While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

PS1 Social and Environmental Assessment and Management Systems;
PS2 Labor and Working Conditions;
PS3 Pollution Prevention and Abatement;
PS4 Community Health, Safety and Security;
PS5 Land Acquisition and Involuntary Resettlement;
PS6 Biodiversity Conservation and Sustainable Natural Resource Management; and
PS8 Cultural Heritage.

PS7 Indigenous Peoples is not applicable to this project as there are no project affected people who would be considered indigenous, as defined in PS7.

In support of its offering a loan to the Government of Senegal, which included for an urbanization program, the World Bank categorized its Dakar Diamniadio Toll Road project as a Category A and conducted a full scale environmental and social assessment with its applicable policies. As part of the larger project, the following impacts will have to be carefully managed: (i) impacts on 30,000 inhabitants and reinstallation of about 3,000 families; (ii) the division of a congested urban area by the highway; (iii) the crossing of a classified forest; (iv) and the closure of an irregular landfill will have to be carefully managed.

IFC has also categorized its project as A because of the specific impacts from the resettlement of approximately 20,000 families, coupled with the crossing of a classified forest.

IFC has reviewed the assessment of the Project’s environmental and social impacts and risks. A key component of this assessment has been the environmental and social action plans prepared by APIX, with the assistance of the International Development Association (‘IDA’) of the World Bank Group, particularly with respect to resettlement, the closing of the Mbeubeus irregular landfill, and the impacts on the Mbao Classified Forest. Furthermore, IFC consulted with its World Bank colleagues and reviewed the information in the World Bank Project Appraisal Document. The implementation of these plans by APIX - and SENAC’s plans to mitigate those impacts and risks under its control - provide sufficient reassurance that, upon implementation of their proposed plans and IFC E&S Supplemental Action Plan (ESAP), that the Project will be developed in accordance with the IFC’s Performance Standards on Social and Environmental Sustainability (“PS” or “Performance Standard”). Findings of the IFC’s review and conclusions are summarized for each applicable PS in the paragraphs below.

PS1 - Social and Environmental Assessment and Management Systems

The Agence Nationale Chargée de la Promotion et de l’Investissement des Grands Travaux (APIX, s.a.) is the government agency in charge of environmental and social assessment for the World Bank project and IFC’s project and particularly the resettlement and compensation of the project affected people. Because APIX is responsible for all sections of the road, an environmental and social impact assessment (ESIA) has been undertaken on the entire toll road right of way and the resettlement site, not just the portion under consideration for financing by IFC. The ESIA included soil and groundwater analysis and concluded that groundwater cannot be used for drinking or agricultural purposes, because of this, water will have to be piped into the site and agricultural activities using groundwater should not be allowed at the Tivaoune Peul resettlement site; APIX, s.a. advised that each tenant will sign a release letter to confirm that they understand that the groundwater is not to be used for drinking and agricultural activities (the resettlement is further discussed in PS5). Furthermore, the ESIA describes potential impacts on and offset option for the Protected Forest of Mbao (this is further discussed in PS6 below). Several other alternatives to and designs of the proposed toll road were considered in the ESIA prior to selecting the proposed project. Alternatives considered in the analysis include improving the existing road, other designs for the highway, and a further extension toward Thies. The current project design was selected because it best addressed economic, social, environmental, technical factors whilst achieving the project goal of decongesting the route in and out of Dakar.

SENAC is responsible for the finance, design, construction, operation and maintenance of the concession. SENAC has subcontracted the design and construction to a joint venture composed of Eiffage TP and Eiffage Senegal (the EPC Contractor) which is one of the reputable construction companies in Senegal and has been operating in the country since 1926. Both companies have received the following certifications: NF EN ISO 9001 for Quality Management System and NF EN ISO 14001 for Environmental Management System. SENAC and the EPC Contractor have a joint Environmental Management Plan (EMP) that takes into account the requirements of the concession agreement and also includes a health and safety check list. Furthermore, SENAC has a Health, Safety and Security Plan (HSSP) to manage various aspects of the project and as such will have HSS coordinator during construction phase. SENAC will also have an Environmental Health and Safety Manager onsite to ensure proper implementation of the EMP and HSSP. The EPC Contractor will enhance the Environmental Management Plan for the Project prior to construction phase so that it will comply with IFC’s environmental and social requirements applicable to this project. SENAC will operate the toll road with the technical assistance of APRR, which is experienced in managing toll roads payment system and is part of the Eiffage Group.

