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.
OCP has a group level ESMS structure aligned to ISO 14001:2015 requirements. Each site whether operational or under development is required to develop and implement an ESMS following this framework. JESA has developed a HSE Project Execution Plan which incorporates OCP policy requirements and sets out the HSE management system to be implemented for the construction phase. JESA has also drafted a set of minimum HSE requirements, which will be included in the request for proposals and in the contracts for the construction contractors. Collectively the OCP and JESA requirements will be referred to as the project requirements. The sections below detail the ESMS as applied to the project during the construction and operations phase.
Policy: OCP has in place a sustainability strategy, supported by several group level policies (last updated in April 2020) including sustainability, environmental management, and occupational, health and safety (“OHS”). These policies apply to all OCP sites and facilities including this project and are publicly disclosed on OCP website: https://www.ocpgroup.ma/sustainability/policies-and-standards.
Identification of Risks & Impacts: OCP has undertaken EIAs for the plants in accordance with Moroccan legislative requirements and are in line with IFC PS requirements. The main impacts identified include contamination of soil and water resources, air and noise pollution, vegetation removal, waste management, and increased traffic during construction; and water use (due to general water scarcity in the area) and waste management, during operations. Main positive impacts include employment opportunities and electricity production from renewable energy. Furthermore, according to the project requirements, the construction contractors will undertake a HSE risk assessment for construction activities, identify suitable control measures and develop and maintain a risk register. All task specific hazards will be managed using a Job Hazard Worksheet prepared following a Job Hazard Analysis (“JHA”) to be undertaken by the contractors prior to initiating any activities.
Management Programs: The project EIAs include framework EMPs, which provide the organizational structure for E&S management, mitigation measures and monitoring requirements applicable to the construction and operation phases of the project and are aligned with the WBG Environment, Health and Safety (“EHS”) Guidelines. The construction contractors and the operator will develop a Construction Environmental Management Plan (“CEMP”) and Operation Environmental Management Plan (“OEMP”), respectively, based on the framework EMP and in alignment with IFC PSs and WBG EHS Guidelines. (ESAP # 1). These plans will be supported by a number of associated “sub” plans including: emergency preparedness and response; labor management; health and safety; waste management; spill prevention and response; traffic management; and stakeholder engagement (including grievance management). Additional details about these associated plans and what they should include are provided in the applicable Performance Standard sections of this ESRS that follow.
Organizational Capacity & Competency: Both OCP and JESA have strong capabilities to manage a range of HSE and OHS issues as well as understanding of IFC and international best practices provisions and standards. During the construction phase, JESA will have a construction management team based at the Khouribga and Benguerir sites. The team will be led by a Site Manager and will include a HSE Manager responsible for overall HSE management and performance, supported by a team of HSE personnel to monitor, act and report on the activities of the construction contractor. Additionally, at each site, the construction contractors will be contractually required to have a HSE person on-site supported by a team of HSE supervisors (see PS2 section for more information). Similar arrangements, tailored to fit the operations requirements will be put in place during the operations phase. The project will finalize or establish the HSE organogram for the construction and operations phases of the project, respectively. (ESAP #2). Appointed personnel will have adequate qualifications and experience, including knowledge of international requirements and best practice. As per the project requirements, the contractors will be required to set up and implement an appropriate HSE induction and ongoing training program for all workers.
Emergency Preparedness & Response: OCP has a corporate standard on emergency response planning. All facilities in Morocco have a Plan de Gestion des Crises (Crisis Management Plan) in place. For the project, JESA has developed an Emergency Preparedness and Response (“EPR”) Plan that sets out emergency situations and scenarios (fire, explosions and natural hazards), organization responsibilities and response requirements. In line with the project requirements, the project EPR and in accordance with the IFC PS1 and PS4 provisions, an on-site ERP will be prepared for both the construction and operation phases of the project (ESAP # 3).
Monitoring & Review: OCP has corporate standards on environmental performance monitoring and HSE performance control, audit and safety observations. As part of its project management system, JESA has outlined specific processes to monitor and measure the effectiveness of their and their contractor’s management plans / programs as well as compliance with relevant Moroccan legal requirements. JESA will draft monthly progress reports based on the review of the construction contractor reporting requirements including, the contractor’s progress reports, on-site inspections of the project in accordance with GIIP, and information provided by the contractor from time to time. As per the project Requirement’s, the construction contractors will develop and report on a minimum set of Key E&S Performance Indicators (“KPIs”).
