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
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the above Performance Standards.
This project will not have adverse impacts on indigenous peoples’ lands and thus PS7: Indigenous Peoples is not part of the scope of this review.

PHR is a Category A project because of the potential significant and irreversible impacts on the Mesoamerican biological corridor which is considered critical habitat, the ecological integrity of the Reventazón River, and on the complex and ecologically sensitive downstream Reventazon – Parismina – Tortuguero hydro-biological system.

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. In addition to the typical environmental, social and health and safety (ESHS) impacts and risks associated with any large hydropower construction activity (e.g. dust and noise emissions, wastewater, solid and hazardous waste generation and disposal), the principal potential environmental and social impacts of concern are: (a) potential interference on the connectivity of the Barbilla-Destierro Biological Sub-Corridor (SBBD) which may adversely affect ecological processes; (b) disruption on the ecological integrity and migratory fish pathways of the Reventazón River aquatic natural habitat; (c) uncertainty of the effects to the complex and ecologically sensitive downstream Reventazon–Parismina–Tortuguero hydro-biological system; (d) acquisition of 2,000 hectares of land involving some vulnerable families; (e) white water rafting (WWR) operators downstream of the project; and (f) dam safety and downstream emergency and community preparedness.
The sections that follow describe how ICE expects to manage the significant potential ESHS impacts and risks of the Project, as well as any additional mitigation measures described in the Lenders Supplemental Environmental, Social and Health and Safety Action Plan (ESAP) necessary to ensure compliance with the IFC Performance Standards (PS) on Environmental and Social Sustainability and other Lenders environmental and social policies and requirements.

Environmental and Social Assessment
ICE originally developed a very comprehensive Environmental and Social Impact Assessment (ESIA), substantially aligned with good international industry practice (GIIP) and with PS1. The scope of the ESIA includes all ancillary infrastructure such as the transmission line, access roads, quarries, disposal areas, among others. It was submitted to the Secretaría Técnica Nacional Ambiental (SETENA, http://www.setena.go.cr), and approved in 2009 (Resolution SETENA Nº 1778-2009). This ESIA presents an extensive environmental and social baseline identified impacts and risk (for a summary see ESIA Chapter 11 matrixes 11.16.1-7 pp1170-1181), and developed a preliminary set of management measures (for a summary refer to Chapter 12, Table 12.1 pp 1186-1247).
Reventazon HPP Early Disclosure

In 2011, and owing to the involvement of multilateral development financiers, ICE prepared a series of complementary environmental studies
Reventazon HPP Early Disclosure

to further strengthen ICE’s assessment and management in some key areas. These studies were divided in two consecutive phases and had the main purpose of better defining the detailed actions ICE needs to implement with regard to: (a) potential impact on the connectivity of Barbilla-Destierro Biological Sub-Corridor (SBBD), (b) residual adverse impacts on the Reventazón River aquatic habitat, and (c) uncertainties associated with potential adverse environmental and social impacts on the complex and ecologically sensitive downstream Reventazón – Parismina – Tortuguero hydro-biological system. In addition, the complimentary studies also (d) strengthened ICE’s land acquisition and involuntary resettlement framework to comply with IADB’s and IFC’s resettlement standards and policies, (e) assessed and developed a protocol to determine GHG emission from the reservoir, and (f) expanded the Cumulative Impacts Assessment of multiple hydroelectric projects in the Reventazón River.
The impacts related to the Transmission Line are not significant, it is less than 2 km long and its footprint will be mostly limited to transmission tower foundations. Improvement and/or construction of new access roads are expected to be minimal. Potential impacts can be avoided and mitigated through the incorporation of impact control and management procedures.
Alternative Analysis
There are four specific hydropower projects with a capacity greater than 100 MW considered in ICE’s proposed expansion plan: Reventazón (314 MW), Diquis (608 MW), Savegre (160 MW) and Pacuare (167 MW). Diquis raises more complex and highly sensitive environmental and social issues, including physical displacement of indigenous communities (http://unsr.jamesanaya.org/special-reports/la-situacion-de-los-pueblos-indigenas-afectados-por-el-proyecto-hidroelectrico-el-diquis-en-costa-rica-2011), Savegre and Pacuare are located on rivers which are still free flowing, and have each about half of the nominal capacity of Reventazón.
