This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because the proposed project is expected to have limited adverse E&S risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures, as described in the following sections. The brownfield road expansion will be mainly developed in the RoW of the existing road (i.e., 5 ha will be impacted outside of the RoW), in modified habitats not used for agricultural activities.

Key E&S aspects associated with the project include the following: (i) the Client's ESMS to assess and manage E&S risks and impacts; (ii) management of labor and working conditions and occupational health and safety (OHS) policies and practices, including of contractors and subcontractors; (iii) management of project-related economic displacement of population; and (iv) the Company's stakeholder engagement activities related to E&S aspects.                                 

 PS 1 - Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System and Policy

The PdC has a robust ESHS regulatory framework and dedicated ESHS teams, and has a good track record managing ESHS impacts and risks under loans from other development institutions such as the Andean Development Corporation (CAF) and the Inter-American Development Bank (IDB), including implementation of large Land Acquisition, Involuntary Resettlement, and Livelihood Restoration Programs (RAPs). No significant environmental impacts or large resettlement are envisioned for the Project included under IFC Loan, as it involves enhancement, pavement, and expansion of existing roads with already consolidated rights-of-way. The Project will be divided into sections that will be allocated through a tender process to various contractors to allow for parallel construction and expedite completion.

The environmental and social impact assessment (ESIA) of any transport project in the Province of Cordoba must comply with the requirements of the Provincial Environmental Policy Law (Law No. 10208). The Road Department of the PdC (Vialidad) submitted the required documentation to the Enforcement Authority, which, due to the anticipated limited impacts and risks, granted a license to proceed without an ESIA. As per ESAP item #1, PdC will develop a focused Environmental and Social Assessment (ESA) commensurate with the Project risks, in line with IFC Performance Standards, WBG EHS General Guidelines, and WBG EHS Guidelines for Toll Roads. This assessment will properly define the project's area of influence, identify high-risk areas (e.g., sensitive receptors, regions with higher erosion risks, river crossings), and assess the impacts on those areas. Impacts related to land acquisition and economic displacement will be included in the ESA (see PS5 Section of this document for more information).

Management Programs

As per the tender documents developed by Vialidad, the contractor is requested to prepare an Environmental Management Plan (PGA, per its Spanish acronym). Requirements are specified in the General Environmental Technical Specifications (GETS), which cover the E&S management practices that will need to be considered by the contractor during construction. The GETS outlines the E&S minimum requirements for various aspects of construction projects (e.g., surface and groundwater resources, natural and cultural heritage sites, construction camps and workshops, machinery and equipment, borrow pits and quarries, debris disposal, material production plants, detour roads and management of waste). The GETS also include a model E&S Management Plan (PMAyS), detailing the management programs that need to be part of the contractors’ PGAs, including an environmental protection program, a training program, an environmental contingency response program and monitoring and reporting program. The programs within the PMAyS and their content are considered generally aligned with IFC PS and good practice, and are considered adequate for the Project’s risk profile.

In addition, the tender documents developed by Vialidad include a Technical File of the Occupational Health and Safety (OHS) Program (Programa Unico de Higiene - Seguridad En El Trabajo – Legajo Tecnico) that (i) provides a comprehensive analysis of potential risks associated with various construction activities and site conditions; and (ii) includes a Risk Prevention Manual, covering the main mitigation measures for each analyzed risk. the primary risks and management actions for OHS in construction. According to the tender documents, the contractor is required to prepare an OHS Program to align its OHS practices in the field during construction with those in the Technical File. As part of ESAP item #1, PdC will ensure that the contractors' management plans incorporate any additional mitigation measures required for those sections where the high-risk areas are located, as needed.

As per ESAP item #2, PdC will prepare a Monitoring and Review Plan to supervise the implementation of the PGAs and OHS Programs by the contractors. This plan will also ensure that the labor conditions of contracted workers comply with relevant legislation and PS2. This Plan will include a list of Key Performance Indicators (KPIs) designed to measure and track the effectiveness and progress of the implementation of the PGAs, OHS Programs, and labor conditions. These KPIs will facilitate the comprehensive application of the 'Plan-Do-Check-Act' (PDCA) cycle. OHS KPIs will include not only accidents, but also First Aids and Medical Treatments, near misses, OHS observations, and property damage. The Plan will encompass the requirement to oversee the adequacy of the E&S training provided by both PdC and the contractor.

After construction, the Monitoring and Review Plan will be updated to ensure continuous reporting of information relevant to the Project to IFC within the Annual Monitoring Reports. This Operation and Maintenance E&S Management Plan will include considerations aligned with WBG EHS Guidelines for Toll Roads about road paving and resurfacing, painting activities and emergency response, including a maintenance plan to prevent mechanical failure of vehicles due to road conditions.

