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Financiera de Desarrollo Nacional S.A.

$128 million
Environmental and Social Review Summary

Environmental and Social Review Summary 

Puerto de Antioquia  

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only. 

Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content. 

MIGA has been approached to support a loan facility to Financiera de Desarrollo Nacional (FDN), a development bank majority owned by the Government of Colombia (GoC), with minority interests held by the International Finance Corporation (IFC), the Development Bank of Latin America (CAF) and Sumitomo Mitsui Banking Corporation (SMBC). The use of proceeds of the loan will be for the development of a US$650 million greenfield multi-purpose port facility (Puerto de Antioquia, hereafter referred to as the ‘Project’) in the Gulf of Urabá, Antioquia region, Colombia for handling containers, dry bulks, general cargo and roll-on/roll-off (RORO) cargo (refer to MIGA Summary of Proposed Guarantee).  

The Project will be developed by Sociedad Portuaria Puerto Bahía Colombia de Urabá S.A. (hereafter referred to as the ‘Project Enterprise’ or ‘PE’), which was created to develop the Project. Key shareholders in the PE include CMA Holdings, Puertos, Iversiones y Obras (PiO) S.A.S., the Antioquia government through Instituto para el Desarrollo de Antioquia (IDEA) and banana industry partners (CI Uniban, Agricola Santamaria, Banafrut and CI Tropical). CMAT/Eiffage Holdings is a joint venture of CMA Terminals, which owns and operates 19 port terminals, and Eiffage, one of the largest construction companies in Europe. In addition to FDN, the Project is also being financed by Inter-American Investment Corporation, IDB Invest (refer to IDB ESRS disclosed August 2019).  

Consorcio Terminal Maritimo (COTEMA), a joint venture between Effiage (France) and Termotécnia Coindustrial (Colombia), has been selected as the main Engineering, Procurement, and Construction (EPC) Contractor. A consortium of Egis Ports (France) and Aqua&Terra (Colombia) have been selected as the Owner’s Engineer (OE) for the Project, and Rina has been engaged as the Independent Environmental and Social Consultant (IESC). 

The Project is located in the southern end of the Gulf of Urabá, known as Bahía Colombia, Antioquia region, municipality of Turbo, Colombia. The Project will replace the existing ship loading operations (major shipping lines already call at Urabá despite the lack of modern port facilities), becoming the main outlet for Urabá’s banana and fruit exports. Due to its location and logistic cost advantages, it is also expected that Puerto Antioquia will divert cargo in and out of Medellín (the second largest city in Colombia and main international trade region in Colombia), and in and out of Bogotá and surrounding areas.  

The Project was granted a 30-year right over an offshore area of 130 hectares (ha), located in an exclusion zone where activities not related to shipping are already prohibited. The terrestrial components of the Project will be built on 38 ha of land previously used for farming. These lands are heavily disturbed and in varying stages of regeneration, with the exception of some small remaining fragments of primary vegetation. 

Project components include, (i) an offshore platform with 1,337 meters (m) of berth (570 m for container operations, 537 m for bulk and general cargo, 230 m for RORO) capable of handling super post-Panamax vessels; (ii) a 3.8 kilometer (km) viaduct, onshore bridge over the León River and access road that connects the offshore deck with the inland terminal; (iii) a 38 ha inland terminal/logistic facility, including a container yard, dry-bulk storage facilities, warehouses, inspection areas, maintenance and administration buildings and utilities; and (iv) a new 2.4 kilometers (km) two-lane access road between onshore facility and the town of Nueva Colonia. The Project’s initial handling capacity is of 600,000 Twenty-foot Equivalent Units (TEU) (expandable to 800,000 TEU), 1.15 million tons of general cargo/year, 3 million tons of bulk cargo, and 60,000 vehicles. Ancillary facilities include worker accommodation camp; water treatment plant and sewage treatment plant located within the inland terminal/logistic facility footprint. The Project will receive power from the national grid. According to the proposed construction schedule, the offshore works will take approximately 24 months and the onshore works, including the erection of temporary facilities, will take approximately 30 months. Construction is scheduled start in 2020. 

