FINANCING PLAN (IN US$):€¦ · Web viewProject Type: Full-Sized Project. the GEF Trust Fund....

Submission Date: 3 Mar 08

Re-submission Date:

NAPART I: PROJECT INFORMATION GEFSEC PROJECT ID: 3082GEF AGENCY PROJECT ID: 3714COUNTRY(IES): MoroccoPROJECT TITLE: Safe PCB Management Programme in Morocco, Pillar IGEF AGENCY(IES): UNDPOTHER EXECUTING PARTNER(S): Ministère de l’Energie, des Mines, de l’Eau et de l’Environnement (MEMEE)GEF FOCAL AREA(S): Persistent Organic Pollutants GEF-4 STRATEGIC PROGRAM(S): POPs SP1 Strengthening Capacities for NIP Development and Implementation POPs SP2 Partnering in Investments for NIP Implementation)NAME OF PARENT PROGRAM/UMBRELLA PROJECT: Safe Management and disposal of PCBs in Morocco

A. PROJECT FRAMEWORK (EXPAND TABLE AS NECESSARY)Project Objective: The project objective is to enhance the technical capacity for safe management and disposal of pure PCB oils and PCB containing equipment at all stages of PCB management cycle.

Project Components

Indicate whether Investment, TA, or STA**

Expected Outcomes

Expected Outputs GEF Financing*

Co-financing* Total ($)($) % ($) %

1. Legal and administrative capacity building.

Pillar I

TA 1. Streng-thened legal, policy and ad-ministrative framework for PCB management and disposal

1. Implementation of the framework PCB regulation supported.

2.Sub-regulations, binding guidelines covering all stages of PCB management drafted.(Support to National PCB Committee)

3. Environmental and food limit values for PCB risk mitigation developed.

4. Govt officials, decision makers and private sector convinced of the importance and urgency related to PCB disposal and general population informed about the

451,000 75 147,000 25 598,000

CEO Endorsement PCB management and disposal in Morocco Pillar I

REQUEST FOR CEO ENDORSEMENT/APPROVALPROJECT TYPE: FULL-SIZED PROJECTTHE GEF TRUST FUND

Expected CalendarMilestones Dates

Work Program (for FSP) November 2007GEF Agency Approval September 2008Implementation Start October 2008Mid-term Review (if planned) March 2010Implementation Completion October 2011

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dangers of PCBs

2. Technical Assistance for minimization of PCB releases.

Pillar I

TA 2. Safe PCB management at PCB holder level introduced and further PCB sources identification

1. Capacity to avoid PCB exposure during handling and maintenance increased.

2. Capacity to identify PCB sources and equipment in operation and at entry in country increased.

233,750 71 94,000 29 327,750

3. Technical assistance for export disposal of pure PCBs

Pillar I

TA 3. Pure PCB containing equipment disposed in participating industries.

1. Capacity to avoid PCB exposure during dismantling, transportation and storage Increased.

2.Existing PCB dismantling procedures up-graded

3. PCB equipment replacement accelerated through economic instruments.

4. As urgent disposal measure, 205 tons of PCB oils are exported and 685 tons of associated equipment treated.

1,155,250 20 4,632,200 80 5,787,450

Outcome 4: Monitoring Learning Adaptive Feedback and Evaluation

4. Project monitoring, local and global benefits as well as lessons learnt documented

1Development and implementation of Project Monitoring and evaluation tools and systems.

2.Information and outreach

3. External Evaluation

141,000 84 27,000 16 168,000

5. Project management 217,000 44 273,000 56 490,000

Total Project Costs 2,198,000 29 5,173,200 71 7,371,200


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B. FINANCING PLAN SUMMARY FOR THE PROJECT ($)

Project Preparation* Project Agency Fee Total at CEO Endorsement

For the record:

Total at PIF

GEF 334,900 2,198,000 253,290 2,786,190 2,779,040Co-financing 90,000 5,173,200 5,263,200 4,951,950Total 424,900 7,371,200 253,290 8,049,390 7,730,990

C. SOURCES OF CONFIRMED CO-FINANCING , including co-financing for project preparation for both the PDFs and PPG. (EXPAND THE TABLE LINE ITEMS AS NECESSARY)

Name of co-financier (source) Classification Type Amount ($) %Government of Morocco National Government Grant 466,000 10Government of Morocco National Government In-kind 545,000 11PCB holders (For names of companies ee Annex II Prodoc)

Private Sector In-kind, hardware costs for replacement equipment

3,862,000 72

PCB holders Private Sector In-kind technical staff

300,200 7

Total Co-financing 5,173,200 100% D. GEF RESOURCES REQUESTED BY FOCAL AREA(S), AGENCY(IES) OR COUNTRY(IES)

GEF Agency Focal Area Country Name/

Global

(in $)Project

Preparation Project Agency

Fee TotalUNIDO POPs Morocco 2,437,600 243,760 2,681,360UNDP POPs Morocco 334,900 2,198,000 253,290 2,786,190(select) (select) Total GEF Resources 334,900 4,635,600 497,050 5,467,550

* No need to provide information for this table if it is a single focal area, single country and single GEF Agency project.

E. PROJECT MANAGEMENT BUDGET/COST

Cost ItemsTotal

Estimated person weeks

GEF($)

Other sources ($)

Project total ($)

Local consultants* 234 144,000 --- 144,000International consultants* --- ----- ----- ------Office facilities, equipment, vehicles and communications**

38,0001 60,000 98,000

Travel** 20,000 ----- 20,000Total 234 202,000 60,000 262,000

* Provide detailed information regarding the consultants in Annex C. ** Provide detailed information and justification for these line items.

1 The government contribution for office and travel budgetlines consists of providing office space the GEF grant will provide for office equipment supplies as well as communication facilities, intenet, phone charges etc.The travel budget is reserved for in-country travel to various industries for ensuring timely participation as well as keeping contacts with regional PCB initiatives.


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http://gefweb.org/Documents/Council_Documents/GEF_C21/C.20.6.Rev.1.pdf

F. CONSULTANTS WORKING FOR TECHNICAL ASSISTANCE COMPONENTS:2

Component Estimated person weeks GEF($)

Other sources ($)

Project total ($)

Local consultants* 500 375,000 375,000International consultants* 62 186,000 186,000Total 561,000 561,000

* Provide detailed information regarding the consultants in Annex C.

G. DESCRIBE THE BUDGETED M&E PLAN:

1. Project monitoring and evaluation will be conducted in accordance with established UNDP and GEF procedures and will be provided by the project team with support from UNDP/GEF. A Project Inception Workshop will be to be held within the first three months of the project implementation with the full project team, relevant government counterparts, key counterparts and UNDP. A Project Steering Committee including the government, UNDP, industry and NGO representatives will be constituted at project inception and will meet quarterly to review project progress, provide strategic guidance, and approve annual work plans and budgets.

2. Day to day monitoring of implementation progress will be the responsibility of the Project Manager and National Project Director, who will be assisted by a Monitoring and Evaluation expert serving part time. The Monitoring and evaluation expert will, with assistance of international expertise, develop a project Monitoring and Evaluation system. This will be validated by the government after which baseline data will be compiled. This baseline will be the benchmark against which progress of the project will be monitored. It is foreseen that the baseline will include both project output indicators as well as indicators for measuring actual PCB risk reduction. The last could include restricted sampling and analysis or epidemical studies/data collection.

3. The Project Steering Committee will be instrumental for monitoring project progress as well as changes in selected risk reduction indicators. The project team will report to the Project Steering Committee against the agreed indicators at each meeting of the PSC.

4. A Mid-Term review of the project will be conducted by a project independent national expert and nominated government officials. The Mid-Term Evaluation will determine progress being made towards the achievement of outcomes and will identify correction course if needed. It will focus on the effectiveness, efficiency and timeliness of project implementation; will highlight issues requiring decisions and actions; and will present initial lessons learned on project design, implementation and management.

5. The information and outreach material developed, particularly lessons learned sections, will also, to some extent, provide tools for evaluation. These sections will be partly based on review and evaluation findings and their wide distribution will provide feed-back, further providing data on the impacts of the project.

6. A two person team of national and international independent evaluators, strengthened with government appointed experts will conduct a terminal evaluation with a lessons-learned section for wide distribution to other countries planning similar PCB disposal and replacement projects. The Final Evaluation will take place three months prior to the Terminal Tripartite Review meeting, and will focus on the same issues as the mid-term evaluation, but will concentrate on the wider impacts of the project activities. The final evaluation will also review the sustainability of results, including the contribution to capacity development and the achievement of global environmental goals. The Final Evaluation shall also provide recommendations for follow-up activities.

Financial Monitoring

7. Financial monitoring and adherence to adopted yearly budgets will be controlled through annual project audits. These audits will be done as per standard procedures for Nationally Executed projects as in force for UNDP CO in Morocco.

2 Not including the estimated technical expertise at Goverment and private sector technical experts which are calculated as in-kind contribution


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8. The financial audits will, in addition to ensure adherence to bidding and other procedures, emphasize the cost –effectiveness of the action undertaken. The financial audits will further validate the input utilization or `”budget-delivery” which may to a certain degree be used for monitoring the implementation efficiency or speed of the project.

9. The Monitoring and Evaluation plan and budget can be found in the table below. As the PIF did not include a separate Monitoring and Evaluation component the expenses are budgeted under Project Component 3.

Type of M&E activity Lead responsible party underlined Budget (indicative) Time frameInception Report Project Implementation Team None At the beginning of project

implementationDevelopment of M&E system

Project team, government executing agency

28,000 At the beginning of project implementation

Baseline and update agreed monitoring variables

Project team, M&E expert, Project Steering Committee

38,000 First quarter of project implementation.

Project Implementation Review (PIR)

The Government, Implementing Agency (IA) Country Office, National Executing Agency, Project Team, IA Task Manager, and Target Groups

None Every year, at latest by July of that year

Implementing Agency (IA) annual reports

The Government, IA Country Office, National Executing Agency, Project Team, IA Task manager, and Target Groups

None Every year

Quarterly Progress reports Project Manager None At the end of every quarterMid-term evaluation Government, IA Country office 6,000 project + 6,000

government in-kindApproximately 18 months from inception.

Terminal Evaluation, including lessons learned

Project team, IA headquarters and Task Manager, IA Country Office, National Executing Agency

27,000+6,000 government in-kind

At the end of project implementation, before terminal tripartite

Terminal Report IA Country Office, IA Task Manager, Project Team

None At least one month before the end of the project

Audit National Executing Agency, IA Country Office, Project Team

15,000 (total for project duration)

Yearly

PART II: PROJECT JUSTIFICATIONA. describe the project rationale and the expected measurable global

environmental benefits: 10. The main global benefit from the project will be the safe disposal of minimum 205 tons of pure PCB oils within

685 tons of equipment. This figure is includes all targeted pure PCB waste including those to be disposed with the cash contribution provided by Governemnt of Morocco totalling in approximately US$ 466,000. All targeted PCBs will be destroyed and the risk that they will be globally redistributed will be eliminated. The introduction of safe in-country management practices for PCB contaminated transformers will contribute to the global benefits as the global community can be assured that the remaining PCBs in Morocco are being responsible and sustainably managed and disposed.

