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.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
E&S Policy and Management System: The PTP has a Quality, Safety and Environmental (QSE) Policy aligned with TMPA’s Corporate QSE Policy, which includes commitments to: (i) ensuring regulatory compliance; (ii) evaluating and managing E&S risks and impacts; (iii) proper waste management and sustainable use of natural resources; (iv) identify, evaluate, and manage health and safety risks of its activities to its workforce and partners; (v) security of assets at the port; and (vi) achieve overall health safety and environmental excellence.
TMPA operates an Integrated Management System (IMS) described in a QSE Manual certified against international standards; ISO 9001:2015 (Quality), ISO 14001:2015 (Environment) and ISO 45001:2018 (OHS). As part of the IFC investment, TMPA will update its E&S Policy, incorporating Human Resources and EPC E&S requirements, and based on the existing IMS, update its E&S Management System (ESMS) to adapt it to the needs of the project construction and operations phases, detailing coordination arrangements with TME, TMU, TMF, and EPC Contractors / Subcontractors, as well as processes pertaining to assessment of environmental, occupational health and safety (OHS) risks and impacts from its activities, and operational control procedures to mitigate the identified risks and impacts in line with local regulations, IFC Performance Standards (PS) requirements, and relevant WBG EHS Guidelines (ESAP #1).
Identification of Risks and Impacts: A Local ESIA was developed for the project and submitted for approval by the relevant state authority on 11 July 2023 and subsequently updated on 24 August 2023 to align with IFC PSs, by including (a) socio-economic baseline data collection, (b) stakeholder engagement plan, (c) climate impact assessment, (d) cumulative impact assessment, (e) critical habitat assessment, (f) assessment of designated project laydown and temporary staging area, and (g) additional water and sediments monitoring data incorporation. As part of IFC financing, supplementary baseline studies and impact assessments will be conducted (ESAP #2) to strengthen E&S management and monitoring approach including transport impact assessment covering both road traffic and maritime transport.
The project will obtain 20 million cubic meters of rock materials from existing quarries 8 km from the port and transport them using existing access road. Supplementary E&S impact assessment of the access road has identified high traffic risks, which warrants the creation of a 4.7 km bypass road around the populated area. Access rights have been secured by the EPC Contractor, and a formal usage agreement has been established between the EPC contractor and the mayor of the local commune, which will retain use of the road beyond the construction period. TMPA will ensure that if there is evidence of existing economic activity or community dependency on the land prior to construction, the EPC contractor will prepare a Livelihood Restoration Plan (LRP) which includes: (i) a summary of past and future engagement with project affected persons (PAPs); (ii) quantification and categorization of the impacts on land; (iii) conditions for land donation; (iv) compensation arrangement; and (v) monitoring framework (ESAP #3)
A climate risk assessment conducted as part of the ESIA, and other analytical tools, indicate that the project area is subject to climate-related vulnerabilities like (i) increasing temperatures and heatwaves, (ii) increasing wildfire risks, and (iii) coastal flood hazard. As part of IFC investment, TMPA will ensure that climate change projections on heat stress to employees and impact on water resources are factored into the OHS procedures and water management plans including; altered work regimes, automation, personal protective equipment for work activities, guidelines to reduce exposure during extreme heat, emergency planning and training on extreme weather events, provision of shading/resting areas within the port and terminal to abate the heat; availability of potable drinking water across all shading areas, water and soil quality monitoring, a drainage design solution that includes appropriate allowance for climate change in outfall design and monitoring of the Oued Rmel Canal (ESAP #4).
Management Programs: An ESMP has been developed as part of the ESIA, which provides a summary of mitigation and monitoring measures and indicates that the EPC Contractors are responsible for the management of E&S aspects during the construction phase. As part of the IFC investment, TMPA will ensure that EPC Contractors develop a construction phase ESMP and relevant implementation plans and procedures(combined in the ESMP or as standalone documents) aligned with IFC PS, the updated ESIA and the supplementary assessments, including; (i) E&S Monitoring Plan; (ii) Emergency Preparedness and Response Plan; (iii) OHS Plan; (iv) Worker Accommodation Plan; (v) Labour Management Plan; (vi) Supply Chain Management Plan; (vii) Air Quality, Noise and Vibration Management Plan; (viii) GHG & Energy Efficiency Management Plan; (ix) Waste Management Plan; (x) Wastewater Management Plan; (xi) Pollution Prevention Plan; (xii) Hazardous Materials Management Plan; (xiii) Water Management Plan; (xiv) Community Health, and Safety Management Plan; (xv) Security Management Plan, including a Code of Conduct for security personnel; (xvi) Terrestrial and Marine Traffic Management Plan; (xvii) Biodiversity Management Plan; and, (xviii) Chance Find Procedure (ESAP #5).