SENAC provides a Quality Assurance (QA) Manual template to its contractors, subcontractors or any other service providers and requires that they provide a copy of their completed Quality Assurance Manual to SENAC and distribute it within their organization. The QA Manual is required to meet ISO 9001 and 9000 norms. Prior to commencement of works, service providers must submit a QA plan to the SENAC project director for approval. External audits of the implementation of the QA system will be undertaken on regular basis.

As part of this investment, SENAC will report on its environmental, social performance, as well as development impact on an annual basis. IFC will also require that an independent third party consultant verify the monitoring data and that progress on the environmental and social action plan be disclosed at least annually to the affected community. SENAC has devised a reporting framework for the EPC Contractor to report on its activities, environmental non conformities, and accidents. In addition a Technical Committee comprised of APIX, EGIS, SENAC and AATR meet on a monthly basis to review project progress. Furthermore SENAC is in the processing of creating a monitoring committee comprised of staff from Eiffage, SENAC, NGOs, investors (public and private), and APIX. The purpose of this committee is to analyze and measure factors such as the socio-economic impacts of the construction phase, environmental protection, sustainable activities, and the increase of activities around the highway (i.e., traffic, industrialization). SENAC in coordination with APIX is currently studying the option of having a station on the construction site to facilitate communication with the affected community as well as provide easy access for the community to lodge any grievances.

Based on our review SENAC will need to address in their ESMP a community grievance mechanism, as well as community health and safety issues during construction and operation. Furthermore, they will need to include adherence to the IFC Performance Standards and Guidelines in their construction contract in order to meet IFC’s requirements under PS1.

PS2 – Labor and Working Conditions

SENAC has not yet fully developed its own human resources policy and procedures; however it follows that of Eiffage Senegal with a focus on compliance with local labor laws. Prior to employment, employees are required to take a medical exam to confirm their physical aptitude to meet the job requirements. SENAC does not hire candidates under 18 years of age and requires proof of identification prior to employment. Each employee (open ended or short term) is provided with a written contract that stipulates: (i) salary; (ii) terms of contract; (iii) terms of reference of the job; (iv) holidays (entitled after one year of service); (v) maternity leave; (vi) medical benefits through Institut de Prevoyance Maladie Eiffage Senegal (which are extended to employees’ spouses and children); (vii) probation period that varies between 8 days to 3 months depending on the employees’ grade. As per Senegalese labor laws, the employees have the right to join a union and to bargain collectively, in addition, workers’ grievances are addressed through the union. SENAC will contractually require that all subcontractors respect Senegalese labor laws and will undertake a basic due diligence on the subcontractors through a screening process before they are approved.

Fire and life safety aspect as well as occupational health and safety are addressed in the Company’s Health Safety and Security Plan.

As part of this investment, SENAC will be required to develop a human resource policy and procedure or employee handbook, which will include section describing grievance mechanism, the right to freedom of association, the performance evaluation system, and the terms of the contract in order to meet the requirement of PS2.

PS3 – Pollution Prevention and Abatement

The EPC contractor is responsible for obtaining all permits and approvals. SENAC is required by its contract under the concession agreement to execute the construction and operation phase in accordance with environmental protection regulations of the Government of Senegal and to implement an Environmental Management Plan and monitoring program based on the mitigation measures in the EIA and permits. As previously discussed, the EPC contractor is ISO certified for Quality Management System and Environmental Management System. SENAC will, however, verify that the following relevant recommendations and mitigation measures called for in the EMP, and according to the applicable norms (surveys, permits, etc.), are integrated into a specific procedure by the EPC contractor, which should contemplate:

(i)          Dust control measures;
(ii)         Control of erosion and sedimentation;
(iii)        Solid and liquid waste management (spill prevention, and waste disposal);
(iv)        Noise mitigation;
(v)         Emergency Response Plan; and
(vi)        Rehabilitation and restoration of disturbed areas.

SENAC has in place an emergency response system as part of its Health Safety and Security Plan. The Emergency Response Plan will include a plan for handling accidents involving possible pollutants and hazardous substances.

