Midelt Solar Power Complex Project

Home , Agoudim, Boulemane Province, Errachidia, Mibladen, Midelt, Midelt Province

AFRICAN DEVELOPMENT BANK GROUP

PROJECT : MIDELT SOLAR POWER COMPLEX PROJECT – PHASE I

COUNTRY : KINGDOM OF MOROCCO

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) SUMMARY

Team Leader Adama MOUSSA, Principal Electrical Engineer RDGN1/COMA Succès MASRA, Principal Economist and Financial PERN1/COCM Analyst William DAKPO, Regional Procurement Coordinator SNFI1/RDGN Modeste KINANE, Principal Environmentalist SNSC Mamadou YARO, Regional Financial Management SNFI2/RDGN Team Members Coordinator Patrice HORUGAVYE, Chief Socio-Economist SNSC Vincent CASTEL, Chief Economist RDGN1/COMA Appraisal Wadii RAIS, Financial Analyst, COMA Team Iman SERROKH, Disbursement Assistant FIFC3/COMA

Acting Sector Adama MOUSSA RDGN1 Division Manager Resident Yacine FAL COMA Representative Regional Director- Mohamed EL AZIZI RDGN General Sector Director Ousseynou NAKOULIMA PERN

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) SUMMARY

Project : Noor Midelt Solar Power Complex – Phase I Project No.: P-MA-FF0-004 Country: Kingdom of Morocco Department: Category: 1

Introduction

This document is a summary of the Framework Environmental and Social Impact Assessment (ESIA) of the NOOR Midelt Solar Power Complex Project - Phase I. The detailed design of the NOOR Midelt project’s power plants will be provided by the projects selected following an international competitive bidding, which explains why this assessment is a framework ESIA covering: (i) the entire site and related infrastructure (water and road infrastructure, power supply for water infrastructure (22kv line); and (ii) all the different technological options. Following their selection, the developers will submit specific ESIA/ESMP for each power plant, taking into account the specificities of each plant and will be based on the specific proposal of the developer to whom the project has been awarded. This framework ESIA was submitted to the National EIA Committee which declared the project’s environmental acceptability and issued it on 12 January 2016.

In accordance with the African Development Bank’s Integrated Safeguards System (ISS) and national requirements, this project is classified in Category 1. This summary was prepared in compliance with the AfDB’s environmental and social impact assessment guidelines and procedures for projects in the aforementioned category.

The project description and rationale are presented first, followed by the legal and institutional framework in Morocco. A brief description is then given of the main physical conditions in the project area through its physical, biological and human components. The technological options are available and compared in terms of technical, economic, environmental and social feasibility. The most significant positive and negative impacts on the bio-physical and human environments (socio-economic) are then presented. It should be noted that these are anticipated impacts, irrespective of the type of solar power plant and those concerning related infrastructure. Enhancement and mitigation measures are then proposed to increase the benefits and/or prevent, minimize or offset the negative impacts along with the monitoring programme followed by a presentation of public consultations held as well as complementary initiatives relating to the project. Finally, the executing agency’s existing capacities are analyzed.

1. Project Description and Rationale

1.1. Project Rationale

This project is part of the Moroccan solar power programme (the NOOR programme) estimated at US$9 billion and whose objective is to develop, by 2020, electric power generation capacity of at least 2000 MW through large-scale integrated solar power projects covering several sites. The Ouarzazate (580 MW), Laayoune (80 MW) and Boujdour (20 MW) site development works are ongoing and expected to be completed in 2018. The development of renewable energy projects in Morocco, especially relating to wind or solar power, is combined with industrial integration (local) to strengthen green job-creating sectors and contribute to the emergence of national expertise in that area. 2

These projects will enable the country to: (i) reduce its energy dependency and supply industrial units with electric power at competitive prices; (ii) develop new industrial sub-sectors through strong local project integration (technical assistance is being provided in order to map these sub- sectors); and (iii) honour commitments made by Morocco under COP 21 and 22. The Bank is also envisaging technical assistance to promote power efficiency and renewable energy experience sharing between Morocco and Africa.

1.2 Project Objectives

The project sector goal is to build national electric power generation capacity in order to improve the security of supply and availability of electric power against a backdrop of sustainable development. The project will help to sustain growth and improve the population’s living conditions. Its goal is to reduce the country’s energy dependency and build national electric power generation capacity by deploying electric power production from renewable energy sources. It will help to: (i) mitigate the negative impact of energy imports on the general government budget and on the trade balance; (ii) reduce vulnerability to fuel price fluctuations and to the volatility of these prices; (iii) create a local industry in the solar power sector by manufacturing equipment; (iv) strengthen national renewable energy expertise; and (iv) protect the environment.

The project’s specific objective is to develop in a Public-Private Partnership (PPP) context, two power plants (NOORm I and NOORm II) using hybrid solar power technology, that is, a mix of concentrated solar power (CSP1) (with a CSP capacity of 150 to 190 MW per plant) and photovoltaic (PV) capacity. PV capacity will be optimized by the developer.

The project will also increase the use of PPP models in electric power generation from renewable sources in Morocco.

1.3 Project Description

The Noor Midelt (NOORM) project consists in the construction of a solar power generation complex with several tranches (plants). Its development is planned in several phases under a PPP for private electric power generation in IPP2 form covering the design, financing, construction, operation and maintenance of solar power plants over a 25-year period. The first phase ‘NOORM First Phase’ of the project, the subject of this project, will comprise two (2) hybrid solar power plants (mix between CSP and PV technologies). Each plant will have a CSP capacity of 150 MW to 190 MW with a thermal power storage system that will allow its operation for at least five hours without solar radiation (after sunset or during cloudy periods). The CSP technology could be of the parabolic trough collector or solar tower type (see analysis in the section on the analysis of alternatives for details).

The project comprises a single component described below.

1 Concentrated Solar Power 2 Independent Power Producer 3

Table 1: Project Component Project Component (amounts in million UA) Description Component Description Design and development of two PV/CSP hybrid solar power plants (each with a CSP NOORm capacity of 150 to 190 MW). The PV capacity will be optimized by the developer, Power including site development, solar fields, power plants, electric power evacuation, Electric Power Plant I thermal power storage systems, thermal energy transfer systems, cooling systems, Infrastructure environmental and social measures, technical assistance, engineering and

NOORm development, works control and supervision, project administration and Power management, financial statement audits, monitoring and evaluation, etc. Plant II Total Project Cost 1.7 billion units of account (UA3), i.e. US$ 2.3 billion

The project will be financed by the AfDB, AFD, EIB, the World Bank, the Clean Technology Fund and KfW, the European Commission and private developers (for equity contributions).

The project concerns the following related infrastructure:

 Water Infrastructure: (I) Water intake at the Hassan II dam reservoir; (ii) Lifting and de-sludging stations; (iii) Water pipe from the de-sludging station to the on-site storage reservoir; (iv) electric power supply for water supply equipment (22kv line);

 Road Infrastructure: (i) Improvement of main access road on an existing feeder road from NR 13 to the site; (ii) Construction of a second access road from the Hassan II dam to the site on an existing road;

 Electric Power Infrastructure: Two 22kV power lines are planned to supply the site and hydraulic structures, namely: (i) Line 1: linking the Zaïda sub-station to the site via the national road and the right-of-way of the site access road. This line will be extended to the site to provide redundancy; (ii) Line 2: Linking the Mibladene sub-station to the site from the dam. The electric power facilities developed by ONEE for the evacuation of energy generated by the plants (400 kV/225 kV lines, establishment of sub-stations, extension of sub-stations, feeder lines, etc.) will be the subjects of specific ESIA and procurement plans4 Other infrastructure will be covered by this ESIA.

1.4 Project Location

The site of the future solar power complex (NOORM) is administratively located in Midelt province on an Upper Moulouya plateau about 20 km north-east of the town of Midelt. It is accessible 30 km from National Road 13 linking Meknès to Midelt. The site’s low, flat profile is suitable for the construction of a solar power complex. The site is also located about 11 km from the Hassan II dam (400 million m3) from which the complex will be supplied with water. It should be noted that the site is not far (about 10 km) from the Mibladen transformer sub-station (225 kV) which could be used to evacuate part of the electric power generated by the complex.

3 At the May 2017 conversion rate: UA 1 = US$ 1.37102; UA 1 = EUR 1.25437 4 The land acquisition plan corresponds to the resettlement plan in accordance with the Bank’s involuntary resettlement policy 4

Figure 1: Map of Project Location in MIDELT Province

Figure 2: Map of Project Location on a 1/50,000 scale Topographic Map

2. Policy, Legal and Administrative Framework

2.1 Applicable National Regulatory Texts

Act No. 11- 03 governing environmental protection and development protection promulgated by Dahir 1-03-59 (Royal Decree) of 10 Rabii I 1424 (12 May 2003), defines the principles and directions of an environmental legal strategy for Morocco. This general law meets the need to adopt a global, integrated approach that most closely matches the need for environmental protection and the country’s economic and social development needs.

Dahir 1-03-60 of 12 May promulgating Act 12-03 governing environmental impact assessments (Official Gazette No. 5118 of 19 June 2003). The Moroccan government has promulgated a number of laws, currently in force, that include environmental protection and development, of which the following may be mentioned:

 Framework Act No. 99-12 establishing the National Environment and Sustainable Development Charter;

 Act No. 12-03 on environmental impact assessments, promulgated by Dahir No.1- 03-60 of 10 Rabii I 1424 (12 May 2003) and its enabling decrees.

 Decree No. 2-04-564 of 5 Kaada 1429 (4 November 2008) establishing the modalities for the organization and conduct of the public survey concerning projects submitted for environmental impact assessments;

 Decree No. 2-04-563 on the responsibilities and functioning of regional environmental impact assessment committees;

 Act No. 13-03 on air pollution control promulgated by Dahir no. 1-03-61 of 10 Rabii I 1424 (12 May 2003) and its implementing decrees;

 Act No.10-95 on water, published in the Official Gazette on 20/09/1995 as amended and supplemented by Act No. 19-98 and its implementing decrees;

 Act No. 28-00 relating to solid waste management and disposal and its implementing decrees;

 Dahir No. 1-69-170 (10 joumada I 1389 /25 July 1969) on soil conservation and restoration

 Act no. 12-90 relating to Urban Planning and its implementing decree;

 Act No.22-80 on the Conservation of Historical Monuments and Sites, Inscriptions, Artifacts and Antiquities;

 Act no. 65-99 relating to the Labour Code and its implementing decrees;

 Dahir of 20 hija 1335 (10 October 1917) on forest conservation and exploitation; 6

 Act 13-09 on renewable energy;

 Decree No. 2-10-578 of 7 joumada I 1432 (11 April 2011) implementing Act 13- 09 on renewable energy;

 Act 47 -09 on energy efficiency and its implementing decrees

 Act 29-05 on the Protection of Flora and Fauna Species and Control of their Trade. (Dahir 1-11-84 of 21 July 2011) ;

 Dahir 1-60-063 (25 June 1960) on the development of rural settlements;

 Decree 2-70-510 (8 October 1970) on preventive measures to be taken on-site;

 Act 7-81 on expropriation in the public interest and temporary occupation (6 May 1982); and

 Organic Law 113-14 on municipalities.