Supply Chain: JESA has a supply chain Code of Conduct prohibiting forced labor together with HSE requirements, as well as a supplier Capability Assessment procedure that includes labor and HSE provisions. The Code of Conduct is annexed to all construction and supply contracts. In addition, the general terms and conditions to be used for the construction and supply contracts requires that any supplier adheres to all applicable HSE laws/regulations, and JESA’s HSE policies and procedures. JESA will implement these requirements at the project level.
PS2: Labor and Working Conditions
The project is expected to employ up to 300 workers at the peak of the 12-month construction phase of each plant. A majority of these workers will be employed by the construction contractors and sub-contractors and are likely to be sourced from Morocco. Some expatriate staff may be retained for project management and specialized construction related work. There are high expectations of employment opportunities amongst the local communities; therefore, JESA will work with the construction contractors and the local communities to ensure that local recruitment is maximized and equitable to the extent possible. Up to 20 workers will be employed during the O&M phase of the project.
Human Resources Policies and Procedures: OCP has publicly disclosed corporate policies on general human rights, general human capital, social dialogue, diversity, and inclusion and working conditions. These policies describe OCP’s commitments including freedom of association and effective recognition of the right to collective bargaining, elimination of all forms of forced or obligatory labor, effective abolition of child labour, and elimination of discrimination in employment. The policy also has specific commitments on working time, remuneration, physical and mental working conditions, social dialogue and retirement. Through its corporate policies on social dialogue and diversity and inclusion OCP has also committed to implement grievance mechanisms across all OCP Group operations. OCP’s corporate policies are aligned with PS2 requirements and are applicable to the construction and O&M phases of the project.
Working Conditions and Term of Employment: The project will ensure that all employee contracts are consistent with Moroccan law and IFC PS2 requirements. All employees (including those employed by contractors and subcontractors) will be provided with a contract in French/ Arabic, stipulating their terms of employment, working conditions (including health and safety requirements), wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, vacation, holidays as well as other leaves stipulated by national legislation. Contracts of the construction phase workers shall have a clear description of the short-term nature of the project and provide an indication of the potential employment duration. No labor camp is proposed under the project as most of the contractors’ labor force is expected to be hired from the nearby villages and towns. Other workers including skilled labor and project management staff, who may come from outside the project area will be housed in rented accommodation. OCP will develop a transportation management plan to address the risks associated with transporting equipment and workers to and from the worksite (see ESAP # 9).
Guided by the project requirements and consistent with the requirements of Moroccan law and PS2, each construction contractor and operator will develop (i) Policy statements on non-discrimination and equal opportunity, prevention of child labor and forced labor, freedom of association and sexual harassment; (ii) a set of Human Resources (“HR”) procedures including local recruitment, with provisions for increasing gender equality; worker induction; disciplinary requirements (including in relation to sexual harassment); and demobilization of the project workforce following completion of construction (iii) Workers Code of Conduct to account for respectful worker behavior including in host communities and zero-tolerance provisions against sexual harassment; (iv) Labor Grievance Mechanism; and v) a set of working conditions and terms of employment. These HR policies and procedures, Code of Conduct, Labor Grievance Mechanism and working terms and conditions will apply to all project workers including those employed by any sub-contractors and be made readily accessible and clearly communicated at induction and through the provision of additional sensitization and training. (ESAP # 4). JESA will put in place appropriate monitoring requirements including third-party audit procedures to ensure that the construction contractors and their sub-contractors maintain statutory compliance with Moroccan law, the labor requirements, and PS2 provisions. (ESAP # 5).
Occupational Health and Safety: Key OHS risks for a PV project include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, traffic accidents, exposure to electric shocks and burns, and safety issues related to panels module assembly. To manage these risks, guided by the project requirements and in line with IFC PS2 and relevant WBG EHS Guidelines, the construction contractors will develop a Health and Safety Plan covering key aspects such as: Job Safety Analysis and Risk and Hazard Assessment and associated management procedures for work activities; Protective Personnel Equipment (“PPE”) requirements; Permit to Work System; Lock Out-Tag Out System; OHS signage requirements; medical support requirements; rest and sanitary facilities; actions and procedures related to COVID-19; training requirements, including at induction and repeated/refresher Toolbox Talks; roles and responsibilities for implementation of plan; incident recording and investigation; performance monitoring; etc. The contractors will also be contractually required to deploy a suitable number of appropriately qualified Health and Safety supervisors for effective supervision of compliance with the contractual provisions relating to OHS requirements. A Health and Safety plan and associated procedures will also be developed for the operations phase by the operator (ESAP # 6).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency – Greenhouse Gases: Greenhouse gas emissions (“GHG”) from the project during construction, are expected to be minimal and predominantly associated with the use of fuels such as in generators, transport, on-site equipment, and machinery. Although the quantities of emissions have not been calculated, these are expected to be low and significantly less than 25,000 tones CO2 equivalent (tCO2eq/year). The project is expected to generate approximately 876 gigawatt hours of electricity per year, resulting in a predicated annual GHG reduction of 639,500 tCO2eq/year.
