COMMENTS ON GROUNDWATER ISSUES IN “A TECHNICAL REVIEW OF SPANISH NATIONAL HYDROLOGICAL PLAN. EBRO RIVER OUT-OF-BASIN DIVERSION” (TRSNHP) 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 e-mail: email@example.com Contents 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 españoles. 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 opinion. 4. Scope and aim 1 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 same. First general consideration – Differences between the Appendices and the General Report 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 TRSNHP. 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 First 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. Second 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. Third 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. Fourth 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. Bibliography Arrojo, P.(ed.) (2001) “El Plan Hidrológico Nacional a Debate”. Editorial Bakeaz, Bilbao. 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 Culturales. Los Frutos de la Ciencia. Real Academia de Ciencias y Espasa Calpe. Madrid. Pp. 11-24. 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 creados en la política del agua española”, en “Toma de decisiones XXX”. Pp.: 269-285. Llamas, M.R. (2002) “Las aguas subterráeas bajo la nueva Directiva Marco”, en Gestion y Control del Agua frente a la Directriva Marco, Herráez (ed.). Universidad Autónoma de Madrid y Canal de Isabel II. Madrid. Pp.: 15–24. Llamas, M.R. (2003) “Lessons learntfrom the Impact of the Neglected Role of Groundwater in Spain’s Water Policy” in Water Resources Perspectives:Evaluation, Management and Policy. Alsharhan and Wood (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 Water Policy” in Water Security in the Third Millenium. Mediterranean countries towards a Regional Vision”. UNESCO Science for Peace Series. Vol. 9: 271–293. Samper, J. and Llamas, M.R. (ed.) (1999) “Actas de las Jornadas sobre las Aguas Subterráneas en el Libro Blanco del Agua”. Asociación International de Hidrogeólogos-Grupo Español. ISBN 84-920529-5-3.