The State Comptroller published today (19.3.24) a follow-up report on the handling of the climate crisis and additional reports on environmental matters (at the present time, a sub-committee of the State Control Committee has deemed an additional report concerning Haifa to be confidential)
A collection of reports on environmental protection:
· Transboundary air pollution originating from waste incineration in the Judea and Samaria area
· Aspects of the government's actions on environmental pollution in the Haifa Bay – follow-up audit
In the matter of the climate: "The government is dragging its feet"
In the matter of transboundary air pollution originating from Judea and Samaria: "A long-standing failure of the Civil Administration and the Ministry of Environmental Protection"
State Comptroller Matanyahu Englman raises an alert in the matter of the handling of the climate crisis: "Alongside giving their attention to defense, the Prime Minister and the ministers must deal with the environmental risks. Most of the environmental reports that we are publishing today were completed before the war. I regard their publication at this time as important.
The government is dragging its feet. This is another red flag for the Prime Minister and the ministers; most of the defects that we warned about in 2021 have not been rectified; the State of Israel is left with many declarations and a long string of government decisions regarding its commitment to act in climate matters, but not all the necessary actions have been taken; the lack of actual rectification action forces the state to be faced with many risks; the acts of the Treasury have delayed and even halted certain matters of the state's preparation for handling the climate crisis".
On transboundary air pollution originating from Judea and Samaria: "This is a long-standing failure of the Civil Administration and the Ministry of Environmental Protection. The air pollution hazards from incinerations have worsened during the course of the Swords of Iron War, with the Ministry of Environmental Protection receiving more than 50,000 complaints from residents – but it did not update the Ministry of Health. These are health and environmental damages of more than NIS 9 billion by 2030".
On air pollution in the Haifa Bay: "For 3 years (2019-2021) the Ministry of Environmental Protection has not reported to the government as to how the plans for the reduction of air pollution are being implemented – and it has not published any figures regarding 60% of the severe deviations in the emission of pollutants from factories in the bay area" (2021-2022).
The Israeli government's actions and its preparation for the climate crisis – an extended follow-up audit
The government's functional stagnation in the climate sphere: The government has published declarations and made decisions – but it has not taken any actions that would allow any actual progress. Most of the defects that the Comptroller warned about in 2021 have not been rectified.
The findings of the special report published by the State Comptroller in October 2021, examining the Israeli government's actions and its preparation for the climate crisis, indicated profound and fundamental gaps in the government's preparation actions and the state's failure to meet the targets it had set itself. A glance at the progress of the government's actions in the matter since the publication of the previous report led the State Comptroller to make a decision, at the beginning of 2023, regarding the conduct of a comprehensive follow-up audit designed to examine whether the Israeli government was rectifying the defects that had been raised in the previous report – and whether it is advancing the actions that would ensure its preparation for the crisis, simultaneously with the significant risk it is confronted with and its international obligations.
The comprehensive follow-up report once again reveals, via a detailed follow-up of the handling of more than 100 audit findings that were raised in the previous report, a worrisome picture: The majority of the defects have not been rectified at all or have only been partially rectified; the State of Israel is left with many declarations that were published mainly in a long string of government decisions regarding its commitment to act in the climate matter, but all this without spearheading any processes and without adopting actions that would allow any actual progress. Therefore, we may characterize the governmental conduct in the matter as "functional stagnation".
We can indicate six fundamental failures that explain the government's stagnation during the course of the past few years, and in certain matters all the more so during the two years that have elapsed since the publication of the previous report:
1. The absence of a leading government party with the authority to make decisions: The absence of a leading and committed government party for achieving the state goals, acting to implement a customized and holistic government plan that would be decisive in disputes. The continuation of functioning on the basis of the decentralized government network, without any response for the existing functional barriers raised in this follow-up audit, does not deal with such barriers in the implementation of the government ministries' preparation for the climate crisis.
2. Delay in binding regulation (legislative entrenchment): The most partial implementation of dozens of decisions made by the government in recent years, and a delay in the promotion of the Climate Law. It should be noted that towards the end of the audit, the government began taking actions to promote the Climate Law, but the new bill does not contain binding goals that would allow the matter to be spearheaded and assimilated effectively in all the government's actions.
3. The failure to promote carbon tax: The absence of a financial tool that would allow the internalization of the external costs incurred on account of economic activity which emits greenhouse gases (GHG) and would allow the imposition of a carbon tax to be avoided in the export of Israeli merchandise abroad, as part of the "package" of reforms in taxation and incentives aimed at mitigating and setting off the increase in the cost of living and compensating equity-deserving populations and local industry in the event they suffer damage – something that is liable to occur if the carbon tax is promoted on its own.
4. Under-challenging in the electricity network: There is no investment for upgrading and building the technical capabilities along the chain of the electricity network, including expanding the dilution of the energy sources.
5. The absence of government risks management including: The preparation of a binding government-wide national attribution scenario that will constitute a tangible compass for the formulation of detailed work plans dealing with the threat.
6. The absence of a budgetary framework for climate: The Ministry of Finance's approach to budget in segments is unsuitable for the complexity and scope of the matter, and simultaneously with the absence of any control in the matter, this leads to a low utilization of the budgets designated for the matter. This is even more problematic in view of the prominent gaps between the sums actually utilized since 2015 on climate matters, which are much smaller than the sums that the state invests, via various supports in fossil fuels.
Therefore, the findings of this follow-up audit should be regarded as being the raising of another red flag for the government and the Prime Minister. There is special importance for combined international action for the purpose of confronting the climate crisis, and the State of Israel must play an active part in this dealing along the rest of the world. The absence of tangible rectification action in the state's conduct in the matter of climate crisis spearheaded by the government and the person standing at its helm, poses a future threat to the state that is relevant for the present generation and for future generations.