In accordance with environmental regulation approach adopted and presented in this paragraph, the upper limits retained for emissions for the construction phase of the new NOOR-Midelt Solar complex are based on the grids proposed in the Moroccan legal texts (implementing decrees and draft decrees for release thresholds). In the case of some parameters (noise) not covered by existing Moroccan regulations (see Annex 1), the complement is provided by the World Bank Group Environmental, Health and Safety Guidelines of April 2007.

According to the Dahir n ° 1-03-60 of May 12, 2003 promulgating law n ° 12-03 relating to the environmental impact studies, the project is subject to the realization of an ESIA.

2.2 Institutional Framework

The main institutions concerned by the project are:

 The Ministry of Mines and Energy is responsible for the preparation and implementation of government energy and mining policy as well as the control of other sectors within its remit. The MEMEE coordinates and acts as the secretariat to CNEIE / CREIE. The role of the CREIE is to review environmental impact assessments and prepare relevant documents on projects entrusted to it (projects with an investment threshold below or equal to MAD 200 million, with the exception of multiregional or cross-border projects). The CREIE gives its opinion on the projects’ environmental acceptability. The CNEIE participates in the preparation of EIA–related guidelines prepared by the government authority responsible for the environment;

 The Ministry Delegate in charge of the Environment at the Ministry of Energy, Mines, Water and the Environment: The Environment Department’s mission is to prepare and implement national environmental and sustainable development policy by establishing efficient tools and measures, implementing concrete actions 7

and promoting a coordination culture that will foster a partnership and programme- based approach;

 The Water Basin Agency (ABH): Water Basin Agencies were established pursuant to Act 10/95 governing water resources. In each water basin or series of water basins, a public establishment with a moral personality and financial autonomy called a ‘basin agency’ was established. The project area depends on the Moulouya ABH. The mission of the ABH is to assess, plan, manage and protect water resources and issue authorizations and concesssions relating to the water public domain (WPD) in their areas of action. Under the Midelt project, an authorization for withdrawals from the Hassan II dam reservoir must be obtained from the ABH ;

 The High Commission for Water Resources, Forestry and Desertification Control (HCEFLCD) is responsible for: (i) Administering by delegation of the Head of Government, property subjected to the Forest Regime as well as the enforcement and control of related applicable legal and regulatory texts; (ii) Protecting, enhancing, developing and promoting forest, alfa grass and silvo- pastoral resources on land subjected to the forest regime; (iii) promoting and implementing actions to expand and develop land suitable for forestry other than State-owned forest land; (iv) Coordinating the preparation and implementation of plans for the management of watersheds and complexes as well as nature reserves and monitoring and evaluating them in consultation with the different ministerial departments or other organizations concerned; (v) coordinating, in consultation with the different ministries and organizations concerned, the implementation at the national level, of the provisions of the different international conventions relating to desertification control, forests, wildlife and its natural habitat, etc.

 MASEN (Moroccan Agency for Sustainable Energy) was established in March 2010 to implement the Moroccan Solar Plan announced in Ouarzazate in 2009. MASEN is a joint stock company (held by the State, the Hassan II Fund, the National Electricity and Water Authority (ONEE) and the Energy Investment Company (SIE) and a dedicated energy support public fund) The purpose of MASEN as defined under Act 57-09 establishing it, is to develop a programme of integrated electric power generation projects from solar power for a total minimum capacity of 2000MW by 2020 comprising: (i) solar power plants; (ii) related outputs and activities that will contribute to the development of the installation areas and the country. MASEN’s perimeter was recently expanded pursuant to Act 37-16 to cover all renewable energy.

 Special Project Companies: Following an international competitive bidding process, one or two private consortia will be recruited to develop the two project power plants (NOORm I and NOORm II) as PPP for private electric power production in IPP form. Two special project companies (SPC) will be established, that is,. one per plant. The majority shareholders will be the private consortium (75%) and MASEN through its MASEN Capital subsidiary (25%). Each special project company will be responsible for the design, financing, construction, commissioning, operation and maintenance over a five-year period of the plant for which it was established; 8

 Provincial Employment Commission: a provincial commission will be established by the Governor of the Province and its responsibilities will include: (i) recruitment monitoring; (ii) ensuring that the recruitment process complies with established practices; (iii) ensuring transparency and equity; (iv) sensitization and mobilization of actors. This commission will include the local authorities, MASEN, ANAPEC as well as the special project companies.

2.3 The Safeguard Policies of the African Development Bank (AfDB) applicable in the context of this project

The Integrated Safeguards System (ISS) through the following operational safeguards (OS):

 Operational Safeguard 1–Environmental Assessment: This operational safeguard is triggered since it is an investment project automatically requiring an environmental and social impact assessment;

 Operational Safeguard 2 – Involuntary Resettlement: this safeguard is triggered since the project will lead to economic resettlement (without the physical displacement of people);

 Operational Safeguard 3 – Biodiversity and Ecosystem Services: This operational safeguard is not triggered since the project will not affect any high potential biodiversity or ecosystem service area;

 Operational Safeguard 4 – Pollution prevention and control, hazardous materials and resource efficiency: This operational safeguard is triggered by the risk of pollution and various nuisances during works implementation.

 Operational Safeguard 5 ‑ Labour conditions, health and safety: this operational safeguard is triggered by the existence of risks to the health and safety of workers relating to site operations.

The other relevant policies and guidelines remain applicable as soon as they are triggered in the context of the ISS. These include:

 The Bank’s Gender Policy (2001);

 The Framework for Enhanced Engagement with Civil Society Organizations (2012);

 Policy on Disclosure and Access to Information (2012);

 Handbook on Stakeholder Consultation and Participation in AfDB Operations (2001)

 Policy on Population and Strategies for Implementation (2002); and

 Environmental and Social Assessment Procedures for the Bank’s Operations (2015). 9

2.5. Other International Texts

Morocco has signed and ratified over sixty International and Regional texts in this area, the most important of which are: (i) the Bern Convention (1979) on the Conservation of European Wildlife and Natural Habitats, adopted in 1979, and ratified by Morocco on 25 April 2001; (ii) Bonn Convention (1979). This global Convention established by the United Nations Environment Programme (UNEP) has 70 contracting countries. Its Secretariat is located in Bonn, Germany. It is a convention concerning the conservation of wild species of migratory animals; (iii) RAMSAR Convention. This convention concerns wetlands of international importance especially for waterfowl habitat. It was adopted at Ramsar (Iran) in 1971 and entered into force in 1975. It constitutes a framework for international cooperation on the conservation of wetland biotopes. Morocco ratified this Convention in 1980 and now, over 150 countries have adopted it; (iv) Vienna Convention (1985) made it mandatory for countries to take appropriate measures to protect the ozone layer. Morocco ratified the Vienna Convention in March 1996; (v) Rio de Janeiro Convention (1992) on Biological Diversity (CBD) is an international convention adopted at the Earth Summit in Rio de Janeiro in 1992; (vi) Framework Convention on Climate Change (New York, 1992). The objective of this Convention is to stabilize greenhouse gas concentrations in the atmosphere at a level that that will prevent dangerous human interference with the climate system (vii) Kyoto Protocol on Greenhouse Gas Emissions (Kyoto, 1997) which calls for a reduction in greenhouse gas emissions in the context of the United Nations Convention on Climate Change, whose participating countries have met annually since 1995. Morocco ratified the Kyoto Protocol in 2002.

Studies have also been carried out taking into account the environmental and social safeguards of other donors including the World Bank and EIB, etc.

3 Description of the Project Environment

3.1 Definition of the Study Area

The overall study area comprises two concentric areas around the site of the NOOR-Midelt solar power complex project. There are, therefore, from the centre to the periphery of this area, the Project site and the immediate and distant perimeters.

The immediate perimeter corresponds to a strip about 500 m wide around the property boundary of the project installation site. Within this perimeter, a detailed analysis of the environment will be conducted. In particular, this analysis will cover fauna/flora/habitats and a review of cadastral documents. This zone comprises the areas likely to be affected by the works or operation of the complex (plots for installing panels, mirrors, towers, access roads, the routing of underground cables, and areas for setting up and assembling the different project components). In this immediate perimeter, the following factors will be taken into consideration: (i) water resources including water courses; (ii) soil; (iii) fauna and flora; (iv) noise; and (v) odour.

The distant perimeter corresponds to the area with potential larger-scale project impacts. In the context of this environmental and social impact assessment, the distant perimeter of the assessment area mainly corresponds to the area with landscaping and, especially, socio-economic impacts. Indeed, all or part of the inhabitants of neighbouring douars will be directly or indirectly affected by the project and its right-of-way at the local level. In this so-defined distant perimeter, the following factors will be taken into consideration: (i) water resources, including water courses and 11 the Hassan II dam reservoir; (ii) fauna and flora; (iii) movements; and (iv) the main socio- economic factors.

3.2 Main Physical Parameters

Location: The future Noor-Midelt Solar Power Complex Site is administratively located in Midelt Province and covers a total area of 4400 ha. It is situated on an Upper Moulouya plateau about 20 kilometres north-east of the town of Midelt. The site is accessed from the national road NR 13 connecting Meknès and Midelt. The proposed project is composed of classified land under the collectively-owned land regime. This consists of collective land covering about 2714 ha, belonging to the Ait Oueflla and Ait Rahou Ouali ethnic communities and forested land covering about 1427 hectares of state-owned land of the forest administration. MASEN has already finalized the procedure for the acquisition of land for the project site. This land will be acquired under the acquisition plan prepared to complement the ESIA.

In addition to meeting project needs in terms of available land area, several technical and socio- economic criteria contributed to the selection of this site: (i) the project area enjoys strong sunlight; (ii) the site is close to the Hassan II dam (about 11 km) which meets its water needs; (iii) there are possibilities for electricity connections; (iv) there is access via the NR 13; (v) the low, flat profile of the land is suitable for the construction of a solar power plant; (vi) there are no dwellings on the site; (vii) there are few stock breeding activities around the site due to the sparseness of vegetation in its immediate vicinity; (viii) environmental constraints are minimal; (ix) no historical monument is registered within a radius of 3km around the site; (x) the site is located outside any protected nature or tourism area.

Topography and Geomorphology: vast plateaus dominate the study area and are divided into two contrasting E-W strips: one to the north and the other to the south. The gentle and regular topographic slope of about 2% descends from north to south. The project site is at an elevation of between 1307 to 1477 m. It is crisscrossed by chaabas created by erosion caused by water run-off and which provide natural drainage for rainwater to the water courses adjoining the plateau.

