While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with all Performance Standards with the exception of Performance Standard 7 since there are no Indigenous Peoples as defined by IFC living in the vicinity of the mine and its facilities. The nomadic herders in Mongolia are not considered indigenous as per IFC’s definition under Performance Standard 7.

While OT is preparing all the documentation for the project based on IFC’s 2006 Performance Standards, OT has indicated that it will follow the intent of the updated Performance Standards which came into effect on January 1, 2012.

This is a Category A project because it is a very large, complex project with correspondingly significant risks and impacts on the environment and way of life in the Southern Gobi. The key concerns relate to the cross-cutting issues of water resources, biodiversity, community development and ecosystem services.

For all future activities that significantly alter the scope or footprint of the Project, OT will conduct additional environmental and social impact assessments in compliance with Mongolian law, and that are consistent with IFC’s Performance Standards, including full consultation and disclosure. Examples of such additional ESIAs would be for expansion of production, construction of the power plant and for Khanbogd Worker Housing Development (including water supply arrangements) and Khanbogd Industrial Estate.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives. OT is committed to meeting the requirements of the IFC Performance Standards as demonstrated through the integrated ESIA. All requirements are equally applicable to OT staff as well as its contractors.

Policy

In addition to meeting the requirements of Mongolian Law and the IFC Performance Standards, the project will comply with Rio Tinto’s applicable standards on environment, occupational health & safety, community health, safety and security. The Rio Tinto Communities Standard includes support to health and/or livelihood initiatives that address community priorities.

These standards are the basis for a project-specific Health, Safety & Environment Policy defining environmental and social objectives and which is operationalized through a Health, Safety & Environment Management System (which reflects the key elements of ISO14001) and a Community Management System.

Identification of Risks and Impacts

The five-volume Oyu Tolgoi integrated ESIA builds upon an extensive body of existing studies and reports prepared since 2002 for project design and development purposes and for Mongolian approvals. A range of project component-specific detailed environmental impact assessments (DEIAs) were prepared for Mongolian approval and permitting purposes under the Environmental Protection Law (1995), the Law on Environmental Impact Assessment (1998 and amended in 2001) and the Minerals Law (2006). These initial EIAs were prepared over a 10 year period from 2002 to date.

Since 2002, OT has collected baseline data for planning and impact assessment: (i) field sampling programmes and surveys, such as surface and groundwater quality, dust measurement, fauna surveys and vegetation surveys; (ii) verbal evidence provided through interviews both with permanent residents and with settlers and herders; (iii) specific monitoring programmes undertaken by OT in accordance with Mongolian requirements and in compliance with international standards; (iv) laboratory assessment; and, (v) secondary data review through public sources of information, mapping and graphics sources. click here for more information

The project has generated significant employment opportunities for the region with a construction workforce peaking at about 14,800. The permanent workforce will be 3,500. OT has developed a Labour Management Plan detailing the methods, measures, and procedures to (i) achieve compliance with Mongolian labour law and international standards; (ii) achieve local and national employment targets; and (iii) ensure that recruitment, employment and training are carried out in a fair and transparent manner, consistent with good international industry practice.

Discrimination in the workplace based on nationality, race, sex, social origin or status, wealth, religion, or ideology is strictly prohibited, according to Mongolian regulations, although women are prevented from undertaking certain high risk forms of manual work as set out in separate regulations. Workers rights are also protected by means of collective agreements which may be concluded within professions or economic sectors and at the region, soum, aimag, or city level. Collective agreements also identify a range of the social benefits to which workers are entitled. All such collective agreements must be registered with the relevant legislative body. The Labour arbitration court settles collective labour disputes and a court or commission settles escalated individual labour disputes not resolved in the workplace. Mongolia has been a member of the International Labour Organisation (ILO) since 1968 and the country ratified the ‘core’ ILO Conventions, i.e. the eight conventions that have been identified by the ILO''s Governing Body as fundamental to human rights at work. click here for more information

Ambient Conditions

The project area is characterised by a dry, continental interior climate with extremes of temperature from high summer temperatures to very cold winter temperatures. Spring months are characterised by frequent dust storms which can adversely impact mining-related operations and disrupt air transport. Rainfall is under 100 mm annually with a significant excess of evaporation over rainfall.

The Project is located in a remote area with no existing industrial facilities in the vicinity of the MLA, thus baseline studies show that air quality in the project area is good except for high natural dust concentrations in the air in the Gobi region, particularly associated with seasonal dust storms. Dust concentrations are generally higher in areas of overgrazing and in heavily disturbed areas such as along roads. Dust plumes are clearly visible along many of the highways.

No permanent settlements exist within a 10 km radius of the mine site. The nearest soum centre, Khanbogd, is located approximately 45 km to the north-east. Hence there are no sensitive community receptors close to the mining and construction operations in the MLA. However, wildlife and herders are potential receptors of noise associated with heavy vehicle traffic on the Oyu Tolgoi-Gashuun Sukhait road and the construction of the Gunii Hooloi water supply pipeline. Baseline noise surveys show that noise levels are varied but within IFC guideline limits and are dependent on irregular localised noise sources such as road traffic. click here for more information