On the other hand, the Reventazón River is already impacted by three hydropower projects currently in operation, and its potential environmental and social adverse impacts are likely to be less significant and easier to manage than those caused by any of the other three new large hydropower project alternatives. Additional hydropower development in the Reventazón River had been identified by ICE since the late 1990’s. The initial Project design contemplated a reservoir at a level of 380 meters above sea level (masl) and implied a significant physical displacement of affected communities and flooding of nationally important wetlands. The prefeasibility analysis carried out in 2003 identified various design options, and the final recommendation proposed a dam maximum operating level of 265 masl, thus reducing the size of the reservoir and therefore the project’s environmental and social footprint.
Cumulative Impacts
The cumulative effects analysis performed as one of the complimentary studies required by the Lenders, identified the following key potential impacts over Valued Environmental and Social Components (VECs) or sensitive receptors: (a) contribution to the continued alterations to terrestrial habitats and final conversion of aquatic and riparian habitat of the Reventazón River, (b) incremental changes in water quality and sediment dynamics, and (c) potential undefined contribution to the continued degradation of the downstream wetlands.
The cumulative effects identified have management strategies defined either as part of the environmental management plans and procedures included in the ESIA and/or as part of the ESAP. These proposed management strategies and actions are described below under the applicable Performance Standard.
It should be noted that since the beginning of ICE’s intervention in the Reventazón in the 1960’s, the company has recognized the need to identify and manage the cumulative impacts and risks of multiple hydro electric power developments in the same river, especially with regard to watershed management, land use changes, and erosion control. For instance, at the time that Cachi HPP was being constructed, ICE purchased a total of 110,000 ha of the Reventazón upper watershed and on the 23rd of January 1964 it created the first Forestry Reserve in Costa Rica: Reserva Forestal Rio Macho. When the Protected Areas National System was created ICE transferred this Forestry Reserve to the Environmental Ministry (MINAET – Ministerio del Ambiente, Energía y Telecomunicaciones) who created the National Park Tapantí – Macizo de la Muerte, that together with the La Amistad Biosphera Reserve constitute the biggest protected area of Central America encompassing a total of 500,000 ha.
A key recommendation of the cumulative effects assessment and management study is that ICE uses best efforts to assure that the Comisión de Manejo y Ordenamiento de la Cuenca Alta Río Reventazón (COMCURE http://sites.google.com/site/comcurecr/Home) mandate is extended to include the mid and lower Reventazón watershed. The COMCURE was created via Law 8023 with the main mission to protect the Reventazón Watershed. ICE has led the COMCURE since its inception, and was a key contributor to the development of the watershed management plan PREVDA - Programa de Reducción de la Vulnerabilidad y Degradación Ambiental. The PREVDA has the participation of local governments, academic and research institutions, local producers and cooperatives, for a total of 27 institutions, 13 cooperation agreements (convenios de cooperación), and involves over 90 professionals. The PREVDA has five (5) lines of actions: (a) sustainable development and increased agro-forestry productivity, (b) management of forest cover, (c) stream rehabilitation and erosion control, (d) environmental education and capacity building, and (e) biological monitoring. Because of its good management and importance for Costa Rica, the Reventazón Watershed is one of the few watersheds in Latin America included in the UNESCO International Hydrological Program – HELP: Hydrology for the Environment, Life and Policy, (http://www.unesco.org/new/en/natural-sciences/environment/water/ihp/ihp-programmes/help/). COMCURE’s work and PREVDA implementation has been very successful. Overall benefits are tangible, with 1555 producers benefitted over that last 10 years, more than 2 million new trees planted, resulted in an 11% (16,000 ha) improvement of forest cover in the upper basing, and a measurable reduction of approximately 7% of the sediment load into the existing reservoirs from the watershed.
Management Program
The original ESIA has an extensive Environmental Management Program (PGA - Plan de Gestión Ambiental) with close to 150 programs and actions, including but not limited to: (a) construction pollution prevention and control (e.g. noise, emission, wastewater discharges), (b) erosion control, water drainage management and protection/ restoration of vegetal cover, (c) solid and waste management, (d) occupational and health and safety measures and indicators, (e) fauna and flora rescue and re-introduction plans, (f) amphibian and fish in-captivity breeding and re-introduction, (g) fish capture and release (hauling) from downstream river reaches to areas upstream of the dam, (h) restoration of biological corridor connectivity via reforestation, payment for ecological services (PES) or even considering a fauna bridge over the reservoir, (i) use of bird collision devices in the transmission line, (j) reforestation and watershed management, (k) land acquisition, compensation and some income restoration programs, (l) community engagement and capacity building, (m) local hiring and transport facilitation for local hires, and (n) several improvement of impacted communities infrastructure and facilities (e.g. community health posts, schools, access road, community centers, telecommunications, water storage, aqueducts and water supply, among others). These plans and procedures are not conceived nor presented as part of an Environmental, Social and Health and Safety Management System (ESHS-MS), but as individual actions to manage specific identified impacts and/or risks.