Geology and Pedology: The land targeted by the project is located on the Upper Moulaya sill, a geological basement known for its very long-term geodynamic stability. From a lithological standpoint, the main area is marked by the presence of three large formations: clayey siltstone, basalt and granite, while there is a predominance of granite in the extension areas. The study area contains brownish-red mountain and forest soils, chestnut soil, usually eroded, skeletic, interspersed with rocky surfaces of the palaeozoic or of igneous origin. The north of the region is composed of chestnut and light chestnut soil in bare and eroded areas with a crusty horizon, mainly on Mesozoic rocks (Cretaceous and Jurassic) supporting stipa and alfa grass.

Climate: The Region has a semi-arid climate with a clearly pronounced cold winter season. Average monthly temperatures vary from 6.2°C in January to 24.7°C in July. The prevailing winds blow monthly from the South-West to North-East at speeds not exceeding 4 m/s. The months with least sunshine are November, December, January and February (221 to 229 hours) and those with most sunshine are May, June, July and August (at least 290 and 321 in July). In Midelt, the average number of frosty days is fairly high. The first frosts occur fairly often in November and the last ones in April. Frost is extremely rare in October and May. The annual number of frosty days was between 17 in 1963 and 65 in 1971. Average annual relative humidity is only about 50%. 12

Air, Noise and Vibrations: On the whole, the study area does not contain any significant sources of emissions of air pollutants. The distant perimeter is only exposed to low road pollution from traffic on the NR 13 and RR 503. The project is far from urban areas and the nearest human settlements are several miles from the site boundaries. During visits to the study area, no significant source of noise was identified.

Water Resources: The study area is sterile from a hydrogeological standpoint and only a few small surface aquifers were observed around the study area which are already tapped for drinking water supply and subsistence farming purposes. Within the study area platform, tributaries form a dense, but considerably attenuated network, which channels storm water as a homogeneous water table towards the downstream part of the Sidi Ayad wadi. The entire network channels water to the Moulouya wadi which passes about 11km south of the site.

Groundwater Quality: Most of the groundwater in the Upper Moulay is of high quality with dry residues of between 200 and 500 to 700 mg/l and bicarbonated calcium-magnesium facies. Water with the highest mineral content gathers in the Turonian limestone unit and in the conglomerates and lake limestone unit of the Plio-Villafranchien era. The latter have slightly higher levels of salinity (500 to 800mg/l), especially in the most arid sectors or downstream from ancient alluvial deposit flows (Enjil and Aït Lahcen plains). Since dry residues reach 1 to 1.2 g/l in the waters of the Lias aquifer in contact with underlying saliferous Triassic rocks and those of the Permo- Triassic Age (Ahouli dome), in the latter case some waters may have dry residues of between 1 and 2 g/l.

Climate change and natural hazards: Flooding/high waters. Potential risk of overflowing of the Sidi Ayad and Bou Tazart wadis on the Eastern and Western edges of the site as well as from the network of chaabat crossing it. On the ground, this risk appears moderate in view of the effective organization of run-off from the site plateau. Soil Swelling: Near the surface, quaternary formations (0 – 6 m), in particular, the earthy-limestone member which causes instability of the banks. Wind Action: whipping up of abrasive sand in sub-equatorial direction in particular in the northern plateaus. Frost: the average annual number of frosty days is fairly high (38) with considerable interannual variability. Linear Water Erosion: this is the most common form of erosion in the study area. Undermining of Wadi Banks: areas of bank erosion have been periodically identified on the edges of the site at the level of the Sidi Ayyad and Bou Tazart wadis. Seismic Risk: the study area is in seismic zone 3 (RPS 2000). This zone is characterized by a maximum horizontal acceleration at the level of the bedrock of 0.10 g and by a peak ground speed of 0.10 m/s with a 10% probability of exceedance in 50 years.

3.3 Main Biological Parameters

Main plant formations: the surveys carried out as well as observations made in the region concerned show that the vegetation comprises steppe formations distributed on the basis of geomorphologic structures Thus, at the level of the channels Retama sphaerocarpa formations have developed accompanied by Peganum harmala, Euphorbia rigida, Panicum turgidum and Juncus rigidus (Juncus maritimus). The plain and hills contain two types of steppes: (i) the first, of the grassy, cespitose type comprises Alfa grass (Macrochloa antiatlantica = Stipa tenacissima) ; (ii) the second of the woody chamaephytic type comprising Launaea lanifera, Noaea mucronata, Peganum harmala, Salsola vermiculata, Hammada scoparia and Astragalus armatus.

The zones in the environs of the study area site also contain, in addition to the types of vegetation described above, many other formations, the most important of which are organized by Salsolavermiculata, Astragalus armatus and Noaea mucronata.

Floristic Wealth: Based on current knowledge (from data compiled by the Botany Unit of the Rabat Scientific Unit and which was used for the national biodiversity study, the region’s flora comprises 67 taxa, 10 of which are endemic to Morocco and 2 endemic to Morocco-Algeria. These taxa are broken down into 25 families. The Asteraceae, Poaceae and Fabaceae are the most frequently represented in the region. The location of the photovoltaic park does not have any particular impact on this flora.

The project site is not near any ecologically and biologically significant area (EBSA). The closest EBSA to the project area is Jbel Ayachi located 40 km to the south of the site.

Birdlife: In view of the geographic position of the project site, located in the eastern north-south migratory corridor and vice-versa, birds represent the most important component of this impact assessment. The site is home to all the main traditional species of the steppe environment of the eastern High Atlas, including elegant Ammomane, Ammomanes cincturus, the Thekla lark, Galerida thekelae, the crested lark, Galerida crostata, the cream-coloured courser, Cursorius cursor, the large desert lark, Alaemon alaudipes, the short-toed lark, lesser short-toed lark, wood lark, corn bunting, black wheatear, European stonechat, raven, meadow pipit, skylark, little owl, spotted sandgrouse, trumpeter finch, Bucanetes githagineus and the tawny eagle Aquila rapax. Of the 82 species identified, 2 are listed on the IUCN Red List. These are: Chlamydotis undulada the houbara bustard (in the vulnerable category) and Neophron percnopterus Egyptian vulture (in the endangered category). The latter is a migratory species, a scavanger vulture which, like all vultures flies and glides in circular paths at very high altitudes. This behavior means it will definitely not collide with the solar plant facilities. Apart from these two species the rest are not classified on the list or are classified as of ‘least concern’.

Of course, the site is located in the eastern corridor known for its major migratory bird routes, especially of sparrows, but does not have any attractive environmental elements for these birds (water courses and riparian vegetation, shrubby formations, sheltering cliffs, cropland…). Due to this situation, the birds avoid landing in this location and, in general, overfly the site towards the Upper Moulouya valley at a fairly high altitude.

Potential or confirmed reptiles or amphibious species on the project site and in its environs: attraction of the site. Among main reptiles observed or reported on the site and in its environs, 25 taxa were listed: the Mauritanian toad, the green toad, the North African green frog, horseshoe snake, Mauritanian viper, hooded snake, High Atlas mountain dwarf lizard, etc. All the reptile and amphibious species on the site are classified by IUCN in the ‘LC’ category; least concern.

Mammals: Among the major mammals observed or reported on the site and in its environs, 15 taxa were listed: the hare (Lepus capensis), abundant on the site; the wild rabbit (Oryctolagus cuniculus), rare on the site; the barbary squirrel (Atlantoxerus getulus), rare in the study sector; the North African gerbil (Gerbillus campestris); the Rozet macroscelide Elephantulus rozeti), a micromammal endemic to North Africa; diurnal fat sand rat (Psammomys obesus), abundant gerbil species; wood mouse (Apodemus sylvaticus); grey mouse (Mus musculus); great jerboa (Jaculus orientalis); weasel (Mustela nivalis), very rare mustelidae on the site; the African wildcat (Felis libyca), very rare; Egyptian mongoose (Herpestes ichneumon) ; red mongoose (Herpestes sanguineus), 14 very rare on the site; Genet (Genetta genetta), very rare on the site. All these species benefit from national regulations (considered as threatened) as set forth in the Protected Areas Master Plan. Only the Algerian hedgehog (Erinaceus algirus) is listed in the IUCN Red List under the ‘VU’ vulnerable category. The other species are classified in the ‘least concerned’ category.

3.4. Main Socio-Economic Parameters

The project site comprises 2 plots with a total surface area of 4,141 ha, both located in Midelt Province. One main zone falls under the authority of the rural municipalities of Mibladene and Ait Ben Yacoub and an extension zone is entirely located in Zaïda rural municipality. This municipality is located on the north-east edge of the Province and is, therefore, adjacent to the Enjil rural municipality which falls under the authority of Boulemane Province. This close proximity will also have implications in the definition of the project’s socio-economic impact areas.

Immediate Proximity Impact Area It is clear that, of the municipalities in which the project is set up, Zaida municipality in Midelt is the main one affected. There are proposals for the addition of the municipalities of Mibladen and Aïn Ben Yacoub, both located in Midelt province and Endjil municipality belonging to the neighbouring province of Enjlil. Due to their location in the immediate vicinity of the site, all these municipalities fall within the immediate proximity area.

The immediate proximity impact area currently has a population of 30,000 people almost half of whom in the centre of Zaida and its rural hinterland. This area contains few human settlements and the few village localities identified in the area that should be mentioned are: (i) Aït Ghiat: 490 people for 131 households; (ii) Agoudim: 420 people representing 84 households; (iii) Arbane: 360 people representing 72 households; (vi) Ahouli : 126 people representing 26 households; (vii) Rahala Sidi Ayad: 432 people representing 52 households; and (viii) Aïn Dheb: 51 people representing 15 households.

Extended environmental impact area: The project will become a pivotal economic element that will have considerable spin-off in an entire sub-region characterized, on the one hand by an austere physical environment and, on the other, by the weakness of its economic foundations and structures. The two economically fragile provinces where the project is established, that is, Midelt and Boulemane provinces, will be considered as the project’s wider impact area. The existing situation in this area is reviewed below. It should, however, be noted that, despite its location in the immediate geographic vicinity of Boulemane Province, most of the project activities will be oriented towards Midelt Province.

Demography: According to the 2014 census; the two provinces in the project area have a reconstituted population of 486,933 people, 60% of whom live in Midelt province. Since the latter was only established in 2009 on the basis of municipalities drawn from Khénifra and Errachidia provinces, it was necessary to carry out a meticulous reconstitution which provided accurate data on the constituent municipalities and communes of Midelt province. This reconstitution was confirmed by the findings of the 2014 General Population and Housing Census. The population of the wider project impact area grew between 2004 and 2014 at an average annual rate (AAR) slightly below the national average over the same period. This could be explained by its key position straddling 2 economic regions and its fairly buoyant economic activity. 15

Transport Infrastructure: Midelt |Province is crossed by two national roads: the NR 13 from Meknes to Azrou-Errachidia and the NR 15 to Missour. The future access road to the project site between Boulaajoul and Zaïda will be connected to the NR 13 and will more or less follow the existing track. The province also has one regional road: the RR 503 to Khénifra which passes quite far from the project site. From these roads, access to the Moulouya Plain is relatively easy by paved regional or provincial roads of average quality (to Boumia, Tounfite, Aghbalou, and downstream towards Mibladen). On the other hand, the outlying municipalities are often extremely isolated.

