I, the undersigned, Maher Najjar, holder of I.D. No. _____________, having been put on notice that I must tell the truth and nothing but the truth and that if I do not do so, I will be subject to criminal penalties under the law, hereby declare as follows:

 

1.      My name is Maher Najjar. I am the Deputy Director of the Coastal Municipalities Water Utility (CMWU). I make this affidavit in support of a request and/or court petition that the Israeli authorities provide fuel and electricity to vital humanitarian institutions in Gaza.

2.      The Coastal Municipalities Water Utility is the Semi public utility that runs the water and sewage systems in Gaza. We rely on electricity and fuel to run the system.

3.      The water and sewage system is in a very vulnerable situation. Especially since June 2007, severe restrictions on the entry of goods into the Gaza Strip have disrupted the functioning of the water and sewage system in Gaza, including spare parts.

4.      Water and sewage pumps in Gaza run on electricity. When there is not enough electricity, they run on standby generators, which are powered by diesel and designed to run no longer than 8 hours per day.

5.      Since the beginning of the military operation on December 27, 2008 and especially since the electricity and water systems were badly damaged in the start of the ground operation on January 3, 2008, we have been unable to provide water to well over 530,000 of Gaza's residents (approximately 400,000 people in Gaza City and the North, 100,000 people in Rafah, and 30,000 people in the Middle Area). In addition, because of the lack of fuel and electricity to sewage pumping stations, sewage is piling up in the streets and harming the health and safety of Gaza residents. There is an additional danger that the sewage lake in Beit Lahiya will overflow within a week, endangering the lives of 10,000 people living nearby.

6.      The information I provide is based on my contacts with technicians, suppliers, and residents calling to report malfunction of the water and sewage system. My ability and that of my technicians to fully assess the damage is limited because of the danger of leaving our homes and the disruption of phone service for communication.

7.      As of last night, there is no electricity at all in Gaza City. All lines feeding Gaza City from Israel have been shut down due to damage from the shelling and bombing. The local power plant has been shut down since December 30, due to lack of industrial diesel. As of today, the entire water and sewage system in Gaza City and the Northern Area is entirely dependent on backup generators run by diesel.

8.      In addition, two of the lines feeding electricity to Rafah, one from Israel and one from Egypt, have been damaged.

9.      I have no additional diesel reserves, and I cannot obtain additional diesel right now.  The water wells and sewage pumping stations that still have diesel will run out within a few days, others have none.

 

10. Gaza City has 45 water wells supplying 550,000 people. Approximately 25 of those wells are not working at all, including two damaged from airstrikes. The remaining 20 wells are operating approximately 4-5 hours per day, using back up generators.

11. The last time we were able to distribute diesel for back up generators to Gaza City was approximately 10 days ago. I expect that within three days, the remaining 20 water wells in Gaza will also shut down, because their diesel reserves will run out, meaning there will be no water supply at all to Gaza City.

12. Even the 20 water wells that are partially working are of extremely limited use, because without electricity in the multiple story buildings in which most people in Gaza City live, there is no way to pump the water to people's homes.

13. We have received many phone calls from people in Gaza City complaining that they have no water. Many have stockpiled drinking water, but they have no water for the toilet or for washing themselves, their clothing and their dishes. In addition, because they cannot leave their homes, it is not clear how they will purchase additional drinking water.

 

14. The water system in the northern area serves approximately 350,000 people through approximately 35 water wells.

15. There is no electricity at all supplied to the Northern Area now because the lines were hit yesterday.

16. Yesterday, we distributed 8,000 liters of diesel to 10-15 of the water wells in the Northern Area. It will last for approximately 2-3 days.

17. At least 20 of the water wells in the North are stopped completely. One was destroyed in the military operation, and the others have no fuel reserves.

 

18. Rafah has 10 water wells serving about 200,000 people. Most of those wells no longer have any electricity supply.

19. We distributed 6,000 liters diesel yesterday to Rafah. It will last for approximately 3 days, permitting supply for 8 hours per day.

20. Many in Rafah are already without water, and we anticipate that within 3 days, 70% of the population will lose access to water.

 

21. There are approximately 230,000 people in the Middle Area.

22. Yesterday, an airstrike hit a water pipeline in the Middle Area, cutting off supply to three wells feeding 30,000 people. We can't repair the pipeline because it is close to the areas being bombarded. If I had electricity, I could supply those people from other sources.

 

23. The sewage situation is highly dangerous. Out of 37 pumping stations, 32 are operating only partially because of the lack of electricity. Five out of 37 pumping stations are not operating at all:

24. In Beit Hanoun, a 16-inch pipeline from the main pumping station into the treatment plant in the north was hit by the airstrikes. Sewage has been flooding for the past four days, and there are people living nearby. We have requested coordination from the Israeli military, via international organizations, to allow technicians into the areas to fix the pipe, but thus far there has been no coordination.

25. For the remaining 32 pumping stations, we expect that fuel will be depleted within 3-4 days, meaning that the sewage will flood into the streets and the sea.

26. This is extremely dangerous, especially for highly populated areas like Gaza City.

 

 

27. The most dangerous problem is the 4 million cubic meter wastewater treatment plant in Beit Lahiya, the one that overflowed in March 2007 and killed five people. Since the tragedy, we dug lagoons to deal with the overflow. But now we don't have electricity or fuel to pump overflow sewage from the main lake into the lagoons. Even with the decreased amount of sewage being pumped into the lake because of the breakdown of the sewage system, the sewage level of the lake is rising by approximately 1.5 cm to 2 cm each day. Within a week, there would be an increase of 15-20 cm in the lake level, which is very close to the level that endangers the 10,000 people living nearby. Of course, any strikes near the lake would also be extremely dangerous.

28. I provided the information in this affidavit on January 4, 2009, via the telephone, to Adv. Sari Bashi of Gisha-Legal Center for Freedom of Movement. I confirmed the truth of its contents when read back to me and sent to me via cell phone text message. I do not have electricity in my house and so cannot fax my signature for this affidavit or leave my house to have my signature witnessed.

29. I affirm that this is my name, and the content of this affidavit, which I have confirmed orally to Adv. Bashi, is true. I have been put on notice that I must tell the truth and nothing but the truth and that if I do not do so, I will be subject to criminal penalties under the law.