The main community health safety and security impacts from the project include the following: (i) transmission of communicable diseases from the workforce to the community; (ii) increase in non-communicable disease; (iii) health risks associated with dust, vibration, and noise emissions; (iv) risks associated with materials and personnel transport; (v) presence of open excavated areas and trenches (risks associated with active worksites); (vi) security arrangements, both in terms of access to the mine site, fencing and associated facilities and the use of security services; (vii) conflicts and other unwanted interactions between OT personnel and the community; (viii) health issues exacerbated by population influx; (ix) herder health; (x) health issues associated with artisanal miners; (xi) food security and nutrition; and (xii) potential for emergencies/emergency response.
To mitigate these impacts, OT developed a Community Health, Safety and Security (CHSS) Management Plan covering the Project area of influence. The Plan addresses: (i) direct hazards, risks and impacts arising from activities under the control of OT, including works implemented by contractors and sub-contractors; and (ii) indirect risks and impacts, which are not under the immediate control of OT, but to which the Project contributes through its activities and operations. The ESIA includes other management plans that incorporate CHSS aspects, such as D2: Air Quality Management Plan, D12: Hazardous Materials Management Plan, D11: Transport Management Plan, D19: Worker Health, Safety & Security Management Plan, and D20: Emergency Response Plan.
OT is developing a Community Health, Safety & Security Programme (CHSSP) that currently includes herder outreach activities, capacity- development of health services, provision of community assistance in relation to STI/HIV prevention and response, and direct assistance in relation to an emergency response centre.
OT has established a number of policies in relation to community health, safety and security. These include the following: (i) urban development and public infrastructure; (ii) community development and social investment; (iii) maintaining site safety and conformance with established visitor procedure protocols within the MLA. OT has also developed a camp policy and Code of Behaviour which aims to ensure a safe and secure living environment at the accommodation camps. In addition to the specific requirements related to workers residing on the camp premises, the Code contains provisions which contribute to minimizing risks that may spread outside the camps and potentially involve the local communities.
The Human Rights Guidance that was developed by Rio Tinto draws on the principles of the United Nations (UN) Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social and Cultural Rights, UN Secretary General’s Global Compact, and the Voluntary Principles on Security and Human Rights. Rio Tinto’s procedures for using security personnel are based on human rights principles and include guidelines and restrictions on the use of force. These procedures are reinforced through continuous training and applied to contract security personnel as well as to employees. Training of security personnel is used to reinforce the principles. All these principles apply equally to security contractors and are made an explicit condition of business with the Company. Rio Tinto is a signatory to a host of international commitments and standards and is dedicated to meeting them. The Company was involved from the inception of the Voluntary Principles on Security and Human Rights and has supported these principles since their announcement in 2000. Rio Tinto was also a founding member of the United Nations Global Compact, and is an active member of the UK Network and the Communication on Progress Working Group. Rio Tinto’s Communication on Progress is published annually on their website.
Transport
In order to mitigate the risks associated with materials and personnel transport, the Project has developed a Transport Management Plan that takes into account transport routes, speeds, times of travel, and other safety measures to protect the local community.
Areas where herders and wildlife cross the transportation routes used by OT’s and contractor vehicles have been identified and appropriate signage will be erected to alert drivers of possible crossings by humans and animals. Records of animal sightings will be recorded and records will be maintained by the OT Environment Department.
Driver training also includes procedures for driving when animals (herd or wild) are observed in proximity to or on a road. This includes requirements to stop if necessary. Vehicle speeds on unsealed roads are restricted to a maximum of 80 km/h with limits as low as 10 km/h at sensitive receptor locations (e.g. camp areas and near work sites). All OT trucks and those on dedicated contracts will be fitted with GPS tracking devices and speed control, so that driver compliance with the speeds designated by OT can be enforced.
The Transport Management Plan includes a Traffic Awareness Programme for villages and towns affected by Project-related traffic. OT is implementing the Traffic Awareness Programme jointly with Project contractors and with participation of the local Police departments and administrators. The Traffic Awareness Programme links in with the Road Traffic Injury Prevention Plan which is part of the CHSSP.
Hazardous work
Most hazardous work (such as heavy construction activities, blasting, mining, haulage of ore, and storage of hazardous chemicals or machinery) takes place within the MLA boundary fence. This area is controlled by gates and security personnel at checkpoints all times, thereby preventing the access of unauthorized third parties.
A “security zone” has been established around the MLA which limits access to the Project site as well as other land outside the site as defined by the Mongolian government. Monitoring of the requirements within the “security zone” will be the responsibility of the Health and Safety Department and CSP as well as the construction contractors.
Security
The OT site sub-contracts security services to a Mongolian security company. Another Mongolian security company provides contract services and security advice for building and expatriate safety specifically for operations in Ulaanbaatar. Both security companies are certified by the Mongolian government. To this effect, OT has developed and adopted a standard/procedure that describes the minimum requirements for all personnel, contractors and sub-contractors related to security arrangements and the use of force.
Influx and associated health impacts
OT is aware of the risk of an increase in communicable diseases due to the Project-induced in-migration and population influx and prepared plans to mitigate them.
Communicable diseases of concern in Mongolia include tuberculosis, sexually transmitted infections (STIs) and brucellosis. Risk of respiratory disease, as well as food and water-borne diseases (such as cholera and typhoid) may also increase in informal migrant settlements due to congested living conditions and a lack of sanitary facilities. In the CHSS Management Plan, the company has identified a number of specific risk prevention measures, including: (i) medical services and comprehensive worker health screening is in place for all workers; (ii) comprehensive STI/HIV prevention and awareness programme is being implemented to protect workers and their families, as well as the provision of voluntary testing services; (iii) Healthy Workforce Policies are being implemented to encourage workers to adopt safe sexual and other health-related practices (e.g. hand and food hygiene) as part of the Workers’ Personal Health Program; (iv) vaccinations for workers and their families are provided for relevant communicable diseases in accordance with risks identified by Project medical staff; (v) health promotion to herders, youths and high risk groups includes offering the same STI/HIV awareness programme and preventive measures for workers and local communities; (vi) OT is working with the Mongolian Ministry of Health and local government to strengthen national control programmes for the most prevalent communicable diseases in the local soums; (vii) investments in the local medical facilities and services are being made by OT. These include contributing to the improvement of soum and aimag health facilities, funding training for family planning and sexual health services and counselling, and providing additional equipment for testing, monitoring and treatment of the most prevalent communicable diseases; (viii) OT will partner with local government to promote immunisation within the local community and particularly among children; (ix) epidemiological surveillance and monitoring of community health will be accomplished through local and regional health clinics and service providers. OT recognizes that current Mongolian health services are stretched and that investment is needed to support these services, therefore it will consult with the relevant stakeholders and agencies to identify areas of potential investment and assistance; (x) as part of the Company’s participation in the SGRDC, the Project will contribute to the improvement of health care infrastructure in the Project area of influence; and (xi) through its CHSSP, the Project will also support health service provision, including diagnostics and surveillance. A Communicable Diseases Prevention Action Plan is included as part of the CHSSP.
OT is committed to developing a range of health promotion related activities within the community to minimise expected increases in lifestyle related disease. These are focussed on healthy nutrition, physical activity, tobacco, alcohol and stress. A Non-Communicable Diseases Prevention Action Plan is included as part of the CHSSP.
Issues of herder health will continue to be monitored by OT as part of the Herder Outreach Programme and the Healthy Soums Programmes. The programmes offer health information to herders which would otherwise not be available. A range of organizations have responsibility for the health of local residents including national and local government, local NGOs and OT through the CSP department.
Community safety and security
A major change to the Project impacted communities is the movement of population. The net effect of this is increases to the population of Khanbogd. These changes are expected to impact on social cohesion and stability, and may contribute to an increased risk of crime, especially robbery. Mitigation measures for these potential impacts on community security include the Influx Management Plan, the Regional Development Plan, the Environmental Management Plan, the Oyu Tolgoi HSES Monitoring Programme and the Security Response Plan.
Artisanal miners health
There is no artisanal mining practiced in the OT Project area of influence as the Mongolian Government closed down all artisanal mining in the region in 2007. However, OT has developed a strategy to address health issues in potential employees who may have been artisanal miners. Specifically, OT will monitor for possible mercury exposure since artisanal gold miners use mercury amalgamation processes.
Community emergency preparedness and response
A project-wide Emergency Response Plan has been developed and implemented. As part of the Plan, specific procedures are in place to address: (i) natural disasters; (ii) pandemics; (iii) medical emergencies; (iv) fires and explosions; (v) traffic incidents; (vi) civil unrest; (vii) bomb warnings; and (viii) environmental incidents including release of fuels and hazardous substances.
In order to protect local communities the following provisions will also be implemented: (i) OT will work with communities and administrators to identify an effective emergency alert system for the Project; (ii) OT will provide potentially affected communities with information regarding the potential hazards and Project responses; (iii) OT will work with communities in a collaborative manner to develop action plans for their preparedness and response; (iv) participative workshops and emergency response demonstrations will be carried out in Project-affected communities; and (v) the Emergency Response Team for the OT Project will be identified to local communities near the site so that they are familiar with this group should they need to be deployed off-site at any time.
Training
All employees of OT and contractors to OT are provided with basic training on health, safety and security, including health awareness training and induction in the Camp Policy and Code of Behaviour. Additional specialist training is to be provided to the security personnel (including on the human rights and the use of force), drivers (as outlined in the ESIA Section D11: Transport Management Plan), and key personnel involved in activities that are conducted off-site, e.g. along the transport route.
Community grievance management
The community grievance procedure will continue to be used to monitor if any issues related to security personnel arise during construction and operations. The procedure categorises different types of complaints, including a category for any grievances related to security arrangements. OT’s Stakeholder Engagement Plan includes a copy of this procedure and different categories of complaints recorded. This procedure is being implemented with local residents. The OT Communities team shall be involved in any issues related to Project security and local communities. OT commits to involve external stakeholders (i.e. police, soum / aimag authorities) in any off-site security incidents and ensure appropriate incident response procedures are implemented.

