Sociedad Portuaria Puerto Bahía (SPPB): Key ESHS impacts and risks during construction include: the potential negative impacts to a total of five Afro-Colombian communities; the potential negative impact on coastal-mangrove natural habitat remaining at Ciénaga Honda; and potential risks related with the directional drilling of the pipeline under el Canal de Dique to connect the transference station with the storage tanks at the terminal site; and those typically associated with large infrastructure civil works. The Cartagena bay is naturally deep, and the shallower areas near the port are 19 meters deep and therefore the SPPB project does not require dredging. Once in operation, the key ESHS impacts and risks are those characteristic of any port operation, such as potential increase of oil spills and explosions, fugitive and/or accidental spills from vessel and road traffic; treatment and disposal of ship effluent and ballast waters; potential increase in accidents between ship traffic and local artisanal fishing boats; restriction of access to fishing grounds; and occupational health and safety to port and shipyard employees. As a point of reference, Cartagena Bay currently handles an estimated volume of 3,000 container and cruise line vessels per year averaging 70,000 – 80,000 DWT. Puerto Bahía’s operation (liquids + multipurpose) would increase this volume by approximately an additional 300 vessels per year, roughly 10% of the current traffic volume. 
Oleoducto del Caribe (Olecar): Key ESHS impacts and risks during construction include: the potential negative impacts over 32 communities along the ROW, including a total of six communities considered IPs (e.g. Afro-Colombian or Indigenous Peoples communities) and Olecar’s ability to develop adequate community engagement and management plans for the pipeline from Affected Communities and obtain Free Prior and Informed Consent (FPIC) from potentially affected IPs; land acquisition and potential involuntary physical and economic resettlement related with ROW easement; and potential impact on natural habitats (e.g. Canal del Dique Estuary) along the pipeline’s routing direct area of influence; and those typically associated with large infrastructure linear civil works.  Once in operation, the key ESHS impacts and risks are those characteristic of any pipeline operation, such as fugitive and/or accidental spills; noise and air emissions from pumping stations; community health and safety; and occupational health and safety due to maintenance activities.  
Pacific Infrastructure (PI): The Company will have in place procedures and capacity in place to manage all these impacts and risks with existing pollution prevention and control technologies and with standard environmental and social management practices, such as those described in IFC’s EHS Guidelines.
The sections that follow describe how PI expects to manage potential ESHS impacts and risks of its operations, including proposed mitigation measures necessary to ensure that both SPPB and Olecar will be consistent with the IFC Performance Standards. 
Environmental and Social Impact and Risks Identification Process and proposed Management Program: 
Sociedad Portuaria Puerto Bahía (SPPB): SPPB has conducted two different but complimentary ESIAs in accordance with Colombian environmental laws and regulations and in-line with GIIP. The first ESIA process involved extensive social and environmental baseline determination as well as an exhaustive impact and risk identification process. This ESIA was approved by the ANLA (Autoridad Nacional de Licencias Ambientales) on August 19th, 2011 via resolution 1635.
After this first approval, PI modified the original SPPB design by (a) eliminating a fluvial terminal component in the initial design, (b) expanding the terrestrial footprint by incorporating a 8.5-ha site on the right bank of Canal del Dique (Pasacaballos), (c) incorporating an additional maritime area under concession for liquids loading berths and vessel maneuvering, (d) construction of berthing positions for the exclusive handling of hydrocarbons and derivatives, and (e) construction of dry cargo loading dock (solid bulk and general cargo). This new design also included (f) directional drilling under the canal to construct a single pipeline connecting the transference station with the main storage area at the terminal, and (g) the construction of a 2x5 MW natural gas power plant for internal consumption. This modification required an additional comprehensive ESIA process that was approved by ANLA on November 19th, 2012 via resolution 0950.
During the ESIA process environmental baseline conditions were determined, potential impacts of construction and operations assessed, and mitigation and monitoring plans and mitigation measures developed. These include solid waste, water quality, and effluent management programs, and air quality and emissions management and control, among others. 
