As can be seen from the allegations, this is the third time that the Transport Infrastructure Directorate has published the Aginaga tunnel construction project. Although it seems that this project cannot be debated at first glance, it follows that it really needs to be questioned when it is analysed in more detail.

First of all, it should be noted that this project has been a clear response from the administrative bodies responsible for the protection of natural areas since its processing began in 2008. In this regard, the Directorate of Biodiversity of the Basque Government warned in 2008 that the route is included in the area of special protection of the marsh of Olaberrieta and that the construction of infrastructure in it is “expressly prohibited use”, according to the ordination established in the Sectoral Plan for Wet Areas. The Biodiversity Directorate therefore stated that “the project should be redefined in this area”. The Biodiversity Directorate document is available.

In addition, the Wild Animals and Plants Service of the Provincial Council of Gipuzkoa, in its December 2021 claims, has made a rigorous criticism of the main objections it raised in its response to the document on the scope of the environmental impact study "because they have not yet been taken into account". In this regard, it points out that the Aginaga tunnel project is only a small part of a larger project which provides for the unfolding of the railway network between Zarautz and Usurbil. Therefore, it requests the joint environmental impact assessment of all sections of the work projected in the natural space of the Ría del Oria. Furthermore, it proposes a route alternative to prevent the railway project from being run by the marsh of Olaberrieta and the entire Special Area for the Conservation of the Ria del Oria, from Aginaga to Motaondo (Orio). The allegations of the Wild Animals and Plants Service deserve special mention and the document is available.

However, these warnings and proposals have not been taken into account and the Department of Territorial Planning, Housing and Transport continues in its attempt to carry out a project repeatedly questioned by the harmful effects on the natural space of the Ria del Oria.

On the other hand, there has been an incident in which the Basque Government has had to suspend the process of approving the project and restart the processing, since the Directorate General of Coasts and Sea of Spain has requested the dismissal of the project that was submitted to public information last year, as a result of the project's affections to the Public Land Domain. For this reason, the Transport Infrastructure Directorate has re-exposed the project publicly, adding a viaduct in a short space of 30 meters to “reduce” the occupation of landfills planned in the Public Land Maritime Domain of the Marsh of Olaberrieta.

In any case, the Environmental Impact Study considers the impact on the marsh and the Relevant Natural Spaces “serious”. Furthermore, it should be noted that Mount Irisasi and the Vega de Itzao are not exempt from a major impact. These allegations highlight, in addition to the severity of the conditions on the vegetation, the impact of the track 5 meters wide and 3 km long (with included lighting channels) that the project plans to implement from Irisasi to Olaberrias and along the Itzao valley on the current track. This route completely fails to comply with the measures established to ensure the difficult accessibility of these areas of high natural value.

Together with the environmental reasons, the claims claim that the project does not carry out any application study nor does it imply a lower socio-economic evaluation of the work. In this regard, it should be noted that the Aginaga tunnel project was designed in the first years of the year 2000 as part of a broader plan that included the construction of a lot of variants with new routes from Usurbil to Zarautz. However, this plan was launched two decades ago in a context of strong economic growth and strong expansion of infrastructure, and under the present conditions it must be thought that all this is very doubtful. In other words, in the current context, the Aginaga Tunnel project does not present any rigorous justification, let alone when less aggressive alternatives can be proposed for improving the rail network in this section and which do not require the construction of new infrastructures.

Therefore, these claims, instead of building the Aginaga tunnel, advocate an alternative strategy based on the optimization of the current rail system. In other words, an alternative strategy is advocated here to improve the Euskotren line, with more modest actions and without the need to build a new infrastructure, which would allow a frequency of 20 minutes in peak hours if necessary in the circulations between Donostia and Zarautz. To do this, it is proposed the creation of a double track crossing in the old Aginaga station in Txokoalde and the reopening of the station, along with the elimination of the step at the level existing at the entrance of the neighborhood and the adoption of the necessary measures to reduce the environmental impact of the train pass through the Itzao valley and the margins of the Rio Oria.

Finally, it should be pointed out that this document of allegations addressed to the Basque Government to request the rejection of the Aginaga tunnel project is intended to contribute to all people, groups and associations in order to promote an even more urgent reflection. In this regard, in order to ensure that all interested persons and associations have the necessary time to analyse the project and to deal with the matters they deem necessary, an extension of public information and the period of claims is requested at the end of these allegations.