The execution of the PGA has an expected cost of about US$17MM. This cost does not include the incremental investment associated with several modifications to the project design and operation scheme that took place as a result of the ESIA process, such as: (a) small 13.5-MW Francis-turbine mini-hydro to allow for the release of a minimum of 15 m3/s and avoid drying up the dewatered segment during the dry months, (b) modification from originally three 96-MW Francis-turbines to four 73-MW Francis-turbine to allow for a permanent release of additional 25 m3/s to meet the 40 m3/s social and ecological flow needs downstream from the powerhouse, and (c) construction of a bridge over a creek of documented rich amphibian biodiversity, Quebrada Guayacán, instead of the originally planned enclosed tunnel, to assure that the penstock river-crossing over this affluent, would not negatively impact the ecological integrity of this Quebrada. Furthermore, the social component alone of the PGA encompasses 115 preventive, mitigation, and compensation actions.
As it will be further described in subsequent sections, as a requirement for IFC’s financing, and based in the complimentary studies performed to address the broad issues and key gaps of the ESIA, ICE developed a mitigation strategy and management framework. This strategy includes: (a) ESHS-MS: enhance current ICE’s environmental, social and occupational health and safety plans and procedure, into an ESHS-MS according to PS1 requirement and GIIPs, (b) Critical Habitat: protecting, restoring, and improving the structural connectivity of the biodiversity corridor at the tail of the reservoir via conservation and reforestation efforts, and developing tracking and monitoring mechanism to assure enhancement of the corridor’s functional connectivity, with the ultimate objective of documenting net positive gain over time; (c) Residual Impacts on Natural Habitat: offset the residual direct impact on the aquatic natural habitat, by identifying, restoring/conserving/protecting an ecologically similar river system as a healthy and free flowing aquatic habitat; and (d) Adaptive Management: develop a monitoring/supervision protocol with clear environmental and social indicators and associated thresholds to detect and mitigate any significant unpredicted downstream impact. To improve management of social impacts and risks, this strategy focused on development and implementation of (e) a Social Management Program that includes the following building blocks: (i) Stakeholder Engagement Plan; (ii) Strategic Resettlement Framework and Livelihood Restoration Plan; (iii) participatory water resource management; (iv) environmental education; (vi) Community Investment; and (vi) Social Monitoring Program.
Organization
ICE is a mature organization that has a very competent and large in-house environmental and social expertise. It is made up of not only of Costa Rican top researchers and experts, but some of them are recognized global expert in their respective fields. ICE has close to 100 specialists – not including the preventive medicine, doctors and occupational health and safety team – divided in five units: biology, forestry, social/community relations, archeology, and civil work construction supervision and waste management. In addition, the core team has two additional units involved in property valuation and watershed management/municipalities engagement.
Currently, each new-project’s ESHS unit works independently from ICE at the corporate level, and there is no formal nor independent ESHS supervision and reporting process. As a requirement for IFC’s financing, ICE will create an independent Environmental and Social Monitoring and Supervision Unit for the PHR that will be anchored and report to ICE at the corporate level.
Monitoring
In addition to SETENA’s monitoring of ICE’s execution of the PGA, as noted above, ICE will establish an independent ESHS Monitoring and Supervision Unit to ensure all monitoring activities called for in the ESIA and PGA are carried out, including basic pollution prevention and control emission, discharges, and noise monitoring activities. Finally, an Independent Environmental and Social Consultant (IESC) will be appointed by the Lenders to supervise compliance with the legal agreement, including ESAP implementation.
Environmental monitoring is further described in PS3 and PS6 sections. Social monitoring includes: (a) biannual update of the social baseline, (b) monitoring of river use in the critical trench (4.2 km between the project dam and the point of water release at the power house), (c) daily monitoring of affected roads (use and frequency), (d) noise measurements in critical points, (e) quarterly monitoring of impacts related to workers influx, and (f) underground water resource monitoring along the conduction tunnel.

Human Resources Policy and Management
ICE is a state-owned company and the Human Resources policy and procedures applied to the Project are based on Costa Rican labor regulations, which are aligned with the ILO Core Labor Conventions regarding freedom of association, forced labor, discrimination, and child labor, of which the country is signatory. The Company will improve its labor procedures by implemented a Workers Redress Mechanism as per PS2. All workers at project site receive copies of their labor contracts and are entitled to all the benefits dictated by law, such as contribution to pension and health insurance.
