Dueville, 18/12/2013

FAILURE ON THE MANAGEMENT OF THE LIFE+ PROJECT SOR.BA - RESTORATION OF BACCHIGLIONE SPRINGS AND HABITAT OF SPA IT3220013 AND SCI IT3220040 LIFE09 NAT/IT/000213

Introduction Speaking as Dueville inhabitants, a town in the outskirts of Vicenza (Veneto region, northeastern Italy), we would like to express our concern regarding the management of the Life+ project Sor.Ba (COD. 09/NAT/IT/00213) which is being implemented in the natural protection area called Bosco di Dueville. Bosco di Dueville has already been incorporated in the network Natura 2000 both as a Special Protection Area (SPA, code IT 3220013) and a Site of Community Interest (code IT3220040). We know this area very well since we are fond of spring water biodiversity, bird watching and of wild nature in general. At first we were excited supporters of an environmental redevelopment project whose plan was the recovery of the natural area. The initial aim was the conversion of an old fish-farming (born and developed during the 60s) in original natural water springs canals and pools. We have taken into consideration the declarations of intent coming from the public authority of the Provincia di Vicenza (i.e. the administrators of the province of Vicenza area, group leader of Life+ Sor.Ba) with great interest, especially when the main objectives that regarded the natural area Bosco di Dueville focused on environmental protection and natural ecosystem valorization. Unfortunately, over the years, we reckon that such appreciable intentions have been repeatedly contradicted by negligence and inappropriateness. As a result, we are concerned that this unique area, characterized by highly valuable and threatened species and habitats - of great natural value therefore - can be altered by the mismanagement and the inappropriateness on behalf of local administrators.

Detailed possible account of facts giving rise to complaint Collecting direct evidence and several documents that provide proofs about the intentions of public authority to modify the use of this natural area, here below we aim to highlight the mismanagement of Life+ proposal and project execution: Alteration and loss of habitat of European Importance (code 3260 water courses from plain to mountain levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation). The site, called Parco delle Sorgenti, is located in the south of the SPA Bosco di Dueville. The area is characterized by a significant presence of habitat 3260 although it is not reported in the regional mapping. Actually part of the area was still occupied by fish-farming during identification
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and monitoring of the natural habitats (i.e. for technical reasons the habitat 3260 is not represented as a whole). Nevertheless, the Appropriate Assessment report (introduced by article 6, comma 3, of Habitat Directive 92/43/CEE), at chapter n. 4, page 27 (document n. 1 attached) Inquadramento dellarea interessata dal progetto, compiled for this Life+ project, highlighted that the basins and channels have fallen into disuse, comprehensive of all banks, are now characterized by a great colony of hygrophilous vegetation that is well represented in all the water spring areas around (In the Italian report you can read as follows: Le vasche e i canali in disuso, compresi tutti gli argini, sono ormai caratterizzati da una folta colonizzazione di vegetazione igrofila che caratterizza tutte le altre zone dellarea delle risorgive page 27, paragraph 5). From photographic documentation attached to the Appropriate Assessment report and from a photo here inserted (Fig. 1), one can deduce that, during planning and even more during the operational implementation of the plan, the Community Interest habitat n. 3260 was predominant along most of the basins once used for fishfarming.

Figure 1Typical vegetation of water springs (habitat n. 3260) in Bosco di Dueville.

To give a measure of its extension, the map here below (Fig. 2) and particularly the area highlighted in yellow (surrounded by a continuous red line), which is the subject of the Life+ project, can be used to estimate an area of approximately 13000 m2 covered by such vegetation.

Figure 2 Area subjected to requalification as a result of Life+ Sor.Ba project. The area highlighted in yellow (ca. 13000 m2) was fully covered by water springs vegetation (habitat n. 3260).

In this context, Fig. 3 underlines how the Community interest habitat 3260 was modified: instead of retrieving the existing waterways (a), the canals were dried (b), larger and deeper basins and canals were created and the habitat 3260 was completely destroyed (c, d).

Figure 3 Existing canals with habitat 3260 before and after destruction.

 The Appropriate Assessment report, in relation to the project action called Reconstruction of the original morphology of spring waters and Bacchiglioncello creek on the basis of land register mapping (In the Italian report you can read as follows: Ricostruzione della morfologia originaria delle risorgive e del corso del Bacchiglioncello sulla base delle tracce catastali, structural intervention I, page 29, document n. 1 - Appropriate Assessment) and in relation to the impacts resulting from the execution of the field works (page 34, paragraph 3), suggested the realization of more economical and ecological sustainable solutions. Such solutions have never been taken into account in the successive project phases. In our opinion, one of the most interesting solution was the following: the hypothesis to originally reconstruct the morphology of water springs and of Bacchiglioncello creek must be taken into account. The same re-naturalization process might be obtained by means of winding of existing canals, with considerable decrease of land movement and as a consequence of intervention impacts (in the Italian report you can read as follows:lipotesi progettuale della ricostruzione della morfologia originaria delle risorgive e del corso del Bacchiglioncello dovrebbe essere riconsiderata. Lo stesso risultato di rinaturazione si potrebbe ottenere con interventi di meandrizzazione dei canali esistenti, con notevole diminuzione dei movimenti terra e quindi di impatto dellintervento). Results of such in-observance are now visible just overlapping two images that show the area before and after the works. Actually, neither the original course of Bacchiglioncello creek was re-created, nor the water spring pools that were positioned just on the right side of Bacchiglioncello are now visible. In place of Bacchiglioncello creek and pools, now one can see a network of backwater bodies (document n. 2 attached). Backwater is the result of the new oversized canals and pools (Fig. 4) that greatly increase the residence time of water (i.e. a very large volume of water that cannot flow in short time), altering the initial design aiming at create a water spring environment.

