26179 - El Jadida RADEEJ

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Environmental & Social Review Summary

Project Number

26179

Company Name

Régie Autonome Intercommunale de Distribution d’Eau et d’Electricité d’El Jadida (RADEEJ)

Date ESRS Disclosed

Feb 7, 2008

Country

Morocco

Region

Africa

Last Updated Date

Sep 30, 2022

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Apr 3, 2008
Signed : Apr 29, 2008

Sector

Water and Wastewater Utilities

Industry

Infrastructure

Department

Regional Industry - INF Africa

Project Description

RADEEJ is an inter-municipal public enterprise providing water supply, sanitation and electricity distribution services in El Jadida, Morocco. The proposed investment is a partial credit guarantee for up to MAD 150 million ($19.5 million) for a loan to be provided by local banks to RADEEJ for investments in sewerage infrastructure. The total project, with an estimated cost of MAD 550 million ($72 million), includes rehabilitation of collection infrastructure and construction of treatment and discharge facilities, and would bring El Jadida and nearby municipalities up to national standards defined in the National Liquid Sanitation Plan (PNAL). RADEEJ is working on extending its sanitation services to include the municipalities of Sidi Bennour, Azemmour and Zemamera, as well as the rural communities of Oualidia and Ouled Frej.

The scope of activities in El Jadida will include:

- Rehabilitation, upgrading and extension of the sewerage network including a coastal interceptor line approximately 3.9 km in length ($22 Million)
- Design and construction of a wastewater treatment plant ($11.50 Million)
- Design and construction of a sea outfall ($33.50 Million)

Overview of IFC's Scope of Review

The scope of review of RADEEJ''s compliance with IFC’s Performance Standards included evaluation of RADEEJ''s management capacity of its environmental, social, health and safety performance. The review relied on documents and reports made available by RADEEJ, IFC technical consultant’s report, and interviews conducted by IFC staff during their site visits. During the visit IFC staff conducted interviews with key management personnel including RADEEJ''s Head of Water and Sanitation Division, Head of Human Resources and various operational managers and staff.

E & S Project Categorization and Applicable Standard

Performance standards (PS) that are applicable for this investment include:

- PS1: Social and Environmental Assessment and Management System
- PS2: Labor and Working Conditions
- PS3: Pollution Prevention and Abatement

The following Performance Standards do not apply to the project in El Jadida:

- PS4: Community Health, Safety and Security

There are no adverse community health, safety or security issues with the sanitation project in El Jadida.

- PS5: Land Acquisition and Involuntary Resettlement

Land for right of way alignments for sewers, interceptor pipe, treatment plant and ocean outfall structures are owned by the government. Land that has been acquired or is in the process of being acquired is neither inhabited nor used for any activity. Also, any acquisition of land by RADEEJ will be consistent with Moroccan regulatory requirements which have been determined to be consistent with relevant World Bank policies.

- PS6: Biodiversity Conservation and Sustainable Natural Resources

No known impacts from project related activities in El Jadida. An EIA will be conducted to examine any related issues with discharge of effluent through the ocean outfall.

- PS7: Indigenous Peoples

No known indigenous peoples are known to be within the project areas of El Jadida.

- PS8: Cultural Heritage

The sewerage system in the Portuguese City section of El Jadia is a UNESCO World Heritage site, and was renovated by RADEEJ in 2004-2005 in accordance with Moroccan law. No additional cultural heritage sites have been identified within the scope of this project.

This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects. RADEEJ’s operations help extend water and wastewater treatment services in a region with limited infrastructure for safe disposal of sanitary and industrial wastewater. Wastewater treatment services provided by RADEEJ help in environmental protection and enhancing public health through treatment and disposal of sewage.

Environmental and Social Mitigation Measures

RADEEJ has presented plans to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - Moroccan laws and regulations, IFC Performance Standards and applicable World Bank/IFC guidelines. Information about how these will be addressed by RADEEJ is summarized in the paragraphs that follow:

- Social and Environmental Assessment and Management Systems:

RADEEJ conducts environmental and social assessment for projects according to Moroccan law. RADEEJ’s activities in the construction, operations and maintenance of sanitation infrastructure require close coordination with local government departments. Projects are undertaken after conducting an assessment of project impacts and subsequently undertaken after obtaining the necessary regulatory clearance and permits.

RADEEJ has overall responsibility for ensuring consistency and compliance with Moroccan regulatory requirements. RADEEJ has demonstrated its capacity in managing large projects (e.g. the present interceptor works), with the support of consultants. For its design, engineering and procurement, potential impacts of the project are identified during the project planning stage, and are used to prepare specific environmental control plans containing identified solutions consistent with local regulatory requirements. Routine monitoring and supervision activities are undertaken by operational staff, including periodic reporting on key environmental and safety control factors, such as effluent quality and employee-related incidents. Human resources are managed effectively at the corporate level by the Director General via a HR department, which has oversight of all RADEEJ’s facilities and operations. Oversight of environmental, worker health and safety and human resources to comply with Moroccan laws and regulations is at the corporate level by various directors.