The Project will also require construction of the following Associated Facilities: (i) a 115kV electrical transmission line, approximately 4.9 km long, connecting the port to the substation of Nueva Colonia; and (ii) a 13-km alternate road from Nueva Colonia to Apartadó to allow for the progressive expansion of port operations. The transmission line construction will be undertaken by Empresas Públicas de Medellín (EPM), the incumbent utility in the region, while the Apartadó-Nueva Colonia road will be built by a contractor yet to be determined who will be engaged by the public entities involved, as this will constitute public infrastructure. As such, the PE will have no control and only limited leverage over the implementation of environmental and social management measures during the construction and operation of the Associated Facilities. Construction materials will be sourced from existing quarries, which are not considered Associated Facilities of the Project.  

The Project area is adjacent to the mouth of the river León and close to the town of Nueva Colonia (municipality of Turbo, population approximately 24,000). Other communities within the area of influence of the Project are Río Grande (population approximately 11,500), which is located at the junction where the Project access road meets the main highway, and Puerto Girón (approximately 500 families), which is across the river León from the Project area. Two Afro-descendant ethnic minority groups are potentially affected by the Project:: the Consejo Comunitario de Puerto Girón (“Puerto Girón”) on the right bank of the Río León and the Consejo Comunitario Mayor de Comunidades Negras de Nueva Colonia (“COMANUCO”), within the town of Nueva Colonia. 

It is proposed that the existing Nueva Colonia-Río Grande road to the Turbo-Apartadó highway will be used by the Project for construction. This road passes through agricultural lands except for one stretch that crosses through a heavily populated part of Nueva Colonia for approximately one kilometer, and another stretch that borders the community of Río Grande for approximately 750 m where the road intersects with the main highway. It is anticipated that no improvements or upgrades to the road will be required. Once the Project enters operation, port-related traffic will be diverted around Nueva Colonia on a bypass road to be built prior to that time. As currently designed, the bypass will pass entirely through agricultural lands (banana plantations). The Project’s transmission line, connecting the port to an existing substation in Nueva Colonia which will be extended, will be approximately 4.9 km long and will pass through a patchwork of previously disturbed habitats.  

The Project is categorized as Category A according to MIGA’s Policy on Environmental and Social Sustainability (2013) due primarily to the Project’s potential impacts on indigenous peoples (two afro-descendant communities are potentially affected by the Project), as well as the Project’s potential impacts on critical habitats (marine and terrestrial) and threatened marine mammals and sea turtles. Other key environmental and social risks and impacts include (i) impacts to artisanal fisherfolk; (ii) indirect impacts to local communities, including ethnic minority communities, due to population influx during construction (e.g. from construction workers) and operation (e.g. from Project-induced population growth); (iii) impacts to roadside populations from Project-related traffic during construction and operation; (iv) impacts to non-Project marine traffic during construction and operation; and (v) displacement of jobs of workers in the banana shipping operations currently occurring in the Project area. 

While all Performance Standards are applicable to this investment, based on our current information, the investment will have impacts which must be managed in a manner consistent with the following Performance Standards (PSs): 

  • PS1:  Assessment and Management of Environmental and Social Risks and Impacts 

  • PS2:  Labor and Working Conditions 

  • PS3:  Resource Efficiency and Pollution Prevention  

  • PS4:  Community Health, Safety and Security 

  • PS5:  Land Acquisition and Involuntary Resettlement 

  • PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource  

  • PS7: Indigenous Peoples  

  • PS8:  Cultural Heritage 

In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project: 

  • General EHS Guidelines (2007) 

  • EHS Guidelines for Ports, Harbors and Terminals (2017) 

  • EHS Guidelines for Electric Power Transmission and Distribution (2007) 

Other relevant guidance includes: 

  • Workers’ Accommodation: processes and standards. A Guidance Note by IFC and EBRD (2009) 

  • Good Practice Handbook: Use of Security Forces: Assessing and Managing Risks and Impacts (2017) 

  • Good Practice Note: Managing Contractors’ Environmental and Social Performance (2017) 

The following documents were reviewed by MIGA:  

  • Supplemental Environmental and Social Impact Assessment - ESIA (Compliance Plan for Social and Environmental Performance Standards). Aqua&Terra. (September 2018) 

  • Environmental and Social Impact Assessment. Modification of Environmental License for the Project of Construction and Operation of a Port Terminal of Solid Bulk in the Municipality of Turbo. (October 2015) 

  • Environmental and Social Impact Assessment – Transmission Line. Aqua&Terra. (2019) 

  • Environmental and Social Impact Assessment – Project Access Road. Aqua&Terra. (2019) 

  • Environmental and Social Review Summary and Environmental and Social Action Plan. IDB Invest. (August 2019) 

