WG Economics Document n°1 Assessment of environmental and resource costs for supporting the implementation of the Water Framework Directive Building on experiences from the Netherlands, France and Spain Date 14/07/2014 Document status Draft This “share of experience” document aims at illustrating how environmental and resource costs can be assessed for supporting the implementation of the European Union (EU) Water Framework Directive (WFD). It complements the earlier Information Sheet on the “Assessment of Environmental and Resource Costs in the Water Framework Directive” prepared by the Drafting Group ECO2 of Working Group 2B of the Common Implementation Strategy (CIS) and finalised in June 2004. This document presents in particular the experiences carried out by three Member States (MS): The combined assessment in the Netherlands of historical environmental and resource costs already internalised in drinking water and waste water services; The assessment of environmental costs carried out in France in the context of the second WFD management cycle; The separate assessments of environmental costs and resource costs performed by Spain for the Guadiana River and presented in the River Basin Management Plan. Overall, the assessments of environmental costs carried out by the three countries focus on costs, be it costs of measures proposed for reducing existing pressures on the aquatic environment or costs of measures already taken and internalised into payments (fees/bills) of users of concerned water services. It is expected that these illustrations can help other MS to develop and apply adequate methodologies for assessing environmental & resource costs in the context of their second WFD river basin management cycle. 1 Contents 1. Background ..................................................................................................................... 3 2. Assessing Environmental & Resource Costs – A reminder ........................................ 6 5. Illustration 1 - Assessing (combined) historical environmental & resource costs in the Netherlands........................................................................................................................... 11 6. Illustration 2 - Assessing environmental costs in the context of the second river basin management cycle in France ................................................................................................ 13 7. Illustration 3 - Assessing environmental and resource costs in the Guadiana River Basin in Spain....................................................................................................................... 21 8. In conclusion: guiding the assessment of Environmental & Resource Costs in the context of the WFD implementation .................................................................................... 27 2 1. Background1 The European Union (EU) Water Framework Directive (WFD) has strengthened the role of economic methods and tools for supporting water management decisions in Europe. The WFD promotes a more systematic application of economic methods for supporting water management decisions, such as cost-effectiveness or cost-benefit analyses. It also promotes water pricing that: ensures a sound and transparent recovery of the costs of water services (both financial and environmental & resource costs); and provides an incentive for more efficient water use. In this way, water pricing may contribute to the achievement of the environmental objectives of the WFD (good water status for all waters) and the sustainable use of water. While guidance on the assessment of financial costs and financial cost recovery for water services is rather straightforward, the assessment of environmental and resource costs is more challenging. Key issues linked to the assessment of environmental and resource costs range from the very definition of these costs (individually or combined), the different methods that can be applied for this assessment or the relevance of individual methods for supporting specific water management decisions (e.g. for illustrating the relative importance of these costs or supporting the design of economic instruments for internalising these costs). This challenge was recognised at the onset, the assessment of environmental and resource costs being a key issue addressed in the WATECO guidance and its annexes adopted in 2002 in the context of the WFD Common Implementation Strategy (CIS) 2 . The clarifications provided by the WATECO guidance was, however, felt not sufficient. And complementary efforts were made to provide additional guidance: in particular, an Information Sheet dedicated to the “Assessment of Environmental and Resource Costs in the Water Framework Directive” was prepared by the Drafting Group ECO2 of Working Group 2B of the CIS and finalised in June 20043, following the organisation of a dedicated workshop on this topic in March 2004 4. This Information Sheet stresses in particular the two main methods that can be used for assessing these costs, namely: The cost-based approach that is based on the determination of the cost of measures to protect (or to prevent damage to) the environment. The environmental costs calculated are often used as a proxy for environmental damage; The benefit-based approach which focuses on the determination of the loss of potential benefits from the damage caused by the unsustainable use of water (i.e. the benefits that could be expected if water would be used sustainably and the environmental objectives of the WFD achieved). These approaches build on “stated-preference” techniques that help assessing individuals’ Willingness to Pay and Willingness to Accept. Ten years later, the assessment of environmental and resource costs is still considered challenging by many MS. MS have applied a variety of approaches for performing the assessment of environmental & resource costs, ranging from a qualitative description of these costs, the analysis of current environmental taxes and charges expected to internalise (partly) these costs or the assessment of costs of measures already taken for reducing (past) pollution and pressures. While they are clearly complementary, these different approaches do not address the same components of the wider “environmental and resource costs” issue, as illustrated in the figure presented below. 1 This general section has been developed by Gloria de Paoli and Pierre Strosser (ACTeon) in the context of their support to DG Environment to the activities of the Workingn Group (WG) Economics of the Common Implementation Strategy (CIS). For more information on the activities of the Economics WG, to contact: Lukasz Latala, DG Environment, at [email protected]. 2 http://ec.europa.eu/environment/water/water-framework/economics/pdf/Guidance%201%20-%20Economics%20%20WATECO.pdf 3https://circabc.europa.eu/sd/a/5337253e-6f26-4d25-84f4-34b2184f22cf/Final%20version%2005-07-04.pdf 4 Environmental and Resource Costs and the Water Framework Directive An overview of European practices Workshop Proceedings. Editors Roy Brouwer and Pierre Strosser. RIZA Working Paper 2004.112x. (http://publicaties.minienm.nl/download-bijlage/14703/2004-112x.pdf) 3 Figure 1. Linking measures, water status and ERC (assessments) The aim of the document at hand to share the experiences of selected MS more widely to support MS with the application of assessments in the context of the second WFD river basin management cycle. The present document builds on three illustrations: The illustration of the cost-based approach for the combined assessment of historical environmental and resource costs in the Netherlands. However, as these costs are already internalized through existing pricing mechanisms, these costs are to be considered as financial costs in the context of the WFD cost-recovery assessment5; The assessment of current environmental costs carried out in France in the context of the second WFD management cycle, building also on cost-based approaches; The separate assessments of environmental costs and of resource costs performed by Spain for the Guadiana river basin, using in particular prices of land and water transactions for capturing resource costs. The salient features of the three illustrations are presented in the following summary table. 5 See also the definitions of ERCs and related clarifications in chapter 2 of this document. 4 Table 1. Key features of illustrations presented in this report Issues The Netherlands France Spain Cost type considered Combined historical environmental & resource costs already internalised/recovered in tariffs for water services Current environmental costs (costs not yet internalised), distinguishing “costs imposed on other water users” (named “compensatory costs”) as a separate category Current Environmental (not yet internalised) costs & resource costs, cost types assessed separately Scale of the assessment National Methodology applied Cost-based method using information on current water service costs (including self-services) Combination of illustrations from different French river basin districts Assessment of current environmental costs based on estimates of the costs of the full programme of measures required for achieving good water status “Compensatory costs” assessed on the basis of current costs of remediation and mitigation actions taken by users negatively impacted by the current state of the aquatic environment Guadiana river basin For environmental costs: based on estimates of the costs of measures required for achieving good water status Resource costs: based on the price of water/irrigated land in existing water/land market transactions The document is structured as follows: Chapter 2 summarises the main methodological issues and options that are presented in existing guidance, in particular in the Information Sheet dedicated to the “Assessment of Environmental and Resource Costs in the Water Framework Directive” prepared by the Drafting Group ECO2 of Working Group 2B of the CIS. As MS have mostly applied the costbased approach, chapter 2 will focus on illustrating the cost-based approach; Chapter 3, 4 & 5 presents the three illustrations developed for the Netherlands, France and Spain, respectively; In conclusion, Chapter 6 proposes a series of recommendations to guide the assessment of the recovery of ERC to be carried out by MS in the context of the second and third RBMPs. 