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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a Category B project according to IFC’s Environmental and Social Review Procedures. The Project will be located in an area designated for industrial purposes and all project facilities will be built outside any designated Ramsar wetland sites. Impacts related to the Project will be time limited (short term during construction) and site limited (within the immediate project site) and not expected to result in significant long term impacts. Any environmental, health and safety issues linked to the Project can be appropriately managed using accepted good engineering and environmental, social and health and safety practices.

The Project will not require involuntary resettlement or land compensation as the future on-shore facilities will be constructed on land which is the property of RDP and the off-shore facilities will be built within an area granted by the Tuxpan Port Authority to RDP. Also, the Project will not have adverse impacts on indigenous peoples or over cultural property. Hence, PS5 (Land Acquisition and Involuntary Resettlement), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) do not apply for the purpose of this review.

Environmental, social and health, safety development are at the core of RDP’s philosophy. IFC’s appraisal considered environmental and social management plans for the Project and gaps if any between these plans and IFC requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and in the agreed Environmental and Social Action Plan (ESAP) disclosed in this review summary. Through implementation of these management plans and the ESAP the Project is expected to be designed and operated in accordance with Performance Standards objectives

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.

Environmental and Social Assessment: The national environmental authority (SEMARNAT) awarded the project’s environmental license in October 2012 based on a comprehensive Environmental Impact Study (Manifestacion de Impacto Ambiental, Modalidad Regional - MIA-R) prepared by URS Corporation Mexico S. de R.L. de C.V. (URS) on behalf of the Company and following applicable Mexican requirements. As part of the MIA-R development process the Company also engaged with several other environmental institutions such as the Instituto de Ecologia (INECOL), a highly recognized biodiversity research institution in Mexico, the Veracruzana University (UV) and Sistemas Integrales de Gestion Ambiental (SIGEA). As part of this process, the Company commissioned baseline and assessment studies including those for: hydrology, hydrogeology and geo-morphology, water and air quality, soils, sediments, biodiversity (including vegetation, birds, mammals, amphibians and reptiles, fish, zooplankton, benthic communities, crabs, among others), landscape and socio economic parameters. Also, extensive work was conducted by INECOL to evaluate the potential risks from the construction and operation of the Project on the mangroves located on the northeastern and southeastern sectors of the property and to define mitigation and monitoring measures to manage these areas over the lifetime of the Project.



The Project’s location and the approved MIA-R took into consideration recommendations provided by SEMARNAT relating to the protection of the mangrove/wetland areas and land use planning regulations established for the region (Programa de Ordenamiento Ecologico Regional-POERT).



Management Program: The Project’s environmental impacts related to site preparation, construction and operation will be managed under RDP’s Environmental Management Plan (EMP) as defined in the environmental permit approved by SEMARNAT. This EMP includes management procedures that cover the Project’s activities in the following areas: (i) environmental management during site preparation (ii) soil protection program; (iii) fauna rescue program; (iv) wetland protection program; (v) management of dredging activities; (vi) management of emissions and noise; (vii) management of fuels, lubricants and chemical products; (viii) management of non-hazardous and hazardous waste (ix) management of effluents; and (x) environmental, social and health and safety training.



The site preparation, construction and dredging contractors will be required to follow RDP’s commitments as stated in the EMP, MIA-R and any other local environmental, social and health and safety regulations and will be continuously supervised by RDP’s EHS Department.

The Company will revise its existing EMP for site preparation and construction activities and align these requirements with IFC’s General and Sector Specific EHS Guidelines to include environmental and health and safety considerations applicable to this phase.



Also, as
part of its commitments on pollution prevention, the Company will put in place detailed audit procedures to assure contractors compliance with national requirements and IFC Performance Standard provisions. This will include quarterly ESHS independent inspections of site preparation and construction activities.



Organization: In parallel to the preparation of the MIA-R by URS, the Company retained a local consulting firm (SIGEA) and two third-party organizations (INECOL and the Veracruzana University) to support them in the preparation of the environmental assessment document and in developing the necessary permit applications from the government.