  • Puerto Antioquia, Gulf of Urabá, Antioquia, Colombia. Environmental and Social Due Diligence report. Rina. (October 2019) 

  • Residual Biodiversity Impact Assessment Puerto Antioquia, Gulf of Urabá. ERM. (Draft, December 2019) 

  • Puerto Antioquia Habitat Assessment. ERM. (Draft September 2019) 

  • Puerto Antioquia Critical Habitat Assessment – Review. Fundacion Omacha. (Draft October 2019) 

  • Draft Environmental and Social Management System documentation (including policies, plans, procedures, etc.) prepared by Puerto Antioquia. (November 2019) 

  • Environmental License (Autoridad Nacional de Licencias Ambientales). (January 2016) 

  • Desk Study for Potential Explosive Remnants of War (ERW) Contamination, Gulf of Urabá Development, Colombia. (May 2019) 

In addition to reviewing the above documents, MIGA met with the IDB Invest team and the IESC to get a better understanding of Project risks and impacts. An E&S due diligence site visit, which will include a visit to the Project site and meetings with FDN, Project E&S staff and representatives of local communities and government authorities, is planned for January 2020. This ESRS may be updated following the MIGA site visit. If it is determined that this ESRS was materially deficient without the information from the site visit, then the updated ESRS will be re-disclosed for another 60-day period in accordance with MIGA Access to Information Policy (2013).   

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project and identified gaps between these and MIGA’s requirements. Where necessary, corrective measures intended to close these gaps within a reasonable time period are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards. 

Key environmental and social (E&S) issues associated with the Project business activities are summarized in the paragraphs that follow. 

PS1:  Assessment and Management of Environmental and Social Risks and Impacts 

Environmental and Social Assessment and Management System  


As part of the Environmental and Social Management System (ESMS), the Project has prepared an E&S Policy (Política Ambiental y Social, February 2019) in line with the requirements of PS1, which reflects its commitment to sustainable development and to the management of the Project’s E&S risks and impacts. The Policy includes objectives, environment, economic and social components and roles and responsibilities. The Project has also developed the following policy documents, which are integrated into the ESMS and broader E&S policy: Land Acquisition and Involuntary Resettlement Policy; Corporate Social Responsibility Policy; Health, and Safety Policy; and Labor and Human Rights Policy (February 2019). The PE has started to disclose the E&S Policy to its workers; and has committed to disseminating the Policy more broadly as the Project workforce grows.  

Identification of Risks and Impacts: 

The PE first secured an Environmental License (Autoridad Nacional de Licencias Ambientales) in 2012, and an updated Environmental License was obtained in 2016 following approval of an updated Environmental and Social Impact Assessment (ESIA) (which had been revised to account for changes in the Project’s design). The ESIA provided a comprehensive assessment of the Project’s risks and impacts in line with national requirements. An IESC was engaged in 2016 to undertake an E&S gap assessment of the Project against the IFC Performance Standards and applicable WBG EHS Guidelines. This initial review resulted in a Gap Assessment and Recommendations Report, which provided a rapid assessment of the key areas of concern and potential risks and impacts.  Two years elapsed, and then in 2018 a more comprehensive E&S Due Diligence review was undertaken by the IESC, which included a detailed ESAP to bring the Project into compliance with lenders’ requirements. Key gaps in the ESIA included: (i) area of influence not in line with PS1 requirements (i) lack of comprehensive marine baseline and critical habitat assessment; (ii) lack of assessment of the risks and impacts of Associated Facilities; (iii) lack of assessment of risks related to unexploded ordinance (UXO); (iv) lack of consideration of job losses and economic consequences for existing banana transportation system; (v) lack of cumulative impact assessment; and (vi) lack of evaluation of impacts on artisanal fisherfolk. Other gaps were related to documentation required for the management system (see below). An updated area of influence definition (December 2019), complimentary Risk and Impacts Assessment (first completed in March 2019 and regularly updated since), ESIAs for the transmission line (July 2019) and new access road and bypass (October 2019) and a Critical Habitat Assessment (draft, September 2019) and Residual Biodiversity Impact Assessment (draft, December 2019) have been completed to address the identified gaps.  

The Project has not yet conducted a Cumulative Impact Assessment (CIA). It is anticipated that the most significant cumulative impacts will occur during the operations phase, and the Project has committed to developing a CIA, which will include impacts from the Project’s future operations and other long-term planned expansion (ESAP item).  