Below is a detailed reference to each one of the chapters of the extended follow-up audit:
Mitigation – actions for the reduction of greenhouse gas emissions
Israel is still not a leading country in the determination of emissions reduction goals * It has not set a more ambitious goal for renewable energies, and has not yet presented a goal for 2050 * Greenhouse gas emissions from 2015 to 2022 rose by 1% when in 2022 alone, after the coronavirus, there was a surge of 3.5% in emissions * According to the rate of electricity manufacture from renewable energies manufactured until now, in 2030 its rate is expected to reach just 19%, far from the original goal (30% of renewable energies).
Global warming, arising from greenhouse gas (GHG) emissions, is acknowledged to be one of the most severe problems that the international community has to deal with. In order to reduce GHG emissions, the partner countries to international agreements, including Israel, have set national goals. The follow-up audit examined how the recommendations for the rectification of the defects raised in the previous report have been implemented, aw well as additional aspects connected to the actions of the government and the public bodies that did not appear in it.
The Comptroller found that Israel is still not a leading country in the determination of goals, and even that some of the updated goals are on an intensifying trend of the level of national ambition, for example, the setting of an absolute goal instead of goals per capita for a 27% reduction of GHG emissions by 2030 and 85% by 2050, are inconsistent with the level of ambition that exists in this matter in the other developed countries. As of 2020, there is a considerable gap of 52%-93% between the rate of the reduction of GHG emissions goal set by Israel for 2030 (27%) and the reduction of GHG emissions goals set by developed countries including the United States, the European Union, Great Britain, Germany, France, Japan and the Netherlands (from 41% to 52%). Israel has not presented a more ambitious goal for renewable energies for 2030, and it remains 30%. As of June 2023, the Ministry of Energy has not yet set a goal for renewable energies for 2050. According to the OECD, a gap is expected between the goals set by Israel for 2030 and 2050 and the forecast for achieving them with the present policy tools, and the forecast for 2030 is that the gap will be at the rate of approximately 20%, and it will steadily increase (in a situation of business as usual) and reach approximately 650% in 2050.
The follow-up audit also found that in 2020 Israel achieved the lowest reduction among the developed countries, at a rate of 2% in relation to 2015 – a gap of 5.5 to 10 in the economy-wide rate of emissions reduction in the surveyed countries (which reduced from 11% to 20%) – and in 2021 Israel achieved a slight reduction of 1.5% in absolute emissions in relation to 2015. However, in 2022 the amount of GHG emissions in Israel increased and reached 81.06 million tons CO2e, i.e. an increase of approximately 3.5% in relation to 2021. This is also reflected in the emissions per capita, which increased during this period by approximately 1.5%. In the accumulative, these figures embody an erasure of the achievements in the reduction of GHG emissions in Israel – and an increase of almost 1% in relation to 2015 – mainly due to an increase in the emissions in the transportation sector, the industrial sector and the construction sector. According to the Ministry of Environmental Protection's forecast, implementation of the government's policies at the present rate will achieve a reduction in emissions of only approximately 12% in 2030 in comparison with the set goal of 27% (56% less than the goal) – i.e. emissions in a scope of 69.4 million tons GHG this year instead of 58 million tons. The expectation whereby the national goal for reduction of emissions will not be achieved arises from the sectorial goals not having been met. Thus, for example, the manufacture of electricity from renewable energies is expected to be 19% in 2030 instead of 30% as set in Government Decision 465. Moreover, the reduction of emissions from the energy sector is expected to be only 21% instead of 30% (almost one third less than the goal, assuming that the manufacture of electricity from coal will then cease).
The Comptroller found that as of the end of June 2023, the government had not implemented Decision 4080 dated July 2018, which was designed to cease the ongoing operations of coal-powered Units 1-4 in the Orot Rabin facility. These units continue to manufacture electricity by means of coal as the primary fuel. This and more, following the global shortage of coal, Units 1-4 are operated using high-sulfur coal, leading to increased pollution levels and greenhouse gas emissions that are even higher than those emitted in the past, despite the consistent level of electricity production from coal in those units. Additionally, the follow-up audit found that due to considerations related to the survivability of the electricity market, these units will be retained for preservation, meaning that emissions from them will not cease completely, and Israel will not meet its sectorial and overall goals for reducing GHG emissions. Regarding the manufacture of electricity from renewable energies, it was found that even though Israel had set itself low goals in relation to the other OECD countries – this goal was only achieved in 2022, when 10.1% of the electricity consumed was generated from renewable sources, instead of in 2020. The Ministry of Environmental Protection estimates that in 2025 the manufacture of electricity from renewable energies out of the total consumption will be approximately 14% (approximately 30% less than the interim goal set of 20%). The follow-up audit found that Israel shows a gap of approximately 90% in the penetration of new electric vehicles into the overall new vehicle market, compared to the average in European countries, and their percentage is still very low, at only about 1.14% of the total number of vehicles. Furthermore, there is a noticeable gap between the current percentage of electric vehicles in the total vehicle market and the goal of 25% the government set for 2030, and it is doubtful whether this gap can be bridged within seven years.
The Ministry of Transport plans to convert only urban public buses to electric vehicles, while these buses account for only about 18% of all buses and minibuses traveling on Israeli roads. Furthermore, the Ministry of Transport has no goals for converting non-public urban buses, intercity buses, and minibuses to electric vehicles.
