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.
PS 1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Policies and Management Systems: CCT has developed and implemented a robust ESMS largely aligned with the requirements and objectives of IFC PS1 and local legislative and regulatory requirements. The city’s development strategy and approach are largely guided by its current five-year Integrated Development Plan (IDP) and related Municipal Spatial Development Frameworks (MSDFs). The IDP identifies the management of various E&S aspects as key priorities for the city, including biodiversity, water sustainability, air quality, climate change and resilience among others. The implementation of the IDP and MSDFs is underpinned by an overarching Environmental Strategy detailing the city’s long-term approach to environmental management and sustainability, including aspects related to resilience, ecosystems, and environmentally sensitive and low impact urban development.
To ensure alignment with national legislative requirements, and to further support the city’s E&S management approach, several policies, procedures, and management plans have been adopted and implemented. These include an Air Quality Management Plan, Climate Change Strategy, Local Biodiversity Strategy and Action Plan, Water Services Development Plan, Integrated Waste Management Policy, and Social Development Strategy etc.
Identification of Risks and Impacts & Management Programs: CCT’s identification of risks and impacts at a subproject level is largely driven by the completion of an Environmental Impact Assessment (EIA) or Basic Assessment (BA), as required under the National Environmental Management Act (NEMA) and associated EIA Regulations, per which a comprehensive EIA is required for activities with potentially significant E&S impacts. Considering IFC proceeds will only go to subprojects with limited E&S risks and impacts, per local requirements, such identification of E&S risk and impact of eligible subprojects will be done through completing a BA, including a subproject-level Environmental & Social Management Procedure (ESMP), for approval by the competent authority. As per the requirements of NEMA and associated regulations, the implementation of the ESMP is monitored and audited by the competent authorities. Where a BA has been completed, third-party service providers (e.g. construction contractors) are required to comply with the requirements of the associated ESMP, and report to the competent authority as required. As per the requirements of the BA, each subproject is required to have an Environmental Control Officer (ECO) mandated to monitor and report on the subproject's compliance with the associated ESMP.
As per ESAP#1, where a subproject does not trigger the requirements for a BA and associated ESMP, the city will define, and implement, a generic ESMP detailing the management of key E&S risks and impacts related to site access, air quality, soil erosion, and waste management among others, as well as reporting and monitoring requirements. The generic ESMP will reflect the current operating context, and local legislative and IFC PS requirements.
Organizational Capacity and Competency: CCT is comprised of 12 directorates (Waste and Sanitation, Spatial Planning and Environment, Safety and Security, Human Settlements and Economic Growth etc.), multiple departments and services. CCT does not make use of any municipal entities for the provision of water, electricity, waste management etc. as these services are housed within the applicable directorate and managed directly by the city.
Each directorate, and their various departments, is responsible for the implementation, management and monitoring of the city’s E&S policies and procedures at a subproject level. While E&S responsibilities reside within each directorate, the city’s overall environmental management approach is overseen by the directorate for Spatial Planning and Environment. This directorate is made up of various departments including Environmental Compliance, Biodiversity, Environmental Health, and Environment Management Inspectors. The directorate for Spatial Planning and Environment is also tasked with ensuring legislative compliance and authorization of city subprojects. Where required, the city can enforce regulatory and compliance requirements through the Environmental Management Inspectorate.
Emergency Preparedness and Response: As per the requirements of the Disaster Management Act, CCT has developed a municipal Disaster Risk Management Plan (DRM). The management plan serves to confirm and define organizational and institutional arrangements within the city to effectively prevent and mitigate disasters and emergency situations. In addition to the DRM, at an operational level, specific hazard/risk DRM plans and related emergency procedures, have been developed.
Responsibility for the implementation of the DRM falls to the Disaster Risk Management Centre which is mandated to provide guidance and direction for the effective implementation of the management plan by all directorates in the city, increase awareness and knowledge of disaster risk reduction and management methods and opportunities, and contribute to community resilience.