The national ESIA only requires analysis of a ‘no project scenario,’ and therefore, a more comprehensive analysis of alternatives was not undertaken as part of the ESIA. Regardless, during the pre-feasibility stage, the Project conducted a limited analysis of alternatives in relation to the Project’s potential intersection with a nearby protected area. The Project design has also gone through a number of iterations, including modifications to minimize environmental impacts (e.g. the size of the off-shore platform was reduced to minimize the dredging footprint; the viaduct route was selected to minimize impact on natural habitats).  

The Project carried out a Climate Change Analysis, which resulted in the definition of a series of climate change mitigation and adaptation measures that the Project plans to implement (e.g. infrastructure has been designed considering wave height, tides and sea level rise according to climate change predictions). These measures are based on the recommendations in the Climate Change Management Plan for Maritime Ports of Colombia (Ministerio de Ambiente y Desarrollo Sostenible, Ministerio de Transporte, INVEMAR 2017). A natural hazard risks assessment will also be undertaken to ensure that the potential impacts of climate change are adequately incorporated into project design (ESAP). 

Management Programs:  

The Project Enterprise is in the process of developing an ESMS to facilitate implementation of the Environmental and Social Management Plan in line with the requirements of PS1 and International Organization for Standardization ISO 14001:2015 Environmental Management Systems. The ESMS will include (i) the policies listed above; (ii) procedures for identification of risks and impacts; (iii) management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) monitoring and review; and (vii) stakeholder engagement (ESAP item). While the comprehensive system is not yet complete, many of the components that will eventually comprise the system have been developed. As a condition of the EPC contract, the EPC will be required to develop and implement an ESMS in line with the Project’s ESMS and the requirements of PS1.  

The Project developed a series of E&S management and monitoring plans as part of the ESIA process and has been modifying and supplementing these plans over the past year in response to continued feedback from the IESC. Once completed, the Project will integrate all these plans into an overarching Project-level Environmental and Social Management Plan (ESMP) (ESAP item). The ESMP will in turn comprise the backbone of the ESMS. 

Organizational Capacity and Competency: 

The Project currently has two E&S managers: a Social Manager and a Sustainability Manager (Environment, Health and Safety). Two assistants report to the Social Manager, who also oversees third-party consultants hired to assist with discreet tasks. Sustainability Manager is assisted by 2 coordinators (HSE & Fisher folks). Staff from key shareholders, experienced with managing the EHS aspects of other ports financed by development finance institutions, will begin to support the EHS manager once the project nears the construction stage. In addition, the Project has hired two external consulting firms – one local and one international – to ensure the Project is designed, built and operated in accordance with international E&S standards. In October 2019, all project managers received training in the IFC Performance Standards.  

During the operational stage, the PE has proposed the following structure for a fully staffed E&S department. The department will be led by an E&S Director, an Environmental Coordinator, and an EHS Coordinator, and will include an Abiotic Team, a Biotic Team, a Social Team, a GIS Team, and a junior environmental engineer (ESAP item). 

Emergency Preparedness and Response: 

As part of the ESIA process, the Project developed a Contingency Plan in which it evaluates various emergency-relate risks. Subsequently, the Project prepared an Emergency Response Plan (February 2019) that identifies emergency response actions in general terms as well as a more complete Emergency Preparedness and Response Plan (November 2019). This last plan provides a solid basis on which the Project will now develop a full-fledged Emergency Preparedness and Response Plan commensurate with the nature and scale of the Project’s risks as per the requirements of PS1 (ESAP item).   

Monitoring and Review: 

The Project developed an extensive series of monitoring plans for tracking the biotic, abiotic, and social Project-related impacts as part of the ESIA. The Project is committed to updating and supplementing these plans in order to reach full compliance with PS1.  

The Project will also be monitored by social and environmental authorities, the IESC, the Lenders and MIGA’s environmental and social teams. The Project will also be required to submit a Semi-Annual E&S Monitoring Report during the construction phase and Annual E&S Monitoring Reports during operations.   

Stakeholder Engagement: 

The Project’s Stakeholder Engagement Plan (“SEP”) reflects a broad analysis and identification of Project stakeholders, and clearly differentiates between affected and interested parties. Project stakeholders identified in the SEP include: local communities, fisherfolk associations, Afro-Colombian Community Councils, educational institutions, religious groups, economic groups, academic institutions, local and municipal authorities, the Urabá Regional Environmental Corporation, maritime authorities, armed forces and other governmental institutions at the regional and national level, and banana producers, among others. Affected parties are identified in the SEP, and the SEP includes activities to engage and consult with these parties.  