Comptroller Englman recommends that the Ministry of Environmental Protection continue to promote the anchoring of the national goal of zero carbon by 2050 as part of legislation, so that Israel will become carbon neutral and not content itself with just a low carbon economy, and also set goals for the reduction of GHG emissions from the agricultural and construction sectors both for 2030 and 2050. The Ministries of Environmental Protection, Energy, Transport and Economy, as well as the Planning Administration at the Ministry of Interior, must reduce the gaps in achieving the reduction of GHG emissions and comply with the goals set for the main sectors producing GHG including the energy sector, the transportation sector, the industrial sector and the waste sector.
Adaptation – the national preparedness for adapting to the climate changes
86% of government ministries have no approved and budgeted preparedness plan for climate changes * 75% of the public bodies have no information on the scope of the expected financial damage due to the climate crisis * At the Climate Change Preparedness Administration at the Ministry of Environmental Protection there was only one employee and another job standard which had not been filled.
The intensification and exacerbation of climate events, alongside the ongoing changes in climate patterns, have the potential for significant damage and impact on Israel's economy. These include many risks to national and urban infrastructures, the continuous functional capabilities of economic bodies, and the provision of services to residents. Moreover, they pose a threat to Israel's national security in security, regional, and geo-strategic aspects, as well as civil aspects, including the public healthcare system, agriculture sector, water and food supply, energy sources, technological systems' functioning, and biodiversity. Government decisions and additional reports have emphasized the importance of advancing early prevention and preparedness measures to promote Israel's readiness for the future impacts and damages of climate changes.
The previous report found that the State of Israel lacks a national climate changes adaptation plan, and about 84% of the public bodies in Israel (and which were asked about this issue in the previous survey circulated by the Office of the State Comptroller) do not have a ministry-level climate risks adaptation plan. The follow-up audit found that this defect has been slightly rectified: Israel still lacks a national climate changes adaptation plan; out of the 60 public bodies that responded to the survey (29 of which are subject to Government Decision 4079 and an additional 31 public bodies), only five (about 8%) have an approved ministry-level preparedness plan, while an additional six bodies (about 10%) have a plan in its initial implementation stages.
After about five years since Government Decision 4079 was passed, 82% of the public bodies surveyed (49 out of 60) still do not have an approved climate risks preparedness plan. It should be emphasized that an examination of such government ministries designated in the government decision, and which are under an obligation to prepare for the risks of the climate crisis, found that the decisive majority (86%, 25 out of 29 of the bodies designated in Government Decision 4079) do not have a ministry-level approved and budgeted preparedness plan.
90% of all the surveyed bodies have not reached the implementation stage of their preparedness plan, and over one-third (21 out of 60) have not even begun the initial steps in formulating a preparedness plan. In 35 out of the 60 surveyed public bodies (58%), the full budget required for the development of a climate change preparedness plan, which is an initial stage in the preparation, was not allocated: In 19 bodies (31%) no budget was allocated for this stage at all, while in 16 out of the 60 bodies (27%) only partial budgeting was allocated. The Climate Change Preparedness Administration at the Ministry of Environmental Protection still does not have clear powers vis-à-vis the government ministries, and there is no mechanism that obliges them to report to the Administration about their activities. The previous report found that the Administration was operating without any job standards at all. The follow-up audit found that for the first time, one job standard had been approved for the Administration Director, which had been filled at the end of 2022, and another job standard for another employee that had not yet been filled (compared with an average of 11 job standards in the three countries having parallel units: Switzerland, England and Sweden). The Preparedness Administration has not yet succeeded in setting itself up as a national center of knowledge, and it is finding it difficult to promote relevant studies in the matter of preparedness, so that the decision-making processes lack any sufficient research and scientific database.
The Comptroller found that the actions for establishing a national calculation center for climate simulations at the Meteorological Service, a project considered to be technologically complex, had not yet begun as stipulated by the government decision, and they are being delayed. This delay is liable to reduce the operation time of the calculation center that, pursuant to the government decision, is due to operate in this format only until the end of 2027. Without the establishment of the calculation center, the Israeli government will continue to prepare for climate changes based on imprecise climate models.
Approximately 75% of the surveyed bodies (45) lack any financial information regarding the scope of the expected damages in their areas of responsibility due to the climate crisis; and 92% (55 out of 60) have not yet completed the examination of the costs associated with the potential damages in their areas of responsibility.
The Comptroller extended his examination concerning the preparedness of the transportation sector for the risks involved in the climate changes and found that no preparedness plans had been prepared and the resources aspects required for them had not been examined.
As for the healthcare system, it was found that in 2022 the Ministry of Health had formulated a preparedness plan consisting of 41 specific tasks. However, as of June 2023, the ministry has only implemented 11 of these tasks (26%). This is partly because the Ministry of Health has not allocated a dedicated budget for the plan, and it has not appointed specific parties to lead its implementation. Furthermore, the follow-up report found that no progress had been made in approving the 2016 National Plan for Health and Environment.
Comptroller Englman recommends that in view of the risk entailed by the lack of a preparedness plan by the public bodies, every public body in Israel should prioritize the preparation of this plan and budget it as soon as possible. It was recommended that the Ministry of Finance ensure the necessary budget for the formulation of the ministerial preparedness plans.
Economic aspects, taxation aspects and financial aspects of the climate crisis
There are 90 ministers of finance from all over the world in the Climate Coalition, but not from Israel: The Ministry of Finance continues to regard climate as an environmental issue rather than an issue that concerns the entire economy * Contrary to the government decision, carbon tax has not yet been instituted – and the delay is liable to adversely affect the competitive ability of Israeli exporters to Europe * The Bank of Israel manages the state's foreign currency reserves portfolio, in a scope of approximately 200 billion dollars, without taking climate risks into account.