11. Nationally one can expect environmental and health benefits, thanks to decreased releases as less PCB containing equipment are in operation. Further it can be assumed that less PCBs are reaching the environmental and food sources which further contribute to health status among the local population. These health-related benefits are difficult to assess and quantify and evaluate.

12. Another important national benefit is the experience and capacity gained by most stakeholders in developing a clear plan from cradle-to-grave on how to sustainably manage a particularly problematic industrial chemical. The overall approach and tools developed in the project can with modifications be utilized for other problematic


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chemicals within and beyond the sphere of Stockholm Convention POPs. Hence, the project experience and adopted approaches will contribute towards overall sustainable chemicals’ control.

13. Apart from the global environmental benefits, the final beneficiaries of the project will obviously be the Moroccan people and their environment. A more direct beneficiary is the Ministry of Territory Development, Water and the Environment, which will get access to technical and managerial support for preparing POPs legislation and to develop educational and information material on PCBs as well as their dissemination. The environmental inspectors and customs officials will benefit from increased professional competence from the training activities.

14. Other major beneficiaries will be private sector entities with hazardous waste, PCBs, in their possession. Though they will be required to dispose the PCB they will be given an affordable option of disposing the waste. All private sector partners are expected to gain technical capacity thanks to the project.

B. DESCRIBE THE CONSISTENCY OF THE PROJECT WITH NATIONAL PRIORITIES/PLANS:

15. Morocco signed the Stockholm Convention on 23 May 2001 and ratified the same on 15 June 2004.

16. The Moroccan National Implementation Plan for POPs was submitted to the Stockholm Convention Secretariat on 2. May 2006. The NIP puts management of PCBs as first priority for a successful implementation of Stockholm Convention obligations and commitments. The POPs NIP requires Governmental departments, particularly MATEE, to develop and roll-out comprehensive legislation, prepare and disseminate information material for avoiding the release and exposure of PCB in industrial activities. The NIP further includes action for “Reinforcement of capacities afro management and eliminating of PCB oils and equipment” as one of its major actions.

17. The country drivenness in the project preparatory process has been further manifested by the commitment of all key ministries to expedite the drafting and submission of the framework PCB regulation. The draft decree has been finalized and submitted for enactment. The draft legal framework will create a sustainable ground for fostering further country drivenness and control, which the project activities will support.

18. Further, The project fits within the objectives of the UNDAF and of the CCA between UNDP and the Government of Morocco (2007-2011), namely through the strengthening of the legal, policy and institutional framework for environmental protection, in harmony with international instruments. Indeed, the project contributes directly to the capacity reinforcement of national institutions in the elaboration and implementation of policies and action plans, in conformity to rules and regulations and international commitments.

C. DESCRIBE THE CONSISTENCY OF THE PROJECT WITH GEF STRATEGIES AND STRATEGIC PROGRAMS:

19. The GEF-4 introduces a number of novel aspects for projects in order to be GEF-eligible and supported. Projects, and project countries, should show commitment to policy change and contribute explicitly towards the Strategic Objectives and their indicators.

20. As proven by developing and taking first steps in adoption of the PCB legislation, Morocco has demonstrated its willingness to adopt the necessary policies as called for in selecting priority countries for continuing GEF support

21. Further, the objective of the project will directly contribute towards the Strategic Objective of GEF-4 for Operational Programme 14 which sets the long term impact of GEF interventions as a reduction in the exposure to POPs of humans and wildlife.


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http://gefweb.org/uploadedFiles/Projects/Templates_and_Guidelines/C31-10%20Revised%20Focal%20Area%20Strategies-07-23-07_Final.pdf

22. The project outcomes and activities (see next section or project Logframe) are explicitly supporting Strategic Objective 1: Strengthening Capacity for NIP Development and Implementation and Strategic Objective 2: Partnering in Investments for NIP Implementation of POPs focal Area Strategy for Persistent Organic Pollutants.

23. The Strategic Objective 1 (b): Strengthening Capacity for NIP Implementation aims at supporting countries to increase its capacity to implement their Stockholm Convention obligations and NIPs in a sustainable, effective and comprehensive manner.

24. The project works towards GEF POPs Strategic Objective 1 (b) via the projects Outcome 1.“Strengthened legal, policy and administrative framework for PCB management and disposal” through i) Support for making the framework PCB regulation operational ii) drafting and enacting sub-regulation, binding guidelines covering all stages PCB management; iii) Developing and facilitating approval of environmental and food limit values for PCB risk mitigation; iv) Raise awareness and educate government officials and general population about the dangers of PCBs (POPs) and the possible adverse effects of exposure.

25. All these project activities will contribute towards the GEF Strategic Objective 1 indicators

a. Legislative and regulatory framework in place in supported countries for the management of POPs, andchemicals in general;

b. Strengthened and sustainable administrative capacity, including chemicals management administrationwithin the central government in supported countries; and

c. Strengthened and sustainable capacity for enforcement in supported countries.

26. Indicators b) and in particular c) will further be contributed towards by several outputs and activites under project Outcome 2.“Safe PCB management at PCB holder level introduced and further PCB sources identification” and which will bring the enforcement officials up the technical knowledge level needed for efficiently enforcing PCB safety regulations developed.

27. The GEF Strategic Objective 2: Partnering in Investments for NIP Implementation aims at reducing POPs production, use, and releases as well as the stress on human health and the environment caused by POPs.

28. The exact nature of contributing interventions would be detailed in each country’s NIP and they would phase-out and destroy POPs in an environmentally sound manner, and/or use of substitute products and alternative practices that prevent or reduce the generation and/or release of POPs.

29. As indicated in the introductory and Baseline analysis sections, PCB equipment management, phase-out and replacement is well-anchored in the POPs NIP in Morocco.

30. The project as a whole is contributing towards POPs Strategic Objective-2, but specifically project Outcome 3. “Pure PCB containing equipment in participating industries disposed” will contribute to the indicators of the GEF POPs Strategic Objective 2 indicators reported towards are:

a. POPs phased-out from use (tons and cost per ton per compound);b. POPs destroyed in an environmentally sound manner (tons and cost per ton per compound and mode of

destruction);

31. The POPs/PCB phase out activities contributing towards indicator a will be initiated in project Outcome 2. Where “Increased capacity to identify PCB sources and equipment at industries and entry in country” will initiate the phase-out cycle. The actual POPs destruction and replacement will be carried out as a part of Project outcome 3.

32. Further, the GEF Strategic Objective 2 indicator :

a) Reduced exposure to POPs, measured as the number of people living in close proximity to POPs wastes CEO Endorsement PCB management and disposal in Morocco Pillar I

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that have been disposed of or contained.

33. will also be contributed towards by the project activities. Measuring the contribution towards indicator c) will require setting up of appropriate system for documenting which replaced PCB sources (equipment) have already caused exposure to people living in the vicinity. This will be done as a part of the monitoring and evaluation activities.

34. There is also a number of people exposed to PCBs in their daily work practices during maintenance and dismantling and temporary storage etc, who will thanks to the project no longer be exposed. Again appropriate system for measuring this risk reduction needs to be set-up during the project.


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D. OUTLINE THE COORDINATION WITH OTHER RELATED INITIATIVES:

35. For scheduling, co-financing and practical implementation reasons the Safe Management and Disposal of PCBs in Morocco was separated to its two originally envisaged Pillars. This proposal project establishes Pillar I which puts its emphasis on regulatory strengthening and ensuring safe management at PCB holder level as well as disposes most pure PCBs identified in Morocco.

36. Obviously the Coordination with Pillar II of the project will be very close. It is envisaged that the same project steering structures would be utilized for both Pillars. Further, additional coordination for the activities related to management of slightly PCB contaminated equipment will be developed during implementation as Pillar I will contribute towards their safe management during their remaining time, by avoiding releases and cross contamination, while Pillar II will dispose the same equipment at the end of their technical life.

37. As the project is concentrating on a quite narrow technical area, national regulative framework, safe handling and disposal of pure PCBs it will have limited need for coordination with other national initiatives. Links will be established with the National Hazardous Waste Center (CNEDS) in order to find possible synergies and use the PCB management project as a vehicle for capacity building of institutions and individuals working closely with CNEDS.

38. Cooperation with the African Stockpiles Programme will be explored during the project implementation. Possible areas of mutual interest may be reduction of POPs exposure through awareness and educational efforts as well as in tendering and transporting POPs waste from Morocco as many final disposal operators accept both pure PCBs and POPs pesticides and associated contaminated materials. For such operations logistics arrangement established in Pillar I may be used by the ASP Programme. It should be further noted that most PCB decontamination technologies can also dispose of POPs pesticides. While such operations are not usually economically well justified it may be a potential possibility for disposing minor quantities of POPs pesticides unearthed after main disposal stage of ASP.

39. Moreover, the proposed project, will tie close contacts and exchange of experiences with the UNEP-led regional PCB project, in which Morocco will participate. The regional PCB project is still in the PIF and preparatory phase and as the Government has not yet received an official request from UNEP on the specific activities to be undertaken in the framework of the regional PCB project in Morocco.

40. It is foreseen to establish close links between the project management teams of the national UNIDO/UNDP project and the regional UNEP project to ensure that project activities of these two projects are fully complementary.

41. With the implementation of the UNDP-led pillar I of the overarching PCB project in Morocco and the development of PCB management structures in pillar I and by implementing activities of the proposed project, Morocco will gain vast experience in establishing regulatory regimes and in the environmentally sound management and disposal of PCBs. This experience gained will be shared with participants of the UNEP-led regional PCB project and will therefore provide benefits to the whole region.

42. The officials working on PCB/hazardous waste issues at Ministère de l’Énergie, des Mines, de l’Eau et de l’Environnement (MEMEE) will have a central coordination and experience sharing between the regional and national projects. It is foreseen that Ministry personnel will attend regional workshop and present experiences gained in the national context. Main emphasis will be put on presenting experiences from project activities that can support activities among the countries participating in the regional project.

43. Areas where Pillar I is identified to support the regional project are at in the design phase of the projects:

44. Designing and drafting of national legislation, comprising also of detailed technical guidelines at various stages of PCB management to ensure its safety.


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45. Development of environmental and food limit values in the national context as well as estimating risk reduction and costs of monitoring programme for various limit levels for PCBs.

46. Pillar II is contributing to the regional project in demonstrating viable strategies to dispose of low contaminated PCB- equipment through a dedicated national facility, which is the preferable PCB disposal technology option of PCB contaminated waste of the Government of Morocco.

47. The project will strengthen fundamental capacities in chemical management within the country and provide mechanisms to link the PCB work at local level to the broader national chemicals management agenda in support of the Strategic Approach for International Chemicals Management (SAICM). It will also serve to support the GEF’s strategic aim to promote sound management of chemicals. SAICM, adopted in February 2006 in Dubai, supports achievement of the goal of WSSD Johannesburg Plan of Implementation that seeks to ensure that, by the year 2020, chemicals are produced and used in ways that minimize their significant adverse impacts on the environment and human health.

