The new facilities will be constructed on a piece of land that was acquired, prior to Azito Phase 1, by the GoCI from the village of Azito. The project will be developed on the existing site, which is located in a modified habitat area. There are no habitats of significant biodiversity value in the vicinity of the project. PS5: Land Acquisition and Involuntary Resettlement and PS6: Biodiversity Conservation and Sustainable Natural Resource Management are therefore not applicable to the project.

Identification of Risks and Impacts

An ESIA for the Azito 4 expansion project was prepared by ERM (who prepared the ESIAs of the previous Phases 1 and 2 in 1998 and for Phase 3 in 2012). An initial version of the Azito 4 ESIA was completed in January 2017 and submitted to ANDE, regulator in charge of the validation of the ESIA in Côte d’Ivoire (according to Environmental Act n°96-766 and the main decree n°96-894 determining rules and procedures applicable to ESIA for development projects). An updated version was completed in November 2017 to meet IFC’s requirements. The Azito 4 ESIA was approved and validated by ANDE in January 2018.

The ESIA presents an updated baseline data set collected on the site and direct surroundings, identifies the environmental and socio-economic impacts of the project during the construction and operational phases, and recommends mitigation measures to minimize negative risks and impacts (also covering construction and operations). The main risks identified are related to the emissions to air and ambient air quality, ambient noise, water consumption and discharge and risk of contamination, waste handling and disposal, socio-economic impacts, occupational health and safety for construction workers, community health, safety and security and project decommissioning. Quantitative studies were carried out involving numerical modelling of emissions to atmosphere, ambient air quality and noise during plant operations, and quantification of water abstraction and discharges. The ESIA includes a section specifying that cumulative impacts are considered for the existing activities and on-going expansions. The report states that there is limited room for additional projects in the area and confirms that the impacts of the existing surrounding projects (including the Azito Phases 1 to 3) are included in the baseline collected for the Phase 4 project ESIA. 

Based on the results of the ESIA, the project developed a standalone ESMP that summarizes the mitigation and monitoring measures to address impacts during construction and operation phases. The client is planning to update the existing Environmental and Social Management System (ESMS) of the Azito power plant to reflect and include the proposed expansion.

The ESIA included an analysis of project alternatives including for example: siting of project components to minimize the potential for impacts on the environment and communities; combustion technology options; configuration of turbines and energy recovery systems; NOx control methods; and alternative fuel types.

Management Programs

For the construction of Azito Phase 4, the project is currently developing a set of operational procedures, related to communication, security, occupational health and safety (OHS) and incident management, that will be included within the contract of the project’s engineering, procurement and construction (EPC) contractor in charge of the construction. The objective of these procedures is to guarantee the integration of these issues from the start of the work and adhesion to applicable social and environmental legal/national and international requirements and implement environmental and occupational health and safety (EHS) measures listed in the ESMP.

During the operational phase, Azito Phase 4 will be managed under the Quality, Health, Safety and Environment (QHSE) and sustainable development policy already being implemented by Azito O&M for the existing Azito power plant. The QHSE management system implemented at the plant currently conforms to ISO 9001, ISO 14001 and OHSAS 18001 standards. Different operational procedures are in place to manage the environmental and social performance of the company, including emergency preparedness and response, waste and water management, external and internal communication management, hazardous product or first aid management. The operation of the future expansion project will be integrated within the environmental and social management system of the existing plant upon commissioning.

Organizational Capacity and Competency

Azito O&M has a competent and skilled team in charge of environmental, social and health and safety of the plant in operation. Two employees are managing the QHSE questions and another one is covering the social and community relation aspects. While Azito O&M has an appropriate E&S organization in place, Azito Energie will, for the construction phase, guarantee that sufficient resources are allocated to HSE from the beginning of the work, with roles and responsibilities clearly defined both for Azito and the EPC contractor. This includes Azito Energie deploying at least one fulltime dedicated HSE Manager during construction and the EPC Contractor deploying at least one HSE supervisor to ensure implementation of the management program.

Emergency Preparedness and Response

The existing plant has procedures, trained personnel, and equipment for responding to emergencies, including explosion, fire, chemical spills, accidental release of petroleum products, and medical emergencies. Prior to the start of construction activities, Azito Energie plans to review the Emergency Response Plan for the Phase 4 construction activities (to be prepared by the EPC). Similarly, prior to the project’s commissioning, Azito O&M plans to update and implement a revised site-wide Emergency Response Plan that includes Phase 4 operations.

