Buenos Aires Subway Investment Program

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IIC’s Communications Group
E-mail: divulgacionpublica@iadb.org

For project inquiries, including environmental and social questions related to an IIC investment, please contact the client or the IIC using the contact information provided above. In addition, project affected communities have access to the IIC Independent Consultation and Investigation Mechanism.
Tel:+1 (202) 623-3952
Fax: +1 (202) 312-4057
Address: 1300 New York Ave. NW Washington, DC. USA. 20577
E-mail: mecanismo@iadb.org or MICI@iadb.org

Project Number: 
11913-01
Expected Consideration Date by the Board: 
12/13/2016
Date Posted: 
10/21/2016
Company: 
Subterraneo de Buenos Aires S.E.
Financing Requested: 
US$ 150 million
Sector: 
Transportation and Logistics
Environmental and Social Category: 
B
Location: 
Argentina
Country: 
Scope Objective: 

The project consists of the execution of investments over the Line D of the Buenos Aires Subway system including the acquisition of rolling stock, control signals and other equipment and the execution of some construction works with the goal of increasing the frequency of trains and improve the safety, quality and the overall capacity to serve the subway’s demand. The investment plan will include an IIC A loan of up to US$100 million and is expected to mobilize additional funds of up to US$ 50 million.

The outcomes of the investments plan over the Line D of the Subway is expected to: i) double the transportation capacity of Line D, to up to 30 services per hour to allow the Line D to transport approximately 650 thousands commuters ii) improve the quality of service (air conditioning, reduced travel times, reliability, internet access), iii) improve the efficiency and safety of the operation by improved performance and preventive maintenance.

 
Environmental Review: 

1. Scope of Review
Subterráneos de Buenos Aires Sociedad del Estado (SBASE or the “Borrower”) is a company controlled by (the government of) the Autonomous City of Buenos Aires (“ACBA”). SBASE’s aim is to provide suitable, efficient, and good quality public service; to enhance the value of existing subway lines—including the above-ground Premetro light rail line; to develop the subway infrastructure; and to provide the public service safely. The current subway operator is Metrovías S.A., an independent company that operates the subway through an Operation and Maintenance Framework Agreement with SBASE under which Metrovías is the service concessionaire.

The technical due diligence visit was conducted on July 11-13, 2016. The visit was performed by Ernani Pilla and Ricardo Torres, officials from the IIC Environmental, Social, and Governance Division and by Karin Torres, with the consulting firm ERM. The visit also served to assess environmental and social conditions, verify socio-environmental management records (e.g. internal documents on procedures, certifications and operating authorizations), and interview those in charge of social, environmental, and safety and health issues, as well as workers, contractors, and local authorities. Activities during the visit included meetings at the SBASE offices, where officials from SBASE, Metrovías, Civil Defense, and the Environmental Protection Agency were interviewed. The mission visited the work yard and the construction area at Congreso de Tucumán to verify working conditions and that contractor DYCASA was complying with environmental, health, and safety procedures and standards.

2. Environmental and Social Categorization

This is a category B project according to the IIC’s Environmental and Social Sustainability Policy because it could produce certain effects that may be avoided or mitigated by following generally recognized performance standards, guidelines, or design criteria.  The main project-related environmental and labor issues related to the Project are: i) assessment and management of environmental and social risks and impacts, ii) labor and working conditions; iii) resource efficiency  and pollution prevention, and iv) community health, safety and security.

3. Environmental and Social Context
The Project and its physical investments are located in a completely urbanized area, thus  the natural environment components such as soil and water should be considered in a fully anthropic context within the Autonomous City of Buenos Aires. The D Line is one of the six current lines that, along with the Premetro, comprise the Buenos Aires subway network, which is fully built and operating.

4. Environmental Risks and Impacts and Proposed Mitigation and Compensation Measures

4.1 Assessment and management of environmental and social risks and impacts
SBASE lacks a comprehensive Environmental and Social Management System (ESMS) and does not yet have an approved environmental, security, occupational health and safety and social policy. Neither does it have procedures for identifying environmental risks and impacts during the construction stage, nor environmental and occupational health and safety procedures (HSE) for the construction and operational stages. SBASE does not have a contingency and emergency response plan in place for the subway. Despite the aforementioned shortcomings, measures are being taken to address these gaps. For example, SBASE is in the process of organizing the functions of the Environmental and Quality Management directorate team that will be in charge of implementing the ESMS.