Figure 4 Overview of the area previously occupied by narrow canals of water spring and now (after works of requalification) composed by large and deep pools, with a very residence time that definitely altered the original vegetation.

Such modification of natural water movement along original spring water canals does not represent an habitat of a Community Interest habitat n. 3260 at all. On the contrary, such habitat was clearly observable exactly in this area before works started (Fig. 1, 3). We want to underline that this is the most important area subjected to requalification, as also suggested by Life+ Sor.Ba proposal. Further confirmation is given from what happened in the so called southern lake (In Italian it is rendered as laghetto sud). Actually, this area had to be converted as habitat 3260, and several works of drainage, re-profiling and construction of upstream and downstream ends were made with the aim to create a water spring habitat 3260. However, the final result was completely different: a
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lake with deep water (at least 3 m depth Fig. 5) with significant eutrophication was created; moreover, it has been observed the presence of many fish carps of great size that show the creation of a habitat completely different from that for which the project was financed (Fig. 6, see also the complete video in http://vecchiobosco.blogspot.it/2013/12/le-carpe.html).

Figure 5 The so called laghetto sud is now characterized by deep water, not representing habitat 3260.

Figure 6 Frames drawn from a video, documenting the presence of fish carps in the newly created pools, symptoms of mismanagement and alteration of the original plan. The entire video is available here: http://vecchiobosco.blogspot.it/2013/12/le-carpe.html.

It turns out to be surprising reading from the website created by the Provincia di Vicenza and dedicated to Sor.Ba project (http://www.vicenzanatura.org/el/p-113.gli_habitat.html, last visualization 27-11-2013) the description of the requirements necessary to identify the water spring habitat 3260: in any case the conditioning factor is the presence of water in motion throughout the whole seasonal cycle (the Italian version is the following: in ogni caso il fattore condizionante la presenza dellacqua in movimento durante tutto il ciclo stagionale). In addition we report what was stated in the descriptive landscape relation (Relazione paesaggistica), which is part of the Preliminary plan (Progetto preliminare) (document n. 3, page 35) drawn by public administrators (Provincia di Vicenza): it is of primary interest on behalf of the province of Vicenza, as the managing body of environmental resources, to give to the area a natural morphology compatible not only with the ancient morphology of Bacchiglioncello creek and water spring canals, but also with the maintenance and recovery of existing - or potentially available - ecosystems. These assumptions are an integral part of the Guidelines for the management of the aforementioned area as it is a Site of Community Interest in addition to being a Special Protection Area (in the Italian report you can read as follows: Infatti precipuo interesse della Provincia di Vicenza, quale Ente gestore delle risorse ambientali, da assegnare allarea un assetto fisico naturalistico compatibile non solo con il recupero morfologico dellantico tracciato del Bacchiglioncello e quindi idrico delle risorgive, ma anche, con il mantenimento ed il recupero degli ecosistemi ancora esistenti o potenzialmente perseguibili. Tali assunzioni fanno parte integrante delle Linee guida per la gestione dellarea citata in Premessa essendo essa, come ricordato, un Sito di Interesse Comunitario oltre che di Protezione Speciale). Fieldworks done in the middle of breeding season for birds. The natural area, that is subjected to redevelopment, has been recognized as a nesting site for typical bird species of wetland for at least 10 years (i.e. from the gradual abandonment of basins previously used for fish farming). Along the canals derived from the old fish-farming, moorhens (Gallinula chloropus), coots (Fulica spp.), mallards (Anas platyrhynchos) and little grebes (Tachybaptus ruficollis) found their habitat. These species, as well as many others, here settled with significant abundance thanks to favorable environmental conditions, as it has been also reported in a document prepared by the local section of LIPU (Representative of Birdlife International in Italy; see document n. 4, pages 3-5) in Vicenza. For this reason, one of the main instructions that were reported in the Appropriate Assessment recommended to implement all the work during winter so as to have minimal disruption of flora and fauna species (In the Italian report you can read as follows: I lavori dovranno essere eseguiti durante il periodo invernale cos da avere il minimo disturbo per le specie floristiche e faunistiche) (document n.1, page 38). This mitigation measure was completely ignored during the requalification of the site. As a matter of fact, all main field works were carried out just in the middle of two breeding seasons with relevant damage especially to aquatic species (Figure 7, representing few frames of a video that well describes the attempt nesting of a little grebe in advanced work. The video is available at http://vecchiobosco.blogspot.it/2013/06/il-principe-delbosco-ha-perso-il-suo.html).