Education: Koranic school education is the most widespread form (5,152 pupils out of a total of 5,986 in Midelt province, that is, about of 86% of the total number), especially in rural areas. Pre- school education is offered in nursery schools and other kindergartens that will provide training based on modern methods as well as equipment. About 14% of pupils receive this type of education. In the province, there are 113 primary schools, over 80% of which are in rural areas. 73% of the 36,197 pupils are enrolled in rural areas and 1,000 in private schools. Half of the province’s junior secondary schools are located in rural areas. A third of all schools in urban areas are private. About 52% of pupils in urban areas are enrolled in state schools. State-run urban schools are slightly bigger than those in rural areas (1,234 pupils in the first case compared to 830 in the second case). It is worth noting that only 1.6% of pupils attend private schools which do not exist in rural areas.

Health: Midelt Province has one public hospital (H) with a capacity of 108 beds, one Urban Health Centre (CSU) as well as a Haemodialysis Centre. The Province also has 27 Municipal Health Centres (CSC) 12 of which have birth units, 3 of which are outside the health centre and 20 dispensaries.

Agriculture: In Midelt Province, the cropping system comprises two tiers: (i) rose family fruit (apples and pears ...), olive trees; (ii) low crops (cereals, alfalfa and market garden crops...) combined with extensive cattle and sheep rearing. The apple tree plays a key role in Midelt’s economy. The high yields have greatly contributed to improving the living conditions of smallholders who now earn considerably more than when cereal cropping was the only activity carried out in the area. Midelt apples have a very good reputation. The region produces one of the country’s highest quality apple. This reputation has grown with the organization of the Midelt apple festival which has made the product known throughout the world. This is a festival which enhances the Midelt apple as well as the potential of the area.

Forestry: As regards forest formations, the Meknès-Tafilalt region is characterized by a diversity of natural forest species covering an area of about 772,590 ha, that is, 7.7% of the national natural forest area. Alfa grass is to be found in large quantities in Midelt province. It covers much of the landscape especially at average altitudes as in the study area.

Industry: Most of Midelt province’s economic activities are focused on the agricultural, forestry and mining economic sub-sectors. Consequently, the industrial fabric is, for the moment, reduced to a strict minimum with, in all, only the following two enterprises: (i) clay tile and brick factory; (ii) wood sawing, planing and treatment.

Handicrafts The region’s main artisanal activities are woodworking which is possible due to the presence of trees such as the cedar, pine and olive; the manufacture of urban and traditional carpets; textiles with decorative items and fine embroidery. 16

Drinking Water: Drinking water is supplied to the province’s municipalities from wells, boreholes and springs with an estimated access rate of 70%. Central Midelt is supplied by the Atman Ou Moussa spring and two boreholes

Electricity: electric power is distributed by the services of ONEE through three commercial branches established in Midelt, Boumia and Rich. The distribution agency in Midelt province is supplied from four source sub-stations. The medium voltage network covers 1,338 km and supplies 388 public distribution sub-stations and 154 client stations. The low voltage network, for its part, covers 2,464 km and serves almost 64,000 households (i.e. 97% of all households).

Land Tenure Structures and Land Use: The legal status of land in the project area comprises the following four types of land ownership: (i) ‟Melk‟: privately held land belonging to an individual or a group of several people; (ii) collective lands: belonging as freehold and jointly to the entire ethnic community concerned and Guich land. These two systems involve a lease of the right of ownership insofar as the right holders only enjoy fragile usufruct rights; (iii) ‘’Habous’’ land: an institution under Muslim law presented in the form of an asset that a donor may offer to a charitable religious, humanitarian, social, organization or even for public esthetic purposes; (iv) property owned by the State, legal body governed by public law, classified in the public domain (streets, beaches, ports,...), private property from amicable acquisitions, expropriation and confiscation…) and forest lands (forests, dunes, …).

Most of the land on the solar power complex site is classified under the collective land system. There are about 2,643.74 ha of collective land belonging to the Ait Oueflla and Ait Rahou Ouali ethnic communities and forest land covering about 1,474.31 ha, included in the land belonging to the forest administration.

4. Project Alternative Solutions

4.1 Solar Options

Renewable energy is still highly under-exploited in the Mediterranean regions and accounts for only 4% of Mediterranean countries’ energy balance (including hydro-power). However, Mediterranean countries have extremely favourable sunlight conditions and have vast unoccupied areas that could accommodate significant electric power generation capacity. The construction of solar power plants will help to build the generation capacities of the countries of the South and meet domestic consumption. Part of this additional capacity could be earmarked for export to the countries of the European Union. The development of solar energy and enhanced energy efficiency will help to diversify the energy mix and reduce dependency and the risks relating to large-scale use of fossil fuel. These technologies are still in their infancy in industry and therefore represent strong potential for the creation of new markets and are promising in terms of job creation, transfer of technology and, consequently, economic and social development.

4.2 Site Selection

The selection of the site for the solar power complex in the Midelt zone is mainly linked to the high level of sunlight which is a feature of the region. With a Direct Normal Irradiance (DNI) above 5.3 kWh/m2/d, the sector has a significant solar endowment. In addition to meeting the project’s needs in terms of available surface area, several technical, socio-economic and environmental criteria contributed to this site’s selection: (i) the project area enjoys strong sunlight; 17

(ii) the site is close to the Hassan II Dam (about 11 km away) which meets its water needs; (iii) there are opportunities for power connections; (iv) easy access via the NR13; (v) the flat profile is suitable for the installation of a solar power plant; (vi) there are no dwellings on the site; (vii) environmental and social constraints are minimal; (viii) no historical monument is registered within a 3km radius of the site; (x) the site is located outside protected nature reserves and tourism zones.

4.3. Project Alternatives

The objective of this hybridization of Photovoltaic (PV) and Concentrated Solar Power (CSP) solar technologies is to: (i) generate electricity during daylight hours from the PV and/or CSP system; and (ii) generate power through the CSP system to meet peak electric power demand.

Table 2:Main Differences between Photovoltaic and Concentrated Solar Power

Photovoltaic Solar Concentrated Voltaic Concentrated Solar Power Concentrated Solar Power Power (PV) Power (CVP) (CSP) Parabolic Troughs (CSP) Solar Tower The PV effect is Sunlight is This type of plant is composed The evenly distributed mirrors are obtained by the concentrated by optical of parallel rows of long called heliostats. Each heliostat absorption of photons lenses on a highly parabolic trough concentrators. reflects directly towards the into semi-conducting efficient semi- The sun’s rays are focused on a receiver at the top of the solar materials such as conducting unit horizontal receiver tube, in tower. The energy focused on the silicon which which a heat exchanging fluid receiver is then either directly generates electric circulates, whose temperature transferred to the thermodynamic voltage generally reaches 400°C. This fluid, or used to heat an fluid is then pumped through intermediate heat exchanging exchangers to produce medium which is then transferred superheated steam which to a boiler and the steam produced activates a turbine or electric activates the turbines. generator. Not only captures Preferred technology Only captures direct radiance The concentration factor may solar radiation for regions with direct (abundant in areas with high exceed 1000, which makes it directly from the sun, irradiance > 2000 levels of sunshine such as possible to reach high but also diffuses it kWh/m 2.yr. deserts in the Mediterranean temperatures of 600 ° C to 1000 ° solar belt) C. PV requires very few CVP requires very few Significant need of operating Significant need of operating staff. operating staff. operating staff. staff. The main advantages The main benefits are : The main advantages are: (i) The main advantages are (i) are: high reliability - (i) very efficient and yields at least twice those of electric power is generated day not subject to wear economical; (ii) very PV for equivalent solar and night; (ii) little maintenance; and tear they require low water consumption radiation; (ii) possibility of (iii) low ecological impact; (iv) little maintenance. (20 litres / MWh) (iii) storing thermal power directly; power generated is inexpensive The assembly of Small carbon footprint (iii) simplicity of construction photovoltaic (22 g/kWh) ; (iv) Easy process; (iv) boosts the installations is simple and non-polluting development of the local and these are adapted recycling; (v) economy through the need for to the needs of each uninterrupted labour; (v) possibility of project. production throughout associating other sources of the day; (vi) very high energy; (vi) recycling of electric conversion installations is simple yield; (vii) Low impact following their dismantling on fauna and flora; (viii) lower cost per 18

Photovoltaic Solar Concentrated Voltaic Concentrated Solar Power Concentrated Solar Power Power (PV) Power (CVP) (CSP) Parabolic Troughs (CSP) Solar Tower KWh generated compared to PV The main The main The main disadvantages are: (i) A very large construction area disadvantages are : (i) disadvantages are: (i) the high cost of necessary (several dozen km2) is required cost of installation concentration and investments (linked to the and it must be sufficiently exposed which remains high; monitoring system turbine and all ancillary to sunlight throughout the year, (ii) PV yields are still resulting in installations), but is balanced with an ambient temperature low, (20% in the best considerable additional in the case of large-scale above 25°C to ensure a high yield. cases); (iii) PV energy cost; (ii) The plants; (ii) construction is –During construction this vast is, therefore, more geographical complex; (iii) electricity can structure requires considerable suitable for projects possibilities for the site only be generated when the sky engineering expertise. with low needs such are limited (the only is cloudless; (iv) need for heat- - Negative visual impact (some as a single-family exploitable radiance is conversion cooling system; (v) perceive it as deterioration of the home; (iv) Water direct solar radiance); risks of fire or explosion linked landscape) consumption for and (iii) cloudiness to the presence of gas, high - Need for fossil fuel supply to cleaning modules prevents the capture of pressure steam and high maintain the heat-exchange fluid (2l/m2) ; (v) level of sun rays. Areas with temperature synthetic oil, as at the right temperature. electric power least sunshine are thus well as risks of oil pollution - Significant release of water (in generated is not stable excluded. (use of synthetic oil), and, the case of wet cooling). (vi) No power - Finally the fact that finally,significant release of generation in the the technology is not water (in the case of wet evening and at night; yet sufficiently mature cooling). (vii) PV unit yields like traditional decline over time: 1% photovoltaic power yield reduction per impedes possible year. progress.

The CSP component will have a gross capacity of between 150MW and 190MW per plant and the PV capacity will depends on the technological configuration to be proposed by the developer to optimize the CSP/PV hybrid solution. The objective of this hybridization of PV and CSP solar power technologies is to: (i) generate electric power during the day from the PV system and/or the CSP system; and (ii) ensure production from the CSP system to help to meet demand for electric power at peak times.

4 Main Potential Impacts

4.1 Summary of Positive Impacts during the Construction Phase

Economy and Employment: The works will have a temporary positive impact on employment and the activities of dredging and construction firms and indirectly on the local proximity economy as a result of some spin-off linked to the presence of workers in the region. Over 1,500 jobs per plant and 600 to 800 for all municipal facilities will be created. It is expected that thousands of indirect jobs will be created and the socio–economic development of Midelt province will be considerably boost.