With regard to monitoring and evaluation activities, SBASE does not have procedures in place for evaluating its environmental and social performance (performance indicators and internal audits). It also lacks mechanisms for monitoring the performance of the civil construction contractors (audit procedure for contractors). However, in the framework of the operating and maintenance agreement, SBASE inspects and audits Metrovías annually to verify it is compliance with the legal requirements for operating the subway.
SBASE has a webpage http://www.buenosaires.gob.ar/subte where information on the subway’s activities is published. External communications and complaints are received through the Citizen Response System (Sistema de Atención Ciudadana, SUACI), the 147 hotline, social networks, and complaint log books located in the subway ticket booths. However, SBASE lacks procedures outlining the mechanisms for responding to the complaints received and standardizing the results (e.g., communication on service interruptions, users affected by construction of works, communications in the event of emergencies, channels for coordination, and interinstitutional communication).

4.2 Labor and Working Conditions

4.2.1 Working conditions and management of labor relations
SBASE complies with domestic labor laws applicable to its employees.  Argentina’s main labor regulations include obligatory social security contributions, freedom of association and freedom to organize labor unions, a ban on exploitative and abusive child labor, and nondiscrimination in the workplace. SBASE has a procedure in place for selecting new workers that includes orientation on administrative issues and a talk on the operational safety risks Metrovías is in charge of, should their positions require it. It should be noted that internal hiring takes precedence over any external search for professionals. Two drills and training sessions on workplace risks are conducted annually and coordinated by the occupational health and safety unit. SBASE has 395 direct employees, 40% of which are women and 60% of which are men. Between 1% and 2% of all workers have a disability and hold a Disability Certificate. However, SBASE lacks a human resources policy, internal workplace regulations, or an equivalent document listing the rights and duties of workers along with a procedure and mechanisms for dealing with complaints and grievances aimed at workers and partners (e.g. reports of harassment, mistreatment, etc.).

4.2.2 Worker health and safety
The SBASE information reviewed was found to include occupational health and safety management documents, such as health and safety policy PRE-001/2013, which spells out SBASE’s commitments and objectives on health and safety. The risks identified include both operational and administrative risks. Written work procedures are also in place for critical hazards (e.g., electrical hazard, earthmoving with trucks, assembling scaffolds, working with excavators, nighttime work, grounding overhead power cables, etc.). However, there was no evidence of records on compliance with health and safety management carried out by SBASE or the Operator, including, for example: i) identification of hazards, risk evaluation, and control measures; ii) incidents, accidents, and occupational illnesses; iii) investigation of accidents and corrective measures; iv) occupational medical examinations; v) monitoring of physical, chemical, biological, and psychosocial agents, as well as ergonomic risk factors; vi) internal workplace health and safety inspections; vii) distribution of personal protective gear; and viii) induction, orientation and training – amongst others. Finally, SBASE does not have a procedure in place for orienting new staff, nor does it have a program for training and annual reorientation of its workers and contractors.

4.2.3 Supply chain (contractors and suppliers)
SBASE is in charge of maintenance activities and execution of the subway expansion projects, for which it uses contractors. As part of the tender documentation, SBASE includes the obligation for contractors to comply with its legal obligations. However, SBASE does not have procedures and processes in place for evaluating contractor performance.

5. Resource Efficiency and Pollution Prevention
The Technical Environmental Impact Assessment (ETIA) for the D Line includes a Corrective Environmental Action Plan (CAP). The CAP of the subway’s D Line required a greenhouse gas emissions inventory to be conducted to identify and record opportunities for optimizing energy consumption of the subway’s equipment, activities, and facilities in order to identify the operations and equipment that consume the most energy and, based on results, prioritize and take advantage of opportunities for saving energy in the future. The CAP also includes a commitment to develop an energy efficiency plan, but SBASE has not provided any evidence of that plan being developed.

5.1 Pollution prevention
The EAP spells out the controls associated with mitigating the environmental impacts entailed in the operating activities. Metrovías is responsible for applying the EAP. As explained previously (see above), SBASE does not have management procedures in place for the construction activities, for which reason the legal requirements on and procedures of its contractors will be applied.

