Morocco - Social Development Agency Project : environmental management plan

E517 KINGDOM OF MOROCCO SOCIAL DEVELOPMENT AGENCY ENVIRONMENTAL MANAGEMENT PLAN A. Background 1. Introduction: The proposed ADS Project aims at introducing new approaches and mechanisms for meeting poor communities and vulnerable groups. The specific objectives of the project are: - To test new approaches for delivering social services in a more relevant and cost effective manner by supporting the establishment of a participative demand- driven mechanism that will reach out to poor communities; and - Better organize local communities to take advantage of setting development priorities and implementing development activities by strengthening the capacity of local NGOs. 2. Investment components: The project will consist of the following four main components:. (i) Community Development and Social Infrastructure: subprojects will cover areas from basic education and primary health care to literacy activities as well as rural drinking water and wastewater. (ii) Support to Economic Infrastructure and Income Generation: three kinds of subprojects will be supported and include: - Subproject that enhance the economic infrastructure in rural and slum areas such as irrigation, small markets and rural roads. - Subprojects that finance training and non-financial support activities that are directly related to creating employment opportunities - Subprojects that support the expansion of the existing micro finance operations to new geographical areas. (iii) Institutional Development for Intermediaries: this component supports and increase the effectiveness of the first two components by supporting the capacity of ADS' intermediaries to identify, appraise and implement sub-projects. (iv) Studies and ADS Capacity Building: this component will provide support to different institutional and operational aspects of the ADS to learn from experience with similar operations in other countries. 3. Institutional Arrangement: The implementation of the Project falls under the responsibility of the Agence de Developpement Social who would be in charge of coordinating the various activities with concerned sectoral ministries, local governments, communities, and NGOs. The Agency will operate at both the national and local level. ADS' intermediaries, who EMP-final (November 2001) FILE P of 8 would include NGOs, associations and local government, will be responsible for the implementations of the subprojects. 4. Project Environmental Category: The proposed project would support environmental improvements through rehabilitation and improvements in roads, schools, primary health care centers, small water supply and sanitation systems in small poor communities and villages. Potential adverse environmental impacts during both construction and operation are restricted in magnitude and severity. Environmental guidelines to be used during the various project stages will be prepared and will enable the identification of all environmental concerns prior to project implementation through the development of an EMP that would include mitigation activities and monitoring procedures. In addition, an environmental assessment report will be prepared for the construction of low cost sanitation and new rural road subprojects. Furthermore the project will not fund any sub-project that would require resettlement, land terracing on slopes greater than 40%, deforestation, or would adversely affect natural habitats, biodiversity, and cultural heritage sites. Accordingly, the proposed project has been placed in "Category B" in accordance with World Bank Operational Policy (OP 4.01) on Environmental Assessment (January 1999). 5. Legal and Regulatory Framework for Environmental Assessment Since January 2000, the Department of Environment, part of the Ministry of land use planning, environment, urbanism and habitat, is the governmental institution responsible for the development of a national policy for environmental management. The DOE is undergoing several review procedures to up-date the country's environmental policies and regulations including the preparation of a law for the protection of environment, an Environmental Impact Assessment (EIA) decree, as well as norms and standards for environmental protection. Although the ETA decree has not been passed by the Government, EIA studies are being undertaken for some projects especially those that are being funded by International Organizations and Lending Agencies. A national committee grouping representative of several ministries have been formed for the environmental assessment evaluation of projects. It is estimated that so far around 60 EA studies have been reviewed by the DOE in collaboration with the national EA committee. In addition to the environmental laws that have been prepared by the Department of Environment, a number of regulations exist in Morocco regarding environmental protection. For instance the water law No. 10-95 of August 1995 includes several articles related to the protection and preservation of surface and ground water resources, the disposal of wastewater, as well as water re-use for agriculture purposes. The Government has also ratified a number of international conventions for Environmental Protection. 6. Environmental review of subprojects funded by ADS A rapid environmental review was conducted on subprojects already submitted to the Agence de developpement social for approval and funding from the budget of the Agency. The cost of the nine subprojects that were recently approved for funding vary between 3500 USD and 73000USD. Out of these nine subprojects, there are six water and irrigation subprojects, one for EMP-final (November 2001) Page 2 of 8 a 60-m length wadi overpass and two construction subprojects for a day care and a youth center. None of the subprojects would have major irreversible environmental impacts, on the contrary all subprojects would contribute to positive environmental impacts. However, in the future the cumulative impacts from subprojects located in the same area might be significant if environmental considerations within each subproject are not properly addressed. As subprojects are identified on a demand-driven basis, their evaluation will take into consideration