• The river management is presented as a necessary flood protection project to deal with the consequences of climate change. The natural river bed and banks will be completely deforested for about 17 km (over 1,400 riparian trees, mostly hydrophilous will be cut down) and fixed with impermeable cement materials and gabions (“grey infrastructure”), which increase water flow velocity and flood discharge.

• The river will be cut off from its natural floodplains (Petreza) and its wetlands, especially the one at the Estuary (1st Priority protected wetland).

• These flood protection methods are considered obsolete and have been abandoned internationally. On the contrary, the EU’s biodiversity strategy for 2030 and the EU Strategy on adaptation to Climate Change, as well as the pending EU Nature Restoration Law, following modern scientific understandings, mandate Nature-based Solutions (NbS), among others, for the purposes of flood protection.

• River management works will cause an increase in the flood discharge at the estuary (according to the project own estimations) and consequently result in aggravation of the flood risk.
• Full flood protection within the project can only be achieved with the construction of a retaining dam; however, the dam is not part of Phase 1 of the project nor is it taken into account in the EIA.
• There is a serious deficiency of the project’s 1st Phase in case of a 50-year rainfall, where there may be overflow near the estuary  with high discharge velocities of at least 80 cumecs (even higher for events with a return period above 50 years).
• In low-lying areas of the town of Rafina, near the estuary, in the event of a flood the rainwater network will not be able to operate due to the enormous force of the water in the planned drainage channel of the Great River. This may lead to flooding of these areas as rainwater will not be drained to a sufficient extent.

• The project will permanently and irreversibly change the natural form of the river, effectively turning it into a stormwater conduit. The planned works completely ignore the wetland character of the river while they are now considered outdated and regressive, both at the European and international level, where the preservation of islands of natural environment and biodiversity in the urban fabric is a requirement.

• Any intervention will cause significant and irreversible damage to the ecosystem of Rafina’s Great River and in particular to the bird species that nest in this area. It is very likely that the Marathon minnow (Pelasgus marathonicus) and the freshwater blenny  (Salaria fluviatilis) will disappear and that there will be devastating effects on the local population of the European eel (Anguilla Anguilla), which will be felt far beyond the borders of Greece.

• The project will have adverse consequences both on the highly aesthetic natural landscape and on the world’s historical and cultural heritage. The area of Pikermi is an archaeological site and landscape of particular natural beauty and has been characterized since the 19th century as the “Acropolis of Paleontology” due to the discovery of fossilized animals dating back seven to eight million years.

• Moreover, on the bed, in the immediate vicinity of it and in the riparian areas of the river, ancient remains of all eras can be found (ancient buildings, cemeteries, aqueducts, reservoirs, dams, Roman aqueduct, etc.).

The project violates the main EU environmental Directives on environmental licensing, habitats, birds, water and flooding. Inter alia:

• The Water Framework Directive (WFD) 2000/60/EC does not allow the degradation of surface waters unless an exception is approved according to article 4 par.7. In the case of Rafina’s Great River, while the planned works (excavations, earthworks, installation of wire cages, cementing of the bed) in the context of the project involve new modifications of the physical characteristics of the surface water system, which affect the natural or ecological state of the river and possibly indirectly the groundwater, such an exception (Article 4 par.7 Directive 2000/60) has not recorded neither in the current River Basin Management Plans (SDLAP 2017), nor in the 2nd revision thereof (2023) currently under public consultation.
• The environmental documentation does not quantify the impact of the project on the A’ category wetland of the estuary, which is included in the Register of Protected Areas of the River Basin Management Plan (Directive 2000/60/EC).
• No impact analysis has been carried out for the survival in the modified environment of the artificial riverbed of protected species, such as the migratory European eel (Anguilla Anguilla) and the endemic Marathon minnow (Pelasgus Marathonicus), nor is it foreseen to take appropriate measures and justify these measures.
• Although the retention dam, which belongs to the projects of the upstream section, was set as a condition for the calculation of the flood supply, it was excluded from the environmental licensing in order to be reviewed in the 2nd phase (after 10 years). This is the so-called “salami slicing” in violation of Directive 2011/92.
• Before the adoption of the presidential decree for the river’s delineation (2021), which is the last stage of the staged “permission”:
  • there was no relevant consultation in violation of Article 9 par.3 of the Aarhus Convention and Article 14 par.1 of Directive 2000/60.
  • no new comprehensive EIA took place, so that it relates to all aspects of the project, which were either not assessed or require a new assessment.
• Flood prevention measures of the Flood Risk Management Plans (Directive 2007/60), such as the promotion of sustainable land use practices, the improvement of water retention as well as the controlled inundation of certain areas in the event of a flood, are not implemented. Instead, the project serves to change existing land uses in the opposite direction, i.e. for residential and commercial development.