Towards a climate neutral EU:
efficient allocation of EU funds

Mistake to avoid: a non-functional, oversized rainwater reservoir built in an unsuitable protected area, using unsafe materials.

Organisation: Clean Air Action Group, Hungary Website: Added: February 07, 2023
Project start date: July 01, 2020
Project end date: November 15, 2021


In 2021, a 3 hectare rainwater reservoir and a km long concrete-lined channel was constructed in Zsombó village, on the territory of the Kiskunság National Park, which is part of the core area of the National Ecological Network - a priority nature protection area. The construction of the reservoir was justified by preventing inland water damage caused by rainwater -- despite years of drought in the area officially designated as a semi-desert by the UN in 2020. The construction involved the movement of nearly 20,000 cubic meters of soil in the area of the Kiskunság National Park Directorate. The area should have been recultivated by the end of September 2022, however, hills of the extracted soil stand in the middle of the semi-desert plain of high ecological value. It is not known what funds will be used for recultivation, as the project has been declared successful and closed.

The project has been closed despite the fact that the reservoir's water permit expired at the end of September 2022, and its extension has not been requested ever since. The concrete channel is also not connected to the reservoir. The material of the constructed dam is of much lower quality (not retaining water, but allowing it to pass through, making it unsuitable for dam construction) than the one indicated in the documentation, as it was revealed by independent legal and environmental experts. When requesting the necessary prior consent from the Kiskunság National Park Directorate, the municipality provided misleading information to the Directorate about the reservoir plans (a 1,8 hectare area was indicated, which was modified to 3 hectares without notifying the Directorate). When the Directorate discovered the area modification, it was “too late” to stop the project, because the delay would have jeopardized the EU financing. A total of five cases have been reported so far to the police in connection with the construction of the Zsombo reservoir. Investigations are ongoing, including suspected budget fraud and forgery of documents.

A further concern is that while the most efficient way of retaining water would be on the fields themselves, or in many small reservoirs, currently it has been much easier to obtain the necessary permits for large reservoirs, because EU funds can be requested for those, as opposed to the smaller ones. In recent years, at least 14 reservoirs or stormwater ponds have been built in and around the same Homokhátság area, where there has been no major rainfall for three years, and which has been officially designated as a semi-desert by the UN in 2020. Therefore, instead of looking for the most efficient way of spending EU funds on climate adaptation, stakeholders (including authorities and municipalities) prioritize profit maximization (i.e. rent seeking) and tend to realize oversized projects regardless of their actual necessity and impact on the natural environment.

Financial data

200 mil HUF / ~530 000 EUR Share of EU funding: 100 %


- As a precondition for receiving EU money, the legal and institutional system of the given country must be of the highest standard. Only this can ensure the proper use of EU funding.

- Strong civil society and effective independent media (including robust investigative journalism) must constitute a part of such a system.

- Small-scale and nature based projects should be preferred to big developments and constructions. To avoid unnecessary and oversized developments, the justification of the necessity of the project should be pre-approved by an independent professional body. It should be avoided that in certain years, certain types of trending projects (e.g reservoirs, playgrounds, viewing towers) become known for being favorable to receive EU funding, enabling rent-seeking people to implement such projects regardless of their real necessity.

- The information on any investments financed with public money should be disclosed and widely disseminated to all stakeholders in proper time in advance, so that comments could be made before detailed planning and implementation.

- Monitoring and control: it should not be possible that a funding project is successfully closed, when several parts of the project (e.g materials used for dam construction, missing recultivation of moved soil in a national park area) were not completed in the way it was planned and agreed on. If criminal charges are proven, public funding should be withdrawn, and costs should be covered by the responsible person/legal entity. The persons in the authorities which approved the project should also be charged.

- National Park Directorates and other environmental authorities should have the necessary capacity to be able to notice fraud and administrative glitches (e.g. data modified retroactively in a document). Authorities should be independent, not interested in project financing, and make decisions based on purely professional and legal criteria. (Unfortunately, today, this is not the case: Rent seeking is currently often supported by the authorities: permitting procedures are being rushed and pushed through regardless of the risk of causing damage just to keep deadlines and make sure EU funding is not lost.)

Information sources

Other info

European Climate Initiative (EUKI)
This project is part of the European Climate Initiative (EUKI). EUKI is a project financing instrument by the German Federal Ministry for Economic Affairs and Climate Action (BMWK). The EUKI competition for project ideas is implemented by the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH. It is the overarching goal of the EUKI to foster climate cooperation within the European Union (EU) in order to mitigate greenhouse gas emissions.