5 2. Assessing Environmental & Resource Costs – A reminder6 1. Environmental and Resource Costs in the Water Framework Directive According to Article 9 of the WFD, “Member States shall take account of the principle of recovery of the costs of water services, including environmental and resource costs”. However, although the term explicitely recurs in Article 9 only, ERCs are also implicitely involved in other WFD obligations, as illustrated in Box 1 below7. Box 1 – The role of Environmental and Resource costs in WFD implementation Environmental and resource costs come into play in different Articles of the WFD Article 9: take account of the cost recovery of water services, including environmental and resource costs. Article 9: Member States shall ensure by 2010 that water pricing policies provide adequate incentives for water users to use water resources efficiently, and thereby contribute to the environmental objectives of this Directive. Annex III and Article 11: make judgments about the most cost-effective combination of measures in respect of water uses to be included in the programme of measures. Article 4: possible economic justification for derogation (including designation of water body status): Objectives derogation if the achievement of these objectives would be disproportionately expensive. Derogation for new modification or sustainable economic activity, if benefits of this activity outweigh benefits from good water status. In other words, the assessment of ERCs plays a role in: The assessment of cost recovery of water services. Assessing the total costs, including ERCs, and the way such costs are paid for by the different users, allows for assessing: (i) the extent to which the Polluter Pays Principle applies; and (ii) to what extent ERCs are already internalized through existing pricing mechanisms; Providing an incentive for a more efficient water use, by internalizing such costs in the pricing mechanisms, Selecting a cost-effective Programme of Measures, by providing a signal of how, and to what extent, existing and new environmental targets are met, or not and what the associated costs are; In the cost-benefits analysis, where the costs of measures are compared to damage and opportunity costs avoided or, in other words, the avoided environmental and resource costs. 2. How to define ERCs? Even though the WFD explicitely mentions environmental and resource costs, it does not provide a clear definition of such costs. This gap was then filled by the WATECO Guidance (2003) 8, which provided the definitions highlighted in Box 2 below. Box 2 – Environmental and Resource Costs: definitions in the WATECO Guidance Environmental Costs: 6 Thiscosts section has been developed basedon onthe the earlier contributions from Rob vander Veeren, economist at athe “The of damage that water uses impose environment and ecosystem and those who use the environment (e.g. Ministry of Transport & Water Management, The Netherlands. reduction in the ecological quality of aquatic ecosystems or the salinisation and degradation of productive soils)”. 7 As also illustrated in Assessment of Environmental and Resource Costs in the Water Framework Directive: Resource Costs: Information sheet prepared by Drafting Group ECO2 Common Implementation Strategy, Working Group 2B, June 2004. “The costs of foregone opportunities which other uses suffer due to the depletion of the resource beyond its natural rate of 8 WATECO Guidance (2003), Glossary, pages 69 & recharge or recovery (e.g. linked to the over-abstraction of 72 groundwater)”. 6 However, in order to be operational, these definitions needed to be further developed, and this was done in the Information Sheet developed in 2004 9. First of all, the concepts of environmental and resource costs must be further clarified, as follows: Environmental costs: a distinction can be made between damage costs to the environment and to those who use the water environment. The costs of environmental damage refer to non-use values attached to healthy functioning aquatic ecosystems, whereas the costs to those who use the water environment refer, conversely, to the corresponding use values 10; Resource costs: these costs only arise if alternative water uses generate a higher economic value than present or foreseen future water use. This could occur foe a variety of reasons, including institutional ones (e.g. current or future distribution of pollution permits). Thus, in contrast with the definition in the WATECO Guidance, resource costs do not only occur in case of water resource depletion, but they can arise as a result of an inefficient allocation of water and/or pollution, when alternative water uses would generate a higher net economic value. There is obviously a strong link between environmental costs and environmental damage, so that assessing these costs require a thorough knowledge on the physical status of the water system, the pressures exerted on the system and the related damage. In general, the extent of the damage depends upon the difference between some reference and target situation. In the context of WFD implementaiton, the reference status would be the expected status of a water body in 2021, whereas the target status would be the good ecological status in 2021: the environmental costs will be determined by the difference between expected and good status. This example bring us to another key distinction that needs to be made when assessing environmental and resource costs: the difference between internal and external ERCs. In the above example, internal and external ERCs can be distinguished as illustrated in the figure below. Current status Expected status in 2021 Environmental costs internalized through PoM implementation Good status External environmental costs Figure 2. Internal and external environmental costs in WFD implementation In the context of WFD implementation and cost recovery, the actual costs of activities and measures, which prevent and mitigate potential damage to the water environment and to other water uses, must be regarded as internal environmental protection costs. Ideally, in accordance to the Polluter Pays Principle, these costs are distributed among user groups on the basis of user groups’ contribution to the environmental damage. Internal environmental protection costs can be considered as financial costs –as these are the actual costs incurred for implementing measures and activities. Thus, what we are interested in are the external environmental and resource costs. 9 Assessment of Environmental and Resource Costs in the Water Framework Directive: Information sheet prepared by Drafting Group ECO2 Common Implementation Strategy, Working Group 2B, June 2004. 10 This is in line with –and further clarifies- the distinction made in the WATECO Guidance between use and nonuse values 7 3. The assessment of Environmental Costs: the cost-based approach11 As previously mentioned, two main, non-mutually exclusive approaches are available to assess environmental and resource costs: the cost-based and the benefit-based approaches. The costbased approach is the most widely applied methodology so far and, for this reason, this paper only focuses on this approach. The flow-chart below illustrates the main steps of the cost revcovery assessment, which includes the assessment of ERCs, and namely: Environmental (impact) assessment to qualify and quantify the environmental damage involved: this step requires the identification of pressures and impacts on water bodies; Economic assessment of internalized costs: which measures are in place to tackle the environmental damage? What are the costs of these measures? And who pays for such costs? The costs that are imposed on polluters or beneficiaries of environmental services are defined as internal environmental costs; in contrast, the costs posed on other water users, including the environment, are considered external environmental costs. The assessment of these costs is required in the context of cost-recovery assessment and how costs of existing or planned measures are internalized through existing or planned pricing and financing mechanisms. As these costs are already internalized through existing or planned measures, are financial costs (as previously mentioned); Economic assessment of the residual damage, or external environmental protection costs: the costs of this residual damage are in fact the environmental costs which need to be assessed. According to the cost-based approach, outlined in the flow chart, the environmental protection costs are used as a proxy for the environmental (damage) costs. As previously mentioned, when existing or planned measures are sufficient to reach good ecological status by 2021, there are no environmental (damage) costs. However, for several reasons (e.g. technical reasons) existing or planned measures might not be sufficient to reach GES by 2021, and such measures are rather aimed at reaching a lower target status. In this case, the environmental damage is the difference between the target status and GES, and the related environmental costs are the costs of the additional measures which would be needed to reach GES. 11 Text based upon Assessment of Environmental and Resource Costs in the Water Framework Directive: Information sheet prepared by Drafting Group ECO2 Common Implementation Strategy, Working Group 2B, June 2004. 