The IESC due diligence identified a few gaps in the SEP (e.g. the need to include additional stakeholder groups: Río Grande community, roadside residents and businesses, and fisherfolk not associated with the local fishing associations; and improved coverage of vulnerable groups), and the PE provided an updated version of the SEP in November 2019, which addressed these gaps.  

The ESIA has been made available in Spanish at the Nueva Colonia Library and the Project’s mobile office in the community. Furthermore, the Project has disclosed Project-related information actively and appropriately as part of its overall stakeholder engagement strategy. Project information was also disclosed by IDB Invest in August 2019.   

The IESC review (March 2019), which included interviews with a range of stakeholders (including sub-groups (women, youth, Indigenous People) within affected communities), concluded that the PE has engaged in a process of informed consultation and participation, which has led to broad community support for the Project. The IESC further concluded that community leaders and members interviewed understand the Project’s impacts and opportunities and are active participants in various coordination mechanisms to follow up on impacts and management plans. MIGA is in the process of verifying the IESC’s determination of broad community support and will update the ESRS with its determination once completed.  

External Communication and Grievance Mechanisms: 

The SEP includes sound procedures and methods for external communications with specific stakeholders. The PE has committed to manage and evaluate external communications based on PS1 and ISO 14001 requirements.  

The SEP also includes a Community Grievance Mechanism (“CGM”) for managing community grievances. The CGM is easily accessible by stakeholders through a variety of means (e.g. phone, e-mail, representative offices in local communities) and includes clear procedures for disclosure of the CGM among communities within the Project’s area of influence. It also includes procedures for the receiving, screening and managing complaints, as well as for responding to complaints within the time limits established by Colombian Law. The IESC recommended that the PE further enhance its CGM to include: (i) procedures to receive, manage and respond to complaints that are anonymous; (ii) procedures for conducting root-cause analyses; (iii) procedures for determining remedial actions for repetitive, high-risk grievances; (iv) a system for ranking complaints based on level of risk; and (v) a schedule and procedure for the CGM’s regular review and update. In response, the PE provided an updated CGM in November 2019 incorporating the IESC’s recommendations. 

Ongoing Reporting to Affected Communities:  

The Project actively participates in the following groups: (i) Comité Técnico Territorial y Comunitario de Nueva Colonia (CTTNC), a community-based coordination and decision-making mechanism representing the Consejo Mayor de Comunidades Negras de Nueva Colonia (COMANUCO); (ii) Juntas de Acción Comunal; (iii) Asociación de Pescadores Artesanales de Nueva Colonia (APEANCO); (iv) Asociacion de Mujeres Productivas de Nueva Colonia; and (v) Representantes del area rural de Comunal San Jorge and Vereda Nueva Union. The Project is also a member of the Río Grande Junta de Acción Comunal, and other local organizations. Through its participation, the Project has engaged and reached agreements with a wide array of stakeholders, and continues to regularly report to stakeholders via these committees. 

PS2:  Labor and Working Conditions 

The Project workforce is expected to approach 1,200 workers at the peak of construction. During operations, the average direct workforce is expected to comprise approximately 500 workers. It is anticipated that the construction workforce will be mostly local. Memoranda of Understanding (MOUs) signed with the communities of Nueva Colonia, Puerto Girón and El Canal, specify that the Project is committed to fill 80 percent of all direct construction jobs with regional residents—giving priority to members of local ethnic communities. 

Working Conditions and Management of Worker Relationship:  

The Project’s Labor Management and Human Rights Policy states the Project’s commitment to contractual and working conditions compliant with Colombian legislation and PS2. As PS2 requirements apply to both the Project and its contractors, the Project has included explicit provisions in the Labor Management and Human Rights Policy and in the EPC contract to ensure that the Project’s own policies and the PS requirements are implemented by the EPC Contractor, sub-contractors and suppliers.  

During construction, the EPC will have a temporary worker camp that will house approximately 400 workers. A Worker Accommodation Plan (Plan de Alojamiento de Trabajadores, November 2019) has been developed to manage the relationship between these workers and the surrounding communities which will be enhanced to include a Worker Code of Conduct and a prohibition on lodging workers in communities of ethnic minorities or other areas where the population is highly vulnerable (ESAP item).  

