The new tramway lines will be constructed on existing roads and the maintenance center will be constructed on land owned by the Municipality of Casablanca. Therefore, no land acquisition and involuntary resettlement are anticipated for Component 1. Limited risks of livelihood impacts are anticipated as discussed under PS1 and PS5 sections of this ESRS. The tramway project is located in an urban setting and as such no risks of adverse impacts on conservation of biodiversity within the projects’ area of influence have been identified.

For Component 2, the Region’s Massaleek program will only involve the upgrade of existing roads within the public right of way and will avoid any significant acquisition of private land. Limited livelihood impacts are anticipated towards informal users of public land as discussed under PS5 section.

With respect to PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, communes were screened against existing high biodiversity values.  In adherence to the avoidance tier of the mitigation hierarchy, roads located in communes that could present potential risks to high biodiversity values were screened out of the project.  Therefore, only communes with minimal biodiversity risk are being considered.  For this reason, there are no impacts of concern associated with PS6.

There are no risks or impacts associated with Performance Standard 7: Indigenous People –  no indigenous people are known to have been in the project area.  PS8: Cultural Heritage impacts are not anticipated for Component 1 as the baselines carried out as part of the ESIAs did not identify any risk or impact on cultural heritage. Similarly, risks and impacts on cultural heritage are not anticipated for Component 2 as it will involve existing roads with limited widening in places. Chance find management is required by the national legislation and addressed under the general administrative clauses for public works (Cahier des clauses administratives générales applicables aux marches de travaux –CCAG-T article 38), and a chance find procedure will be established for both components.    

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.  

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, as both components are expected to result in a limited number of specific environmental and social risks and impacts that can be minimized, avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. 

Key environmental and social (E&S) issues associated with Component 1 include: i) the capacity and systems of the Region and Casa Transports, including the relevant interinstitutional agreements, to assess and manage E&S impacts and risks of tramway infrastructure construction and operation, ii) labor and working conditions and occupational, health and safety (OHS) of construction workers, iii) stakeholder engagement, iv) potential temporary economic impacts on existing businesses and their accessibility during construction of the two lines, v) community health and safety including traffic safety, noise and vibration during operation, vi) emergency preparedness and response including life and fire safety during operation.  For Component 2, key E&S issues include i) the capacity and systems of the Region to screen, assess, avoid or minimize and manage E&S risks and potential impacts associated with the upgrading of the selected roads, ii) potential livelihood and land use impacts due to widening of the rural roads within the existing right of way in public land, iii) community health and safety, iv) labor and working conditions and OHS for construction workers, and v) stakeholder engagement.   

 Environmental and Social Assessment and Management System and Policy:

The Region has a set of norms and regulations applicable to public works which will need to be complied during the construction and operations of the project.  As part of ESAP item 1, the Region will issue an overarching environmental and social policy, applicable to both components included in the proposed investment, to articulate its objectives and principles that will guide the projects to achieve sound environmental and social performance, consistent with IFC’s Performance Standards. The policy will include a statement regarding the applicability of Performance Standards on Components 1 and 2.

Component 1:

Casa Transports hired an E&S consultant (NOVEC) to assist in the risks and impacts identification process and develop the environmental and social impact assessment (ESIA) studies for both T3 and T4 lines and a framework Environmental and Social Management Plan (ESMP) for the project, as described below under the “Identification of Risks and Impacts” section of this document. Casa Transports will ensure that the project ESMP commitments, consistent with IFC’s Performance Standards, are passed on to the contractors through the technical specifications of the tender documents, which include a Responsible Construction Policy (“Charte des travaux responsables”) covering environmental and social requirements for contractors. Contractors’ supervision will be carried out by the PMC.

As per ESAP item 2a), Casa Transports will commission the PMC to develop a construction phase Environmental, Social, Health and Safety Management Plan (Construction ESMP) describing E&S objectives, roles and responsibilities, plans and procedures to manage and control E&S risks and impacts during construction of T3 and T4, consistent with IFC’s Performance Standards. The Construction ESMP will be included in the contractor contract requirements and Casa Transports will require that each contractor prepares the relevant implementation plans. The PMC will review the contractors’ implementation plans and report to Casa Transports that the plans are aligned with the Construction ESMP, and will supervise their implementation.