General context

The Project is located in the Central Asian Gobi Desert eco-region, which is characterized by very low population density and a mosaic of low-statured desert and steppe vegetation typical of the South Gobi region of Mongolia and neighbouring China. Despite its sparse vegetation and scant surface waters, this eco-region supports a diverse fauna with populations of global conservation significance for a number of globally and/or nationally threatened species, including the Asiatic wild ass (or khulan, Equus hemionus), the goitered gazelle (or black-tailed gazelle, Gazella subgutturosa), the houbara bustard (Chlamydotis undulata) and the saker falcon (Falco cherrug). Diverse bird assemblages are common and the area supports important breeding populations of globally threatened species.

In the Omnogovi aimag, the presence of important populations of threatened fauna has led to creation of the Small Gobi Strictly Protected Area (SGSPA), located along the Mongolian-Chinese border approximately 80 km to the south of the OT MLA. The SGSPA is comprised of two blocks, Block A which lies to the west and Block B which lies to the east. An existing road is being upgraded by the Project to transport concentrate via the Gashuun Sukhait border crossing point which itself lies within the western extremity of SGSPA Block B. To the west of the mine area, the coal road (from Tavan Tolgoi coal mine to the border) divides this habitat and effectively fragments the ungulate populations given its heavy traffic volumes. Both the coal road and the OT-Gashuun Sukhait road cross a portion of the SGSPA Block B in the 13 km immediately north of the border crossing point.

The infrastructure corridor comprising the OT-Gashuun Sukhait road and power line also cross the Galbyn Gobi Important Bird Area (IBA), which is approximately 25 km to the south of the project MLA. The IBA supports important breeding populations of globally-threatened bird species, such as the saker falcon, and the houbara bustard among other threatened fauna.

Baseline

The vegetation in the Oyu Tolgoi project area largely comprises low-growing, drought- and cold-tolerant shrubs, perennial grasses and annual plants. Trees are absent over much of the landscape, but are locally abundant in areas where shallow groundwater exists. The vegetation supports populations of both wild and domestic large herbivores. Vegetation of conservation interest includes: saxaul (Haloxylon ammodendron), Siberian elm (Ulmus pumila) and granite outcrops that have distinct floral communities owing to the aridity of the surrounding region. Rare and very rare species were identified in the project area by Mongolian legislation, largely for their medicinal or other economic and cultural interests. All of the vegetation species are widespread in the greater Gobi region of Mongolia and China or are more widely distributed westwards into central Asian countries.

At least 137 species of birds have been reported from the OT project area and species are being added regularly by project staff biologists, including several listed on the International Union for Conservation of Nature (IUCN) Red List. Of these, one species, the Egyptian vulture (Neophron percnopterus), is categorized as globally Endangered, six species are categorized as globally Vulnerable, one species is categorized as Near Threatened and a further two species are categorized as Least Concern. One further species, the short-toed snake-eagle (Circaetus gallicus), has endangered status in Mongolia.

The mammals of the project area include a rich mix of small mammals (e.g., jerboas, gerbils, bats, hedgehogs), and carnivores (e.g., mustelids, wild cats, foxes, wolves). The area also hosts globally important populations of large hoofed animals that have become decimated or extinct in many of their historical ranges. These include the Asiatic wild ass, which is IUCN Red-listed as Endangered and the goitered gazelle, which is IUCN Red-listed as Vulnerable. Rocky areas support Siberian ibex (Capra sibirica) and argali sheep (Ovis ammon), IUCN Red-listed as Least Concern and Near Threatened, respectively, although the argali has endangered status in Mongolia. Both the goitered gazelle and the Asiatic wild ass are also considered desert migratory or nomadic species, and both are protected under Mongolian and international wildlife conservation laws and agreements. In Mongolia, threats to these species include illegal hunting for meat and increased human activity associated with mining activity and associated infrastructure.

The species considered of greatest conservation interest with respect to the Project is the Asiatic wild ass. Southern Mongolia currently holds the largest population of Asiatic wild ass in the world, representing almost 80% of the global population. While globally significant populations of Asiatic wild ass are well documented from the southern Gobi region, the habitats utilized by this nomadic species have been locally fragmented to varying extents by the creation of transportation infrastructure (eg, the Tavan Tolgoi ‘coal road’, the Ulaanbaatar - Beijing railway (which lies several hundred km east of the mine site) and the fence constructed along the China-Mongolia border.

