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Ciutadella is one of the municipalities where underground water resources are in the worst state, to the point that the new General Plan is currently halted because it cannot guarantee supply for the projected population.

Two years ago, the Sustainable Water Management Plan for the municipality was drafted. GOB submitted comments because there were very concerning situations. Given the chronic nature of these issues for decades, the intervention by the Civil Guard and the judicial complaint, potentially qualifying as an environmental crime due to water management, were considered good news.

Now, it has been announced that the Government is approving the Water Management Plan, but no one has responded to the comments. Therefore, we recall them here so they do not remain in a drawer:

1. Abstractions that do not comply with legal requirements

Of the 76 authorised abstractions, 30 of them have no data on authorised volume. Almost all active wells have extraction pumps that exceed the maximum allowed depth set by the Hydrological Plan. In some cases, water is pumped from tens of metres below sea level, significantly facilitating seawater intrusion.

Many wells are located within safety perimeters of one kilometre, where activities that may pose sanitary risks (such as livestock or industrial operations) are prohibited. Some of the well-meaning proposals included, such as controlling fertilisation and manure management in agricultural operations or relocating certain urban land uses, are often not under municipal jurisdiction or, in any case, require many years of sustained management.

For these reasons, GOB requested that, in accordance with current regulations, any wells that do not comply with the Hydrological Plan should not be counted as viable sources for municipal water supply.

2. Tariffs that do not recover costs

The EU Water Framework Directive requires full cost recovery of the integral water cycle. The new proposed tariffs in the document (introducing a new tier from 1.1 m³/day, with no specific price mentioned) did not appear to ensure full cost recovery.

In this regard, GOB cited key deficiencies that need to be addressed through budgetary resources:

• Reducing water losses in the supply network, which currently exceed 30%.
• Necessary improvements to the southern wastewater treatment plant, where nearly 60% of the flow fails to meet chemical oxygen demand quality standards and shows high salinity.
• Planned expansion and upgrades for the northern treatment plant, where 85% of the flow presents excessive salinity.
• Improvements needed at the Serpentona treatment plant, which receives a daily flow exceeding its hydraulic capacity.

For these reasons, GOB requested a new tariff review that clearly differentiates reasonable consumption from unreasonable consumption, so that the former remains affordable while the latter is truly discouraging and ensures full recovery of the integral water cycle costs in the municipality.

3. Network losses and per capita consumption

Data from the Directorate-General for Water Resources show water losses or unaccounted volumes in the supply network reaching 30.7% in the most reliable years.

The Hydrological Plan stipulates that real water losses in existing urban supplies must not exceed 17% by 2027.

Based on the most reliable data from 2018 to 2021, the direct metered consumption per actual population ranged from 237.27 to 247.98 litres/person/day. To this figure, one must add the volume extracted from the aquifer but lost along the way. Thus, total consumption per actual population rises to 296.1 litres/person/day.

It is important to recall that the Balearic Islands Hydrological Plan establishes a maximum allocation of 250 litres per person per day, considering both the registered and seasonal population. This figure includes all municipal, domestic, commercial, industrial, service uses and network losses (pipelines, reservoirs, and distribution).

In the comments presented, GOB requested that no new growth be authorised in the municipality until compliance is demonstrated with the consumption and network loss limits.

4. No control over agricultural or rural consumption

Ciutadella’s municipal territory includes a significant area of land dedicated to intensive irrigation using tracks or pivots, leading to massive water extraction from the aquifer, especially during the dry season, for fodder crops.

Studies in Menorca estimate that an intensive farm requires about 5,000 m³/ha/year. So, a 20-hectare farm will use around 100,000 m³ annually just for irrigation. In many of these areas, pesticides are used, which may contaminate the water.

This reality is not reflected in the Plan, although it likely represents extractions equal to or greater than urban use. There is no record that these irrigated lands have certified meters or that any farms are submitting extraction records to the water resources authority.

The document also fails to account for the existence or the issues posed by numerous rural clusters, known as “hortals”, located in the municipality.

According to Menorca’s territorial planning instrument, rural settlements in Ciutadella include: S’Hort d’En Vigo, S’Hort d’Es Fasser, Ses Retxilleres, Camí de Ses Vinyes, S’Hort Nou, La Vinya, Montefí Nord, Rafal Nou, Sa Llegítima, Son Aiet, Sant Antoni, Torre Vila, Ses Mongetes, Son Cavalló, Es Caragol.

This significant number of rural properties with houses and gardens, located on rustic land but often established illegally, results in considerable pressure from water abstractions (declared or not), and a near-total lack of sewerage and control over wastewater, which can lead to nitrate and other contamination.

GOB requested that this pressure be incorporated into aquifer extraction estimates. It is possible to estimate agricultural extractions in the municipality based on existing land cover maps, which allow for fairly accurate calculations of the impact of such activities and rural settlements.

5. The desalination plant is no longer enough

The experience of the Ciutadella desalination plant, the only facility of its kind on the island, should serve as a lesson. When a desalination plant is introduced, the message sent to the public is that water availability is no longer a problem. This leads to increased consumption.

But since desalinated water is far more expensive than groundwater, all economic mechanisms attempt to limit replacing well water with desalinated water. The result can be seen in Ciutadella.

The desalination plant was published in the BOE in 2003 and started operations in 2011. Yet, it is still only partially used due to its cost. All growth since then has relied on wells.

Ciutadella receives many tourists, both those staying in holiday developments and day visitors. All these people require water. According to the Sustainable Water Management Plan’s forecasts, even in August 2031, with the desalination plant operating at full capacity, more water will still be needed from the aquifer than today. A scenario that reality cannot sustain.

6. Managing human pressure

When even a large desalination plant is not a solution, perhaps it is time to consider controlling the human pressure we are placing on the island:

• Aquifer depletion is a major environmental indicator, affecting both people and ecosystems (many wetlands are drying up due to lack of freshwater input).
• While we have increased tourist numbers, our per capita income has declined. The economic approach is also failing.
• Perhaps it no longer makes sense to define a carrying capacity that continues to expand the existing tourist accommodation.
• Maybe Menorca should aim to reduce and redirect tourist beds to improve the quality and profitability of tourism.
• Perhaps public funds should no longer be spent on tourism promotion.
• Maybe it’s time to apply limits to human pressure, such as restricting tourist vehicles.