The Labor and Human Rights Policy contains procedures for grievance management in cases related to sexual harassment and industrial safety. The Project has prepared a draft Labor Management Plan and Construction Workforce Demobilization Plan (Plan de Manejo Laboral y Plan de Reducción Laboral, November 2019), which includes a Worker’s Grievance Mechanism.  

The Project has prepared a Local Hiring Strategy, which includes principles and procedures for increasing employment opportunities among Project-affected communities. The Strategy has been discussed with affected communities and is reflected in MOUs signed with these communities. The Project has also developed strategic alliances with workforce training institutions dedicated to increasing employment rates among the local population. The Project has developed a draft Local Hiring Plan (Plan de Contratación Local, October 2019), which includes: (i) mechanism for tracking the hiring status of interested local workers; (ii) provisions for the training of interested local workers; (iii) a procedure for systematically documenting the justifications based on which any local applicants are rejected; and (iv) a procedure for providing periodic feedback to local communities on the Plan’s implementation status.  

Protecting the Work Force: 

The Labor and Human Rights Policy also includes a general commitment to the protection of workers’ rights as well as specific guarantees related to freedom of association and non-discriminatory management practices. It states the Project’s prohibition of forced labor and child labor, and its acceptance of organized labor and collective bargaining. Child and forced labor are also explicitly prohibited in the draft Labor Management Plan, which has been prepared by the PE. The Policy also explicitly mentions the Project´s commitment to United Nations and International Labor Organization principles, including equal pay and non-discriminatory labor practices, the implementation of which is further elaborated in the Labor Management Plan.  

Occupational Health and Safety:  

The PE has developed a Worker Health and Safety Management Plan describing how the Project will address risks and impacts during the Project’s construction phase. The goal of the Plan is “zero workplace incidents”. The Project has also developed an Occupational Health and Safety Management System Manual (Manual Sistema de Gestión Seguridad y Salud en el Trabajo, November 2019) to address in more detail the specific risks that workers will face, including detailed procedures for investigating and analyzing any accidents that may occur during Project construction or operation. 

Workers Engaged by Third Parties: 

In its Labor and Human Rights Policy, the Project expresses its commitment to ensuring that subcontractors have recognized integrity and the capacity to implement an E&S management system compatible with the Project’s policies and the PS requirements. To operationalize this commitment, the Project will develop a Contractor Management Plan aligned with IFC’s Good Practice Note: Managing Contractors' Environmental and Social Performance (2017) (ESAP item). The Contractor Management Plan will ensure contractor compliance with national laws and the PE’s Labor Management and Local Hiring policies; access to the worker grievance mechanism by contractors´ workers; and overall compliance with PS2 requirements by contractors.  

PS3:  Resource Efficiency and Pollution Prevention 

Resource Efficiency:  

The PE has developed a Resource Efficiency and Pollution Prevention Plan (November 2019), containing sub-plans for the following thematic areas: atmospheric and noise control; solid and hazardous waste; and pesticide use and management. Other energy efficiency aspects of the Project include: (i) natural gas powered trucks will be used for transporting cargo between the terrestrial terminal and the marine terminal; (ii) the length of time that ships stay in the Gulf of Urabá will be reduced to less than one third of current times; (iii) the Project will reduce the number of trips of tugboats, barges, vessels and personnel through the Río León and around the anchoring areas of the Gulf; and (iv) most of the equipment that will operate in the port will be electrical (both Ship to Shore (STS) gantry cranes and rubber tyred gantry (RTG)  cranes).  

During construction greenhouse gas (GHG) emissions are expected to be short-term and insignificant. Emissions estimates have not been completed for operations yet, but GHG emissions are expected to be more than 25,000 tonnes of carbon dioxide equivalent per year (tCO2e/year) The Project will quantify its GHG emissions following the guidance in the International Maritime Organization’s Port Emissions Toolkit--Guide No.01: Assessment of Port Emissions (ESAP item), and report emissions annually to MIGA. 

During the construction phase, water use will be limited primarily to the provision of sanitary facilities, cleaning, preparation of concrete and cement mixtures, and control of dust on roads. The Project has obtained a license for water collection in the Río León at a rate of 1.5 liters per second (l/s) for the construction and operation phases. During construction, the Project is authorized to make industrial use of the water for manufacturing concrete and suppressing dust on roads. During operations, the water intake will be 1.5 l/s from the Río León. This water will be used primarily to supply the fire system and to clean equipment and shipping containers. 