Total workforce at construction peak is estimated to be 3300 workers; mostly ICE’s direct employees (2925) and only a minority of approximately 375 workers will associated to contractors. Approximately 80 workers will be employed during plant operation. As per ICE’s institutional policies and ESIA’s commitments, the supply of unskilled and skilled local labor for the construction and operation will be maximized to the extent possible in close coordination with local communities’ representatives. To date 58 % of the construction workforce has been hired from nearby communities.
Current work schedule for the Project’s administrative personnel is of forty eight hours per week, which in compliance with the Costa Rican Labor Code, allows for an additional free day that can be flexibly used. Construction workers have special schedule arrangements depending on their specific tasks. For instance, tunneling crews are divided in two 12-hours daily shifts for 11 continue days with 3 days of leave. Construction works are undertaken complying with the hours per week allowed by Costa Rican regulations.
Workers accommodations during construction activities are located at the Project site and have a capacity to host 1100 employees. Schedules and rotation calendars or workers staying at the camp site vary depending of their tasks, but in average they have 3 days of home leave for every 10 work days. These accommodations are in-line with international standards and those living at the camp have to abide by a Code of Conduct which addressed, among other, conduct (e.g. alcohol consumption) and environmental issues (e.g. minimization of energy and water use, waste management, etc). There is a Project-level chapter of a national workers union within the Company with about 250 unionized workers to date. The workers union has a fluid communication with the Project’s management and conducts monthly meetings. ICE will directly employ the majority of the workforce required for the Project, with only a minority of workers to be engaged through subcontractors who also are required to abide by the Project’s labor regulations.
Occupational Health and Safety
ICE has a consolidated Occupational Health and Safety (OHS) team who has developed policies and procedures, sets targets and indicators for all business units, provides training and performs capacity building events, supervises/ audits compliance, ranks the business units and reports status, issues and proposed corrective actions to ICE’s upper management. ICE’s Occupational Health and Safety Management System follows GIIP and it is constituted by fifteen core procedures that assure appropriate occupational risk assessment and management for all applicable tasks, and training requirement/ limitation for each task, as well as indicators and targets to monitor performance. These procedures include: (a) occupation risks identification and documentation process, (b) critical tasks analysis (e.g. working in heights, working in confined spaces, tunneling, blasting and working with explosives, working near water, welding, among others), (c) mandatory use of Personal Protection Equipment (PEP), (d) contractor requirements and supervision, (e) behavioral-based safety indicators, (f) emergency preparedness and response, and (g) training.
This Department also follows the general health of employees, and include: (h) employee/worker entrance physical exams, (i) monitoring of the health conditions of workers/employees to assure good working environment, (j) actions to avoid spread of contagious or sexually transmitted diseases, and (k) providing proper ergonomic conditions, and hearing and visual protection.
The Occupational Health and Safety Department is made up of one hundred and forty four (144) professional, including a total of six (6) specialists working the corporate level for all generation projects. At the time of appraisal, there were a total of seventeen (17) OHS professionals working at the construction site.
In 2011, ICE as a whole reported a total of 23,323,153 man-hours worked, with an accumulated 889 LTI, for a frequency and incidence rates of 38 per million man-hours and 9 per thousand workers, respectively. For the same period, the PHR reported 5,311,992 man-hours with an accumulated 92 LTI, and better frequency and incidence rates than the corporate averages of 17 per million man-hours and 4 per thousand workers, respectively.
Since currently ICE does not monitor OHS performance of its sub-contractors, the above indicators relate only to direct ICE’s employees. At the PHR ICE has approximately 3 major subcontractors working on-site, and it is likely to hire 2 more over the construction period, totaling 375 of contracted workers. As a condition of IFC investment, ICE has agreed to develop a mechanism to monitor sub-contractors compliance with ICE’s own OHS policies and procedures.

Mitigation measures currently being applied at the construction site include standard construction pollution prevention and control measures, such as (a) noise monitoring and abatement measure, (b) tunnel excavation water discharge containment in sedimentation and pH compensation ponds and monitoring prior to discharge back into surface waters, (c) domestic/camp wastewater treatment, (d) equipment exhaust emissions control and monitoring, (d) erosion control, exposed slope re-vegetation and rain run-off water drainage and management measures, (e) solid waste and hazardous waste handling, classification, characterization and disposal, among others. Waste rock from the tunneling excavation works will be reused in concrete preparation and other civil works as much as technically feasible, and the remaining refuse waste will be disposed in a couple of licensed landfills located within the project site. All material required for the construction of the civil works is extracted from within the project area -mainly from the river bed- and extraction permits have been provided by the national authorities as part of the ESIA approval process.