Assessment

Mongolian DEIAs such as those prepared for the Project are not required to address biodiversity related issues to the level envisaged by Performance Standard 6. To supplement the DEIA environmental assessment work completed, an expert group of biodiversity specialists was engaged by the Project in March 2011 with the following scope of work: (i) to assess biodiversity impacts and mitigation strategies; (ii) to conduct a biodiversity values and a critical habitat assessment; and, (iii) to advise on the development of a biodiversity monitoring and evaluation programme and a biodiversity offsets program. This team – the Rapid Biodiversity Assessment team (RBA) – was comprised of experienced local and international specialists from Flora & Fauna International, The Biodiversity Consultancy, Wildlife Conservation Society, the Wildlife Science and Conservation Centre (Birdlife International’s national partner), World Wide Fund for Nature-Mongolia, National University and elsewhere.

The RBA team identified a number of ‘priority biodiversity features’ associated with the Project area as part of a biodiversity values assessment. This assessment is based on Rio Tinto’s Biodiversity Action Plan guidelines. The following features are identified as the priority features impacted in the area of influence: Mongolian chesney (Chesneya / Chesniella mongolica – endangered status in Mongolia), Asiatic wild ass, argali, goitered gazelle , Mongolian gazelle (Procapra gutturosa), swan goose (Anser cygnoides), ferruginous duck (Aythya nyroca), short-toed snake-eagle, saker falcon, Egyptian vulture, great bustard (Otis tarda), Houbara bustard, relict gull (Larus relictus), Pallas’s sandgrouse (Syrrhaptes paradoxus), Mongolian ground-Jay (Podoces hendersoni), yellow-breasted bunting (Emberiza aureola), riverine elm trees, and tall saxaul forest.

A critical habitat assessment was also conducted to determine the biodiversity values that qualify as critical habitat per Paragraph 9 of Performance Standard 6. The critical habitat assessment is an example of best practice in critical habitat determination. Biodiversity values that qualified as critical habitat are as follows: (i) Asiatic wild ass, argali, short-toed snake-eagle and the Mongolian chesney plant given concentrations of these globally or/or nationally listed endangered species; (ii) goitered gazelle given concentrations of this migratory species; (ii) granite outcrops as they contain unique assemblages of floral communities. Note that ecosystem services were also considered as part of this assessment, and these are described below.

Impacts & Mitigation

The biodiversity risk assessment matrix outlined in the Rio Tinto Biodiversity Action Planning guidance (Rio Tinto 2010) was used to assess the level of risk to each priority biodiversity feature arising from the various project-related direct and indirect impacts. The ESIA also identifies potential impacts on those species not considered to be priority species. The risk assessment method classifies risks based on the consequence and the likelihood of an event.

The impacts assessed as high or critical risk to priority biodiversity features are as follows:
indirect habitat loss due to avoidance of infrastructure,
mortality from illegal hunting and collecting facilitated by increased access and in-migration,
mortality or injury related to collisions with vehicles and the powerline,
direct habitat loss under infrastructure, and
mortality from increased populations of natural predators.


Also relevant to biodiversity and ecosystem services, the ESIA identifies a number of hydrological uncertainties that require further studies and monitoring to understand the response of surficial aquifers to groundwater abstraction and the connectivity between aquifers. These include the potential impacts associated with dewatering of the mine area, the Undai River diversion, groundwater abstraction from the Gunii Hooloi basin and the Durulj Mount Southern basin.

The Project’s approach to biodiversity management is outlined in the company’s overarching Biodiversity Strategy (contained in an annex to the ESIA). In accordance with this Strategy, the Project has developed a series of on-site and offset mitigation measures. Offset measures are described further below. Onsite mitigation measures are detailed in the ESIA and are summarized in the Project’s Non-Technical Summary, available as part of the disclosure package. Mitigation measures include the installation of bird flight diverters on all power lines, insulation works on medium and low voltage lines, traffic control measures and restrictions to minimize the impacts associated with the Project road use, hunting and collecting control measures, rehabilitation and restoration of disturbed land, establishment of a native plant nursery, the creation of a replacement spring to compensate for the loss of Bor Ovoo spring and support to and engagement in sustainable regional development initiatives.

Of the on-site mitigations, those relating to the OT – Gashuun Sukhait road are particularly notable. As mentioned above, the Tavan Tolgoi ‘Coal Road’ passes some 20 km west of the MLA. As the ‘Coal Road’ and the OT – Gashuun Sukhait cross at a point north of the border, the two roads run roughly parallel but gradually getting closer to each other as they approach the crossing point. The ‘Coal Road’ which has been in use since 2006 has effectively fragmented ungulate populations between the Blocks A and B of the SGSPA. Despite the existing Tavan Tolgoi ‘coal road’, the OT Project has made a world-leading commitment to install a series of underpasses along its OT – Gashuun Sukhait road (also known as the concentrate transport road). Underpasses will be designed using best international knowledge to date and will be sufficient in number to allow ecological permeability, given known animal daily ranging distances. Despite best efforts to implement mitigation measures along the OT - Gashuun Sukhait road, residual impacts remain for the Asiatic wild ass and the goitered gazelle. The Project will be addressing such impacts through its Biodiversity Offset Strategy (described below). In addition to the installation of underpasses, OT will also explore possibilities to promote future regional connectivity of ungulate populations in the South Gobi by engaging with regional development bodies and organizations on non-project linear infrastructure in the region.

These measures will be fully captured in the forthcoming Biodiversity Management Plan for the operations phase. The current Flora and Fauna Management Plan developed for the constructions phase also contains relevant mitigation. In order to bridge the gap between the remaining months of the construction phase and the operations phase, IFC worked with the client to develop a Biodiversity Action Plan (BAP). The BAP contains a series of time-bound commitments relating to the abovementioned mitigation measures. The BAP and the mitigations outlined in the ESIA will be the basis by which the operations phase Biodiversity Management Plan is developed.

It should be noted that the ESIA also identifies a number of avoidance and minimization measures that were not adopted by the Project. The primary reasons relate to technical feasibility, the timing of implementation with respect to the advanced stage of construction, as well as actions that would be required by third parties. Note also that Performance Standard 1 above describes the shortcomings identified by IFC in the use of baseline information to inform the routing of the 220 kV transmission line.

Biodiversity and Other Monitoring

A Biodiversity Monitoring and Evaluation Programme (BMEP) is being developed for priority and critical habitat qualifying species and is a fundamental aspect of determining compliance with Performance Standard 6 requirements over the long-term. Monitoring results will enable the Project to take an adaptive management approach with respect to managing impacts. The design will include appropriate metrics and threshold values with the aim of measuring progress towards the overall goal, which is to obtain a net gain of critical habitat biodiversity values in alignment with Performance Standard 6 requirements. The BMEP is also essential for OT to demonstrate its commitment to having a Net Positive Impact (NPI) on biodiversity, in conformance with its NPI policy. A qualified organization will be retained by OT to design and implement the BMEP.