8 Cost-based approach Figure 3. Assessing environmental costs with the cost-based approach12 Thus, one of the basic requirements of the cost-based approach is the establishment of proper reference and target situations. In the context of WFD implementation, it makes sense to establish that: reaching GES by 2021 is the reference situation; and the actual expected objective in terms of ecological status for a specific water body by 2021 is the target situation. 4. Assessing resource costs At present, there is no specific guidance on the assessment of resource cost. The WATECO Guidance illustrates potential methods for performing resource costs assessment, as reported in Box 3 below13. It specifies that further development are required in this field. 12 Adapted figure from Assessment of Environmental and Resource Costs in the Water Framework Directive: Information sheet prepared by Drafting Group ECO2 Common Implementation Strategy, Working Group 2B, June 2004. 13 WATECO Guidance, page 122. 9 Box 3 – Example of resource cost assessment from the WATECO Guidance Two users (City A and City B) are competing for the use of the same water. It is possible to estimate the demand curve for each of them; If there is sufficient water available to satisfy both demands, there is no scarcity and the resource cost of water is zero; Suppose that due to poor rainfall in a given season, there is only a limited amount of water available (supply with scarcity). Due to this scarcity, there will be a resource cost, which can be calculated by finding the price for which total demand is exactly to the supply with scarcity. The difference between that price and the normal price is the resource cost, as shown in the Figure below. 10 5. Illustration 1 - Assessing (combined) historical environmental & resource costs in the Netherlands14 1. The practical application of the cost based approach For the Netherlands, two considerations played an important role for choosing the cost based approach: 1) data availability and (2) the reliability and accuracy of the available data. Data on current abatement costs are largely available; at least more readily available than numbers on ‘lost benefits of not being in a sustainable situation.’ Secondly, policy and decision-makers require reliable and accurate estimates in different phases of the implementation of the WFD. On top of that, the costbased approach connects to the WFD required efficient price incentives as well as the WFD required cost-effectiveness of the programme of measures and has the important advantage of being pragmatic and traceable. The calculation of environmental costs for the 2004 reporting requirements was based on available data about environmental costs related to water from Statistics Netherlands. Statistics Netherlands calculates these costs based on national guidelines which are in line with the international environmental cost accounting guidelines provided by the OECD and Eurostat for environmental protection measures. Recently, based on data from Statistics Netherlands, the same approach was applied to provide an update of the costs recovery of water services15, including the calculation of environmental costs (Sterk Consulting and Bureau Buiten, 2013)16. The above approach connects to the WFD required efficient price incentives as well as the WFD required cost-effectiveness of the programme of measures and has the important advantage of being pragmatic and traceable, and moreover, the required information is largely available. 2. Example: assessing historical environmental and resource costs related to waste water treatment costs The water service ‘waste water treatment’ can be seen as the implementation of measures with the sole purpose to reduce damage to the (aquatic) environment up to the level of existing water quality. Therefore, all costs for wastewater treatment are seen as environmental and resource costs. And, since we have 100% cost recovery for our water services, these environmental and resource costs are internalized and recovered completely. 14 This illustration has been prepared by Rob vander Veeren, economist at the Ministry of Transport & Water Management, The Netherlands. For more information on this illustration and on the Dutch experience in the application of economics methods and tools for supporting water management, to contact: [email protected]. 15 Statistics Netherlands (2014), Economische beschrijving KRW deelstroomgebieden 2005, 2008, 2010, 2011, Den Haag, 2014. http://www.cbs.nl/NR/rdonlyres/27926896-8A38-4152-9DD621DDF6857F78/0/2014econbeschrijvingKRWstroomgebiedenpub.pdf http://www.helpdeskwater.nl/publish/pages/32460/namwa_stroomgebieden_definitief_rapport_1_maart_2014.pd f 16 See: http://www.helpdeskwater.nl/publish/pages/32460/kostenterugwinning_van_waterdiensten_2013_eindrapport.pd f 11 Table 2. Total revenues and costs for waste water treatment in 2012* Actors Revenues (million €) Regional water authorities 1.284 Self services - Industry 266 - Agriculture 66 - Households 21 Total 1.637 *Costs self services industry 2011 figures Source: Sterk Consulting and Bureau Buiten (2013). Costs (million €) Cost recovery percentage 1.292 99% 266 66 21 1.645 100% 100% 100% 100% The costs included are investment costs (depreciation and interest) and operation and maintenance costs (including labour etc). The regional water authorities who are responsible for public wastewater treatment in the Netherlands have to make sure that they balance their budgets, since they are allowed to make neither profits nor losses. So they are keen on making sure they recover their total costs completely. Therefore, cost recovery rates are 100%, with annual fluctuations caused by the fact that the levies charged are based on estimations at the beginning of the year, which often differ (only slightly) from the actual costs incurred during the year (in the example above, this difference is 1%). The revenues are secured by means of an earmarked levy, that has to be paid by all users of the water service, and of which the revenues are only allowed to be spent for the purpose the money is collected for (i.e. wastewater treatment). Also for self-services, cost recovery rates are 100% by definition, since, if large companies want to operate wastewater treatment plants themselves, they have to pay for it themselves (same applies to individual treatment facilities operated by agriculture and private households). Sources: Hueting, R. (1974), new scarcity and economic growth: more welfare through less production? http://www.managementissues.com/media/new_scarcity_and_economic_growth_hueting.pdf Sterk Consulting en Bureau Buiten (2013), Kostenterugwinning van waterdiensten 2013, Leiden, december 2013. http://www.helpdeskwater.nl/publish/pages/32460/kostenterugwinning_van_waterdiensten_20 13_eindrapport.pdf Statistics Netherlands (2014), Economische beschrijving KRW deelstroomgebieden 2005, 2008, 2010, 2011, Den Haag, 2014. http://www.helpdeskwater.nl/publish/pages/32460/namwa_stroomgebieden_definitief_rapport_ 1_maart_2014.pdf 12 6. Illustration 2 - Assessing environmental costs in the context of the second river basin management cycle in France17 1 Introduction In the framework of the cost-recovery assessment required under Article 9 of the Water Framework Directive (WFD), there is a need to assess environmental costs. Environmental costs are damages caused by various water uses to the environment, ecosystems and people using water as a resource for their activity. However, environmental costs cannot be measured accurately and thus can only be estimated. In France, environmental costs were estimated through two complementary methodologies. On the one hand, the costs of damages caused to the environment and ecosystems were estimated by the costs of maintaining or restoring good water status, i.e. the overall cost of the programme of measures (PoM). On the other hand, as damages to the environment may affect other activities, externalities borne by water users, in the form of additional expenditures, were also estimated. These particular costs were named ‘compensatory costs’. 