Moving forward, the Company will put in place an appropriate ESHS organization with roles and responsibilities clearly defined both during construction and operation. This includes securing at least one dedicated environmental and health and safety professional during site preparation and construction to ensure implementation of the management program (see ESAP Action 1). RDP will also require the site preparation and construction contractor(s) to deploy qualified EHS professionals during their work. While the contractor is required to ensure adherence to applicable environmental, social and health and safety requirements, the Company will also obtain support from qualified consultants to put in place detailed procedures to audit and document contractors compliance with national requirements and IFC Performance Standard provisions.



Monitoring and Reporting: The Company will be required to submit bi-annual environmental reports to SEMARNAT on EHS performance during the site preparation and construction phase. The Project will also be periodically supervised by the Tuxpan Port Authority (APITUX) and the government’s environmental authority (SEMARNAT’s Procuraduria Federal de Proteccion al Ambiente – PROFEPA) for compliance with the commitments included in the MIA-R.

Human Resources Policy and Management: It is expected that approximately 680 direct workers will be deployed at the Project site during construction and about 2,000 direct workers are expected to be engaged in the terminal during operations. Mexican labor regulations prohibit all forms of forced or child labor and provides for the right for workers to form unions. This established Mexican labor regulation covers a broad range of labor matters including employment contracts and collective agreements, conditions of employment, insurance, social security and occupational health and safety.



The Company currently has two types of contracts for its employees, both aligned with the national labor law; those for permanent staff (contrato de trabajo por tiempo indeterminado) and those for part time staff (contrato de trabajo por tiempo determinado). These contracts specify labor conditions, rest and vacation days, bonuses, health insurance and training requirements.



Construction contractors will be required to adhere to applicable labor laws including prevention of child and forced labor. RDP will put in place appropriate audit procedures to obtain assurance on construction contractor compliance with applicable labor laws.



As part of IFC’s investment, RDP has agreed to develop a Human Resources Policy aligned with PS2 to clearly define the rights and obligations of employees and the employers regarding compensation and benefits, working hours and occupational health and safety, among others (see ESAP Action 2). The development of this Policy will also include a worker’s grievance mechanism for both company workers and construction labor to be able to document and address concerns and claims in a timely manner



Occupational Health and Safety: The Project’s health and safety issues during site preparation and construction are being managed under the Company’s contractual agreements with its construction contractors. These contractors are required to follow local occupational health and safety regulations and the requirements set forth in the EMP developed by RDP for the Project, which will include occupational health and safety (OHS) issues applicable to this phase. This should include adequate training in the relevant hazards, the use of personal protective equipment, safety procedures and emergency response, among others.

Given the nature of container handling and storage it is not expected that RDP will generate significant amount of gaseous emissions or effluents. Power consumption is expected to be moderated and will be supplied from the national grid. Greenhouse gas emissions associated with this project will be negligible. Non-potable water required for the administrative buildings and limited operational activities will be sourced from the municipal water system. Potable water will be sourced from bottled water.



According to the MIA-R, the site preparation and construction phases will generate short-term and in some cases permanent impacts of low to moderate magnitude related to the landscape, soils, flora and fauna, water quality and risks of accidents. Accordingly, the EMP includes management actions to minimize and mitigate these impacts. The MIA-R also lists a series of positive impacts during these phases related to the generation of employment and enhanced local economic activities, reduced pressure over the mangrove areas within the property from its protection and enhanced knowledge on the management of mangroves from the establishment of the scientific research center on site.



Air Quality and Noise Control: As mentioned above, gaseous emissions during operations will be minimal. However, during construction activities some emission of gases and of particulates (dust) are expected and the EMP includes specific requirements to address this issue, including inspections and emissions certification of vehicles, keeping construction material wetted down while on storage, covering trucks transporting earth material, controlling dust on access roads through the use of water and providing PPE to workers.



Noise generated during construction will include the use of heavy equipment such as front loaders and trucks. Also, temporary noise impacts will result from the installation of the piles at the pier. Some of the management and mitigation measures within the EMP include the adequate maintenance of vehicles and equipment, monitoring of the work environment to maintain noise levels within the established regulation, providing PPE for workers and carrying out monitoring of noise when new activities are introduced.