4.2 Summary of Positive Impacts during the Operational Phase

Upgrading of the access roads to the level of national trunk roads will help to open up the douars along the planned layout of the areas concerned with facilitation of access, communication, trade and freedom of movement of goods and people for a local population comprising hundreds of 19 households. The upgrading will also help to reduce travel costs and time as a result of the creation of all-weather roads, the upgrading work and measures that will be taken to facilitate traffic and transit. It will contribute to the revitalization of the economy in the areas crossed which could experience rapid economic development. Freight delivery times will be improved as well as conditions of comfort and security. This will significantly increase the value of land and other immovable properties around this road right-of-way. The route of the future feeder road directly serves the centres of Boulaajoul and Zaida, especially the douars of: (i) Ait Ghiat; (ii) Agoudim; (iii) Ain Dheb; (iv) Arbane; (v) Ahouli; (vi) Tazansout; (vii) Rahhal Sidi Ayad (Sidi Ayad and Sidi Said)

Employment: the jobs to be created during the operational phase are: (i) 100 positions per plant; and (ii) 50 for the management of common infrastructure.

Development Impact: The Moroccan solar power programme has been rolled out by MASEN through integrated projects comprising solar power plants as well as related outputs and activities which contribute to the development of their specific areas and, more generally, to the country’s development. MASEN is seeking to maximize synergies and spin-off from its energy projects by contributing to poverty reduction, the improvement of living conditions of communities within the vicinity of its electric-power-generation sites, shared sustainable economic development as well as environmental protection. By adapting to the socio-economic profile of the project regions, MASEN operates in many sectors, in particular, basic infrastructure, education, health and agriculture. MASEN’s local development approach is based on three traditional areas of intervention ranked by order of priority: (i) territorial development; (ii) opening up of territories and (iii) improvement of people’s living conditions. Furthermore, by improving electric power supply, the project will support the productive sectors of the national economy. It will support the PERG launched in 1996 (with financing from the Bank and several other donors) and which made it possible to achieve a national electrification rate of 99.43% in 2016 compared to 18% at its launching, with a beneficiary population of about 12.5 million people. The availability of electric power in rural or peri-urban areas improves the living conditions of people in social categories that are sometimes without modern energy resources, reduces their isolation and builds security in the localities which explains the project’s contribution to social inclusion. The project also aims to promote industrial integration in the field of renewable energy with the manufacturing, in Morocco, of various solar power plant equipment. It also builds national expertise in this field with a positive impact on youth employment, economic activity and tourism in the Midelt region. At local level, the amount obtained for the sale of the land on which the solar power complex will be constructed will be used to finance development activities for the local communities should they opt to develop projects. Needs analysis and project prioritization sessions will be organized and could lead to a list of projects with several components (irrigation schemes, drinking water supply, protection of infrastructure, protection of cropland, road infrastructure projects, health infrastructure and education-related projects).

Gender Impact: the project will have a positive impact on women. Indeed, it will help to guarantee better electric power supply to the Moroccan population including in rural areas. The availability of electricity in households will help to strengthen gender mainstreaming in economic and social development. This could lead to the development of profitable economic activities that will improve household living conditions. Since solar power projects will be developed by MASEN using a local integration-based approach, several social and local development actions will be developed, some of 20 which will be in favour of women and girls (training programmes in sewing, weaving, knitting- embroidery and metalwork etc.).

Reduction of Greenhouse Gas Emissions: the project will contribute to the mitigation of climate change impacts by reducing carbon intensity in the electricity sub-sector in Morocco. The electric power generated by the project’s two solar power plants will replace the generation of thermal power from fossil fuels, in particular coal and diesel/fuel oil which remain the dominant sources in electric power generation in Morocco (55% in 2015). In comparison with the mix of fossil-fuel- fired plants (coal, gas and fuel oil) operated by ONEE, the NOORm I and NOORm II plants of Phase 1 of the Midelt solar power complex (of the present project) will each avoid greenhouse gas emissions equivalent to 600,000 tonnes of CO2eq i.e. a total of 1.3 million tonnes of CO2eq. During the 25 years of their operation (duration of PPP contract) these two plants will avoid the emission of 32.5 million tonnes of CO2eq and 39 million tonnes of CO2eq if their life span is taken into account (30 years).

4.3. Summary of Main Negative Impacts during Construction

Land acquisition: The acquisition of land required for the project is being finalized by MASEN. The acquisition procedures are at an advanced stage and vary depending on the legal status of the property. In any event, the procedures used are compliant with existing national legislation, especially as regards compensation and indemnification of eligible persons. Land to be acquired to accommodate the complex comprised collective land and land in the forest domain. It was acquired following an agreement with the local communities concerned and the forestry authorities. It was carried out through a procedure for expropriation in the public interest with the payment of compensation determined in accordance with the law. The land on which the access structures will be constructed (off-site) was in the water public domain, the road public domain or belonged to local communities (easements). It was mobilized on the basis of agreements with these communities (in compliance with Moroccan law on easements) and the signing of agreements with the public bodies concerned. The land on which the complex’s water supply facilities will be constructed will be acquired pursuant to a concession contract and in return for the payment of levies for the part relating to the water public domain, on a temporary occupation basis for land in the forest public domain and on the basis of an agreement with the communities and the provincial authorities in the context of easement rights for the part owned by the communities.

Infrastructure and Road Traffic: The mechanical constraints induced by the movement of equipment-transportation vehicles, personnel-transportation vehicles and the additional truck or car traffic for teams working on the site may temporarily congest or degrade the traffic routes used. This is, however, considered to be a moderate risk.

Industrial risk and Occupational Health: The presence and operation of construction machinery as well as the presence of personnel, modifications made to the normal functioning of equipment and handling operations may be the source of accidents and therefore generate industrial risks. There are risks of fire, explosion and discharge of products, during the works, close to hazardous products handled or stored (sulphur, ammonia, acids). Risks relating to electricity, risk of electrocution, mechanical and physical risks may be anticipated for personnel during the works and operational phases. This risk is considered to be moderate.

Geology and Soils: Site clearance, soil sealing, movement of earth, erosion, pollution and the presence of equipment and vehicles could lead to: (i) the use of space and breakdown of soil 21 structure owing to the technology applied; (ii) the works and site installations will generate residues of construction materials as well as solid and liquid waste which must be managed as they are produced since they represent a potential source of water and soil contamination near the project; (iii) leakage and spillage of fuel during transportation, storage and refueling of vehicles; and (iv) soil contamination. This risk is considered to be moderate.

Water and Soil Pollution: potential source of soil and water pollution: the site works and installations will generate residues of construction materials as well as solid and liquid waste which must be managed as they are produced; site works and installations likely to generate different types of effluents and pollution loads carried by run-off waters; the risk of accidental pollution caused by leakages and accidental spillages in storage areas and circuits for synthetic oil and inflammable liquids (fuel oil and diesel). Leaks from the heat exchange fluid transfer system. Increased spillage around panels. The covering of the land creates shady areas and superficial drying up of land by reducing precipitations under the modules. This risk is considered to be moderate.

Visual Impact and Damage to Landscape: The photovoltaic and CSP installations on the ground have the potential to change the natural environment because of their size, their consistency, their design and the materials used. Modification of the microclimate under the modules due to the effect of covering them (and also above the modules through the release of heat). Disruption of the arrival of cold air. The module surfaces are sensitive to solar radiation resulting in rapid heating which may reach 50 to 60°C. This risk is considered to be moderate.

Impact on Fauna and Flora: The solar power complex’s impact on birdlife is minimal and will only lie in the visual nuisance when birds are moving or flying over the site. In the case of the solar tower the impact on birdlife is considered to be negative because of risks due to heat flows and the high temperature near the installation’s receptor. This will particularly concern birds whose flight altitude is the same as that of the tower receptor. The change that could be made by the installation of the solar power plants especially by the creations of shaded areas under the rows of modules could be disruptive for flora and animal species with low mobility (invertebrates, small reptiles and micromammals). Concerning the flora, it is important to highlight that there is no tree or shrub on the project site. The vegetation is made up of some rare herbaceous plants including formations of Stipa tenacissima, Peganum harmala, Salsola vermiculata, Retama sphaerocarpa and Juncus maritimus, Retama sphaerocarpa and Peganum harmala.

Restriction of access to the site for the population and livestock: Land acquisition for the solar complex and its development will result in negligible loss to the land grassing rights of the people and local farmers on these collective lands belonging to the Ait Oufella trib. It is important to highlight that the project site almost free of vegetation with grassing value.

Influx of job seekers: During the construction phase, the project will generate significant direct and indirect employment opportunities, which may attract many jobseekers to the project area. It is also important to note that: (i) local expectations in terms of job creation that are well above the potential of the complex; (ii) decommissioning of the worksite and its consequences, represent a risk, that needs to be managed proactively; (iii) temporary migrants, in view of their large numbers, may not find appropriate local accommodation and accommodation capacity may be exceeded; (iv) local economic stakeholders who need a proactive policy that would promote their integration into the project, etc. However, it is worth recalling that these jobs are mainly temporary and concentrated (at 97%) during the construction phase. 22

4.4 Summary of Main Negative Impacts during the Operational Phase

Water Requirements: Photovoltaic technologies only require water to clean the solar panels. They use about 200 times less water than thermal-solar technology with wet cooling and 40 times less with dry cooling (air). The water required in the construction phase of the complex and common facilities will be drawn from the Hassan II Dam which has a capacity of 400 million m3, and will be transported by tanker truck to the project site pending completion of the project’s water supply system during the operational phase. Cooling water requirements: it is planned to equip the CSP plants with dry cooling systems to reduce water consumption. Estimated water consumption at the NOOR Midelt solar power complex is about 1 000 000 m3/year, i.e. 0.5% of the Hassan II Dam’s regular annual volume. A supplementary study on sustainable water supply, including long-term climate change risks, is ongoing.

Impacts relating to optical effects and the electromagnetic field Optical effect: optical disturbances (shimmering, optical illusions, etc.), Modification of surface light. The project will generate electromagnetic radiation created by photovoltaic inverters. Potential emitters of radiation are solar modules, connection lines, inverters and transformers.

Fire Hazard. Since the photovoltaic installations include electrical equipment, a fire hazard exists (short-circuit). The project installations are built of glass, concrete and steel which are non- inflammable materials. In the case of CSP, the risk lies in the receptors. The other main risk linked to CSP operation is the turbine-related risk. There is, indeed, a fire and explosion hazard due to turbines operating under pressure and at a high temperature and the use of small quantities of gas or petrol as well as a major risk source linked to the presence of fossil fuel.

Geology and soil: the risk of accidental pollution caused by leakages and accidental spillage in storage areas and circuits for synthetic oil and inflammable liquids (fuel oil and diesel). Leaks from the heat exchange fluid transfer system. Increased spillage around panels. The covering of the land creates shaded areas and superficial drying up of land by reducing precipitations under the modules.

Soil Sealing: Modification of the microclimate under the modules due to the soil sealing effects (and also above the modules through the release of heat). Disruption of the inflow of cold air.

