The project is classified as Category B according to IFC’s Policy on Environmental and Social Sustainability. Components are considered of limited E&S risk involving minor infrastructural improvements on existing pedestrian and road networks.   

The main environmental and social issues during construction and operations include: (i) implementation of appropriate risk and impact identification, assessment, mitigation, management and supervision practices; (ii) adherence and application of good sector-specific international industry practices (GIIP) during construction, including worker occupational health and safety and community health, safety and security; (iii) appropriate management and supervision of contractors; (iv) open, consistent and transparent engagement and timely disclosure of information with stakeholders; and (v) appropriate and timely redress of grievances.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.      

Environmental and Social Assessment   – Environmental and social assessment of transport projects must adhere to the requirements of Law No. 123, which guides the environmental impact assessment (EIA) process. 

Decree no 222/2012, of Law 123, categorizes projects according to the scope, nature and significance of risks and impacts. The Environmental Protection Agency or   Agencia de Proteccion Ambiental    (APRA), under the Ministry of Environment and Public Spaces of CABA, is the governing authority over environmental and social matters. APRA classifies projects in accordance to three main risk categories: (1)   Sin Relevante Efecto    (SRE) for projects with no important or relevant environmental impacts, (2)   Sujeto a Categorizacion    (S/C) projects with potential risks and impacts, and (3)   Con Relevante Efecto Ambiental    (CRE) for projects with specific environmental impacts and risks. The scope, breadth and detail of environmental assessment of a project depends on its categorization. Only projects categorized as CRE require undergoing extensive public consultation.  

All components financed as part of this project have been classified as   Sin Relevante Efecto,    in other words, of low environmental and social risk, and do not require environmental impact assessments or public hearings.  

SoT will submit to IFC the technical designs, specifications, environmental reviews and supporting contractor operational management plans and programs for all projects, including any CAA and/or Resolution(s) emitted by APRA. (  ESAP Condition 1).    Policy –    The SoT is subject to complying with all policies and procedures established by the Government of the City of Buenos Aires  .    The SoT has a set of policies and procedures regulating the design, planning, use, maintenance and management of public transport systems, including roads used by vehicles, bus transport systems, users and pedestrians. Environmental regulations fall under the responsibility of APRA, and social considerations, like human resources and labor conditions of workers, engagement with stakeholders and resolution of grievances are managed centrally by departments within the Government of the CABA. CABA policies and procedures are broad in nature, encompassing the full range of issues considered in the relevant PS’s applicable to this project.  

Identification of Risks and Impacts –      As per their mandate, SoT   is required to   carry out an evaluation of technical and environmental and social considerations at the early stages of the project design.  The evaluation will combine with mobility and transport/traffic modelling to understand the use of space and the overall impacts and benefits that will derive from these improvements. Risks and impacts will be minimized to the extent possible during technical design. Risk mitigation measures will include the use of safe design, installation of appropriate signage, and communications (maps, timetables, etc.) to users on the service provided. 

Management Programs –    SoT is the project developer of components financed under this project. Private firms will be hired to manage and maintain the integrity and functionality of the projects. SoT will ensure that all private contractors during construction and operations recognize, integrate and comply with relevant environmental and social obligations and principles aligned with PS 1 – 4, in addition to the relevant legislative requirements.  

Organizational Capacity and Competency –    SoT is one of several centralized units within the CABA. Transportation projects developed by SoT are designed, planned, and implemented by the Sub-secretary of Transit and Transport (SSTT), which in turn has three general management units: (i) mobility planning; (ii) transit and transport, and (iii) transport infrastructure. The unit is also responsible for safe, healthy and sustainable movement of people on public transport systems. On the other hand, healthy mobility projects, such as the Bicycle Public Transportation System “Ecobici” and the cycle lanes, are planned, developed and maintained by the Sub-secretary of Safe and Healthy Mobility. 

The project will require cross coordination and planning with other city wide agencies, such as the department of international relations, public spaces, procurement, communications, emergency services, etc. APRA, the Environmental Authority, will manage regulation and enforcement of environmental matters and programs across the city. The role of SoT will be focused on design, planning, implementation and oversight of projects, while APRA will ensure the application and compliance of environmental safeguards.  

Emergency Preparedness and Response –   Please see detailed commentary under   PS 4    – Community Health, Safety and Security   , below  .  

Monitoring and Review –   Environmental monitoring will be carried out by the project operators, reported to APRA and provided to IFC in the Annual Monitoring Report (AMR)

Human Resources Policies and Procedures –     The CABA transport strategy, defines roles, responsibilities and reporting lines of each position, and includes procedures establishing workers’ rights in relation to their job functions. SoT workers are government employees, protected under national labor laws as government officials. Argentine labor laws respect the right of workers to affiliate with trade or industry unions, through representative collective agreements. They explicitly promote non-discrimination and equal opportunity. 