PS4 – Community Health, Safety and Security

Managing pedestrian incursion during construction and operation of highways in the Dakar area is a major problem, which usually takes the form of people crossing the roads without using the pedestrian fly-overs and street sellers congregating near congestion points. The problem is exacerbated by the presence of often informal drop-off/pick-up points for the private mini-buses (‘cars rapides’), which create traffic congestion and will have to be sorted out in coordination with the authorities. The toll road will have high barrier walls to prevent pedestrians from entering the toll road and the drop-off/pick-up points for the minibuses will be limited to specially designed areas in the exchanges and outside the toll areas, and better on N1 accesses. Pedestrians will be prevented from entering the road past the toll barriers. To mitigate the impact of the blocking of pedestrian traffic, there will be pedestrian fitted crossings (over/under passes). Furthermore, as part of its overall development plan for PIS, the APIX has developed plans to provide additional social and economic infrastructure on each side of the toll road to reduce the need for people to cross over.

SENAC is seeking to develop a memorandum of understanding with the National Police of Senegal for laying out the conditions for enforcement of traffic laws within the toll road area, which will include a mechanism for reporting credible allegations of unlawful or abusive acts to police authorities.

PS5 – Land Acquisition and Involuntary Resettlement

As previously discussed, APIX will be responsible for the resettlement of people from the project site. APIX is being supported by the World Bank with both technical assistance and financing for the resettlement itself. As a government-led resettlement, the provisions of paragraphs 22-25 of PS5 would normally apply. These paragraphs require the client to carry out its own assessment of the government-led resettlement to identify any gaps between the resettlement benefits provided by the government and the objectives of PS5. Given, however, the involvement in the preparation of and the approval by the World Bank of the resettlement documents, IFC has based its PS 5 assessment on these documents and has not required SENAC to prepare a separate evaluation. In the absence of financial support from the GoS, World Bank, AFD, and AfDB for the resettlement, the Project would neither be feasible nor could it be compliant with international standards for resettlement: revenue from the tolling concession does not cover the full cost of construction (which is being subsidized by the GoS), much less the cost of resettlement.

Section 1 and 2 Dakar to Pikine. APIX carried out the land acquisition on this section of highway prior to the development of the public-private partnership approach to the project and IDA involvement. Land acquisition was based entirely on compensation. A resettlement audit of this section identified 60 people who had not yet been compensated. In its review of the project, IDA identified the gap in compensation and has agreed with APIX on a resettlement action plan to address the gap. The primary action concerns the payment of remaining compensation to the project affected people. From the perspective of PS5, cash compensation is appropriate because livelihoods in this urban area of Dakar are not land-based and there are active markets for housing.

SENAC will put in place a procedure which will include a site visit to ensure that the right of way on future sections of the highway is in fact clear of all prior inhabitants before accepting the handover. Furthermore, APIX will represent in the transfer sheets, which are part of the legal handover of the right of way to SENAC, that the land acquisition has been carried out according to the methodology agreed to with the World Bank.

Section 3, Pikine to Keur Massar. This section of the proposed toll road is the most densely populated. Construction will take place on this section after construction starts on Section 4 because of the complexity involved in resettlement of the project affected people. As the area is a high density residential area, the displacement is predominantly physical rather than economic. Of the 3,131 households to be affected, 888 are owner-occupied and 2,243 are occupied by tenants. The tenants will be provided by the Grantor with financial assistance for locating new habitations to rent. House owners have been offered a choice between cash compensation and a new house. First priority for new houses will be for those who are living in the houses they own. During the consultations, approximately 75% identified their preference for a new house. Cash compensation will be at fair market value for constructing a new house. By law, cash compensation will be paid by the Directorate of Domaines, in the Ministry of Economy and Finance.

People without legal title, 90% of the Project affected people, will be eligible for new houses. Those who choose compensation will be paid out of an APIX account by an inter-ministerial group. The Project will monitor the use of the funds as much as is possible and will assist the people in this situation with obtaining title.

