The following Performance Standards are not applicable:

PS5: Land Acquisition and Involuntary Resettlement – is not applicable since the land acquisition process has not resulted in involuntary physical or economic resettlement, including for the main site (25 WTGs, meteorological masts, platforms, foundations and roads and cables trenches), substation, and OHL right of way. 

PS7: Indigenous Peoples - is not applicable since there are no Indigenous Peoples or territories in the project’s direct or indirect area of influence.

PS8: Cultural Heritage is not applicable since no cultural heritage has been identified to date.

?   Environmental and Social Assessment and Management System and Policy

PECASA has a written Environmental and Social Management System (ESMS), which contains framework management plans, a list of trainings for company management, workers, nearby communities and reporting responsibilities’ lines. As per the ESAP #1, PECASA will develop a Sustainability Policy stating its commitment  to meet national and IFC environmental and social requirements . This Policy will be approved by the Board and well disseminated amongst every person involved in the project. PECASA will include the E&S Policy in its ESMS, and update its ESMS based on the need to develop additional baseline, update impact assessments, mitigation measures and monitoring, especially during operations, as per the ESAP #2. 

?   Identification of Risks and Impacts

Following the national permitting and assessment requirements, PECASA obtained the Environmental License in January 2004, which was modified twice due to changes in the project in June 2012 and January 2017. This license approves the ESIA/EMP and project’s construction and operation for the development of a 100 MW wind farm (i.e. including a possible future doubling of capacity), substation, transmission line, and access roads. In addition, the company has obtained the Definitive Concession, the Certificate of Special Regime Registration and No Objection from the Aviation Authority and for the grid connection. Some outdated permits were renewed prior to construction.

Land leases have been signed for 20 years beginning at construction commencement and are automatically extended for 20 years if no written document is received one year before the expiry date. A payment upon signing the contract was agreed for the access: land required for the WTGs and substation originally involved 165 affected parcels. During the planning of the construction, the company identified other alternatives, and the total affected parcels were reduced to 107. There is no contract regarding one project parcel affected by an access road. As it belongs to the community, there is no person or entity with whom a formal agreement could be signed, and only an informal verbal authorization from the community has been obtained by the sponsor. The company will document this. An annual rent was established and has been paid from the moment construction started in mid-2017. The price for each parcel varies between each wind turbine, and other utilities (platforms, foundations, roads, cables trenches or OHL). PECASA owns a clean title over the parcel required for the substation (approximately 1ha of land). For the OHL, the entity responsible for securing the land is the grid operator (ETED). Nevertheless, easement contracts have been signed by the earlier shareholders of PECASA with all land owners (61). Once construction finishes, the ownership of the interconnection facilities will be transferred to ETED’s responsibility through the Property Transfer Contract. The easement contracts will then be automatically transferred to ETED, as stated in a specific clause included in those contracts.

?   Management Programs

The ESMPs for the construction phase produced by the contractors were reviewed prior to construction to ensure the requirements established for the project have been captured adequately. All contracts between PECASA and third-parties include a clause to undertake works to international standards. As per ESAP #10, the company will ensure that the ESMPs during construction include the requirements presented in the PS3 session of this ESRS. In addition, an operational ESMP will be produced prior to commencement of operations, and special attention will be given to the definition of the survey methodologies, as per ESAP #3.  

?   Organizational Capacity and Competency

The organizational structure, roles and responsibilities during construction are well defined. The EHS team is managed from Akuo’s Headquarters in Paris, France, and managed onsite by a site manager, and an OHS manager, with the support of external E&S consultancy companies. The OHS manager will coordinate with the EHS managers from the contractors. Community relations are managed by Community Liaison Officers (CLOs), local residents from El Copey and Los Limones who were hired by Akuo and have worked with the communities from the beginning of the project. Although the CLOs are capable of registering and communicating community grievances to PECASA and undertaking some communication activities, provided that they receive the relevant training to do so, Stakeholder Engagement Plan (SEP) implementation will be a direct responsibility of PECASA’s EHS team (with CLO support), as per ESAP #19. 

Going forward, as per ESAP #4, the company will hire an Independent E&S Consultant (IESC) experienced in IFC’s requirements and international standards during the construction and the first 2 (two) years of the operational phase, to supervise environmental, social, and health and safety activities, including studies, surveys, analysis, and implementation of mitigation and compensation actions. The IESC will advise and provide support to the company since the scoping phase, to assure quality control of E&S matters, including the activities listed in the ESRS.