Organizational Capacity and Competency: TMPA has a clear E&S organization with defined roles and responsibilities and, along with TME, is responsible for implementing and monitoring the ESMPs during construction. The PTP organogram includes a QHSSE Manager with direct reporting lines to TMPA’s Managing Director. He is supported by two EHS Engineers and two EHS Supervisors. The PTP team is supported by a dedicated project implementation team from TME with an EHS Manager who will liaise with the EPC Contractors’ EHS Managers and delivery team.
Going forward, TMPA will enhance its EHS organization for the operation phase with clearly defined roles and responsibilities and reporting lines. Additionally, TMPA will appoint a dedicated liaison person from TMF to assist the EPC Contractors in managing community engagement with the neighbouring communities and work closely with the local government authorities in the development and implementation of social mitigation measures as identified in the ESMPs. Furthermore, TMPA will ensure that the EPC Contractors deploy an EHS organization comprised of at least one dedicated environment professional, safety professionals, and human resource professionals (ESAP #6).
Training: TMPA has a structured EHS training program covering aspects such as health and safety, first aid, fire safety and vehicle and navy safety and training is provided to all staff including contractor workers. TMPA will require EPC Contractors to implement an EHS training program for the construction workers including induction training, daily toolbox talk, training on emergency response and construction safety as well as awareness on all updated EHS policies, standard operating procedures (SOPs) manuals, risk identification, management plans, worker's grievance mechanisms, and gender-based violence and harassment (GBVSH) before the beginning of the construction works (ESAP #7).
Emergency Preparedness and Response: A robust emergency response system exists at the port under the harbor master’s office and is supported by a well-trained and resourced team with drills organized frequently. As per ESAP #5, TMPA will develop a project-level Emergency Preparedness and Response Plan.
Monitoring and Review: TMPA’s corporate IMS requires regular monitoring of project activities and ESMPs by TMPA’s QHSSE team and external auditing by third parties. As per ESAP #5, TMPA will develop a construction phase project-level E&S Monitoring Plan in line with IFC PS and relevant WBG Environmental Health and Safety Guidelines. During the operation phase, the E&S monitoring will follow the current TMPA monitoring regime which is generally consistent with IFC PS.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures: TMPA’s HR policy is aligned with local requirements and includes provisions for non-discrimination, anti-harassment, and compensation for overtime as well as child labour. TMPA will cascade its HR Manual to the project and ensure the Ethical Chart approved by TMPA board with specific mention of zero tolerance to discrimination of age, race, color, and nationality in the workplace is signed by EPC Contractors (ESAP #8).
Working conditions and terms of employment: Tanger Med Group employs 620 people at the corporate level, constituted of 82 % male and 18% female. Even though there are no unions, a workers’ representatives committee has been established since 2016 in line with Moroccan Labour Code.
Grievance mechanism: TMPA has an internal grievance mechanism and an associated two-tier mechanism for direct employees to address workplace concerns. A copy of the internal grievance process notice is posted close to the information board of each floor in the administrative block. The Ethical Chart will formalize the ‘open door policy’ within the HR department where internal complaints are treated in confidentiality and anonymously. As part of the IFC investment, TMPA will ensure that the workers of the EPC Contractors will have access to the Workers’ Grievance Mechanism in line with PS2 and maintain a log of workers’ grievances (ESAP #9).
Workers engaged by third parties: 1200 workers are expected to be employed during the construction phase while 116 during operations, the majority (80%) of which will be directly employed by the project. TMPA has contracts with three security companies, transportation, and catering companies. Contracts include reference to meet national Moroccan labor law in hiring and payment. Informal and casual labor is not permitted within TMPA perimeter. At the award of the EPC contract, TMPA will ensure that the EPC Contractors will (i) be required to comply to National labor Code and to include TMPA’s IFC PS-aligned labor requirements in the contracts with the workers, and (ii) prepare and implement a workers accommodation plan in line with PS2 requirements and consistent with the IFC/EBRD’s Workers Accommodation Process and Standards (ESAP #10).
Occupational Health and Safety: TMPA’s OHS management system, which is ISO 45001:2018 certified, relies on core procedures including risk identification and assessment, risk management, and procedure for identification and compliance with regulatory requirements. The corporate QHSSE procedure stipulates that TMPA projects must have documented systems for managing OHS. The ESMS (ref. ESAP #1) shall include specific contractor requirements, such as OHS risk assessment requirements for EPC contractors. As per ESAP #5 TMPA will ensure that EPC Contractors prepare an OHS Management Plan.