Water: Only accidental pollution (for example, synthetic oil) can cause water quality to deteriorate. There will be no water withdrawal at the site. The sealed surfaces will impact on storm water. With a dry cooling system, the project will have a moderate impact on regional surface water resources mobilized by the Hassan II dam.

Biological Environment: The solar power complex’s impact on birdlife is minimal and will only lie in the visual nuisance when birds are moving or flying over the site. In the case of the solar tower the impact on birdlife is considered to be negative because of risks due to heat flows and the high temperature near the installation’s receptor. This will particularly concern birds whose flight height is the same as that of the tower receptor. The change that could be made by the installation of the solar power plants especially by the creation of shaded areas under the rows of modules could be disruptive for flora and animal species with low mobility (invertebrates, small reptiles and micromammals). The electric power lines may in some cases cause an increase in bird deaths: (i) by colliding with the cables; and (ii) by electrocution between two cables or on the pylons. 23

4.5. Cumulative impacts

The fact that there are no activities and projects planned in the immediate vicinity of the site limits possible negative cumulative impacts. The impacts identified as well as the proposed compensatory measures are, therefore, of a cumulative nature for a complex with a capacity of 1 000 MW. Cumulative impacts specific to solar power plants will be identified and mitigated in the specific ESIA/ESMP which will be prepared when the developers are selected and, especially, the detailed design completed.

The main positive cumulative impacts during the works phase concern job creation during the works and, subsequently, an increase in the incomes of the communities concerned.

5 Mitigation/Enhancement Measures and Supplementary Initiatives

6.1 Normative and Administrative Measures

It is necessary to ensure project compliance with applicable regulations, and administrative requirements:

 Compliance with environmental and social regulations: The project must be compliant with existing national environmental and social regulations and those of AfDB both in the works phase and in the operational phase. In this respect, the ESIA report was approved by the national committee on 1 December 2015 with the issuance of the acceptability certificate dated 12 January 2016. Also, on 11/06/2015, ABH gave its approval to withdraw 1 Mm3 from the Hassan II dam reservoir.

 Compliance with land tenure regulations: The project has not resulted in any population displacement and a land acquisition plan has been prepared in compliance with existing land tenure regulations in Morocco and AfDB requirements. These elements are contained in the Land Acquisition Plans prepared as supplementary documents and which must be implemented before the implementation of works on the sectors concerned.

 Selection and Recruitment of Developers: the Environment, Hygiene, Health and Safety (EHSS) specifications are incorporated in the bidding documents (BD). All the documents included in the bidding documents for the recruitment of developers (including the environmental and social clauses) will be submitted for donor approval prior to publication.

 Submission of specific ESIAs and ESMPs: Within the framework of the development of the NOOR Midelt solar complex, each plant will be subject to a specific ESIA and ESMP, accompanied by a specific public consultation with the aim of presenting in detail the specific impacts of the plants and related mitigation measures. These will make it possible to take into account the specificities of each plant, and will be based on the specific proposal of the developer to whom the project has been awarded. These reports must also comply with the requirements of the Moroccan authorities and the international financial institutions.

 Just, Fair and Prior Compensation:

LAP I: Land acquisition procedures concerning the Midelt solar power complex site have been finalized and are described in the LAP 1.

LAP 2 : The common infrastructure concerned by this LAP includes: (i) road infrastructure : access road to the site; structure on the Sidi Ayyad Wadi ; (ii) MV electric power infrastructure required from central Zaïda.

LAP 3: The land mobilization procedures concerning the infrastructure to supply the Midlet solar power complex with raw water from the Hassan II Dam are described in the Land Acquisition Plan (LAP 3). 25

The compensation plan will be effectively initiated prior to works start-up for each section concerned.

6.2. Summary of Specific Measures and Supplementary Initiatives

Construction and Operational Phases

Land Acquisition: MASEN’s land acquisition procedures are carried out in compliance with legislation in force and are described in the land acquisition plans prepared by MASEN in compliance with World Bank guideline OP 4.12 and AfDB’s OS-2. The acquisition of land (LAP 1) will not cause any physical displacement of the local population. These are collective lands belonging to the Department responsible for forests and the local communities. This impact will be mitigated by the implementation of the different LAPs.

Impacts on Road Transport Infrastructure: the main measures to be taken are: (i) avoid overloading heavy duty vehicles; (ii) provide for any convoy with exceptional loads (equipment for the complex) with means of transport according to the rules: adapted heavy duty vehicles, notification to the authorities, accompanied by escort vehicles, choice of appropriate time for passing through urban areas; (iii) coordination with local and regional authorities to anticipate peak periods for traffic induced by the complex’s sites and, if necessary, envisage road management measures aimed at limiting traffic congestion in certain places and at sensitive times; (iv) minimization of the number and distance of journeys by delivering supplies as close as possible to the site and optimization of vehicle capacity while complying with road regulations.

Impact on Water Resources: A drainage system must be established in order to: (i) divert clean upstream run-off water to prevent it mixing with leaching water in the works area; (ii) drain the works area towards a clarification facility (filter berms and settling pits…) before discharging it into the natural environment; (iii) ensure that cleared/terraced land that is not built or sealed is replanted to minimize erosion; (iv) ensure that materials likely to be carried off by run-off water are stored outside areas with fast flows and in waterproofed areas equipped with holding tanks; (v) that the construction of a waterproof area on the site will be planned for maintenance work on site machinery (lubrication, oil changing, repair works, etc.); (vi) that oily waste water from vehicle maintenance operations will be collected through intercepters. An authorized specialized firm will remove the recovered oil for recycling. All the residual sludge will be transported to a specialized treatment facility; and (vii) storage of waste water in areas adjacent to water courses of the hydrographic network must be avoided.

Risks of Water and Soil Pollution : in order to minimize waste-related impacts the following measures are planned: (i) waste reduction at source to the extent possible; (ii) storage and handling taking into account the risk and compatibility of waste materials; (iii) in the case of hazardous waste, the use of dedicated, waterproof facilities equipped with adequate retention capacity; (iv) segregation of waste by type and recycling potential; (v) ensure that all waste is controlled in compliance with the Waste Management Plan and perform audits to confirm such compliance; (vi) ensure the use of waterproof elements and secondary retention tanks during refueling operations; (vii) excavate and treat impacted earth as soon as a stain or leak is detected to prevent pollutants (such as hydrocarbons) from infiltrating the groundwater table; (viii) carry out regular visual inspections of secondary retention tanks and look for possible leaks or seepage; (ix) create an asphalted area for vehicle and machinery refueling and maintenance operations. This area will be equipped with a drainage system to prevent any soil pollution. 26

Hazardous material storage areas will be waterproof and covered and include secondary containment (waterproof protection walls resistant to the stored materials), leak-proof tanks, waterproof surfaces in order to prevent seepage and leakage on to the ground. The molten salt tanks, fuel storage tanks /HTF5 /chemical products will be correctly maintained and placed on a waterproof platform.

An HTF leak detection system will be used to alert operators as soon they occur, separate HTF present in the salt chain and determine the exact location of the incident. The system will consist of manometers installed between the heat exchangers and of analyzers installed in the hydrogen collector with sampling flanges to detect HTF leaks.

For the parabolic trough receptors, thermal oils will have the best biodegradability characteristics. They will pass through a waterproof circuit and the valves will be regularly maintained.

In the event of pollution, the contaminated area must immediately be covered with highly absorptive materials. The complex will be equipped with all the sanitary facilities and a wastewater treatment plant to provide biological sanitary waste water treatment before its discharge into the natural environment. The measurement of total hydrocarbon content is recommended annually during the first three years.

The drainage wells below the evaporation ponds to detect leaks must be regularly inspected. All the surface reservoirs and ponds will have overflow pipes towards an effluent collection point. Dry cooling is recommended using evaporative condensers to minimize water consumption and the volume of purged liquids. Carry out regular control and monitoring of the quality of water and discharges from: (i) the wastewater treatment plant; (ii) water cooling systems; (iii) the evaporation pond; and (iv) stormwater drainage system.

Sludge from the wastewater treatment plant will be disposed of in ad hoc places in accordance with the rules in force. Liquid waste and wastewater containing hydrocarbons, lubricants and solvents, etc. will be appropriately disposed of (deoiling). The liquid storage tanks will be inspected and tested under pressure to minimize the risks of potential leaks. All refueling areas will be on waterproof surfaces with the supply of accidental spill response kits.

Industrial and Safety Risk: In order to minimize industrial, health and safety risks for workers and communities, it is planned to: (i) equip labourers with safety helmets, gloves and footwear and to ensure that they are worn by all the people working on the site; (ii) test the structure’s integrity before commencing work; (iii) implement a Fall Protection Programme which will, in particular, include training in climbing techniques and the application of corresponding measures; inspection, maintenance and replacement of fall protection equipment; (iv) establish criteria for the use of integrated fall protection systems; (v) use at least 16mm (5/8 inch) double nylon safety belts or any other material of equivalent resistance; (vi) avoid installation and maintenance work in adverse weather conditions, especially if there is a risk of lightning strikes; (vii) install panels, obstacles (for example bolts on doors, grids as well as steel barriers around transmission line pylons and sensitize/inform the general public to prevent them being in contact with potentially hazardous material; (viii) earth conductive elements (for example enclosures and other metallic structures) installed close to the lines, out of reach of these active parts by distancing, barriers or isolation of live elements; (ix) have work carried out by a person who is aware of electricity risks and has been

5 Heat Transfer Fluid 27 trained and equipped with appropriate tools; (x) ensure that supervision of the implementation of recommended safety measures is carried out by a person who is aware of electricity-related risks; (xi) ensure that employees are trained in maintenance work and wearing of Personal Protective Equipment (PPEI) : helmet with a chin strap, fall arrest harness, safety footwear (xii) ensure visual inspection of PPE before every use; PPE will be inspected prior to each intervention. There will also be an annual inspection by trained personnel authorized to carry out such controls. All deteriorated, damaged or non-compliant PPE will be replaced.

Fauna and Flora Protection Measures: the establishment of an environmental protection policy which will prohibit project personnel from carrying out unnecessary clearance work and deliberately interfering with wildlife. The development and implementation of a Route Management Plan to minimize the impacts generated by the mobilization of equipment and personnel. The following additional measures will be taken: (i) adapt the construction of enclosures (widest possible opening) in order to facilitate the movement of terrestrial wildlife, even its migration to neighbouring land; (ii) equip power lines with effective markers to minimize the risk of birds colliding with these continuous linear obstacles that they encounter when flying through or seeking food; (iii) visual scaring system (artificial bird of prey silhouette, known as scaring devices, affixed to the frame so that birds of prey will overfly it and avoid the cables) ; (iv) birdlife must be monitored twice a year (Autumn and Spring) during the first year of the complex’s operation in the vicinity of the power line (form the dam side to the site). Concerning the flora it is envisaged a tree-planting programme adapted to local constraints. Planting will be done at the fringes of the complex for its better integration into its environment. It is also planned to develop green spaces based on plants and local species that better meet the natural needs of wildlife. Greenspace will be regularly monitored for the attractiveness of birds. Finally, it should be noted that forest estate compensation is a provision applied to all temporary occupation permits. It is equal to the amount corresponding to the reforestation work of the area occupied times five. The said amount shall be fixed by the concerned Regional Director of Forests and Water affairs on the basis of the average of the amounts relating to reforestation work per hectare in the area.

