Seven Reasons Why WWF Opposes The Spanish National Hydrological Plan and Suggested Actions and Alternatives

The Spanish National Hydrological Plan (SNHP) law was adopted by the Spanish Parliament in July 2001 and entered into force in August 2001. It has two main parts: a new water transfer of 1,050 cubic hectometres per year from the Ebro River Basin to another four river basins in the north, south-east and south of the country, and a package of 865 public water works.

WWF opposes the SNHP on a number of levels and believes that in its current form it is not a feasible, sustainable plan. WWF also proposes actions to improve and re-orient the Plan.

Arguments against the Plan include:

1. It’s a "yesterdays" Plan and does not fit with today’s need for integrated water planning and management, and sustainable development.

Despite short term benefits for the construction industry, farmers, agri-traders and the tourism industry, actual long term effects of the SNHP through unsustainable planning and management will actually mean a reduction in "ecosystem services" for local people, and a lowered potential for socio-economic development based on sustainable activities. The construction of big dams and water transfers only serve to perpetuate the water deficit and encourage the idea that water is an unlimited resource.

2. It will not work because factors like climate change and poor quality of water at the source of the transfer have not been properly considered.

Failure to take into consideration the results of climate change, such as loss of existing water resources over time and furtherdeterioration of the already poor water quality from the donor river (in the case of the Ebrotransfer), as well as the prohibitive cost of trying to deal with these two factors on the overall cost of the transfer, means the SNHP is doomed to fail before it begins. The current mismanagement of aquifers (ie. illegal boreholes) also means that, by the time transferred surface water arrives, the water tables will have been exhausted, creating a new deficit at the original source.

3. It is not economically justified, the figures are wrong and the cost has been underestimated.

The economic justification of the SNHP is full of errors, does not respect scientific and technical knowledge, does not adequately analyse cheaper alternatives and completely fails to consider the full cost recovery of the Ebro River transfer. A rigorous analysis of the SNHP should have taken into account other costs, including the environment and resource costs, the full cost of building the big dams and the cost of treating the polluted, salinised water arriving in the "receiving river basins" (in the case of the Ebro transfer).

4. It will have significant impacts on species and habitats protected under EU legislation.

Both the Ebro River transfer and the works will have a severe impact on 126 Important Bird Areas (32% of Spain’s total) and 86 Special Protection Areas designated under the Birds Directive (28% of Spain’s total). The water infrastructure works planned across the country will also affect 18 species and 14 habitats protected by the EU Habitats Directive, including priority species like the Iberian Lynx and the Brown Bear. At least 71 of the proposed works have been identified by WWF as having adverse effects on 82 Sites of Common Importance, which the Spanish Government have themselves proposed for inclusion in the European network of protected areas, Natura 2000.

Deterioration of the unique ecosystem of the Ebro Delta will result from: Reductions in sediment transport; increased duration and length of the salt wedge upstream; longer anoxia periods in the estuary, pollution from fertilisers and pesticides; increased salinity in the Delta water bodies leading to the disappearance of some lagoons; impacts on wetland vegetation; reductions in fish and shellfish fisheries; and severe effects on protected animal species.

5. It goes against EU legislation and policy, and is therefore illegal.

The SNHP is in breach of several articles of the EU Treaty, and also contravenes the objectives and provisions of certain EU Directives, notably the Water Framework Directive, the Habitats and Birds Directives, the Directives on Environmental Impact Assessment (EIA), the Strategic Environmental Assessment Directive (SEA), as well as overall European Commission/EU commitments under international conventions. (eg. Arhus Convention on access to environmental information and justice on environmental matters.)

6. It will misuse up to 8 billion Euro of EU Taxpayer money.

The Spanish government aims to execute the SNHP with the use of considerable EU Structural funding, in particular the European Regional Development Fund and the Cohesion Fund. (up to one third of the 22,87 million Euro total cost could be met by the EU). But the guidelines for the use of EU funds are not being met.

In practice much of the investment proposed under the SNHP will benefit areas with relatively high levels of economic development, especially the east and south-east coastal regions, while transferring water away from the extremely poor Aragon mountains and the rice-farming Ebro Delta region.

7. There are alternatives!

The SNHP does not sufficiently consider more feasible and economic alternatives to the large water infrastructure projects it promotes. Considerations which could make a difference across Spain without the need for a major transfer and works scheme include  proper control of water use, full cost recovery, desalinisation, water saving via modernisation of irrigation systems, water re-use, intermediary markets or water banks, territorial and urban planning and the integrated management of surface and groundwater.

• Elaborate an independent Environmental Impact Assessment for the whole plan in order to have a non-biased report on the environmental impacts.

• Conduct a more in-depth analysis of water resource availability in Spain (including groundwater resources)

• Conduct a cost-benefits study of the Ebro River transfer and an assessment of (sustainable) alternatives to this transfer.

• Develop an in-depth analysis of alternative water management measures to the current SNHP, ensuring full transparency and proper public participation

• Revise the SNHP ensuring full transparency and proper public participation in the development of alternative water management measures.

• Implement Integrated River Basin Management in line with the Water Framework Directive

• Revise the SNHP taking into account the results of all the above-mentioned analyses and activities, ensuring full transparency and proper public participation

• Enforcement of EU policies and legislation, ensuring the SNHP does not go ahead until it can be proven it is not in breach of any obligations under Community law.

• Adopt and defend a joint Commission position regarding EU funding for the SNHP

• No funds for the current SNHP

ACTIONS TO BE TAKEN BY BOTH SPAIN AND AT THE EU INSTITUTIONAL LEVEL

Promote environmental integration and coherence between water policy objectives and the Common Agricultural Policy and the EU Regional Funds.

WWF’s main objective is to stop the SNHP as it currently stands, and to ensure that it is revised so it does not jeopardise nature conservation and contributes to the proper implementation of the Water Framework Directive’s principles and requirements for sustainable water management, leading to higher economic and social cohesion in Spain.

June 2002