Novembre 2018 - Lettera alla Commissione Europea sullo stato ecologico del lago (English version)



Lago di Bolsena



 November 10th 2018



European Commission Directorate-General Environment


Copy to:

PETI Secretariat


Dear Sirs,


Thank you for your letter of 19/09/18 which acknowledges reception of our complaint of september 2nd.


As further supporting material regarding Bolsena Lake, I now inform you that on October 18th, 2018 we presented our observations to the Water Protection Plan of the Lazio Region (PTAR) proposed by the D.G.R. 819/2016. The PTAR includes all of the River Basin Management Plans (as required by the Water  Framework Directive (WFD), Art. 13) for the Latium Region. Before its final approval by the Regional  Council, the PTAR must be submitted for observations to those declaring to have an interest, such as municipalities, associations, and so on.


It is a very important plan, especially for us living near a lake. If no one makes observations "the one who is silent agrees" and the PTAR will be approved in the state in which it has been proposed. For the citizens  and for our lake it would be a disaster. The observations were to be presented to the Lazio Region Commission VIII (Environment) on October 18 th 2018 and then confirmed in writing by October 21st. This is in violation of the WFD, Art. 14.2, which allows “at least six months” for comments.


The Region did not alert the Municipalities inviting them to study the PTAR and to present their observations, thus no municipality in the basin of Lake Bolsena presented itself at the hearing. Those who, like us, requested it, received the text of the plan one day in advance via the link


This PTAR is the first update of the river basin management plans and was due in 2014. Thus it is based on completely outdated environmental data sets. The plan consists of 1246 pages full of data and graphical representations that cannot be read and evaluated in a few hours. However, we presented ourselves at the audition and, with reference to the Bolsena Lake, we have verbally declared the following:


“ The PTAR, as well as every plan, begins with the description of the current state, starting from which the actions to be done are developed. The PTAR abounds in details, but it seems lacking in some parts. For example, the hydrogeological situation is not clearly described.


The lake is of volcanic origin having therefore a very small rainfall basin. The resident time of the lake is 300 years for which the emissary river has a negligible flow: everything that enters the lake remains practically forever.


The insoluble heavy pollutants such as sand fall deposited on the bottom, the soluble ones are in a small part metabolized by the ecosystem, floating excrements migrate slowly to the outlet river and reach the  sea coast of Tarquinia after having left in the lake abundant doses of soluble substances such as phosphorus, which is a nutrient of phytoplankton, causing lake eutrophication.


The PTAR gives a vision of the current state that does not correspond to reality. Describes as "good" the state of the lake and "excellent" the bathing. Starting from this base the Plan is useless, will just leave  things as they are.


But, neither the state of the lake is good, nor the bathing is excellent. On my phone I have a video showing the slurry spills in the lake. Works to restore the sewage system are delayed and abundant sewage continues to reach to the lake.


A few days ago the Mayor of Bolsena gave a public conference describing an alarming situation. At the conference there was a representative of the seaside syndicates of Tarquinia who said: “I come from Tarquinia. When you Mayor said that the river, which actually is a shity river, ends on Tarquinia beach, clearly hit me in the heart ...”


When the restoration works on the pumping stations of the ring sewage collector will be competed,  perhaps we may say that finally the problem of bathing and tourism has been solved, but certainly not that of eutrophication. The damage has already been done during many years of postponement of the works: a large amount of phosphorus coming mainly from sewerage has now accumulated in the lake. In fact the total phosphorus has gone from 8 micrograms per liter in 2005 to 16 in 2017.


For this reason the lake has passed from the classification "good" to "sufficient" breaking the legislative decree 152/2006 that requires that the lakes that are in “sufficient” state have to go to "good" by 2015.  The European Commission is becoming interested to this serious infringement.


I will not say here what should be done since I will present my observations in written form, but  I emphasize that according to article 452 of the Penal Code it is considered environmental disaster the irreversible alteration of the equilibrium of an ecosystem, either when the elimination is particularly burdensome and achievable with exceptional measures, particularly when the damage is produced in a protected area.


I believe that one of the problems of the lake is in the situation of low political importance, given that  voters in the basin represent only 0.3% of the Lazio electorate”.


At the end of the hearing I delivered the following observations in writing.



To the VIII Commission of the Lazio Region

Today 10/18/2018, as President of the Lake Bolsena Association, I present my observations to the PTAR (D.G.R. 819/2016) as required by Legislative Decree 3/4/2006 No. 152 Article 122.