Influx of jobseekers : A provincial commission will be established and chaired by the Governor of the province of Midelt and will be responsible, inter alia, for: (i) monitoring recruitment; (ii) ensuring that the recruitment process is in accordance with established procedures; (iii) transparency and fairness; (iv) sensitizing and mobilizing stakeholders. This commission will include local authorities, MASEN, ANAPEC and project companies. The expectations of the local population in terms of job creation, economic and social development are so high that the establishment of transparent and effective communication is essential in order to control these expectations and, to the extent risk of frustration and disappointment (see stakeholder engagement plan in the consultation section). In addition, particular attention should be paid to the local housing capacity of temporary accommodation for migrants and to the decommissioning at the end of construction.

Dismantling Phase Measures: MASEN undertakes to take the necessary measures to fully dismantle the solar power complex installations after it has finally ceased operations. This will entail: (i) the dismantling of the plants; (ii) dismantling of related equipment; (iii) levelling of the foundations of concrete platforms; (iv) neutralization of the local network including the earthed connection between the delivery and connection sub-station; (v) soil must be restored in accordance with the local context by topographical rehabilitation and vegetation works in order to restore its natural aspect. 28

It should be noted that the project impacts remain within the limits of the applicable standards.

Complementary Initiatives: Complementary initiatives to improve the economic and and socio- cultural development of communities will be proposed by the socio-economic study and socio- economic actions plan being finalized by MASEN. The first initiative in favour of employment will be the establishment of an employment commission in the province to study the best way to promote local employment.

The objective of the local development program is to: (i) Contribute to the local development of the regions where the projects are located; (ii) act as a development arm in complementarity; (iii) contribute to fighting against poverty, access to infrastructure and sustainable and shared economic growth; (iv) Proactively carry out structuring actions that respond to the needs of local populations.

On the basis of the socio-economic impact study recommendations, Masen has identified 12 projects to be implemented that will benefit the population and which are fully in keeping with its local development strategy. The targeted sectors at this stage are: (i) Basic infrastructure; (ii) health; (iii) education. Once these projects are established as well as those initiated by the DAR (Rural Affairs Department at the Ministry of Interior) using funds secured from the sale of land, they will contribute positively to the local development programme for the project area.

7. Supervision/Monitoring of Environmental and Social Management Plan and ESMP Cost

MASEN has shown strong commitment to guaranteeing environmental protection and the safety of personnel working both during the construction and operational phase. Consequently, the objectives set in the supervision plan aim to:

(i) Establish a management system based on a clear hygiene and safety and environmental protection plan;

(ii) Ensure that the goal of the environmental supervision and monitoring plan remains a priority during the project’s implementation;

(iii) Aim to achieve zero incidents;

(iv) Minimize the impact on the natural environment; and

(v) Continue to review and verify the management of the Hygiene, Safety, Environment (HSE) component during project implementation.

As the project owner, MASEN shall appoint an environmental officer to monitor the environmental recommendations during the project construction phase. This person will help to implement the works to verify the adequacy and effectiveness of the proposed mitigation and prevention measures. On the basis of detailed engineering designs, the project owner shall incorporate the adopted mitigation measures in the specifications that the works contractor retained will have to comply with.

The first stage of environmental supervision will entail the appointment, prior to the start-up of the construction activities, of an experienced technical and environmental supervision team in order to ensure effective works implementation. A group composed of the works supervisor, the project 29 owner’s staff and environmental monitoring officer, should see to compliance with and application of all the proposed measures and recommendations through regular supervision of the recommended measures for environmental protection and the restoration of affected environments.

7.1.1 Monitoring Indicators

The indicators provide qualitative or quantitative information on the project’s environmental and social benefits: The will be monitored by MASEN: (i) Effectiveness of the insertion of EHSS clauses in the construction documents; (ii) recruitment of EHSS experts for each developer; (iii) submission of required supplementary studies; (iv) efficiency of site works waste disposal systems; (v) implementation rate of environmental and social mitigation measures; (v) number of gender- disaggregated jobs created; (viii) degree of involvement of local communities in works monitoring; (ix) quality and functionality of completed infrastructure; (x) effectiveness of compensation ; (xi) number of works-related accidents ; (xii) Number of complaints recorded and processed within the time limits; (xiii) regularity and effectiveness of monitoring; (ix) submission of quarterly ESMP implementation reports.

Close attention will also be paid to the following indicators: (i) monthly water consumption monitoring; (ii) monitoring of legionella in the cooling systems; (iii) monitoring of fauna and flora – monitoring the state of vegetation on the edges of the complex; (iv) monitoring of birdlife and herpetofauna in the same sectors.

Indicators specific to the power plants, their frequency as well as the role and responsabilities for their monitoring will be defined whitiin each specific ESMP that will be submitted by the developers for approval by MASEN and the DFIs including the Bank.

7.3 ESMP Cost

The estimated construction and implementation cost for each power plant is included in the plant’s development cost (including, health, safety and hygiene, environmental protection, etc). Land acquisition, the other main item in the ESMP’s cost, is covered by MASEN for an estimated amount of over 82 million dirhams. Planting of trees in the forestry domain is applicable to all temporary occupancy permits. Its cost is equal to the amount corresponding to the reforestation work of 5 times the area occupied. The said amount shall be fixed by the concerned Regional Director of Forests and Waters Affairs and on the basis of the average of the amounts relating to reforestation work per hectare in the area. Finally, the cost of other initiatives comprising local development projects will be known when MASEN on consultation with the other actors, finalizes the projects to be implemented. Its provisional cost is estimated to 89 million dirham.

8. Public Consultations and Disclosure

8.1. National and AfDB Requirements

The main Moroccan laws and regulations on environmental protection are: (i) Dahir No. 1-14-09 of 4 joumada l 1435 (6 March 2014) promulgating Framework Law No. 99-12 establishing the National Environment and Sustainable Development Charter; (ii) Act 12-03 concerning environmental impact assessments promulgated by Dahir No.1-03-06 of 10 Rabii I 1424 (12 May 2003), establishing the list of projects concerned, the implementation procedure and consistency of impact assessments.

According to AfDB’s 2013 ISS, throughout the environmental and social assessment process, the Bank undertakes to ensure that the borrower or client organizes transparent consultations with the affected communities in particular with vulnerable groups, in order to allow them to participate in a free, prior and informed manner in decisions concerning the prevention or management of environmental and social impacts. Indeed, these will be as follows - (i) free: of intimidation and coercion; (ii) prior: timely in terms of the assessment process, allowing sufficient time to access information , understand it and prepare responses; (iii) informed : advance availability of relevant, understandable and accessible information in the appropriate language. As shown in the following sections, these requirements were complied with in relation to the ESIA and Resettlement Plan.

8.2 Public Consultations as Part of the Preparation and Validations of the ESIA/ESMP

In the case of the NOOR Midelt project the environmental acceptability process initiated with the National Environmental Impact Assessment Committee (CNEIE) began in accordance with the procedures including the conduct of the public survey comprising the following stages:

(i) Submission of the ESIA to the National Impact Assessment Committee on 5 May 2015;

(ii) Forwarding of public survey document to Midelt province on 11 May 2015;

(iii) Preparation and signature of decree by the Province’s governor on 9 June 2015 ;

(iv) Purchase of registers;

(v) Publication in newspapers: two notices were published in Arabic and French in local newspapers (‘Le matin’ issue of 17 June 2015 and ‘Almassae’ issue of 16 June 2015) ;

(vi) Initiation of public survey on 30 June 2015 ;

(vii) Conduct of public survey, drafting of the survey report and forwarding to CNEIE ;

(viii) First review meeting with CNEIE on 8 October 2015 ;

(ix) Forwarding of ESSP to CNEIE on 30 October 2015 ;

(x) Second meeting with CNEIE which declared the project’s environmental acceptability on 1 December 2015. 31

The public consultation meeting was held in MIDELT on 10 March 2016 at 10am in the ‘Afrah Al Atlas’ reception hall. The public notice was published in two newspapers with national readership on 4 March 2016 (in French and Arabic). A letter was sent to the Governor of Midelt province who took the step of sending a general invitation to all the actors concerned or likely to be affected by the project.

The consultation’s objectives were: information, consultation and concertation with the participants on the different environmental and social challenges of the NOOR Midelt solar power complex identified by the ESIA. This consultation was organized and conducted on behalf of MASEN in order to integrate all the stakeholders in the project, gather the different remarks and proposals from participants and, finally, to provide answers to the questions raised. Over 100 people representing the different stakeholders concerned and civil society actors of the project participated in this public consultation including representatives of: (i) the territorial communities of Zaïda, Ait Ben Yacoub, Mibladen and Midelt municipality (ii) the ethnic communities and populations themselves; (iii) development associations (women and youth); (iv) ONEE (Water and Electricity Branches) ; (v) the National Provincial Education Delegation; (vi) the Provincial Agricultural Directorate; (vii) the Provincial Equipment Directorate (viii) the Regional Investment Centre; (ix) the Midelt Institute of Technology; (x) the Chamber of Commerce and Industry; (xi) the Provincial Forestry Directorate ; (xii) the Regional Agricultural Development Authority (ORMVA); (xiii) the Vocational Training and Labour Promotion Authority (OFPPT); (xiv) the Regional Environmental Division; (xv) the Ministry of Tourism Delegation; and (xvi) the local authorities.

There was broad participant support for the project and its spin-off for the region’s socio- economic development. Some concerns were raised relating to: (i) the environmental impacts of the NOOR Midelt solar power complex; (ii) supplies to the NOOR Midelt solar power complex (i) the transfer of land and compensation ; (iv) youth employment and training; (v) local infrastructure development; (vi) social actions to be implemented. All these concerns were addressed to the satisfaction of all the participants. The related minutes have been prepared and annexed to the ESIA report.

The Framework ESIA was published on the MASEN site in September 2016. http://www.masen.ma/en/publications/rapports/noor-midelt. The Bank will publish the summary of the Framework ESIA on its site 120 days prior to the project’s submission to the Bank’s Board of Directors.

8.3. Consultations during Preparation of the Land Acquisition Plan (LAP)

See summary of LAP which complements this ESIA.

8.4 Practical Consultation Arrangements for the Remaining Stages and Grievance Management

In the context of the development of the NOOR solar power complex, each power plant will be the subject of a specific environmental and social impact assessment, accompanied by a specific public consultation with a detailed presentation of impacts and compensatory measures for the plant concerned. The Stakeholder Engagement Plan (SEP) which will be developed and implemented by MASEN will ensure that the concerns of all stakeholders are, to the extent possible, taken into account in an inclusive manner in accordance with the principles of the SEP, to identify 32 supplementary socio-economic activities that could be implemented to enhance and scale up the project benefits. The main objective of stakeholder engagement is to ensure that the local populations involved in the project receive all the necessary information in a simple and clear format so that they understand the implications of the project on their communities ; And proposed mitigation measures designed to support the population and mitigate any adverse effects.