Monitoring and Review: As per the requirements of NEMA, subproject proponents (including contractors and sub-contractors where relevant) are responsible for monitoring the implementation of the ESMP, and the generic ESMP once developed (ref. ESAP#1) and reporting to the competent authority. The competent authority is also responsible for the annual auditing of subprojects to check on environmental approval compliance. In addition, the city’s Environmental Compliance Department can conduct random audits of subprojects. Where non-compliances are identified, the Environmental Management Inspectors have the mandate to ensure compliance and issue fines.
In addition to subproject monitoring activities, in 2022 CCT developed, and disclosed, a State of the Environment Report covering aspects related to biodiversity, invasive species, green open space, inland and coastal water quality, water use, wastewater, climate change, air quality and solid waste.
PS 2: Labor and Working Conditions
Human Resources Policies, Labor and Working Conditions: CCT currently employ approximately 31,500 workers across the various directorates and departments. In addition to some workers involved in CAPEX-related activities, the municipality engages third-party service providers to support subproject implementation activities such as E&S assessments, authorizations, construction, etc. The male to female ratio of all workers is approximately 60% to 40% respectively.
Human resources (HR) are managed under the Corporate Services directorate, that incudes various functions such as HR Management, Performance Management, Policy and Planning, Payroll and Personnel administration, Talent management, Occupational Health, Employee relations, Training among others. The HR Management department is responsible for the oversight of labor and working conditions within the city. The city’s HR management system, policies and procedures are noted to be complaint with PS2 as well as relevant legislative requirements including but not limited to the Employment Equity Act, Skills Development Act, Labor Relations Act, Basic Conditions of Service Act, Income Tax Act, and respective Collective Bargaining Agreements (CBAs) among others.
Currently, the majority of the city’s workers are unionized across the Independent Municipal and Allied Trade Union (IMATU) and South African Municipal Workers Union (SAMWU). The city is a member of the South African Local Government Association (SALGA) who engage and bargain on behalf of the municipality with the respective unions under the auspices of the South African Local Government Association bargaining council (SALGBC). Currently, there is a Main Collective Agreement, entered into in September 2015, between SALGA and the respective trade unions, with several addenda in force. There are also collective agreements relating to Metro division matters in place which includes collective agreements relating to Fire Services, Bulk Water Services, and local conditions of service.
Non-Discrimination and Equal Opportunity: Non-discrimination and equal opportunity within CCT is largely managed under the auspices of the Employment Equity Act, which seeks to ensure equal opportunity and fair treatment through the elimination of unfair discrimination. The city has also adopted an Employment Equity and Diversity strategy and associated Employment Equity Plan.
Grievance Management: The existing Main Collective Agreement defines the grievance management procedure available to all municipal workers. The procedure, which defines a three-step process, is largely aligned with the requirements of PS2. Where issues and/or grievances fall outside of the scope the established grievance mechanism, the city has adopted a Whistle Blowing policy, managed under the Forensic Services department, whereby workers and external stakeholders have the option to report, anonymously if required, grievances and concerns relating to maladministration, harassment, discrimination, fraud, and corruption among others.
Occupational Health and Safety: Workers and third-party service providers involved in eligible subprojects are required to comply with legislative OHS requirements, including the OHS Act, and the city’s overarching OHS management system. The management of OHS within the city falls under the OHS department within the Corporate Services directorate. As a component of the city’s OHS activities, workplace inspections, incident investigations, and OHS training are conducted. In addition, the department oversees occupational health, occupational hygiene, fleet risk management, and evaluation and monitoring.
For specific subprojects, line managers are required to develop a project plan following which the OHS department will complete a readiness assessment. Line managers are also required to conduct incident investigations, and implement corrective actions as required. All incidents are recorded within the city’s SAP program, where monthly reports are generated, and root causes identified. The city has also implemented standard operating procedures relating to Incident Management and Personal Protective Equipment (PPE) among others.
Workers Engaged by Third Parties: As noted, the municipality, if necessary, utilizes third-party service providers, including construction contractors and sub-contractors, on certain subprojects, and they are required to comply with local labor regulations and OHS requirements, including the provision of personal protective equipment (PPE), have an onsite safety officer on sites with more than 20 workers, and maintain a safety file detailing their appointment letter, a copy of the OHS Act, Labor Relations Act , an OHS Management Plan, relevant risk assessments, a letter of good standing, and material safety data sheets for hazardous materials (if required).