It is appropriate to preface the current state of the lake in its main qualitative aspects: the bathing sanitary quality and the eutrophication process. As far as bathing is concerned, it is sufficient to watch the video (attached) recorded in August, where large quantities of excrements are floating at the exit of some pumping stations of the sewage collector, which then, transported by the currents, reach the pelagic zones.


When the restoration work on the pumping stations of the sewage ring collector will be finished, one can perhaps say that finally the problem of bathing and tourism has been solved, but certainly not that of eutrophication. The damage has already been done during many years of postponement of the repair works: a large amount of phosphorus, coming mainly from the sewage spills, has now accumulated in the lake as shown in the graph taken from a scientific publication. In fact, total phosphorus went from 8 micrograms per liter in 2005 to 16 in 2017.


The European Water Framework Directive (WFD) 2000/60 / EC, concerning the protection of waters, implemented with Legislative Decree 152 article 77, states that the lakes, which were in "sufficient" quality status in 2008, must reach the state " good "in 2015. In our case the inverse happened, the lake, that in 2008 was in " good "state, is currently degraded to "sufficient" as certified by ARPALAZIO for the period 2015-2017. For which imposes, through the PTAR the urgent inversion to “good”.


The Regional Councilor Silvia Blasi and the Councilor of the Municipality of Montefiascone Rosita Cicoria have made an official inspection of the pumping stations and have noted "that the works are currently stopped. On 20 stations only in 4 have been mounted both electrical boards and pumps; in the remaining the boards were present, but not installed. In many stations not all pumps are those foreseen by the project, many electric generators are not functioning.


After the inspection, a meeting was held with the Region, from which it emerged that "at least for the time being, the work on the pumping stations cannot continue, as the available budget has been exhausted, we hope that other funding will arrive to finish the works. As for the water treatment plant at Marta, currently undersized, it will be first necessary to find the funds for the disposal of sewage sludge, a cost that according to what the engineer Proietti said, can be very variable but on average it is around 150 euros a metric ton; whereas the tons to be disposed of are around 5000, a rather considerable amount must be found ". That is 750.000 euros.


The PTAR establishes an order of importance for the various protection and restoration interventions, and allocates funds according to the needs of the basins. In this regard, our observations and requests for updating the PTAR with reference to the Lake of Bolsena (Marta basin) are:


1)   The assessment of the quality of Lake Bolsena as "good" (page 235, table p. 295) is erroneous. Both the Lazio ARPA (summary table of the ecological and chemical status of the lakes of Lazio - monitoring period 2015 - 2017), and an authoritative scientific publication (R. Mosello et al: Long-term change in the trophic status and mixing - The regime of a deep volcanic lake - Lake Bolsena, Central Italy) shows that the state of the lake is currently "sufficient".


In addition, the definition of the objectives ("maintenance", Table 8-5, page 323), the criticality indexes (Table 8-4, page 320) and the calculation of investments (Table 6-5, page 225) ) are to be reviewed. This


considering that (as we read on page 333): "The minimum quality objective of the resource imposed by the Water Framework Directive (2000/60/EC) is the" good ecological status "of water bodies, and this objective is to be considered "non-negotiable". Furthermore, this directive puts a ban on the deterioration: these  two violations of the directive are under investigation by the European Commission.


2)  We also contest the classification of bathing waters as “excellent” (4.1.9 and table 4-1 (page 162), which is a consequence of the low frequency of monitoring and the too low number of sampling points, in violation of the Directive 2006/7 / EC for water bodies with frequent "short-term pollution" such as Lake Bolsena. The clear demonstration is the fact that the lake area - 22 Road connection S. Antonio - where during the summer 2018, during several months, all the sewage waters of the four northern municipalities were seriously leaking, the bathing is qualified “excellent”.


3)   Conservation measures, in the Special Areas of Conservation of the European Natura 2000 network, protect the environment and preserve its integrity, thereby reducing the costs of restoration and conservation. The conservation measures adopted by the Lazio Region for Lake Bolsena do not meet the criteria of the Habitats Directive (92/43 / EC), and consequently involve additional costs. The PTAR should foresee the adaptation of conservation measures to the legislation.


4)   Costs of infringements of European legislation: for the Lake Bolsena the EU PILOT 6800/14 / ENVI pre- infringement procedure is underway due to the missing application of Directive 91/271 / EC. Investigations are being conducted for the violation of the Water Framework Directive. Three Italian Courts are investigating for crimes against the environment related to lake pollution. The economic and critical indicators should take into account these investigations and the urgency of resolving violations of European legislation, even considering the heavy penalties following convictions by the European Courts (see convictions C-251/17 31 May 2018).


