Some comments on the Blueprint and CAP review
Even though two-thirds of the group of experts from all Member States (MS) working on agriculture and water, the European Commission (EC) as well as other stakeholders agreed that “cross compliance should be strengthened, broadened and better enforced in order to ensure positive effects on ecological status and achieve the Water Framework Directive (WFD) objectives”, the Common Agricultural Policy (CAP) reform did not propose any relevant measures.
The European Parliament (EP) vote held on the 13th of March 2013 failed to enforce water policies as a precondition to receiving CAP payments by eliminating the WFD and the Sustainable Use of Pesticides Directive from cross compliance. It is outrageous that water protection has been reduced to coverage by the Farm Advisory System to raise farmers’ awareness. Also the European Commission (EC) did not go further than weakly advising an implemention of these measures once all member states have correctly implemented the overall WFD policies. Requirements for farmers diminished steadily as the negotiations proceeded, until the European Parliament reached a political agreement with the 27 Member States in July 2013 which ultimately eliminates almost all possibilities for environmental protection through CAP.
In annex you can find concrete WFD measures which are related to agriculture and could have been made mandatory through cross compliance. As you can see these requirements are very basic and common sense would expect them to be in place already. This is not the case. Farmers may receive EU funding and be recognized as “sustainable” farmers even though they do not have any legal water use entitlement, even though they may pollute strategic aquifers for drinkwater supply with various pesticides and fertilizers, destroy river beds and riparian vegetation, cause soil erosion and dry up our last wetlands.
We now need to work to avoid the Structural & Cohesion Funds & European Investment Bank loans (2014-2021) - money provided for “rural development” and “practices against climate change and environmental degradation” - being spent on measures and strategies that worsen things even more. In addition, as social movements have detected and denounced many times, the current political framework which allows systematic perversion of the objectives and fraud linked to waterworks funded by EU money, doesn’t seem to be reformed.
In the following sections we outline just some aspects related to these dynamics of commodification of water in agriculture.
To address the over-allocation detected in the Blueprint analysis, the EC proposes to develop a guidance document in the framework of the WFD Common Implementation Strategy in order to enhance the determination of ecological flows, the quantity of water needed to reach a ‘good status’ of water bodies, and integrate these in the next River Basin Management Plans (RBMPs) cycle.
Environmental flows are actually a cap on water use, but there is no political will to enforce its application. Indeed, according to the WFD environmental flow regimes should be considered as a “prior restraint” before any use, so it may not be considered as a kind of “environmental use” and therefore fall into the allocation competition. The implementation of this measure is an interesting challenge, as it would require an adaptation of each Member State’s legal framework on water and a revision of all water abstraction permits according to this environmental constraint.
When dealing with the implementation of environmental flows, managers need to “free” water from over-allocated water basins under current legislation. This may be very difficult, as water use rights are extremely protected. For example, a proposal has been developed in Catalonia (Agencia Catalana del Agua, ACA) on the possibilities to implement environmental flows in a stretch of the River Ter, which has 85 hydropower plants in a 208 km riverbed. ACA considered different negotiation options such as: flexibility of the water use right according to the river’s flow regime conditions, subsidies to renovate turbines, concentrating production in some strategic points, or enforcing the reduction of water rights by providing compensation. At the end of the day, the biggest quantity of water use rights holders only agreed to a refund of lost profits according to the legal period of the water use right (most expire in 2061) resulting in an estimated 75 million euros.
If such a scheme would be proposed in a river where agriculture is the main cause of over-allocation, these procedures would be even more difficult. Huge investments of public money have been made in order to “save water” and increase efficiency through modern irrigation technology, but these investments never have been aimed at a reduction of water use rights, therefore never actually ”freed” any water for environmental flows, instead, consolidated these demands. Moreover, farmers admit that the most interesting part of receiving subsidies to transform currently rain fed crops or modernize gravity flow irrigation plants with pressurized irrigation systems is the increase of capital value of the land.
Therefore we may conclude that the private capitalization of public investment and speculation with water use rights are forms of commodification that override common interest to protect our water bodies. In the Catalan movements, we call these procedures commodification of water flows, which may be added to all other forms of commodification we already read in other articles.
Metering irrigation water
The Blueprint states that an assessment of RBMPs reveals that “(…) incentive and transparent water pricing is not applied across all MS and water using sectors, also due to the lack of metering”. Furthermore, in the Report on Scarcity and Droughts it is reported that “metering is a pre-condition for effective water allocation and pricing.”
The considerations on impacts of water use, especially in agriculture, have to be considered in more than its quantitative terms. Over-allocation is the reason for over-exploitation, as well as the failure to implement adequate environmental flows. The idea that a better pricing and allocation will be possible mainly through water metering is at best a restrictive vision. This measure may answer the question “how much water is used?” but does not tackle “how?” and “wherefore?” is it used. Especially in agriculture these questions make a huge difference.
Most low technology input farming, such as traditional, agro ecological and smaller scale farms, use a higher quantity of water per hectare for irrigation in comparison to agro-industrial farms. Nonetheless, in most cases, these flows are returned to the hydrological cycle and do not contain a heavy pollution which wetlands and living rivers cannot clean. This means “more” water, but for sustainable agriculture and healthy products.
When an “inefficiently” irrigated land turns into a highly technified and “efficient” one, the economic structure of the farm changes: high energy, operation and maintenance costs increase water price. Therefore, in order to get the promised increase of income, economies of scale and different crops have to be adopted. This implies a profound change, not only in water use, but also in the production pattern, input levels, working conditions, mechanization, biodiversity and landscape. Most of these effects are in contradiction with all environmental policies, as well as the objectives of food sovereignty.
