OBJECTIONS TO THE EBRO WATER TRANSFERS
I sign these objections to the Ebro transfer project as made public by Trasagua in the document "Summary of the project for the water transfers passed by article 13 of Law 10/2001, 5th July 2001 (the National Hydrological Plan, NHP) and study of their environmental impact", as I believe that the information enclosed in this document has been manipulated so as to present these water transfers as feasible and necessary, when it is known that they will be completely unsustainable from all points of view; socially, environmentally, and economically.
Lack of studies of alternatives: The document does not offer a full study of the alternatives to these transfers. It merely makes reference to the "Strategic Environmental Assessment" published in January 2002, which was clearly biased in favour of the transfers option. The Environment Ministry still fails to study alternatives based on an optimal combination of various options (demand management, re-use, desalinisation, combined use of ground and surface waters etc), which is the normal method of hydrological planning at present in developed countries.
Lack of respect for the river Ebro and its Delta: The document gives the go-ahead for the water transfers arbitrarily planned in the Ebro Basin Hydrological Plan, and then accepted by Law 10/2001 of the NHP, ignoring the warnings of the scientific community about their environmental impacts and without preparing the conservation measures for the Delta which are also required by Law. It also disregards the principle of Basin Unity in the Water Framework Directive which demands that the Ebro be protected from any deterioration.
Impacts on areas receiving the transfers :The document states that the transferred water will not be mixed with local waters of the receiving areas. This is technically impossible, as is the statement that they can prevent the transfer of exotic species using filters of 1.5mm given that the larvae of the zebra mussel is 30 times smaller than this. The Vinalopo-Jucar transfer, a key element for the Ebro transfer, will overexploit the Jucar which has no minimum ecological flow assigned to it in its lower section. The conservation of the Albufera wetlands is based on excess water from agricultural uses and treated waste water, but with no real guarantees. The excess uses along the Segura Basin will only worsen the problems which previous hydrological planning has already created.
Poor water quality: The document states that 45% of the transferred water will be for drinking uses despite the fact that the sulphate content of the Ebro's water is above the compulsory limits set in Directive 75/440 for pre-drinking waters. The Ebro's waters are also above the recommended limits of conductivity. Furthermore, it is predicted that both these parameters will worsen, by as much as 50%, in coming years, according to information which the Environment Ministry presented to the European Commission.
Unsustainable energy costs: The document admits that the energy costs will be far higher than first stated in the NHP project, although it still fails to apply the life cycle analysis which is the standard tool for environmental assessment of large projects. The actual energy costs of the transfers, and the accompanying CO2 emissions, will be far above those of any of the alternative options, including desalinisation.
Waste of economic resources: The document calculates the costs of the transferred water without taking into account the amortisation of the investments. This goes against the cost recovery principle of the Water Framework Directive and tries to hide the real costs of the transfers which will be higher than a combination of alternatives such as efficiency, re-use, and desalinisation.
The above points are fully demonstrated in the studies which the Foundation for a New Water Culture has presented to the Environment Ministry. In conclusion, as the Ebro transfers would be a misuse of resources, breaking Spanish and EC Laws, without solving the water problems of Spain, I request that the aforementioned project be immediately paralysed and that measures be taken to allow for its complete withdrawal.
PASSPORT / ID NUMBER ................................