Given that water resource management has implications for impacts on ecosystem services, OT will develop and implement a multi-disciplinary Monitoring and Evaluation Programme which will include water impacts on vegetation, pasture quality, priority biodiversity features and critical ecosystem services. It will build on the ongoing water monitoring program (described in Performance Standard 3 above), and will include relevant metrics and threshold values adequate to determine compliance over the long-term. Results from this monitoring programme will also enable the Project to take an adaptive management approach with respect to ecosystem services.

Biodiversity Offsets

The ESIA predicts residual impacts on biodiversity primarily due to indirect habitat loss, an expected increase in illegal hunting and bird collisions with powerlines. In order to comply with Performance Standard 6 as well as to conform with the Project’s NPI policy on biodiversity, a biodiversity offsets programme will be implemented. To this end, the Project has developed a Biodiversity Offsets Strategy and NPI forecast. These documents, along with OT’s Biodiversity Strategy, are available as part of the ESIA.

The Offsets Strategy is based on wide-reaching consultation with technical experts and other relevant stakeholders. The NPI forecast projects potential biodiversity losses and gains over a 25 year period of time. Using methods (quality hectares) to determine losses on biodiversity with respect to offset gains, a defensible offsets ratio was determined for each priority biodiversity value. These methods are considered to be in alignment with best practices in offset design. The results of the forecast suggest that it is technically feasible to achieve NPI on critical habitat biodiversity values.

A number of offset actions have been proposed over a large ‘offsets landscape’ of approximately 50,000 km2 across the soums east and west of Khanbogd soum (Bayan-Ovoo, Khatanbulag and Khuvsgul soums). These include, inter alia, the following actions:

Reduced illegal hunting and collecting
Improved rangeland management
Reduced impacts of non-project powerlines
Strengthened protected areas management, and
Demonstrate and contribute to best-practice regional development

The two primary offset actions, reduced illegal hunting and collecting and improved rangeland management, draw from lessons learned of existing programmes and aligns with existing national and regional programmes, such as the mobile anti-poaching units model of the World Wide Fund for Nature-Mongolia, the Nature Conservancy’s Development by Design Gobi Region Landscape Assessment Project and the Government of Mongolia’s Mongol Mal Programme focused on livestock and herders.

The Project is committed to strengthening the management of the SGSPA and implementing programmes to enhance the conservation aims. The Offsets Strategy contains an initial list of recommended actions that are based on the SGSPA Management Plan. The final interventions will be determined in consultation with relevant government authorities. The Project will engage with non-government organizations such as Birdlife International’s national partner, the Wildlife Science and Conservation Center of Mongolia to develop management recommendations for the Galbyn Gobi IBA. The Project will implement those management recommendations where they contribute to the long-term sustainability of conservation outcomes in the offsets landscape.

Some level of risk and uncertainty is inherent to the delivery of biodiversity offsets and NPI and IFC acknowledges the challenges associated with offsets design and implementation. The offset design takes into account these sources of uncertainty and risk. For this reason, the proposed interventions incorporate the precautionary principle and aim to exceed the minimum requirements with a significant contingency. The Project will also engage the IUCN-Rio Tinto NPI Protocol and Review Panel, a mechanism that provides an independent process for the verification and measurement of corporate progress towards achieving its NPI target on project sites. This Panel will be piloted at OT to independently verify the success of the Offsets Strategy over time. The Project has earmarked an appropriate budget and qualified organizations will be identified to implement the Offset Strategy. The Project is also committed to working with the government through broad stakeholder consultation.

Ecosystem Services

The ESIA includes an ecosystem services review that employs an integrated methodology to identify potential impacts on key ecosystem services. The review identifies eight ‘Priority Ecosystem Services’ of which four are considered critical ecosystem services. These are as follows: (i) water regulation in terms of the ecosystem’s water storage potential in determining the rate of aquifer recharge (regulating service); (ii) livestock pastureland (provisioning service); (iii) biomass fuel (provisioning service); and (iv) freshwater (provisioning service). The identification of priority services was based on significance to local communities and the number of spatial alternatives in the landscape. On-site mitigation measures are collated in the ecosystem services chapter of the ESIA. As described above, a multi-disciplinary Monitoring and Evaluation Programme for water impacts on vegetation, pasture quality, and critical ecosystem services is being developed by the Project.

OT has conducted a comprehensive assessment of project impacts on cultural heritage, including archaeological and paleontological surveys, ethnographic assessment and extensive stakeholder consultations.

The area is rich in archaeological and paleontological heritage, including both physical artifacts, ritual sites, places of cultural or historical interest, fossil sites and protected landscapes (‘tangible’ heritage) together with rituals, ceremonies, folklore, music, handicrafts, and traditional knowledge (‘intangible’ heritage).

Ritual sites include ovoos, stone or wooden structures built on historically, culturally or religiously significant places or a particular mountain or hill that is located separately from other mountain ranges, and stupas – religious monuments made of bricks, mud, wood, and other materials. Ovoo rituals also represent a very important part of the traditional spiritual practice that links local communities to the land.

Intangible cultural heritage in the region include rituals and worship performed in local monasteries, such as daily Tsogchin chanting, Gombo sutra, meditation on the 25th of every lunar calendar month, and the 15-day meditation on the Lunar new year. In addition, local crafts and traditions identified as intangible cultural heritage include: (i) metal smithing; (ii) Urtiin duu singing; (iii) Tradition of Tsulkhir and Bajuun flour making; (iv) animal brands used by herding families as symbolic inheritance from their ancestors; (v) a tradition of making Mongolian ger and ger facilities; (vi) deity images and ritual worship objects inherited from ancestors; (vii) traditional food and diet adhered to by herding families; (viii) kin relationships and the knowledge of kinship affiliation; (ix) the game of Building Stone Gers; (x) the game of Ankle Bone Shooting (Shagai); (xi) traditional taboos of Gobi people inherited within herding families; and (xii) local Buddhist and shamanist practices.

An Ethnographic Assessment has been conducted to identify and record sites of spiritual significance in the areas of the OT - Gashuun Sukhait road, transmission line pylons, water pipeline, and the new airport. This assessment was carried out by the Institute of History (Department of Ethnology and Anthropology) of the Mongolian Academy of Sciences.

The Company has developed measures for minimizing and mitigating impacts and these are presented in the OT Cultural Heritage Management Plan, which is included in the ESIA.