During operation, the main water quality risk is associated with the potential infestation of the Reventazón reservoir with the water hyacinth. Existing ICE operated upstream reservoirs at Cachi and Angostura, show extensive coverage with this water pest, which is a known sign of reservoir eutrophication, reduces water storage efficiency (evapo-transpiration), may increase infestation of mosquitoes and other water-related pest, cause operational complication and increased costs. In the Cachi and Angostura reservoirs, the company has initiated a pilot program for the biological and mechanical removal of the water hyacinth. Capitalizing on the results of this pilot program, ICE will develop a Water Hyacinth Introduction Prevention and Dispersion Control and Monitoring Program for the Reventazón Reservoir.
ICE will closely monitor all the potential emergency situations, including (a) landslides, (b) earthquakes, (c) volcanic eruption, and (d) heavy rains and flooding. Furthermore, the Company will develop an early warning system, and when possible, immediate and middle term response measures. ICE has developed a Hydrological Prevention System (SPH - Sistema de Prevision Hidrológica) that allows to detect high flow and flooding situation in the Reventazón watershed. This SPH is currently a key risk management tool in the construction site, as it provides real-time information of the river water levels, and includes risk warnings that trigger evacuation from the different area of the construction site.
ICE will consolidate all these measures into an Emergency and Natural Disaster Management Plan, and this will be a component of the construction and operation ESHS-MS.
Gross greenhouse gases (GHG) emissions expected from the PHR’s reservoir are estimated to be around 400,000 teqCO2 per year, which based on the expected annual generation would translate in GHG emission intensity of around 0.19 teqCO2/MWh. From the perspective of net GHG emissions, the project is expected to be neutral, i.e. not to increase or decrease in any significant way the average GHG emissions intensity of the electrical grid in Costa-Rica, which heavily relies on hydropower generation. The details of this assessment can be found in Section I: Emisiones de Gases de Efecto Invernadero of the supplemental environmental studies that are part of IFC Early Disclosure implementation, and are based on the IHA 2010 GHG Measurement Guidelines for Freshwater Reservoirs.
The area to be flooded is composed mainly of pastures and limited patches of secondary forest. Aligned with GIIP, prior to flooding the reservoir ICE will selectively remove any forest cover for valued timber, improve access, navigation, and for aesthetic purposes. In addition, ICE has agreed to confirm the above preliminary estimations through actual measurements of GHG emissions during PHR’s operation.

During construction, the primary risks to community health and safety identified for this Project are associated with traffic safety, noise, and dust generated by the transport of materials, equipment, and workers to and from the Project site, which will mainly affect three (3) villages located along the two main access roads. To minimize risks on public health, disturbance in living conditions associated with its vehicular movements, ICE has put in place a series of preventive/mitigation actions/programs including: (a) earth roads watering, (b) periodic review of public health indicators associated to respiratory diseases, (c) noise measurement, and (d) vehicle controls in critical points and involvement of local transporters. Additionally, in order to minimize potential risks to pedestrians from increased traffic, ICE has also put in place a series of preventive mitigation actions/programs including: (e) building curves for pedestrians, (f) building protection walls in school facilities, (g) road signals, (h) vehicle control in critical points, (i) safety and defensive driver training, (j) contractual sanctions for traffic violators and (k) public safety campaigns.
During operation, the main risks associated with community health and safety relate to (a) a catastrophic event due to dam failure and (b) downstream flow daily fluctuation during peak generation.
ICE has extensive experience building hydropower project, applies best civil construction practices, and in its history it has never had any catastrophic dam failure event. At any case, ICE has hired an independent international external expert firm that is currently reviewing dam engineering design and will supervise construction twice a year, and the Lenders have hired an independent engineer to confirm design standards are consistent with GIIP.
Furthermore, together with the existing SPH - Sistema de Prevision Hidrológica, the PGA includes an Emergency Preparedness and Response plan which covers aspects such as dam failure or operations under extreme floods, and includes an early warning system, and a clear chain of command and notification to the communities and property owners potentially affected downstream. ICE has been successfully applying this communication procedure on an annual basis when the bottom flushing of Cachi and Angostura take place. All communities downstream are familiar with the procedure, are used to cooperating with ICE when reservoir flushing takes place, and understand the chain of command and lines of communication in case of emergencies and/or grievances.