5.2 Waste management and hazardous materials
During the technical visit to the Congreso Tucumán work yard, it was found that Metrovías properly manages the waste generated (e.g., the waste is identified, labeled, and stored for later final disposal by a licensed company). SBASE verifies that all the legal requirements applicable to waste management are followed. At the Congreso de Tucumán construction works, it was observed that the waste generated is stored properly by contractor DYCASA. Hazardous waste is stored with the corresponding label in appropriate containers depending on the type of hazard. Furthermore, hazardous waste is disposed of in landfills approved for this purpose.

6. Community Health and Safety
Performance Standard 4 applies to the Project because its construction and operational activities can present risks to health and to the health of the communities located in the area of influence of the works.

6.1 Infrastructure and equipment design and safety
SBASE has a qualified technical team with proven experience executing subway projects and has qualified contractors for executing the projects.

6.2 Hazardous materials management and safety
Performance Standard 3 includes more details on hazardous materials management and safety (see above).

6.3 Community exposure to illness (i.e. health risks from the construction works)
Construction works present risks to the service users. These risks have not been identified or included in a community health and safety plan by SBASE or its construction contractors.

6.4 Emergency preparedness and response
Performance Standard 1 includes more details on emergency preparedness and response.

6.5 Security personnel
SBASE does not have procedures governing the work of physical security staff and their use of force or weapons. Physical security is provided by a private company that does not answer to SBASE.

7. Land Acquisition and Involuntary Resettlement
The Project requires application of the Performance Standard 5 due to a land acquisition process for the construction phase. SBASE is negotiating the acquisition of a private piece of land where commercial activity is conducted. The land would be used to build an access point at the 9 de Julio Station. The negotiation is being conducted in accordance with current law, which involves assessing the value of the land up to a maximum price established by the Banco de la Ciudad de Buenos Aires, to be offered to the land owner. If an agreement is not reached, SBASE will activate the expropriation process described in the ACBA Expropriation Act - Law 238.

8. Cultural Heritage
Project activities do not include activities that would modify the D Line’s current infrastructure and are thus not expected to affect cultural heritage. The Operation and Maintenance Framework Agreement includes a clause on the protection of cultural heritage. The city’s Office for Service Management is in charge of maintaining the cultural heritage. It is recommended that a procedure for handling chance archeological finds—to be applied by the contractors—be developed to take advantage of an opportunity for improvement.

9. Access to Information on the Project
SBASE has prepared a document (“Environmental Analysis”) describing the main aspects of the Project—e.g., physical investments and works, regulatory framework, and the strategy for managing the impact of the investments. This document is available to the public through the subway’s website: http://www.buenosaires.gob.ar/subte. Also, SBASE’s communications team will design and implement a communication strategy for informing the subway’s users about the Project, including, for example, flyers, information kiosks, and advertisements on signs, in the media, etc. Finally, for any work the Environmental Protection Agency believes will have a “relevant impact” (for example, possibly for the Catedral station), SBASE must submit a Technical Environmental Impact Assessment and conduct a public hearing as a requirement prior to the Environmental Protection Agency’s issuing of the environmental suitability certificate.

 

No.

PS/RL

Entity Responsible

Indicators

Execution deadline

1.       

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

 

Environmental and Social Policy

Quality and Environmental Management team

a.       ESMS activities plan approved for execution;

b.      ESMS implementation program and budget approved for execution;

c.       Policy updated, approved, published, and distributed, and communication of the policy recorded;

d.      Process for reviewing the policy approved for use

First disbursement

 

First disbursement

 

First disbursement

 

Second disbursement

 

2.       

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

Procedure for Identifying Environmental Risks and Impacts

Quality and Environmental Management team 

a.       Procedure approved for use;

 

b.      Documentation of training conducted

First disbursement

 

First disbursement

3.       

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

Management Programs

Quality and Environmental Management team 

a.      Procedures approved for use;

 

b.      Documentation of training conducted

 

First disbursement

 

First disbursement

4.       

PS 1: Assessment and Management of Environmental and Social Risk and Impacts.