The developer will respond to all complaints and answers will be prepared within a short lapse of time. If the complaint is serious, remedial measures will be immediately taken. A complaints register and a letter box will be installed on MASEN’s premises on the Midelt site and will be used, if required, to collect people’s complaints. Complaints may also be filed at the following e- mail address [email protected].

The complaint management system will comprise several elements: (i) publication of the SEP and report on the public consultations on the project developer’s web-site (www.masen.org.ma); (ii) provision of contact information: address, telephone, fax and email; (iii) Opening of a complaints register.

Response time: All complaints registered will be replied to within 30 days.

Complaint Management: In order to ensure efficient management of claims, it is necessary to retain a written record of all complaints. The file established will include the date of the complaint, all follow-up actions, the final outcome and the date of notification to the complainant of the decision. If necessary, complaints may be filed at the e-mail address or placed in a letter box to be installed in MASEN’s premises on the Midelt site.

Monitoring and Reporting: the commitment of all the stakeholders to the project life cycle is a dynamic and stimulating process. The developer is required to supervise implementation of the stakeholder engagement plan and performance of the complaint settlement mechanism. In terms of monitoring, the developer will be responsible for taking all the necessary measures to ensure stakeholder participation in the supervision phase. In addition, an expert in social affairs will be recruited by MASEN and based on the Midelt site. Directly attached to the MASEN local development department, he/she will be responsible for collecting and processing complaints and grievances, conflict management as well as the monitoring and evaluation of local development projects. In terms of information, the developer will establish communication with, and prepare regular reports for communities and people concerned throughout the project life cycle.

9. Residual Impacts and Environmental Risk Management

9.1. Negative Residual Impacts

No average or high negative residual impact is expected following implementation of the mitigation measures. The negative residual impacts are minor and will not be the subject of specific measures.

9.2 Environmental Risk

The complex must be protected against the risk of fire. The adaptation of the fire protection system will be designed and calculated in compliance with recommended standards and practices and the requirements of all the competent authorities. These fire risks will be controlled by the protection 33 of electrical installations from lightning strikes and their regular control as well as the retention of an isolation zone in relation to the closest site boundaries.

9.3 Climate Risks

The project was classified in category 2 in accordance with the Bank’s climate screening system: (I) risk of overflow/flooding from the Sidi Ayad and Bou Tazart wadis ; (ii) linear water erosion; and (iii) fairly high average annual number of frosty days (38) with a wide inter-annual variability.

The following mitigation measures will be taken: (i) bridge calibration, bank protection, an accurately sized artificial drainage system to minimize the risk of erosion on-site and flooding in downstream areas. Also, the hydrological and hydraulic study carried out for water supply to the site takes into account an analysis of the long-term effects of impacts of climate change, especially those concerning the availability of water and the selection of the intake at the level of the Hassan II dam which has a capacity of 400 million m3. In order to minimize water consumption, the CSP plants will be designed to use a dry cooling system. Each plant should not exceed 520 000 m3 resulting in the project’s total water consumption of 26% of the dam’s annual capacity (0.13% per plant). Total water consumption of the entire Midelt solar power complex is estimated to be 0.5% of the regular annual volume of the Hassan II dam, with a minimum impact on the region’s water resources. A study on sustainable water supply, including the long-term risks of climate change, is being finalized.

The project will contribute to the mitigation of climate change impacts by reducing carbon intensity in the electricity sub-sector in Morocco. The electric power generated by the project’s two solar power plants will replace the generation of thermal power from fossil fuels, in particular, coal and diesel/fuel oil which remain the dominant sources in electric power generation in Morocco (55% in 2015). In comparison with the mix of plants using fossil fuels (coal, gas and fuel oil) operated by ONEE, the NOORm I and NOORm II plants of Phase 1 of the Midelt solar power complex (of the present project), will each avoid greenhouse gas emissions equivalent to 1.3 million tonnes of CO2eq. During the 25 years of their operation (duration of PPP contract) these two plants will avoid the emission of 32.5 million tonnes of CO2eq and 39 million tonnes of CO2eq if their life span is taken into account (30 years). As a reminder, the Moroccan solar programme (2 000 MW) which includes this project, will save one million tonnes of oil equivalent in fuel and avoid greenhouse gas emissions equivalent to 3.7 million tonnes of CO2 per year.

9. Institutional Capacities

MASEN has set up a dedicated Environmental and Social Management (ESM) team to ensure optimal management of the environmental and social aspects relating to its activities. MASEN’s environmental and social management (ESM) team comprises 5 permanent members working full- time for MASEN: (i) A Sustainable Development Project mamager attached to the Structuring Department; (ii) a sustainable development officer, attached to the Structuring Department; (iii) a local development officer; (iv) an HSSE (Hygiene, Health, Safety and Environment) officer employed by MASEN Services; and (v) a local development officer employed by MASEN Services based on site.

The project manager and sustainable development officer perform, in particular, the functions of environmental and social safeguard measure coordinators in the context of relationships between MASEN and donors (Institutional Financial Investors - IFIs) and the company’s contractual commitments to the latter. The local development officer is responsible for implementing 34

MASEN’s local development programme taking into account the Environmental and Social Management Plans (ESMP) resulting from the Environmental and Social Impact Assessments (ESIA). The HSEQ officer is among others a Hygiene-Health-Safety specialist based on site as close as possible to the solar power complexes developed to ensure efficient management of environmental, health and safety aspects on-site.

Internally, the different members of the ESM group work closely with the Structuring, Forward Planning and Implementation Directorates in order to identify environmental and social impacts and incorporate the required mitigation measures right along the solar plant development chains. This has forged close functional ties between the teams, continuous coordination work and the constant involvement of members of the management board in monitoring the aforementioned subjects. All the necessary resources were thus allocated to ESM to allow it to correctly assume its duties in particular to enable it to control the establishment of and compliance with the environmental and social impact assessments carried out as well as compliance with the contractual obligations of project companies responsible for constructing the plants. The MASEN ESM is also the key interlocutor of the developers’ environmental and social management team. The latter, chiefly responsible for implementing specific environmental and social management plans, reports regularly to MASEN on the implementation progress of all the mitigation measures.

10. Conclusion

In general, the assessment shows that the project will have major positive impacts in terms of social spin-off. The project may also have negative impacts. However, the anticipated negative impacts are likely to be efficiently managed as a result of the satisfactory implementation of the environmental safeguard measures formulated in the ESMP. As a result, in compliance with national regulations, an acceptability certificate was issued in January 2016.

11. References and Contacts

The summary was prepared on the basis of the following documents:

 ESIA report on NOOR solar power complex – Midelt, 2016

 Land Acquisition Plans; 2016 et 2017

For further information, please contact:

 Nadia Taobane, Structuring Director, Masen ; [email protected]

 Meryem Lakhssassi, Sustainable Development Project Manager, Masen ; [email protected]

For the African Development Bank (AfDB)

 Adama MOUSSA, AfDB, Morocco, Email : [email protected] ;

 Patrice HORUGAVYE, AfDB, Côte d’Ivoire, [email protected] ;

 Modeste KINANE, AfDB, Côte d’Ivoire, Email : [email protected] 35

Annex 1 Project effluents must comply with general limit values for direct liquid discharge into the natural environment recommended under Moroccan regulations i.e. for the main pollution indicators: (i) BOD5 : 100 mgO2/l; (ii) COD: 500 mgO2/l; (iii) SS: 50 mg/l.

Table 3 : Limit Values for Direct Liquid Discharges - Moroccan Decree PARAMETER MOROCCO PROJECT Temperature in °C 30 pH 6.5 – 8.5 [1] SS mg/l 50 Kjeldahl Nitrogen mg N /l 30 [2] Total Phosphorous P mg P/l 10 2 2 COD mg O2/l 500

BOD5 mg O2/l 100 2

Active Chlorine Cl2 mg/l 0.2

Chlorine Dioxide ClO2 mg/l 0.05 Aluminium Al mg/l 10 Detergents mg/l (anionic, cationic and non-ionic) 3 Conductivity in µs/cm 2700 [3] Salmonella/5000ml Absence Vibrio cholerae/5000ml Absence Free cyanide (CN) mg/l 0.1 Free sulphide (S2-) mg/l 1 Fluoride (F) mg/l 15 Phenol Index mg/l 0.3 Hydrocarbons mg/l 10 Oil and Fat mg/l 30 Antimony (Sb) mg/l 0.3 Silver (Ag) mg/l 0.1 Arsenic (As) mg/l 0.1 Barium (Ba) mg/l 1 Cadmium (Cd) mg/l 0.2 Cobalt (Co) mg/l 0.5 Total Copper (Cu) mg/l 0.5 Total Mercury (Hg) mg/l 0.05 Total Lead (Pb) mg/l 0.5 Total Chrome (Cr) mg/l 2 Hexavalent Chrome (Cr) mg/l 0.2 Total Tin (Sn) mg/l 2 Manganese (Mn) mg/l 1 Total Nickel (Ni) mg/l 0.5 Selenium (Se) mg/l 0.1 Total Zinc (Zn) mg/l 5 Iron (Fe) mg/l 3 AOX mg/l 5 Source: Moroccan Decree fixing the limit values for direct liquid discharges

[1] 6.5 to 9 when neutralizing is done with lime [2] More stringent values may be required in the authorization decree depending on the quality objectives of the receiving environment [3] In the case of discharge into inland surface water. 36

Ambient Air Quality Air quality standards and limits are those recommended by Moroccan legislation and presented in Table 4 below: Table 4: Limits Retained for Ambient Air Quality Pollutant Threshold Type Limit Values

Limit value for health 125 centiles 99.2 of daily averages. Sulphur Dioxide (SO2) protection. (µg/m3) Limit value for ecosystem 20 annual average. protection.

Limit value for health 200 centiles 98 of hourly averages Nitrogen Dioxide (NO2) protection 50 annual averages. (µg/m3) Limit value for plant 30 annual averages. protection.

Carbon Monoxide (CO) Limit value for health 10 daily maximum of rolling average (mg/m3) protection over 8 hours. Suspended Solids Limit value for health 50 centile 90.4 of daily averages; (µg/m3) protection PM10.

Sources: Decree No. 2-09-286 of 20 hija 1430 (8 December 2009) fixing air quality standards and air monitoring modalities. Noise The noise level limits recommended by the World Bank have been retained since there is no Moroccan standard. They are set out in Table 5 below:

Tableau 5 Noise Level Limits Maximum Authorized Noise Level (hourly measurements in dB(A)) Receptor Daytime Nighttime (07h00-22h00) (22h00-07h00) Residential, institutional, educational 55 45 Industrial, commercial 70 70 Sources: Critical Environmental, Health and General Guidelines. (EHS). World Bank, 2007.

If the existing background noise already exceeds the World Bank recommended limits, the increase caused by the project shall not exceed 3 dB (A).