The area around the Project does not have human settlements so there will be no impact to local communities. It is expected that during operations there will be continuous noise from the operation of cranes, transport vehicles, etc but these levels will be maintained below those established in local regulations. Proper PPE will also be provided to workers.



Erosion Control: During site preparation and construction erosion might be present from the clearing of vegetation and related earthworks. The EMP has specific requirements for the Company and the construction contractor to develop an Erosion Control Plan prior to any vegetation clearing and the installation of erosion control/water management structures to avoid impacts
on the Tuxpan River and the adjacent mangrove areas. Topsoil will also be salvaged from the site prior to any activities and donated to the municipality or to neighboring sites for agricultural or reforestation activities. The Erosion Control Plan will establish monitoring requirements to assure compliance with the above requirements.



Solid and Liquid Waste Management – the Project is expected to generate moderate quantities of non-hazardous waste and limited amounts of hazardous waste during site preparation, construction and operation. The EMP includes specific requirements to establish a waste mitigation hierarchy to minimize, reuse, recycle and then dispose of wastes. Training requirements are also included in the EMP to raise awareness on adequate waste management practices. The Project will construct temporary storage areas for the various types of waste before they are transported off-site by authorized waste transportation contractors to authorized disposal or treatment centers (previously authorized by SEMARNAT and the Secretaria de Comunicaciones y Transporte - SCT).



The Terminal’s design includes measures and equipment to minimize, segregate and treat wastewater, storm water and runoff through the facilities and particularly in areas such as the vehicle maintenance areas. These measures include wastewater treatment plants, oil/water separators, grease traps etc. Liquid wastes generated during site preparation and construction will include those from portable toilets. Liquid wastes generated during operations will include those from workshops, office buildings and kitchen facilities. During operations, all effluents will be treated in a packaged aerobic wastewater treatment plant before discharge to the Tuxpan River in compliance with NOM-001-SEMARNAT-1996 and IFC EHS Guidelines. Prior to discharge, the appropriate discharge permit will be obtained from CONAGUA. Rain water will not be mixed with effluents and will be channeled away from the site. The sludge produced in the treatment plant will be disposed of in an authorized sanitary landfill.



Also, during operations, liquid waste generated by ships (i.e., bilge waste, ballast water, sweater and used oils) will be managed by third parties that must be licensed, insured to cover potential damages and have in place environmental management plans. RDP will require third parties to dispose of all waste in accordance with municipal requirements at designated sites.



Dredging: The Project will include dredging of a canal in the Tuxpan River to bring the depth down from - 10 to -16 meters to allow for access of Post-Panamax vessels to the pier platform. The total length of the navigational channel excavation, from the maritime zone to the docking zone will be approximately 6,510 meters. The width of the canal will vary from 100 to 130 meters depending on the section of the canal, except in the area of the turning basin which will have a width of 500 meters.
All the dredging work will be carried out in previously dredged areas as part of the ongoing port activities.



The Project is expected to use some of the dredge material produced (estimated at 6 million m3) as fill in the landscape program for the site. For this, a sedimentation pond will be used on site to recover granular dredge materials for fill. Dredge materials not used for fill will be disposed of in two areas offshore designated by the Port Authority (APITUX) for the disposal of this material. One of the disposal sites is located 6.3 nautical miles from the navigational channel with a capacity to receive 2,000,000 m3 of material. The second is located 4 nautical miles from the navigational channel and has a capacity for 10,000,000 m3 of material. The disposal sites are located several kilometers southwest of an existing protected area (Lobos-Tuxpan Reef System) and, hence, no impacts are expected upon this protected area. APITUX already has the environmental permit (MIA) for the two dredge disposal locations with the second approval pending from SEMARNAT and the Secretaria de Marina (SEMAR).



Dredging will be conducted with a suction dredge (Hopper Dredge) in most of the channel which will limit the amount of sediments which could be suspended from these activities. When sediment removal is done near the shoreline on site, these activities will be carried out using excavators (clamshell) which will be surrounded by filtering fabrics to avoid the dispersion of sediments.