The OT Code of Behaviour includes cultural heritage sensitivities. The observance of the Code of Conduct is ensured through regular refresher training, control by responsible supervisors and application of the prescribed disciplinary measures in case of breaches.

Cultural Heritage Programme (CHP)

In order to minimize and mitigate the impacts on tangible and intangible cultural heritage, OT has developed a Cultural Heritage Programme (CHP) as part of its CHMS. The CHP involves three phases, the first of which was conducted between July 2010 and March 2011. The CHP is considered a living document that will continue to be updated. The main aims of Phase I were: (i) to prepare an inventory of cultural heritage resources; (ii) to understand potential changes to these resources through the OT Project; (iii) to conduct a risk assessment of threats and risks to these resources; and (iv) to prepare documentation and literature on the resources for the benefit of the Mongolian people. Research for Phase I investigations was conducted in Khanbogd, Manlai, Bayan-Ovoo and Dalanzadgad soums. Phase II of the CHP (April to July 2011) defined a long-term strategy for the protection of tangible and intangible cultural heritage resources of the Omnogovi aimag.

Consultations and stakeholder meetings have been the integral elements of the CHP. A series of stakeholder meetings held in 2010 enabled the establishment of an Advisory Board to counsel the Project on the cultural heritage concerns of key stakeholders. The Board comprises 15 members of the local community, interested parties, archaeological organizations and a representative of OT.

As part of the CHP, OT has also supported the restoration of Demchig Monastery which has since become a focus point for visitors as well as locals. Support for traditional crafts, museums and cultural festivals have been also provided as part of CHP.

Archaeological and Paleontological Heritage and Chance Find procedure

For all areas where ground disturbance activities will take place, including the open pit and other excavations, there is a chance finds procedure developed in consultation with Rio Tinto’s cultural heritage advisors. The procedure is designed to ensure the safety, integrity and proper handling of any previously undocumented objects of cultural or historical significance, including archaeological assets and paleontological features. Observance of the procedure is mandatory for all OT employees and contractors.

To date, the principal mitigation measure for archaeological impacts has been a number of rescue excavations undertaken jointly with Ulaanbaatar State University, Mongolian National University, Mongolian State University of Education, Archaeology Department of Mongolian Academy of Science (MASIA), Ulaanbaatar. The principal mitigation measure for paleontological impacts has been on-site monitoring by paleontologists during earthmoving activities in sensitive areas, and a number of salvage excavations undertaken by the Paleontology Centre, Mongolian Academy of Science, Ulaanbaatar.

OT’s comprehensive stakeholder engagement activities are guided by the Stakeholder Engagement Plan (SEP), which has been developed to manage the many aspects of stakeholder engagement by the company and it is publicly available from OT’s web-site.

OT’s stakeholder engagement builds upon Rio Tinto’s “Communities Standard” described in Performance Standard 5 above . It specifically deals with the principles of consultation and engagement and is closely aligned with the IFC Performance Standards and EHS Guidelines and EBRD’s Environmental and Social Policy.

Multiple stakeholder engagement and public consultations activities have been undertaken as part of the ESIA. Stakeholder identification was conducted in 2008 in a comprehensive workshop with community relations staff and other OT departments, including Environment, Communications, Human Resources and Procurement. A comprehensive list of stakeholders was developed from this process and is continually being updated. The stakeholder mapping process has been used to define the appropriate level and types of engagement required for the different affected parties.
A number of methods of stakeholder engagement are used, including: (i) meetings with Government Representatives such as collaboration with the SGRDC; (ii) household visits and consultations; (iii) surveys and interviews; (iv) focus group discussions and workshops; (v) participation in local community meetings (Bagh Khural); (vi) participation in public events, education and outreach; (vii) site tours for local community members.
OT has developed a schedule and Action Plan based on results from the assessment of the stakeholder engagement programme to date. The action plan identifies target groups and the specific range of engagement activities required for each stakeholders group. The Action Plan is included in the SEP.
In addition, OT has developed a specific community consultation plan to ensure effective engagement with local communities prior to, during, and after the Undai river diversion (Undai River Diversion Plan). The plan contains the methods and recommendations for ongoing engagement with local herders living near the Undai river, as well as the wider herding community in Khanbogd soum, government authorities, and other stakeholders who may be affected by or interested in this specific component of the Project. The Undai River Diversion Plan is included in the SEP.
Community Development and Community Agreements
Community development projects have been in place since 2004 at OT. The five core programmes for health, education, local business development, cultural heritage and herder support have been central to community consultation and engagement efforts conducted by the Project during exploration and early works construction. As a result, numerous local communities, NGOs and other partners have been engaged with the Project.
OT has actively sought to develop long-term community development initiatives within its target soums. A series of regional community development programmes have been launched including: (i) Herder Livelihood Improvement Program; (ii) Local Business & Economic Development Program; (iii) Cultural Heritage Programme (CHP); (iv) Community Health, Safety, and Security Programme (CHSSP); (v) Participatory Environmental Monitoring (PEM) Programme by stakeholders for the Project; (vi) Local Supplier Development Program, with programmes started in Khanbogd, Dalanzadgad, and Ulaanbaatar; and (vii) Local and Regional Planning and Infrastructure (LRPI) Program.
OT began development of Community Agreements with local communities and soum/aimag authorities in September 2010, in accordance with Article 42 of the Minerals Law and with the Rio Tinto Communities Standards.
OT has engaged local NGOs and specialist “community visioning” consultants to facilitate the development of a clear and broad-based community vision for each of the four target soums around the Project. This exercise is also intended to result in the development of strategic community development plans and programmes for each soum.
Visioning exercises have been completed with all target communities and a range of government and non-government stakeholders. A Steering Committee was established to guide the process and identify participants, and facilitate the future agreements. This included aimag and soum authorities, herders and elders representatives, local women’s and youth NGOs, business representatives and OT. It is expected that formal agreements will be finalized with communities before production begins.
Grievances procedure

OT has implemented a comprehensive Community Grievance Procedure, described in the SEP.
As part of the community grievance process, grievances are required to be categorized, so that the type of complaint being reported can be readily identified. Complainants/Aggrieved Persons or OT may complete the classification of grievances. When public grievances are reported, the Community Grievance Procedure (a six-step process) shall be invoked to ensure containment and resolution of grievances. Detailed actions required for each step are outlined in the procedure, together with the key responsibilities for each step in the community grievance process. The grievance process and a summary of grievances will be report to the community through the Khanbogd soum government and Citizen’s Khural at regular intervals, to be determined by the Mediation Committee