RADEEJ relies on subcontractors and consultants for providing training to its staff on an as needed basis. To improve its training program, RADEEJ is working on a partnership with the El Jadida University to provide job specific training to its employees. Contract workers are contractually obliged to have adequately trained workers and comply with applicable Moroccan standards. As required by Moroccan regulations, RADEEJ provides status reports such as those for environmental and health and safety performance to the relevant government authorities.

- Labor and Working Conditions:

RADEEJ has a human resources department which has oversight of its 500 employees. RADEEJ complies with Moroccan labor legislation for all its employment relationships, including laws and regulations on acceptable conditions of work, monthly minimum income and maximum permissible workweek. Morocco has ratified ILO Convention 98 (Right to Organize and Collective Bargaining Convention, 1949) and the main ILO Conventions on forced labor (Conventions No. 29 and 105), child labor (Conventions 138 and 182) and discrimination (Convention No. 100 and No. 111).

The workforce at RADEEJ is unionized, and has the same terms of employment as other public service employees in Morocco. Morocco’s Labor Code protects trade unions against employer interference and prohibits dismissal or discrimination of workers due to union affiliation or participation in union activities. The minimum employment age is 18 years. The Constitution and Labor Code prohibit forced labor. RADEEJ requires and monitors subcontractors for compliance with all relevant Moroccan labor legislations including those for occupational health and safety.

Facilities are audited annually by regulatory agencies and in compliance with Moroccan regulations. The Labor Code stipulates that the employer is obligated to take all measures necessary to effectively protect the lives and health of workers, maintain adequate safety and health conditions, and provide the necessary tools to prevent occupational accidents and diseases. RADEEJ sewerage workers receive immunization and are adequately equipped and trained on the use of PPE such as gas detectors, ventilation equipment, masks, etc.

RADEEJ will require its contractors to comply with all relevant requirements of Moroccan legislation and IFC’s Performance Standard 2. Construction and other contracts will specify occupational health and safety commitments to be observed by the contractors and subcontractors, as well as monitoring responsibilities. To ensure documented consistency with Moroccan laws and IFC Performance Standards, RADEEJ will review and update its Occupational Health and Safety procedures and training programs

- Pollution Prevention and Abatement:

In El Jadida a combined system collects and conveys domestic and industrial effluents, as well as stormwater to 5 points on the seashore where they are discharged without any treatment. An industrial pretreatment program regulates discharge of industrial effluents to municipal sewers to comply with national regulations and standards. Currently about 90% of the El Jadida population is connected to the RADEEJ sewer system, while the remaining population relies on on-site sanitation. RADEEJ presently has the responsibility for management of sewerage systems in El Jadida, as well as emptying of septic tanks of customers who are not connected to the sewer system. Discharge of untreated sewage to the ocean is is not regulated by Moroccan law at the present time. However, due to contractual obligations with the El Jadida municipality, discharge of treated effluent at the ocean outfall will be consistent with Moroccan law for effluent quality applicable to discharges to inland water bodies.

As a part of the project, an ocean outfall will be constructed to discharge treated effluent. Subject to completion of detailed studies and an EIA, it is expected that the point of discharge will be approximately 2,000 meters from the shore line within the territorial waters of Morocco. The area of discharge is not subject to any international treaties or conventions that restrict the discharge of effluent. Impact of discharge of effluent to the ocean will be assessed by a consultant as a part of the EIA. Design of the wastewater treatment plant and the ocean outfall will take into consideration and mitigate any potential impacts that may be identified during the EIA process, in addition to meeting local regulatory requirements.

Sludge (from sewers and septic tanks), greases, and debris from sewers are bagged and sent to the municipal sanitary landfill for disposal. Hazardous materials are managed consistent with Moroccan regulatory requirements. RADEEJ will retain a consultant to recommend alternatives for the disposal of sludge from the proposed wastewater treatment facility.

Stakeholder Engagement

Dialogue and communication with affected communities including public consultation and disclosure of environmental and social impact assessment occurs through procedures established by host country regulations. Specific procedures will be developed to incorporate community engagement, including clear procedure on disclosure and consultation with potentially affected communities. RADEEJ will establish methods for communicating environmental and social aspects to external interested parties and maintain procedures for receiving, documenting and responding to concerns from any external interested parties relating to the project.

For more information, see the company’s website: http://www.radeej.ma, or contact:

M. El Hassan BOUKOUTA, Directeur
Régie Autonome Intercommunale de Distribution d’Électricité, d’Eau et d’Assainissement de la Province d’El Jadida (RADEEJ)
Avenue Houmane El Faouaki
B.P. 55
EL JADIDA
MAROC/MOROCCO

Telephone: +212 (23) 34.21.98/34.35.98
Fax:+212 (23) 37.38.96

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.

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Environmental & Social Review Summary

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E & S Project Categorization and Applicable Standard

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Environmental and Social Categorization and Rationale

Environmental and Social Mitigation Measures

Environmental and Social Mitigation Measures

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