Management of Hazardous Materials: Hazardous materials used during site preparation, construction and operation will include fuels, lubricants and other chemical products. Fuels and lubricants will be stored in compatible containers and within designated bermed storage areas 1.5 times larger than the amount stored. These areas will be located away from sensitive environments (water courses, wetlands) and will be covered and adequately ventilated. Maintenance of vehicles will be carried out in designated areas and, in the case of emergency maintenance, secondary containment will be installed. During site preparation and construction activities, contractors will develop an Emergency Preparedness and Reponses Plan to address incidents and accidents. Training will also be provided to workers on spill management and emergency response.

Community Health and Safety: No significant impacts on community health and safety are expected as result of the construction and operation of the terminal. The access road to the terminal is located along agricultural and industrial areas and away from any communities. The City of Tuxpan (with a population of 143,400 inhabitants) is on the opposite side of the site across the Tuxpan River. The primary risk to community health and safety identified is associated with traffic safety and potential vibration and dust generated by the transport of construction materials, equipment and workers to and from the Terminal during construction. The main risk identified during operations is related to increased volume of traffic from the transport of containers from the port to Mexico City. The government is in the process of building a new 264 km road to connect Tuxpan and Mexico City of which 252 km have already been completed and 12 km are currently in construction.



As part of IFC’s engagement, the Company will incorporate traffic management requirements into the existing EMP for site preparation and construction. Also, following construction activities and prior to the start of operations, the Company will develop a Transportation Management Plan to establish safe speed limits, vehicle maintenance requirements, training requirements for drivers and other safety measures as needed (see ESAP Action 3).



Security Personnel Requirements: During operations, RDP will engage the services of a private security company and guards are expected to be armed. As a condition of IFC’s investment, prior to starting operations, the Company will develop a Security Forces Management Policy to ensure coordination with the local armed forces and that all security personnel follow specific guidelines based on IFC’s PS4 and good international practices in terms of implementation of a code of conduct, training, equipment needs and monitoring of security personnel.

The Project is located within a wider Endemic Bird Area – EBA (North-East Mexican Gulf Slope) which runs along northeast Mexico and encompasses the Gulf of Mexico’s coastal plain in the states of Tamaulipas and northern Veracruz.



The Project site covers an area of 85.72 hectares comprising mostly secondary vegetation (grassland) product of past agricultural activities in what was previously tropical rainforest. The site also includes a portion of mangrove on the northeastern corner of the site (2.02 hectares) and also on the southeastern corner of the site (6.47 hectares). This southeastern mangrove is also located within an established Ramsar Site (Manglares y Humedales de Tuxpan) which covers a total area of 6,870 hectares and runs along the coast to the south and north of the Tuxpan River.



The engineering of the Project has been designed to protect the two mangrove areas located within the site as well as the ecological flows needed to support the health of these wetland systems. The modification of the initial design has included avoidance of the northeast mangrove and the establishment of a buffer zone of 4.27 hectares around this area and the avoidance of the southeastern mangrove and the establishment of a hectare buffer zone of 6.43 around this area. Also, as part of the modifications to the initial design, and following extensive hydrogeological and hydrological investigation work with support from INECOL, the Company will be constructing the eastern portion of the pier (about 187 meters) as an “open pier” through the use of piles to allow for passage of water from the Tuxpan River to the northeastern mangrove during high tide. The mangrove areas will also be fenced off to avoid the trespassing of workers to the mangrove or buffer areas. Finally, as part of the wetland management program, the Company has committed to reforest 1.708 hectares in the buffer zone of the northeastern mangrove.



Following baseline studies conducted by the Veracruzana University in 2011 several species of birds, mammals and reptiles were identified within and around the Project site. Of the birds identified, 12 are protected under national legislation (Subject to Special Protection). Of these species, all are considered as Least Concern (LC) by IUCN except for one species (Egretta rufescens) which is considered as Near Threatened (NT). It is important to note that most of the bird species identified are migratory and do not actively use the site with the exception of four species (Falco femoralis considered as LC by IUCN, Buteogallus anthracinus considered as LC, Egretta rufescens considered as NT and Rallus elegans considered as LC). Of the species of mammals identified during baseline studies, none are protected under national legislation and all are considered as LC by IUCN. Finally, of the species of amphibians and reptiles identified, eight species are protected under national legislation (5 as Subject to Special Protection and 3 a
s Threatened). Of the total species of amphibians and reptiles identified, 5 are considered as LC by IUCN.



