1. Generalization.

The document corresponds to a set of 165 recommendation items – varying as to the degrees of their relevance, acuteness, urgency that will hardly retain the attention of decision makers at the level of neither Heads of governments and sectors of economy nor senior officials of international global organizations. It would be more expedient to distribute specific actions ensuring water resources management adaptation by decision making levels which:

• Require the attention of global UN and other international organizations;
• Seek to make decisions at national governmental and parliamentary levels;
• Call for decisions at the agencies/sectors levels (water, agriculture or energy) that could be implemented by corresponding ministries;
• Are addressed to local authorities as well as to direct water users.

Then each of the audiences might find well-defined recommendations specifically designed for their attention – recommendations significantly less in numbers and more focused on vital issues enabling particular decision makers to grasp the essence of problems and identify the points at issue.

2. On the whole, it should be noted that though the document is called a strategic one there are few strategic issues in it.

In particular, it should be noted that the draftsmen have remitted their attention to one of the most significant water-related problems affecting water management strategies - the issue of global changes. Consequently, such global-scale developments as changes of prices on energy and food, susceptibility to financial crises, influence exerted upon water markets by private mega-companies are omitted from the list of major problems specified in par.6.

3. Concrete comments to the Theme I: Global Changes and Risk management.

• Par. 11 - Need for developing national and sub-national strategies is underlined here. However consideration should be given to the fact that all measures to manage water basin resources are planned within the framework of the main unit – that is of the basin area with all its interrelated elements: water, land, climate change, demography, social and economic conditions. Therefore the priority should be given to development of basin strategies, especially pertinent to transboundary waters. At that, multipurpose use and development of water resources must be directed at equitable participation and use of water resources by all sectors, abstaining from giving priority to some separate sector which possesses infrastructure – for example, to hydro-energy. In these strategies first-priority consideration should be given to long-term water or water sources regulation to compensate consequences of increasing natural extreme phenomena recurrence – floods and droughts – since only such regulation can mitigate impacts of hydrologic changes caused by climatic transformations;
• Par. 14 – Infrastructure project design in anticipation of climate change should be developed in the first line with regard to irrigation infrastructure, which, unfortunately, is not mentioned in this paragraph. Impacts of climate change on urban and rural infrastructure – highlighted here – will be by far less powerful than its affect on agriculture;
• Par. 17 – It is a very good appeal calling for necessary increase in financing arrangements undertaken by developing countries within adaptation measures. But it is incomprehensible to whom this call is addressed. Evidently the wording might be specified as follows: “…international financial institutions and bilateral donors are to define this support as of high-priority”;
• Within the “Theme I” there is no any mentioning that certain climate changes may create positive potential for augmenting water productivity – for example, in irrigated agriculture due to prolongation of vegetation period and contraction of temperature deviations, especially during presowing period;
• The greatest threat to water management in conditions of climate change is brought by glaciers melting away and corresponding depletion of ice component in surface flow. It is expedient to include the following recommendation: “… problems caused by expected rate of river water content reduction due to the impact of glacier evolution should be solved through relevant water saving rates and lower specific water consumption rates”.

4. The “Theme II is dedicated to Human Development towards the Millennium Development Goals”.

Of paramount importance for arid regions are: - “Element 2 – Water for Energy and Energy for Water” and “Element 3 – Water for Food Production”.

• Par. 43. - It is necessary to underline that the current rise in prices on electricity makes absolutely noncompetitive other than energy generation water uses – this causing irreversible damage to both irrigated agriculture and natural complex – thus making impossible to pay compensation for loss of profit required by hydro energy organizations. The necessity should be emphasized of toughening operation regulations in such like hydro schemes; operators cannot be allowed to gain their commercial benefits while ignoring interests of other basin water users – it is obligatory to ensure equitable access to water for both the energy sector and other water users. Experience gained along these lines in Canada and the USA ought to be made use of - water reservoirs and their operation regimes in these countries are transferred to water management agencies, whereas hydro energy sector is vested with the rights equal to those allotted to such water users as irrigated agriculture and nature management in order to prevent infringement of this or that sector’s interests and rights;
• Para.45 – It necessary to pay attention to obligatory prior approval and coordination of hydro schemes construction between all other (including transboundary) water uses; investments in such like construction projects are to be made only if there are no threats and risks for other water users on the basis of ensuring their rights for fair and equitable water use. The text should be amended with the following wording: “Investments in hydro power stations on all water bodies (water basins) including transboundary rivers are to be made in compliance with Water Law taking into account interests of all riparian states and after independent international expertise is carried out with regard to identifying possible impacts of construction on water, environmental and socio-economic situation in downstream areas”;
• Attention should be drawn in the “Element 3” to the role of irrigated agriculture as the most significant factor in the endeavour to accomplish Millennium Development Goals (MDGs), especially in rural areas. In terms of these MDGs it is necessary ensure sustainable water delivery for irrigated agriculture within science-based water demands. To pay attention at an inadmissible fact of 11 million ha fall out from irrigated lands area in countries of the former Eastern Block;
• Para. 48 – While emphasizing necessity to modernize land reclamation projects, it is advisable to declare for expediency of wide-scale introduction of IWRM and obligatory establishment of water saving quotas as one of the main measure to achieve adaptation to climate change;
• The “Element 3” should be amended by the paragraph on wide application of collector-drainage water and waste waters from urban and rural territories for irrigation.