Organizational Capacity and Competency

Human Resources Management team / Quality and Environmental Management team 

a.       Profiles for Quality and Environmental Management team positions approved for use;

b.      Diagnosis on allocation of supervisory personnel;

c.       Documentation of training conducted;

First disbursement

 

First disbursement 
 

First disbursement 

5.       

PS 1: Assessment and Management of Environmental and Social Risk and Impacts.

Emergency Preparedness and Response

Quality and Environmental Management team / Metrovías / Civil Defense

a)      Contingency and emergency plan approved for use;

b)      Documentation of process to validate the plan from local authorities;

 

Second disbursement

 

Second disbursement

6.       

PS 1: Assessment and Management of Environmental and Social Risk and Impacts.

Emergency Preparedness and Response

SBASE/Metrovias

a)      Evacuation plan updated for use;

b)      Pictures, video, and web links documenting dissemination of the D Line evacuation plan

Second disbursement

 

Second disbursement

7.       

PS 1: Assessment and Management of Environmental and Social Risk and Impacts.

Emergency Preparedness and Response

Quality and Environmental Management team

a.       Documentation of the implementation of handcars in the D Line stations;

b.      Documentation of updates to the signage and evacuation plan, including location of the hand cars on the D Line;

Second disbursement

 

Second disbursement

8.       

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

 

Monitoring and Review

Quality and Environmental Management team 

a.    Performance indicators approved for use;

b.    Auditing procedure approved for use;

c.     Documentation of training conducted

d.    Annual audit program;

e.    Annual audit budget approved;

f.     Audit reports and record of closure of findings.

First disbursement

 

First disbursement

 

First disbursement

Second disbursement

Second disbursement

 

Second disbursement

9.       

PS 1: Assessment and Management of Environmental and Social Risk and Impacts.

External communications and grievance mechanisms

Management of user services

a.       Procedure approved for use;

b.      Documentation of training on application of procedure.

First disbursement

 

First disbursement

10.   

ND 2: Labor and Working Conditions

Working Conditions and Management of Worker Relationship

 

Human Resources Management

a.         Human Resources Policy approved for use and dissemination documented;

b.         Internal work regulations approved for use, dissemination to each worker and training on its application documented;

c.          Procedures approved for use;

d.         Training on the use of the procedures documented; 

First disbursement

 

First disbursement

 

 

 

First disbursement

Second disbursement

11.   

ND 2: Labor and Working Conditions

Occupational Health and Safety

Quality and Environmental Management team 

a.       Procedures approved for use;

b.      Training on the use of the procedures documented;

Second disbursement

Second disbursement

12.   

ND 2: Labor and Working Conditions

 

Supply Chain

Quality and Environmental Management team 

a.       Procedures approved for use; training on the use of the procedures documented;

b.      Contracts with ESMS compliance clauses documented

c.       Annual reports standardizing the results and lessons learned;

First disbursement

 

 

Second disbursement

 

 

Second disbursement

 

13.   

ND 3: Resource Efficiency and Pollution Prevention

 

Resource efficiency

Quality and Environmental Management team / Works management team

a.       Energy efficiency plan approved for use;

b.      List of priority projects to be incorporated into engineering projects of SBASE’s Maintenance Plan;

Second disbursement

 

Second disbursement

14.   

ND 4: Community Health and Safety

 

Community Exposure to Disease

Quality and Environmental Management team / Works management team / User Services Management team

a.       Community health and safety plan approved for use;

b.      Socialization of plan with SBASE team documented;

First disbursement

 

First disbursement

15.   

ND 4: Community Health and Safety

 

Security personnel

Human Resources Management

a.       Procedure approved for use;

b.      Documentation of training on application of procedure.

c.       Documentation of steps taken with Metrovías to implement the procedure;

First disbursement

First disbursement

 

First disbursement

16.   

ND 5: Land Acquisition and Involuntary Resettlement

Quality and Environmental Management team

Planning Management team / Legal and Technical Office

a.       Procedure approved for use;

b.      Documentation of training on application of procedure.

 

First disbursement

 First disbursement

17.   

ND 8:  Cultural Heritage

Quality and Environmental Management team

a.      Procedure approved for use;

b.     Documentation of training on application of procedure;

First disbursement

First disbursement

 
 

For more information, contact:   iicmail@iadb.org