48. The SAICM approach details a Global Action Plan for action contributing towards the overall goal of achieving a sound chemicals management as per the Johannesburg timeline. This Global Action plan is divided into a number of Work Areas where contribution to SAICM can be achieved. These Work Areas are given in the table below together with notes on which the proposed project is contributing to.


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SAICM Global Action Plan Work Area Project Activity1. Assessment of national chemicals management to identify gaps

and prioritize actionsLegislative analysis and developing legislative frameworks applicable to substances beyond PCBs

2. Human health protection Securing and disposing sources of hazardous chemicals3. Children and chemical safety Replacement of PCB equipment within communities, sport

facilities etc.4. Occupational health and safety Providing safety training during operation, maintenance and

disconnection etc of PCB containing equipment5. Implementation of the Globally Harmonized System of

Classification and Labelling of Chemicals (GHS)N/A

6. Highly toxic pesticides – risk management and reduction N/A7. Pesticide programmes N/A8. Reduced health and environmental risks of pesticides N/A9. Cleaner production N/A in classic process improvement meaning. Production

without hazardous chemicals yes.10. Remediation of contaminated sites Identification of PCB contaminated sites and policy advice11. Lead in gasoline N/A12. Sound agricultural practices N/A13. Persistent, bioaccumulative and toxic substances (PBTs); very

persistent and very bioaccumulative substances; chemicals that are carcinogens or mutagens or that adversely affect, inter alia, the reproductive, endocrine, immune or nervous systems; persistent organic pollutants (POPs)

Fully

14. Mercury and other chemicals of global concern; chemicals produced or used in high volumes; chemicals subject to wide dispersive uses; and other chemicals of concern at the national level

Yes, by targeting one particularly problematic substance. Further project increases government capacity to deal with high volume chemicals used in different sectors and sources.

15. Risk assessment, management and communication PCB exposure reduction, labelling contingency palnning16. Waste management (and minimization) Hazardous waste disposal17. Formulation of prevention and response measures to mitigate

environmental and health impacts of emergencies involving chemicals

PCB holder management plans including emergencies.

18. Research, monitoring and data Restricted soil and human exposure data for PCBs19. Hazard data generation and availability N/A20. Promotion of industry participation and responsibility Highly by PCB holders21. Information management and dissemination As a part of results dissemination and contact with other

regional PCB initiatives.22. Life cycle Included from possible imports to use, maintenance

disconnection and disposal23. Pollutant release and transfer register (PRTRs) – creation of

national and international registersNot systematically but in a restricted manner dealing with PCBs, tracking of equipment etc.

24. Education and training (public awareness) Education of government officials and PCB holders, workers as well as restricted public awareness raising on PCBs

25. Stakeholder participation Yes. Details in Prodoc section.26. Implementation of integrated national programmes for the

sound management of chemicals at the national level in a flexible manner

PCB management adapted to Moroccan context

27. International agreements Implementation of Stockholm Convention. Implementation of Basel Convention in export procedures.

28. Social and economic considerations Considered in project development and cost-effectiveness considerations.

29. Legal, policy and institutional aspects Creating a full-fledged PCB management legislation as legislative and process example for other

30. Liability and compensation N/A31. Stock-taking on progress Lessons learnt and their dissemination32. Protected areas N/A33. Prevention of illegal traffic in toxic and dangerous goods Creation of legislative rules for PCB export import and

enforcement training34. Trade and environment N/A35. Civil society and public interest non-governmental organization

(NGO) participationBy involvement in project steering and other outreach activities

36. Capacity-building to support national actions Over-arching objective to create capcity for continuing PCB and other hazardous chemicals management

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E. DESCRIBE THE INCREMENTAL REASONING OF THE PROJECT:

49. The project activities pertaining to strengthening of legislation and assisting in its implementation, equipment re-placement, education, awareness and disposal of pure PCB equipment are to a large degree incremental from a GEF perspective.

50. The POPs NIP requires Governmental departments, particularly MATEE, to develop and roll-out comprehensive legislation, prepare and disseminate information material for avoiding the release and exposure of PCB in industrial activities. However, there are no earmarked resources for this activity and it can be expected that the awareness raising activity among the key partners and handlers of PCBs would not be carried out without outside financing.

51. The updating and expansion of the PCB inventory and the analysis facility is a crucial follow-up activity to the initial PCB inventory compiled under the POPs Enabling activity project. Without this activity much of the information compiled in this project would not be benefiting future activities trying to avoid exposure and releases of PCBs.

52. It is somewhat difficult to establish a baseline scenario. A probable baseline scenario would be that an undetailed PCB regulation would be adopted, but without further technical specifications developed and even less integration into actual PCB management stages. This would leave companies to find their own best means of dealing with the matter, without access to expertise and training.

53. Some companies, like ONE, has already taken action on some of their PCB transformers and it can be expected that such responsible companies would find resources for continuing their activities in the baseline scenario, even if at a slower pace. It is practically impossible to estimate how much of PCBs would be treated in the baseline scenario. It should however be noted that it is not probable that any specific PCB handling training would be given to companies employees or employees of companies providing maintenance, decommissioning or transport services.

54. Due to these financial constrains, it can be assumed that in the baseline scenario, many of the PCB containing equipment would simply be dismantled and dumped in an unsafe manner, in many cases without understanding that they are containing dangerous material. This could lead to unsafe practices such as firing high concentration PCBs in various incinerators and burning devices.

55. Without the GEF-assisted project, some companies or waste and scrap recyclers would most probably drain the PCB equipment, recycle, incinerate or dilute the oils, and sell the casings as scrap metal. All these unsustainable practices would be performed by companies or individuals without proper knowledge of risks posed by PCBs and the possibilities for their mitigation. The result would be an increased human and environmental exposure of PCBs as well as dioxins and especially furans from improper incineration of PCBs.

56. It can also be expected that in the baseline scenario a high number of PCB containing equipment and waste will be left lying around at industrial sites. This would lead to deterioration of the transformer and capacitor casings with resulting leakages and release of PCBs in the environment. In short, the baseline scenario cannot guarantee that proper workers’ protection and environmental safety aspects are followed in decommissioning, transportation and disposal operations of PCB containing equipment and are therefore incremental. Further, the PCB containing equipment would not be replaced before release and risk situations may happen.


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http://gefweb.org/uploadedFiles/Documents/Council_Documents__(PDF_DOC)/GEF_31/C.31.12%20Operational%20Guidelines%20for%20Incremental%20Costs.pdf

Project Component Baseline GEF alternative Incremental costs

1. Legal and administrative capacity building.

Pillar I

1.No PCB framework law 2.No secondary legislation/guidelines covering PCBs.3. No environmental limit and quality standards for PCBs. 4. Some awareness has been achieved by the POPs EA project and other information campaigns.

A comprehensive fully consulted, accepted and integrated PCB legislation covering all stages in the PCB life-cycle.

Relevant information and educational material developed. This material being disseminated among governmental institutions as well as integrated in the educational curricula.

Personnel costs US$ 442,000PCB contamination and Cost benefit study:US$ 64,000Workshops:US$ 45,000Travel etc: US$ 47,000Incremental cost US$598,000Co-financing US$ 147,000

2. Technical Assistance for minimization of PCB releases.

Pillar I

No safety handling of PCB training conducted or PCB management plans developed, due to lack of regulatory coverage and resources for such.

NO further PCB identification as authorities lack the required knowledge and routines with resulting in PCB releases and exposure

Only a few companies checking the PCB concentration in their equipment. Authorities without proper enforcement possibilities

Oil recyclers not analyzing collected oils with resulting PCB recycling and release.

All major holders developed PCB management plans and PCB handling training conducted reducing PCB releases and exposure from PCB equipment still in use.

All PCB containing equipment identified and labeled, reducing risk situations and releasesPCB legislation enforceable by authorities.

Personnel costs US$ 222,000Workshops:US$ 20,000Informal sector outreach and laboratory analysis subcontracts: 40,750Travel etc: US$ 25,000PCB holders Labeling: US$ 20,000Incremental cost US$327,750Co-financing US$ 94,000


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Project Component Baseline GEF alternative Incremental costs

3. Technical assistance for export disposal of pure PCBs

Pillar I

Some PCB holders and a few transformer servicing companies take precautions for PCB exposure and releases during decommissioning, transport and storage.

Only some PCB containing equipment replaced due to lack of financial resources for replacement and adequate disposal.

Most PCB containing equipment would be left at site until PCB release occur.

All PCB holders and transformer servicing companies taken measures to reduce exposure and releases.

Swift and safe decommissioning, collection and disposal of PCB containing transformers leading to destruction of some 685 tons of pure PCB containing equipment.

Personnel costs US$259,200Technical upgrade at PC holders and servicing companies US$ 80,0003

Workshops and in-house training US$ 40,000Travel: US$ 10,000Sub-contracts for packaging , in-land transport and storage US$ 145,500Cost of replacement transformers US$ 3,862,000Subcontract for IMO packaging and international transportation US$ 466,000Sub-contract for disposal of Pure PCB transformer s and associated waste US$924,750Incremental cost: US$ 5,787,450Co-financing US$ 4,632,200

Outcome 4: Monitoring Learning Adaptive Feedback and Evaluation

No activity in the baseline scenario.

Efficient project monitoring and evaluation, guiding activities towards achieving outcomes

Personnel costs US$ 108,000M&E development: US 20,000M&E and lessons learnt workshops and related material US$ 30,000Travel US$ 10,000Incremental cost: US$ 168,000Co-financing US$ 27,000

Project management

No project with resulting environmental degradation

Efficient project implementation with resulting local and global environmental benefits

Personnel Costs: US$ 357,000Office, communication, travel and audit US$ 133,000Incremental cost: US$490,000Co-financing: US$ 273,000

Total incremental cost:US$ 7,371,200Co-financing of the incremental cost:US$ 5,173,200GEF US$2,198,000

3


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Objective and outcomes

Issue Risks and Assumptions Risk Management measures

Objective of the project is to enhance the capacity for safe management of PCB oils and PCB containing equipment at all stages of PCB management cycle.

Strengthened legal and administrative framework for PCBs.

Risk: Various and opposite views on safety may delay adoption of technical guidelines

The technical working groups will have broad participation in order to iron out differences in preparatory stage rather than at time of adoption.

Safe management of sources of PCBs at PCB holder and equipment service levels increased.

Risk: Delays in adoption of legal framework and specific guidance may hamper implementation

Keep PCB holders abreast with future requirements so they can plan for appropriate action even before guidelines adopted.

Environmentally sound replacement of PCB equipment

Risk: Public sector holders are dependent on budget allocations for replacement equipment

Risk Increasing metal prices and exchange rates may change price levels from calculated.

Project management (NPD and PM) will enter into discussions with funding sources (relevant national officials and local governments) on this issue.

Beyond Project control, if risk materializes co-financing requirement increase and quantities possible to dispose decrease.