Monitoring and Reporting

Azito O&M is currently monitoring several E&S indicators relevant for the operation of the existing power plant. As part of the future inclusion of the project in the existing operation, Azito O&M is planning to improve its E&S monitoring program and ensure that it includes the collection, record, and analysis of relevant performance indicators including ambient air quality, noise or water discharged, as presented in the ESMP, and that monitoring results are reported internally to Azito Energie’s senior management for review and used to identify and undertake any corrective action to improve E&S performance and ensure compliance with Ivoirian laws and IFC Performance Standards.

Azito O&M currently operates the existing Azito power assets and will also be responsible for operations and maintenance of the Azito 4 expansion. For existing operations, Azito O&M currently employs 52 full time people permanently and 3 short-term contractors. In addition to Azito O&M employees, 12 security guards, 5 cleaning/housekeeping staff and 6 restaurant/canteen staff, all contracted workers, are also employed by Azito O&M. Azito O&M will contract an additional estimated five operational staff and contractors once construction of Azito 4 is completed.

As future operator of Azito 4, Azito O&M’s human resource policies and procedures will apply to persons responsible for management and operation of Azito 4. Azito O&M provides working conditions and terms of employment that complies with the national labor code and the IFC Performance Standard 2. Working conditions and terms of employment – including type of employment contract, working hours and overtime arrangements, wages and overtime pay, benefits, wage deductions, breaks, rest days, holidays, leave, workers’ organizations, access to training, performance evaluations, and disciplinary procedures– are documented in the Human Resources manual. Non-discrimination provisions in terms of recruitment and hiring is a legal requirement and included in the policies of Azito O&M.

The construction phase of the extension is expected to last for approximately 30 months and will require up to 1,000 workers during peak time activities and an average of 400 workers over the entire construction period. The company includes requirements in contract to ensure that the EPC contractor will be required to adhere to applicable labor laws and to ensure that its sub-contractors also comply with the same applicable laws.

Azito O&M employees are free to adhere to any worker’s organization. This is encouraged by the company. All employees are currently affiliated with the National Syndicate for Gas and Electricity. Regular meetings are organized between the management and the worker’s representatives. The HR manager plays the role of secretary during these meetings, and the workers representatives can raise issues and grievances that are recorded and discussed during follow-up meetings. The HR manager also receives direct complains and grievances from the employees and is in charge of the follow up.

As per legal requirements in Côte d’Ivoire, Azito O&M has a health and safety committee. The committee comprises of representatives of the management team, the workers’ representative, staff, and medical doctor. The health and safety committees have legally defined objective that includes management of employees’ health and safety (including fire and life safety) matters, quarterly meetings organization and recording and dissemination of meeting minutes.

Occupational Health and Safety

Azito O&M addresses health and safety in operations through the QHSE management system certified to OHSAS 18001 standards. The company developed a procedure that describes the job hazard analyses methodology of the plant in operation and the translation of the risk identified into operational procedures. This document was reviewed and updated in 2015. Safe work procedures/instructions for the applicable topics (hot work, confined space, work at height,) have been developed based on these analyses and workers are trained for the procedures. The Company has a work permit system in place.

Azito has recently celebrated 10 years of continuous operation at the power plant without any lost time accidents, lost time injury and fatalities. All work-related accidents are reported to the National Security Office (CNPS). Procedures are in place to record and investigate on incidents. Safety signage are installed, use of personal protective equipment is adequate and appropriate procedures for safety awareness and training of employees including contract workers is in place.

In prevision of the construction phase for the Azito 4 expansion, Azito Energie contractually requires the EPC contractor to develop and implement a Health and Safety Management Plan (H&SMP), that will comply with the requirement and management plans of Azito Energie and Azito O&M. The plan will also be cascaded down to all subcontractors that will be active on the construction site. The H&SMP will assess all risks associated with the construction activities and detail procedures for topics such as the provision of personal protective equipment and ensuring their appropriate use; trainings identification and organization, safe working procedures and emergency response, provision of medical care, first aid, health monitoring, vaccinations, pest management and measures for prevention of disease spread; accident/ incident monitoring, investigation, reporting and corrective action; and periodic joint audits and corrective action.