technical, socio-economic, institutional, gender and environmental aspects. The following illegibility criteria related to environmental requirements will be observed during the project cycle: (i) Subprojects that can have considerable irreversible negative impacts will not be approved for funding and would include: - Land terracing on slopes greater than 40% - Subprojects requiring deforestation - Subprojects adversely affecting natural habitats and biodiversity - Subprojects that would affect cultural heritage sites. - Subprojects that include the purchase and use of pesticides and herbicides. (ii) Depending on the magnitude and the extent of the environmental impacts, the following subprojects would require an environmental assessment report to be prepared according to the terms of reference provided in the environmental guidelines manual: - New rural roads; - Subprojects adjacent to critical natural habitats or protected areas. Post- review of EA will be subsequently undertaken as part of the regular Bank supervision missions. (iii) Subprojects with minor environmental impacts would require the implementation of an environmental management plan (EMP) according to the typical examples that will be provided in the environmental guidelines manual include: - Rehabilitation and upgrading of public schools - Rehabilitation and upgrading of health centers - Community potable water supplies - Wells and spring protection - Low-cost sanitation subprojects - Rehabilitation of rural roads - Small scale irrigation and drainage schemes Subprojects requiring the preparation of EMP will be reviewed and approved by ADS as part of its prerogatives. The first three subprojects will be reviewed by the Bank after which only subprojects costing above 200 000 USD will require prior approval of the Bank. Periodical monitoring of subprojects will be conducted by ADS to ensure compliance with submitted monitoring plan. Moreover, monitoring and evaluation of subprojects will be ElVIP-final (November 2001) Page 3 of 8 conducted by a local or international consultant during the midterm review and at the end of the project. 7. Assessment of Environmental Capacities L'Agence de Developpement Social was recently created and is still in the process of recruiting its staff members. So far, the Agency has managed to recruit a number of qualified professional staff members. At present there are around eight persons working on the evaluation of subprojects that are being submitted for funding. There is good environmental awareness among the staff of the Agency, however there is limited capacity with respect to environmental requirements such as environmental assessment, mitigation measures and monitoring. Moreover, the Agency is not planning to have a full time environmental specialist within its core team. Consequently it will be necessary to provide the Agency with technical assistance for environment including training workshops and provision of short-term environmental specialists. Environmental awareness is also present among most intermediaries that will be executing the subprojects. However, most associations do not have environmental specialists within their members and it would be recommended to provide them with technical assistance with respect to environmental matters. The Department of Environment (DOE) has a special division for environmental assessment studies. Under the Mediterranean Environmental Technical Assistance Program (METAP), the World Bank provided several capacity building activities including training workshops for the division of environmental impact and other line ministries. METAP also assisted in the preparation of environmental assessment guidelines. However, at present the division of environmental assessment has only one staff member for preparing terms of reference, reviewing environmental assessment studies and assisting at the meetings of National committee. Con-sequently the DOE will not be able to provide major technical assistance to ADS. B. Environmental Management Plan (EMP) 8. Objectives and Structure of the EMP The objectives of the EMP are to mitigate the adverse environmental impacts identified in each subproject. The implementation of the EMP will improve the quality of subprojects and will ensure the participation of concerned stakeholders. The EMP will consist of three kinds of activities: - Implementation of mitigation measures; - Strengthening the capacities of ADS, NGO, associations and local government; - Monitoring and evaluation of mitigation measures identified during subproject formulation or within the environmental assessment report. EMP-final (November 2001) Page 4 of 8 9. Implementation of Mitigation Measures Mitigation measures identified following the desk/or field review shall be properly implemented. Typical environmental impacts and possible mitigation measures are given in Table I for guidance. Intermediaries will be required to adapt the generic mitigation measures for the various subprojects to be executed. Table 1: Potential Environmental Impacts and Proposed Mitigation Measures for Different Subprojects Project Component Potential Impacts Mitigation Measures Responsibility Roads rehabilitation * Clogging of natural * Maintain ditches and Contractor drainage channels outlets * Poor storm water * Provide drainage Contractor/Intermediaries drainage facilities * Encroachment on private * Detailed property Intermediaries/contractor property boundary surveys and setting out * Dumping of excavated * Proper disposal at agreed soil not to be used sites Contractor anymore as fill * Risk of damage to * Coordinate with Intermediaries/Concerned unknown archaeological appropriate government government agency sites agency * Combat erosion near * Plant trees along road Intermediaries/community road site sides, construction of terraces etc. Rural water supplies * Contamination of water * Eliminate sources of Ministry of and sanitation sub- lines contamination Equipment/Basin agencies projects and population * Reduction in water * Better water management Water users' committee availability to other and respect of allowed consumers quota * Degradation of water * Regular survey of water Ministry of Equipment quality quality * Provision of kits to Ministry of Health