Ecologistas en Acción de Toledo has submitted allegations to the informative study of the high-speed line Madrid-Oropesa. The organization highlights the «serious deficiencies» of the environmental impact study and considers that the project should be rejected «due to its socioeconomic unsustainability and the serious environmental impacts it would cause on species and protected areas of the Natura 2000 network and in the city of Toledo.»
Ecologistas en Acción de Toledo believes that the best option for the project is the zero alternative and that, failing that, both the informative study and the environmental impact study should be redone to address their «content deficiencies» and to evaluate alternative routes that do not affect Toledo or the Natura 2000 network in the province.
In an extensive document that has already been sent to the Ministry of Transport and Sustainable Mobility, Ecologistas en Acción de Toledo has expressed its «reasoned» opposition to the Madrid-Extremadura High-Speed Line project in the Madrid-Oropesa section, which has been made public for the third time in the last 20 years, as reported in a press release.
The allegations of Ecologistas en Acción de Toledo have been shared and discussed with other environmental organizations at the national and European level who share uncertainties and doubts about the project. Three main blocks argue the position of Ecologistas en Acción on this project.
Firstly, in relation to the unsustainability represented by the transport model associated with the installation and operation of high-speed railway lines, it must be considered that Spain and Castilla-La Mancha are among the territories with the highest number of kilometers of transport infrastructure (high-speed lines, highways, motorways, etc.), which, according to the organization, entails a huge expenditure of public funds both in construction and maintenance.
«However, this expenditure does not result in affordable prices for high-speed lines for the general population but significant benefits for a few contracting companies, concessionaires, and the tourism sector.»
Furthermore, it warns that the promotion of high-speed is leading to the dismantling and closure of regional and freight lines. «High-speed is not an ally in the fight against climate change no matter how much those who promote these types of infrastructures insist on saying it.»
AFFECTATION OF THE NATURA 2000 NETWORK
A second aspect alleged by Ecologistas en Acción refers to the impact on the Natura 2000 network and threatened species, whose assessment, as it assures, is hindered by a «very deficient» environmental impact study for which only two days of fieldwork have been dedicated, one of them in the middle of August, relying on «outdated» data sources dating back ten to fifteen years.
«This deficient information should have invalidated the environmental impact study from the outset and led to an official complaint against the promoter and those responsible for the study’s rigor.» Among the specific impacts that Ecologistas en Acción has quantified to the best of its abilities, it must be said that the alternatives selected by the Ministry will severely affect the integrity and ecological functionality of an important area of the Natura 2000 network.
Particularly — it explains — the SPA ‘Steppe area of the right bank of the Guadarrama River’ declared for the conservation of habitats typical of steppe bird species in compliance with the European Birds Directive.
And the high-speed line’s route would cut through the middle, warns Ecologistas. The impact on the SPA has been estimated in terms of surface area of at least 500 hectares, as «not only the physical space occupied by the infrastructure must be taken into account», but also the emptying effect it has on steppe species in a strip of 1,300 meters as assessed by scientific studies provided in the allegations.
«The construction in this protected environment of the high-speed line would severely jeopardize the conservation of resident populations of steppe bird species according to the national and regional catalogs of threatened species, such as the great bustard, the little bustard, the pin-tailed sandgrouse, the black-bellied sandgrouse, the Montagu’s harrier, the hen harrier, and the lesser kestrel, or of birds of prey such as the Spanish imperial eagle or the Bonelli’s eagle (some of them in danger of extinction).» Fragmentation and alterations of the habitat, and risks of electrocution or collision (with trains, catenaries, etc.) are some of the most prominent impacts in this regard.
TOLEDO’S DECLARATION AS A WORLD HERITAGE SITE AT RISK
Thirdly, the association has assessed the social, territorial, landscape, and cultural heritage impacts on Toledo that could jeopardize its declaration as a World Heritage City and generate a new urban structure in an already disorganized city.
In this sense, any of the options considered, ‘Toledo Central’ or ‘Toledo Exterior’ to provide high-speed AVE service as a «dead-end» to the regional capital, would have «severe impacts» for one reason or another that are not unrelated to the public debate currently on the table in the city.
«The Toledo Exterior option would lead to higher environmental impacts during the construction phase, and territorial and urban impacts during the operational phase. It involves the construction of a greater number of viaducts over the Tajo River, with the consequent impact on the riverside ecosystem.»
According to the organization, the greater prominence of the peripheral station in the industrial park would also lead to an increase in emissions linked to the movement of citizens from the city center to the periphery, and in the context of the imminent drafting of a new Municipal Planning Plan for the city of Toledo could result in the creation of a new attraction pole in the vicinity of the Santa María de Benquerencia Industrial Park or, «even worse,» around the Villaseca junction.
On the other hand, the Toledo Central option would involve turning the Toledo station into a through station without the need for a change of direction and combining all high-speed services in a single station. As a consequence, the service offered to the population would be better than that proposed by the Toledo Exterior alternative. However, this option, as presented, «ignores the strong impacts» on the landscape of the river and the city as a World Heritage Site and, therefore, «should not be viable.»
In this dilemma, it would be necessary to consider other options that, if implemented, should combine all the conflicting aspects, conclude from Ecologistas en Acción.