The construction area will be completely isolated and barricaded from the existing plant to prevent movement of personnel between the two sites. The EPC contractor will be required to deploy appropriately qualified supervisors for effective supervision of compliance with the contractual provisions relating to labor working conditions.

Resource Efficiency, Energy and Material Efficiency Projects

The project design consists of a combined cycle gas turbine (CCGT) technology which is considered one of the most efficient option in terms of fossil fuel energy conversion efficiency, due to the lower carbon intensity of natural gas (when compared with other fossil fuels) as well as the use of waste heat to generate additional power in the combined cycle mode. The gas turbine to be selected for the project has an electricity generating efficiency of about 36% (LHV, net) when operated on natural gas. Once converted to a CCGT plant, the efficiency will reach at least 51% (LHV, net). The use of the CCGT technology will significantly increase the energy efficiency of the project and limit the incremental emissions.

Water

Raw water for the project will be supplied from two ground water wells, already used by the existing power plant. Raw water will be used for a number of processes, including gas turbine compressor washing (intermittent use), HRSG make-up water (blowdown), water for NOx abatement (during emergency operation with DDO no more than 5% of the annual operating hours), make-up water for the closed cooling water system. It is also used for several existing plant wide systems which the project will utilise, such as fire-fighting water and sanitary water. A very conservative estimate of raw water consumption of the project is estimated to average 16 m3/h (when functioning with gas). As a result, the total volume of water abstraction for the entire power plant will average no more than 45 m3/h. The current abstraction rate for all four phases will remain unchanged although the total annual water consumption from the wells will increase. Recent monitoring of groundwater quality from both wells does not show significant degradation of water quality with respect to saline intrusion or other parameters. The project contributes to water conservation by opting for air cooled condensers. The company plans to further enhance its plant-wide water management plan by identifying additional opportunities to improve water efficiency and reduce water consumption and improving water quality monitoring.

GHG Emissions

The project’s greenhouse gas emissions will primarily be carbon dioxide emitted by the gas turbine due to combustion of natural gas. CO2 emissions performance is estimated around 658 gCO2/kWh gross (gas-fired OCGT) and 454 gCO2/kWh gross (gas-fired CCGT). Total GHG emissions are estimated to average 905 000 tonnes of carbon dioxide equivalent (CO2e) annually during combined-cycle operations.

Air Emissions and Ambient Air Quality

The project will emit pollutants to air temporarily during the construction phase and permanently during the operational phase. During the construction phase the pollutants of interest will be dust and particulate matter, evaluated as PM10, PM2.5 and Total Suspended Particulates (TSP), nitrogen dioxide (NO2) and oxides of nitrogen (NOx), and sulphur dioxide (SO2) arising from construction traffic. Sources of dust and particulate matter include earthworks, access road construction and traffic along the existing road that connects the site to the main access road.

During the operational phase, the main pollutant of interest will be NO2. The project will use natural gas as a primary fuel. DDO might be used as an emergency backup and will not exceed 500 hours or more than 5% of the total annual operating hours. NOx emissions from the gas turbine will not exceed 51 mg/Nm3 during natural gas combustion and 152 mg/Nm3 during DDO. These limits are consistent with the 2008 World Bank Group Environmental, Health and Safety (EHS) Guidelines for Thermal Power Plants.

To complement the previous ambient air quality survey carried out in 2001, background air quality measurements were conducted in 2016 as part of the ESIA for nitrogen dioxide (NO2) at 8 selected baseline air sampling locations - determined through consideration of the prevailing wind direction (almost exclusively from the southwest) and the location of sensitive receptors, in order to gain a representative sampling of the ambient air quality in the airshed) - during 4 to 6 months (depending on the location) using diffusion tubes. Average background concentrations are consistent with those of a non-degraded airshed, due to the presence of annual average NO2 levels of 16 µg/m3 or below (depending on the location), considered to be below the World Health Organization (WHO) Ambient Air Quality Guidelines (AAQG) of 40 µg/m3 (annual mean).

