Filenews 19 May 2024 - by Angelos Nicolaou
The Water Development Department (WDD) was the first to find the violation of the terms of the environmental approval of the Sustainable Development Plan of the Akamas National Forest Park (NFP) in October 2022.
According to a WDD letter dated 8/10/2022 for the implementation of Phase A of the improvement of the main road network of the Akamas NFP, the Department of Forests (DF) and the Department of Environment (IT) were aware that the conditions set for the construction of hydraulic works (bridges and culverts) were not incorporated into the final construction plans of the main forest roads, which fall within the Natura 2000 Special Area of Conservation (SAC) and Special Protection Area (SPA) Akamas Peninsula sites.
As can be seen from the letter of the WDD, which is the competent authority for the protection of watercourses and the conservation of fish fauna, the violation of the terms of the environmental approval of the Akamas NFP Sustainable Development Plan and Phase A for the improvement of the main road network in the protected areas of the Natura 2000 Network, it was first detected in October 2022, i.e. exactly one year before the relevant complaints of environmental organizations filed at the end of October 2023.
It is noted that the relevant conditions set by the WDD in December 2021 concern the protection of watercourses along the main forest roads Aspros Potamos – Toxeftra – Lara and Toxeftra – Avakas – Lipati. These watercourses include the Avgas river, the tributary Hartsiotis and the estuary of the river Toxeftra, where significant populations of the European eel (Anguilla anguilla) have been identified. This species is classified as critically endangered worldwide, in Europe and the Mediterranean, based on the "Red List of Threatened Species of the International Union for Conservation of Nature". The species is also included in the conservation objectives of the Natura 2000 Special Area of Conservation (SAC) Akamas Peninsula.
According to the Reasoned Finding for the project to improve part of the main road network of the Akamas NFP – Phase A', dated 2/12/2021, among others, the following are provided:
"Do not carry out activities (such as debris, waste or construction materials) and vehicle passage/parking in the bed of the rivers Aspros, Kalamouli, Avgas, Ellin Petra and Mychos, as well as in the argakia of Koufa, Trypimeni and Kaskia, where significant populations of eel are found.
Particular attention should be paid to the points where crate pipes are expected to be constructed in the rivers Aspros, Kalamouli, Avgas, Ellin Petra and Mychos, as well as in the argakia of Koufa, Trypimeni and Kaskia, by implementing measures such as: transport and deposition of sludge downstream of the old bridge, permanent presence of water and preservation of low riparian vegetation, as well as collection before and repositioning of European eel individuals after the completion of the works.
For the construction of bridges, apply the following practices in order to limit impacts to an extent that ensures the livelihood and well-being of the fish. Such practices concern, inter alia:
In the case of bridge construction, construct types that do not seal the bed (e.g. with piers and beams).
In cases of construction of bridges where for purely technical or environmental reasons the use of box culverts or cement pipes (kiougia) cannot be avoided, their lower part (foundations) should sink into the riverbed. Their submersion will be at a sufficient depth to be determined by the WDD, always taking into account the dynamics of each water body, to ensure that in case of flooding their foundations will not be revealed and therefore vertical / abrupt altitude differences will not be created along the bed.
In general, in cases of construction of any other type of project on rivers, choose types that in the long run will not create vertical/steep elevation differences, even if there is no maintenance of the project.
Where, for purely technical or environmental reasons, it is not possible to avoid the creation of a vertical/steep elevation difference within the bed (municipalities, etc.), a ramp should be constructed on the upstream and downstream parts, with a maximum slope of 30 degrees and with rough surfaces (e.g. large angular swimming stones protruding significantly from the surface), or provision should be made for the creation of a fish passage, which should be constructed according to specific standards applied abroad, while its detailed plans should be submitted together with the relevant environmental study and the application for planning permission to be approved in advance by the WDD.
Especially in the case of the river Avga and Kalamouli to construct a ramp in its upstream and downstream sections, with a maximum slope of 30 degrees and with rough surfaces (eg large angular swimming stones that protrude significantly from the surface). Especially for the river Avgou, to immediately demolish a recent construction with a retaining wall within the bed and perpendicular to the flow of the river, which resulted in the creation of an obstacle more than 2 meters high that prevents the two-way movement of aquatic organisms and mainly the upward course of eels from the sea to the gorge, in consultation with the WDD.
To make as little impact as possible on the riverbed/watercourse riparian zone and the river ecosystem and sediment."
Changes are needed in hydraulic works
According to the EDA Report for Phase A of the Akamas NFP Road Network, which was issued in March 2024: "The hydraulic works with particular emphasis on those in the Avakas area should be examined by the WDD for changes regarding their functionality in relation to the movement of eels. Propose the necessary measures within 15 days of the adoption of this Report and return to the Ad-hoc Committee for information and discussion". According to a letter from the WDD Director to the Director General of Environment (DGP) of the Ministry of Agriculture, Rural Development and Environment (YGAAP), dated 2/4/2024, on "Review of Akamas SAR projects and infrastructures":
"In the context of the WDD's participation in the Project Team for the Sustainable Development Plan of the Akamas NFP, officers of my Department have examined on site the hydraulic works that have been implemented so far in the context of Phase A of the road network in the Akamas NFP, for which there is significant concern regarding their proper hydraulic operation and the impact they are expected to have on the hydromorphology of the watercourses and the populations of the European eel that live in the river Avga (Avaka).