The Community Relations department is responsible for ensuring that community grievances are adequately managed and resolved, including coordinating the receipt of and response to all complaints / grievances. Relevant OT managers actively participate in and are responsible for helping to resolve complaints that relate to their technical areas, e.g. environment, engineering, construction etc. All contractors and relevant suppliers are required to follow and implement the Community Grievance Procedure.
Consultation and Disclosure of the ESIA
OT has a dedicated website (http://www.ot.mn) which is in both Mongolian and English. The website contains background information about the Project, policy documents, as well as current details about activities being undertaken and key Project milestones. A range of environmental and social reports are disclosed on this website including a copy of the ESIA and SEP.
OT prepares a monthly info sheet in Mongolian for local communities. The info sheet has been in place since January 2009 and is used to keep local people regularly up to date with Project related activities and issues.
Print media, television and radio are used by OT to provide updated information about the Project. Specific articles have been published following key milestones in the Project development process.
Disclosure and consultation on the consolidated ESIA and Management Plans will be undertaken to ensure that the affected parties are fully aware of the environmental and social impacts that may affect them and OT’s commitments towards minimizing and managing such impacts.
General activities will include the following: (i) the ESIA (including a Non technical Summary) and Management Plans will be released by OT on its website, and will also be available in OT branch offices in the south Gobi, other public locations in the south Gobi (see below), and at the Oyu Tolgoi Information Center in Ulaanbaatar; (ii) disclosure of the ESIA documentation will be in Mongolian and English, as relevant to the location where it is being disclosed; (iii) Fact Sheets on key ESIA themes/topics and commitments by OT to manage impacts will be prepared in Mongolian for local disclosure. Fact Sheets will include information in a culturally- appropriate format for residents in Khanbogd, Manlai, Bayan Ovoo and Dalanzadgad soums; (iv) OT will advise people e.g. through the website, advertorials, in newsletters, one-on-one meetings, advisory groups and the media etc, on how they can access a copy of the updated ESIA documentation, as well as the timetable and process for making comments on the ESIA; (v) OT will engage with local communities and relevant local, regional and national authorities on the content of the ESIA / Management Plans to discuss key social and environmental impacts and mitigation measures that may affect them; (vi) OT will provide appropriate mechanisms for stakeholders to provide feedback on the ESIA documentation, including through a response mechanism on the OT website, through comment boxes at branch offices in the Project area and through regular contact with community relations staff as part of routine consultation activities; and (vii) lenders will provide project information and website links to the OT website in accordance with their own disclosure policies.

The key documents will also be available for review at public locations throughout Omnogovi aimag and in Ulaanbaatar, including:

OT LLC offices in Khanbogd soum centre, Manlai, Bayan-Ovoo, and Dalanzadgad
OT LLC website ot.mn/en/about-us/environmental-social-impact-assessment/esia
Additional locations in Omnogovi:
Khanbogd: Ceremonial House (Yosloliin Urguu)
Manlai: Information Hall, Governor’s Office
Bayan-Ovoo: Secondary School
Dalanzadgad: Central Library and the Citizen’s Hall
In Ulaanbaatar: Oyu Tolgoi Information Centre.
Comments or questions can be submitted by email: mailto:OTESIA@ot.mn or by using drop-boxes (forms and drop boxes can be found at the locations listed above.)

*ICP - Information Consultation and Participation **BCS - Broad Community Support