The Construction ESMP will include, but not be limited to, the following plans and procedures: waste and effluent management; hazardous material storage and spill management, dust, vegetation and tree management; environment monitoring, including construction phase noise and vibration measurement, inspection and reporting; life and fire safety; labor compliance; chance find procedure; construction area safety; traffic and pedestrian safety, occupational health and safety (OHS) and workers’ accommodation.

RATP Dev manages the E&S aspects for the operations of Lines T1 and T2 as per a set of procedures which were approved by Casa Transports, including solid waste storage, EHS inspections, environmental impacts identification, risks and opportunities management, emergency response plan, OHS register, training plan, operation rules (including drivers’ permits and speed restriction compliance), and accident investigation.  Per ESAP item 2b) Casa Transports will ensure that the operator develops and implements the operation phase ESMP for Lines T3 and T4 (Operations ESMP), consistent with IFC’s Performance Standards, complementing the existing procedures with relevant provisions for resource efficiency, solid waste disposal, effluent management, noise and vibration monitoring and management, hazardous materials management, human resources management, worker grievance mechanism, and security management.

Component 2:

For the first phase of the Massaleek program, environmental requirements were addressed in accordance with the general requirements of the Decree n.2-14-394 of 13 May 2016: Cahier des clauses administratives générales applicables aux marches de travaux in Article 30 – Environmental Protection, Article 31 – Construction waste management, Article 33 – Safety and hygiene management measures and Article 34 – healthcare and first aid to workers and employees. Region’s Technical Specifications also include requirements for materials extraction activities to comply with standards for environmental protection defined in the Cahier des prescriptions communes (CPC) applicable to public road works (arrêté n° 451-83 du 06/12/82). Per ESAP item 3, the Region will develop and implement an ESMP which will operationalize the technical specifications and will include relevant provisions for OHS, environment and biodiversity protection, community health and safety, land acquisition and economic displacement, emergency response management, worker accommodation, worker code of conduct, screening procedure for road materials suppliers and a chance find procedure, all consistent with IFC’s Performance Standards.

Identification of Risks and Impacts

Component 1:

To meet national requirements (Law 12-03), Casa Transports prepared the ESIAs for both tramway lines, which have been submitted to the National Impact Assessment Committee in March 2019, and will be updated and finalized based on the outcome of the public disclosure and consultation process and the feedback from the committee. The ESIAs assess potential construction and operation impacts (including impacts on air, noise, hydrology, landscape, flora and fauna, traffic, community safety, cultural heritage) and provide mitigation and management measures, which are described in the framework ESMP. The E&S assessment process is consistent with IFC’s Performance Standard 1.

No streets or roads will be permanently closed or rerouted for the project. A number of intersections will be cross-cut by the tram lines necessitating some reorganization of vehicular traffic. An overall reduction of parking spaces is expected along the streets affected by the project, which will be mitigated by creating new parking spaces as part of the Urban Mobility Plan of Casablanca.  Temporary impacts associated with noise, dust and access restrictions due to construction activities will be minimized with mitigation measures described in the ESIA, including among others phased construction, creating delivery and pedestrian access points to surrounding businesses and residences, and public information campaigns on construction activities.

Component 2:

There is no legal requirement in Morocco for an environmental and social assessment of the type of works required for the rural roads upgrading program. As per ESAP item 4 the Region will develop an E&S screening procedure to be included in the ESMP and applied to all road segments included in the program.  The procedure will allow the identification, ahead of the detailed design for each road upgrade, of the sensitive environmental and social receptors (such as environmentally sensitive areas and protected areas, cultural heritage, community infrastructure, livelihood impacts), and the definition of the relevant mitigation measures. As described above in the “Applicable Identified Performance Standards” section of this document, biodiversity risks were screened out of this project.  That said, as part of the screening process, any residual local biodiversity values as well as ecosystem services will be included in this process and in the above mentioned ESMP.

Organizational Capacity and Competency:

Component 1:

The Technical Directorate of Casa Transports has a dedicated team of specialists and will have overall responsibility for the construction of the tramway line system, including contractor management. As per ESAP item 5a), Casa Transports will designate an E&S officer within the project organization with responsibility for E&S assurance and monitoring during construction and for reporting to IFC.  As per ESAP item 5b) Casa Transports will ensure that the PMC will have a dedicated E&S manager and the required team with the knowledge, skills and experience necessary to implement the project’s requirements and standards, consistent with IFC’s Performance Standards.

RATP Dev has a dedicated team in charge of Quality Safety and Environment and Casa Transports will require the operator to maintain an adequate team to manage E&S risks and impacts during operations of Line T3 and T4. 