Outcome 1. Strengthened legal,

policy and administrative

framework for PCB management and

disposal

PCB framework law, technical guidelines and administrative procedures adopted.

Risk: Without adoption of PCB law there is no urgency or incentive for the central administrative steps.

Risk: Various and opposite views on safety and precaution may delay adoption of technical guidelines

The ready PCB law draft has broad approval already and the final touches before adoption will be first priority when project implementation commences.

The technical working groups will have broad participation in order to iron out differences in preparatory stage rather than at time of adoption.

F. INDICATE RISKS, INCLUDING CLIMATE CHANGE RISKS, THAT MIGHT PREVENT THE PROJECT OBJECTIVE(S) FROM BEING ACHIEVED AND OUTLINE RISK MANAGEMENT MEASURES:


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Issue Risks and Assumptions Risk Management measures

Outcome 2: Safe PCB management at PCB holder level introduced and further PCB sources identification

PCB exposure and releases during maintenance and handling in absence of PCB holder developed PCB management plans.

Risk: Potential PCB holders not willing to identify possible PCBs in their possession, and therefore not participate.

Ensure that such requirement is legally binding and give appropriate technical guidance on how to develop PCB management plans. Include checking of plans in enforcement of environmental permits.

Outcome 3. Environmentally sound replacement and disposal of pure PCBs in participating industries.

Overall volume of PCB equipment decommissioned and disposed not reached.

Risk: increase in transformer prices may reduce interest to replace before mandatory deadlines.

Beyond Project control, if risk materializes co-financing requirement increase and quantities possible to dispose decrease.

Human and environmental exposure to PCBs during handling.

Risk: without proper practices and risk reduction measures pure PCBs will be released during transformer draining and other handling stages.

Training and assistance to PCB holders in setting-up PCB spillage, containment and emergency procedures including clean up procedures, isolation of areas and containment, emergency communication procedures, notification of authorities established under project activity 2.1.2.

Training and assistance to PCB holders, PCB waste management companies and officials in safe dismantling and on-site storage of decommissioned PCB containing equipment.3.1.1.


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G. EXPLAIN HOW COST-EFFECTIVENESS IS REFLECTED IN THE PROJECT DESIGN: 57. Safety and cost-effectiveness has been the guiding principles in designing the activities related disposal of

the identified pure PCB containing equipment and waste. The reason for deciding of not pursuing local disposal of this waste stream was based on the economic calculations, showing the unfeasibility of establishing disposal capacity for pure PCBs in Morocco. In these calculations also safety concerns played a role particularly considering the definite and not too large overall waste stream of pure PCB in the country. It was not considered cost-effective to established very stringent safety and environmental monitoring procedures for disposal of pure PCBs in the country and consequently the export option for pure PCBs was pursued.

58. Overall the disposal cost 685 tons of PCB containing equipment for a price US$ 1.4 million, resulting in a kilo price of US$ 2.1 per kg (GEF contribution US$ 1.4 /kg). Due to the somewhat longer transports the overall disposal cost is higher than for GEF projects in Central and Eastern Europe where disposal bids around US$ 1 per kg including shipping can be achieved. However, the price is considerably lower than operational costs of dedicated PCB disposal facilities for pure PCB oils.

59. The project management component has been slimmed down to a minimum in order to design a cost effective project, still ensuring timely delivery and early achievement of the of the environmental and health benefits of the project.


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PART III: INSTITUTIONAL COORDINATION AND SUPPORTA. PROJECT IMPLEMENTATION ARRANGEMENT: 60. The project will be executed and implemented through The Ministry of Territory Development, Water and

the Environment (MATEE). The actual project components will be directly implemented under the realm of Directorate for Environmental Monitoring and Prevention of Environmental Risks, DSPR, of MATEE. Though the responsibility for execution lies with MATEE several project components will be implemented in close cooperation with other Ministries. Indeed the project success and sustainability relies heavily on a close cooperation between a number of ministries and institutions as well as private sector partners.

61. Of the Ministries the cooperation will be particularly close with Ministry of Industries for cooperation on PCB identification and control of safe practices with PCB equipment still in use and various stages between decommissioning and final disposal.

62. The Ministry of Finance, Customs Department, will also be a key Department in ensuring that PCB equipment are identified if such would be subject to importation to Morocco either as new or in second hand equipment.

63. Ministry of Education will also be a partner for certain project activities aiming at integrating PCB (and PTPs) issues more widely in the in the educational curricula.

64. Overall, the management arrangement of this project is aiming at supporting the long-term needs for managing PCBs in Morocco and creating a solid and sustainable foundation for sound PCB management. Hence the project management arrangements are sub-ordinated the PCB management Committee as proposed to be established in the PCB framework regulation as shown in the schematic picture below.

65. The PCB regulation envisages Ministry of Territory Development, Water and the Environment as the organizing and preparatory institution for implementing the PCB regulation. Consequently MATEE will coordinate the project and chair the Project Steering Committee which in the short-term will provide the technical support for the Regulation while gradually shifting the responsibility toward the permanent government structures.


PCB Committee as established in PCB regulation

UNDP Project Steering Committee National Project Director

MATEE

Project Implementation UnitProject manager , assistant

Outcome 1. Project experts, government experts, stakeholder experts

Outcome 2. Project experts, government experts, stakeholder experts

Outcome2 . Individual experts Outcome 3. Project experts, government

experts, stakeholder experts

Monitoring and evaluation

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66. The Project Steering Committee will have representation from other ministries relevant to different project activities such as Ministry of Industry, Ministry of Interior, Ministry of Equipment and Transports, Ministry of Energy and Mining and Ministry of Health.

67. The PSC will be further strengthened by representatives of key industrial stakeholder as major contributors of the project as well as representatives from civil society organizations particularly involved in hazardous waste and chemical safety issues.

68. The PSC will further be strengthened by representatives of independent technical experts. The access to these experts can be ensured by including AMEDE (Association Marocaine des Expert en Gestion des Dechets et en Environnement) in the steering structure of the project.

PART IV: EXPLAIN THE ALIGNMENT OF PROJECT DESIGN WITH THE ORIGINAL PIF:

PART V: AGENCY(IES) CERTIFICATIONThis request has been prepared in accordance with GEF policies and procedures and meets the GEF criteria for CEO Endorsement.

John HoughDeputy Executive Coordinator, aiUNDP-GEFGEF Agency Coordinator

Project Contact Person Dr. Suely Carvalho, PTA Chemicals

Date: 5 Mar 2008 Tel. and Email:[email protected]


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ANNEX A: PROJECT RESULTS FRAMEWORKLogical Framework and Objectively Verifiable Impact Indicators

Project Strategy Objectively verifiable indicators

Goal

The Goal of the project is to protect human health and deterioration of the environmental quality by avoiding human and environmental exposure of PCB oils and PCB contaminated oils, particularly in industrial sized equipment. Despite their technical benefits, PCBs are known to have deleterious effects on human health and the environment. Further PCBs are bio-accumulative and prone for long range global transport . Consequently PCBs are listed as POPs slated for elimination in the Stockholm Convention. While Morocco is committed to eliminate PCBs the elimination needs to happen in a controlled manner and by minimizing releases of and exposure to the chemicals at all stages. This constitutes the goal of the project.

Indicator Baseline Target Sources of verification Risks and Assumptions

Objective of the project is to enhance the capacity for safe management of PCB oils and PCB containing equipment at all stages of PCB management cycle.

Strengthened legal and administrative framework for PCBs.

1.PCB framework law discussed2.No legislation/guidelines covering PCBs before considered waste.

1.Adoption of framework law 2. Adoption of 5 binding technical guidelines on different stages of PCB management.Adoption of 3 environmental quality guidelines

1.Government Gazzette2.Orders of relevant ministers responsible for various aspects and stages of PCB cycle

Assumption: legislation considered a priority also for new government (parliament).Risk: Various and opposite views on safety may delay adoption of technical guidelines

Safe management of sources of PCBs at PCB holder and equipment service levels increased.

1.Major companies sensitized but not systematically adopting PCB exposure minimization measures2. Government institutions not actively controlling PCB management and movement.

1. All major holders/handlers have developed PCB management plans. Target 25 plans.2. All industrial and customs inspections report on PCB issues. Target: 300 inspections3. Suspected equipment and oil samples analyzed. Target: 200

1. Documentation submitted as per mandatory reporting to Ministry of Environment.2. Inspection reports at relevant ministries.3. Project documentation pertaining to PCB analysis fund.

Assumption: PCB law will require submission of PCB management plans by holder/handler.

Risk: Delays in adoption of legal framework and specific guidance may hamper implementation

Environmentally sound replacement of PCB equipment

1. Some PCB holders have undertaken PCB dismantling and disposal operations.

2. Replacement hampered by high prices of replacement equipment and disposal

1.All PCB holder have introduced/ reviewed their PCB decommissioning, transport and replacement procedures. Target 20

2. 211 transformers replaced and disposed

1. To be developed as a part of project monitoring and evaluation. e.g. follow-up to trainings.

2. Procurement receipts and disposal certificates.

Assumption: External trade commitments will decrease transformer prices.Risk: Public sector holders are dependent on budget allocations for replacement equipment

Risk Increasing metal prices and exchange rates may change price levels from calculated.


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Outcome 1. Strengthened legal, policy

and administrative framework for

PCB management and disposal

1. PCB framework law adopted.

2. Project facilitated discussions, lobbying and workshops for facilitating final adoption.

3. Number of Ministries, PCB holders and NGOs taken administrative steps to operationalize PCB framework law.

4. Number of PCB sub-regulation, binding guidelines covering all stages of PCB management enacted.

5. Raised knowledge level and awareness of PCB risks within administration, particularly provincial.

1.Interministerial discussions on PCB framework law conducted.

2. Project preparatory stage developed drafts for discussion and held 2 workshops.

3. No preparations done in anticipation of PCB legislation.

4. No legislation/guidelines covering PCBs before considered waste. NO specific PCB waste rules.

5. Some knowledge and awareness created in central government.

1. Adoption of the PCB framework law within year 2008.

2. 2 additional workshops and 3 smaller information meetings held with ministries and key decision makers.

3. Most concerned ministries and departments taken administrative action, such as designing responsible officers, introduction of PCBs in reporting schemes etc Target: 4

4. Adoption of 5 binding technical guidelines on different stages of PCB management.Adoption of 3 environmental quality guidelines.

5. Provincial workshops organized.

Target : 4 workshops

1.Government Gazette.

2. Workshop attendance lists and notes on meetings from project documentation.

3. Internal administrative orders in ministries. Ministerial reporting sheets and forms.

4. Orders of relevant ministers responsible for various aspects and stages of PCB cycle.

5. Workshop attendance lists from project documentation.

Assumption: legislation considered a priority also for new government (parliament).

Risk: Without adoption of PCB law there is no urgency or incentive for the central administrative steps. Assumed: Appropriate technical knowledge at ministries to organize administrative response to law.Risk: Various and opposite views on safety may delay adoption of technical guidelines


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Outcome 2: Safe management of identified sources of PCB at PCB holder level and further identification PCB sources and equipment.

