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written by the US Technical Review Team c/o Alex Horne Associates
January, 2003

                                                                   by M. Ramón Llamas
                                                                     Emeritus Professor
                                                     Complutense University of Madrid
                                               Fellow of the Royal Academy of Sciences
                   Former President of the International Association of Hydrogeologists


   1. Abstract
   2. Resumen
   3. Introduction
   4. Scope and aim
   5. General considerations
   6. Specific considerations
      6.1. Weaknesses of the assessment on the water needs that justify the Ebro
           River Diversion
      6.2. Gaps about the analysis of groundwater mismanagement
   7. Conclusion
   8. References

                                                                        March 9, 2003
1. Abstract

The Executive Summary and the Coclusion of the TRSNHP approve practically
without any reserve the Ebro River Diversion. Nevertheless, some parts of the
report, mainly Appendices C and D, contain severe objections to the economic
feasibility of the proposed Ebro River Diversion.

These comments are mainly related to the way in which groundwater management is
considered in the SNHP. This is a crucial issue because the initial and main goal to
justify the construction of this huge hydrological infrastructure is to solve the
situation of the assumed overdrafted aquifers, mainly in the Segura basin. The
analysis of this crucial and radical       problem is very weak. The mentioned
bibliography is incomplete and seems biased. The main source seems to be an
internal report of the Spanish Ministry for the Environment. Surprisingly, the access
to this internal report has been denied to this author. Nevertheless, it is a well known
fact the administrative, legal, institutional groundwater situation in the Segura basin
can properly be defined as chaos, or better as a hoax.

Therefore, it is strongly suggested to stop the detailed design of the Ebro River
Diversion until a solid evidence exists on a real change in the groundwater
management in the Segura basin.

2. Resumen

Tanto las conclusiones como el “Executive Summary” del TRSNHP aprueban sin
reservas el trasvase del Ebro, “a cambio de que se introduzcan acciones (?) que
mejoren la calidad del agua del Ebro y la salud de los humedales mediterráneos”.
Sin embargo, dentro del texto y especialmente en los apéndices C y D se introducen
algunos comentarios que prácticamente indican que el actual proyecto del trasvase
es inconsistente o inviable.

Este comentario se refiere principalmente al tratamiento que hace el informe
TRSNHP acerca de los problemas de las aguas subterráneas en el SE español. El
tema es crucial, ya que el principal motivo para realizar el trasvase del Ebro es
    resolver la denominada “sobreexplotación de los acuíferos”. La información
    utilizada por los autores del TRSNHP parece incompleta y sesgada. El documento
    básico parece se un informe interno del Ministerio de Medio Ambiente cuyo
    contenido parece estar vedado a los ciudadanos españoles, por lo menos a este autor.
    La gestión y el control de las aguas subterráneas en la cuenca del Segura desde hace
    varias décadas es un auténtico caos, por no decir un engaño al conjunto de los
    Por todo ello, se sugiere con fuerza que el proyecto detallado del Trasvase de Ebro
    sea detenido hasta que exista una sólida evidencia de un cambio en la gestión de las
    aguas subterráneas en la Cuenca del Segura.
    3. Introduction

    On January 2003, the Foundation of the Politechnical University of Cartagena
    (FUPC) loaded in its Website the Technical Review of the Spain’s National
    Hydrological Plan (TRSNHP). According to the media, several corporations located
    in Murcia, mainly the shipbuilding CO. IZAR, had funded this report with a cost of
    US$ 300,0001. The media also indicated that the main goal of this action was to
    provide an “independent assessment” to the European Union (EU) Commission in
    order to get EU subsidies for the construction of large hydraulic infrastructures –
    mainly an aqueduct and several reservoirs– needed to transfer the water.