Figure 7 - The frames drawn from a video, available at http://vecchiobosco.blogspot.it/2013/06/ilprincipe-del-bosco-ha-perso-il-suo.html, show how that works of requalification inside the natural area were carried out in the middle of two breeding seasons with relevant damage especially to aquatic species.

Moreover, we want to point out that this issue, in itself serious since the area is qualified both as a Site of Community Importance (SCI) and Special Protection Area (SPA), as well as supported by EC funding, was publicly supported by administrators of the Provincia di Vicenza. They publicly reported that the works of requalification would begin in spring as well as supported the opening of the area when the works were not completed http://www.vicenzanatura.org/it/news/2012/05/02/74/inaugurazione_parcole_sorgenti_del_bacchigl ione/, last visualization 6/12/2013. The opening of the area involved the entrance of hundreds of people in the natural area as invited by the public administration of the Provincia di Vicenza (a video documenting the opening during breeding season is available here: http://vecchiobosco.blogspot.it/2013/12/inaugurazione.html).
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 Since the works to be done throughout the whole period of redevelopment were significantly impactful, the Appropriate Assessment (document n. 1) prescribed that the areas affected by the works must provide interventions to limit the spread of dust and prevent spills of hazardous li quids (In the Italian report you can read as follows: Le zone interessate dai lavori dovranno prevedere interventi per limitare la dispersione di polveri e prevenire sversamenti di liquidi inquinanti, page 38, paragraph 3). We reckon that this mitigation measure was never applied as we have never seen the application of mitigation measures. As an example we want to highlight that the access roads used by the trucks were never wet, although the area was provided by huge amount of water easily accessible. This misuse directly damaged vegetation and birds nesting around. One of the main expectations from local citizens and public opinion was on the hypothesis of restoration of the ancient building previously used for fish-farming which is located in Via Bissolati, Dueville (VI). During the public presentation of the Life+ Sor.Ba, the directors of Provincia di Vicenza (team leader of the Sor.Ba project) proposed a solution that seemed worthy, i.e. the replacement of the dilapidated structure, as a consequence of decades of neglect, with a wooden building that would meet the ecological and landscape requirements of a natural protected area. Such building would have been used as a visitor center for environmental education. This assumption was subsequently confirmed in the project planning, as reported in the document n. 5 (Fig. 8 was drawn from the document), where the old building was compared to the rendering of a new hypothetical environment friendly building.

Figure 8 Images drawn froma project planning representing the old building and the rendering of a hypothetical environmenl friendly building. 8

Conversely, the old building was demolished and its faithful reproduction in concrete was reproduced (Fig. 9).

Figure 9 The new building greatly impacts the landscape and was made of concrete instead of wood.

Furthermore, analyzing in detail the executive project one can see that not only the external structure of the building was maintained: as a matter of fact a functional continuity in the use of the building was maintained. Document n. 6 (a detail is shown in Fig. 10), taken from the executive project, reports the presence of a grid whose presence and declared intended use is water collection from fish-farming activities, most likely with adjoining warehouse and house for the caretaker.

Figure 10 Magnification of a detail that is visible in the executive project and that represent the grid for fish farming activities (document n.6).

The inadequacy of the building and its recovery management is also emphasized by the excessive and unnecessary night-long lighting (Fig. 11) of such building and surrounded area, with negative consequences for avifauna and alteration of biotic communities.

Figure 11 Excessive unnecessary night-long lighting in the natural protected area.

Such uncertainty (or non declaration) on the intended use of the building is dangerous and must be clarified: 1. Why the grids for water collection of fish farming activities were maintained during the recovery of the building, although the building should be dedicate to environmental education activities?
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2. Is it reasonable to think that fish farming activities are still possible? What would the impact of fish farming effluents be on the water and generally on the environment without a water treatment plan? Finally, we want to let you know that on December 22nd 2013, in the area "Parco delle Sorgenti" sited in the Bosco di Dueville, there will be guided tours around the natural site (Fig. 12), although fieldworks financed by EU through Life+ project are not yet complete. Moreover, we want to underline that such folk festival, promoted by public administrators and enriched by typical dishes, misrepresents the ultimate meaning of the Life+ projects and its financing. The aim of the Habitats Directive and the designated Special Areas of Conservation should be the protection of the European natural heritage and the promotion of sustainable activities that involve their valorization.

Figure 12 Brochure of folk festival that will take place at Parco delle Sorgenti although fieldworks are not yet complete.

Conclusions As Dueville inhabitants who care about the area in which they live, we are available to provide more detailed explanations in order to prevent further negative consequences for this natural area, that is an integral part of our cultural identity. We are going to send this complaint hoping that your response can banish our suspicions, i.e. that EU funding for the protection of nature can be used as a Trojan horse. We are afraid that there is going to be a fraud against the public interest and the SPA Bosco di Dueville, just
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in time when the local community is, although slowly, becoming aware of the value of biodiversity and regulatory principles that encourage respect and preservation of nature.

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