WWF Opposition to 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
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
Failure to take into consideration the results of climate change, such as loss
of existing water resources over time and further deterioration of the already
poor water quality from the donor river (in the case of the Ebro transfer), 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 (i.e.. 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
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
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. (e.g. 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.
ACTIONS FOR A SUSTAINABLE WATER MANAGEMENT PLAN ACROSS SPAIN
ACTIONS IN SPAIN
• Elaborate an independent Environmental Impact Assessment
for the whole plan in order to have a non-biased report on the environmental
• 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
• Revise the SNHP ensuring full transparency and proper
public participation in the development of alternative water management
• 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
ACTIONS AT THE EU INSTITUTIONAL LEVEL
• 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
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.