More specifically, the examination of the projects found that:
- The culverts that have been constructed in large watercourses in the area have serious operational problems, which are expected to lead to water diversion from the existing bed and erosion of road slopes and/or adjacent plots.
- In watercourses, in which large square culverts have been constructed), serious hydromorphological alterations have already been caused, due to extensive earthworks, which are estimated to exacerbate the problem of water diversion outside the bed and erosion of slopes of the road under construction and/or adjacent plots.
- Despite the adoption of modifications by the designer, in the square culverts constructed in the river Avga (Avakas – Toxeftra), which hosts populations of the European eel, which is a species of designation of the Natura 2000 area, however, with the first winter floods, it appeared that these modifications did not bring the expected results for maintaining the continuity of the river and the unhindered movement of eels.
For the above points, a detailed information note is attached. Based on the conclusions reached, the WDD proposes that all hydraulic works of Phase A of the project be reviewed by the designer as soon as possible and solutions be proposed that will solve the above problems. If and where necessary, remove square culverts, redesign and construct crossings with proper operation in mind to avoid erosion, diversion and hydromorphological alteration, ensure the continuity of the river for the movement of eels and achieve the conservation objectives of the Akamas NFP".
WDD: Opposition to the design of construction plans
As stated in the attached briefing note with the views of the WDD on hydraulic works, in the context of Phase A for the improvement of the main road network in the Akamas NFP, which is attached to the letter of the WDD Director to the DG YGAAP, dated 2/4/2024:
"On 9/11/2021, the WDD had sent its views on the Improvement of the road network for the implementation of the Sustainable Development Plan of the Akamas NFP – Phase A' to the IT. For project consideration, plans for the proposed hydraulic works were not available. The views of the WDD were incorporated in the relevant environmental opinion issued on 2/12/2021 and updated on 30/3/2022.
In autumn 2022, the WDD identified the construction plans of the project, as they were included in the tender for the execution of the project and sent a relevant letter to the DF on 8/10/2022, expressing its opposition to the design, as the terms of the environmental opinion for the crossings on the watercourses were not applied.
On 16/12/2022, following a meeting between the WDD and the DFD and the designer of the project, issues related to the design of the project and the disagreements that the WDD had, since the conditions set by the department and included in the environmental report were not taken into account.
The main concerns of the WDD concerned the deterioration in the hydromorphology of watercourses and the creation of obstacles in specific watercourses, in the movement of the European eel, which is a species designated for the Natura 2000 site. During the meeting, the DF informed that it could not make significant changes to the construction plans as any implementation of the WDD requirements would create additional costs, needs for land expropriation and a long delay in the project, with the risk of losing the co-financing of the project. Based on the above, and under the circumstances, the DF accepted only minor design improvements compared to the original construction plans, such as the creation of grooves in the culverts of the hydraulic points and the construction of an ichthypassage ramp in the proposed terrace within the Avga riverbed.
With the implementation of the project and following on-site visits by WDD officers on 6/2/2024 and 1/3/2024, and examination of the hydraulic works at the Akamas NFP, problems were identified concerning the hydraulic operation of square culverts in the large watercourses (Avgas River and Hartsiotis Tributary), for which the WDD expresses serious concerns, as due to the extensive interventions in the bed and slopes of the watercourses, The on-site morphology has changed in relation to the construction plans, which may lead to erosion of the slopes of the road under construction and diversion of watercourses to adjacent plots. At the same time, the modifications made to improve the continuity of the river for the movement of eels seem not to work satisfactorily and do not ensure their unhindered movement.
In light of the latest developments and the modification of parts of the project in order to reduce the environmental impact, it is possible to address in a timely manner the significant problems of hydraulic operation of the projects identified with the construction of the culverts, the hydromorphological alteration of the watercourses, but also to find an optimal solution that satisfies the concerns of the WDD to ensure the continuity of the river, which, due to the pressure for the implementation of the project, were not adequately addressed.
At the same time, the WDD considers that the infrastructure to be built at the Akamas NFP should, precisely because it is an SAR, be a model for future projects, not excluding watercourse crossings, but also for the way important species are managed and therefore the optimal planning should be applied".
Watercourse culverts were covered with deposits
The attached briefing note of the WDD notes the following:
'Limitation of the drainage capacity of culverts due to sediment deposition:
1. The WDD expressed in a telephone communication with the designer, but also in the meeting of 16/12/2022, the opinion that the design of the culverts may create a problem in their drainage, due to the transfer of sediment, which in combination with the altitude of their placement in relation to the altitude of the river bed, can lead in some cases to their filling with sediment and subsequent overflow and erosion of the road, and in other cases the creation of an altitude difference within the riverbed. Already, from the first months of their operation, culverts of large watercourses have been covered to a significant extent with deposits.
2. In these cases, the designer repeatedly stated that the culvert should be systematically cleaned of sediment, which the WDD does not consider an acceptable practice, nor a correct approach for the design and construction of passages on watercourses. In addition, the frequent entry of machinery and disturbance of the bed and ecosystem to clean the culverts and sediments upstream and downstream will have environmental consequences in such an environmentally sensitive area. There are solutions for river crossings that are not needed at all or need very rare maintenance, and such solutions should be chosen especially in sensitive areas."