As part of the commitments of the Company in the MIA-R, prior to any earth works or site preparation activities, RDP will carry out a flora and fauna rescue program which will include the relocation of species of plants, reptiles, amphibians and small mammals to similar habitats to assure their continuity. The commitment also includes establishing a monitoring program and key indicators to measure the success of the rescue and relocation program. Other requirements within the EMP, and following the rescue program, include the gradual clearance of vegetation, advancing in a manner as for species of birds and fauna to move to adjacent areas.



As part of the commitments established by RDP in the MIA-R, a scientific research centers will be established on site which will be managed by third party institutions which could include INECOL and the Veracruzana University. The objective of this center will be to support research activities associated with the protection and conservation of mangroves and the training of professionals in the management of these types of ecosystems. This research center will also be responsible for the monitoring of the conditions of the wetlands around the site and in the reforestation program established as a commitment in the MIA-R.

As noted above, there are no affected communities surrounding the port/terminal site as the city lies across the river. The Company carried out its engagement process for the MIA-R in line with established Mexican regulations. This included publishing information on the Project in a local newspaper on August 15, 2012 and making the full MIA-R document and the executive summary available on SEMARNAT’s website for comment starting on August 16, 2012. On August 29, 2012 the Company published additional information on the Projects impact’s and mitigation measures in the local newspaper and hard copies of the MIA-R were also made available in SEMARNAT’s regional office in Veracruz and the national office in Mexico City. Comments from the public were received by SEMARNAT and were responded to on an individual basis prior to granting approval.

Grievance Redress
The Company does not currently have a grievance redress mechanisms to receive, register and monitor complaints, claims and suggestions from project-affected people. As part of its commitments with IFC, RDP will develop and implement a Grievance Redress Procedure for site preparation, construction and the operations phase of the Project in line with IFCs PS requirements (see ESAP Action 1). The Company will also require the construction contractors to establish their own procedures with the Company to monitor the status of each public complaint received for prompt resolution.

The Environmental License including a description of the Project’s environmental and social management program will be available on SSA Mexico’s website http://www.ssamexico.com and its local office in Mexico and Tuxpan.

For additional information please contact:
Name: Eduardo Gomez Guadalajara
Address:Insurgentes Sur 1898, Piso 11, Col. Florida, Del Alvaro Obregon,CP 01030
Phone: 54 82 82 00
E mail: mailto:eduardo.gomez@ssamexico.com
Website: http://www.ssamexico.com/

Broad Community Support is not applicable for this project

Title	Description	Anticipated Completion Date	Status	Comments	Completion Date
Organizational Capacity	Engage a qualified full- time ESHS professional to supervise ESHS management during site preparation and construction activities.	First Disbursement 90 Day(s)	Completed	Completed
External GM	Develop and implement a Grievance Redress Procedure in line with IFC requirements to receive, register and monitor complaints, claims and suggestions from project- affected people.	First Disbursement 90 Day(s)	In progress	Under discussion with IFC Client
EHS Monitoring	Carry out quarterly independent EHS audits of site preparation and construction activities in alignment with IFC’s General and Sector Specific EHS Guidelines.	31-Jul-2015	Completed	Completed
HR Policy	Prepare a Human Resources Policy aligned with PS2 to clearly define the rights and obligations of employees and the employer regarding compensation and benefits, working hours, occupational health and safety, grievance redress procedures, among others.	First Disbursement 90 Day(s)	Completed	Completed
Traffic Management Plan	Develop a Traffic Management Plan for the operations phase of the Project to establish safe driving requirements including speed limits, inspection requirements, signage, training requirements for drivers, dust control activities, among others.	01-Dec-2016	Completed	Completed
Biodiversity	Submit a Mangrove Management and Monitoring Program with support from a recognized biodiversity institution or Consultant which includes all commitments established in the MIA-R and monitoring requirements to measure the effectiveness of the mitigation measures established.	First Disbursement 90 Day(s)	Completed	Completed