Climate risks are expected to impact the state's financial situation, the gross national product, the growth rates and the state budget, since the chronic effects and the acute effects of climate changes are expected to cause substantial damage to various sectors in the economy in the long term: They are liable to adversely affect the growth in the economy and interfere with its activity or harm state revenue and its ability to provide adequate services to its citizens. Furthermore, climate change has a direct impact on price stability in the economy.
The Comptroller found that the Ministry of Finance continues to regard the matter of climate as an environmental issue handled mainly on the professional-performance ministerial level rather than an economy-wide financial issue. The Ministry of Finance rarely takes initiatives in the field, and sometimes it even takes a stance that leads to blocking of the necessary resources for the fight against climate change that it affects. The Ministry of Finance's reluctance to move to the front of the stage as a dominant party in the promotion of climate policy, as other OECD countries have done, has a negative impact on affectively achieving the State of Israel's goals in this field. Out of the 37 OECD countries, Israel's minister of finance (and the ministers of finance of additional three countries) did not join the Coalition of Finance Ministers for Climate Action. This testifies as to the Israeli Ministry of Finance's isolation from the most central forum where the relevant practices for the fields under its responsibility are being developed.
About a year and a half after the publication of the previous report, not one of the parties in charge of the macro-economic forecasts in Israel – headed by the Ministry of Finance, the National Economic Council and the Bank of Israel – had still not formulated a national economic and fiscal assessment related to climate change and the formulation of climate policy (mitigation and adaptation) – in the long or medium term. Conducting a unified and validated national economic and fiscal assessment for the entire government is an important tool for reducing uncertainty and making well-informed decisions regarding climate policy in Israel.
Government Decision 286, which was passed after more than 13 years of discussions on the matter of carbon pricing, prescribed that with effect from 2023, carbon tax would be imposed gradually on some of the fuels. The follow-up audit found that as of November 2023, a carbon tax had not been imposed and at that time there was no willingness on the part of the Ministry of Finance to promote the implementation of the government decision. According to the Ministry of Finance's Budget Department, the non-implementation of a carbon tax will lead to a loss of revenue of more than NIS 2.5 billion during 2023, and more than NIS 7.5 billion from 2023 to 2028 (in the accumulative). The non-implementation of a carbon tax in Israel is inconsistent with repeated OECD recommendations in the matter.
The Comptroller warns that in the absence of the implementation of a carbon tax, Israel is exposed to trade restrictions in the form of the CBAM promoted by the European Union for the imposition of a carbon tax at the entrance to European borders on imports from countries without a carbon pricing mechanism. Consequently, it is possible that European countries will gradually impose a carbon tax on energy rich goods exported to them from Israel, on account of the emissions during their manufacturing process, and this will increase the price of these goods and is liable to adversely affect the competitive edge of the manufacturers in Israel. Furthermore, the revenue from this tax will not go to the State Treasury, but to such countries that charge it. Making zero emissions the acceptable global standard is also expected to divert international investments in the private and government sectors from Israel to those countries following a sustainable economic policy.
The follow-up audit found that annual government support for fossil fuels is steadily increasing (except for the year 2020 due to the coronavirus pandemic). This support nearly doubled, rising from about NIS 2.2 billion in 2010 to a peak of NIS 4.2 billion in 2019, and although it declined in 2020 (due to the coronavirus pandemic), the upward trend resumed in 2021. Support data for 2022-2023 are expected to rise even more in light of the new exemption from the coal tax and the discount on the gasoline tax, amounting to a cumulative total of about NIS 3.5 billion. These subsidies act as an economic incentive, increasing demand for fossil fuels instead of shifting demand to other alternatives or improving energy efficiency. Subsidies of such extensive scope are inconsistent with Israel's long-standing goals to reduce GHG emissions and other pollutants, and they undermine its efforts to transition to a low-carbon economy.
The Comptroller found that more than two years since the establishment of a team to examine rules for responsible investments (ESG considerations in the fields of environment, society and government) in its investment policy, the Bank of Israel has not yet completed the examination process and has not made any decisions on the matter. Therefore, the Bank of Israel manages Israel's foreign exchange reserves, which as of June 2023 amount to $202 billion, without taking into consideration ESG factors and without integrating the risks arising from climate change within its investment considerations. This is despite the trend highlighted in the 2022 NGFS survey, where about 40% of the central banks that responded (about two-thirds in the European Union) take climate considerations into account in their current monetary policy.
Comptroller Englman recommends that the Ministry of Finance initiate and spearhead a thorough study for the analysis of the long-term economic and fiscal effects, including assessments of the costs of preparedness for climate change in Israel.
Climate governance – organizational, functional and professional preparation for handling the climate crisis
69% of the government ministries: The government handling of the matter of climate is not good at all or is not so good * Only approximately 32% of the sums approved for handling the climate crisis from 2015 to 2022 have actually been spent * From 2015 to 2022 the government encouraged the demand for pollutant fuels by means of tax incentives that reached 33 times the sum invested in the climate field * As of 2020, approximately 56 countries have entrenched their activity in the climate field in legislation; Israel is still not among them.
Addressing the climate crisis necessitates comprehensive government attention – it demands multi-ministerial cooperation on many issues and monitoring the implementation of actions by government ministries. The whole range of the findings of the follow-up report and the responses obtained to the questionnaire in the matter circulated by the Office of the State Comptroller among the government ministries, whereby 69% of the respondents are of the opinion that the government's handling of the climate issue is not good at all (8 respondents) or not so good (26), reflect a situation where the government's activity in climate issues is insufficient, and this difficulty continues to exist.