Similarly, as part of the both ESIAs processes the Company commissioned Fundación Mamonal to carry out a social baseline, and Fundación Puerto Bahía engaged the five potentially affected Afro-Colombian communities located within SPPB’s direct area of influence, namely the communities of Ararca, Santa Ana, Pasacaballos, Caño de Oro, and Bocachica.  In compliance with ANLA’s request SPPB carried extensive community consultation and engagement with Affected Communities, including the five Afro-Colombian communities. The main ESHS impacts and risk jointly identified between the SPPB and the Affected Communities included: increase in noise levels; affectation of air quality; landscape alterations and potential changes in temperature; risk associated to  hazardous materials/liquids spills; further deterioration of marine and coastal habitats; affectation of fishing sites, routes  and fisherman income; changes in communities social dynamic and potential for social conflict; alterations of traditional cultural patterns (acculturation); employment generation; and improvement in access roads and local infrastructure. The Environmental and Social Management Plan (ESMP) has been discussed and agreed with Affected Communities, and specific avoidance, reduction, mitigation, or compensation measures have been prepared for each one of these identified impacts and risks.
In compliance with applicable Colombian social and environmental, labor, and occupational laws and regulations, SPPB has developed an ESMP containing a total of 19 management programs to be applied during the construction phase and 10 management programs to be applied during operation, respectively. For construction, these include an overarching Environmental and Social Management Plan (GA-1) and a Health and Safety Management Plan (GA-2), and a series of more specific programs such as: biotic natural resources conservation (e.g. mangrove compensation, protection of endangered species); abiotic natural resources preservation (e.g. soil conservation, surface water and drainage management); pollution prevention and control and monitoring plans (e.g. air and noise emissions, air and water quality, solid and hazardous waste management); and  social management activities (e.g. fisheries management, community communication and engagement, local hiring, environmental awareness and education); among others. Similarly for the operations phase, there is an overarching ESHS Management Plan (GAO-1) and a series of specific programs mostly focused on monitoring the effectiveness of the different resource conservation, pollution prevention and control, and social communication and engagement activities and programs.
Oleoducto del Caribe (Olecar):  Prior to the commencement of a full ESIA process, the ANLA required PI to perform a comprehensive alternative analysis (DAA- Diagnóstico Ambiental de Alternativas). This alternative analysis evaluated three potential routings for the pipeline as well as the no-pipeline option; characterized the geo-physical, environmental, and socio-economic area of influence and assessed the potential significance of ESHS impacts and risks for each alternative. With the intention of minimizing ESHS impacts and risks, PI proposed to the ANLA their technical opinion on the best alternative as well as the general proposed ESHS management framework. PI recommended Alternative 1, which is the shortest option with a total of 128 km, running mostly parallel to an existing Ecopetrol pipeline ROW. This alternative does not cross any critical habitat, and runs mostly along flat agricultural lands and pastures. Ecologically sensitive areas such as Parque Natural Regional Manglares de Guacamayas and the Monte Maria and Serrania de Coraza are completely avoided. It must be noted, however, that all three alternatives need to cross the Canal del Dique Estuary (natural habitat) before they reach the SPPB transference station. Alternative 1 affects 3.5 km of the Canal del Dique Estuary, where the company is proposing to perform directional drilling to avoid disturbances as much as possible. 
On the social front all three alternatives include Affected Communities in their direct area of influence, including Afro-Colombian and Indigenous Peoples communities (Zenú). Alternative 1 direct area of influence includes a total 32 Affected Communities, as opposed to 36 and 40 affected by Alternatives 2 and 3, respectively. Of these 32 Affected Communities, 18 self-identify as IPs, but only 6 meet the criteria to be officially recognized as IPs by the GoC. All three alternatives require the negotiation of easement agreements for the ROW, however physical and/or economic displacement is expected to be limited. Alternatives 1 and 2 only require the relocation of two households when the pipeline is approaching the SPPB transfer station in the sector of Pasacaballos. Alternative 3, which was not selected, would have entailed the relocation of 23 families. 
The DAA proposed a general preliminary ESHS management framework that includes a total of 30 different plans and programs, including: pollution prevention and control measures; protection of river crossings; solid, liquid and hazardous waste management procedures; soil protection and re-vegetation programs; biodiversity resources management; and social management programs related to prior and informed consultation and community engagement, resettlement and livelihood restoration, local employment and grievance mechanism. The Management framework will be further developed and strengthen, including its consultation with Affected Communities as part of the ESIA process.    