Oyu Tolgoi(29007) Appraisal Disclosure Snapshot – Version 2
Description	Anticipated Completion Date
Power Plant Environmental and Social Impact Assessment (ESIA) : For a Power Plant that is part of the Project as defined by Lender Policies, OT LLC will deliver to the Independent Environmental & Social Consultant (“IESC “) a Power Plant Environmental and Social Impact Assessment ( Power Plant ESIA), in accordance with the timeframes mandated by the Investment Agreement. This Power Pant ESIA will be prepared in accordance with Applicable Lender Environmental and Social Standards and applicable Environmental and Social Laws. Applicable “Environmental and Social Laws” to be defined by reference to list of laws specified in the Power Plant ESIA as in effect at the date of the Power Plant ESIA. The IESC will confirm to OT LLC when it is satisfied that the Power Plant ESIA is consistent in all material respects with Applicable Lender Environmental and Social Standards . OT LLC will publically disclose the Power Plant ESIA as approved in accordance with Applicable Lender Environmental and Social Standards.	31-Dec-2016
Biodiversity Action Plan (BAP) OT LLC will implement mitigation and other measures identified in the BAP in accordance with the BAP schedule. OT LLC will report to the lenders on the status of the BAP implementation.	31-Dec-2014
Operations Phase Environmental and Social Management Plans (OESMPs): OT LLC will deliver to the IESC the OESMPs for review in accordance with Applicable Lender Environmental and Social Standards “Applicable Lender Environmental and Social Standards” to be defined by reference to agreed lists of relevant performance standards specified in the Project ESIA as in effect at the date of the Project ESIA.. The IESC will confirm to OT LLC when it is satisfied that the OESMPs are consistent in all material respects with Applicable Lender Environmental and Social Standards. The OESMPs will address the following issues: § Air Quality Management (including Greenhouse Gas Emission Management); § Noise & Vibration Management; § Topsoil Management; § Petroleum & Fuels Management; § Biodiversity Management; § Water Resources Management; § Waste Management; § Waste Rock Management; § Tailings Management; § Transport Management; § Hazardous Materials Management; § Emergency Response; § Occupational Health and Safety; § Cultural Heritage Management; § Stakeholder Engagement; § Resettlement Action; § Influx Management; § Labour Management; § Community Health, Safety & Security Management; and § Mine Closure Management.	31-Dec-2012
Mine Closure Plan: OT LLC will deliver to the IESC a Mine Closure Plan prepared in accordance with Applicable Lender Environmental and Social Standards. The IESC will confirm to OT LLC when it is satisfied that Mine Closure Plan is consistent in all material respects with Applicable Lender Environmental and Social Standards. Future updates will be in accordance with the mandated schedule for updates required under Mongolian Regulations, at that time any changes will also be aligned with the OESMPs	31-Dec-2012
Worker Housing Development: OT LLC will develop the Khanbogd water supply. OT LLC will undertake consultation and other appropriate engagement with local stakeholders on the proposed water supply, in accordance with Applicable Lender Environmental and Social Standards, when information is available from water resource assessment studies. Based on this work, OT LLC will deliver to the IESC a draft report on the options for the water supply. OT LLC will deliver to the IESC a Worker Housing Development ESIA prepared in accordance with Applicable Lender Environmental and Social Standards and applicable Environmental and Social Laws, (Applicable “Environmental and Social Laws” to be defined by reference to list of laws specified in the Worker Housing Development ESIA as in effect at the date of the Worker Housing Development ESIA.) including the approval of any site agreed with GOM for review and approval by the Lenders. The Worker Housing Development ESIA will provide details on planned measures to mitigate impacts to biodiversity and ecosystem services (e.g., herder wells) associated with water supply and worker housing development for the community of Khanbogd. The IESC will confirm to OT LLC when it is satisfied that Worker Housing Development ESIA is consistent in all material respects with Applicable Lender Environmental and Social Standards OT LLC will publically disclose the Worker Housing Development ESIA as approved in accordance with Applicable Lender Environmental and Social Standards.	31-Dec-2014
Industrial Estate: OT LLC will deliver to the IESC an Industrial Estate ESIA prepared in accordance with Applicable Lender Environmental and Social Standards and applicable Environmental and Social Laws, (Applicable “Environmental and Social Laws” to be defined by reference to list of laws specified in the Industrial Estate ESIA as in effect at the date of the Industrial Estate ESIA) for review and approval by the Lenders. The ESIA will provide details on planned measures to mitigate impacts to biodiversity and ecosystem services associated with industrial estate development. The IESC will confirm to OT LLC when it is satisfied that Industrial Estate ESIA is consistent in all material respects with Applicable Lender Environmental and Social Standards. OT LLC will publically disclose the Industrial Estate ESIA as approved in accordance with Applicable Lender Environmental and Social Standards..	31-Dec-2014
Pastureland Management System: OT LLC shall deliver to the IESC a Pastureland Livelihood and Improvement Strategy in accordance with Applicable Lender Environmental and Social Standards. The Pastureland Livelihood and Improvement Strategy is expected to: (i) include Key Performance Indicators for monitoring effectiveness of implementation, (ii) be developed in consultation with local stakeholders, community members, and the specialists involved in the design and implementation of the Biodiversity Offsets Strategy and (iii) have a design consistent with the objectives of the Biodiversity Offsets Strategy and the BAP. The IESC will confirm to OT LLC when it is satisfied that Pasture Livelihood and Improvement Startegy is consistent in all material respects with Applicable Lender Environmental and Social Standards. Based on the Pastureland Livelihood and Improvement Strategy, OT LLC shall deliver to the IESC a Pastureland Livelihood and Improvement Plan in accordance with Applicable Lender Environmental and Social Standards. The Pastureland Livelihood and Improvement Plan will be a fully detailed management plan that (i) incorporates all relevant aspects of the updated Resettlement Action Plan, (ii) incorporates all relevant aspects of the Biodiversity Offset Management Plan(s), (iii) is integrated into the Monitoring and Evaluation Program for critical ecosystems services and for Livelihood Improvement Program, (iv) employs an integrated implementation and monitoring approach across the OT LLC environmental and social teams.	31-Dec-2014
Concentrator Expansion Reports: OT LLC will deliver to the IESC a Concentrator Expansion Report for any concentrator expansion for production rates above 100,000 tonnes per day (tpd) and any material expansion thereafter for review and disclosure (if required) in accordance with Applicable Lender Environmental and Social Standards. The Concentrator Expansion Report will provide details on planned measures to mitigate impacts associated with this expansion and document that OT LLC has: a) maximized practicable opportunities for water recovery (e.g., from the tailings storage facility) and water reuse so as to minimize the additional groundwater withdrawals associated with this expansion; b) performed necessary hydrogeological studies to confirm the availability of any additional water supplies required in connection with the expansion and that the extraction of this additional water will not have adverse effects on any other users of such additional water (e.g., biodiversity, herders), after taking into account the implementation of any mitigation measures; c) either obtained the necessary permits/approvals from the Government of Mongolia for any such required additional groundwater or submitted applications for such permits/approvals; d) evaluated biodiversity and social impacts associated with increased vehicular traffic associated with the expansion; and e) evaluated the cumulative effects associated with the expansion.. The IESC will confirm that it is satisfied that each Concentrator Expansion Report is consistent in all material respects with Applicable Lender Environmental and Social Standards. A Concentrator Report may involve, where applicable, revisions to relevant Environmental and Social Management Plans.	31-Dec-2014
Independent Environmental and Social Monitoring Program: OT LLC will develop a 3rd party Independent Environmental and Social Monitoring Program, and submit a a Terms of Reference to be approved by the Lenders. The Lenders will confirm that they are satisfied that the Independent Environmental and Social and Monitoring Program is consistent in all material respects with Applicable Lender Environmental and Social Standards. It is expected that the Terms of Reference will require the IESC to conduct regular monitoring visits at the cost of OT LLC and prepare monitoring reports for public disclosure (after review and comment by the Lenders and OT LLC). Such monitoring will include the implementation of the ESMPs and ESAP.	31-Dec-2012
Environmental & Social Reports: OT LLC will prepare and submit to Lenders annual Environmental and Social Reports in a agreed form to include a report on the implementation of the ESMPs and ESAP.	31-Dec-2016
Transmission line from Oyu Tolgoi to Khanbogd soum centre: OT LLC will deliver to the IESC an environment and social appraisal for the Transmission line from Oyu Tolgoi to Khanbogd soum centre (Transmission Line Appraisal). The IESC will confirm whether it is satisfied that the Transmission Line Appraisal is consistent in all material respects with Applicable Lender Environmental and Social Standards. OT LLC will publically disclose the Transmission Line Appraisal as approved.	31-Dec-2012
Oyu Tolgoi - GSK Road diversion: OT LLC will deliver to the IESC an environment and social appraisal for the temporary Oyu Tolgoi - GSK Road diversion (Road Diversion Appraisal) . The IESC will confirm whether it is satisfied that the Road Diversion Appraisal is consistent in all material respects with Applicable Lender Environmental and Social Standards. OT LLC will publically disclose the Road Diversion Appraisal as approved.	31-Dec-2012
Update of Resettlement Action Plan (RAP): OT LLC shall deliver to the IESC an updated Resettlement Action Plan (RAP) taking into consideration; (i) Latest information on the project and its impacts (ii) The updated compensation procedure (iii) Pastureland and Livelihood Improvement Strategy (iv) Outcomes of stakeholder engagement activities, including CAO process (if available and relevant); (v) Co-operation agreement (if available and relevant) (vi) Various planned socio-economic assessments and an audit of the compensation program to be completed in 2014. The IESC will confirm whether the updated RAP is consistent in all material respects with Applicable Lender Environmental and Social Standards. OT LLC will publically disclose the updated RAP as approved.	31-Dec-2014