Component 2:

The Region supervises the program through its technical team, supported by an engineering consultant for technical aspects only. There was no dedicated E&S management oversight for the implementation of the first phase of the rural road upgrade program.

As per ESAP item 6, the Region will appoint an E&S officer and hire an external E&S consultant to support the organization to manage E&S aspects and implement mitigation measures for Component 2 and to monitor and report to IFC on implementation of ESAP and project requirements consistent with IFC’s Performance Standards.

Emergency preparedness and response:

Casa Transports and the Region will ensure that for both components the Construction ESMP includes emergency preparedness and response. For the operation of Lines T1 and T2, RATP Dev has in place an extensive emergency preparedness and response plan (Plan d’Intervention et de sécurité) which was approved by Casa Transports.  Equally, Casa Transports will ensure that the operator of Lines T3 and T4 develops and implements its emergency preparedness and response plan as part of the Operation ESMP, in line with IFC’s Performance Standards. The plan will be consistent with the plan adopted for the operations of Lines T1 and T2 and be complemented with spill response procedures and emergency drills program.

Monitoring and Review:

The Construction ESMP of the tramway and the rural roads will include a monitoring and reporting framework covering, among others, waste and effluent management, traffic safety, noise and vibration, inspections and audits, occupational and community health and safety, incidents and accidents, labor compliance, tree protection and management, community grievances, and chance finds.

RATP Dev monitors and reports annually to Casa Transports on traffic accident statistics and related safety actions, water and electricity consumption, grievances from the public, human resources, training, occupational incidents, communication/sensitization actions. As part of the Operations ESMP, the tramway operator will complement its monitoring and reporting procedures to include management of solid wastes and hazardous wastes, and management of effluents.     

 The Region employs about 50 full-time staff, among which 40% are women. Casa Transports directly employs about 40 staff and approximately half of them are women. The tramway operator currently employs around 600 direct workers, and about 5% are women.

In the construction phase Component 1 is expected to generate around 1300 jobs, including contractors and subcontractors, while the workforce during operations will comprise about 500 jobs including   security contractors. Component 2 is expected to generate around 900 jobs for the road works.

Human Resources Policies and Procedures/Working Conditions and Management of Worker Relationship: 

The Region hires its direct employees under a royal decree (dahir) on hiring and working conditions of public officials (issued in 1958) and a regional decree issued in 2015. The decrees governing working conditions and terms of employment are consistent with IFC’s PS2. The Region has a limited number of contracted workers in housekeeping and maintenance, also hired as public officials under the same decree, through a centrally managed process.

Casa Transports has human resources (HR) policies and procedures covering job descriptions and grades, recruitment procedures, leaves and performance evaluation in compliance with the Labor Code and consistent with PS2. For the construction of Lines T3 and T4, Casa Transports will contract about 40 different contractors which will be supervised by the PMC. Casa Transports has developed a Responsible Construction Policy (Charte des travaux responsables), as described above under PS1, which all the contractors and their sub-contractors are required to comply with as per their contracts. This policy covers labor compliance clauses such as respecting legal age limits, monitoring workforce and obligation to have employment contracts in place. Construction supervision by the engineering consultant for Component 2 will also cover labor compliance.

Human resources  requirements for RATP Dev and their compliance with applicable laws are defined in their contract with Casa Transports, which includes the requirement for a human resources policy covering recruitment, remuneration, career and performance management. RATP Dev has a detailed training plan for employees and relevant performance indicators are monitored and reported annually. In addition to the direct employees, there are around 600 contracted station officers, and 20 landscaping workers. RATP Dev requires their subcontractors to follow the labor code and audits them annually. Equally, an operator’s Human Resources Policy, consistent with IFC’s PS2, will be required for Lines T3 and T4 operations and it will be incorporated within the Operation ESMP as per ESAP item 2b).

Workers’ Organizations:

Although there is no established union or collective bargaining agreement in Region or Casa Transports, public officials decree and labor code in Morocco recognize employees’ rights to form and join unions of their own choosing and prohibits any discrimination on the ground of union membership. Each entity has established their own worker representative systems.

Majority of RATP Dev workers are unionized under the Moroccan Workers Union (UMT - Union Marocaine du Travail). A negotiation process, involving several worker committees, has started in January 2019 between the union and operator’s management to establish a collective bargaining agreement (CBA).