    This Ebro diversion has created torrents of controversy in Spain. The various
    lobbies involved in the Spain’s Water Policy are being very active (Llamas,
    2001b).The “Fundación Nueva Cultura del Agua”, incorporated about five years ago
    and mainly formed by University professors, has also loaded a copy of the TRSNHP
    in its Website and has announced an open debate –through a videoconference– to be
    held on March 13, 2003. As a preparation for this debate, the concerned persons are
    asked to send their opinion on the topic in a short written note. What follows is my

    4. Scope and aim

  According to a personal comment of one of the authors of the TRSNHP, the amount received by US
team has been significantly smaller.
Given the logical limit of the size of this note, I am going to mainly deal with
groundwater resources aspects that are more related to my expertise and/or are
more crucial or radical in order to understand and solve the current social conflict.
Therefore, I will firstly emphasize on some general considerations about the whole
TRSNHP. Secondly I will highlight several gaps of the TRSNHP in relation to the
current chaos in the legal, administrative, and institutional groundwater management
in the Segura basin. This chaos has been the basic and radical cause of the approved
Ebro river water diversion; if this chaos is not corrected even before proceeding to
design the large necessary infrastructures, the whole project will be a failure that
will be mainly paid with the Spanish tax-payers money. The story of the last
decades shows the persistent reluctance of groundwater users in the area to comply
with the existing regulations and also the serious neglect by the Segura basin
Authority to enforce the regulation. It is not logic to think that, when the large
aqueduct be constructed, they both will change their attitude. These relevant issues
are not practically commented in the TRSNHP.


5. General considerations

The terms of reference for the TRSNHP contract are not included in the delivered
report. Therefore, some failures or weaknesses mentioned hereafter may be due to
the fact that the two co-leaders of the report decided to deal only with those aspects
required by the contractor (FUPC), mainly using the information provided by the

First general consideration – Differences between the Appendices and the General

One shocking aspect of the TRSNHP is the differences between Executive summary
and the Conclusion of the report and the text of section 4.1.5 and the Appendix C
(Economics) and also, to a certain extent, Appendix D (Water Resources). This
issue has been also emphasized by other Spanish experts in their comments on the
In general, the main text of the report and of its executive summary clearly approves
the construction of the large hydraulic infrastructures for the Ebro river diversion,
what was obviously the goal of the contractor. The TRSNHP also recommends
creating soon some kind of public institution to improve the quality of the Ebro river
and of the wetlands of the Spanish Mediterranean Region. Nevertheless, practically
no data are given about the budget to perform such improvements in the Ebro river
quality and in the Mediterranean wetlands which are not neither identified nor
quantified in the TRSNHP. On the other hand, both recommendations will become a
must if the EU Water Framework Directive is really implemented. Consequently, it
will be very easy for the Ministry of the Environment to approve this TRSNHP
suggestion but to delay its implementation “ad calendas graecas”.

I do not mean that wetlands do not constitute a really important issue. As a matter of
fact, I am the leader of a research project on “conflicts between groundwater
development and wetlands conservation”. The Marcelino Botin Foundation and
Mundi-Prensa have published three books on this topic in 2002 and 2003. One of
these three books (Fornés and Llamas, 2003) is devoted to the analysis of the
problems in the Spanish Mediterranean wetlands. Also our team has been the
promoter of the Resolution VIII.40 on the same topic in the last RAMSAR
convention (Valencia, November 2002).

Second general consideration. Biased information to the US Team

In the TRSNHP the inclusion of the lists of the experts or stakeholders interviewed
on the different issues is missed. Also the bibliography mentioned seems rather
biased in some aspects, or at least incomplete. I understand the US Technical Team
was in Spain only about one week and, logically, the contractor supplied to them the
bulk of the information. It seems probable that a good number of papers that were
not favorable to the Ebro river diversion were not made available to the US team. In
any case they are not mentioned in the report. For example, the book edited by
Arrojo (2001) or the Analysis of the SNHP done by a group of experts for the
“Fundación Nueva Cultura del Agua” are not mentioned. This report is in the
Website of this Foundation since the beginning of 2002. The preprint of the paper
by Llamas(2003) was made available to the U:S: Team.

On the contrary, information supplied to the US Team has been denied to the
Spaniards. For instance, in the TRSNHP (Water Resources Bibliography) it is
mentioned a “Sustainability of Groundwater Use, Internal Report”. I have written
several times to the “Dirección General de Obras Hidráulicas” asking for a copy of
such internal report and up today (March 10, 2003) I have got no answer.