1.PCB exposure and releases during maintenance and handling.

2. Number of PCB holder developed PCB management plans.

3. Number of contacts with informal sector on PCB recycling.

4. Number of institutions and personnel able to identify PCB sources and integrate it

5. Number of NGO/CBO led PCB educational sessions for informal sector actors.

6. The number inhabi-tants dwelling in vicinity of PCB equipment or other sources:

1. Some companies sensitized to PCBs. Not many concrete steps taken.

2. No systematic PCB management plans, some partial investigations, risk reduction steps undertaken.

3. No reports/knowledge of PCB use in the informal sector

4.1. Central government and some private sector personnel received PCB identification training.3.2.

4.2.No PCB checks by customs at equipment entry in country

5. No NGO/CBO led PCB activities

6.Baseline to be determined during setting-up of project M&E system

1. All known PCB holders sensitized o steps for minimizing PCB exposure. Target :25 companies.

2. All known PCB holders drafted PCB management plans.Target :25

3. NGO/CBO lead information and outreach. Target 3 cities and 150 contacts.

4.1. All relevant personnel received training. Target.300 trainees

4.2. All industrial and customs inspections report on PCB issues. Target: 300 inspections

5.15 educational sessions for informal sector in PCB risk and avoidance of exposure

6.To be determined during setting-up of baseline.


2. Documentation sub-mitted as per mandatory reporting to Ministry of Environment.

3. Project reports submitted by NGO/CBO.

4.1. Workshop attendance lists from project documentation.

4.2. Inspection reports at relevant ministries.

5. Project documents. Report from completed sub-contract.

6. Project M&E documentation and calculations of exposed people before and after removal of PCBs

Assumption: Learnt reduction minimization put in practice.

Assumption: PCB law will require submission of PCB management plans by holder/handler.

Assumption: part of PCB oils are recycled/used by informal sector.

Risk Potential: PCB holders not willing to identify possible PCBs in their pos-session, and therefore not participate.

Risk. Number of potential PCB equipment entries at some border points low so that the PCB issue is not properly taken up in the routines.

Assumption: Informal sector oil recycling wide spread

Assumption: existence of intact PCB equipment can be reflected in a risk calculation.


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Outcome 3. Pure PCB containing equipment in participating industries disposed.

1.PCB exposure and releases during maintenance and handling.

2. Number of non-replacement committed PCB holders engaged in initial steps of PCB replacement.

3. Number of PCB equipment decommissioned and disposed.

4. Volume (tonnage) of PCB equipment disposed.

1. Some companies sensitized to PCBs. Not many concrete steps taken.

2.1. 21 out of 43 companies engaged.

2.2. Unawareness and replacement equipment prices known reasons for resistance for replacement.

3. Some companies have performed restricted PCB disposal activities. Exact figures not known.

4. Some companies have performed restricted PCB disposal activities. Exact figures not known.

1. All companies participating in the project driven PCB replacements trained and upgrade their dismantling, storage and transportation practices minimizing PCB. Target: 21 PCB holders and 5 service companies.

2.1. 40 companies taken action for replacing PCB equipment.

2.2 Financial incentives in government policies for PCB replacement.

3. Target 211 transformers disposed.

4.1 446 tons of equipment with 148 tons of pure PCB oils disposed

4.2 239 tons of Government sponsored additional PCB equipment disposed


2.1 Project documentation on company contacts and visits. Documentation from PCB service companies and transformer vendors.

2.2. Government published policy/fiscal documentation.

3-4. Report from participating industries and waste collecting sub-contractor.

3-5. Certification of Disposal from final disposal installation

Assumption Price level of transformers hampers replacement.Risk: increase in transformer prices may reduce interest to replace before mandatory deadlines.

Assumption: Free-trade agreements will decrease customs duties on transformers

Assumption: disposal prices remains at calculated levels. Risk exchange rate risk US$ budget and € prices for closest disposal companies.


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ANNEX B: RESPONSES TO PROJECT REVIEWS (from GEF Secretariat and GEF Agencies, and Responses to Comments from Council at work program inclusion and the Convention Secretariat and STAP at PIF)

Comment at Council review November 2007:

France: The PIF should be precise on how the PCB will be disposed.

IA response: The project will dispose pure PCBs and PCB contaminated porous material from transformer carcasses through exports, while PCB contaminated mineral oil and PCB contaminated metals from electrical equipment will be decontaminated within Morocco using the decontamination facilities established under Pillar II of the PCB management in Morocco project.

For export disposal, the least expensive and technically safe disposal option will be chosen. This will be determined through competitive bidding as per UNDP rules in force. In practice this will mean an open solicitation of bids from reputable companies, eg. companies published in UNEP publications on Worldwide PCB destruction capacity, which will be judged for their technical solidness and safety during transport and disposal. The judgment will be done by a review committee comprising of national and international experts, representatives of the Government of Morocco and UNDP using pre-determined selection criteria.. As per rules, the least expensive technically responsive bidder will be contracted. In practice this will be a hazardous waste disposal facility in an OECD country as UNDP has not identified safe PCB disposal facilities in non-OECD countries.

It is foreseen that all pure or high concentration PCB oils and PCB contaminated porous material will be exported. For transformer carcasses, it is envisaged to dismantle and to decontaminate the metallic components in the disposal facility established under Pillar II. The easiness of cleaning the metallic components and residual value recovered through the recycling of the metals (copper and steel), ensure that the within the country decontamination of the metals would be a more economical option.

UNEP comments on the UNDP/UNIDO PIF ‘Safe management and disposal of PCBs in Morocco’ (FSP) at submission of PIF November 2007

UNEP comments IA response

Morocco has one of the largest populations of electrical equipment in the region and so an early start on PCB elimination is important. Unfortunately, this project seems to have a number of weaknesses that need to be addressed.The proposal makes little or no reference to the POPs National Implementation Plan and provides no data from it. As PCBs are the highest priority set out in the NIP, it would have been useful to include in Part II (A) a summary of NIP inventory data to illustrate the scale and character of the PCB problems that need to be addressed.

The preparatory stage of the project has updated the NIP inventories. The current situation can be found in the baseline sections in respective pillars.The NIP for Morocco, as in for other countries, did not include a significant source of PCBs, as that encounter in mineral oil filled transformers. Post NIP Studies have demonstrated that it is the case in developed countries (Europe and North America) PCB contaminated mineral oil is a significant problem in Morocco. The Project Document includes results of a recent study conducted on electrical transformers in Morocco that confirms this premise.

Similarly, Part II A provides information on neither the character of the electrical supply industry in Morocco nor the number and character of private sector stakeholders that need to be addressed: Is the proposal designed to deal with a single private

The baseline section of Pillar I gives an overview of the electrical supply and consumption in Morocco. The project targets all PCB holders, some of which are utilities, other are industries and small installations of different character in ownership of their transformer. List


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national utility or are activities and costs based on the need to address a large number of private sector PCB owners?

for targeted pure PCB equipment can be found in Annex II of Pillar I project document. The owners of electrical transformers includes the electrical utilities (generation, transmission and distribution), as well as industrial and institutional users of electricity. Pillar II will deal with all sectors in Morocco where PCB-contaminated transformers may be found.

Furthermore, the proposal makes no mention of techniques that are already or may soon be available in Morocco for the treatment of PCBs. We understand, for example, that a major international company specialising in the dechlorination of PCB oils and decontamination of equipment is already operational in Morocco. Furthermore, we understand that a major cement producer is examining the suitability of its most modern plant to burn mixed fuels including hazardous wastes such as PCBs. These are material to the project, influence its design and management as well as its budget and incremental cost calculation.

During the preparation stage the project team visited a number of companies including electrical and services companies. In every instant, it was indicated that the market in Morocco was not ready for the establishment of this type of services. The proposed project, aware of this reality, is proposing to establish the conditions for such service companies can bring these technologies to Moroc-co. The document included a study of the major non-combustion technologies currently in use in the world for the treatment of PCB contaminated oil.

Moreover, a major cement producer in Morocco was visited, who shared results for PCB incineration tests conducted in similar facilities in other countries. The owner indicated that the facility was prohibited to mix fuel with PCBs or other chlorinated toxic materials. This was subsequently confirmed by representatives of the Moroccan Ministry of the Environment.

A GEF-supported project that did not take advantage of such locally-available facilities would need to build strong arguments for not doing so and could be seen to be in competition with and damaging the business rationale for private, commercial investments in environmentally valid technologies.

As outlined above, the preparatory phase revealed that the disposal market in Morocco is not ready for the establishment of locally-available facilities to treat PCB-contaminated equipment. The proposed project will therefore support Morocco in building necessary in-country capacity to meet its obligations under the Stockholm Convention. More details are provided in the project document.

The proposal makes only a single passing reference to the UNEP regional project ‘Demonstration of a Regional Approach to Environmentally Sound Management of PCB Liquid Wastes and Transformers and Capacitors Containing PCBs’ in which Morocco also participates. It is clear that, if both projects are to proceed, then more detailed and close working relations need to be determined. The statement, in Part II D, that Phase II of the project will tie close contacts with the UNEP-led regional project is too limited as proposed components in Phase I are also similar to components of the UNEP project.

Without details of the UNEP regional project, detailed linkages are difficult to develop. However, the linkages section in CEO endorsement documentation provides information in this regard.

As the Moroccan government is overseeing the implementation process of the UNIDO/UNDP as well as the UNEP projects, it will ensure that any duplication of work will be avoided once detailed information of the UNEP regional project is available.

Part II A (third paragraph) notes that while Phase I of the project is planning to destroy 224t of PCBs in 667t of equipment only about 50% of this amount may be readily available for treatment. The rest is described as ‘unaccounted for’. If this material is not available, it represents a significant threat to the effectiveness of the project and should be described in the risk table of Part II F. How will it be accounted for?

The wording “unaccounted for” is poorly chosen, but refers to equipment that have no private sector owner, are either abandoned or are in ownership of the various government institutions, such as armed forces and civil aviation organizations. These PCB sources will be disposed by government cash co-financing in cooperation with GEF.

We note also, from the Project Framework table, that while the export of the 224t of PCB oils is to be done in Phase 1, the (empty) equipment will only

Main storage for untreated transformer carcasses will be within Pillar II facility. Pillar I will have temporary storage facilities for empty transformers either at holder


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be treated in Phase II. There is no implementation plan at this stage of project development but it seems that Phase I will result in the storage of contaminated equipment for some time awaiting treatment in Phase II. In addition to the surface-contaminated metal parts that might be treatable in the facility planned for Phase II, this PCB equipment will also contain highly contaminated porous elements that will not be amenable to local treatment and will need to be exported for destruction. There seems no provision for this in the current proposal.

level or at port. Ensuring their safety is included in project activities. Any non-metallic parts from dismantled are to be exported for disposal.