In the previous report, the Comptroller recommended that the government designate the handling and ongoing management of this issue to a permanent, designated, integrative body with executive powers and the ability to decide between alternatives and in cases of disputes, which would lead the issue. The follow-up audit found that although various governmental entities are involved in some aspects of integrating climate issues, such as the Ministry of Environmental Protection, the Ministry of Energy, the Ministerial Committee, and the National Security Council, none have the aforesaid characteristics that may assist in effective integration.
From 2015 to 2022 Israeli governments utilized only 32% (NIS 988 million) of the funds that they had resolved to allot to climate issues in these years (NIS 3 billion, of which NIS 1.584 billion was actually allocated) – a utilization level that does not allow for the effective implementation of the established climate policy. This issue is further exacerbated by data indicating that during the same period, the government forfeited state revenues exceeding NIS 32 billion through supports and subsidies for fossil fuels – 10.6 times the amount planned for climate investment (the decision to allocate about NIS 3 billion), and 33 times the amount actually invested (budget utilization of NIS 988 million). These gaps starkly reflect the priorities of the governments during those years – multiple declarations of setting climate goals without the necessary resource allocation to achieve them, alongside continued funding policies that undermine their achievement.
In actuality, a work model of segmented budgeting (divided by ministry) and one-time or specific budgeting does not allow for the systemic advancement of the climate crisis issue. In 47 government decisions addressing the climate crisis issues, made by governments between 2007 and 2022, which decided to designate approximately NIS 7 billion, the government ordered the execution to many government ministries (about 15 in number) in more than 70 individual allocations. The manner in which the missions are allocated does not conform to the complexity of the handling of this crisis.
During the past 16 years, 47 government decisions related to addressing the challenges of the climate crisis were passed, but Israel has not shown any significant improvement in achieving its national climate objectives: Essential government decisions dealing with the climate have not been implemented, have been partially implemented, or are only in the initial stages of implementation.
As of 2020, about 56 countries had entrenched their policy actions in the climate field in legislation. Israel is still not one of them. The goals set in the Climate Law bill, as of September 2023, are largely declarative. It is noticeable that despite the obligations it imposes, and the policy tools it sets forth, the bill lacks additional policy tools that would allow decision-makers to integrate a variety of considerations, promote processes at the operational level, and consequently meet the goals and commitments it sets. The new bill also lacks a mechanism designed to regulate a framework for the long-term budgeting of climate policy and sources for its funding. Furthermore, its language does not bind government entities, and it even creates a path for them to retreat from realizing the set goals.
The Comptroller found that the Ministry of Finance's stance in the matter of establishing a normative foundation through climate legislation comprises several strata: (a) Opposition to giving normative validity to GHG reduction goals in the Climate Law, preferring instead that the goals be anchored in a government decision; (b) A demand that the goals should not bind the government but only represent goals to aspire to, in order to prevent "judicial authority interference with government decisions." This stance presents a real and fundamental difficulty, since effectively the ministry demands unlimited flexibility in changing climate goals, which is liable to allow these goals to be pushed aside in favor of any other issue that may be on the agenda. This stance might delay and, in some cases, even halt the achievement of the climate goals. The Ministry of Energy, the Ministry of Economy, the Budgets Department at the Ministry of Finance, and the National Economic Council, agree that there are currently inter-ministerial barriers, such as in the installation of PV facilities; the deployment of charging stations for electric vehicles; the promotion of policy instruments and economic tools such as carbon tax and tax support for the transition to a low-carbon economy – and without the removal of such barriers, Israel will not be able to achieve its climate goals – but every party establishes barriers by itself, while there is no leading party that can decide in case of disputes or promote climate issues, including the relevant legislation, due to the opposition of various parties.
Comptroller Englman again recommends designating the handling of the climate change issues to a permanent, consolidating body that will lead the subject and possess executive powers and the ability to decide between alternatives and in cases of disputes. Alternatively, bestowing upon one of the bodies (such as the Ministry of Environmental Protection, the Ministry of Energy, the Ministerial Committee and the National Security Council) with the currently missing characteristics and powers required. The ministries dealing with the issue must reinforce Israel's commitment to the realization of a climate policy.
Transboundary air pollution originating from waste incineration in the Judea and Samaria area
A multi-year failure by the Civil Administration and the Ministry of Environmental Protection in the handling and prevention of waste incineration in Judea and Samaria * Air pollution hazards from these incinerations have intensified from 2017 to 2022 and have become further aggravated during the Swords of Iron War * During these years, the Ministry of Environmental Protection received more than 50,000 complaints from Israeli residents in the matter, the majority of which contained complaints of physiological phenomena – but it did not involve the Ministry of Health in them * The Office of the State Comptroller estimates that the external costs of the harmful health and environmental effects from these incinerations are expected to total at the very least NIS 9.1 billion from 2023 to 2030.
The phenomenon of various types of waste incineration, in open spaces and in an uncontrolled and unregulated manner, has been ongoing for about 20 years at least in the Judea and Samaria area. In these incinerations, many pollutants and toxins are emitted into the atmosphere, and exposure to them is liable to have harmful health effects. This report deals with transboundary air pollution originating from the incineration of mixed Palestinian domestic waste and the incineration of waste from electric and electronic equipment in Judea and Samaria.
The audit findings regarding the scope and implications of the phenomenon are set out below:
· From 2017 to 2022, air and odor pollution nuisances from these incinerations have expanded and intensified, adversely affecting the daily lives of Israeli and Palestinian residents. After the outbreak of the Swords of Iron war, from October to November 2023, heads of local authorities in the Shfela (the Judaean Foothills), the central region and the surrounding areas raised complaints about the aggravation in the phenomenon of waste incineration in Judea and Samaria that have a transboundary impact.