Potential risks to community health associated with the creation of breeding areas for mosquitoes at the reservoir have been analyzed and are considered negligible, given the expected significant daily variations in the reservoir level. At any case, as part of its PGA the Company will monitor possible presence vectors and disease outbreaks that could be directly associated to the Project and will implement vector control and other mitigation measures accordingly.

ICE has focused a considerable amount of resources on identifying biodiversity values in the project’s area of influence and on developing a mitigation strategy. ICE has a well established understanding of the Reventazón River ecology based on extensive monitoring on a total of 25 sampling sites along the river with hydrological, hydro-morphological, water-quality, and biological –including fish and invertebrates- data that has been collected on a regular basis over the last 10 years. The project has considerable in-house capacity, including a large number of capable biodiversity (mainly fauna and flora) specialists. As highlighted in the subsequent sections, ICE has also engaged external experts and has consulted with reputable conservation organizations in the development of biodiversity-related assessments and mitigation.
Project-related biodiversity impacts can largely be described in terms of natural and critical habitat, and are as follows: (1) direct impacts on the aquatic natural habitat, potentially leading to residual impacts on the ecological integrity of the Reventazón River, which include the significant degradation / conversion of certain migratory fish pathways; and (2) direct and indirect impacts related to the reservoir’s location in a critical habitat, and the consequent potential barrier effect to the structural and functional connectivity of the SBBD corridor, which could affect key evolutionary processes (e.g. genetic flow of the Jaguar and other fauna and flora).
The sections below outline the project’s mitigation approach in both the aquatic natural habitat and the terrestrial critical habitat. These and other mitigation measures will collated in a Biodiversity Action Plan (BAP) to facilitate and monitor their timely implementation. ICE will also be developing its own overarching biodiversity policy to memorialize its commitment to biodiversity. The policy will spell out ICE’s commitment towards no net biodiversity loss in natural habitats and net gain in critical habitats.
Aquatic Natural Habitat
ICE developed an in-house 2 MM US$ hydro-ecological flow model (RANA), which incorporates social and biological data to determine downstream minimum flow regimes environmental and social impacts. Habitat preference curves were also developed for key (native) fish species to determine needs and potential habitat loss in the affected reaches. Through the ESIA process, using a considerable amount of data and the RANA model, ICE determined that: (a) no significant modification of the natural habitat would take place if there was a 15 m3/s minimum release in the dewatered segment; and (b) that a minimum of 40 m3/s would be required to sustain the ecological and social flow needs downstream of the powerhouse. If these two minimum flow conditions are met, the ecological integrity, including the existing assembly of fish and invertebrates, of the Reventazón River is predicted to be largely maintained.
From the outset this project design considered biodiversity amongst other environmental and social values. However, given the barrier effect caused by the dam, there are anticipated project-related residual impacts on migration pathways of the bobo and mountain mullets as well as the “chupapiedras”. On-site mitigation measures adhering to good practice will be implemented, such as fish and amphibian hatcheries with accompanying catch-and-release measures that aim to re-populate and compensate for these losses in the river upstream from the dam. Long-term success of these measures is not certain.
For this reason, and in order to address significant residual project-related impacts, ICE will also implement a biodiversity offset mitigation on an ecologically-equivalent free flowing river. Based on fluvial ecological criteria, which conforms to the “like for like or better” principle in determining potential offset sites, ICE has selected the Parismina River. Internationally-recognized, external experts have been involved with this decision-making and will continue to be engaged.
Management interventions that will be implemented on the offset river site include (a) work with farmers and landowners to reduce erosion, sedimentation, and pesticide run-off in the watershed, and (b) riparian restoration and other habitat enhancement measures that promote river conditions to support native fish and invertebrate species. The project plans to utilize methods put forth by the Business and Biodiversity Offset Program (BBOP), such as the habitat-hectare approach and an assessment of biodiversity loss/gain will be developed. The overall aim of the combined on-site and offset mitigation measures is to achieve no net loss of identified biodiversity values, and preferably net positive gain. To monitor progress towards this objective, ICE is in the process of developing relevant metrics that will be incorporated into a biodiversity monitoring program. External experts will also be consulted as part of this process.