Component 3 of the project, essentially to deal with 667 t total weight of equipment and the export-led destruction of 224t of PCB oils, has a total cost of $5.8M. This represents a cost of $8,826 t-1 of equipment treated or $26,280 t-1 of oil. In addition, there are, presumably, additional treatment costs for the surface-contaminated metal parts in Phase II. These figures are significantly higher than the quoted disposal costs set out in Part II G and need better justification and explanation.

Also cost for replacement for new equipment is included in project component 3. The actual export-led disposal of all associated PCB contaminated waste is budgeted at US$ 2,100 per ton including packing, transport and disposal.

We can find no mention of capacitors that may be PCB filled and that would, presumably, be shipped intact for destruction.

The number of capacitors with PCB identified is 394 units, of varying dimensions, weight and capacity. The total weight of the capacitors is approximately 8,8 tons and the PCB content is approximately 2,5 tons. Shipping intact for disposal is envisaged.

We understand from the Morocco PCB inventory that only limited analytical testing of transformer oils has been done. The very limited tests show that about 60% of the mineral oil transformers tested were PCB contaminated (PCB > 50ppm). It is not clear whether these very limited results are representative of the transformer population as a whole but is so, some 18,000 transformers of the estimated 30,000 population will need decontamination. While each transformer may contain only a small quantity of PCBs, the total population to be treated makes this a significant element of the project.

In addition to the analytical work done prior to the preparation of the proposed project, random sampling of over 100 additional transformers confirmed the original finding that more than 20% of the transformers tested contained PCBs over 50 ppm. Moreover, a significant number of those transformers contain PCBs over 100,000 ppm. It can be concluded that the PCB level is too low for the transformers to have been built as PCB transformers and too high to have been accidentally contaminated. Therefore, the retrofilling of mineral oil transformers with pure PCBs can be considered as a common practice in Morocco.Discussions with electrical utilities representatives suggest that the total number of transformers (transmission and distribution) is in the order of 100,000 units. The estimate of PCB contamination is based on historical data and the study conducted under the proposed project.

Contamination can result in a number of ways: oil mixing during servicing and maintenance; retrofilling of PCB transformers with mineral oils, purchase and filling of mislabelled ‘2nd hand equipment’ said to be PCB-free, and so on. Management systems need to be put in place early in the project to ensure (a) that further contamination is prevented; and (b) that contaminated transformers are not sold for metal reclamation. Both result in continuing PCB releases and increasing costs of treatment. It is, therefore, disappointing that this work is relegated to an essentially separate Phase II of the project and not dealt with earlier and better integrated with the

Pillar I and II will be implemented simultaneously. Drained transformer carcasses from Pillar I will be stored and decontaminated under Pillar II. Porous material collected from the PCB transformers will be shipped to European incinerators.


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management elements of Components 1 and 2.Is the output for component 4a strictly necessary? There have been many studies of available techniques. The approach could rather be the careful determination of a technical specification followed by a call for commercial offers for treatment meeting Convention (both Stockholm and Basel) standards.

Agreed and changed in the project document.

How does output 1 of Component 4b relate to the outputs of Component 2?

The requirements and system of managing PCB contaminated equipment will be developed and rolled out (disseminated, trained) for PCB holders in component 2 while component 4 will in continue the support ensuring the proper operation of the systems at company level

Output 3 (2?) of Component 4b provides for the installation of a destruction technology to PCB containing equipment and related PCB wastes. Is this intended only for ‘low-level’ wastes arising from the cross-contaminated equipment? How will it deal with wastes arising from Component 3 (output 4)?

The proposed project Pillar II focuses in mineral oil transformers contaminated with PCBs. It has been generally understood that the reference to low level means PCB below the 10,000 ppm. The dechlorination system currently in use in other jurisdictions are able to destroy pure PCBs or other POPs. Pure PCBs and porous material from PCB transformers will not be decontaminated in Morocco, these wastes will be shipped to dedicated facilities abroad. If the frequency of finding high concentration contaminated PCBs transformers is high, it is expected that the selected technology provider may opt for the installation of a reagent preparation to reduce its costs.

Part II E provides little argument related to incremental costs. We might expect that the holders of larger amounts of electrical equipment, such as transformers and capacitors, include sums for replacement, maintenance and servicing in annual capital investment and operational plans. Bearing in mind the potential high rate of cross-contamination, such costs represent a baseline against which the GEF increment can be assessed

Please refer to incremental cost section in the documentation. Some replacement is taking place and is consequently baseline however the waste targeted is replaced at an accelerated pace, thanks to project intervention and is hence incremental.

The second paragraph of Part II E is undoubtedly true but its meaning here under incremental reasoning is not clear. The proposal notes the role played by the metal reclamation industry in the uncontrolled release of PCBs but provides no activities related to them. Are they to be excluded from this lucrative business in future? If not, how will they be educated or engaged to ensure PCB releases are minimised or, better still, eliminated? The sale of transformers for metal reclamation of metals represents income for many enterprises and offsets equipment replacement costs. How is income from copper and ferrous metal recovery factored into the budget and incremental cost reasoning?

The participating companies are giving the PCB equipment in their entirety to the project. This has not been calculated as co-financing, though it could undoubtly be done. For Pillar 1 the metal price will reduce the disposal costs, ie. the price paid cash for disposal. For Pillar 2 the metal price will subsidize the de-chlorination cost. Metal reclamation industry will need to concentrate on non-PCB containing/contaminated equipment in future in Morocco, which can be considered a great risk reduction measure as it will reduce untrained/unprotected handling of PCBs.

World Bank comments on the UNDP/UNIDO PIF ‘Safe management and disposal of PCBs in Morocco’ (FSP) at submission of PIF November 2007

World Bank comments IA response

Cost-effectiveness/economic justification. We have fundamental concerns about the cost-effectiveness/economic justification for component 4

The document has been modified to better explain the business case. Private Sector will invest its own capital for the establishment of the proposed


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i.e. the proposal to build "a local facility for decontamination" with the private sector at a cost of around US$4.5-5.0 million. Using the figure cited in the PIF of US$2,500/ton, Morocco could export 2,000 tonnes of PCB oils and contaminated equipment for disposal and yet it is indicated that there are only 443 tons of equipment to dispose of. In addition, there are technical questions about where and how the facility will be located/tested/certified/etc? What will it be used for after the PCBs have all gone?

PCB services in Morocco. The Project will provide the selected Technology Vendor with a contract to decontaminate 3,000 metric tonnes of PCB contaminated mineral oil. The estimated balance of PCB contaminated transformers in Morocco and the potential application of the dechlorination system to other obsolete POPs would provide additional business opportunities to the selected Technology Vendor

Realism of cofinancing estimates. The PIF indicates that over US$6 million will be provided as a grant by the private sector. No information is provided to indicate how this large amount of funding will be raised or managed, or to justify that it is a realistic goal.

The co-financing appears realistic as for Pillar I the confirmed co-financing amounts to US$ 5.3million. For pillar II, the Private Sector will invest its own capital to establish the proposed PCB services in Morocco as indicated in the document. Investment estimates for the different components has been included.For details please consult the two CEO Endorsement Forms and the project documents

Coordination with other related initiatives. While there is no material conflict with the activities of the on-going GEF funded African Stockpiles project in Morocco, we are surprised that no mention is made of it and we are aware of no coordination efforts so far.

UNDP is not part of the African Stockpiles Programme, and was not requested by Government of Morocco to seek integration with ASP for this initiative. However, cooperation with the African Stockpiles Programme will be explored during the project implementation. Possible areas of mutual interest may be reduction of POPs exposure through awareness and educational efforts as well as in tendering and transporting POPs waste from Morocco as many final disposal operators accept both pure PCBs and POPs pesticides and associated contaminated materials.

As pillar II seeks to establish national capacity for the dechlorination of PCB-contaminated equipment, possible links could be established to the ASP in the future in terms of treatment of POPs pesticides, depending on the selected technology option. Moreover, during the planned updating of the PCB inventories in pillar II, any occurrence of POPs pesticides will be shared with the ASP national/regional implementation team.

In addition, we are puzzled as to whether this PIF is for a freestanding project, or if it relates to or overlaps in some way with the PCB initiative discussed under Component 2 of the UNEP proposed Regional Component of the Strategic Partnership for the Mediterranean Sea Large Marine Ecosystem which was approved for Work Program entry in June 2007.

The PIF, and the project is a free-standing initiative to minimize risks from PCBs in Morocco. While it does contribute positively to minimizing releases to Mediterranean ecosystems, it does not primarily focus on the region targeted by Strategic Partnership for the Mediterranean Sea Large Marine Ecosystem programme. Further the PCB component, activity 2.3; in UNEP’s regional project is implementing action in Albania, Egypt, Lebanon, Libya And Syria. Consequently, no duplication of effort is proposed.


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Response to Review by GEF Secretariat at submission of PIF October 2007

Country/Region: MoroccoProject Title: Safe management and disposal of PCBsGEFSEC Project ID: 3082GEF Agencies: UNDP, UNIDO

--------------------------------------------------------------------------------------------------------------------------------------------6. Will the project deliver tangible global environmental benefits?

The project aims to dispose of 224 tons of pure PCB oils and to treat 443 tons of contaminated equipment.

These amounts (224 of pure PCB oils and 443 tons of associated contaminated equipment) will be disposed within activities included in Pillar 1 of the project. Additional, and considerably higher quantities, of PCB contaminated oils and equipment will be disposed within Pillar II (see also point 11. Cost –effectiveness)

8. At the time of concept pipeline entry discussion, gefsec noted that it seemed premature to emphasise local disposal options when little seemed to be known about the PCB inventory – in spite of the NIP work. After 18months and $340K of project preparation, the PIF still provides no data that would justify setting up a local facility. Moreover, the scope of such a facility is very ambiguous, described in some parts of the document as dealing with decontamination of PCB containing oils, and in other parts as suitable to destroy PCB containing equipment.

Unless strong justification can be made for this investment, gefsec recommends at this point dropping pillar 2 which seems ill-defined, with the open possibility to submit a PIF later on if the case can be made. – Pls also see WB comments.

For Pillar I: The pure PCB oils have always been planned to be exported for disposal with a preference to treat the metallic parts in country.

After further discussions with the GEFSEC over the phone, it was found preferable to keep the PIF as one entity rather than splitting them up. To address the above concern however, Pillar II on disposal of contaminated oils is revised to explore possibilities “for decontamination and treatment of PCB contaminated equipment” including options of treating the waste (or parts of the waste stream) in Morocco or abroad. Pillar II will further implement the most technically adept and cost- effective option, for a waste quantity estimated at time of submission.

Otherwise, as in most of these documents, we lack a clear presentation of amounts of PCBs present in the country; what portion of it is to be addressed by the project; and assurances that mechanisms will be in place to ensure sustainability.

As the preparatory stage has already commenced for this project is can be noted that pure PCB equipment identified in Morocco stand at 667 tons. Consequently the project aims at disposing all known pure PCBs, provided that detailed budget calculation and co-financing commitments will allow for this.

The figures for contaminated equipment are not known in detail. For contaminated equipment the situation will be further investigated during the ongoing PDF (PPG) stage and estimations, as well as the share of the waste to be treated will be presented at stage of submission.