The company will prepare an organizational structure for operations, including roles and responsibilities for E&S matters, and designate a senior company official at the executive level with overall responsibility for ensuring that all E&S aspects of the company’s performance are properly managed and executed, as per ESAP #5.   

?   Emergency Preparedness and Response

PECASA’s Emergency Preparedness and Response Plan (EPRP) includes procedures in case of several scenarios, such as medical emergency, fire emergency, road traffic accident, hazardous spill, work at height, and natural disasters. A separate contingency plan has been produced to address hurricanes and earthquakes. SEMI’s Emergency and Contingency Plan has also been provided for review.

As per the ESAP #6, the contingency plan, and emergency and preparedness response plans of PECASA and its contractors – such as Akuo Energy, SEMI, and GAMESA - will be reviewed and detailed to be project-specific, detail the potential scenarios, objectives, contain specific information about how to respond to different emergencies, clear scope of responsibilities, identification of first responders, contact information of emergency agencies, hospitals, operations centers etc. Procedures should identify any foreseeable events such as earthquakes, hurricanes, traffic accidents, floods, fire, landslides, social unrest, criminal actions, etc. and should establish clear action items.

One month before the start of delivery of the wind turbine equipment on site, the TSA Contractor is contractually required to participate in the PECASA’s communication with local communities to describe this activity and the emergency procedures. This will be included in the project’s SEP to be updated by the company, as per ESAP #19 below.

?   Monitoring and Review

As per ESAP #2 and #10, the company will amend the contractors’ management programs for the construction phase (CESMPs) as needed. The contractors will provide monthly results of the E&S KPIs defined by PECASA to be included in the company’s monthly reports. Among others, these will include grievance logs and management, findings from E&S audits and inspections, workforce (detailing women and/or migrant workers’ participation), incidents/accidents, water management, construction materials management, and waste management. The company will prepare a robust monitoring program for the operational phase, including EHS monitoring responsibilities at PECASA and contractors level based on the outcomes of further studies. Additional actions are detailed in specific sections in the following items.

PECASA will review the Construction ESMP (CESMPs) produced by the contractors to ensure these include: (i) information about the source and amount of construction material, and wastes and disposal areas, and ensure that any quarry being used has the correct environmental licenses in place; (ii) estimations of water consumption (including domestic water use, dust control, compaction, and water used for making concrete), assessment of the impacts on the potential water sources resource vis-à-vis availability to other users, providing mitigation measures if required; and (iii) detailed measures for the management of erosion and runoff to reduce as much as possible the loss of soil due to extreme weather events.

?   Human Resources Policies and Procedures

The number of SEMI’s workers during the construction will be around 53 people, while GAMESA will hire 40 workers, and PECASA will have six employees. The company’s workforce required during the operational phase is anticipated to reach approximately five direct workers. Gamesa (O&M contract) will hire technicians on an “as needed” basis.

As PECASA does not have any employees, the HR Policy applicable to the project is the one from Akuo Energy. Akuo Energy’s corporate HR Policy is guided by fundamental principles of human rights, such as those in the International Labor Organization (ILO) Core Conventions. Going forward, as per ESAP #7, PECASA will ensure that these principles and PS2 requirements are followed by third-parties contractors, including: (i) Working conditions (typical working hours, maximum number of overtime hours, regularity of pay, provision of transportation to site, disciplinary actions etc.); (ii) Non Discrimination and Equal Opportunities clause, with special attention during recruitment to hire women, and disadvantaged peoples, measures to allow disadvantaged or vulnerable people to access project benefits, and engagement of migrant workers on equivalent terms and conditions to non-migrant workers in similar work; (iii) Labour grievance mechanisms; (iv) Freedom of Association and the Right to Collective bargaining; (v) Occupational Health and Safety (OHS) Policy and procedures. TSA and BoP contracts’ annexes already include “Acknowledgement of IFC Standards” stating that these contractors will be compliant with IFC PSs, and follow Akuo Energy’s HR Policy.

?   Working Conditions and Terms of Employment.

The HR Policy makes no reference to migrant workers, and most workers will be community members that live close to the sites. Yet, the sponsor informed that a few migrant workers will be contracted. The company informed that they will follow the national labour law, which requires a proportion of 80/20 foreign workers. As per ESAP 10, Akuo will include commitment in HR Policy to engage migrant workers on equivalent terms and conditions to non-migrant workers in similar work.