2 Damages to the environment and ecosystems costs assessment Based on the assumption that once good water status (as defined by the WFD) is reached, no more damages affect aquatic ecosystems and water resources, the costs of damages can be well approximated by the cost of reaching good status. Thus, France decided for the WFD 2 nd cycle to approximate environmental costs by the total costs of the programme of measures necessary to reach good status by 2027. The cost obtained is an indicator of the overall effort remaining to achieve good status for all waters. Approximating environmental costs by the total costs of what remains to be implemented also supports awareness raising. This indicator appeared as a good way to communicate the idea of environmental costs to basin authorities, since it is very concrete and realistic. When data are available, the costs of pollutions / disturbances should also be assessed and explained (i.e. who causes them, who pays for them and which ones could be avoided if preventive policies were implemented). The following methodology was used. In the framework of costs recovery, ‘compressible’ environmental costs should be assessed (that is to say costs that can be offset by actions thus planned in the programme of measures up to 2027). ‘Incompressible’ environmental costs (i.e. in the case of water bodies where the aim is not good status (good potential or less stringent objective)) are not considered in the calculation as these are considered indirectly in the HMWB designation and less stringent objectives analyses. The main difficulty thus consists in determining all the measures required for achieving good status for all waters by 2027. However, this methodology has limitations. One has to keep in mind that caculating environmental costs through the cost of the programme of measures remains an approximation. Moreover, this indicator should not be compared with the costs actually implemented and should not be used as a tool for monitoring the implementation of the programme of measures proposed under the second planning process. As knowledge improves every day, quality objectives may indeed change and new costs sources may be identified. Consequently, the base for evaluating environmental costs is not steady over time. In particular, if assessed through this methodology, the weight of environmental costs may remain the same while many investments are done. 17 This illustration has been prepared by Blandine Boeuf, water economist at the Ministry of Ecology, France. For more information on this illustration and on the French experience in the application of economics methods and tools for supporting water management, to contact: [email protected]. 13 Example of the Seine-Normandy basin Environmental costs due to the industry Environmental costs may be approximated by calculating the costs of actions undertaken to restore the environment and necessary to highly reduce current pollutions. The cost of reduction, or even cessation, of classical industrial pollutions was estimated at 55 million euros per year for industries’ own infrastructures and at 40 million euros per year for industries contribution to the restoration of local authorities sewage treatment plants. Overall, total estimates amount to 95 million euros per year on average for the Seine-Normandy river basin. Calculating the costs of the Programme of Measures : Example of water abstraction Programme of Measures evaluation Thanks to the analysis of the river basin characteristics, pressures on water bodies were identified. A list of possible measures per type of pressure was elaborated at the national scale. Thanks to the water agencies “cost databases, unit costs were calculated for each measure. Once the local basin authorities had defined the relevant measures and the base to apply them (building in particular on the Article 5 assessment and local knowledge), the cost of measures for a specific location/water body and a specific pressure could be calculated. Example of water abstraction For example, the pressure ‘water abstraction’ could be identified for several water bodies. Local authorities could then select the measure ‘water storage’ among the list of possible measures to reduce abstractions if this measure was seen as the most relevant measure for the specific conditions of the water body. If the total capacity of the water storage measure would be estimated at 100 000 cubic meters, total costs of the measure would be 450 000 € since the average unit costs for water storage was estimated at 4,5 euros per cubic meter. Example of the Seine-Normandy basin Environmental costs due to households Environmental costs due to households may be estimated by the treatment costs of the whole point source pollution generated by households (including the building of treatment plants or any other works necessary to treat these pollutions). From of financial perspective, the efforts remaining in order to treat point source pollution are estimated around 670 million euros per year for households. This includes an estimation of the annual depreciation of the investments to realise in order to treat all the point source pollutions (treatment plants, networks...). Environmental costs due to the industry Environmental costs due to the industry may be approximated by calculating the costs of actions undertaken to restore the environment and necessary to highly reduce current industrial pollutions. The cost of reduction, or even cessation, of classical industrial pollutions was estimated at 55 million euros per year for industries’ own infrastructures and at 40 million euros per year for industries contribution to the restoration of local authorities sewage treatment plants. Overall, total estimates amount to 95 million euros per year on average for the Seine-Normandy river basin. Environmental costs due to agriculture The total amount of measures which would be necessary to undertake in order to completely suppress diffuse pollution from agriculture was estimated at 1,6 billion euros per year in the river basin Seine-Normandy. Therefore, it can be considered that environmental costs due to agriculture are around 1,6 billion euros. Example of the Rhone-Mediterranean Basin Based on extrapolations of the investments made during the first programme of measures and on hypotheses regarding future investments, the total cost of measures in order to reach good water status in the RhoneMediterranean basin was estimated at 5,92 billion euros, i.e. 395 million euros per year. Environmental costs were then distributed among the different users depending on the pressure origin generating the measure planning. These amounts are transfers paid by the environmenta since the environment currently bears the damage in the absence of corrective measure. The following table was obtained: 14 PoM beneficiary Measures concerned PoM amount 20132027 (in million euros) Beneficiary User Amount (in million euros) Annual amount (in million euros per year) Agriculture Pesticides pollution reduction 1648 Agriculture 1648 110 Local authorities (water and sanitation) Pollution reduction (including substances) 1116 Households 870 58 Industry 240 16 Local authorities (services and environement) and agriculture Local and quantitative management 382 Households 243 16 Industry 91 6 Agriculture 48 3 Industry Pollution reduction (including substances) 1477 Industry 1477 98 Environment Hydromorphology 1297 Industry 432 29 Agriculture 432 29 Households 432 29 As a consequence, PoM benefits (and thus a proxy for environmental costs) can be estimated for each user category: Beneficiary Million euros per year % Households 103 26% Industry 150 38% Agricutlure 142 36% 3 Compensatory costs assessment While the environmental costs previously evaluated focused on the damages caused to the water resource and the aquatic environment (environment-centred approach), compensatory costs only consider the impacts on other water activities (anthropocentric approach). Both approaches are thus complementary. Compensatory costs are costs borne by a water user due to the aquatic environment and/or the water resource degradation caused by another water user. Compensatory costs match expenditures spent due to a degradation – or a known threat - in order to regain and potentially maintain the initial state of the water body or an equivalent level of human activity. For example, agricultural effluents lead to water eutrophication. Water is then abstracted by drinking water plants that might require additional treatment because of water eutrophication. Eutrophicated waters additional treatment costs are thus considered as compensatory costs borne by water services because of agriculture. Consequently, compensatory costs (for water) are part of environmental costs as defined in the WFD. They represent in fact the most tangible part of these costs (that stakeholders and water users easily understand) and that can be most easily calculated. The concept of “compensatory cost” is not a concept explicitly referred to in the WFD. This concept is used in France in order to increase knowledge on environmental impacts and related costs. 15 The word ‘compensatory’ refers to two complementary dimensions : (1) Compensatory costs are costs spent by a user in order to compensate for the (negative) consequences of a water resource degradation made by others (crossed-effects); and, (2) Compensatory costs partially include costs required for restoring the state “before degradation”. This restoration may concern the environment state (agricultural measures financed by drinking water services in catchment area), the level of activity (drinking water distribution observing regulatory norms) or the water use (fisher or tap water consumer wellbeing). Expenditures must be spent by the service or user, due to pollutions originating from other users activities. Moreover, compensatory costs refer to a norm for human water use and not for the aquatic environment (in relation to good water status as defined by the WFD). The focus is for example on the costs paid by water services to purify water for human consumption and not on the costs borne by polluters to reduce the pressure on the environment. Therefore, they cannot be approximated by the costs of the programme of measures like other environmental costs. One has to look at the expenditures actually spent by other economic activities/water uses due to water degradation. Compensatory costs are part of environmental costs and their valuation is more easily accessible. The reliability of the costs/expenditures estimated is generally rather good. These costs are assessed with certainty in comparison to non-market benefits (such as patrimony value). Moreover, costs presented as euros actually spent are more understood and accepted by stakeholders than values obtained through