The project is classified as Category B according to IFC’s Policy on Environmental and Social Sustainability, as the adverse environmental, social, labor and occupational health and safety impacts and risks are expected to be few in number, be site specific, reversible, and readily addressed through standard design criteria and internationally recognized mitigation measures. Projects to be financed under this corporate loan to the Province of Cordoba involve expansion and/or completion of existing intra and peri-urban and rural roads with limited new environmental and social footprint.

Environmental and Social Assessment

The environmental and social impact assessment of any transport project to be developed in the Province of Cordoba must adhere to the requirements of the Provincial Environmental Policy (Law No. 10208) which outlines the general environmental risk management principles and provides guidance on the environmental and social impact assessment (ESIA) process. Each project proponent must submit to the Environmental Secretariat a “Project Environmental Notification” (Notification), which describes the overall components of the project, design, and expected environmental and social impacts and proposed mitigation measures.   Depending on the expected magnitude of environmental and social impacts and risks, the Environmental Secretariat issues a license to proceed or requires the project sponsor to perform a complete ESIA process, which includes public consultations. When an ESIA is required, the Environmental License is issued after completion of the public consultations and the formal technical review by the ESIA unit of the Environmental Secretariat. The status of the three projects to be financed under this proposed IFC investment is as follows:  (i) Capital Ring-Road (“Circunvalación”) was divided in four segments, identified as IA, IB, II and III. Segments IA and II have issued Notifications, while segment III was required to undergo a full ESIA process. All three segments have been granted their respective Environmental Licenses. The only segment of the Capital Ring Road that at the time of appraisal still had not submitted the Notification was segment IB. It is expected that this segment will also require to undergo a full ESIA process. The other two projects, (ii) Ring Road Access Avenue (“Costanera”) and (iii) Alpa Corral Roads -Provincial Route 23, are still in early bidding stages and therefore the Notifications are yet to be issued. Neither of these projects is expected to be subjected to a complete ESIA process. Submission of Notifications, ESIA, and resulting Environmental Licenses will be a requirement under IFC’s investment (ESAP actions #1 and 2). Notifications and ESIAs available at the time of IFC’s appraisal are disclosed with this ESRS as part of the Client Documentation.

Identification of Risks and Impacts

The project developers, whether Caminos de la Sierra or Vialidad, prepare the Project Environmental Notification and/or ESIA as applicable, and typically outsource through environmental and social consultant firms to carry out the environmental and social assessment and management programs. Based on the Notifications and ESIAs available to IFC at the time of appraisal, as well as assessments prepared for other roads, both developers have mechanisms and capacity to adequately identified and manage potential impacts and risks associated with the construction and operation of road projects. The reviewed Notifications and ESIA adequately identify typical ESHS impact and risks associated with construction such as (i) air and noise emissions, (ii) excavation earth movement and soil disposal, (iii) solid waste and hazardous waste management and disposal, (iv) wastewater discharges and modification of drainage systems, (v) construction related nuisances to neighboring communities, and (vi) occupational health and safety risks of construction workers and heavy machinery operators.

Organizational Capacity and Management Programs

Both the Notifications and the ESIA include environmental management plans (Planes de Manejo Ambiental - PMAs) commensurate with the expected impacts and risks and compliant with local regulations and with good international industry practices. For instance, the ESIA for Segment III defines the ESHS organization and outlines details for seven ESHS management sub-programs to be implemented during construction, including: (i) effluent management and water consumption, (ii) solid waste management, (iii) management of chemical products. (iv) air quality control and noise abatement measures, (v) stakeholder engagement and communications, (vi) landscape management, and (vii) traffic management and signaling. Similarly, it defines a total of four ESHS management sub-programs to be applied during the operation phase, including: (i) civil works maintenance, litter/garbage collection and cleaning program, (ii) energy savings / efficiency programs, (iii) pollution abatement and control – mainly noise, and (iv) operations and maintenance personnel capacity building and training programs.

The Province of Cordoba does not have a consolidated Environmental and Social Management System per se; however, it has dedicated departments that monitor and ensure compliance with ESHS requirements. The Environmental Units of Vialidad and of Caminos de la Sierra have in-house teams of 2 and 4 professionals, respectively, which are in charge of developing the Notifications and / or the ESIA for their respective projects, as well as implementation of the PMAs. These teams are supported by outsourced ESHS consulting firms. The Provincial Environmental Secretariat has a total of 183 professionals, who review studies, provide the licenses, and monitor compliance with the approved PMAs. The Minister of Social Development is responsible to develop the land acquisition, involuntary resettlement, and livelihood restoration programs (RAPs); and has a team of 18 social workers, 10 architects, three lawyers, and one engineer who collect information, develop the affectation plans, evaluated the costs, negotiate with affected property owners and/or users, and manage any purchase, relocation, restoration and expropriation process. This process is described in more detail under PS5.

Emergency Preparedness and Response

The available Notifications and ESIA include a section on the required EPR planning. The emergency plan for each project will include measures to respond to inundations, fires, landslides, road accidents, and hazmat spills.

Monitoring and Review

The ESIA Unit of the Environmental Secretariat performs periodic compliance supervision visits. The supervision mechanisms are defined in each project’s PMAs; specifically the ESIA Unit will perform monthly compliance supervision audits throughout construction works. The ESHS units of Vialidad and Caminos de las Sierras will also maintain permanent field ESHS inspectors throughout the construction periods and continue to supervise compliance with PMAs during operations.