As part of the ESIA, potential incremental impacts from operating activities were evaluated through the use of a predictive atmospheric dispersion model (AERMOD) under open and combine cycle operating modes. The modelling took into account the plant design, local meteorology. The modelling also included a stack height sensitivity analysis to determine a suitable stack height for the CCGT exhaust, in order to keep single-project contributions to ambient concentrations of NO2 at a reasonable level (WBG General EHS Guidelines recommend that no single project contribute more than 25% of the air quality headroom to allow for future project development). Based on predictive modelling results, the stack height was set to 55 meters. When firing natural gas, the maximum project contribution could reach up to 58% (open-cycle mode, limited to the first 14 months of operation) and 23% (combined cycle mode, used thereafter) of the NO2 1-hour maximum WHO Ambient Air Quality Standard (200 µg/m3) and 17% (combined cycle) of the NO2 annual average WHO Ambient Air Quality Standard. The Azito 4 plant design includes a continuous emissions monitoring system (CEMS) to automatically monitor NO2 emissions at the stacks on an on-going basis.

Azito Energie will update its monitoring and reporting procedures to achieve and demonstrate compliance with WBG 2008 emissions requirements and national ambient air quality requirements. (ESAP Item no. 2).

Noise

Noise emissions from Azito Phase 4 will add to sources of noise from the existing power plant and other existing noise sources in this peri-urban environment. Since the site is already industrialised, noise levels around the project site often exceed the noise level guidelines of the WBG General EHS Guidelines. During the daytime, existing average noise level measurements ranged between 47 dB(A) and 66 dB(A). During the night-time, average noise measured levels ranged between 46 dB(A) and 54 dB(A).

The ESIA included an assessment of this potential increase in noise levels during construction and operations. It identified the main sources of noise during construction to include use of powered mechanical equipment; site preparation, pile driving and foundation works; and installation of equipment. The sources of noise associated with the operation of the power plant are expected to include the HRSG, gas turbine, steam turbine and cooling tower.

Potential impacts from incremental noise during construction and operation included background noise measurements carried out in September - October 2016 and an evaluation with a noise propagation model (SoundPLAN v.7.3) which generates noise contours based on assumed noise emissions levels of construction equipment and activities and operating equipment to provide an overall view of the predicted noise levels around the project site. Increased noise at the nearest residential noise sensitive receptor (NSR) during construction activities was estimated to be between 61 and 67 dB(A). Azito Energie is requiring the EPC to implement several mitigation measures (for example, as done during the previous construction phases, construction works carried out at night will be limited to activities which do not produce significant levels of noise at the nearest NSR) and to monitor noise levels at the nearest NSR.

Operational phase noise levels are estimated not to result in increased background noise by more than 3dB(A) at any location. The EPC contractor as part of their design layout optimisation is obligated to conduct a refined noise propagation modelling using reputable sound model to confirm that the expansion project noise emission will remain below the applicable limits presented in the WBG EHS general guidelines at the most sensitive receptors and that the overall plant will not result in an increase of more than 3 dB over current baseline conditions at either of these locations. The Company will provide IFC with the noise model results and technical specification showing design specification that will ensure compliance with the IFC EHS guidelines limits and national ambient noise standards (ESAP Item no.3). Azito O&M also plans to monitor noise during operation of the Phase 4.

Wastewater Management

The main sources of wastewater during the construction phase will be sewage from the construction site facilities and surface runoff and sediment load. Wastewater will be managed as described in construction phase waste management plan ESMP stipulated in the EPC contract.

Dedicated wastewater treatment, equipment and drainage will be constructed as part of Azito 4 to manage any contaminated wastewater during the operational phase. This includes an industrial wastewater treatment plant, an oil/water separator, neutralization pond, and final retention basin. All water will be managed according to site operational Water Management Plan.

Oily water is treated through an oil-water separator. Treated waste water from biological treatment facility and the oil-water separator are mixed, equalized, pH treated and pumped to a final retention basin. When full the water is tested and if found conforming to Ivoirian and applicable effluent guideline values from the WBG EHS Guidelines for Thermal Power Plants (2008), pumped outside the plant premises and discharged in the ditch located along the west fence that connects with the lagoon. As part of the Water Management Plan, Azito O&M will identify opportunities and prioritise reuse and recycling of process water to limit the volume of effluent and reduce water abstraction.