stated-preference valuation methodologies which are still at their exploratory phase in terms of operational use of their results. Consequently, assessing compensatory costs in the framework of the WFD contributes to improving the knowledge on environmental costs linked to the state of the aquatic environment and of water resources. In France, real-size tests on targeted territories were conducted on three thematic areas (drinking water, the marine environment and the quantitative management of water resources) in association with thematic and local experts18. The following main compensatory cost categories were identified: Curative compensatory costs Fish ladders Complementary treatments for polluted waters for industries Complementary treatments for drinking water (nitrates, pesticides, N and P) Palliative compensatory costs Interconnexions implementation for water supply Substitution resource : change of abstraction point Abstraction points deepening and associated treatments Preventive compensatory costs Incentives and subsidies to change phytosanitary practices Subsidies to change agriculture practices Abstraction points protection ncreased water quality monitoring over a certain threshold (drinking water supply) 18 For more details, please refer to : « Analyse sur les coûts Compensatoires en France et en Europe dans le Cadre de la Directive Cadre sur l’Eau (DCE)», Ecodecision, 2011 16 Example of the Rhône – Mediterranean & Corsica basin Curative compensatory costs : example of fish ladders In order to maintain fish stocks for leisure fishing, actions are implemented by users with the support of the water agency to establish the right river conditions for fish. These actions mostly consist in building fish ladders and undertaking feasibility studies. According to the water agency database, the expenditures spent for these actions for the period 2007-2012 reach 6,2 million euros per year on average. Palliative compensatory costs : example of interconnections for drinking water supply In order to secure the quality of drinking water supplied to households, water supply services may need to establish interconnections between various water sources. The investments for interconnection undertaken during the 9th water agency programme, in particular investments targeting water supply security, were extracted listed from the agency database. The total expenditures for the period 2007-2012 were estimated at 4.0 million euros for the entire period. Preventive compensatory costs : example of incentives and financial aid to adapt phytosanitary practices In order to prevent the degradation of catchment areas (which impacts the quality of water abstracted by drinking water supply services), preventive actions are undertaken with users of phytosanitary products. These actions take various forms: awareness raising, trainings, individualised advices, purchase of material avoiding pesticides use, etc. Using the water agency database, expenditures related to these actions were estimated at 2.7 million euros per year on average for the period 2007- 2012. Example of the Rhine-Meuse basin Curative compensatory costs: Complementary treatments for drinking water (nitrates, pesticides, N and P) All the works that have been realised in order to treat nitrates, pesticides and water turbidity were listed. The total amount of costs was divided by the plants capacities in order to establish a reference cost. The reference cost thus obtained was 7800 €/m3/day. This reference cost was applied to the water flow treated, which is 165515m3/day over the Rhine-Meuse basin. Therefore, the total cost of works realised in the Rhine-Meuse basin for complementary treatments was estimated at 126 million euros. This number can be considered as the patrimony built in order to make complementary treatments for drinking water. The annual cost born for these installations renewal was estimated by dividing this cost by the average life time (25 years). The annual renewal installations cost thus obtained was about 5 million euros per year. Example of the Loire-Britanny basin Costs borne by users to maintain drinking water quality The compensatory costs which contribute to maintaining the quality of drinking water supplied include: preventive measures to adapt practices in catchment areas; curative measures such as additional treatments; palliative measures to replace damaged water resources. The following table summarises some compensatory costs which were calculated for the Loire-Britanny basin. Preventive actions Million euros per year Definitions: Catchment areas : agricultural practices, Agricultural practices : 52 local authorities, economic stakeholders, Communication and organisation Additional treatment: households : 13 more treatment or higher treatment PUD and land acquisition 80 between 2007 and 2010 intensity Curative actions Additional treatments OM 47-98 PUD : Public Additional treatments nitrates 5-7 Usefulness Declaration (Déclaration d’Utilité Additional treatments pesticides 45-80 Publique), used in Palliative actions particular to define the Substitution resource Investment : 0,03 (except pipes) protection perimeters Interconnections Investment : 0,012 around catchment areas Drillings deepening Additional treatments : 0,6 Others OM : Organic Matter Health costs : costs linked to bathing, water / 22 river or sea products consumption, following up an anthropic degradation of the environment. The overall costs estimated are between 260 million euros and 350 million euros per year for the Loire-Britanny basin. 17 Example of oysters purification costs Additional costs for oyster producers In the case of water quality degradation (bacteriologic pollution), shellfish production requires additional purification treatments to reach sanitary norms. Such treatments imply additional costs borne by shellfish producers. Purification treatments consist in placing shellfishes in purification basins filled with clean water that provides natural filtration. The area of concrete purification basins generally ranges from 50 to 100 m2 with 1m water deep. Pumping, circulating, oxygenating and filtrating systems are also necessary. The unit cost (in euros/kg of shellfish produced) varies depending on the oysters production range (t/year). The European project ‘Virus safe food’ estimated purification costs at 0,8 euro / kg. Example of PCB costs Additional costs due to PCB pollution in the Rhone river PCB (polychlorinated biphenyls) pollution generates many costs, in particular those associated with sediments management. Compensatory costs are additional costs related to contaminated sediments management (i.e. maintenance, sediments transportation, storage, decontamination,...). In the case of the Rhone river, this additional cost was estimated between 400 000 and 800 000 euros per year, depending on the hypotheses used for calculation. The hypotheses for unit costs were: - an additional cost of 25 euros / m3 for dredging in the case of a contamination; - transportation costs of 25 cents / km for transporting the sediment to the nearby landfill; - the quantity of sediments to be extracted ranging from 6000 to 18 000 m 3. Example of costs borne due to bottled water purchase Tap water is considered safe by 79% of the French population 19. Consequently, the remaining 21% can be considered as buying bottled water for fear of sanitary risks. The average consumption of bottled water in France is 161 l/year20. The average cost of a bottled water is 1,65€/m3. The cost borne by households due to bottled water purchase was thus estimated at 152 million Euros over the Loire-Britany river basin. 4 Environmental costs and cost-recovery The calculation of environmental costs provides useful information with regard to the cost-recovery assessment. The evaluation proposed highlights the damages (assessed in monetary terms) caused to aquatic ecosystems and the water resources, as well as the impacts on other activities. Compensatory costs give insights into the financial transfers between users categories. Other environmental costs underline whether users generating damages to the environment actually pay to repair them and whether the programme of measures (with the calculation methodology described above) is in adequacy with the polluter-pays principle. However, environmental costs do not take into account other financial transfers between water users, in particular taxes and subsidies on water uses, which may compensate for the environmental costs some users generate. As a consequence, these financial transfers have to be integrated in the overall cost-recovery assessment. 