?   Workers’ Organizations

PECASA will ensure that the contractors HR procedures will not discourage workers organizations and collective bargaining, and that they will guarantee workers organizations and their representatives, and provide them with information needed for meaningful negotiation in a timely manner, as per ESAP #7.

?   Grievance Mechanism

PECASA will formalize a grievance mechanism in line with PS2 requirements, publicize its functioning, including confidentiality provisions, and make it available to all third-party workers (i.e. construction and O&M contractors), as per ESAP #8. In addition, the company will ensure that the contractors implement their own channels and procedures. Worker grievances will be recorded in the monthly reports as one of the PECASA’s KPIs.

?   Protecting the Work Force 

Akuo Energy’s corporate HR Policy is guided by fundamental principles of human rights, such as those in the International Labor Organization (ILO) Core Conventions, and as per contractual agreements with third-parties, this must be followed by its contractors.

?   Occupational Health and Safety

The site-specific OHS plan (Plan de Seguridad en Obras and Programa de Seguridad y Salud en el Trabajo) must be reviewed to ensure it considers IFC PS2 provisions. The ESMS and PECASA’s Traffic Management Plan (TMP) contains clear responsibilities and measures to minimize labour safety risks related to traffic. As per ESAP #9, the TSA and BoP Contractors will be required to prepare their own site specific TMP and OHS plans, which should include all relevant measures to ensure occupational health and safety, aligned with PECASA’s ESMS. The EHS person responsible for each contractor will report weekly to PECASA’s EHS Manager onsite regarding the EHS performance of its workers (including its subcontractors) during construction. PECASA’s OHS consultant will implement labour audits regarding occupational health and safety (OHS) during construction, and the IESC will ensure audits outcomes are addressed properly. 

?   Workers Engaged by Third Parties

Whenever it is possible, workers will be sourced locally. Workers from outside the area will be accommodated in existing houses in the surrounding communities. OHS audits will include the conditions of worker accommodation.

?   Resource Efficiency

As per ESAP #10, PECASA will review the Construction ESMPs produced by the contractors to ensure that they include information about the source and amount of construction material and ensure that the quarry from where materials are being sourced have the correct environmental licenses in place.

?   Water

Construction ESMPs produced by the contractors must include estimations of water consumption (including domestic water use, dust control, compaction, and water used for making concrete), and assessment of the impacts on the potential water sources vis-à-vis availability to other users. The company will identify mitigation measures if warranted (i.e. if the usage could adversely impact other users), as per ESAP #10.

?   GHG Emissions

This project will contribute to reduce emissions of CO2-equivalent by generating renewable energy coming from wind resources. In the absence of the project, considering that the same level of demand for electricity would be met by fossil fuel thermal power generation, the average annual emission reductions to be achieved by the project are approximate 110,000 tCO2-equivalent/year.

?   Pollution Prevention

The main pollutant emissions from this type of projects during construction are: dust, noise, and water effluent discharges (including runoff) and emission from heavy equipment engines. 

Construction noise will result in short-term noise impacts due to truck and construction activities. The company will update the noise background survey, modelling, and impact analysis as per IFC requirements ensuring the nearest sensitive receptors are included, as set out in ESAP #11. Sensitive receptors for which, as a result of the project operation, noise background levels increase above the values specified as acceptable or increase in 3 dB(A) or more from the background noise levels, should be identified, and mitigation measures for addressing any exceedances should be included in the ESMPs and implemented. In addition, the company will produce a shadow flicker impact study in line with IFC requirements to identify sensitive receptors where shadow flicker levels are exceeded and establish mitigation measures, as per ESAP #12. 

Wastewater will be very limited as there will be no dormitories in the construction camp. CESMPs will include use of portable latrines during construction, which must be maintained and cleaned at a minimum once a week by a licensed contractor. There will be no on-site wastewater discharges.  There are no anticipated liquid effluent discharges to surface water under normal operation. The ESMP states that chemicals (oils, greases) to be used during construction and operations will be stored in the designated areas to prevent contamination. Construction related pollution will be managed according to good international industry practice throughout project construction. 

Erosion in areas that have been subject to removal of vegetation was observed on site. Reduction of infiltration may occur as a result of compaction by use of heavy machinery. Road design has considered minimization of cut and fill, and platforms have the minimal size allowing the turbine mounting (no storage space is projected on-site other than in the central laydown area). As per ESAP #10, the ESMP will include detailed measures for the management of erosion and runoff during construction and operations to reduce as much as possible the loss of soil due to extreme weather events.