Organizational Capacity and Competency

According to the tender documents, Vialidad will appoint an Environmental and Social Inspection (IASO) and an OHS Inspection Teams, which will work jointly with the Quality Control Unit (including a Chief Inspector, a Laboratory Technician for asphalt and cement quality, and a Topographer) and will be responsible for ensuring the contractor's compliance with environmental, social, health and safety, and quality clauses. In addition, Vialidad requires that the contractor includes in its roster an Environmental Manager, an OHS Manager, and an OHS Technician, as well as training requirements aligned with the PGA. Regarding land acquisition, the administrative procedure to transfer the required areas to the PdC for road projects is managed by Vialidad’s Department of Lands and Valuations. Economic displacement impacts falls under the responsibility of the Environmental Unit of Vialidad’s Department of Planning, Evaluation, and Management Control.

As per ESAP item #3, PdC will designate an E&S coordinator who will be responsible for the implementation of the ESAP and will serve as the liaison with the IFC for managing the Project’s E&S aspects during both the construction and operational phases.

Emergency Preparedness and Response

In the PMAyS, Vialidad includes the requirements of the Environmental Contingency Program (PCA) to be prepared by the contractors.  The PCA outlines emergency measures and procedures to be activated and implemented in the event of unforeseen incidents that could negatively impact the well-being of workers, community members, material assets, and the environment, in general alignment with IFC PS. Its objectives are to establish necessary actions, measures, and procedures to prevent, inform, and respond to contingencies during construction, operation, or maintenance phases, and to ensure maximum safety for construction personnel and the local population, safeguarding human lives and the environment. Contractors must comply with minimum guidelines and requirements for handling contingencies, including having an emergency coordinator, forming an Emergency Brigade, and maintaining an updated Emergency Response Plan in compliance with national and provincial environmental standards. They are also responsible for immediate cleanup of spills and remediation actions, and for analyzing weather forecasts and hydrometeorological data to establish alert mechanisms and mitigation measures for adverse weather conditions.

Monitoring and Review

Contractors activities and E&S performance will be supervised in line with the Monitoring and Review Plan to be prepared as per ESAP Item #2. The Plan will include regular inspections, reporting requirements, KPIs, and enforcement actions to address non-compliance (e.g., service orders to make the necessary adjustments and modifications).

Contractor Management

Contractors are primarily employed for construction and maintenance and are required to submit documents demonstrating the financial and technical capacity to undertake the work in order to participate in public tenders. The tender documents include reference to the World Bank List of Ineligible Firms and Individuals to ensure that WBG’s ineligible companies are not contracted or subcontracted. In addition, the GETS includes the minimum requirements that all contractors must incorporate into their PGAs and OHS Programs. As per ESAP item #2, PdC will monitor the implementation PGAs and OHS Programs by contractors, including the additional mitigation measures for risk-prone areas developed in line with ESAP item #1. After the auditing process, the IASO and OHS Teams will monitor and track the implementation of any identified non-conformities and corrective actions with contractors to completion. Given the nature of the Project, the requirements and management programs included in the tender documents are considered adequate to manage contractors in line with IFC PS1, once the ESAP items are implemented.

PS 2 – Labor and Working Conditions

PdC is a government agency with a substantial workforce operating under governmental labor laws that are generally aligned with IFC PS2. The number of contracted workforce for Project construction is expected to be up to 500 workers at its peak. Given the proximity to the city of Rio Cuarto, no workers' camp is planned.

The working conditions are governed by the Argentinian Labor Code which mostly aligns with IFC PS2. Specifically, the code (i) prohibits discrimination based on gender, race, religion, political opinion, and social status; (ii) requires employers to uphold principles of equality in all aspects of employment, including recruitment, wages, and promotion; and (iii) ensures workers adequate conditions of hygiene, nutrition, and health, including access to potable water and adequate sanitary services. In addition, the Project tender documents require contractors to maintain a record of labor personnel and display a sign at the worksite with the updated minimum wages and the complete payroll of the personnel. As per ESAP item #4, PdC will develop a code of conduct for contractor and subcontractor workers that includes a set of principles, rules, and behaviors including the prohibition and management of GBVH at the Project site as well as with local communities in line with Argentinian legislation and IFC PS2 and PS4 requirements.

Construction workers are represented by the Union Obrera de la Construcción de la República Argentina (UOCRA), and both unionized and non-unionized workers are covered by the union agreements. UOCRA undertakes regular monitoring visits to the work sites and monitors all workers' conditions.

PdC’s grievance mechanism is available for municipal workers, contractors and the general population through a dedicated website (https://cidi.cba.gov.ar/portal-publico/ - Ciudadano Digital - CiDi). As per of ESAP #5, Vialidad will develop a Project-specific Workers Grievance Mechanism (WGM) that includes (i) multiple reporting channels (online, email, phone number, letter, in person) and recording mechanism, with provisions for anonymous reporting; (ii) a detailed procedure for the investigation, response and closure of grievances; (iii) specific roles and responsibilities for Vialidad and the Project contractors; (iv) specific considerations for handling GBVH grievances using a survivor-centered approach, managed by trained personnel; and (v) a dissemination and communication program to ensure all personnel involved in the Project have knowledge, understanding and access to reporting grievances.