19 Baromètre 2011, Centre d’information sur l’eau 20 SOeS, 2007 18 In order to account for environmental costs in the cost-recovery analysis, these costs are then allocated to different water users categories based on the pressures they impose on the environment. They are then integrated in the assessment of the financial transfers between users’ categories and in cost recovery ratios. A user category ‘environment’ was created to simplify the assessment. The overall cost-recovery analysis, integrating various taxes and subsidies, thus shows whether environmental costs are compensated through other financial mechanisms (for example, whether the users generating damages to the environment actually pay for repairing measures or whether financial transfers between different users categories are (partially) compensated through the tax/subsidy system). Water agencies and cost-recovery In France, water agencies collect charges on water uses in each basin. The revenues collected are then allocated via subsidies to projects that aim at improving the state of the aquatic ecosystem and of water resources. This financial system contributes to the implementation of the polluter-pays and cost-recovery principles at the river basin scale (in particular since ‘water pays for water’). As a consequence, this system reduces compensatory costs, via taxes paid by polluters and financial support given to other users for restoring their activity. This system also reduces environmental costs. Thanks to the charges paid by polluters, financial resources are available to restore aquatic ecosystems even if nobody’s activity is directly impacted by the current poor water state. Charge levels and subsidies are defined in the 6-year intervention programme of the water agencies. This programme is adapted to match the WFD objectives and the requirements of the programme of measures, while contributing to the increase of cost-recovery levels. Taxes on water uses The following uses are taxed by the water agencies: Tax Tax payer Pressure targeted Domestic pollution Domestic users Point and diffuse-source pollution due to sanitation. Non-domestic pollution Any economic or industrial activity entailing pollution discharge Industrial point-source pollution. Sewerage systems modernization Non-domestic and domestic pollution tax payers Point and diffuse-source pollution due to domestic and industrial sanitation. Water abstraction Users or industrial users or farmers Water abstraction. Abstraction for hydroelectricity Any person operating a hydroelectric plant for a volume of one million cubic meters flowed in a year Changes in watercourses regimes. Diffuse pollutions Phytosanitary products users Diffuse pollutions due to phytosanitary products and seeds. Livestock farming pollution Livestock farmers (above a livestock threshold) Nitrates discharges pollution due to livestock farming. Obstacles on watercourses Owners of continuous obstacles between Incentive to equip these obstacles and to suppress two riversides (above a certain threshold) those which have become useless, in order to reestablish the river ecosystem well-functioning. Storage in low water period People storing part of or the totality of a river flow in low water period, for a capacity above one million cubic meters. Reduction of watercourses flows downstream (perturbates aquatic life and water uses). Aquatic environment protection Recreational and professional fishers. Fishes species abstraction. 19 Bibliography : Guide pour la mise à jour de l’Etat des lieux, MEDDTL/DEB, mars 2012 Circulaire DCE 2007/18 du 16/01/07 relative à la définition et au calcul des coûts pour l’environnement et la ressource pour l’élaboration des schémas directeurs d’aménagement et de gestion des eaux, Annexe II : Calcul des coûts pour l’environnement et la ressource « Analyse sur les coûts compensatoires en France et en Europe dans le cadre de la DirectiveCadre sur l’Eau (DCE)», Ecodecision, 2011 Etat des lieux du bassin Loire-Bretagne, Agence de l’eau Loire-Bretagne, 2013 Récupération des coûts sur les bassins Rhône-Méditerranée & Corse, Quantification des coûts et des flux financiers – Rapport, Ernst & Young, 2013 Etat des lieux du bassin de la Seine et des côtiers Normands, Agence de l’eau SeineNormandie, 2013 Etat des lieux du bassin Rhin-Meuse, Agence de l’eau Rhin-Meuse, 2013 Etude économique relative à la récupération des coûts des services liés à l’eau du district hydrographique comprenant la Guadeloupe et Saint-Martin, synthèse de l’étude, Acteon, Eco Logique Conseil, 2013 20 7. Illustration 3 - Assessing environmental and resource costs in the Guadiana River Basin in Spain21 1 Introduction The calculation of environmental & resource costs performed for the Guadiana river basin in Spain, following the WFD cost-recovery assessment, has met with similar difficulties as the ones presented in the French case (impossibility to perform accurate and exhaustive calculations for each part of the basin). Therefore, despite the set of rules developed to be as precise as possible, the calculation represents an approximation of the true state of the environment and resource costs in the basin. On the one hand and as indicated in the plan, the environmental costs are calculated as the cost of the measures needed to reach the good status of the water bodies, provided that the current state, lower than good status, is caused by the use of water and linked to a water service. For this reason, these costs are considered as a penalty rate for polluting, which total annual amount is equal to the capital cost (annual percentage rate) of the measures to be undertaken to achieve the good status. According to this, the goal of the assessment of environmental cost is not the recovery of the costs of the measures aiming to restore the environment. This cost-recovery process will take place once the measures are put in place, accounting for the existing financial cost-recovery instruments already in place for this purpose. For the next planification cycle, a new methodology has been developed for assuring a homogenous interpretation in the majority of river basins. Mainly, the definition of environmental cost is more restrictive: the measures are just the ones related directly to one of the water services defined in WFD article 2.38. On the other hand, the Spanish technical instruction for water planning defines resource cost as the opportunity cost in water scarcity situations. These costs can be estimated using payments made in transactions for water use rights and/or transactions of irrigation lands between different uses. 2 Steps followed for the calculation of non-financial costs 1. For the environmental costs: to identify the measures within the PoM aiming to restore the environment from a damage caused by a given water service. For the resource costs: to identify the transactions for water use rights and/or transactions of irrigation lands, and then make the calculation of the opportunity cost of the resource. 2. Distribution of the non-financial costs among the different exploitation systems and subsystems. 3. Allocation of the non-financial cost among the different water uses. 4. Calculation of the annualised non-financial costs. 21 This illustration has been prepared by Jorge Ureta Maeso, Ministry of Agriculture, Food and Environment, (Spain). For more information on this illustration and on the Spanish experience in the application of economics methods and tools for supporting water management, please contact: [email protected]. 21 3 Environmental costs calculation 1. Following the steps mentioned above, we identify the measures within the programme of measures aiming to restore damages caused by the water use and the water services. Table 3. Investment and measures of the programme of measures of the Guadiana River Basin (GRB) to take into account for the environmental costs calculations Service Use Group of measures Measure Investment PM-GRBn (M€) Groundwater abstraction Bulk water supply More than one Environment restoration Control and protection of species potentially afected by the exploitation of dams and associated infrastuctures. (*) Obstacles clearance and longitudinal passage (*) Environmental flows implementation including the infrastructure management. (*) Total Bulk water supply 13.51 5.67 173.04 192.22 Distribution Waste water treatment plants (WWTP) improvement to terciary treatment Public sewerage network sanitation Urban Point source pollution minimization Waste water treatment plants (WWTP) improvement (complementary measures) 6.10 Septic tanks adequacy 3.64 WWTP capacity increase < 2000 population equivalent 1.56 WWTP capacity increase >2000 population equivalent 72.74 WWTP capacity increase. Included in the Waste water guidance draft MAGRAMA-CLM 18.87 Other measures included in the waste water guidance draft MAGRAMA -CLM 190.20 Other measures included in the waste water guidance draft MAGRAMA -EXT 93.00 New WWTP < 2000 population equivalent 116.16 New WWTP >2000 population equivalent 226.05 WWTP improvement to terciary treatment >10 000 population equivalent in sensitive areas 136.71 Total Public sewerage network sanitation Sanitation outside the public sewerage network Industrial / Urban Knowledge and governance Total sanitation outside the public sewerage network Total 45.26 910.28 Staff increase for control and Management of discharges into surface waters (*) 1.44 1.44 1,103.94 * It should be mentioned that, in the new methodology used in the second planning cycle, the measures noted above (*) wouldn’t be considered in this analyse for valuating environmental cost, as they are not related to one specific water service according to WFD article 2.38 definition. 