· From 2017 to 2022, the Ministry of Environmental Protection received more than 50,000 complaints from Israeli residents concerning air and odor pollution nuisances arising from waste incineration in Judea and Samaria. About 44,700 reported a strong odor; about 21,200 reported breathing difficulties; about 13,400 reported burning in the eyes or the respiratory system; about 2,900 reported burning of the skin.
· According to the Civil Administration, the main reasons for the phenomenon of incinerating mixed Palestinian waste in the unregulated waste collection sites are a dearth of landfill sites authorized to handle this waste in the various areas in Judea and Samaria, and the financial inability of the Palestinian localities of a low socio-economic cross-section to finance the cost of transporting their waste to the authorized landfill sites that are located a long distance away from them.
· According to the Civil Administration's data, from 2017 to 2022 there was an increase of approximately 75% (from approximately 70 to approximately 123) in the number of unregulated waste collection sites where domestic Palestinian waste was incinerated. The Civil Administration does not have any data or assessments regarding the scope of the waste incinerated in these waste collection sites and their transboundary impacts. According to assessments made by the Comptroller, in 2022 approximately 422,000 tons of mixed Palestinian waste, constituting 45% of the total mixed Palestinian waste created in Judea and Samaria in 2022, were incinerated in unregulated waste collection sites, while approximately 180,000 tons of it were incinerated in 77 unregulated waste collection sites that had a transboundary impact; for the sake of comparison, it should be noted that in the same year approximately 285,000 tons of mixed waste were incinerated in the whole of Israel.
· The Office of the State Comptroller estimates that the accumulative external costs of the transboundary air pollution as a result of the incineration of mixed Palestinian waste from 2023 to 2030 will total approximately NIS 7.4 billion in the scenario of business as usual; and approximately 10.3 NIS billion in the worst-case scenario. This assessment reinforces the need and the economic viability of completing infrastructures for the regulated handling of all the mixed Palestinian waste as soon as possible.
· Regarding the incineration of electronic waste, it was found that the main reason for its incineration is economic. According to the Civil Administration, most of the electronic waste incinerated in the area of south Mount Hebron is smuggled out of Israel. This is an informal industry of incinerating electronic waste in order to produce valuable metals. This industry provides hundreds of Palestinian families with livelihoods.
· A 2019 study found a statistical correlation between the foci of excess morbidity from lymphoma in children from the Palestinian villages located in the south-west area of Mount Hebron and the location of the electronic waste dismantling and incineration sites. Until the completion of the audit in December 2023, the Civil Administration, which is responsible for managing civil matters in Judea and Samaria, the Shai (Judea and Samaria) District and the Ministry of Environmental Protection did not see fit to promote the handling of the phenomenon of smuggling and incinerating electronic waste in the Judea and Samaria areas.
· The audit found that every year hundreds of pirate electronic waste fires are lit in the south area of Mount Hebron, and they have a transboundary impact. According to assessments by the Office of the State Comptroller, the estimated amount of electronic waste smuggled out of Israel to the Judea and Samaria areas and incinerated, mainly in the south area of Mount Hebron, during 2023, totaled approximately 51,700 tons of electronic waste.
· According to assessments by the Office of the State Comptroller, the accumulative external costs of the transboundary air pollution as a result of the incineration of electronic waste from 2023 to 2030 will total approximately NIS 1.71 billion. We should add to these costs, among other things, the loss of revenue to the State Treasury, which according to an initial assessment by the Office of the State Comptroller totals approximately NIS 116 million for 2023 alone, due to the spillover of electronic waste to Judea and Samaria and preventing the possibility of the metals contained therein being used in favor of the Israeli economy.
Those responsible for the multi-year failure in transboundary air pollution originating from the incineration of waste in Judea and Samaria and finding a solution to this problem:
The audit findings testify as to the failure of the Civil Administration, throughout many years, in promoting environmental infrastructure projects in Judea and Samaria that would allow regulated handling of mixed Palestinian waste and electronic waste.
· Regarding domestic Palestinian waste: Despite the considerable budgets recruited by the Civil Administration for handling the matter over the years – more than 175 million euros from international sources and approximately 126 million from the Judea and Samaria Cleanliness Fund – infrastructures that should have provided a solution to the discrepancy in the handling of domestic Palestinian waste are in the planning or initial performance stages, and may not even be completed by the time the existing infrastructures reach their full capacity.
· Regarding electronic waste: Ventures for the regulated handling of electronic waste in Judea and Samaria through private Palestinian companies, and the formal regulation of this industry in Judea and Samaria as to prevent environmental health and economic damage while simultaneously preserving a source of income for the Palestinians working in the incineration industry, similarly to the solution found for the carbonizers problem in the past, had not been promoted by the Civil Administration.
· After the outbreak of the Swords of Iron War, from October to November 2023, heads of local authorities in the Shfela (the Judaean Foothills), the central region and the surrounding areas raised complaints about the aggravation in the phenomenon of waste incineration in Judea and Samaria that have a transboundary impact.
· From 2017 to 2022 environmental offenses, including waste hazards and waste incineration, did not form the center of the Supervision Unit's activity, despite the rise in the scope of the waste, the number of hazards and the number of complaints received in the matter, and despite its being the main unit having enforcement powers in the field.