The project framework needs to be harmonized with the description provided in the text in particular for:- Project component 1: It appears that the legal/regulatory framework for PCB management already exists and only needs to be strengthened. This contradicts what is said in para 2 of B; (the project will create a full regulatory structure for PCB…)


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- Project component 4: The construction of a local facility for the decontamination of PCB contaminated transformers (which is a questionable option) should be mentioned very clearly as an expected outcome if the case for keeping it can be made.

Revised. Only PCB legislation in place in Morocco is the mentioning of PCBs in the list of hazardous waste. Hence the project initiated “strengthening” from virtually zero baseline will in practice be to create a full legislative system.

Why do “environmental; and food limit values” need to be developed? – surely these can be taken off the shelves?

The idea is not to measure PCB values in food items but rather set legal quality limit values for critical exposure paths such as consumption of fish and lipid food items. It is further not envisaged that toxicological testing would be performed for determining Acceptable Daily Intake but rather consider limit values proposed and adopted by Codex Alimentrius, EU, and other OECD countries, for local circumstances.

11. Is the proposed project likely to be cost-effective?

Concerning the elimination of pure PCB, the cost estimated at $2,500 per ton is in the range of similar projects.

Regarding the decontamination component (component 4), building a local facility for the treatment of 443 tons of contaminated equipment at a cost around $ 4.0 million does not seem to be cost-effective (this corresponds to a cost of $ 9,000 per ton compared to $ 2,500 per ton if the operation is undertaken abroad).

Component 4. Is envisaged to treat considerably more waste, both oils and equipment, that the 443 tons of equipment that will be made available from Pillar I in case a local treatment facility will be constructed. Indeed, the price per ton treated in a local treatment facility can be expected to be considerably less than US$ 2,500. Detailed calculations will be made available if this options is pursued after full option screening.

15. Is the value-added of GEF involvement in the project clearly demonstrated through incremental reasoning?

The section on incremental reasoning describes the dire consequences of no project, but does not describe adequately what baseline activities would take place, on which the project relies.

Revised to reflect the possible scenarios based on anecdotal evidence on already conducted PCB disposal and retrofilling of transformers.

19. Is the indicative co-financing adequate for the project?

One would like to see some information as to how the large amounts expected from the private sector will be raised.

For Pillar I. private sector contribution will be approximately US$ 4 million mainly in form of replacement equipment

What is the logic for the co-financing ratio being lower in comp 4 than comp 3?

The investigation into pure PCB equipment has been largely finalized and the equipment holders have shown a considerable interest demonstrated by co-financing commitments. Component 4 , Pillar II, the final co-financing ratio will be determined at the time of proposal submission.


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One would expect comp 1 that deals with legal and administrative aspects to be co-financed by the GoM at a higher level than present.

Noted further discussions with Government of Morocco will be conducted to increase this share. This will be reflected in the FSP to be submitted.

Response to Review by GEF Secretariat at CEO submission May 2008

Both project pillars: Apparent overlap between activities related to laboratory strengthening and analysis under pillars I and II.

Actual laboratory strengthening will be included in Pillar II. Pillar I will retain a budget allocation for subcontracting laboratory analysis.

The second concern is with the not very well defined character of pillar II. Basically, as I read this, it reads a lot more like an old style project brief for work program approval, rather than a project document for CEO endorsement. It gives the reader a reasonably good idea of what is going to be accomplished, but absolutely not in the details expected at CEO endorsement ? The Who? Where? When? are crucially missing. The analysis of the chosen project design and alternatives is only outlined, and/or unconvincing.

Agreed and reflected in the revised project document being submitted on 19 July 2008 as well as CEO Endorsement Form.

Linkages with related initiatives need strengthening (UNEP regional; GTZ/KfW; ASP). There are also issues of apparent inconsistencies in the documentation.

Agreed. See specific comments below.

As pillar II seeks to establish national capacity for the dechlorination of PCB-contaminated equipment, possible links could be established to the ASP in the future in terms of treatment of POPs pesticides, depending on the selected technology option. Moreover, during the planned updating of the PCB inventories in pillar II, any occurrence of POPs pesticides will be shared with the ASP national/regional implementation team.

UNDP pillar:

UNDP request for CEO endorsement

Project was approved by Council in Nov 2007 ? not Apr 2008. GEF Agency approval needs to be updated. Maybe July would be realistic.

CEO Doc has been corrected. GEF Agency Approval set for September 2008.

Are you sure you can achieve this and push $2.2m through the system in 3 years?

This should not be a major problem. Our experience in implementing the Enabling Activity (NIP) in Morocco has been remarkably good.

Links between Pillar I and pillar II:

There seems to be high opportunity for overlap between activities related to laboratory strengthening carried out under Pillar I, and those proposed to be carried out under pillar II.

Actual laboratory strengthening will be included in Pillar II. Pillar I will retain a budget allocation for subcontracting laboratory analysis.

Table B Co-financing estimated at PIF is $4952K ? not 1282K. US$ 4,951,950 is correctTable C. Shows ?grant? for PCB owners. Is this correct? The

private sector will provide a cash ?grant? contribution to the project?

The private sector will directly purchase replacement equipment and related costs for installing and decommissioning. While this requires cash input, this cash will not enter UNDP accounts and will be marked in-kind.

Table E. Project management.

I can not find the justification for ?travel? and ?office space etc? under project management.

Justification provided

Project management is about 10% of GEF project grant, but about 1% of the co-financing. Project management is expected to be proportionally shared.

As most co-financing is private sector input for replacement equipment, the project management co-financing becomes inevitably low from that funding-source. However, the project management component is co-financed in excess of 22 % by the Government of Morocco.


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Table F shows 62 person weeks for international consultants. Annex C refers to 72 p-weeks.

Corrected, 60 weeks is the accurate number (two weeks deducted due to deletion of lab strengthening)

Section G. It is GEF policy that baseline should be included by CEO endorsement.Exceptionally, it can be developed during the first year of implementation and reported to the GEF through the first PIR. Please state explicitly when the baseline will be developed.

The M&E baseline will be fully developed during first year of project. Much of the M&E baseline is already available and given in the logframe tables.

M&E table is said to show ?responsible party? in bold. This is not the case. Moreover, I would recommend underline which resists better to format changes.

Noted. Corrected.

Terminal evaluation shows GEFSEC as a ?responsible party?. I don?t believe this to be the case (although both GEFSEC and Evaluation office are clients of this and other outputs of the M&E plan).

Corrected.

It is stated in that section that ?as the PIF did not include a separate M&E component the expenses are budgeted under component 3?.I don?t understand the causality here, but moreover, the project document itself includes a (4th) M&E component. Clearly the ?CEO endorsement request? should reflect the main project document.

At some stage during the development of the new GEF formats, it was explained that a separate M&E section is not allowed anymore so the M&E activities were pro-rated over actual activities to be monitored and evaluated. We are more than happy to bring it as a separate project component, which is reflected in the latest version of the documents.

Part II Para A. refers to ?at minimum 120 tons of pure PCB oils?. Yet the ?project framework? refers to 205 tons. Please ensure clarity and consistency across the documentation.

The right figure is 205 tons of pure PCBs.

In any event, I do not understand the first 5 lines. Please rephrase. (Appended here for ease of reference: ?The main global benefit from the project will be the safe disposal of minimum 120 tons of pure PCB oils within 446 tons of equipment. This figure is not including cash contribution of approximately US$ 450,000 from government for disposal of additional equipment for which co-financing has not been identified at this stage (at this stage estimated 239 tons). This is why the previous section referred to 205 tons of PCB-oils, which can be seen as an estimated minimum achievable outcome under pillar I.? ? repeated P30 of the prodoc). P3 of the Prodoc (brief description) refers to 150 tons plus an estimated 55 tons [?]?.

The right figure is 205 tons (150+55) of pure PCBs. Text has been revised

D Coordination: I am surprised that coordination with the ASP does not seem to have been considered.

This was not really discussed during project formulation. UNDP is not actively participating in the ASP so the support in this integration difficult.

Revised linkages section provides some further items in relation to ASP.

The description of collaboration and coordination, and potential overlap with the UNEP regional initiative is too generic and needs to be strengthened through specific activities.

Without details of UNEPs regional projects detailed collaboration need to be complemented at submission of the UNEP proposal.

Revised linkages section provides some further information on this co-operation in particular the Government of Morocco’s contribution to the regional project.

E. Incremental reasoning.

Para 1 and 3 of that section. No, activities pertaining to legislation or expansion of the inventory are not incremental from a GEF perspective?.

Noted

Incremental cost table is difficult to follow as entries do not seem to be aligned with the ?project framework?.

Revised and aligned

In any event, it is surprising to find that the first component on legal and administrative capacity building is considered by the project proponents to be highly incremental, and is mostly financed by the GEF. This is a component where one would expect a strong contribution from the government which would

The outputs under this project component go more deeply in technical details of all stages of PCB life cycle than a framework law. The capacity to develop such technical guidelines is not very high in the relevant ministries. Therefore it has been found best to develop the


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also ensure country ownership of the outcomes. Most of the costs of this component are ?personnel costs?. Is a cohort of national and international consultants expected to be brought in to develop the appropriate regulatory framework? How in that case can we expect ownership from the GoM, and the various administrations involved? This was noted by GEFSEC at time of PIF review.

regulations and detailed technical guidelines (down to company level) by external experts, which are also charged with training seeing that capacity is indeed extended to government and other players.

This will ensure ownership and sustainability together the project is supporting the PCB Committee as established, ensuring that the work will be integrated into the government structure.

In general, all countries subcontract out development of such technical guidelines. Some countries have non-private institutions taking up such contracts, in some these are done by private sector.

It is felt that this component is really crucial the whole project, as without this there will be no legislative basis for any waste handling, e.g. no requirements for anybody to send waste to pillar II facilities (or indeed for the facility itself) etc. Therefore experimenting with other approaches with possible delays is not advisable for this outcome.

The regulative work is also singled out as one of the key input’s from Morocco to the UNEP regional PCB project. Hence it is of utmost importance that the outputs from this activity is of highest possible standard and provided in a timely manner.

How is the project contributing to ?strengthening fundamental capacities in chemicals management? as announced in the PIF, and repeated P30 of the prodoc? Also repeated in P13 of CEO endorsement request of UNIDO. Unless one looks at this very superficially and consider that strengthening capacities for PCB management inevitably contributes to SAICM etc. But it would be nice to see concrete activities leading to strengthened ?fundamental capacities?

Analysis of contribution to SAICM included in the revised document.

Risks The main ?risk? to component 3, which is not alluded to, is that of human and environmental exposure to PCBs during handling. This should be acknowledged, and the project should highlight what safeguard measures will be in place to mitigate that risk ? including the development of a framework, as well as possibly site-specific, contingency management plan(s).

Yes, this is an important risk and is addressed in revised version.

Stakeholder analysis:

Universities/public research labs seem to be missing? Included in revised version.