6. Specific considerations

6.1. Uncritical acceptance of the supposed water demands that are the main cause of
the Ebro River

The US Team accepts as a sure the supposed differences between the water
resources and the water demands. Perhaps this was an implicit or explicit term of
reference in the agreement with FUPC. However, it is surprising that only Prof.
Hanemann in his Appendix C and in the section 4.1.5 seems to recommend
analyzing this issue mainly from the economic point of view. Nevertheless, the
really important Hanemann’s observations (they are rather objections) are not
practically taken into account neither in the Executive Summary nor in the main text
of the report.

It is really surprising that the US Team accepts without any criticism that the
transfer of water is a need to avoid that 42,000 hectares may become lost for Spain’s
irrigated agriculture. Nevertheless, even if it is assumed that such projection is
realistic, the US Team does not question if this loss is really a serious socio-
economic problem. The assumed lost surface is less that 1.5% of the total irrigated
surface in Spain (3.5 million hectares). Is it worth while to create such national
conflict and to spend probably about 10,000 million euros for such potential loss of
irrigated surface?
. The Regional Government of Catalonia has indicated that they do not want the
Ebro River Diversion. The large diversion of water to Valencia was not included in
the Jucar basin that was approved in 1998.
6.2. Silence about the past, present and future groundwater mismanagement in the
Segura Basin.

In my opinion, this is one of the most crucial aspects of the whole conflict and one
serious gap in the TRSNHP. Several Spanish authors have written many times
during the last years, that the legal and administrative chaos in groundwater
management in the Segura basin has been the main cause of the current real or
exaggerated problems in this area (see Samper and Llamas, 1999; Llamas, 2001a;
Llamas, 2003; Llamas et al., 2001; Iribar et al., 2001; Hernández-Mora et al., 2001;
López-Gunn and Llamas, 2001).
Moreover, if this mismanagement is not corrected the expectancy of the arrival of
the Ebro River water to the Segura Basin is not going to solve the current problems
but to create even more serious problems.

The recent (20–30 years old) history of the water resources policy in the Segura
basin shows that groundwater users has had a long tradition of transgressing the
regulations (see Llamas and Pérez Picazo, 2001). According to a press release of the
Trade Union ComisionesObreras (see El Faro, 2001, 20 December 2002, page 15)
the traditional negligence of the Segura basin Water Authority causes that claims,
sanctions.and fines related to illegal pumping and water well drilling are practically
. As a matter of fact, the available official data on groundwater in the Segura basin
are traditionally confuse (see Llamas et al, 2001, pp 197-200)

In my opinion, the only way to correct the current chaos is to stop any action on the
Ebro water transfer until there is a strong evidence that the behavior of the
groundwater users of the region has clearly and steadily changed. In the TRSNHP,
Dracup mentions mildly this topic in his Appendix D. He states that it will be
necessary to be sure that the provisions 17 and 18 in the SNHP Law are
accomplished. In my opinion, this accomplishment of the regulation must not be
deferred to the completion of the aqueduct (see also Llamas, 2002).

Hanemann in his Appendix C comments what has recently happened in the Central
Arizona Project in the USA. In this State those farmers that are users of groundwater
signed the corresponding contracts before the large infrastructures was completed.
They apparently showed a “willingness to pay”. The experience has shown that it
was rather a “willingness to play”.

In our case, it is still worse. Nobody seems to require that a contract between the
Central government and the future Ebro Water Users (farmers, regional
governments, cities and others) has to be signed before beginning the design or the
construction of this large hydraulic infrastructure. This is really a hoax to the
Spanish taxpayers. It is also against the European Water Framework Directive that
strongly recommends the principle of the “full cost recovery”.

7. Conclusions

The supposed “overexploitation” of some aquifers has been the driving force to
justify the Ebro river diversion. However, the TRSNHP does not pay adequate
attention to the analysis of groundwater situation and management in the Segura
basin.. Apparently, the main reference is an internal report of the Ministry for the
Environment. The access to this report has not been possible to this author. Since
several decades, the situation in groundwater management in the Segura basin can
be defined as a technical, legal, administrative, and institutional chaos. There is no
evidence that the attitude of the groundwater users and of the Segura Water
Authority has changed. Therefore, it is a hoax to continue the detailed design of this
huge infrastructure until there is a solid evidence of the necessary change.