Occupational Health and Safety

As per the tender documents, OHS aspects will be under the responsibility of the contractor's OHS Manager, assisted by an OHS technician and supervised by PdC’s OHS Inspection Team. The requirements set forth in the Technical File of the OHS Program and in the Risk Prevention Manual cover the main risks and impacts related to construction and are generally aligned with IFC PS2. In addition, the Risk Prevention Manual includes the reference to the applicable laws, sets out the responsibilities for the contractors’ workers and managers, provides the minimum requirements for storing and handling hazardous materials (including paintings and additives, to be stored in adequately conditioned areas, aligned with WBG EHS guidelines), for managing vegetation control-related risks, and for PPE use. The implementation of the contractors’ OHS programs will be supervised by PdC via the Monitoring and Reporting Management Plan to be developed as per ESAP item #2. PdC will ensure that OHS accident reports include a root-cause analysis and corrective actions to avoid recurrence. In a similar road construction project undertaken in 2022, no Lost-Time Injuries (LTIs) were reported among contractors or PdC employees. As per ESAP item #2, OHS KPIs will be enhanced to include not only LTIs, but also First Aids and Medical Treatments, near misses, OHS observations, and property damage.

PS 3: Resources Efficiency and Pollution Prevention

For resource efficiency, PdC included specific clauses in the tender documents that provide scoring and weighting benefits to proposals demonstrating the use of biofuels (minimum 20% as per Provincial Law No. 10,721) in fleet vehicles or those of subcontractors, and the provision of recyclable goods and biomaterials. Additionally, under the "Program for the Reduction and Compensation of Greenhouse Gas (GHG) Emissions within the Ministry of Public Services," bidders may receive preferential evaluation if they demonstrate the calculation and/or compensation of the carbon footprint of executed works.The GHG footprint of the project is expected to be below 25,000 tCO2e. Water used during construction will come from authorized sources, approved by the Quality Control Unit.

The tender documents for the Project include environmental management requirements to comply with IFC PS3. In terms of construction facilities (including construction yard, asphalt plant, fuel storage), contractors must submit plans and permits to the PdC, including site layouts, technology specifications, and safety measures for fuel, hazardous materials and waste storage. Additionally, contractors must provide to PdC PGAs, monitoring programs, monthly reports and relevant permits for land use, energy, water supply, and effluent treatment.

The PMAyS requires contractors to manage waste according to relevant laws, prohibiting fire for disposal, ensuring temporary storage does not impact the landscape or drainage, and disposal is carried out through licensed service providers. Non-compliance would result in sanctions as per the General Conditions for Public Works Contracts. Construction materials (including inert materials, such as sand, gravel, and concrete) will need come from sources that have undergone an environmental impact assessment and have been granted the necessary environmental permits by the relevant authorities.

As per ESAP item #1, PdC will assess noise impacts at the most sensitive receptors in line with WBG EHS Guidelines, and ensure that noise management plans are in place, as necessary, as part of ESAP item #2.

The Project will enhance the existing drainage system by constructing new longitudinal ditches and maintaining the existing cross-drainage sections. According to Vialidad, there have been no historical occurrences of flooding in the area.

PS 4: Community Health, Safety, and Security

The Project is expected to reduce the risks of interference and accidents between the city's residential traffic and through traffic, which typically consists of heavy-duty vehicles, by creating overpasses and acceleration lanes for roads that need to be duplicated and by reducing at-grade crossings. Pedestrian safety will be enhanced through the implementation of sidewalks with access ramps at underpasses and the installation of pedestrian crosswalks on the service roads, facilitating secure pedestrian circulation. .

In the tender documents, Vialidad included requirements for an Accessibility and Traffic Diversion Program, aiming to mitigate the negative effects of construction on access for residents and businesses by ensuring that collector streets and sidewalks always allow vehicular and pedestrian access. Temporary access to properties must be safe and minimally disruptive, with closures communicated at least one week in advance. For public transport, the contractor must design a diversion program, approved by relevant authorities, detailing affected routes, alternative paths, and temporary stops, and communicate this to community centers, schools, and health facilities fifteen days prior. The program must ensure emergency services can operate effectively. The contractor is required to install all signs, signals, markings, and other devices used to regulate traffic, including posted speed limits, or other special road conditions, in line with local regulatory requirements. The OHS inspection team is responsible for reviewing the road deviation plans, including both horizontal and vertical signals.