Workforce / Human Resources Policies and Procedures

As of September 2017, the Province employed more than 128,000 professionals. Vialidad and Caminos de Las Sierras have a total of 345 and 360 employees, respectively. As government agencies they comply with all applicable labor regulations (Ley No 8015). The Province as well as Caminos de las Sierras have dedicated human resources (HR) departments staffed by 10 and five professionals, respectively. The HR departments ensure the application of non-discriminatory hiring and promotion policies, prohibition of any type of forced or child labor, fair treatment, and non-retaliatory implementation of labor grievance redressal. They also define roles, responsibilities, compensation and promotion packages, capacity and training needs, health benefits and pension plans.   Argentine labor laws respect the right of workers for collective bargain and free affiliation to trade or industry unions.

At peak of construction of the three components to be financed under the first tranche, it is expected that approximately 30 staff for the Capital Ring-Road, 20 for the Ring Road Access Avenue, and 20 for Alpa Corral Roads -Provincial Route 23 will be dedicated by the Province. Contractor’s workforce at peak will account for approximately 1500 workers for the Capital Ring-Road, 200 workers for the Ring Road Access Avenue and 150 workers for the Alpa Corral Route 23.  Given the urban or peri-urban location of the roads, workers will be hired locally and no worker accommodation camps or special transportation arrangements will be needed. During operation, the workforce will be limited to maintenance and operation activities.

Workers Organizations

Workers in Argentina are free to affiliate to the union of their choice. All construction workers are affiliated to the construction workers union – UOCRA (Unión Obrera de la Construcción de la República Argentina). Province of Cordoba’s employees are also free to affiliate to relevant unions and approximately 70% of the province’s payroll is unionized (Public Employees Union). Similarly, about 75% of Vialidad employees are affiliate to SIVIALCO (Sindicato Vial Córdoba), and about 80% of Caminos de la Sierra employees are affiliated to UEACARA (Unión de Empleados de la Construcción y Afines de la República Argentina) and the remaining 20% to UOCRA.

Grievance Mechanism

The Province and Caminos de las Sierras have several mechanisms in place for their employees to raise 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 HR department is in charge of collecting these claims, either in Vialidad or Caminos de las Sierras. These mechanisms are free of retaliation and do not impede access to administrative and judicial processes where needed. Relevant procedures are captured in the Citizen Service Guidance Book which defines the framework for assisting employees with their claims and requests.

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 workers rights in the country and the highly skilled nature of the jobs required in the sector. All employers in the Province are required to verify the age of its workers upon hiring, and to ensure that all their contractors do the same. The minimum allowable age to work in the sector is 18.

Occupational Health and Safety

Occupational health and safety (OHS) is governed by federal law No. 19.587. OHS requirements for construction and operations are defined in the bidding documents and will be closely monitored by both Provincial Labor Authorities as well as the developer’s OHS field inspectors. OHS requirements include procedures to (i) assess the OHS risk profile of the different task, (ii) specific training, qualification and PPE required to perform each task, (iii) daily safety talks, (iv) key performance indicators normalized to total man-hours, (v) incidents and accidents recording, investigation and corrective procedures, (vi) monitoring and review requirements, and (vii) reporting requirements. Vialidad and Caminos de la Sierra have a team of two and three OHS field inspectors, respectively. Both organizations maintain records of OHS performance, including incident rates.  There have not been fatalities in recent years as reflected in the Mutual de Seguros statistics. Average incident rates for road constructions executed by Vialidad and Camino de las Sierras are at 1 accident every 12000 person-hours of work for both organizations.

Pollution prevention and environmental management for the construction and operation of the Provincial road network are guided by the Provincial Environmental Policy (Law 10,208), and require compliance with federal and provincial regulations and application of good international practices. Projects PMAs include pollution prevention and control measures for air emission, noise, wastewater discharges, solid waste and hazardous waste management during construction, as well as maximum emission or discharge standards. The PMAs also include reforestation and landscape requirement. A compliance matrix, key performance indicators, and requirements on decommissioning process are defined.

Potential environmental liabilities could be present in a 1-km section of segment IB of the Capital Ring-Road which will cross an area of the military airport. As a requirement to IFC’s investment (ESAP action #3), the Province will perform an appropriate site investigation audit, and remediate and/or remove and dispose of any contaminated soil consistent with good international industry practices. 

During operation, the PMA includes quarterly monitoring of air quality (PM₍₁₀₎, CO, NO_x, SO₂) and noise at pre-determined stations.

Each project subjected to an ESIA includes a pre-construction program of Stakeholder Consultation and Engagement (Participación Ciudadana). This program must follow a standard structure that includes (i) stakeholder identification and analysis, (ii) engagement planning, (iii) sharing and dissemination of information, (iv) consultation and participation programming, (v) grievance mechanism, and (vi) continuous feedback and improvement. During construction there will be permanent information and engagement via print/billboards, social media, radio broadcasting, as means to keep users informed and connected about new developments affecting their daily traffic commute. Each engagement and consultation process has multiple stages and mechanisms, including but not limited to, the Environmental Secretariat webpage, consultation via an Interdisciplinary Technical Commission, and public hearings. Not all projects have the same level of consultation, as it is commensurate with the level of potential impacts, but typically most projects involve over 100 consultation events.

During operation, either Vialidad or Caminos de las Sierras will continue to organize public awareness campaigns around acceptable driving safety, pedestrian safety, anti-littering campaigns etc.

Roque Spidalieri

Gobierno de la Provincia de Cordoba - Subsecretario de Financiamiento

Rosario de Santa Fe 650, Edificio Bajo, Córdoba