Section G cost-effectiveness

should be strengthened, including by providing estimated cost per ton of PCBs phased out and disposed of, and comparison to similar activities elsewhere if such data is available.

Further elaborated in revised version

Second para: Statement that ?cost effectiveness has not been given the highest priority?? should be deleted or rephrased as it conveys a negative idea that is probably not what was intended.

Rephrased

Annex BResponse to reviews

Response to reviews is not adequate. Response to agencies, gefsec, stap etc review is missing altogether (Annex B). Response to Council (Annex C) should include the full comment that needs responding to, and indication of which Council member made the comment.

Responses to reviews included in revised submission.

A GEFSEC recommendation was to target the informal sector. How is this addressed in the project? (The description of Pillar II makes reference to informal practices which only serves to emphasise the

The issue of targeting the informal sector will be reached, for example, by involving NGOs or the UNIDO/UNEP National Cleaner Production Center (NCPC) in Morocco.


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appropriateness of that early recommendation).Separate subcontracts for NGO/CBOs have been inserted under project component 2 to address the possible recycling and re-use of PCBs in the informal sector.

ProDocActivity 3.2.2 I’m curious about the proposed activity of ?upgrading

of dismantling and temporary storage procedures and infrastructure?.I thought that was covered in ?Pillar II?.

Dismantling is a poorly chosen word, it is about disconnecting, decommissioning and draining of oils and temporary storage arrangements at waste holders or port facilities before shipping. These sites may require some spill containment etc in order to safely keep PCB containing and contaminated material.

Section III. Total budget

Please provide a table showing side by side GEF and co-financing. Otherwise it is impossible to see how both contribute to achieving project objectives.

TBWP is a fixed by UNDP changes in that table are difficult. However, Annex C budget table gives further details and provide subtotals for GEF and other sources after each section. An extra column has been inserted in Annex C budget tables with ticking in the budget lines that are co-financed.

Please provide justification for all travel (total of $87,000 is on the high side).

Justification is provided.

Please provide, ideally draft TORs, or at least a description, of contractual services for first year of implementation.

Description of contractual services provided in budgetary notes.

Annex B. List of cofinancing commitments. Please provide units, for weight, currency etc.

Revised.

Why do some companies show ?0? commitment ? how does the project/GoM intend to deal with these?

The 0-commitments are from PCB holders who are participating in the project but have not, mainly for administrative reasons, yet furnished their co-financing commitment. These holders will participate in the project and are consequently included in the waste disposal target but not counted for in the co-financing calculations.

Please explain in general how private co-financing is estimated, and how it is reflected in the attachments.

The private sector replacement co-financing is estimated by using current replacement costs for every individual piece of equipment targeted by the project. The calculation has been done and endorsed by each participating company as per average figures provided by the suppliers and preparatory project staff

I can not find the commitment letters from the GoM. Inserted.Annex C Annex C with ?details on inputs?. Am I correct to

assume ?ministerial experts? to mean experts from the Ministry ? and to be included in the government?s co-financing?

Correct assumption, additional column ticking in co-financed lines in the annex C. Budget tables verifies.


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ANNEX C: CONSULTANTS TO BE HIRED FOR THE PROJECT4

Position Titles$/

person weekEstimated

person weeks Tasks to be performedFor Project ManagementLocalProject Manager 750 156 Coordination, Project planning and

monitoring, Drafting of ToRs for consultancy input, delivery and quality checking of consultant reports. Progress and financial reporting

Project Assistant 500 78 Administration, accounting, financial administration, clerical tasks

International ------ ----- ----------

For Technical AssistanceLocalVarious according to specific expertise required.

750 288 Project component 1. i)Support for making the framework PCB regulation operational. ii) 1.2.Drafting and enacting sub-regulation, binding guidelines covering all stages PCB management.(Support to PCB National PCB Committee) iii) Developing and facilitating approval of environmental and food limit values for PCB risk mitigation. Raise awareness and educate government officials and general population about the dangers of PCBs (POPs) and the possible adverse effects of exposure.

Various according to specific expertise required.

750 168 Project component 2 i) Increased capacity to avoid PCB exposure during handling and maintenance ii) Increased capacity to identify PCB sources and equipment in operation and at entry in country.


750 44 Project Component 3.i) Increased capacity to avoid PCB exposure during dismantling, transportation and storage. ii) Acceleration of PCB equipment replacement through economic instruments. iii) Final disposal tendering.

InternationalVarious according to specific expertise required.

3000 30 Project Component 1 Project component 1. i) Support for making the framework PCB regulation operational. ii) 1.2.Drafting and enacting sub-regulation, binding guidelines covering all stages PCB management.(Support to PCB National PCB Committee) iii) Developing and facilitating approval of environmental and food limit values for PCB risk mitigation. Raise awareness and educate government officials and general population about the dangers of PCBs (POPs) and the

4 Please see annex V of project document for further details CEO Endorsement PCB management and disposal in Morocco Pillar I

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possible adverse effects of exposure. + monitoring and evaluation.


3000 14 Project component 2 i) Increased capacity to avoid PCB exposure during handling and maintenance ii) Increased capacity to identify PCB sources and equipment in operation and at entry in country. + monitoring and evaluation.

Various according to specific expertise required

3000 8 Project Component 3.i) Increased capacity to avoid PCB exposure during dismantling, transportation and storage. ii) Final disposal tendering. + monitoring and evaluation.

M&E specialist and final evaluation expert.

3000 8 Developing project monitoring scheme particularly to capture risk reduction from decreased PCB exposure. Leading project final evaluation and lessons learnt documentation.

ANNEX D: STATUS OF IMPLEMENTATION OF PROJECT PREPARATION ACTIVITIES AND THE USE OF FUNDS

A. EXPLAIN IF THE PPG OBJECTIVE HAS BEEN ACHIEVED THROUGH THE PPG ACTIVITIES UNDERTAKEN.

Both Pillars of PCB management and disposal in Morocco was included in the original PPG (PDF-B) activities. The Pillar I objectives has been broadly achieved. The critical issue of agreeing on a draft framework PCB regulation has been achieved and this will pave the way for the final adoption of the regulation upon which the more specific technical guidance will be based. Also the participation level, both when it comes to number of companies and their co-financing has been more than satisfactory.

The Government commitment in implementing the PPG stage has been exemplary by supporting and pushing the regulatory change as well as committing itself financially both by providing personnel and by pledging cash for project implementation

OUTPUTS COMPLETED ACTIVITIES

Project Component 1:

Strengthened legal & administrative

framework for PCB management &

disposal

Output 1. Drafting of PCB legislation and submitting it to the political decision making process.

All activities have been completed.The current legislation was reviewed and a regulatory framework for managing PCBs was developed along with a draft decree in Arabic and French.

Output 2. Reinforcement of the administrative framework and PCB knowledge for ensuring safe PCB management

All activities have been completed:Informational material has been prepared to be used as support documentation during training workshops for custom officials, environmental inspectors and other government and regional officials.

Project Component 2: Management of

PCB oils and PCB contaminated

wastes and equipment in a

manner that minimizes human and environmental exposure of PCBs as well as further

identification PCB sources and

Output 3. Establishment of a PCB self reporting system and ensuring an active participation by industries and PCB possessors to identify further PCB equipment and their safe management.

All activities have been completed:There has been active participation from PCB holders, namely during identification of PCB equipment and safe management of PCBs. Awareness-raising and communication from the project team and the Ministry have proved to be rewarding as the PCB holders were very cooperative and participative.The legislative framework and corresponding decree need to be endorsed and promulgated to enable a self reporting system that would be required and regulated by the concerned Ministry.


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equipment

Output 4. Accurate PCB inventories for proper dimensioning and financial budgeting of the selected disposal method established.

All activities have been completed:An inventory was carried by the project team, assisted by 2 chemical & electric experts as well as 2 specialists in disposal of PCB-containing equipment to identify all PCB-containing equipment & waste in Morocco. As it was not possible to analyze all transformers currently in use, statistical methods were used to collect data from enterprises that have already undergone such PCB analyses. Services of a local laboratory were used to perform a series of analyses on non-PCB transformers to determine the rate of contamination at national levelA subcontractor carried out sampling and analysis of 125 transformers in Morocco.

Project component 3

Environmentally sound disposal of PCBs wastes

Output 5. Decision on exporting or establishing of a domestic final disposal taken. (UNIDO Executed)

Activities were carried out by international and national consultants as follows: - Feasibility studies on decontamination and dechlorination technologies for PCB-contaminated electrical equipment in Morocco - Strategic environmental assessment of the planned PCB project in Morocco The detailed studies on technology options for the environmentally sound management and disposal of PCB wastes in Morocco and socio economic impact of the planned project, which are annexed to the UNIDO project document, were completed jointly by the international and national experts.

Output 6. Developing & Submitting to the GEF : PIF, CEO Endorsement Form & Project Document

All activities have been completed:A mission to Morocco to conclude the PIF was organized in September and October 2007. An endorsed PIF was subsequently submitted in October 2007 by UNDP and approved by the GEF. The first draft of Project Document was completed in the beginning of 2008 and discussed with the counterpart, UNDP and the national consultant in a mission to Morocco in February 2008. The final version and the CEO Endorsement Form were discussed with the counterpart and UNDP and submitted to UNDP for submission to the GEF.Discussions were held with stakeholders, namely governmental entities and bi-lateral investors, on project financing and participation modalities. Co-financing is secured: 21 companies have committed to co-financing by disposing and replacement of their PCB-containing equipment in the 3 years after programme inception. This commitment amounts to a co-financing equivalent to 4.15 million US$. The Moroccan government has committed to a co-financing in cash equivalent to 506,000 US$

B. DESCRIBE IF ANY FINDINGS THAT MIGHT AFFECT THE PROJECT DESIGN OR ANY CONCERNS ON PROJECT IMPLEMENTATION.


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C. PROVIDE DETAILED FUNDING AMOUNT OF THE PPG ACTIVITIES AND THEIR IMPLEMENTATION STATUS IN THE TABLE BELOW:

Project Preparation Activities Approved

Implementation Status

GEF Amount ($)Co-

financing($)

Amount Approved

Amount Spent To-

date

Amount Committed

Uncommitted Amount*

1. Strengthening of the legal and administrative framework for PCB management and disposal

Completed 16,000 11,012 4,988 15,000

2. Management of identified PCB oils and PCB contaminated wastes and equipment in a manner that minimizes human and environmental exposure of PCBs as well as further identification PCB sources and equipment.

Completed 72,000 51,882 20,118 30,000

3. Sampling and analysis of PCB contaminated electrical equipment

Completed 16,000 16,224

4. Feasibility studies and strategic environmental assessment – national consultants

Completed 31,500 12,472 18,998

5. Feasibility studies and strategic environmental assessment and preparation of the project document – international consultants

Completed 72,000 61,892 9,889

6.Management and FSP drafting

Completed 127,400 55,928 71,472 25,000

Office space & Facilities Completed 20,000Total 334,900 209,410 125,475 90,000

* Uncommitted amount should be returned to the GEF Trust Fund. Please indicate expected date of refund transaction to Trustee.


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