On November 21st, 2012, ANLA issued via Auto 3622 its authorization to proceed with the full ESIA process for Alternative 1, including extensive social and environmental baseline analysis, community consultation and engagement activities, and a process of prior and informed consultation (Consulta Previa) with affected IPs communities. 
Pacific Infrastructure: Going forward and to ensure appropriate management of the risks and impacts of all additional future developments, PI will develop an integrated corporate-level environmental, social and health and safety management system (ESHS-MS), which will contain, at a minimum, the following elements:
Policy: PI will develop an overarching Policy statement of the ESHS objectives and principles guiding the organization’s ESHS performance. The policy will describe specific objectives and aspirations for its ESHS performance, consistent and with direct reference to the IFC Performance Standards, including principles of FPIC when Indigenous Peoples (IPs) are affected. In addition to the commitment of compliance with all applicable Colombian ESHS laws and regulations, the policy should also include other major ESHS commitments such as compliance with good international pollution prevention and control practices as those described in the applicable IFC EHS Guidelines (e.g. Ports Harbors and Terminals, Crude Oil and Petroleum Product Terminals).
Risks and Impacts Identification Process and Management: The corporate ESHS-MS will define PI’s social and environmental risk and impact identification process consistent with GIIP. This process will include all the necessary steps and methods that are required to screen, identify, analyze, measure, or assess, in quantitative terms to the extent possible, the potential risks and impacts (including environmental, social, health, and safety, and labor and security) associated with the activities to be developed, and assure that the mitigation hierarchy is applied to manage all identified impacts and risks. When applicable, this process will involve a full-scale Environmental and Social Impact Assessments (ESIAs) process that will follow GIIP, conform to Colombian laws and regulations, as well as those of IFC’s Performance Standards. The findings of the project-specific ESIAs will detail a program of mitigation and performance improvement measures and actions necessary to effectively manage the ESHS risks and impacts of each of its developments in line with PI’s corporate Policy.  Project-specific assessments will be used to establish action plans and metrics for project construction and operation.  EPC contracts for each project will incorporate the relevant project-specific mitigation measures and actions identified during the assessment process to ensure compliance with Colombian requirements, as well as IFC PS. Project-specific mitigation measures will include management of impacts and risks addressed in PS2 through PS8. 
Organizational Capacity: 
Sociedad Portuaria Puerto Bahía (SPPB): During construction, the Environmental and Social Management Plan (GA-1) is being executed by a team 6 people, including a social and an environmental inspector from Oiltanking as well as one ESHS manager of the EPC contractor.  In addition, and given the complexity associated with the social aspects of the project, and the need to have good engagement and communication team in the field, Fundación Puerto Bahía has a team of 6 social liaisons to execute and supervise the appropriate application of the social plans and programs, and receive and manage any community grievances. During operation SPPB expects to have a team of two people executing the Environmental and Social Management Plan (GAO-1), and continue with the support from the Fundación Puerto Bahía’s social team.
Oleoducto del Caribe (Olecar):  Since this sub-project is only at the conceptual stages, currently PI has hired Ecoforest to perform all the ESIA activities. In compliance with PI’s own ESHS policy and IFC PS, Olecar will designate an appropriately qualified team supported by adequate financial and professional resources to design and implement the relevant ESHS plans and programs. The resulting Management Plans will be in line with IFC’s Performance Standards 1 through 8 as needed. Some of the specific Management Plans will include, but not be limited to: Integrated Social Management Plan incorporating PS1 (Stakeholder Engagement) and PS7 (Indigenous Peoples) requirements; Security Forces Management Plan as per PS4 (Community Health, Safety and Security), Land Acquisition Plan as per PS5 (Land Acquisition and Involuntary Resettlement), among others.
