There are no risks or impacts associated with Performance Standard 7: Indigenous People –  no indigenous people are known to live or travel through the project area.  PS8: Cultural Heritage impacts are not anticipated as the project will involve upgrading of 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, accordingly, a chance find procedure will be established by the Region.    

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 the upgrade of the rural roads under PRDTS is 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.  There are minimal or no adverse environmental or social risks and/or impacts associated with the procurement of products and equipment for disinfection and sterilization as part of the emergency preparedness and response for the COVID-19 pandemic.

Key environmental and social (E&S) issues associated with the project 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) minimization and management of limited land acquisition, livelihood and land use impacts due to widening of the rural roads, iii) community health and safety, iv) labor and working conditions and occupational health and safety (OHS) for construction workers, v) minimization and management of biodiversity risks and vi) stakeholder engagement and grievance management.   

 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 of the project.  As part of ESAP item 1, the Region will issue an overarching environmental and social policy to articulate its objectives and principles that will guide the project to achieve sound environmental and social performance, consistent with IFC’s Performance Standards.

For the previous phases of the PRDTS 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 2, the Region will develop and implement an Environmental and Social Management Plan (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, community engagement, grievance management, 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

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 3 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 construction, 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.

Organizational Capacity and Competency:

The Region supervises the road program through its technical team in AREP. There was no dedicated E&S management oversight for the implementation of the previous phase of the rural road upgrade program.

As per ESAP item 4, 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 the project and to monitor and report to IFC on implementation of ESAP and project requirements consistent with IFC’s Performance Standards.

Emergency preparedness and response:

The Region will ensure that the ESMP includes emergency preparedness and response.

Monitoring and Review:

The ESMP will include a monitoring and reporting framework covering, among others, waste management, traffic safety, noise and vibration, inspections and audits, occupational and community health and safety, incidents and accidents, labor compliance, biodiversity protection, community grievances, and chance finds.      

 The Region employs about 80 full-time staff, among which about 40 are women and 40 permanent contractors. The AREP employs about 40 staff and approximately 8 are women, and 10 contractors.

The project is expected to require a workforce of about 230 workers in average for the 2 years needed to complete the construction works for the upgrade of the rural roads.

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), whilst the terms of employment for AREP staff comply with the Labor Code applicable to the public sector (“function publique”) and are further defined in a HR Policy (“ Statut du Personnel” ). 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.

Workers’ Organizations:

Public officials decree (Dahir 1.58.008) 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. A few staff from the Region are part of the Union Marocaine des Travailleurs. The Region also has their own worker representative systems (“Commission paritaire”).

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 was enacted in Morocco in 2018 (Loi 103.13) for eliminating gender-based violence, sexual abuse and harassment, with preventive and law enforcement measures. The Region and AREP comply with the national legal requirements.

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 Standard. The existing process, however, does not allow anonymous complaints to be submitted. As per ESAP item 5a the Region will review and update their internal grievance mechanism to allow a channel for submission of anonymous complaints by the employees and will ensure that its contracted workers have access to its grievance mechanism, as well as  AREP staff have access to a grievance mechanism, consistent with the requirements of this Performance Standard. 

It is expected that several local construction contractors will be contracted by the Region for the upgrading of the rural roads. As per ESAP item 5b the Region will include, in the construction contractors’ 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 AREP will supervise construction sites regularly to monitor and report that no child or forced labor are being employed by the contractors. The Region will also develop a screening procedure for its suppliers of construction materials for the road works, under the ESMP as per ESAP 3, that will ban any use of child labor / forced labor in their processes.

Workers Accommodation:

While a total of about 230 construction 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, and in certain cases they may need to be provided with accommodation services. As part of the ESMP (ESAP item 2), the Region will define the minimum requirements for worker accommodation services in line with IFC’s standards, which the contractors will be contractually required to implement as needed.

Occupational Health and Safety:

The project implementation will entail occupational health and safety (OHS) risks which are typical of construction works, including work at height, excavations, trip and fall, lifting, working with electrical equipment, use of fuels and chemicals and other OHS risks, that will need to be mitigated. The tender documents include OHS specifications and require each individual contractor to prepare an OHS plan for approval before commencement of the works.

The ESMP developed per ESAP item 2 will include the project OHS requirements in line with PS2 and will cover risks and hazard identification, prevention and control; use of personal protective equipment; machinery and equipment inspections; work permits, accident prevention, control and reporting; training programs; emergency response; and safety performance.    

 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 the ESMP (ESAP item 2).   

 Given the nature of the road upgrade program, the construction 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 ESMP (ESAP item 2).

Upgrading of rural roads will require bringing in qualified workers from the broader region. In certain cases, the workers may need to be housed in adequate accommodations as described above in PS2. As part of the ESMP (ESAP item 2), 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 through AREP.  