Non-Discrimination and Equal Opportunity:

The royal decree on hiring and working conditions of public officials prohibits any discrimination on the basis of gender. The labor code applies without discrimination on race, gender, handicap, religion, political opinion, union membership, country or social origin. A recent law is enacted in Morocco in 2018 (Loi 103.13) for eliminating gender-based violence, sexual abuse and harassment, with preventive and law enforcement measures. Both Region and Casa Transports comply with the national legal requirements.

Retrenchment:

The operations of Lines T3 and T4 will cause the termination of the service for some of the bus lines currently operating along the routes which will be covered by the tramway system. However, it is planned that new bus routes will be put in service to complement overall public transportation needs.  No retrenchment is expected with the introduction of the new tramway lines.

Grievance Mechanism: 

At the level of the Region, grievances related to working conditions, remuneration and promotions can be raised by the workers to a Joint Committee (Commission paritaire) for further assessment, consistent with requirement of this Performance Standards. The existing process, however, does not allow anonymous complaints to be submitted. As per ESAP item 7a) the Region will modify their internal grievance mechanism to allow a channel for submission of anonymous complaints by the employees. 

The formal grievance mechanism of Casa Transports is focused on receiving and addressing external grievances, whereas there is a practice that internal grievances are handled directly by supervisors.  Employees and contracted workers can individually or collectively submit a complaint to the Labor Inspectorate to start a conciliation process and there are escalation mechanisms in place in case an agreement is not reached between parties. RATP Dev has a grievance mechanism that allow workers to raise issues related to working conditions; RATP Dev will align this mechanism with PS2 in line with ESAP item 2b. 

It is expected that several local contractors will be hired by the Region for the upgrading of the rural roads and hence a consistent grievance mechanism is required.

As per ESAP item 7b) and item 7c) Casa Transports and the Region, respectively, will include in the new contractor contracts, a requirement to have a grievance mechanism in place for construction workers that allows anonymous complaints to be submitted and to record and keep grievance logs available and accessible for inspections and audits. Existing contractors will be informed of the above-mentioned requirement.

Protecting the Work Force / Forced and Child Labor:

Moroccan Labor Code prohibits employment of minors below 18 years old in hazardous works related to construction activities. The engineering consultants for both components will supervise construction sites regularly to monitor and report that no child or forced labor are being employed by the contractors. For the supply chain of Component 2, Region will develop a screening procedure for its road materials suppliers, under the ESMP as per ESAP 3), that will ban any use of child labor / forced labor in their processes.

Workers Accommodation:

Component 1 will prioritize local hiring and, as the project is in urban setting, it is not expected to generate a significant influx of job seekers. The contractual clauses include obligation to provide decent accommodation (daily cleaning, disinfection, housekeeping, sewage and waste management available) and, as part of the Construction ESMP (ESAP item 2a), they will be strengthened to include specific requirements on available space, bathroom areas per person, and prohibition of hot-bedding, consistent with IFC’s PS2 and the relevant IFC and EBRD Guidance Note on `Workers’ Accommodation: Processes and Standards`.

While about 900 jobs are expected to be generated for the upgrade of the rural roads, each road upgrade will require a limited construction workforce.  The construction crews of the local contractors will likely originate from the broader region as qualified workforce is expected to be limited in the rural communes. The project will prioritize hiring from local villages for unskilled jobs. As part of the Construction ESMP (ESAP item 3), the Region will define the minimum requirements for worker accommodation services in line with IFC’s standards, as discussed above, which all the contractors will be contractually required to implement.

Occupational Health and Safety:

Project construction work will entail work at high, scaffolding, excavations, trip and fall, lifting, working in confined spaces, working with electrical equipment, use of fuels and chemicals and other OHS risks that will need to be mitigated. For both components, OHS specifications are included in the tender documents, and for Component 1 they require each individual contractor to prepare an OHS plan for approval before commencement of the works.

For both components, the Construction ESMP developed per ESAP item 2a and item 3 will include the project OHS requirements in line with PS2 and will cover risks and hazard identification, prevention and control including procedures for safe working instructions, use of personal protective equipment, machinery and equipment inspections, and work permits; accident prevention, control and reporting; training programs; emergency response; and safety performance.