Resource Efficiency – Water Consumption & Availability: For the construction phase, it is estimated that approximately 80 m3/day of water, would be required for civil works and domestic use at each site. For the operations phase, it estimated that around 18,000 m3/year and 5,900 m3/year (or an average of 60 m3/year/MWp) of water will be required for wet cleaning of the solar panels at the Benguerir and Khouribga plants respectively. Treated wastewater from the Khouribga and Benguerir wastewater treatment plants will be used for wet cleaning of the solar panels. No water will be sourced from boreholes or other surface water sources. The domestic water needs during operations, estimated to be 100 l/ day, will be met via piped connections from either the OCP water network or the municipal network. The operational water needs of the project constitute a less than 1% of the total water requirements related to the mining and processing activities in each mining area.
Pollution Prevention – Waste: The EIA identified waste streams generated during the construction and operational phases. The overall volumes of both solid and hazardous waste generated by the project during both phases are expected to be low. It is anticipated that the project will produce both non-hazardous wastes, such as paper, wood, plastic, scrap metals and glass, and a limited quantity of potentially hazardous materials such as transformer oils, lubricants, paints, batteries, etc. as well as some electronic waste. Furthermore, leaks from contractors’ vehicles and equipment may impact the soil/subsoil. The project will develop a Waste Management Plan for the construction and operations phase, aligned with local legal requirements, the EMP, project requirements, and IFC PS3 and WBG EHS general provisions (ESAP # 7). The waste management plan will commit to the reduction of wastes whilst maximizing the re-use and recycling of materials and will outline the process for appropriate waste segregation, storage, transportation and disposal. The plan will also include specifics for management of broken, expired or surplus PV panels, address local requirements for the designation of a hazardous storage area, provide details on hazardous waste disposal solution(s) in line with good international industry practices (“GIIP”), and includes provisions to ensure hazardous waste contractors are licensed from the relevant authority.
The project will also develop a spill prevention and response plan commensurate with the potential risks present at the site. This will address the prevention and control of releases and accidents (ESAP # 8).
During the operational phase, no environmental pollution impacts of effluents are anticipated except for wastewater, primarily derived from panel cleaning, and regular household waste generation. The company will implement pollution prevention measures in accordance with national law, IFC’s PSs, and project EIA provisions.
PS4: Community Health, Safety and Security
Community Exposure to Disease: All the sites are in rural mining zones which have been operational for decades. There are scattered dwellings and settlements located in the surrounding vicinity of all the sites, all within the mining zones. The nearest cities are Khouribga and Benguerir located around 5 km and 8 km from the respective mining areas. The growth of these cities has been partially linked to the development of the mines. The project intends to maximize recruitment from local communities to the extent possible. The impact due to the influx of a construction workforce in the area is likely to be relatively small. As per the project requirements, the contractors will be required to have a worker Code of Conduct, adequate health and safety controls, and onsite medical facilities for all workers. These measures are deemed sufficient to manage the risks to the community as a result of exposure to disease.
Road Safety & Traffic Management: During construction, the dominant vehicle movement patterns will be in relation to the transportation of construction workers on a daily basis over the 12 months construction period and material and equipment at defined periods. Increases in traffic related to the construction phase may represent a safety risk for the other road users and communities adjacent to the roads being used. The project shall undertake a Transportation Risk Assessment and guided by the findings, develop a Project Traffic and Transport Management Plan (ESAP # 9). The plan will define transport routes to be used for equipment deliveries based on the risk assessments undertaken to evaluate road traffic and conditions with aim of minimizing impacts. It will also define a safety inspection program for project (especially for local subcontractors) and implement ongoing monitoring of vehicles and proper use of safety measures.
Security Personnel: The sites are in mostly unfenced mining zones. A permanent fence will be erected around the perimeter of the sites. Security and access control to the site will be provided on a 24-hour basis by a third-party security company retained by the contractors/ operator. Security guards will not be armed. As part of the first phase of the solar program, OCP is developing a security management policy that will be consistent with PS4 requirements including IFC’s “Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts”.