Solid Waste Management

The project construction will generate general solid waste (household waste, plastics, paper, food, packaging, glass, office equipment, scrap metal), hazardous waste (waste oil, oily rags, filter cartridges, absorbent materials, medical waste, paint waste and paint cans and lead-acid batteries) and excavated soils and materials excavated corresponding to the foundations of the installations. It is estimated that 100 m3 of ordinary waste (i.e. one truckload) will be generated every month during the construction period of Phase 4. Most of the hazardous waste will comprise oil contaminated materials. These wastes will be managed as described in construction phase waste management plan stipulated in the EPC contract, including EPC staff training. The storage area for waste products will be waterproofed and covered to avoid the waste coming into contact with rain water. The storage area for liquid waste will be bunded. Packaging and general domestic waste will be collected by an independent waste management company and disposed of at the municipal waste disposal area in Abidjan. Volumes of excavated soils should be relatively small in view of the level topography and absence of any basements in the buildings (relatively small foundations).

Azito O&M is planning to update the existing site-wide waste management plan prior to commissioning to include Phase 4 activities and to train Azito O&M staff on the revised waste management plan.

Hazardous Materials

During the construction phase, fuel oil, lube oil, paints, and maintenance products are likely to be required. No bulk storage of chemicals is anticipated. Through contractual requirements, the company plans to ensure that good site management practices are observed by the EPC during construction, and that hazardous materials are properly stored and handled at site (e.g. as appropriate within secondary containment, double walled tanks, over filling alarm system, etc.).

During the operational phase, Azito 4 will rely on the hazardous materials storage infrastructure of the existing power plant. Hazardous materials stored and used at the existing power plant, and which will also be used to support Azito 4, include sulfuric acid, caustic soda; butane gas; DDO (2x6000 m3); solvents; lubricating oils; transformer oil; natural gas (not stored on site but used); acetylene and oxygen. Significant increase in quantities of hazardous materials is not expected to occur as a result of the expansion. In particular, the DDO storage will not be modified. Azito 4 operation will rely on the hazardous materials management procedures already in place for appropriate storage and management of these materials, including, where required, provision of secondary containment and access control.

Community Health and Safety

The entire construction work and project activities will be operated within the existing power plant premises except for some lay-down areas were construction material will be stored, that will be located mostly within the 300 m buffer zone. Given the location of the site, that does not allow access to the local communities given the presence of the existing plant and other industrial facilities, the impact on the community health and safety should be limited. However, the expansion project will mitigate this risk of accident during the construction through access control, appropriate barricading of the area, signage and community safety awareness programs.

During the construction phase, the Azito village will be impacted by the influx of workers that will increase the population, largely through introduction of a migrant workforce but also through potential economic in-migrants settling in the area with the intention of securing employment with the project or seeking other economic opportunities indirectly generated by Project activities. This has the potential to increase demand on services and existing infrastructure, such as health centres, water supply, markets, etc. The interactions between the construction workforce and local communities could also lead to increased occurrence and transmission of communicable diseases i.e. sexually transmitted infections (STIs) including HIV/AIDS.

As part of its contractual obligations, the EPC contractor is required to develop a management plan that will include measures to minimize risk of community exposure to disease due to influx of workers including: ensuring that appropriate medical facilities are available for all workers, periodic health check-up program and an awareness program on HIV/AIDS and STI

The EPC is required to ensure that the workers accommodation (expat workers being accommodated into buildings rented by the company Azito Energie in the vicinity of the construction site) conforms to good international industry and benchmark practices including those defined in the IFC/IBRD Guidance on Worker Accommodation. Most of the workforce will be hired locally and no accommodation will be provided by the company to these workers.

The construction material, that includes backfill material, concrete and structural steel and sheets are expected to be transported to site by road. The peak of Heavy Goods Vehicle (HGV) traffic flow will be for approximately 2 months whilst infill material is delivered to site. During this period, approximately 30 trucks per hour will be used, during daytime hours. The company plans to implement measures similar to those used during construction of the Phase 3 expansion to minimize community health and safety risk due to movement of vehicles/vessels traffic during construction and operation including the development of a traffic management plan that would be applicable to all companies contracted on site.

Infrastructure and Equipment Design and Safety, Hazardous Materials Management and Safety

The project uses several hazardous materials (listed in the PS3 section above) that have the potential to present a hazard to surrounding communities located in the vicinity of the plant. The main risks to the communities identified are the following: rupture of a gas pipeline, oil spillage, chemical leakage (including hazardous waste), fire / boil-over on a DDO storage tank, traffic accident. Operations ESMPs for the existing Azito power plant will be extended to Azito Phase 4 activities. These ESMPs describe mitigation measures (equipment design, for example buried gas pipeline, operational procedures, etc.) to prevent accidents and to limit their severity, in compliance with IFC requirements.