Contractors are not expected to employ external security providers due to the low risk associated with construction sites in urban areas. Instead, contractors station their own employees at workshops to deter potential intruders and manage access control. The deployment of armed security personnel is not expected, as Argentinian regulations allow armed security only in situations where there is a significant risk to assets and people due to security or violence concerns. 

PS 5: Land acquisition and involuntary resettlement

The brownfield road expansion will be developed mostly within the RoW of the existing roads. However, land acquisition will be required for the construction of two roundabouts (approximately 5 hectares of privately owned agricultural land outside the RoW).  For land acquisition, under Argentinian regulations, Vialidad can declare Public Utility and expropriate necessary properties through a process that includes valuation of the property and present infrastructure, and payment of a fair compensation to owners. Prior to the negotiation process, Vialidad requests a ‘Work Permit’ allowing it to enter the land and start the works, indicating that the owner will transfer the land possession to Vialidad after the negotiation process. Vialidad has a grievance mechanism for expropriation management (Mesa de Entrada), managed by the relevant department, such as Land and Valuation, Legal, or Land and Roads Conservation, depending on the grievance's nature. As per ESAP item #6, for the expropriation of the land outside the RoW, Vialidad will provide compensation for loss assets at full replacement cost in line with PS5.

Throughout some sections of the road to be intervened there are formal and informal food-trucks and other mobile and permanent businesses (commonly called “Carritos”) that are located and operate inside the RoW. The exact number of these businesses has not been determined at this point, as they include both permanent and temporary establishments. However, it is expected to be between 8 and 12.  The clearance of the RoW for the development of the Project will result in the economic displacement of the Carritos in the road sections to be intervened. As per ESAP item #7, Vialidad will develop a Livelihood Restoration Plan (LRP) to manage the economic displacement of the affected business to ensure restoring the full range of means that affected individuals, families, communities and business owners use to make a living, including wage-based and other types of income in alignment with PS5. The LRP will include (i) the planning principles, objectives and PS5 applicable requirements; (ii) an inventory of the affected assets and a  socioeconomic baseline of the affected business and people (e.g formal and informal employees and workers) with a cut-off date; (iii) a social survey of the affected communities; (iv) eligibility criteria and livelihood restoration measures; (v) evaluation and valuation methods for the assets and compensations at replacement value; (vi) stakeholder engagement specific to the LRP; (vii) monitoring and evaluation mechanisms and KPIs; (viii) an ex-post completion audit two years after LRP implementation (ix) roles and responsibilities and adequate resources (human and financial) for the planning and implementation of the LRP; and (x) schedule and budget. Vialidad will include in the Community Grievance Mechanism (CGM) to be developed as per ESAP item #8 a dedicated workflow to handle and resolve concerns and grievances related to the LRP implementation, clarifying management responsibilities.

 Vialidad disseminates information about its construction projects through various official channels, such as PdC’s Official Gazette and the Government of Córdoba Website (https://www.cba.gov.ar/). In addition, the Project tender documents require contractors to develop a Social Management Program. This Program provides community information and communication regarding the duration of the works, health and safety impacts, and mitigations , particularly about traffic and pedestrian circulation, vehicular traffic and public services through different means - radio, digital media, community social networks, newspapers, posters and information meetings. The Program also includes the requirement for appropriate signage for the works and a community grievance mechanism, which consists of a complaints log managed by the contractor and manually recorded. Grievances can also be reported through the CiDi section of PdC’s website.

In view of the Project, Vialidad will develop a Stakeholder Engagement Plan (SEP) and a documented Community Grievance Mechanism (CGM) for the Project (ESAP Item #8) in alignment with PS1. The SEP will include the following: (i) Project stakeholder mapping and analysis; (ii) key messages to be delivered (including the dissemination of the contingency plan and CGM) and frequency of consultation; (iii) monitoring KPIs and reporting; (iv) specific roles and responsibilities for Vialidad and the respective contractors; (v) specific considerations on the Code of Conduct (ESAP item #4) applicable to the communities. Dissemination and training will be provided to all workers, including contractors, on these considerations. The CGM will include (i) different reporting channels (online, email, phone number, letter, in person) and recording mechanism; (ii) detailed procedure for investigation, response and closure of grievances; (iii) specific roles and responsibilities for Vialidad and the Project contractors; and (iv) specific considerations for handling GBVH grievances based on a survivor-centered approach and managed by trained personnel. Vialidad will ensure that adequate resources are allocated (personnel, budget) for the implementation of the SEP and the CGM, and dedicated channels for grievances related to land acquisition and economic displacement are in place.

Contact Person: Geologa Aldana Contreras – Ing. Luis Figliozzi

Group Name:  Dpto. Planificacion, Evaluacion y Control de Gestion

Address:  Avda Figueroa Alcorte 445 - Cordoba Capital, Argentina

Email:  unidadambiental.vialidad@gmail.com

Phone:  0351-4342070/78 Interno 221