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SPANISH PARTNERSHIP AGREEMENT 2014‐2020. FNCA EXECUTIVE SUMMARY The Partnership Agreement (‘PA’) is the document in which the Spanish government and the European Commission set out how the funds available in four EU instruments (EFRD, EAFRD, ESF & EMFF) will be spent during the period 2014‐20. The total amount assigned to Spain (except the EMFF, still under negotiation) is 36.13 billion euros. The draft PA for Spain was published for public consultation in April 2014 by the Finance and Public Administration Ministry. The full response of the Foundation for a New Water Culture (‘FNCA’ in its Spanish initials), available in Spanish (http://bit.ly/1oZroKk), focuses on water resource managment issues and centres basically on the Partnership Agreement’s Thematic Objetives (TO) 5 (Promote climate change adaptation and risk management and prevention) and 6 (Protect the environment and promote efficient resource use). Following the consultation exercise, the Spanish government sent the PA to the European Commission, having made only minor changes in structure and others of a largely ‘cosmetic’ nature, but with the main concepts and contents relating to water resources remaining unchanged. The present document is a summary of the FNCA’s consultation response, updated to take into account these minor changes. The proposed Spanish PA suffers mainly from a great lack of precision in relation to the stated EU objectives and a lack of connection between the problems identified and the solutions proposed. There is a surprising absence of analysis of the present situation, and of data or indicators to sustain the arguments presented; costs and alternatives are not analysed and there is no priorization of measures as a basis for the proposed actions; overall, there is no real attempt to draw conclusions or learn lessons to avoid repeating previous errors in the implementation of measures in the 2014‐2020 period. The SWOT analyses lack rigour, are full of inconsistencies and appear to have been carried out separately from the rest of the text, as the measures proposed do nothing to address the most serious problems identified. In particular, even though water stress is one of the most serious problems facing water bodies in Spain (a fact fully recognised in the Spanish Sustainibility Observatory’s report in 2012 http://bit.ly/1iKldoz) this fact is only mentioned once in the PA, (p88, D16) although the document admits (p88, D4) that this might involve a failure to comply with the Water Framework Directive (‘WFD’). The PA does recognise the likely 5% reduction in available water resources in the 2014‐
2020 period, at the same time as there is increased water demand for agriculture; risk to potable Fundación Nueva Cultura del Agua ‐ C/Pedro Cerbuna, 12‐50009 Zaragoza (Spain) ‐ http://www.fnca.eu Página 2 de 4
water supplies; loss of acuatic ecosystems; overabstraction and water pollution; and soil salinization, erosion and organic matter loss; with these problems most acute in irrigated areas (pp78‐80 and SWOT pp87‐89). Having identified these problems, the PA proposes the following actions for EU funding (underlined) although the reality of the situation is often radically different (explanatory text which follows in each case):  Use of desalinated water and treated sewage effluent to reduce water demand (p81). However, the total volume of water for irrigation from these alternative sources will continue to be insignificant (it was only 1.4% of the total, according to official statistics in 2011 – http://www.ine.es/prensa/np802.pdf) whilst overabstraction of aquifers continues to go unpunished, or the cost of transferring water from one river basin to another is kept artificially low (see for example the underused desalination plants and the low cost of the water from the Tajo‐Segura transfer).  Strengthen the polluter pays principle. The approved River Basin Management Plans ignore this through not estimating environmental costs. There are no measures proposed to pay for diffuse agricultural pollution, hydromorphological alterations, abstraction or water infrastructure projects.  Use of economic analysis to improve efficiency and cost‐recovery. In reality, the system for calculating costs and determining the level of cost recovery is a well‐established fraud, as it does not take into account environmental costs, accounting ‘tricks’ are used to exaggerate cost‐recovery rates and the details are concealed in unpublished documents not submitted to public debate. This longstanding system perpetuates conceptual errors which are far from involuntary, constituting a grave, systematic and premeditated abuse of the powers of public officials (e.g. economic case for the Biscarrués Dam, Aragón).  Water markets:  Purchase of water rights to improve efficiency and recover overabstracted aquifers. This measure has not helped to reduce the pressure on water bodies, as the ‘recovered’ water volumes are the excuse for issuing new water use permits which legalize existing illegal water uses (e.g. Special Plan for the Upper Guadiana).  