APIX has identified a 165 hectare site at Tivaouane Peul on which to build new housing for the project affected people, including those being resettled as part of the restructuring of the PIS area. The Tivaouane Peul appears to be the only acceptable remaining large piece of mainly undeveloped land in the greater Dakar area . The use of the site is complicated by the presence of the Mbeubeus irregular landfill located 2 km away from the site. The landfill will need to be closed and capped in order to prevent fumes from the spontaneous combustion of the landfill from reaching the resettlement site. Studies have found that the groundwater under the Tivaouane Peul site is contaminated. As a consequence, water will have to be piped into the site, and the digging of wells forbidden. The site will include the construction of schools, health clinics, markets and other community infrastructure. Because Tivaouane Peul was not identified as the resettlement site when people were consulted on their preference for cash compensation or a house, and because the site is farther away from Dakar than PIS, it is possible that a larger percentage of the project affected people will, in the end, switch to the cash option.

The Mbeubeus irregular landfill employs 800 people in waste-picking, many of whom are children. There is also an informal community associated with the site. A resettlement framework has been prepared to address the economic and physical displacement that will take place when the site is closed. The World Bank is assisting APIX in technical studies that will lead to a full resettlement action plan. The main strategy with respect to the scavenging children will be to improve access to education, particularly vocational training.

One thousand one hundred and twenty-six (1,126) businesses will be affected, so they will receive compensation for the loss of income as a result of being displaced as well as for the loss of any assets. Nine hundred and seventeen (917) of these are small and medium enterprises; two hundred and nine (209) are vendors. Ninety-one (91) pieces of agricultural land will be compensated for lost crops.

Section 4. Keur Massar to Diamniadio. Land use in this area is made up of largely empty parcels of land in partially developed subdivisions. There are 798 empty parcels, 131 houses under construction, 37 inhabited houses, 22 rented houses, and approximately 51 parcels of agricultural land. Land acquisition has been based entirely on cash compensation at fair market value for lost assets. Cash compensation is appropriate in this area because the livelihood is not primarily land-based and an active market for land and houses exists in the area.

On the recommendation of the World Bank, APIX has contracted with two NGOs, MSR and ENDA, to assist project affected people directly in helping them set up their files and ensure that they have the right documentation to be eligible for/access their entitlements. These NGOs have offices physically located in the areas to be resettled. The NGOs are currently verifying the baseline socio-economic data. They also produce monthly reports. The World Bank has also placed a social development specialist is its Dakar office to monitor the progress of the project full time.

PS6 – Biodiversity Protection and Sustainable Natural Resource Management

The Forest of Mbao is currently classified as a protected forest and it is managed by the Department of Water and Forestry. While the forest is classified, it is heavily modified habitat, including some economic trees used by local residents. The total area of the Forest covered by vegetation is estimated at 722 ha; some of the area is already occupied by such things as a waste transfer station, an electrical sub-station, and other buildings and their surrounding grounds. The Project was routed through the Forest as a way of minimizing resettlement from the surrounding peri-urban areas. Not all of the Forest will be impacted, as only about 35 hectares will be taken up by the road project. As part of the commitments made by APIX in the ESIA, a forest management plan has been put in place, which will seek to preserve the ecosystem services of the forest and enhance the non-forest product resources available to local communities in the Forest. The project has received an authorization in principle in April 2007 to put the right-of-way through Forest of Mbao. However, prior to cutting down any trees, the relevant portion of the Forest must be declassified. The declassification decree is expected in mid-May 2010. The offset program that will be financed by SENAC consists of replanting 2 trees for every tree taken down in the Forest of Mbao. The Department of Water and Forestry as well as APIX are in the process of identifying a site equivalent to what will be used by the Project so they can implement the offset program.

PS8 – Cultural Heritage

This Performance Standard has been triggered for the World Bank Dakar Diamniadio project.
No physical cultural heritage has been identified within IFC’s Project right-of-way. A chance finds procedure, however, will be developed as part of the overall social and environmental management system for the Project. The chance finds procedure will be issued and implemented by the EPC contractor.

The client has not directly engaged with the community as community engagement is currently undertaken by APIX as part of the concession agreement. The World Bank has documented the extent of this consultation, which show multiple meetings between October 2005 and July 2008 with a broad range of stakeholders, including the affected communities and their representatives, elected officials, central and local government officials and agencies, and NGOs. Extensive community consultation continues to take place at the grass roots level through the NGOs, as well as community meetings with presence of several government officials.

SENAC is in the process of evaluating various community development initiatives with a focus on youth and capacity building. Eiffage Senegal has several community development programs in the promotion of Senegalese art, aid to medical development, employees’ AIDS awareness and prevention.

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