· The David Unit operates at the border crossings between the territory of the State of Israel and Judea and Samaria to implement the policy of the Staff Officer and the Ministry of Environmental Protection. From 2019 to 2022 a downward trend was recorded in the number of vehicles and trucks seized by the Unit: From 2019 to 2020 a decrease of about 7% was recorded in the seizure of vehicles and trucks, and from 2021 to 2022 a decrease of about an additional 11% was recorded (an annual average of 188 vehicle seizures from 2014 to 2022); an estimate of the trucks smuggling electronic waste from Israel to Judea and Samaria ranges from 2,500 trucks (if all are large electronic waste trucks, and the scope of the smuggling is on the low range) to about 10,500 trucks (if all are small electronic waste trucks, and the scope of the smuggling is on the high range). Therefore, it turns out that the Supervision Unit and the David Unit together seized and/or confiscated a negligible amount of approximately 1.2%-5% at the very most of the trucks smuggling electronic waste through the borders and in Judea and Samaria, and this is on the lenient assumption that in 2022 the aforesaid units together seized and/or confiscated only 128 electronic waste trucks; their enforcement powers were not exercised through ransom by the Civil Administration, and this matter has not been regulated in the David Unit's powers. Furthermore, the Civil Administration, which under the Order Concerning the Transportation of Goods (Judea and Samaria) (No. 1252) 5748-1988, is empowered to enact regulations for the purpose of determining additional powers, such as forfeiture and sale, that could have assisted the David Unit in its work and increase its effectiveness, did not do so.
The audit findings indicate many years of the Ministry of Environmental Protection shirking its responsibility for preserving the air quality in the Israeli localities that suffer from these incinerations. The Ministry of Environmental Protection has not exercised the powers and tools at its disposal that might assist and promote the handling of the phenomenon of the incinerations in Judea and Samaria, alongside the Civil Administration's activity. Among other things, through the handling of the electronic waste produced in Israel and the reduction of its smuggling to Judea and Samaria and the appropriate handling of the reports of the Israeli public to the Environmental Emergency Center Hotline about waste hazards originating in Judea and Samaria. The Ministry of Environmental Protection also did not evaluate the scope of the air pollution caused to Israeli residents from waste incineration originating in Judea and Samaria, nor did it include it in its reports to the public concerning air pollution in Israel, despite the fact that from 2017 to 2022, as aforesaid, more than 50,000 reports had been received and recorded from Israeli residents in this matter, and despite the assessments of the National Array for Hazardous Materials and States of Emergency at the Ministry of Environmental Protection the Judea and Samaria areas was defined as a significant factor for air pollution in Israel. The Ministry of Environmental Protection did not involve the Ministry of Health in the tens of thousands of the aforesaid reports, even though they contained inquiries and complaints from Israeli residents regarding physiological symptoms, including breathing difficulties. Such involvement might have assisted the assessment of the existence of harmful health effects among Israeli residents as a result of many years of exposure to these hazards.
The audit findings indicate two decades of a lack of involvement of the political echelon in the topic of the non-formulation of policy and a government plan for the management and execution of transboundary environmental hazards originating in Judea and Samaria. As far back as the report from June 2017, the Office of the State Comptroller found that the lack of government policy regarding transboundary environmental hazards and the failure to appoint an integrative government party to handle the matter had prevented or delayed, for many years, the promotion of solutions for hazards of this kind concurrently with continued damage to the environment, public health and the public interest. Even though the Comptroller recommended doing this as far back as 2017, only in June 2023, during the present audit, did the government resolve to establish an inter-ministerial team to lead the strategic work to formulate government policy for transboundary environmental management, as well as a plan for handling the waste hazards in Judea and Samaria. The government determined that the team would submit its recommendations to it by the end of January 2024. For four months, until the start of the war in October 2023, a period of time which is one half of the time allotted for completion of the inter-ministerial team's work, no progress has been made in its work.
The findings further indicate the poor and restricted use of the supervisory and enforcement powers in offenses of waste disposal and incineration in Judea and Samaria by all the supervisory and enforcement parties in the area (the Civil Administration's Supervision Unit, the David Unit, the Environment Staff Officer, the Israel Police's Judea and Samaria District), and the powers of the National Fire & Rescue Authority to extinguish fires in Judea and Samaria. The Comptroller found that there were only five records against waste offenders in the Judea and Samaria District in 2022. This amount reflects a decrease of approximately 87% in enforcement against waste offenders in Judea and Samaria in 2022 compared with 2020 (40 records).
By the end of the audit in December 2023, the Civil Administration, the Israel Police's Judea and Samaria District and the Ministry of Environmental Protection were unable to promote the handling of the phenomenon of electronic waste smuggling in the Judea and Samaria areas.
Comptroller Englman recommends that the additional minister at the Ministry of Defense, the Minister of Environmental Protection, and all the relevant parties, should make a diligent effort to close the gaps that have persisted in the handling of this issue for 20 years, and act in coordination and cooperation and share information to formulate and implement an operational toolbox to handle the phenomenon of waste incineration in Judea and Samaria.
Government activity in the matter of environmental pollutants in the Haifa Bay – follow-up audit
(At the present time, a sub-committee of the State Control Committee has deemed an additional report concerning Haifa to be confidential)
The petrochemical industry activity in the Haifa Bay is due to end in 2029, but it is doubtful whether it will be possible to comply with the date set * For 3 years (2019-2021), the Ministry of Environmental Protection did not report to the government how the plans for reducing air pollution are being implemented – and did not publish data regarding 60% of the severe deviations in pollutants emissions from factories in the Bay (2021-2022) * Worrisome gaps were found between the amount of deviations discovered in the surprise samplings conducted by the Ministry of Environmental Protection and the amount of deviations in the samplings the factories conducted themselves.
In July 2019, the State Comptroller published a special audit report that dealt with various aspects of the government's activity in the matter of environmental pollutants in the Haifa Bay. The special report indicated a lack of a comprehensive government vision and a long-term strategy for the development of the Haifa Bay while taking into account the need to reduce the air pollution that prevails there.
