SGW press release on the consultation of the MoE on “cost recovery of water services for all uses”

SGW press release on the consultation of the MoE on “cost recovery of water services for all uses”

Less than two weeks were allocated by the Ministry of Environment for interested citizens to participate not publicly but by email at the ongoing “consultation” on the draft of the Ministerial Decision of the National Water Commission with the title “Adoption of general pricing rules and pricing of water services. Method and procedures for cost recovery of water services of all uses”.  Before cutting to the chase it is worth noting that the process chosen is neither public nor transparent so we cannot characterize it a “public consultation” as the Ministry does. We have decided, however, to share our position on this text posted on August 17 (!) 2016, not only by sending an email to the Ministry but by issuing a press release addressed to all citizens. And we have decided so because this text which was presented amid summer by the National water Commission, by radically changing the way water is billed, converts the common good and essential resource of water to a mere commercialized product for profit.


To a sad demonstration of the quality of the Rule of Law in our country, this draft is being promoted after the failed and persistent effort of domestic and foreign interests for the immediate and full privatization of water services in Greece and unfortunately results in similar consequences to home and other consumers who are now required to pay newly invented “costs” that bring us all face to face not only with the full commercialization of water services but also with that of our water as a resource.

Of course, this irrational and non-scientific attempt to put a “price tag to nature” by assigning “costs” to the preservation of ecosystems and water resources is not an invention of the Greek ministry but is a consistent pursuit of those multinational companies which use “eco-friendly” rhetoric in order to create an “ecosystems market” and even a “water market”, similar to that of Co2 emissions that we have by now evidenced how little it helped to reduce them.

These interests through their lobbyists have managed to “influence” the European Commission’s decisions and thus with the art. 9 of Directive 2000/60/EC, to which the national law is aligning with the MD in “consultation”, the “Full cost Recovery” term was inserted and it was made a guideline for implementation on all Water Services. Hence, in short, under this principle, the member states, when calculating the tariffs of water, they must take into account (as discussed in the second article of the MD under “consultation”) the financial cost, the environmental cost and the resource cost.

To decode the deception against citizens’ interests it is necessary to refer to the three definitions given to these concepts by its creators

A.The “financial cost” is defined as “the economic evaluation of the cost for all projects, infrastructure and processes necessary for services such as water provision, for the uses of Article 2 par. 1 MD. The financial costs include capital costs, operating costs, maintenance costs and management costs.

According to this new definition of financial costs:

1) Consumers are invited to pay once more for infrastructure projects which were paid for decades through a) taxation of generations of Greeks and Europeans (when it comes to infrastructure projects funded by European funds), b) loans that are now part of the unsustainable public debt and c) water bills and fixed fees.

2) They are also asked to pay for non-existent, under construction or shoddy infrastructure projects in regions of the province where in many cases, the competent authorities are unable to provide clean drinking water and sanitation networks do not even exist.

3) They are required to pay the profits of subcontractors who prey on the services sector as it is very clearly stated in Article 4, paragraph 2 bb) since in the definition of the “operating costs” it is included the “cost of concession contracts with third parties”. Just recently such an “innovative” contract was signed by EYDAP which paid a private company to “assess” the existing staff. Such a task was done in-house until today at no “cost” and at any rate it could also be improved in-house if it was necessary.

4) They are required to pay the cost of capital i.e. on the performance of alternative placements (No. 4 par.2.a.av). For example, If a water provider claims that it would earn more if the money given for network maintenance were invested in another activity will we have to pay the “alleged loss of its earnings”? Let us not say naively that water utilities by their constitution have a duty to invest only in infrastructure since only this year EYDAP «invested» € 20,000,000 in Attica Bank. Furthermore, according to the MD consumers must also pay for a secured “reasonable profit” of the private investors in EYATh and EYDAP (Annex 1 a2) without of course quantifying this flexible concept of ‘reasonable’, in a provision of true state “generosity” as if the private investors have any guarantee of profitability when investing in a company in the private sector. This year the dividends that EYDAP distributed were almost 22 million (profits 138 million). But apparently this amount is not “reasonable” and we should all chip in.

B.The “Environmental cost” is defined as “the economic evaluation of the deviation of water status from good status which is required for sustainable utilization of the water resources in accordance with the environmental objectives of Article 4 of Decree 51/2007. “

1) Scientific glory awaits any scientist who succeeds in defining the “cost per cubic meter ‘as the MD claims for the misty “rehabilitation works” (shouldn’t we first study what those might be?) to turn “sustainable” an aqueous stock or a water basin. We wait to see how many municipal water companies and how many municipalities served by EYDAP and EYATh will have zero environmental cost charges unless all regions of the country have no “sustainable” water reserves.