5. The Theme III: – Managing and Protecting Water Resources

• Element 1: - Considering significance of water resources and acuteness of water problems both in regions and in the global context, as well as taking into account considerable vulnerability of water sector to external impacts, it is necessary to pay special attention to the following points while developing items of the “Element 1:
  • No actions carried out on transboundary rivers are allowed to cause negative impact on the current prevalent ecological and water balance of the region;
  • The international legal framework currently in force in the field of water use and ecology must become the basic foundation for developing an effective system of joint use of transboundary river water resources in the regions;
  • The right of any party to implement projects on transboundary rivers’ water resources use is not discarded out, including hydro-technical construction, provided that meticulous independent technical-economic and ecological expertise is conducted based on principles of openness, transparency and total information awareness of stakeholders;
  • Projects implementation is carried out on the basis of a constructive approach and compromise making provision that no interests of other nations are infringed and ensuring two super-important conditions are complied with:
    First – there should not be permitted any reduction of watercourse flow for downstream countries;
    Second – ecological security of the region is not to be endangered.
• Para. 62 – This section should be enhanced, keeping in mind that UN Convention of 1997 had been signed by less than 20% of UN member-states. This indicates that radical revision of attitude to Transboundary Water Law is necessary. The issue should be submitted for consideration at the level of International Water Law solutions by UN Security Council. Certain arrangements should be undertaken along with this to make requirements of International Water Law tougher so as to ensure real access to water for all “thirsty” users and at the same time to protect downstream users from any diktat on the part of upstream countries – numerous illustrative examples of such irresponsible behavior we have been witnessing at present;
• Para. 68 – As a result of commercialization of national Hydro-meteorological Services in many countries, express and forecast information exchange on climate situation and hydrology between countries is becoming difficult. More strict statement ought to be applied with regard to mandatory requirement that all data on the climate state and change as well as state and change of water sources must be put out on-line;
• Para. 70 – The following addition should be included in the text: “International Financial Institutions should provide top priority support in funding training activities among transboundary water managers, decision makers, operators, farmers and other stakeholders”;
• Para. 71 – The following addition should be included in the text: “ While designing water infrastructure for hydro-energy, preference should be given to small water reservoirs – thus avoiding risks of commercial press on downstream water users”;
• Para. 79 – The following addition should be included in the text: “It is expedient to pay special attention to return water use as the means of ecosystem protection and particularly to water use of this kind for wetlands”;
• Para. 82 – The following addition should be included at the beginning of the paragraph: “Adherence to environmental releases is the obligatory priority vector of surface water use; therefore ecological releases should be given primary importance in the strategy of transboundary and national basins water use as well as in annual planning”.

6. The Theme IV: – Governance and Management.

• In this chapter the main emphasis is made on the right to water supply and sanitation. At the same time the right to water for irrigation signifies not lesser importance; at present this vector of water use is extremely unsteady in the majority of developing countries with transition economies. Even there where the right to water for irrigation is validated in the constitution and in national legislation, yet in majority of the countries regulatory mechanisms ensuring implementation and protection of this right have not been worked out. These aspects should be given much more attention in terms of international adequate safeguards pertinent to the right to water for food production as well as such like guarantees at national and local levels. It should be specially underlined that the rights to water are reflected in current international documents rather poorly.
• It is necessary to establish a special UN panel on analysis of water security situation in countries of different political and economic statuses for the purpose of identifying obstacles hindering implementation of the rights and current security measures. Here it is necessary to reiterate that hydro power schemes constitute most serious menace to global security since they having water reservoirs of enormous volume capacities designed to protect water users against negative climate change impacts in the long-term regulation regime, in fact some of them in certain river basins: - have been provoking drastic alterations of river flow regimes by transforming them from summer releases to winter ones; – thus aggravating impacts of climate change and; - condemning millions of people to unstable irrigation, wide-spreading famine and social vulnerability.

7. The Theme V: – Finance

Para. 126 – Pricing strategy should be based on correlation of tariff and income as well as create the cross subsidies system.

8. The Theme VI: – Education, Knowledge and Capacity Development.

• Wide-scale introduction of IWRM implies necessity for complex up-to-date methods of scientific substantiation of IWRM on the basis of social, legal, economic, informational, environmental, hydrologic and soil properties knowledge. Therefore this research area should be reflected in the given section of the document as well as activities on wide introduction of information and computer technologies with application of remote sensing methods and state-of-the-art means of their mapping and imaging;
• Mankind has been facing up to reality – water deficit rise. Future generations will live in conditions when the amount of water per 1 person is considerably less than nowadays. Whereas education of younger children, schoolchildren, students along the lines of frugal water use is not reflected in this subject matter. By and atour, all world religions and ancient traditions focus on water saving. Evidently, it is necessary to promote issues of human ethics, recovery of moral heritage and facilitate respectful attitude to water as to holiness.