What should be done for Rafina’s Great River
Why we are against the project
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 The planned works completely ignore the wetland character of the river while they are now considered outdated and regressive, both at the European and international level, where the preservation of islands of natural environment and biodiversity in the urban fabric is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.
The multiple benefits of NbS in addressing riverine flooding
Nature-based Solutions (NbS) is an innovative concept that takes the form of natural systems, as opposed to conventional “grey” infrastructure solutions. NbS are crucial first and foremost for addressing the biodiversity crisis, for meeting EU and international goals for climate change mitigation and adaptation, and for supporting the transition to a more nature-positive economy.
Floodplains and river wetlands provide seasonal aquatic habitats, create corridors of native riparian forests and create shaded riverine and terrestrial habitats. Furthermore, they help to retain and slowly release discharge from water bodies as well as to facilitate groundwater recharge and improve water quality. River and floodplains contribute to the good hydrological regime and cope with climate change effects.
Improving water storing capacity in the floodplain through Natural Water Retention Measures (NWRM) can be useful to reduce flooding risk. The implementation of NWRM can also occur on farmland; in general the land remains property of farmers and is used for temporary water storage. Retention areas are meant to receive the peak discharge of rivers and therefore to prevent flooding elsewhere. Emergency retention areas can be located along the major rivers to receive large quantities of water in extreme conditions to prevent life-threatening situations and large damage elsewhere in e.g. urban or agricultural areas.
To this end, methods have been designed to support the funding of projects based on NbS. In Greece, a pilot project to address riverine flooding with Nature-based Solutions in the Thessaly Region, Greece (pre-feasibiity study, 2022) was co-funded by the European Investment Bank.
EU funding for a project against EU Strategies and Law?
At the EU level, the EU Biodiversity Strategy for 2030, the EU Strategy for adaptation to Climate Change and the EU Nature Restoration Law under adoption require the restoration of at least 25 000 km of EU rivers to a free flowing state up to the year 2030 through the removal of primarily obsolete barriers and the restoration of floodplains and wetlands. According to the United Nations, there is a critical need to triple the annual investments in NbS globally by 2030.
In view of the above, it is absurd that the management project of Rafina’s Great River, which is totally based on “grey” infrastructure, is funded at a percentage of almost 83 % by assets granted by the EU (EIB & NSRF / Cohesion Fund) and the Council of Europe Development Bank.
In a similar project in the Erasinos river, which is part of the same flood protection financial package and applies “grey” infrastructure as well, the EIB’s Complaints Mechanism (CM-EIB) found the project to be in direct contradiction with recent scientific data and in breach of EU environmental law. According to the CM-EIB, no EIB funds should be used by the Greek authorities until the Erasinos project is redesigned in full compliance with EU environmental law.
What should be done?
In view of the above, we ask that:
- The Rafina’s Great River management and delineation project be redesigned as a climate and biodiversity-positive project that contributes to a number of Sustainable Development Goals (SDGs) in full compliance with EU environmental law (including the EU Nature Restoration Law currently under adoption), the EU Biodiversity Strategy for 2030 and the EU Strategy for adaptation to Climate Change.
- To this end, technical guidance and EU funding should be directed towards a pre-feasibility study on the use of a range of Nature-based Solutions (NbS) for flood risk reduction, water quality improvement, biodiversity and climate change adaptation.
- Until then, no EU and CE funds should be used by the Greek authorities.
- In the meantime, for the purposes of flood protection, urgent interventions should be made only in technically inadequate bridges and dangerous narrowings of the river.
Environmental protection as a human right
The region of Attica (with Athens as a capital), which concentrates 40% of Greece’s population resulting in very heavy environmental charges, has been ravaged by large fires in the recent 10-20 years. Eastern Attica where Rafina’s Great River flows, has been significantly affected as well (e.g. in 2018, 2022, 2023). Moreover, Attica (and Greece in general) has been hit by severe heatwaves in the recent years, including this summer. A few days ago, highly esteemed academics warned about the risk of desertfication of Attica and even of an environmental collapse of the entire system in the years to come (see relevant news articles here and here).
In such a context, the heavy impact of Rafina’s Great River channelization project on biodiversity, the micro-climate, the water bodies and the environment in general, constitutes a severe threat to our well-being and even to our physical and mental health.
Moreover, regarding the endangered migratory species, the degradation of the physical and cultural landscape and the world cultural heritage, the effects will be felt far beyond the borders of Greece.
We claim our right to a healthy, protected and sustainable environment!
In July 2022, the United Nations welcomed the recognition by the General Assembly that a clean, healthy, and sustainable environment is a human right. The same right is recognised in Article 1 of the Aarhus Convention.