control water quality Intermediaries/community * Diseases related to poor * Construction of cess evacuation of wastewater pools when other Population solutions are not feasible * Awareness campaigns Consultants Construction/ * Improper disposal of * Priority given to Contractor/ Students' rehabilitation of wastes rehabilitation of toilets parents committee schools * Installation of sanitation (cesspools) EMP-final (November 2001) Page 5 of 8 Construction/ * Improper disposal of * Install cess pools Contractor rehabilitation of medical wastes * Collect, sterilize and Officer responsible of the health centers evacuate medical waste health center Public health awareness campaigns Ministry of Health Construction/ * Degradation of soil * Provide adequate Responsible Unit of the Rehabilitation of quality drainage and verify Ministry of Agriculture small-scale irrigation regularly soil schemes characteristics * Degradation of irrigation * Operation & Water users' association canals maintenance plan * Excessive and incorrect * Awareness campaigns Responsible Units of the use of fertilizers and * Introduction of new Ministry of Agriculture insecticides agricultural practices Income Generating Activities Small livestock * Overgrazing * Reafforestation and Improved design of project Grazing introduction of new by consultants/ raising techniques beneficiaries Projects in favor of * Deforestation * Use of renewable sources Improved design of project local artisans using of energy by consultants/ wood as energy beneficiaries 10. Training Program and Capacity Building Environmental expertise within implementing bodies will be strengthen. Training programs will designed and implemented with the assistance of local or international experts and will target two levels: (i) ADS staff and Intermediaries: Training workshop will be provided to the staff of ADS, selected intermediaries and line ministries to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the ADS. The training workshop will include case studies and will cover the following topics: - EIA techniques - Screening projects for environmental review - Use of practical checklists - Best environmental practices in design and implementation of projects - Effective implementation of mitigation measures - Project supervision - Monitoring and evaluation (ii) Local NGOs and Communities: Workshops for local NGOs and communities, focusing on public awareness, case studies of environmental issues experienced in similar projects, use of environmental guidelines and implementation of mitigation measures. EMP-final (November 2001) Page 6 of 8 11. Environmental Monitoring Environmental Monitoring will be the responsibility of the intermediaries in close coordination with the relevant authorities and will include: - Compliance monitoring during construction - Monitoring of significant impacts during the operation of the subproject. ADS regional representatives will also conduct periodic monitoring by visiting the sites of the various subprojects at least twice a year. Monitoring indicators shall be developed for both the construction and the operation phase of the subprojects. Monitoring of construction activities will have to ensure that mitigation measures of construction impacts are being implemented properly, while the monitoring of operation is to ensure that no unforeseen negative impacts are arising. Typical examples of monitoring plans are given in Table 2. Table 2: Typical Examples of Monitoring Plan for the Operation of Different Subprojects Sub-project Illonitoring Indicators Responsibility Frequency Roads rehabilitation * Drainage channels * Intermediaries in close Semi-annual functioning properly coordination with local assessment community Water Supply and * Distribution network * Intermediaries in close Sanitation Facilities without leaks coordination with local Periodic - * No leakage or overflows community assessment of manholes or drains * Water Quality * Ministry of Health and Monitoring Ministry of Equipment Small scale irrigation * Irrigation network schemes without leaks * Intermediaries in close Semi-annual * Drainage channels clean coordination with local assessment and properly maintained community * Soil quality parameters * Testing by Ministry of (pH, nitrate, Agriculture or independent Semi-annual conductivity) soil laboratories assessment Construction/ * Toilet facilities clean and * Intermediaries in close Semi-annual rehabilitation of functioning properly coordination with students' assessment schools * Drinking water faucets parents committee and clean and safe from appropriate authority contamination Construction/ * Medical wastes sterilized * Ministry of Health in close Semi-annual rehabilitation of and separated in proper coordination with local assessment health centers containers community * Availability of guidelines for proper disposal of medical wastes EMP-final (November 2001) Page 7 of 8 12. Cost Estimates The implementation requirements at the subproject level will be included as part of the proposed project components No.3 and 4 "Institutional Development for Intermediaries" and "Studies and ADS Capacity Building". An estimated amount of US$ 82,000 will be allocated for meeting the environmental requirements of the ADS as detailed in Table 3 and in accordance with the schedule given in Table 4. Table 3: Cost Estimates Component Qty Unit Rate Total Cost in US$ Thousands US$ Project Management Evaluation of sub-projects 6 MM 3000/month 18 Subtotal 18 EA Preparation/Supervision Short term consultants 8 MM 3000/month 24 Subtotal 24 Capacity Building and Training Workshops: - Training workshop for ADS, intermediaries 2 workshops 8000/workshop 16 and line ministries - Awareness Workshop for Local NGOs and communities I workshop 5000/workshop 5 Subtotal , 21 Operation materials and supplies 3 Moaitoring and Evaluation 2MM 8000/month 16 TOTAL 8 Table 4: Schedule of Implementation Year I Year 2 Year 3 Year4 Year 5 1) Evaluation of subprojects 2) Short term consultants to prepare EA 3) Training - ADS / Intermediarics1fine - ministries - Awareness workshops for local NGOs and communitics - 4) Monitoring and evaluation Yasser El-Gannal P:WOROCCO\HD\73531\APPR\EMP-final.doc December 21,2001 9:23 AM EMP-final (November 2001) Page 8 of 8