A total of 1,024 people (255 for TMPA and 799 from other service providers) worked at the PTP during the first half of 2023 without any lost time incident. TMPA has a pharmacy on site, a doctor available 24/7 with three shifts a day, and a lactation room.
As detailed in PS1, (ref. ESAP #1 & ESAP #5) TMPA will ensure that appropriate project-level monitoring and reporting on OHS performance, including leading and lagging indicators is performed. The PTP ESMS (ref. ESAP #1) shall also define sanitary facility standards to be developed to ensure that EPC Contractors sites are equipped including separate toilets for male and female workers. Similarly, TMPA’s ESMS (ref. ESAP #1) will define standards for project-level medical support, including clinics and / or ambulances, and trained personnel for first aid and emergency response, to be established at construction sites as well as coordination of project response with overall TMPA response system.
TMPA has a routine OHS training for all its employees, customized to the type of risk of the activity. The Project's General Manager will be responsible for ensuring that the staff onsite will have daily safety briefs before accessing the site (ref. ESAP #7).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: TMPA through its utility affiliate (TMU) is implementing initiatives to reduce energy and water consumption in accordance with its sustainability policy, and some of these initiatives will be applied to the project. Given the nature of the project’s activities, the energy needs are not significant, and a majority will be sourced from the existing national grid connection and the remainder through stationary generators. EPC Contractors are expected to source energy, water, and waste management services from TMU.
Greenhouse Gases (GHG): According to TMPA’s carbon footprint summary, the Scope 1 and Scope 2 emissions equate to 3,272 tCO2eq for the current Tanger Med Port Complex as of 2021. There is no GHG emissions assessment for the project broken down by Scope 1 and Scope 2 emissions for construction and operation. During construction, there shall be limited GHG emissions produced primarily from fuel combustion and transportation of equipment and employees to the site. Going forward TMPA will develop a GHG emissions inventory for the Project using internationally recognized methods, including estimation of Scope 1 and Scope 2 emissions for construction (ESAP #11).
Wastewater: The two existing sewage treatment plants (STP) at the Tanger Med Port have spare capacity to treat any additional wastewater generated by the project during construction and operations. Treated effluents from the STPs are re-used to irrigate the green spaces within the port facility. Stormwater from the berth area will be collected in a chamber after passing it through oil & grease traps and then discharged into the sea. The stormwater run-off from the platform which could have oil & grease and other hazardous waste will be collected in an oil & grease separation pit associated with the stormwater network before the final release. The primary liquid effluent that will be generated during construction will be domestic wastewater/sewage from chemical toilets, which will be channelled to the existing STP through a pipeline or by vacuum trucks.
Waste Management: Waste generated during construction will be segregated at source, transferred, and treated at the TMU-operated waste management facility. TMU also manages a specialized hazardous wastes processing plant, designed to treat waste oils and hydrocarbon-polluted water resulting from the operation of ships, in accordance with MARPOL 73/78 convention. Vessel-generated waste, including bilge water, is collected by authorized entities from the vessels and transferred to TMU’s processing plant for treatment and disposal. As included in ESAP#5, TMPA will ensure that EPC Contractors develop and implement a Waste Management Plan (including for hazardous wastes), ensure provision for appropriate storage and handling practices (e.g. contained storage on paved surface with provision for leachate collection drain and sump), and ensure segregated storage for hazardous and non-hazardous waste and hazardous waste quantity to be recorded and tracked from source to grave.
Pollution Prevention: Potential environmental impacts from construction activities are expected to be standard impacts for projects of this type and size and include modification of the bathymetry due to dredging, point source emissions and fugitive dusts, soil erosion and sediment loading increases, noise, waste management, spills of hazardous and other material during transport and construction, water usage, emissions from construction equipment and flood risk during the diversion of the Oued Rmel Canal. Also, during operations insignificant quantities of material will be generated by maintenance dredging restricted only to the deepening of the berth pockets and channel. EPC Contractors are responsible for undertaking detailed design, identification and assessment of offshore disposal areas (if required) and quarry sites. TMPA will contractually require their EPC Contractors to manage such risks in a manner consistent with local laws, IFC PSs and applicable WBG EHS guidelines (ref. ESAP#3).