For the tramway operation, RATP Dev maintains a detailed OHS risks identification and risk assessment tool to screens through each activity and work areas and assess existing prevention and protection measures or identify the need for additional measures. A procedure defines the role of the operator’s management and the QHSE department in identification and implementation of the actions.  RATP Dev reports on implementation of OHS actions in the annual report. The operator will report to IFC on OHS performance (including performance of sub-contractors) and improvement activities in line with IFC’s Performance Standard 2 as part of the Operations ESMP (ESAP item 2b).  

 Component 1

Resource Efficiency and Greenhouse Gases:

The tramway will be electrically powered through an electric line 6 m above the rail. Energy consumption for T3 and T4 is estimated at 40.9 GWh/yr, which is associated with an estimated emission of 29,800 tons CO2/year.

During operation, water consumption will be mainly related to cleaning of tram vehicles at the maintenance center. The tram cleaning system will recycle the wash water, and include a system for collection of used water, filtration, biological treatment and reuse. Water consumption is expected to be around 300 m3/month and will be provided by the municipal network.

Pollution prevention, wastewater, wastes and hazardous waste management:

Risks associated with pollution prevention, wastewater, solid waste and hazardous waste management are typical of construction activities in urban areas. General environmental protection legal requirements for the tramway construction works are defined in article 30 and article 31 of the governmental decree which establishes requirements for all public construction works (Cahier des clauses administratives générales applicables aux marches de travaux – CCAG-T). Pollution prevention requirements and good practices are also included in construction contract project documents (waste management, air emissions, water protection, hazardous material storage). Implementation of management measures by all contractors in line with IFC Performance Standards 3 will be ensured through the Construction ESMP (ESAP 2a).

During operations, an improvement of urban air quality is expected through substitution of vehicular traffic by electrically powered tramway operation not generating local air emission. The technical specifications of heat, ventilation and air conditioning systems of the new tram cars will be compliant with European Union Norm 14750 and will ensure that ozone depleting substances are not used in any equipment.

At the Maintenance Center, wastewater from sanitary facilities will be collected and discharged into the municipal sewer network. Rain water will be handled in a separate network and will go through oil/sediment separation before discharge to the municipal network. Tram vehicles’ cleaning waters from the washing facility will go through filtration and biological treatment process before reuse to reduce water consumption. Final effluents will discharge to the municipal sewer network.

Solid waste from the maintenance center are estimated at 5 t/month (domestic, wood, metal, cardboard) and hazardous waste and used oils at 1.5 t/month.  Waste streams will be segregated, and hazardous waste / used oils will be stored in areas with adequate secondary containment and disposed of through specialized waste contractors in line with Law 28-00 regarding waste management and disposal.

Noise and vibration:

During operation, noise is generated by the contact between wheel and rail braking, by aerodynamic noise generated by the train itself, and by the engine and cooling fans. In line with good practice, project design includes the following noise impact mitigation measures: regular rail reprofiling and application of lubricants to suppress squealing, as well as selection of specific rail profile in curves less than 120 m diameters. The tramway platform will be placed on systems absorbing vibrations when located less than 12 m from buildings. Baseline noise levels were measured along the alignment and will be used to monitor noise levels during operation as per the Operations ESMP.

Component 2

Pollution prevention and control associated with the project are typical of any road construction activity and expected to be limited, given the nature of the project and the limited additional footprint required for the upgrade of each road. They will include, among others, construction noise and vibration, soil erosion and sediment loading and runoff management, dust and exhaust gas emissions, construction waste management, hazardous material management, limited water usage and temporary traffic disruption. Construction risks and impacts will be managed in line with IFC’s Performance Standard 3 through the implementation of Construction ESMP (ESAP item 3).  

 Component 1

Community Health and Safety:

The tramway lines will be constructed within a highly populated urban area. Specific requirements on safety in the areas affected by construction, including traffic safety, are included in the contractors’ tender documents, and weekly coordination meetings (Maîtrise de Coordination de Chantier) will be required to verify their implementation with the participation of all project stakeholders (Casa Transports, the PMC, and the contractors) and institutional stakeholders.

The contractor’s implementation plans, aligned with the Construction ESMP, will have detailed procedures to minimize and monitor noise and vibration, dust, as well as provision of measures to protect communities, pedestrians and vehicular traffic, including barricading, control of access to construction areas, safe alternative pedestrian and vehicular accesses, control of the construction vehicles, and signaling.