In Spain, the promised water savings and environmental benefits due to more efficient irrigation systems have never been proven. Instead, pressurized irrigation projects have resulted in an intensification of farming practices (more crops per year), an extension of the total irrigated area (thanks to pressurized systems and to new zoning linked to waterworks) resulting in an overall increase of water use, as well as pesticide and fertilization pollution runoff.
A sound water measuring and tariff system in agriculture should be based on a more integrated view of irrigation: gravity flow irrigation may be optimised, crops adequate to the climate and biodiversity conditions may be promoted, soil moisture management enhanced and local water reuse systems developed.
The Blueprint mentions that “the presence of a water pricing policy is envisaged as an ex ante condition to obtain financing for certain projects under the Commission’s proposals for Rural Development and Cohesion funds.” Therefore it may be relevant to summarize some more perspectives on water measuring for allocation and pricing:
- Avoid considering efficient quantitative water use only by surface unit, while this should be accounted for at River Basin level.
- When evaluating water use efficiency, the effects at the point of abstraction, runoff and drainage should be accounted for in an overall water balance and environmental impact.
- Energy use should be accounted for in the efficiency analysis.
- Qualitative aspects should be integrated in the account of water use, in order to penalize polluting practices, and social, environmental and cultural aspects of farm structure should be taken in account.
Rural development policies
It is very important for countries that suffer chronical over-exploitation of water bodies, like Spain, that no EU money is spent to increase irrigated land, nor to subsidize irrigation technology. Until now this was indeed not allowed, but new CAP policies are putting this issue back on the table.
The EP voted in favour of funding modernization technologies with EU money and denied the obligation for farmers who received these funds to “handle in” the percentage of water which could be “saved” by the application of this technology to water authorities, in order to allow the implementation of environmental flows. In the current situation, these funds would end up promoting an unsustainable farming model, benefiting mostly the companies involved in waterworks construction, water management technology retail and agribusiness.
Therefore, the proposal to enhance “green infrastructure”, as proposed with large consensus in the Blueprint, should include low technology or traditional irrigation methods. Moreover, lots of information on green water management and rain fed agriculture is available in literature; why are these technologies never mentioned as a viable option to complement blue water management? We guess because there is much less money to be made: with low investment costs and easily managed by farmers, this would lead to much more autonomy for small exploitations from input markets and would reduce the number of farms dedicated to growing water intensive crops, as needed for food industry.
Re-use of wastewater as an alternative supply option
Re-use of wastewater sounds very green, but we have to envision – again - the context:
I- Many rivers are alive thanks to wastewater. This may sound strange, but in Mediterranean contexts the “return” of used water to the environment is really fundamental. We should make sure this wastewater is managed in harmony with the local water cycle and a certain percentage of this treated water should be reserved for environmental flows.
II- Treated wastewater may be seen as a “new source” for water markets.
For example, in Spain we are witnessing the evolution of a new market: companies who treat the water, claim the right sell it. Therefore, re-use may be another reason for the overexploitation and commodification of water.
We cannot accept this CAP reform and need to continue our struggle to preserve our livelihoods: water bodies, biodiversity, food and agriculture are vital to all. We now need to continue monitoring policy implementation processes and reclaim citizen participation in decision making relative to how money provided to our member states for rural development will be spent. Recent negotiations on CAP reform have proven how sensitive governments are to the agro-industrial lobby. We have to defend every field and every farmer from being kidnapped by agribusiness. Fighting against the depletion of water bodies is one of the tools within our reach.
Over the next months, as a follow-up to the Blueprint, the Commission is preparing different stakeholder consultations to implement water policies related to WFD and relevant to agriculture:
- water re-use for irrigation or industrial purposes, including the possibility of a regulation establishing common standards. In 2015, the Commission intends to make a proposal.
- Directive 2006/118/EC on the protection of groundwater against pollution and deterioration (GWD) will be reviewed (Annex I and II) of and come forward with legislative proposals. The Commission will carry out the first review of those Annexes in 2013.
We all know that these consultations are not always very accessible and effective, so we need to work intensively to enhance the communication and mutual support between water and agroecological movements to stop this bubble from growing.
XARXA per una Nova Cultura de l’Aigua, member of the European Water Movement
 Keynote on post 2013 Common Agricultural Policy and water protection in Europe by the CIS Expert Group on the Water Framework Directive & Agriculture / October 2010
 The Commission Communication COM(2010) 672 on CAP reform states that “the inclusion of the Water Framework Directive within the scope of cross compliance will be considered once the Directive has been implemented and the operational obligations for farmers have been identified”.
 Over-allocation occurs when water use permits are handed out by the authorities without respecting the correct explotation rate of a water body. This may lead to cases, like the River Ebro in Spain, where the volume of water people are entiteld to withdraw is higher than the water actually flowing in the river.
 In Water Scarcity and Drought Communication (COM(2012)672) p.5: “uncertainty remains on how water saving at field level is effectively translated into overall water saving at farm and river basin level.” And “modernization [of irrigation] has led to intensification or more areas being cultivated, rather then a decrease in water use.” These aspects wher presented in the Blueprint WFD revision procedure but where not included in the final version; there the benefits of investing in modernizing technologies are considered a certainty even if the need to avoid the “rebound effect” is pointed out – without saying how.
 The concept of green water meant originally the soil moisture when introduced at one of the FAO meetings in 1993 (FAO, 2000). Since then many others have used the concept, such as “Green water is the water held in soil and available to plants. It is the largest fresh water resource but can only be used in situ, by plants” (Droogers et al., 2006. (ISRIC Green Water Credits Report).
 Water withdrawn for irrigation from rivers, lakes and aquifers