?   Solid Waste Management

Domestic (recyclable material and organic waste), industrial (construction material, soil, cardboard boxes, wood) and hazardous (oils, lubricating oils, demolition waste) waste will be generated during construction. As per ESAP #10, PECASA will ensure that the  CESMPs produced by the contractors include  estimations about the amount of waste to be generated and detailed measures to manage wastes during construction.

?   Hazardous Materials

Hazardous materials to be employed for the project should include fuel, oils, lubricating oils and solvents. The ESMPs developed by PECASA and contractors for construction and operation will include good practice hazardous materials management steps.

Community Health and Safety

During operation, impacts to the community health and safety are expected to be limited and mainly relate to maintaining high levels of security and managing potential community unrest. The closest communities are over 2 kilometers away from the project site, and the wind farm operation poses little or no risk to their safety, as Electrostatic and Magnetic Fields (EMF) and Electromagnetic Compatibility (EMC) are not considered relevant given the voltage and proximity to receptors. The main community health and safety risk associated with this project relates to flying tower and blade pieces in the event of extremes storms or hurricanes. The site selected is not in the usual route of storms, and historically has been hit by a hurricane only once in the last 100 years. The company will inform nearby communities and emergency response institutions. In addition, the company will carry out periodic blade inspections and repair any defects that could affect blade integrity. Considering that the wind turbines will be equipped with vibration sensors that can react to any imbalance in the rotor blades and shut down the turbine if necessary, this is considered as a minor risk.

During construction, there may be impacts to the community that are short term and temporary (noise, dust, traffic, influx of workers). As set out in ESAP #19 and #21 below, the strengthened SEP and grievance mechanism will include a means for community members to contact PECASA with concerns.

Towers, blades, and turbines will be transported during construction from the Port of Manzanillo, which is located about 50km east of the construction site. The ESMS has an overarching framework TMP with clear responsibilities, including measures to minimize disturbance and safety risks to local communities. A project specific TMP developed by PECASA includes description of the routes, specific measures, training needs, and defines the areas that need to be covered by the contractor TMP. The ESMS states that the BoP and TSA Contractors are contractually obliged to develop, implement and maintain their own project specific TMPs, which must be disclosed to and followed by their subcontractors. 

   Infrastructure and Equipment Design and Safety

The WTGs foundations’ project design considered as dimensioning factors the seismic loads and the loads potentially generated by hurricanes, the first being the more restrictive dimensioning factor. Security factors have been also considered for the design of the drainage systems.

   Security Personnel

The ESMS anticipates that control at entrances to the site will be performed in order to restrict the entrance only to construction personnel. Contractors EHS plans will include measures for ensuring restriction and management of community access to electrical equipment, construction sites and towers (wind and power), and controlling areas during lifting operations. The substation security is SEMI’s responsibility. If armed guards are used, the company and/or its contractors will develop a site security plan addressing the IFC PS4 requirements and the IFC’s good practices handbook titled “Use of Security Forces: Assessing and Managing Risks and Impacts” (2017), as per ESAP #13.

  The project is located in an area comprised of a partially degraded tropical dry forest, subject to a lot of human pressure and degradation in the last decades. There are no nationally or internationally recognized conservation areas that overlap the project area. The nearest protected area is Monte Cristi National Park, located roughly 10km away; the nearest Important Bird Area is greater than 40km from the site, and none of these areas are likely to be impacted by the wind farm. The aerial high voltage transmission interconnection line will be constructed through mostly agricultural land and some elements with human occupancy, such as a rice factory, households, and a school. It will go along an existing highway, minimizing the potential for adverse ecological impact. The medium voltage power collection system will be subterranean, eliminating electrocution risk for raptors or other birds that may perch on aerial power lines. Turbine pads and road improvement will also require clearance of vegetation, possibly including some natural habitat, consisting of human impacted, secondary growth tropical dry forest fragments. 

Following the vegetation inventory regarding suppression due to access roads and platforms, 17 (seventeen) individuals from endangered and vulnerable species of flora, under the Red List of Vascular Flora in Dominican Republic from 2016, will be transferred to appropriate locations, to be defined by the environmental agency. Among these, there are 2 (two) individuals of  Guaiacum sanctum , considered Endangered C2a under the IUCN Red List (meaning that the population size estimated number is very low globally, and is continuing to decline). The mitigation measures proposed include the reforestation using endemic species. PECASA will develop a vegetation inventory for substation and transmission line once the execution marks are installed on site prior to works.