Pacific Infrastructure: Going forward and at the corporate level, the Company will designate an appropriately qualified individual supported by adequate team of professionals and financial resources, with overall ESHS corporate responsibilities. To ensure adequate support of the newly designated ESHS manager, PI will clearly define his/her responsibilities and communicate these to the rest of the Company and site operating staff.  The corporate ESHS department will also be provided with sufficient authority and resources to achieve effective and continuous ESHS performance across all of PI’s business activities. This may include in-house staff, as well as external consultants. In addition, as an integral component of the corporate ESHS-MS, PI will retain an external environmental and social advisory consulting firm (ESAC) with extensive and proven international experience applying IFC Performance Standards to help guide future developments.    
Monitoring and Review:
Sociedad Portuaria Puerto Bahía (SPPB): During the ESIA process overall baseline ambient quality was assessed, and generally it was determined that the project area of influence is modified and degraded due to the extensive industrial and domestic activity that has taken place in the Cartagena Bay for decades, including untreated domestic and industrial wastewater and sedimentation and contaminant transport from the Magdalena river present in the Canal del Dique. Water quality (e.g. ToC, coliforms, pH, TSS, nitrates, ammonia, TPH, BOD, COD, heavy metals, PAHs, Oil & Grease) was measured in 2007 and 2008 in several sites of the Bay, the Canal del Dique and Ciénaga Honda, generally reflecting poor water quality, especially in the Canal del Dique where high zinc levels were reported. Sediments were measured at the same sites as water quality, where zinc was the only elevated contaminant. PM10 concentration was also measured in five stations around the project’s direct area of influence during 2007 and 2009, and noise levels were also measured in a total of 5 stations, with day and night campaigns in the same two years. All air quality and noise measured values were within the acceptable Colombian legal requirements, with the exception of noise night levels which greatly exceeded the permitted 45 d[B]A residential values.
The pollution prevention and control and monitoring plans have the objective of verifying the effectiveness of the proposed impact mitigation measures, and include procedures to assess air, soil, water and marine sediments quality, as well as noise levels. In addition, the ESMP also includes a sub-program to monitor any measurable impact over flora and fauna, a sub-program to assess the effectiveness of the social management sub-program.
Twice a year, SPPB presents environmental and social compliance reports (Informe de Cumplimiento Ambiental – ICA) to the ANLA. In addition, the SPPB environmental manager meets on a weekly basis with his EPC and Oiltanking counterparts, and presents weekly compliance status reports.  
Oleoducto del Caribe (Olecar): The Olecar ESIA report will propose standard supervision, monitoring, and reporting procedures compatible with Colombian regulation and GIIP.
Pacific Infrastructure: Responsible corporate staff will monitor ESHS performance of future developments against ESIA-based action plans, as well as established monitoring protocols and metrics (e.g. air emissions, air quality).  The results of routine monitoring and measurement activities carried out at the project level, as well as any environmental or safety incidents will be recorded. In addition, PI will implement a formal ESHS audit program to further ensure environment and safety performance for all its business activities. The program will include detailed audit protocols for environmental and safety issues.  Conducted by competent environmental and safety professionals from within the Company, audits will be undertaken for construction sites and operating installations.  Non-conformances with established standards and metrics and the related corrective action recommendations will be recorded and tracked. Project specific environmental monitoring framework will be based on the ESIA environmental and social management plans and programs and address: (i) emissions and ambient air quality, (ii) noise, (iii) wastewater and solid waste, and (iv) occupational health and safety performance indicators, among others. Specific environmental monitoring measures to be implemented will be identified during the ESIA process  including the parameters to be measured, sampling and analytical methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and the definition of thresholds that signal the need for corrective actions.  Monitoring thresholds will be consistent with those referenced in the applicable IFC EHS Guidelines and Colombia environmental quality standards.
Monthly, quarterly, and annual operations and environmental performance data will be consolidated into reports and made available to PI senior management. The results of ESHS monitoring will be evaluated and documented at both individual sub-projects and corporate level.  Reports will furnish the information and data needed to determine compliance with the corporate ESHS Policy and ESHS-MS. The format of these reports will include a summary of findings and recommendations.
In addition, as an integral component of the corporate ESHS-MS, PI will hire an ESAC with extensive and proven international experience applying IFC Performance Standards, that will closely supervise PI’s sub-project compliance with IFC PS. This supervision will include periodic site visits as well as documentation review, and the development of corrective action plans if any breaches are encountered during supervision activities.