22 2. The second step is the distribution of the non-financial costs among the different exploitation systems and subsystems. In accordance with the polluter pays principle, the environmental costs will be allocated for exploitation systems and subsystems where the pressures leading to these costs take place. The following rules are set: Costs regarding bulk water supply are allocated depending on where the investments have been done; Costs regarding groundwater abstraction for exploitation system and subsystem. are calculated Costs regarding urban water services and sanitation outside of the public sewerage network are estimated using the population rate for exploitation system and subsystem; Costs regarding the irrigation distribution are calculated in accordance with the use of irrigation water exploitation systems or subsystems. Table 4. Distribution of the water use per services, exploitation system and subsystem– GRB 2005 SERVICE Bulk water supply Groundwater abstraction Distribution Public sewerage network sanitation Ex.Sys–GRB Central Oriental 75% 1% 59% Sanitation outside the public sewerage network 47% 47% 13% 92% 34% 43% 43% Alto Guadiana 74.0% 100% 90.8% 90.8% 90.8% Tirteafuera 0.02% 0% 0.1% 0.1% 0.1% Bullaque 25.8% 0% 9.2% 9.2% 9.2% 10% 7% 6% 4% 4% 1% 0% 1% 6% 6% Sur Ardila 3. The third step is the allocation of the non-financial costs among the different water uses Once the environmental costs of the water services have been calculated, the allocation of these costs to the different uses is made in accordance with the current water consumption of each individual use. Table 5. Water use distribution per service and uses – GRB, 2005 SERVICE Bulk water supply Groundwater abstraction Distribution Public sewerage network sanitation Sanitation outside the public sewerage network Urban 10% 6% 8% 100% 27% Agriculture 88% 93% 92% Industrial 2% 1% USE 73% 4. The forth steps lead to estimates of annual environmental costs. The investments costs of measures selected for assessing environmental costs are translated into annualised costs, using the Lifespan of the investments (estimated at 50 years for investment in 23 regulation infrastructure and 25 years for the rest) and with a discount rate of 2% (representing the opportunity costs of the resource). 4. Resource costs calculation 1. As mentioned before, resource costs defined as the opportunity cost under water scarcity situations is estimated by the costs arising from payments made in transactions of water use rights and/or transactions of irrigation lands between different uses. The opportunity cost is generally defined as the benefit forgone when a scarce resource is allocated to a given use instead of other uses. In the Guadiana river basin, transaction for water use rights has not taken place. However, there have been takeover bids for groundwater private rights (water exploitations offering more employment and socio-economic benefits) and transactions of irrigation lands to different uses (e.g. to thermo-solar use). The resource cost is a concept that is difficult to calculate, depending on the market and transactions that are taking place and used for deriving opportunity cost. The following tables illustrate how payments in annual equivalent terms are estimated based on bids for water rights and irrigation lands. Table 6. Takeover bids for groundwater private rights and payments in annual equivalent rates, GRB 2006-09 Date of the bid Irrigation surface affected (ha) Payment (€ base 2008) Volumes recovered Registered (m3) Real (m3) Payments in terms of annual percentage rates ¹ (€) (€/m3) 1/06/2006 521,384 56.3 240,816 112,600 19,060 0.17 1/07/2007 9,832,557 1,060 4,434,521 2,085,945 359,436 0.17 2/07/2009 12,334,321 1,227 5,078,947 2,406,400 450,890 0.19 1/08/2009 11,935,786 1,281 5,117,622 2,562,000 436,322 0.17 1/09/2009 19,903,065 1,900 7,982,866 3,800,000 727,571 0.19 2/09/2009 11,940,440 1,217 4,973,604 2,433,800 436,492 0.18 Total Take over bids 66,467,553 6,741 27,828.376 13,400,745 2,429,771 0.18 Table 7. Acquisition of terrains with private water rights associated and their transformation into thermo- solar licensing terrains, payments for the resource in annual percentage rate; GRB 2006-09 Thermosolar plant Surface (has) Annual volume (m3) Total payment (€) Year of the licensing Average price of the irrigation terrains(€/ha) Payment for the resource (€) Total Net 22 Payment (€) (€/m3) Helios I 88.6 177,200 2,215,000 2007 14,536 1,287,890 33,891 0.19 Helios II 110.0 220,000 2,750,000 2007 14,536 1,598,960 42,077 0.19 Manchasol, 1 399.1 798,120 9,976,500 2008 14,198 5,665,854 157,579 0.20 Manchasol, 2 447.2 891,840 11,178,750 2009 13,693 6,122,825 184,823 0.21 1,044.8 2,087.160 26.120.250 14.675.528 418,370 0.20 Total 22 Taking into account a discount rate of 2% and a lifespan of 40 years. 24 We can conclude from the calculations made in the Guadiana river basin management plan that the opportunity cost of the resource in water being used in irrigation for overexploited areas is around 0. 2 € ∕ m³. For other uses, the opportunity cost is assumed to be equal to zero. 2. Distribution of the resource costs among the different exploitation systems and subsystems. Following the polluter pays principle, the resource costs will be allocated to the exploitation systems/subsystems that are at the origin of these costs, i. e. where the water use rights and/or transactions of irrigation lands are taking place. 3.Allocation of the resource costs among the different water uses. They will be allocated in turn to the water use and service concerned. 4. Estimating annual resource costs The calculation of annual resource costs is the result of the multiplication of the unitary price of the resource and the annual water volume per use. 5. A series of “Questions and answers” Following the presentation by Spain at the Economics WG, different clarification questions were raised. These are listed below, along with the answers provided by Spain to each question. 1. Do you have any information on how to assess ERC related to water services than WS, distribution and WWT such as hydropower or navigation? We have focused on the main water services such as water supply and wastewater treatment defined in Art 2. Other water services have not been analysed. It should be convenient to enlarge analysis of services beyond urban and irrigation including energy and navigation. 2. Is self-abstraction included? (for clarification) Volumes self-abstracted from surface and groundwater are included in the water accounts for the analysis of water resources and water demand. Thus, related costs are estimated and used in the financial cost/income computations. 3. What is the explanation of the absence of measures targeting ground water abstraction? (for clarification) Such measures are included in the Programme of Measures, but these are not assigned to environmental costs thus they are not shown in the figure. The main measures dealing with groundwater relate to the quality and quantity control network (already in use) and the installation of volumetric metering devices that is compulsory in most of the RBMP. Quantitative control and common resource management (under water user associations) are also included in most RBMP for aquifers under risk of not reaching GES. 4. Concerning environmental costs. Would it be possible to show how the presented approach (measures - env costs, costs distribution, their allocation among users) is in practice translated into prices/tariffs paid by users and - how the financial resources collected are then used for financing measures? Environmental costs are not currently paid by water users. The Spanish legislation allows to compute water tariffs according to real (financial) costs. Thus, it is not possible for the public administration to charge users with cost not having been effectively expended by administration. The proposal of 25 environmental costs as the difference of the cost already paid by the PoM and the future cost when all water bodies reach GES define the environmental cost as something that 'should be paid' for in the future. This concept, however, is not included in the Spanish legal system. 5. Concerning resource costs. Would it be possible to present an example (can be imaginative) for points 2-4? And similar to the question on environmental costs, it could be good to present how the costs estimated could be translated into users’ charge/tax. In another words how the system can work in practice to help collating financial revenues. Resource cost is defined as the real observed price paid for water resources in a basin. As Spain has provided the possibility to trade water rights in its legislation since 2005, there are some basins where trading can be observed directly (Guadalquivir, Almeria, Tajo, Segura) and others where it can be estimated indirectly from transactions in the land market. In the example shown above, Guadiana water rights were traded indirectly helping to estimate a resource cost of around 0.18-0.20€/m3 per year. This should be used as a reference to estimate the profit from illegal water abstraction in case it should take place. Should it be the case, illegal abstractors should be fined at least by using this value as reference of the damage imposed on water as a public good. 6. Would it be possible to give precise examples of pressures and related measures? How have these been chosen, what are their costs and how were these evaluated? There are cost-effectiveness analyses developed for some river basins. A summary of the Guadalquivir RBMP for quantitative gap reduction is detailed in: Berbel, J., Martin-Ortega, J., & Mesa, P. (2011). A cost-effectiveness analysis of water-saving measures for the water framework directive: the case of the Guadalquivir River Basin in Southern Spain. Water resources management,25(2), 623640. The complete description can be seen in the mentioned RBMP. The figure below presents key elements of such cost-effectiveness assessment. Table 8. Cost-effectiveness ratio of water-saving measures for the PoM Water-saving measures Improvement of urban distribution networks Modernisation of irrigation systems Service cost recovery in urban sector Service cost recovery in irrigation Volumetric billing for irrigation Extension services for irrigators Subtotal23 Strict groundwater abstraction control Total Effectiveness Reduction Impact in total reduction extractions (Mm3/year) (Mm3) Annual Equivalent Cost (106€ per year ) CE pressure reduction (€/m3) CE impact reduction (€/m3) 44.99 2.19 21.61 0.48 9.87 259.51 35.26 172.18 0.66 4.88 17.59 9.58 18.55 1.05 1.94 22.46 2.20 2.41 0.11 1.10 38.26 5.90 6.20 0.16 1.05 9.78 1.58 3.82 0.39 2.42 392.59 56.72 224.77 0.57 3.96 323.11 80.38 5.50 0.02 0.07 715.71 137.09 230.27 0.32 1.68 The subtotal row points out the effectiveness of the measure ‘strict groundwater abstraction control’ which almost achieves the same reduction in extractions as the rest of the measures put together, and has a considerably higher impact reduction. 