Going forward, PECASA will assess the effectiveness and feasibility of operational curtailment strategies and verify bat detection and deterrence technologies to minimize the bats' injuries and fatalities to the maximum extent practicable, as required in ESAP #14.

Limited data on birds was included in the EIA in 2003, including records of three IUCN and nationally protected bird species: Hispaniolan Parrot ( Amazona ventralis  IUCN Vulnerable, nationally endangered), Hispaniolan Parakeet ( Aratinga chloropterus  IUCN Vulnerable, nationally endangered), and Gray-crowned Palm-Tanager ( Phoenicophilus poliocephalus  IUCN near threatened; nationally critically endangered). More extensive and quantitative bird surveys were conducted during 4 campaigns in 2011, as part of the environmental compliance reporting. This surveys reported the presence of a total of 38 bird species: 28 residents, 7 endemics, 2 introduced, and one migratory. Only one of the three IUCN or nationally protected bird species recorded at the site during the EIA studies in 2003 was observed during the 2011 baseline bird surveys: The Gray-crowned Palm-Tanager. However, three additional bird species protected by IUCN and/or nationally were documented at the site during the baseline studies: The White-necked Crow ( Corvus leucognaphalus  IUCN Vulnerable, nationally endangered), the White-crowned Pigeon ( Patagioenas leucocephala , IUCN near threatened, nationally vulnerable), and the Key-west Quail-Dove ( Geotrygon chrysia , IUCN least concern, nationally vulnerable). For the six IUCN and/or nationally protected bird species that have been documented at the site, there is no existing available information regarding susceptibility to collisions with wind turbine rotors or other adverse impacts.  None of them are migratory, and most are expected to either be rare at the site, to fly predominantly below the altitude of wind turbine rotors, or both, reducing the likelihood of significant adverse impacts to these species.  Nonetheless, minor impacts, such as collisions by a few individuals of these species per year, are possible.

Some collision impact is likely for some common, widespread bird species that were observed at the site, that exhibit tendencies to fly frequently within rotor swept altitudes, and for which wind turbine collisions have been documented elsewhere, including Turkey Vulture ( Cathartes aura ), Red-tailed Hawk ( Buteo jamaicensis ), American Kestrel ( Falco sparverius ) and Cattle Egret ( Bubulcus ibis ). Given the population densities of these species, and the low collision fatality rates that have been documented elsewhere, the project is unlikely to result in significant impact to the local or global populations of these, or any other bird species. 

Limited baseline bird survey information suggests that the project area does not lie within a major bird migration corridor, though some passage and overwintering of migrant land birds is likely. However, as per ESAP #15, PECASA will conduct a supplemental bird baseline survey during one year to strengthen the basis for the characterization of bird use of the site, following international best practice study design, starting as soon as possible to minimize overlap with construction. 

No information on bats was included in the EIA in 2003, but a 2012 desktop study identified nine bat species with potential to occur at the site, including two species protected nationally and/or by the IUCN (Cuban lesser funnel-eared bat,  Chilonatalus micropus , IUCN Near-threatened, nationally endangered; Minor red bat,  Lasiurus minor , IUCN Vulnerable, nationally endangered). A five-day acoustic and mist-netting survey conducted during April 2015 documented five bat species at the site, three of which were not predicted to be at the site by the desktop study. All three of these additional species are classified as “Vulnerable” at the national level and classified as “least concern” by IUCN. For the five IUCN- and/or nationally protected bat species that have been either documented at the site or predicted to potentially occur at the site, there is no existing available information regarding susceptibility to collisions with wind turbine rotors or other adverse impacts. However, other bat species in the genus  Lasiurus  are known to be among the most highly collision susceptible bat species, suggesting that  Lasiurus  minor may experience collision susceptibility if it occurs at the site. The project is likely to result in some collision fatalities of bats. However, based on the predicted rarity of IUCN-listed bat species at the site, if bat collision fatality rates are similar to those documented at North American wind energy facilities, the project is unlikely to result in significant impact to the local or global populations of any bat species. 

Per ESAP #16, PECASA will conduct a supplemental bat baseline survey to strengthen the basis for the characterization of bat use of the site.