Critical Habitat - Terrestrial Biodiversity Corridor Area
A number of biodiversity assessments have been conducted in the SBBD, which is an area recognized as an important corridor for the movement and genetic flow of the jaguar. Due to increased habitat fragmentation and prey scarcity, the range of the jaguar continues to be restricted and its long-term survival jeopardized. The structural and functional connectivity should be ensured for the jaguar, as a key species, and other mammals, to meet their migration patterns. The following describes the project’s overall mitigation strategy:
• The completion of a biodiversity assessment of the SBBD area that identifies key biodiversity values and that is adequate to establish a baseline for long-term monitoring;
• The purchase and reforestation of a 50-m buffer around the reservoir to reduce sedimentation, landslides, and erosion and to provide a riparian corridor for wildlife;
• Design and implementation of habitat restoration measures; and
• A number of management interventions to support the protection and conservation of the SBBD, i.e., protection of the remaining forest blocks; reforestation of degraded lands; improved Payment for Ecological Services schemes (PES); agro-forestry initiatives; establishment of a long-term funding mechanism; development of an operational framework and provision of support to current and future corridor management entities (ICE, SBBD commission, MINAET, etc); and capacity building and environmental of education with local communities.
As part of this approach, the project will develop metrics to monitor the effectiveness of these efforts and to move towards enhanced connectivity in the SBBD (e.g., gene flow of jaguars; gene flow among trees to demonstrate seed dispersal; indicator species or species assemblages, presence of invasive flora or fauna species, monitoring of forest succession).
On a smaller-scale, a pre-construction “rescue team” is in place to collect flora species (e.g. orchids and bromeliads) and small fauna species prior to earthworks. A larger effort of this sort will be underway once the reservoir begins to fill the area.
Ecosystem Services
Regarding ecosystem services, PHR does not affect irrigation activities nor human consumption and there are no significant fishing activities other than sporadic sport recreational fishing in the river. However, as noted above, some disruption of commercially-operated whitewater rafting activities is expected. Two sections in the Project’s area of influence are used by a handful of San Jose-based WWR operators offering one-day packages mainly to international tourists, particularly during the cruise ship peak season. ICE will, in consultation with the WWR tour operators, develop a WWR Management Plan aimed at: (a) further identifying potential impacts on rafting operations, (b) mitigate potential adverse impacts, and (c) ensure ongoing engagement with the WWR operator during the life of the Project.

As part of the ESIA process ICE carried out comprehensive Archaeological Prospection studies in the Project’s footprint and adjacent areas which found evidence of multiple archeological sites, including some with pre-ceramic groups dated as far as 13,000 B.C. In 2010 ICE began implementing an Archaeological Patrimony Management Program that is in is in line with the requirements of Costa Rican (Law 6703 Patrimony Protection) and other regulations, as well as with IFC PS8, and has been approved by the Archaeological National Commission (CAN). The Program includes methodologies and procedures to: carry out archeological prospection in advance to earth works; chance find procedure, conduct archeological salvage before and during construction; laboratory research; and in situ conservation when necessary. The Program is being implemented by a team of five (5) archeologists.
Among many other important results, the Program has rescued and cataloged hundreds of archeological artifacts, including 10 petroglyphs, and officially registered 41 archaeological sites. The majority of the archeological sites identified to date present low to medium density of archaeological fragments of pottery and lithics, (i.e. flakes and chipped stones) dated between 2,000 BC-1,500 AC. Artifacts, laboratory analysis, and research results are sent to the CAN and/or to the Costa Rican National Museum.
During the Archeological Prospection, the Project’s archaeological team identified an important archaeological site known as San Antonio. The site is a Pre-Columbian complex expanding over 29.9 ha and includes 13 circular structures, 13 funeral areas, a central square, and 4 petroglyphs. This site is located outside the Project’s footprint and will not be directly impacted by project-related activities. However, as part of the ESIA the Company has committed to the in situ protection and restoration of the site.

The Project is located in the Cantón de Siquirres, Provincia de Limón which is characterized by agricultural economy, mostly small scale cattle ranching, as well as industrial forest plantations and crops for export (e.g. pineapple). The Project’s Direct Area of Influence (DAI) comprises 15 communities, with a total population of 6,000 people, located in proximity of the Project’s construction sites, access roads, camps, reservoir, and buffer zone. Additionally, there are 15 additional communities located downstream of the project (between the power house and the estuary) with a population of 22,000 who may be indirectly affected by Project operations, as well as 2 main White Water Rafting (WWR) operators.
The ESIA consultation process focused on the communities in the DAI and consisted of four phases: (a) field research and dissemination information, (b) validation of the identification of environmental and social impacts and community characteristics/needs, (c) dissemination of identified environmental and social impacts and corresponding management actions/plans, plus public opinion survey (during this phase ICE delivered a written report describing the identified environmental and social impacts and proposed mitigation measures to each one of the affected communities), and (d) feedback to communities and dissemination of the ESIA.