Per concession contract requirement, the tramway operator has developed a procedure and, since 2016, has formed a Safety Unit (Cellule de sécurité ferroviaire) to analyze accidents and to identify corrective actions and system improvements. In 2017, RATP Dev, Casa Transports and the National Traffic Safety Committee (Comité National de Prevention des Accidents de Circulation) signed a tri-partite convention to build an active partnership on communication and sensitization on road safety.

On Line T1, 132 traffic accidents with four fatalities occurred in 2017 and 122 accidents and two fatalities in 2016. The associated accident rates were 0.44 and 0.51 accidents every 10,000 km in 2016 and 2017 respectively.  A large proportion of accidents involved bicycles and horsecars, followed by accidents involving pedestrians, motorcycles and cars. Following investigation, the key root causes of the high accident rates along Line T1 were found to be primarily associated with violations of the traffic code by local drivers but also insufficient signals, especially around construction work areas.  RATP Dev developed an action plan to improve signage and controls at construction areas and eliminate blind spots. The operator also started regular safety meetings with police, implemented safety reviews of tram journeys, and implemented a tool to analyze and manage tram drivers’ performance and compliance with speed restrictions. As part of ESAP item 2b, the operator will develop a Community Safety Management Plan, consistent with IFC’s Performance Standard 4 and good international industry practice. 

Regarding operational safety, at design and construction stage the PMC is responsible for the coordination of the operational safety between each components of the tramway. Technical specifications require tram vehicles to comply with European Norms for Railway safety EN 50126-1, EN 50128 and EN 50129, and the tram manufacturer to develop a safety assurance plan, and to hire an Independent Safety Assessor.  The concession contract requires the tramway operator to develop a Safety Management System, including a risk assessment and procedures to analyze all incidents and accidents, and to develop an Operational Safety Manual (Règlement de Sécurité de l’Exploitation) for approval by Casa Transports. Technical specifications require tram vehicles to be fire resistant in line with European Norm 45545: fire protection of railway vehicles.

Safety of passengers, especially women, was identified as key risk by ESIA and mitigation measures were identified, such as installation of CCTV cameras, awareness raising campaigns on harassment and gender-based violence, training for Casa Transports and RATP Dev personnel. As per ESAP item 8, Casa Transports, in coordination with the operator, will prepare and implement a gender safety action plan including, but not limited to, the measures presented in the ESIA.

Component 2

Given its nature, road upgrade works will be conducted whilst maintaining traffic on each road segment. Safe coordination of works with passing traffic will be required to ensure road and traffic safety. Relevant traffic safety procedure, including use of barricades and signage and deployment of flagmen, will be developed as part of the Construction ESMP (ESAP item 3).

Upgrading of rural roads will require bringing in qualified workers from urban areas. The workers will be housed in adequate accommodations as described above in PS2. As part of the Construction ESMP (ESAP item 3), the Region will develop a code of conduct for the construction contractors, including principles regarding behavior and interaction with local communities.  Compliance with the code of conduct will be monitored by the Region.  

Security Personnel:

Component 1

The operator is contractually required to ensure safety and oversight of the tramway network and to develop a Risk Management Plan for the maintenance center and the trams to address security risk (Plan de Prévention des risques pour le centre de maintenance et le matériel roulant). The National Police is continuously present in the Control Center of the Tramway (where monitors display all stations and intersections) to immediately coordinate all interventions with RATP Dev personnel. Security of Line T1 involves 210 operator’s surveillance officers (unarmed) supported by police officers located in proximity. Lines T3 and T4 will have similar security arrangements. The operator is contractually required to act under Moroccan law, and to declare its security personnel to the Authorities.  A tri-partite agreement between Casa Transports, RATP Dev and the Police defines roles and responsibility of each party focusing on preventive measures, coordination mechanisms and common procedures to be followed in case of security incidents. A security management plan will be developed as part of the Operation ESMP (ESAP item 2b) in line with PS4, addressing recruitment/vetting, training, rules of engagement/use of force for Casa Transports’ security staff and contractors, security systems and equipment monitoring and reporting.

Component 2

Security risks for the road upgrade program are minimal and measures to protect the construction sites will involve agreements with local villages. As for the first phase of the program, access to construction site and materials will be guarded by local community members who will be adequately trained and equipped for the limited duration of the construction works in each commune’s territory. Private security providers will not be used.     