PECASA will implement an intensive bird/bat fatality monitoring program for a minimum of two years once the project becomes operational, following international scientific best practices for such studies, including systematic, weekly searches at all turbines year-round, application of searcher efficiency, carcass scavenging, and unsearched area bias corrections, and application of scientifically valid formulae to estimate overall annual bird and bat fatality rates for the facility (ESAP # 17). 

PECASA will develop an adaptive management plan (ESAP # 18) to provide a mechanism for implementing additional bird/bat impact mitigation measures if observed impacts have the potential to generate population-level negative effects or affect sensitive species, particularly if nationally- and/or IUCN-listed species are being affected. 

No information regarding ecosystem services provided by the project area was described in the ESIA or the environmental performance reports and additional studies. The area is known to be used for the harvesting of wood for the production of charcoal, and cattle herding after the forest is subject to slash-and-burn practices known as “canuquismo”. North of the site, mangrove areas and the presence of the Montecristi submarine natural park (approximately 3km away) add touristic and environmental protection value. In addition, the area’s forest cover serves as a hydrology regulator. The company will engage with the community to avoid wood harvesting for charcoal production increasing in the vicinity of the project as a result of the improvement of road access, and educate the communities in sustainable agroforestry practices as part of the SEP in ESAP #19.

   Stakeholder mapping / analysis and Stakeholder Engagement Plan

A Stakeholder Engagement and Communication Plan (SEP, “Programa de Capacitación Información y Divulgacioón”) was included in the ESIA and attached to the ESMS. As per ESAP #19, the company will review and update the SEP to include stakeholder mapping, a strategy for on-going stakeholder engagement and plans for dissemination of information (including the actions for notification of transportation of WTG components mentioned in the PS4 section, to engage with the community to avoid wood harvesting, to educate the communities in sustainable agroforestry practices,  to inform nearby communities and emergency response institutions about the risks related to flying tower and blade pieces in the event of extremes storms or hurricanes, among others) , frequency of planned consultation activities and information disclosure, a commitment to be updated regularly and key milestones throughout the lifetime of the project. The company will also strengthen engagement with land owners focusing on clarifying their doubts and concerns in regards to the contracts, payments, construction commencement and expectations. The reviewed grievance mechanism (as per ESAP #21 below) will also be included in the SEP. The company will develop community investment plans as appropriate.

   Information Disclosure

A website for the project is anticipated in the written ESMS, including the latest news about the project, the management plans for the construction phase, the project planning, the grievance mechanism, and all other information that might be useful to the local communities. It will also be a way to spread information to other communities, media, students, NGOs, researchers and other stakeholders that will not be a direct target of the SEP’s actions. Updated SEPs (ESAP #19 above) will include specific timeframes and frequency of disclosure activities.

   Consultation

Two public meetings, in El Copey and Los Limones, were undertaken on September 2016 by Akuo, and a pre-construction public meeting would be undertaken on June 2017 in the same communities, with the participation of the BoP contractor. The company will register the questions, opinions and concerns raised during the public meetings from now on and consider them when reviewing the ESMP, and request contractors to also consider them when preparing their site-specific plans, as per ESAP #20. Authorities such as CDEEE, CNE, environmental authorities and grid authorities are updated on the project by regular communications.

   External Communications and Grievance Mechanisms

The ESMS includes a community grievance mechanism, which sets out an overarching strategy for managing community grievances. This will be reviewed to address some gaps against PS1, as per ESAP #21, including contact details for the CLOs, the responsibility for handling grievances, making the recourse to anonymous reporting clear, provision to make printed copies of the grievance form and a box to deposit them in a central location in El Copey and Los Limones, grievance logs with all information obtained in the grievance, the name of who received the grievance and what actions are being carried out to reduce the likelihood of the grievance reoccurring. In addition, the CLOs will be trained on the reviewed grievance mechanism and receive clarification on the importance of registering any grievances that may be identified - even if the occurrence is considered not related to the project.

   Ongoing Reporting to Affected Communities

Annual E&S performance reporting for the affected communities will be addressed when revising the SEP, as per ESAP #19 above. A plan for annual E&S reporting will be included in the new SEP (and integrated into the operational ESMS).

   Salvatore LONGO

+1.809.729.6882

C/Juan Garcia Bonnelly num19 Ensanche Julieta

Santo Domingo – Republica Dominicana