* 원본 *





President Lee, Myung‐bak
1 Cheongwadae‐ro,
Jongno‐gu,
Seoul, 110‐820,
Republic of Korea
email: [email protected]

Minister Chung, Jong‐hwan
1 Jungang‐dong,
Gwacheon‐si, Gyeonggi‐do,
 427‐760,
Republic of Korea
email: [email protected]
August 11, 2009

RE:  Korea’s 4‐Rivers Project

I write to express International Rivers’ concerns about the transparency, rapidity of the planning process, and potential large‐scale negative consequences of the 4‐Rivers project. International Rivers is a non‐profit based in the US with offices in Asia, Africa and Latin America, working to protect rivers and promote human rights. We urge the Korean government to answer our questions and to submit the 4‐Rivers Project for an evaluation using assessment methods that meet state‐of‐the‐art, internationally‐accepted standards before proceeding on this project. Our review of the information publicly available raises questions such as the following:

Has a full environmental impact assessment been done with a proper democratic process of review?
If Korea wishes to pursue flood control as the central element of Green Growth, it should operate within a modern best practices framework from the 21st century, not, as reflected in the current 4‐Rivers plan, from the 19th.  In the developed world governments are removing dams and levees to allow rivers to reclaim their natural course. By international standards, the 4‐Rivers Project cannot legitimately be called a river ‘restoration’ project. River restoration and revitalization are emerging sciences that we take seriously. We must guard against projects falsely promoted as ‘restoration’ to the international community, whether it be to garner trade agreements, funding, or respect.  If the 4‐Rivers Project is a model project, then it should withstand the scrutiny of the public and the review of objective experts.

A project of this scale has implications for the entire water systems of the rivers you propose to alter.  In other countries the lack of cumulative effects analysis alone would likely cause 4‐Rivers an infeasible project to be in breach of environmental laws.

Evaluation must be given adequate time. It is our understanding that the master plan for 4‐Rivers was announced on May 6th, 2009 and the work will begin within a matter of months. We worry that a rush job on evaluation will only further raise questions about the validity and advisability of such a project. Transparency is key in the case of the 4‐Rivers Project. It must be researched, defined, and planned in public view. A normal environmental review by international standards would include a needs assessment, definition and analysis of alternatives, and use investigative scientific studies that can be evaluated by objective scientists. Without access to real plans and engineering assumptions an objective evaluation cannot be made. We respectfully request that you release the full assessment for public and scientific review.

Do the benefits outweigh the costs?
From the publicly available information, it is difficult to determine if and how costs and benefits were analyzed, and whether environment effects were adequately accounted for.  A proper project evaluation requires a transparent evaluation of which social groups and ecosystem components stand to gain and which may be harmed by the project.  Experience with other large‐scale engineering projects has shown that of construction and other implementation costs are usually far higher than predicted. Since it was first proposed, estimated costs of the 4‐Rivers Project has spiraled upwards. We consider it important that all the costs (and benefits) are accounted for, including the costs of restoring riverine ecology.

Are the proposed alterations to the Nakdong River based on up‐to‐date assumptions relating to water use and engineering solutions?
We would suggest reduction of demand should be a key part of any national or international greening or sustainability project and policy.  It is apparent from the supporting documentation for the 4‐Rivers Project that an underpinning assumption is a continued increase in both absolute and per capita water consumption.  We question if this assumption is appropriate, and even if it is, question how large large‐scale dredging and construction of dams and weirs can meet these needs whilst maintaining the integrity of the much wider set of ecosystem goods and services that these rivers currently provide? We would respectfully suggest there are other approaches which will

be more sustainable in meeting all of these perceived needs.

In summary, we are concerned that in the absence of a transparent and inclusive environmental impact assessment that the 4‐Rivers Project in its current form may have a huge negative impact on these internationally important river systems. We respectfully request that information and data be assembled that considers and shows how the impact of dredging, levees, weirs, and concrete at such a large scale is compatible with functioning riparian ecosystems. There are documented cases around the world which demonstrate that the most effective way to restore ecological function is to restore connectivity (longitudinal, lateral and vertical) and dynamic, natural flow regimes (with an adequate supply of sediment and wood). Current best practices would entail laying back riverbanks to detain flood water and allow groundwater recharge, to recreate wetlands and other habitat, and to protect biodiversity. These are the technologies of river restoration.

Yours Sincerely,
 

Patrick McCully
Executive Director

2150 Allston Way, Suite 300, Berkeley, CA 94704‐1378, USA | Tel: + 1 510 848 1155 | Fax: + 1 510 848 1008

[email protected] | www.internationalrivers.org