Grievance Mechanism –   Workers of SoT have several mechanisms in place for raising employment related grievances. These include the employee’s direct manager for immediate concerns or the respective union and/or human resources department for more significant matters. The mechanisms do not impede access to judicial or administrative processes as needed.  

Protecting the Workforce –    Child labor and forced labor are strictly prohibited and strongly penalized by Argentine labor laws. Neither occurrence is a risk for the sector given the strong regulatory framework protecting worker’s rights in the country and the highly skilled nature of the jobs required in the sector. All employers in Argentina are required to verify that workers are a minimum of 18 or older upon hiring.  

Occupational Health and Safety    – Occupational health and safety (OHS) is governed by federal law No. 19587, and sub-laws and resolutions regulating the transport sector in Argentina. The government agency responsible for the oversight of OHS risks in the workplace is the   Superintendencia de Riesgos del Trabajo    (SRT), through specialized entities known as   Aseguradoras del Riesgo del Trabajo    (ART).  

All workers are required (by law) to undergo relevant training on the OHS risks relevant to their job functions. Workers are provided with protective personal equipment to ensure their safety and are trained and monitored to ensure proper use. OHS accidents and incidents are duly reported and documented on-site and emergency preparedness and response drills are undertaken twice yearly on site.  

Workers Engaged by Third Parties and Supply Chain    – SoT will incorporate EHS risk management requirements in contractual agreements with all third parties consistent with the main principles in PS’s 1 – 4, and will require supervision monitoring reports annually, consistent with PS 2 paragraphs 24 – 26.   (ESAP Condition 3)

SoT is responsible for environmental management and compliance matters during construction of the BRT and modal systems. Once built, operational compliance of pollution prevention and environmental matters is carried out by the respective city governmental agency (e.g., public spaces, etc.), and enforced and regulated by APRA.  

Greenhouse Gases   – The projects are not expected to have a direct, significant reduction of GHG emissions, though they will contribute to making the transit of buses and vehicles more efficient and provide users with the option of substituting vehicles for bicycles using the additional 34 km’s of lanes planned for the city, and therefore will have an indirect positive effect toward the reduction of the GHG emissions at the municipal level.  

Pollution Prevention   –    The projects are not expected to have significant or adverse environmental impacts requiring careful consideration during construction or operations, given the limited infrastructural works involved for each component. 

Waste and Hazardous Materials Management  – SoT and its contractors will comply with all waste management legal requirements and provide IFC with details on the type, quantity and amount of waste generated and disposed in the AMR. Disposal of hazardous or dangerous waste is carried out in accordance to law no. 24.051, which requires that records of all manifests evidencing the appropriate transport and elimination of wastes are kept. The main sources of waste expected to be generated by the project are domestic waste and limited construction waste from operation of equipment at construction sites.

Infrastructure and Equipment Design and Safety and Emergency Preparedness and Response–  

SoT checks and verifies that all infrastructure and equipment procured and used for projects, meets the relevant regulatory and sector safety standards according to design and contractual requirements.   

SoT will be responsible for ensuring integration of safety and security design features of the project, consistent with their mandate with respect to the public transport systems it develops. Physical segregation of mass transit and private vehicles significantly reduces the risk of accidents on roads and will represent a positive impact by the project. Other safety and security elements included in the project design are crosswalks, street lights, sidewalks, stations, appropriate signage and communications, etc. 

Emergency Response -    All transport related emergencies are reported to the city’s transit control authority and federal police, who in turn coordinate with fire and medical response teams as needed. SoT is responsible for working with transit control to inform metrobus service providers of obstructions, incidents and delays and to plan and coordinate alternative routes and contingency measures to alleviate traffic on city roads. SoT will report on safety performance of the project.   

Security Personnel –    The metropolitan police has been involved in public transport systems since 2014. Increased police presence combined with the installation of CCTV cameras and video surveillance have had an important impact in increasing the safety of systems.

The CABA have dedicated communications and public service (atencion cuidadana) units that manage all issues around stakeholder mapping, engagement, information sharing, communications and resolution of grievances for all users of public transport systems in the city. These units will ensure stakeholder engagement at the project level in coordination with the SoT The communications department uses several media and tools to communicate with stakeholders and keep them informed of developments affecting the quality and performance of its transport services. It is also responsible for printing maps, brochures, and organizing public awareness campaigns around acceptable behaviors and other issues, while using public transport systems.   T  he public assistance unit has toll free hotlines to capture and respond to complaints, concerns or other issues relating to transport services and infrastructure across the city. Issues are redirected to the appropriate transport agency, who have standardized timeframes and methods for responding to or addressing the concern. CABA procedures for engaging and resolving grievances of stakeholders is considered to be aligned with IFC’s PS requirements.