs, is definitely sectoral, illustrated by the following citation.

"The EA will discuss briefly broader issues, which could influence the project, especially external sources of pollution to the irrigation and drainage sector, e.g. rural wastewater, industrial effluents, solid wast, and environmental-health linkages".

The present study has shown that integration of water resources management goes beyond irrigation and drainage. Considering the importance of public health concerns related to water quality and the multifunctional nature of the irrigation and drainage system, the "external sources of pollution" should be a central element in any water resources management project. Any intervention in the irrigation and drainage system has, as shown by our study, affected one or more of the functions performed by the I&D system. Considering these functions as externalities for the I&D system is overlooking the present alarming water quality situation which has been caused by the very existence of the I&D system.

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