Security risks for the road upgrade program are minimal. Notwithstanding, as part of the ESMP (ESAP item 2), the Region will develop provisions for contractors to manage security, as required, in line with PS4.  

 A biodiversity assessment was conducted to characterize 65 road segments (total length of 386 km) of the PRDTS road program for 2020-2021 for which GIS coordinates were provided. Overall, relative biodiversity values within the various provinces could be summarized as follows: (i) 26 segments in Moulay Yacoub, Meknes and El Hajeb provinces traverse converted agricultural lands with generally low biodiversity value; (ii) 14 segments in Taza and Taounate provinces also traverse large areas of agriculture, although segments located in the northern part of these provinces overlap with the beginning of the Rif mountains where forest, steppe and matorral habitats of higher biodiversity value are found; and, (iii) 25 segments in the south within Ifrane, Sefrou and Boulemane provinces cross the Moyen-Atlas mountains, where higher value forest, steppe and matorral natural habitats are also found. Agricultural areas are also present in these provinces but to a lesser extent with respect to the northern provinces. The south of Boulemane province begins the transition to desert and desertic steppe habitats.

The biodiversity assessment consisted of extensive literature review and a field survey with an international ecologist and local biologist (field team). High value biodiversity species were screened for the entirety of the project area using Critical Habitat criteria.  59 “priority species” were defined, based on their biodiversity value and potential risk of impact; they comprise two mammals, six birds, two amphibians, seven reptiles, 22 insects and 20 plant species.  A field guide was developed beforehand that identifies habitat features per priority species to guide the effort.  “Low”, “medium” and “higher” habitat sensitivity classes were defined based on habitat types, altitude and numbers of priority species. Of the 65 segments, three segments cross habitats with higher sensitivity (total length of 37 km); nine segments cross habitats with medium sensitivity (total length of 72 km); and, 53 segments cross habitats with low sensitivity (total length of 277 km).

All segments crossing Legally Protected Areas, Key Biodiversity Areas (as designated by IUCN) and Important Bird and Biodiversity Areas (as designated by BirdLife International) were excluded from financing. Two of the 65 segments (25 km) cross Sites of Biological and Ecological Interest (SIBEs); these sites are recognized nationally for their biodiversity value and are legally protected under the law for hunting.   PS6 Natural Habitats requirements will apply for all segments crossing medium and higher sensitivity habitats, as defined above.  Critical Habitat requirements will apply to the two segments crossing the SIBE sites.

For all segments included in the financing, footprint expansion will be minimal to non-existent as road segments will be upgraded, but not widened, or minimally so.  Nonetheless, on-site biodiversity minimization measures will be included in the ESMP per ESAP Action 2.  These include, for example, avoiding construction during breeding periods, compensation of tree removal by a ratio of 1:3, restoring water courses, implementing erosion and sedimentation controls, etc. Per ESAP Action 4 a biodiversity specialist will confirm adherence to biodiversity measures and will be present during construction in higher-risk segments.  

Also as part of the biodiversity assessment, interviews were carried out with relevant national stakeholders regarding potential programs that would advance the conservation in higher value habitats. Although footprint expansion is not foreseen in the segments crossing the SIBEs, per ESAP Action 8, the Region will carry out a conservation program to improve biodiversity management in these areas, based on stakeholder feedback.

 The selection of rural roads to be upgraded was conducted collaboratively by the Ministry of Interior and the communes who collected and assessed village level needs.  The Region assessed the list of roads by confirming the relevance of the needs and according to feasibility criteria.

Based on this assessment, the Region prepared the list of roads to be included in the 2020-2021 program which was shared with the local communes. There is no requirement for a wider disclosure and consultation with affected communities.  Based on IFC’s review of available information, local communities are supportive of the program, as it will bring an improvement to their living conditions, particularly in terms of improved access to health services, markets, schools and other social infrastructure, which is otherwise challenging.

The Region has set up a grievance mechanism that is not specific to the rural roads improvement project, and needs to be aligned with the requirements of IFC’s Performance Standard 1. Grievances about the acts of the 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.

As per ESAP item 9, the Region will prepare and implement a project Stakeholder Engagement Plan (SEP) inclusive of a community grievance mechanism, and scaled to the project risks and impacts and development stage. Community grievance mechanism will also address potential complaints related to gender and gender-based violence from communities due to influx of construction workers. 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 4. 

While an ESIA is not required, E&S studies will be carried out for each road included in the project as per ESAP item 3. Under the proposed investment, the Road Upgrade Program will be disclosed on Region’s website and to the affected communities as part of the SEP implementation.    

 Contact Person: Mme Oumama Fassi-Fehri

Company Name: La Région Fès-Meknès

Email: fassifehri13@yahoo.fr