The TRSNHP includes some good recommendations, mainly about future actions to
improve the Ebro River quality and the health of the Spanish Mediterranean
wetlands. However, these recommendations are not accompanied by adequate
analysis of their economic feasibility. On the other hand, these actions are already
required by the Water Framework Directive of the European Union.
The TRSNHP considers that the Ebro River transfer is feasible from the
hydrological and ecological point of view. This feasibility is strongly questioned by
several Spanish scholars (?). However, the TRSNHP conclusions and executive
summary seem to ignore the significant failures in the economic analysis of the
Plan. These failures are mentioned mainly in Section 4.1.5 and in the Appendix C.
These gaps are so relevant that the whole project needs a new assessment, before
initiating its detailed design and its construction.

The TRSNHP admits as a premise the supposed water deficit and future demand in
the regions to receive the Ebro river water and practically does not analyze this
important aspect. This failure may not be the direct responsibility of the US Team
but an imposition of the terms of reference of the corresponding contract. In any
case, this fact makes that the conclusion of the TRSNHP approving the Ebro River
Water Diversion is not acceptable because it is based on an assumption on water
demands that most Spanish experts do not consider realistic

Fifth and most important
The TRSNHP does not pay an acceptable attention to the problem of groundwater
situation in the Segura Basin from the hydrological, ecological, legal, administrative
and political point of view.


Arrojo, P.(ed.) (2001) “El Plan Hidrológico Nacional a Debate”. Editorial Bakeaz,
Fornés, J. and Llamas, M.R. (eds.) (2003) “Conflictos entre el desarrollo de aguas
        subterráneas y la conservacion de humedales”. Fundación M.Botín y Mundi-
        Prensa. Madrid. 380 pp.
Hernández-Mora, N.; Llamas, M.R. and Martínez, L. (2001) “Misconceptions in
        aquifer over-exploitation. Implication for Water Policy in Southern Europe”
        in Agricultural Use of Groundwater (ed. C. Dosi). Kluwer Academic
        Publishers. Pp.: 107–125.
Iribar,V., Grima, J. Y Sanchez-Vila, X.(eds) (2001) “Las aguas subterráneas en el
        Plan Hidrológico Nacional”. Asociacion Internacional de Hidrogeólogos-
        Grupo Español y Mundi-Prensa. Madrid. 127 pp.
Llamas, M.R. (2000) “Del uso y del abuso del agua en España” en Horizontes
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Llamas, M.R. (2001a) “Comentarios para la Comisión de Medio Ambiente del
      Congreso de los Diputados sobre el Plan Hidrológico Nacional”, en Arrojo
      (ed.). Pp.: 269-285.
Llamas, M.R. (2001b) “Incertidumbre e ignorancia, marco institucional e intereses
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Llamas, M.R. (2002) “Las aguas subterráeas bajo la nueva Directiva Marco”, en
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Llamas, M.R. (2003) “Lessons learntfrom the Impact of the Neglected Role of
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      (eds). Elesevier Science, Amsterdam, The Netherlands (in press)
Llamas, M.R. and Pérez Picazo, M.T. (2001) “The Segura catchment and the debate
      on hydrosolidarity”, Proceedings of the 2001 Seminar of the Stockholm
      International Water Institute, Report no. 13: 99–105.
Llamas, M.R.; Fornés, J.M.; Hernández-Mora, N. y Martínez, L. (2001) “Aguas
      subterráneas: retos y oportunidades”. Fundación Marcelino Botín y Mundi-
      Prensa, Madrid. 529 pp. ISBN 84-7114-962-1.
López-Gunn, E. and Llamas, M.R. (2000) “New and Old Paradigms in Spain’s
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Samper, J. and Llamas, M.R. (ed.) (1999) “Actas de las Jornadas sobre las Aguas
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