The present follow-up audit is designed to examine the state of the government's treatment on two main levels: All the government activities for promoting a fundamental long-term response to the problem of pollution in the area; and the governmental actions to reduce the existing pollution from factories and vessels and ports in the interim period – until a thorough and long-term solution is provided.
The follow-up audit found that real progress had been made in a number of aspects, including the approval of Government Decision 1231, which declared the promotion of a strategy for the development of the Haifa Bay that would focus on improving the quality of life of the residents of the area, among other things through the cessation of the activity of the petrochemical industry in the Bay; the establishment of an inter-ministerial steering committee and a designated administration; the installation of regulations designed to reduce the emission of pollutants into the air from vessels – and the approval of the "Gate of the Bay" national outline plan for the transformation of the Haifa Bay area.
Alongside this, it was found that some of the defects noted in the previous report concerning reporting to the government on the degree of implementation of national plans to reduce air pollution in Israel in general, and in Haifa Bay in particular, concerning the supervision of pollutant emissions into the air from factories and periodic sampling in chimneys, had not been rectified or had been rectified to a small extent. Gaps were also found in the handling of the issues that were not examined in the previous audit regarding air pollution from vessels and ports and regarding the information that the Ministry of Environmental Protection publishes to the public about the emission of pollutants from chimneys in factories:
· The State Comptroller found that the deadline for the halting of operations of the petrochemical industry activity in Haifa Bay in 2029, set in the work plan of the steering committee and the administration, was not anchored in a government decision, and therefore the degree of commitment to meet it is less. The main risks that may make it difficult to implement the decision are: Uncertainty regarding the receipt of the budgets required for implementation; difficulties in approving statutory plans for the establishment of alternative infrastructures for the petrochemical industry, among other things due to objections from local authorities and their residents to the establishment of these alternative infrastructures in their territory; difficulties in reaching agreements in negotiations with the factories on cessation of their activities; and possible failure of tenders for the establishment of transportation facilities and facilities for storing energy sources.
· Contrary to its obligation, the Ministry of Environmental Protection did not provide the government for about three years (2019-2021) information and insights regarding the extent to which the national plans to reduce air pollution were implemented in the country in general and in the Haifa Bay area in particular. In this way, the government's ability to examine in these years (2019-2021) the manner in which it fulfilled its obligations to the public as approved in the national plans and to consider taking actions to reduce gaps if necessary, was harmed. The public's right to receive significant environmental information was also harmed.
· It was found that in 2022 the rate of surprise inspections conducted by the Ministry of Environmental Protection and in which deviations and severe deviations were discovered in emission facilities, was more than four times greater than the rate of periodic inspections carried out by the factories and in which deviations and severe deviations were discovered: More than five times than the rate of inspections in which a deviation was discovered (in 8.3 % of the surprise inspections compared to 1.6% of the periodic inspections), and twice the rate of inspections where a severe deviation was discovered (in 1.2% of the surprise inspections compared to 0.6% of the periodic inspections). Similar gaps were also found during 2021. The defect is particularly clear, as the response of the Ministry of Environmental Protection shows that it is aware that periodic inspections carried out by the factories are done after actions designed to improve the inspection findings and therefore do not reflect the routine emissions at the factory.
· The follow-up audit found that out of the 1,412 inspection findings published by the Ministry of Environmental Protection regarding the 18 factories where a deviation was found in the years 2021 to 2022, regarding more than half of the sampling findings (783 out of 1,412, approximately 55%) no information was presented from which it is possible to know whether there was a deviation in pollutant emissions from the chimneys in relation to the permitted emission standards. It was also found that in most cases where a severe deviation was discovered in the emission of pollutants into the air from factories in Haifa Bay in the years 2021 to 2022 (18 cases out of 30, 60%), the Ministry of Environmental Protection did not publish this data for public information in the database.
· The quarterly sampling reports conducted by the Ministry of Environmental Protection on factory chimneys included incorrect data and it was not possible to analyze them and draw conclusions from them, so that in practice the Ministry did not have a centralized and updated report on the subject.
· Since the previous report, seven studies on air pollution and morbidity in the Haifa Bay have been carried out with the funding of the Ministry of Environmental Protection, beginning in the years 2017 to 2019: Four have been published, but three more have not yet been published. One of the published studies found statistically significant relationships between exposure to industrial air pollution of the highest degree between the years 1967 to 2012 and specific cancers and reinforced the hypothesis that environmental exposure to industrial air pollution in Haifa Bay increased the risk of cancer. In June 2023, the Ministry of Health informed the Office of the State Comptroller that after the completion of all the studies, it would be able to summarize its position regarding all of their results and regarding the causal relationship between air pollution and morbidity in Haifa Bay.
· Since the previous report, seven studies on air pollution and morbidity in the Haifa Bay have been carried out with the funding of the Ministry of Environmental Protection, beginning in the years 2017 to 2019: Four have been published, but three more have not yet been published. One of the published studies found statistically significant relationships between exposure to industrial air pollution of the highest degree between the years 1967 to 2012 and specific cancers and reinforced the hypothesis that environmental exposure to industrial air pollution in Haifa Bay increased the risk of cancer. In June 2023, the Ministry of Health informed the Office of the State Comptroller that after the completion of all the studies, it would be able to summarize its position regarding all of their results and regarding the causal relationship between air pollution and morbidity in Haifa Bay.
Comptroller Englman recommends that the government resolutely implements the decision to develop the Haifa Bay as a prosperous and sustainable metropolitan area in accordance with the plan and schedule established, while continuously allocating the required budget for this purpose. The Ministry of Environmental Protection must take actions to reduce emissions of pollutants into the air, tighten environmental supervision in the Haifa Bay area and make information available to the public on these matters.