The Project commenced community engagement activities during the early stages of the ESIA process and between 2008 and 2009 held 156 formal public consultation meetings with the communities in the DAI with the participation of over a thousand people. Multiple additional informative meetings were held in all DAI communities as well as an Environmental Fair that was attended by more than 3,000 people.
As a result of the consultation process, in addition to validating the identification of environmental and social impacts and definition of mitigation measures for the ESIA, some changes to project design were incorporated by the Company to address community concerns (e.g. changes to alignments of access roads, etc). Additionally, ICE signed formal agreements (Environmental and Social Responsibility Protocol) with each of the communities in the DAI. These agreements contain, among others, the following elements: (a) Environmental and social management actions for each community, including participatory monitoring of underground water, (b) arrangements for local hiring and procurement of local services (e.g. machinery, transportation, etc); and (c) community investment commitments. These agreements were publicly disclosed to local communities, municipalities, and governmental institutions in August 2009.
In addition to the ESIA consultation process with communities in the DAI, during 2009 ICE conducted 9 preliminary informative meeting for the communities located downstream of the Project, including coastal communities. These meetings focused on the following topics: (a) possible changes in river characteristics and performance associated to the construction/operation of the Project, and (b) management of sediment flushing for reservoir cleaning. Likewise, between October 2009 and August 2010, ICE held meetings with the main WWR operator in the Reventazon River and these were focused on providing project information, discussing relocation of a rafting deck, logistics, cooperation and safety and security aspects, among other issues.
In order to ensure ongoing community engagement ICE implements the following measures and mechanisms: (a) a local community relations office; (b) bi-monthly meetings with community leaders; (c) grievance redress mechanism; (d) environmental education program and guided visits to the Project site for local schools, and civic society organizations; (e) Social Monitoring Program to assess and report on changes in: social baseline or dynamics, water resources, river uses (rafting, fishing, etc), noise levels, and traffic patterns, among others; (f) local recruitment and procurement, and job training program; and (g) community investment program. These activities are described in detail in the Project’s Stakeholder Engagement Program.
The total cost of the community investment programs agreed upon with affected communities amounts to approximately 10 million US dollars. In addition, ICE has agreed with the Siquirres Municipal authorities to carry out a 7 million investment plan, which includes the construction/improvement of public infrastructure, among other items.

Ing Gravin Mayorga Jiménez
Electricity Manager
Instituto Costarricense de Electricidad (ICE)
Apartado Postal 10032-1000
San José, Costa Rica
mailto:gmayorga@ice.go.cr

Based on the review of Project documentation, assessment of the Informed Consultation and Participation (ICP) process, and interviews with directly affected communities and other stakeholders, IFC has determined that the Project has achieved Broad Community Support (BCS). In general, ICE is regarded as a serious and committed company and the Reventazón project as a development opportunity for economic progress and wellbeing in the region. *ICP - Information Consultation and Participation **BCS - Broad Community Support

Reventazon HPP(31383) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
Final version of the Environmental, Social, Health and Safety Management System (ESHS-MS) for the Construction Phase of the Project based on internationally recognized standards (e.g. ISO 14001), incorporating IDB’s applicable Operational Policies, IFC’s Performance Standards and applicable aspects of IFC’s EHS General Guidelines.	15-Oct-2013	Completed	Completed	10/15/2013
Develop and implement an Environmental, Social, Health and Safety Management System (ESHS-MS) for the Operation Phase: Implement an ESHS-MS based on internationally recognized standards (eg. ISO 14001), incorporating IDB’s applicable Operational Policies, IFC’s Performance Standards and applicable aspects of IFC’s EHS General Guidelines.	31-Dec-2015	Completed	Completed	12/31/2018
Create an independent supervision unit, with a clear mandate, capacity to halt construction works and/or operations if and when needed, detailed procedures and field supervision protocols, and adequate personnel and budget.	30-Sep-2012	Completed	Completed	12/30/2012
Update the Watershed Management Plan, including extensions of the successful Programs to the mid and lower sections. This Plan is expected to include not only general Programs, but expected targets and indicators to measure success.	30-Mar-2014	Completed	Completed	9/1/2015
Create an independent Environmental and Social Supervision Unit for the PHR.	14-Dec-2012	Completed	Completed	12/14/2012
Perform an ex-post Resettlement Completion Audit.	09-Mar-2014	Completed	Completed	12/31/2018
Develop a Biodiversity Action Plan (BAP)	15-Mar-2013	Completed	Completed	4/30/2013
Design and implement a Greenhouse Gases Emission (GHG) Monitoring Program for the Reventazón Reservoir	15-Oct-2014	Completed	Completed	9/1/2015