Azito Energie will update the industrial accidents risks assessment (accident scenarios, probability, severity) of the site to include phase 4 construction and operations (ESAP Item no. 4). Using the result of this assessment, the client is planning to update its existing site-wide H&SMP, Security Management Plan, and maintenance plan prior to construction or commissioning, as relevant, to include Phase 4 construction and maintenance

Emergency Preparedness and Response

The plant has emergency plans (including a “Plan d’Opération Interne” and a “Plan Particulier d’Intervention”) and procedures, trained personnel, and equipment for responding to emergencies, including explosion, fire, chemical spills, accidental release of petroleum products, and medical emergencies. Critical components of the emergency plan are tested on a regular basis. Full scale emergency training exercises are held every year (last test took place in September 2017) jointly with Foxtrot International (operator of the neighbouring gas treatment plant supplying gas to the Azito power plant), district authorities and local firefighters (“groupement des sapeurs-pompiers militaires”).

As mentioned in the previous subsection, Azito Energie will update the industrial accidents risks assessment (accident scenarios, probability, severity) of the site to include Phase 4 construction and operations (ESAP Item no. 3). Using the result of this assessment, Azito Energie is planning to revise its existing emergency plans and procedures to include the phase 4 construction and operations.

Security Personnel

The Azito Power Plant has developed a security management plan prior to the construction of Phase 3. The company contracts a private security firm that provide unarmed security guards to safeguard and protect its equipment and assets. The company ensures that private security forces are properly vetted, trained, and follow policy and procedures. Since the Azito power plant is of strategic importance to the country, two public security forces are positioned at the entrance and around the site: “Police Nationale”, that reports to the Minister in charge of interior, and “Gendarmerie Nationale”, that reports to the Minister in charge of defence. These public security forces play a leading role in terms of access control. There is currently no formal agreement between Azito Energie and the public security forces. Regular meetings are being held to ensure that information related to risk assessment and engagement rules are shared and understood by all parties. To date, no complaints against private security personnel or public security forces have been identified.

Azito Energie will update (1) the security risk assessment that identify and evaluate relevant security related risks (including knowledge of likely risks and likely responses, capacity to manage these risks, ownership of these risks); and (2) the security management plan (including efforts to engage with public security forces) to incorporate phase 4 activities (construction and operation). (ESAP Item no. 5)

Stakeholder Engagement Plan, Information Disclosure, and Consultation

Two villages/communities are considered as potentially affected by the existing plant and future expansion project; the village of Azito, located to the West of the plant, former traditional owner of the land and the village of Béago, located further away to the north of the plant, that are potentially affected by noise and air emission impacts.

The consultation for the expansion project was carried out during the ESIA preparation process. At the local level, consultations involved mainly the communities and municipalities potentially affected by the Project and included approximately four meetings and presentations between September 19 and 23, 2016. Stakeholder comments received during the consultations and recorded by the company mainly consisted of local content and employment needs, trainings, program and support from Azito Energie whilst consultations at regional and national level were used to consult with the regional offices and national institutions concerned. A public hearing was organised with the local communities in mid-November 2017 as part of the ESIA completion process. This hearing included a presentation of the project and associated impacts and proposed mitigation measures with key stakeholders, including local villagers. As requested by the local communities, the Company will disclose the final version of the ESIA (including paper support) to the local communities (Azito and Béago villages) before the beginning of construction. (ESAP Item no. 1)

Ongoing Reporting to Affected Communities and grievance mechanisms

Azito O&M and Azito Energie have both regular contacts with the community’s representatives. Azito O&M has employed a dedicated sustainable development coordinator to proactively engage with neighbouring communities. They also developed a community development program that focuses on health, education, gender equality and local economic development. Azito O&M carries out an annual satisfaction survey in the two villages to identify potential grievances and issues. Regular comments on the expectation of increased employment through Azito O&M have been expressed by the communities. Azito O&M developed a grievance mechanism that is shared with the communities and implemented, in addition to the frequent meetings organized between the community relation officer and the village representatives of Azito and Béago. A limited number of complaints were recorded over the last years since most of the communication and resolution of potential conflicts goes through this direct channel.