Some of the specific pollution mitigation measures to be applied include (a) all equipment operated by the terminal is properly maintained and their emissions are within national standards and IFC EHS Guideline values; (b) trucks entering the terminal premises have appropriate pollution under control certificates; and (c) truck dwell time (particularly engine idling time) is minimized (d) ensure that refrigeration gases used in the reefers meet national ozone depleting substances rules requirements under the Montreal Protocol (e) implement measures to minimize risk of spill and overflow during transportation, (f) provision of water sprays and wheel washing to control mud /dust on roads and stockpiles, (g) covered transport of construction materials in trucks, and (h) managing potential shoreline erosion and erosion along the diverted canal. Going forward TMPA will ensure that erosion control measures are designed at the outlet of the canal and sediment analyses, assessment of dredging technique, and disposal method are part O&M procedures and continue to be responsible for disposal of dredged materials at designated locations ensuring that level 1 pollution analyses are carried out prior to use as fill material for future platforms (ESAP #12).
PS4: Community Health, Safety and Security
Community Health and Safety: The Project activities are within the port perimeter with the closest scattered settlement is located around 1 km of the project site. A blue-flag beach and a small fish port are located approximately 2 km east of the project location. A key source of community H&S impact will be the transportation of materials by the EPC Contractors and the accommodation of project workers during construction and overall increased traffic during operations. As per ESAP #5, TMPA will develop a Community Health and Safety Management Plan informed by the traffic impact assessments (ref. ESAP #2).
Security Personnel: TMPA has a robust security system with trained staff and ISPS certified. The security agents are provided by 3 security contractors. TMPA’s Contractors will deploy limited unarmed security for access control and safeguard of materials and equipment during construction. As per ESAP #5, TMPA will develop a project-level Security Management Plan (SMP) in line with ISPS protocols and IFC PS4.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Tanger Med Port Complex is located on the Moroccan coastline of the Strait of Gibraltar, and as mentioned in the project description, has been operational since 2007. The seascape in which the port is located is defined as an Important Shark and Ray Area (ISRA) and overlaps with the Gulf of Cadiz Ecologically or Biologically Significant Marine Area (EBSA). The Strait and surrounding areas are a hotspot for marine mammals with multiple Important Marine Mammals Areas (IMMAs) present. These IMMAs are considered to be important for subpopulations of Endangered or Critically Endangered marine mammals species, including, killer whale Orcinus orca, long-finned pilot whale Globicephala melas, sperm whale Physeter macrocephalus and common dolphin Delphinus delphi. Whilst the project site does not occupy core habitat for these species, the site is situated in a broad area within the seascape that is of importance for these subpopulations at large, and for this reason, Critical Habitat requirements are conservatively being applied.
To minimize direct impacts (e.g., habitat loss, alteration to water quality, disturbance to marine species), the project design will prioritize drill piling in lieu of percussive piling and follow industry good practices for pre-work watches, soft-starts/ ramping up, establish a buffer zone, soft-start delay and shut-down. Also as necessary TMPA, will undertake mitigation measures including (i) installing noise reduction measures for any percussive piling including barriers to control underwater sound, noise-dampening nets, cofferdams, noise barrier and noise reduction measures during vessel anchoring at the port; (ii) preventing impact to marine sediments by filling of barges transferring dredged sand to 90% and control dispersal of excess dredged sand, use of turbidity threshold alert systems, daily visual monitoring and monitor water transparency; (iii) preventing marine water contamination from spills by supervising all fuel handling operations, avoiding any storage of hydrocarbon within marine environment, ensuring adequate wastewater treatment prior to disposal and having in place adequate spill response capabilities; (iv) preventing impact to flora and fauna by periodically monitoring the physicochemical quality of water and sediment; and, (v) deploying a suitably qualified ecologist to monitor construction and developing a long term marine biology monitoring program. Per ESAP #5, the client, through its EPC contractors will include these and other biodiversity mitigation measures in the project ESMPs.
With respect to Critical Habitat requirements, going forward the TMPA will consult with relevant conservation organization to identify and implement an on-the-ground additional conservation action(s), related to key features that comprise Critical Habitat, and specifically, those species most threatened in the Strait of Gibraltar (ESAP #13). Also, per ESAP #13, the client will develop a fit-for-purpose Biodiversity Action Plan, which will (i) outline measures to be taken to avoid and minimize impacts on biodiversity in alignment with the mitigation hierarchy and as included in the ESMP; (ii) report on the outcomes of consultation, identify the selected additional conservation action(s), and associated implementation measures; and (iii) include monitoring measures for both implementation of the mitigation measures and the additional conservation action(s).