 Component 1

Public consultation and disclosure process for Component 1 is carried out in accordance with national requirements. During the preparation of ESIAs, local stakeholders (such as local businesses, residents, taxi drivers, other public transportation operators) were identified, but not consulted, while consultation with the relevant public agencies was carried out by the consultant. Information regarding the alignment of Lines T3 and T4 and planned work schedules are publicly available on Casa Transports website.

The two ESIAs conform to the requirements of the Moroccan environmental assessment law and regulations, including the relevant disclosure of information and public consultation requirements.  Public consultation was ongoing at the time of appraisal. The national law requires the disclosure of a Non-Technical Summary of the ESIA in French and Arabic and the layout plans at each one of the 16 affected sub-governorates (arrondissements) where public comments are to be received and recorded. Disclosure is announced in local newspapers 15 days before a 20-day consultation period starts in each district. Community’s comments collected at the level of the district are communicated to the General Directorate of Environmental Affairs which convene the National ESIA Committee to review all comments. According to Casa Transports no significant comments were raised from the affected sub-governorates to the National Committee.  The ESIAs, disclosed with this ESRS, are under review and the final versions will be disclosed once approved.

Since 2017, Casa Transports has put in place an effective grievance mechanism which is aligned with Performance Standard 1. The mechanism is widely known and used by the public to raise concerns, complaints and requests related to transportation projects. Grievances are categorized based on their level of urgency according to criteria described in the relevant procedure, whereby the most urgent grievances (such as power shortage due to construction works) are responded directly by Casa Transports within 1 hour and other construction related grievances are responded within 24 hours. Casa Transports also distributes flyers around the construction sites to provide information on planned works, anticipated impacts and details of the grievance mechanism. Info points and boards will be installed at central locations of the project and a guide about tramway works will be distributed to the public.

In addition to the public hearings required by the national regulatory process, additional project consultation with affected communities will be carried out consistent with PS1 requirements; the consultation process will be described in a project Stakeholder Engagement Plan (SEP) which will be disclosed locally. The SEP will include a stakeholder analysis and will specify ongoing disclosure and dissemination of information, consultation planning, grievance mechanism, and ongoing reporting to affected communities (ESAP item 12).

Component 2

The selection of rural roads to be upgraded under Component 2 will be based on a bottom-up process whereby local communes collect and assess village level needs and present requests to the Region. The Region will assess the requests received, based on a list of criteria for each commune including population density, number of affected villages, number of local markets, schools, health centers, density of unpaved roads, and presence of areas with impassable roads during bad weather.

Based on this assessment, the Region will prepare the Rural Road Upgrade Program which is shared with the local communes. The communes are then required to prepare local Road Upgrade Plans and to share them with village representatives at the level of the Communal Councils. Once the plan is finalized and approved at local level, the Region will initiate the construction works. There is no requirement for a wider disclosure and consultation with affected communities, although communities are seen by the Region as supportive of the program, which is perceived as an improvement to their living conditions, particularly in terms of improved access to markets, schools and other social infrastructure, which is otherwise challenging. 

There is no formal grievance mechanism specifically designed for this project; however grievances about the acts of public administration can be raised anonymously by all citizens to a national grievance mechanism accessible online (chikaya.ma). Local communes are small in size and they need assistance to carry out community engagement and to collect and process requests and grievances from the community members. The Region is therefore including the preparation of a wider communication plan as part of the Regional Mobility Plan (RMP) which will identify target groups, key messages and ongoing information process focused on the objectives and the actions under the RMP. While the proposed communication plan is aligned with IFC’s Performance Standard 1 requirements on ongoing disclosure of information to communities, it will need to be supplemented with respect to mapping of stakeholders, consultation with affected communities and collecting and handling grievances in a systematic and consistent way.

As per ESAP item 13, the Region will prepare a project SEP inclusive of a community grievance mechanism for Component 2. The implementation for the SEP and coordination and technical assistance to local communes will be a responsibility of the E&S officer appointed as part of ESAP item 6. 

An ESIA is not required for Component 2, but E&S screening studies will be carried out for each road included in the program as per ESAP item 4. Under the proposed investment, the Road Upgrade Program and the E&S screening studies will be disclosed on Region’s website and presented to the affected communities as part of the SEP implementation.   

  Contact Person: Ahmed EL KIAL

Company Name: REGION CASABLANCA SETTAT

Address: Boulevard Victor Hugo, Quartier des Habous, Casablanca, 20250, MOROCCO

Email: a.elkial@casasettat.ma

Phone: +212 522 441 392

Facsimile: +212 522 440 008