Inter‐basin water rights transfers. Important adverse effects have been confirmed in the river basins of origin, through not analysing economic, social and environmental viability, and granting rights to use more water than previously, thus exacerbating water stress (e.g. rights transfers from the Tajo basin to the Segura). Furthermore, inter‐basin transfers convert water as a public good into a mere traded commodity, which impedes compliance with WFD objectives  Strengthen demand management. The main purpose of the approved River Basin Management Plans continues to be increasing water availability, with significant increases in the reserved water volumes, even in excess of the water available within the river basin (e.g. Júcar River Basin Management Plan). Fundación Nueva Cultura del Agua ‐ C/Pedro Cerbuna, 12‐50009 Zaragoza (Spain) ‐ http://www.fnca.eu Página 3 de 4
 Wastewater and sewerage proposals within the National Water Quality Plan. The PA continues to opt for costly large infrastructure projects such as storm overflow tanks, without resolving the serious underlying problems: the lack of permeable surfaces in cities and combined urban drainage and sewerage networks in the majority of cases.  Use of treated sewage effluent to guarantee environmental water flow regimes. The PA interprets ‘environmental water flows’ erroneously as it applies the term to the ‘excess water’ or saved water after the application of water efficiency measures. The order should be reversed: after obligatory environmental flow regimes have been established for each water body, treated effluents may supply additional water to satisfy other functions. This measure will be pointless unless it is linked to real reductions in the water assigned to particular uses, lower water consumption and using the water permit system to ‘rescue’ the savings achieved by effluent reuse – conditions which the PA does not propose.  Water efficiency through irrigation modernisation. After 14 years of applying this measure in Spain, with an estimated 5 billion euros of investment (a large part of it from EU funds), it is simply unacceptable that the PA continues to propose financing irrigation modernisation without presenting data on water savings in the past, and analysis of results and lessons learned from preceding periods. It is reasonable to state that, with certain exceptions, between the experience on the ground and the arguments presented in the PA, “any resemblance to reality is purely coincidental”. The implementation of this measure has demonstrated that: o Lack of transparency is the norm: there is no information available on water savings, environmental, social and economic effects, nor results of ex post evaluations. o Greater pressure has been created on certain water bodies: not only have water abstraction rights not been reduced in parallel with water savings, but new increases in irrigated areas have also been tolerated (e.g. Guadalquivir basin between 1997‐2008), with further increases approved (e.g. Ebro river basin management plan 2010‐2015, March 2014) or presently proposed (draft National Rural Development Programme for 2014‐2020). o The energetic efficiency of irrigation projects has worsened, compromising their economic viability. o Irrigation subsidy rates have been increased from 40%‐70% with no justification whatsoever and without anything expected in return. o Costs continue to be assigned by surface area rather than by water consumed, and the application of the cost‐recovery principle has not advanced. For the financing of this measure to be legitimate and consistent with EU Regulation 1303/2013, the WFD and the EU 2020 Strategy, the PA must include in its proposal: o
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The presentation of a full report on the effects of irrigation modernisarion projects carried out in Spain the last 15 years. The preparation of an irrigation conversion plan which would require irrigation needs to be reduced in line with the current climate change predictions set out in TO5 of the PA. Measures consistent with the sustainable management of overabstracted aquifers and full control of the enormous number of illegal boreholes. Fundación Nueva Cultura del Agua ‐ C/Pedro Cerbuna, 12‐50009 Zaragoza (Spain) ‐ http://www.fnca.eu Página 4 de 4
And with regard to water governance, the following measures are essential: o Focus water management in demand control and not increasing water availability. o Make public participation processes proactive and meaningful. o Improve substantially the coordination and joint action of all the authorities involved in water management, in order to achieve common objetives and comply with the law. And to conclude, we stress that the argument that the complexity of the Spanish institutional system, which appears several times in the PA, can not be used as a justification for non‐
compliance with the obligations of EU directives by the Spanish authorities, as has been confirmed by the European Court (ECJ sentence of 4 October 2012, C‐403/11, part 25). Zaragoza, June 2014. Authors: Pedro Arrojo, Domingo Baeza, Joan Corominas, Mª. Soledad Gallego, Abel La Calle, Francesc La‐Roca y Concha Salguero. o
Fundación Nueva Cultura del Agua ‐ C/Pedro Cerbuna, 12‐50009 Zaragoza (Spain) ‐ http://www.fnca.eu