23 26 8. In conclusion: guiding the assessment of Environmental & Resource Costs in the context of the WFD implementation Article 9 of the Water Framework Directive requires that Environmental and Resource Costs (ERC) are assessed and included when assessing the recovery of the costs of water services. Furthermore, the assessment of ERCs also plays a role in supporting the search for incentives for a more efficient use of water resources, for selecting a cost-effective Programme of Measures and in the Cost-Benefit analysis. This paper summarized the main conceptual and methodological elements on ERC assessment available in existing guidance documents developed for supporting the implementation of the WFD implementation, illustrating methodological issues with practical applications of ERC assessments carried out by selected MS using the cost-based approach. When assessing ERCs, it is important to distinguish between internalized and external ERCs, and between historical and current ERC: When referring to environmental & resource costs, you need to clearly specify whether your assessment investigates historical environmental & resource costs that are already internalized (via existing financing mechanisms like tariffs for water services) or current environmental & resource costs that remains to be internalized. While the first assessment addresses financial costs of water services – and whether these costs are paid for by water users at the origin of historical environmental degradation, the second assessment is addressing the ERC requirements of the WFD; Environmental & resource costs are an issue if you are not yet at “good water status”! If you have already reached “good water status” for all water bodies in a given river basin district, it is assumed that there are no current environmental & resource costs. All have already been internalized24! If water uses pay directly for the costs of already implemented “pressure abatement” measures (e.g. costs of installed wastewater treatment plants) via specific financing mechanisms (e.g. water tariffs), then you can describe the financing mechanism, assess the rate of recovery of these costs by service users, and you can then state: historical (past) environmental and resource costs are recovered, partially or fully (if financial cost recovery for “pressure abatement measures” are partially or fully recovered). As historical ERCs have already been internalized, these should be regarded as financial costs in the context of cost-recovery assessment. This is illustrated by the approach presented by the Netherlands, where the financial costs of reaching past (wastewater treatment) targets are fully internalized (historical) ERCs 25; Resource costs are an issue only when there are significant water quantity issues in your river basin district, or when current allocations to different uses is not “economically 24 However, even when ERCs are fully internalized via the PoM, some of these costs might still be investigated further. Some water uses might not be contributing to the costs of already implemented measures while putting pressures on water bodies: if only some of the uses are contributing and not others, you might question whether this represents an “adequate” contribution from users to solving past/historical environmental problems/costs. And this is not the full application of the polluter pays principle. 25 Waste water treatment, for example, is regarded as the implementation of measures aimed at reducing the damage to the aquatic environment up to current water quality level. Thus, all costs for waste water treatment are seen as internalized historical ERCs. When cost recovery level is 100% for these costs, these historical ERCs are considered as fully internalized and are financial costs. 27 optimal”. In some cases, resource costs can be a potential issue for catchments with no current water stress under future climate change scenarios26. Environmental costs are both the costs of environmental damage and the costs incurred by those who use the water environment as a consequence of environmental degradation, as indicated in the WATECO Guidance (2003). This is reflected in the approach adopted by France for its 2nd RBMP cycle, where ERCs have been assessed through two complementary methodologies: The costs of damages to the environment and ecosystems were estimated by the costs of maintaining or restoring good water status by 2027 (i.e. the overall costs of what remains to be implemented after 2021 targets are reached). With this method, it is possible to indentify the share of costs generated by each sector, as each of the additional measures needed to reach GES in 2027 target specific sectors –for example, environmental costs due to households are the costs of additional treatment of point-source pollution generated by households, the environmental costs due to industry is approximated by calculating the costs of additional measure to reduce industrial pollution up to reaching GES, and so on. Identifying which environmental costs are generated by each sector allows for identifying who should recover these costs; Damages to the environment may affect other activities and result in externalities borne by water users in the form of additional expenditures: these so-called compensatory costs were also estimated. On a more practical level, compensatory costs match expenditures by the user or the service provider (e.g. water supply companies) due to degradation –or to a known threat- in order to regain and potentially maintain the initial state of the water body or an equivalent level of human activity. Compensatory costs are involved in curative, palliative and preventive actions. Whereas the costs of degradation are approximated by the costs of additional measures, compensatory costs are actual expenditures made by other economic activities/ water uses due to water degradation. They thus represent the most tangible part of environmental costs, a part that stakeholders can easily understand and that is easy to calculate. Moreover, the results of the assessment of compensatory costs will be useful when assessing the benefits that result from the implementation of the programme of measures (proposed for the second RBMP or for achieving good water status). Indeed, if water status improves, these costs will not take place anymore/will be “avoided”. And these avoided costs represent then benefits from water status improvement. Thus, the results obtained from the assessment of compensatory costs can feed into “disproportionate cost” assessments aimed at justifying time and/or objective exemptions. Depending on your context, you can undertake different assessments when applying the cost-based approach, which approximates ERCs with the costs of additional measures needed to reach GES, whenever the water status expected by 2021 is lower than good ecological status. In the context of WFD implementation, ERCs assessment is needed as part of cost-recovery calculations. When doing this, some elements need to be taken into account: o If water bodies are not at “good water status”, and if there are no financing mechanisms for collecting financial resources from water uses currently putting pressures on water bodies, then you can state: current environmental & resource costs are not recovered. o If water uses already pay water-related environmental taxes or charges, then you can state: there is some recovery of current environmental and resource costs. Similarly to the previous option, you can also identify water uses not paying environmental taxes or charges while putting pressures on water bodies: if only some of the uses are contributing and not others, you will question whether this represents an “adequate” contribution from users to solving current environmental problems/costs, bringing practical evidence and justifications. This situation is clearly not equivalent to the full application of the polluter pays principle. 26 In some cases, wáter scarcity might not be an issues, but you might still have some resource costs linked, for example, to past unefficient allocation of wáter permits, or related to climate change. 28 o You can also compare the financial revenues collected via existing financing mechanisms/economic instruments with the estimated costs of the future programme of measures that is required for achieving good water status (note: this is usually not the same as the programme of measures you will adopt in the second River Basin Management Plan (RBMP)). This will highlight how far you might be in fully recovering (internalizing) current environmental and resource costs based on the existing financing/economic instruments. If all financial revenues collected do not recover the costs of the programme of measures required for achieving good water status, then you can state: there is some recovery of current environmental and resource costs (and you can provide the overall recovery level). You can also compare the current payments made by agriculture, households and industry and compare them with the costs of the measures proposed for reducing pressures from these three sectors. You will then question whether this situation represents an “adequate” contribution from users to solving current environmental problems/costs, bringing practical evidence and justifications. 29
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