5)  The malfunction of the final part of the ring pipeline and the purifier located on the river Marta have for years heavily polluted the river Marta and its mouth in Tarquinia. Currently, all the sewage waters of the municipalities of the lake end up in the river without purification, with serious damage to the ecosystem of the river and to the seaside tourism of the municipality of Tarquinia and neighboring areas. Economic and critical indicators should take into account the urgency of solving these problems.


Considering all these premises the PTAR must intervene on all causes of pollution. The interventions necessary to obtain a hypothetical restoration do not only concern the collector, for which however additional works are needed, but also: municipal sewers; the shoreline to the west which is without collector; the abusive sewers and agriculture pollution. The measures we consider necessary are the following:


1.  Update the restoration project of the consortium sewage system

The current sewage system restoration project dates back to 2012, while the tendering process was made  in 2016. During the four years of referrals (now six years have passed) other unforeseen works were necessary that led to additional works. The original project was supposedly designed for savings because it did not include some chapters that need to be included to bring the lake back to a "good" state:

-  testing of the pipes actually outdated;

-  the radio control system;

-  temporary catchment areas in the event of excessive rainfall,

-  a fair supply of spare parts.

The aforementioned works must be assigned without a call for tenders for emergency reasons. It is also necessary to ensure annual funding for the maintenance of the sewage system to prevent the restoration work from deteriorating in the future and the system returning to its previous state. Also the financing for the elimination of the sludge lying in the purifier has to be solved.


2.  To study how the part of the coast to the west, that has remained without a collector, can be protected The extension of the current collector is too complicated, local phyto-purification proposals should be studied which could be co-financed by the European community if they are really innovative.


3.  Review and adjust municipal sewers in parts that spill into the lake or into ditches


This chapter is too burdensome for the individual municipalities because in many cases it is necessary to separate the white and the black waters. The costs are too high to be borne by the municipalities for which extraordinary regional funding is needed.


4.  eco-friendly incentives for agriculture specific to lake basins


In the past, extensive agriculture was encouraged, believing that water was abundant. Quantitative problems then occurred, so much so that the flow of the emissary river is halved. Recently, highly polluting hazelnut crops have been encouraged for all lakes, as for the lake of Vico.


5.  measures to prevent illegal use including biological pits to be lost in the hydrogeological basin


According to an estimate of the Cobalb there are 300 isolated dwellings not connected to the collector, as well as zoo technical installations. The village of Felceti in Valentano pours sewage towards the lake in the frequent cases of malfunctioning of its own purification plant located on the opposite side of the basin.


6.  opposition to geothermal energy in the hydrogeological basin


According to expert studies, geothermal plants in the basin can cause arsenic to rise up in the lake, causing an additional pollution of arsenic to be avoided in an absolute way. Castel Giorgio plant in Umbria takes geothermal fluid from Umbria and unloads it to Lazio without authorization.


7.  Additional note


The Water Framework Directive requires the drafting of a Water Protection Plan. According to the Habitats Directive, each Plan and Project must be subjected to the evaluation of incidence.


The PTAR, in order not to run the risk of being contested in its entirety, requires the evaluation  of incidence. In the current version the information on Lake Bolsena and all the other sites is fragmented in 1254 pages extended to the whole Lazio Region, in large part they are descriptive, scarcely planning: the Assessment of Incidence in this situation appears complex. We suggest that the PTAR be split into chapters, each of which concerns a specific hydrogeological basin. Each chapter should state the current state well separated from the protection plan, and then submit only the latter to the impact assessment.


Geothermal energy should be included in the protection plan as a possible groundwater pollution hazard due to geothermal fluids, characterized by a high concentration of arsenic and other carcinogens.


Unfortunately, a part of the basin of Lake Bolsena is located in Umbria where there is a real risk that the plant of Castel Giorgio will be authorized, whose waste would pollute the Lazio region.


Finally, we would like to remind that in June 2009 the Province of Viterbo approved the Lake Management Plan (PdG), as part of the third supplementary agreement of the "sensitive areas" (APQ7) framework program agreement. It was created by the Province of Viterbo with the collaboration of the University of Tuscia and Lynx Nature and Environment Society. The PdG indicates the provisions formulated by experts  of the lake ecosystem, based on an extensive general study in compliance with the principles established by the Habitat Directive, but it was ignored by the Lazio Region.


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 Very truly yours.

 Piero Bruni - Associazione Lago di Bolsena