2) Even if science succeeds nothing gives us hope that these policies will. In this plan, no specific action is defined nor is it described as mandatory. The money raised from environmental charges will result in the notorious and largely inert “Green Fund” and from there who knows where and when, since there is no time provision for any rehabilitation works and the only reason why the author characterizes the fee as “contributory” is because otherwise it would blatantly violate the constitution.

3) Isn’t the environmental cost a mere revenue raising fee if we take into consideration a region of the country where the aquatic reserve restoration works would skyrocket such a fee if it was calculated precisely?

4) Quite interesting are two of the exemptions from the environmental charges: (a) users who, by applying appropriate management practices, help to maintain and / or improve the good status of water including wastewater reuse and c) regions with geomorphological particularities or extreme climatic conditions. Does this mean that any big enterprise which has political power because of the jobs they “create” and somehow presents evidence of “good management” will be cleared from these charges? Or even, any inventive politician able to characterize his election area as “geomorphologically particular” will he be able to exclude it from the charges?

5) Only outrageous can we characterize one other provision under which consumers are to pay for pollution of water bodies, even if they did not contribute to it (clause d of paragraph 2 of Art. 5 !!!) and even though this damage is never restored? It would be useful here to have an official answer by the Ministry on how many and which of the recorded cases of water pollution have been restored and who paid for it so far.

6) More generally is it logical from the very definition of this fee to allow for such an uneven burden of the citizens who have the misfortune to live in hydrologically deprived areas and have no competence on the water management in the problematic zone?

C. The “resource cost” is defined as “the economic evaluation of alternative uses of water” which is necessary if the Water System is used in excess of the rate of its natural replenishment.”

This new cost definition reminds us of Chile. There the large copper operators, who can afford to pay more, use water from local springs and rivers while residents end up drinking desalinated seawater, since only such is available at lower prices. Must we henceforth pay in the form of “resource cost” the difference of profit in order to prevent our water being used in another way which results in greater economic benefit?

A large industrial unit of water bottling for example which uses the ground water beyond the rate of natural replenishment will it just pay the “resource cost” and continue making profit while destroying the aqueous stock? How is this consistent with the assumed target of “rational use”?

Finally it is worth noting that from this new tariff calculation method are excluded all water services for energy use (no. 2 par.2.a of RM) and of course it is obvious why when one takes a look at how the energy sector operates in our country.

It is clear to everyone that the above provisions are aimed at nothing other than to give plausible excuses for increasing the price of water in perpetuity, in a similar manner as the electricity bills were doubled by the notorious “regulated charges”.

The flimsy argument that the price increase will lead to savings and rational use, in a miraculous way, is a gross misrepresentation of the economic reality since the ones with the economic capacity will comfortably continue paying their excessive consumption, while those who are economically weaker will have to measure their water consumption with the water dropper.

It is another form of indirect taxation, which severely threatens the human right to access to water and sanitation as it was defined by the UN.

Finally, the logic of full cost recovery is directly contrary to the nature of a public service, the nature of the water companies in Greece which is still valid and protected by the Constitution. Any profit, beyond a reasonable one for the continuation of the operation of the enterprises, which in favor of the public interest, must be reinvested for the maintenance and improvement of infrastructure and networks, is simply immoral and imposed on us who have no other option to have access to the most fundamental resource.

For all these reasons, we are completely opposed to the conversion of the common good of water to a product and we therefore ask for the complete withdrawal of the document under “consultation”.

SAVEGREEKWATER, Initiative for the non privatization of water in Greece

(Note: this text was sent to the Ministry of Environment and as a press release to the media in Greece)


Participatory Unifying Movement of Employees & Retirees ofr a public EYDAP in the service of society

Employees Union EYATH (Thessaloniki Water Company)

Naturefriends Greece

Radical Ecology Network

Citizens’ Initiative for the Abolition of the Superfund of the grabbing of Public Property

SOSte to nero, Coordinating Group of Citizens and Organizations, Thessaloniki

Water Warriors, Thessaloniki

Open Solidarity Comittee  of Tinos island

ECO.POLIS Haidari,Athens

PERI.POL.O. Mani (Enviromental and Cultural Group of Mani)

Athens Initiative for a self organized field at Hellenikon

 Cholargos – Papagos Citizens Network

Initiative for the non privatization of water in Greece


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