Pollution Prevention: 

The main impacts on air quality during the Project’s construction phase will result from the operation of heavy machinery. General mitigation measures and management procedures for air emissions and air quality are presented in various management plans developed as part of the ESIA process (e.g., Control of Atmospheric Emissions and Noise; Environmental Management of Vehicles, Machinery, Equipment, Ships and Naval Devices). The only industrial activity in the Project area is banana plantations and limited shipping activities; therefore, the existing airshed is relatively pristine (consistent with conditions expected in non-industrial, rural areas). Similarly, noise and vibrations are currently limited to transportation of bananas. These plans provide general recommendations related to the following aspects: controlling dust along roads; mitigating air emissions from mobile sources; and mitigating dust generation in the dry bulk solids area.  

The management plans also include measures for monitoring compliance with national regulations. Air quality monitoring, for example, will be conducted in the Project’s area of influence semiannually during the construction phase and annually during the operational phase. Sampling points will be located at the terrestrial terminal, at the marine terminal, and in Nueva Colonia.  

Before construction begins the Project will develop a comprehensive plan dedicated to managing and monitoring air quality and airborne noise (ESAP item). The plan will address potential impacts related to noise and vibrations emanating from the construction and operation of the port and all Associated Facilities. The Project will also assess and manage the potential impacts of underwater noise—both during the construction phase (e.g., from pile-driving and dredging) and the operation phase (e.g., from increased ship traffic) (ESAP item). Both the Air Quality, Airborne Noise and Vibration Management and Monitoring Plan, and the Underwater Noise Management and Monitoring Plan, will be aligned with the guidance in the WBG EHS Guidelines for Ports, Harbors, and Terminals.  

Project waste streams generated during construction will include non-hazardous solid waste such as the following: food, paper, cardboard, and other scraps generated by workers; soils from earth-leveling activities; trees and limbs removed to open roads and for facilities construction; general construction debris; and concrete. Hazardous wastes will include oily wastes and solvents typical of large construction projects. The Project has developed the following plans that address the management of hazardous and non-hazardous wastes generally: (i) Environmental Management of Vehicles, Machinery, Equipment, Ships and Naval Devices; (ii) Integrated Management of Hazardous and Non-hazardous Solid Waste on Land, Dock, and Vessels; and (iii) Environmental Management of Water Resources. Furthermore, the Resource Efficiency and Pollution Prevention Plan specifies that two Colombian companies will assume solid waste management during construction and operation. These plans were updated in November 2019 to ensure full compliance with PS3.  

Hazardous materials at port operations typically include large volumes of fuels, solvents, lubricants and other hazardous substances used in port activities by vessels, vehicles, and equipment. In order to deal with them and to control potential spills that may occur from accidents, equipment failures, or improper operating procedures during cargo transfers or fueling activities, the Project has developed an Environmental Management of Fuels, Oils, and Lubricants on Land, Dock, and Boats Plan, which includes general management procedures to address this risk. Before the start of construction, this plan will be updated to ensure its full compliance with PS3 and International Convention for the Prevention of Pollution from Ships (MARPOL). 

The Project will produce wastewater effluents during construction mainly from portable bathrooms and the worker camp. Wastewater from portable bathrooms will be treated by a service provider authorized to carry out this activity. A wastewater treatment plant that will be installed for the camp, will treat domestic wastewater and water used for cleaning the facilities and will discharge 3 l/s, according to the Environmental License (Res. No 0078 of 2016, ARTICLE SEVEN, 2 - Permiso de Vertimientos). The Project has developed a draft Wastewater Management Plan (November 2019) that references the parameters and limits in the WBG General EHS Guidelines (i.e., the Indicative Values for Treated Sanitary Sewage Discharges), which is currently being reviewed by the IESC and MIGA and will be updated to reflect any comments (ESAP item). During operations, the Project will prepare a Ballast Water Management (BWM) program in line with International Maritime Organization’s BWM Convention (ESAP item). It is likely that ballast water will be managed by Direccion General Marítima (DIMAR), which already implements a BWM program in line with international requirements for nearly 700 ships a year at the nearby Port of Turbo.  

Since the Project site receives approximately 2,500 mm of rainfall per year, a Stormwater and Erosion Control Plan will be developed (ESAP item). This plan will include measures to stabilize the right bank of the Río León, which has experienced significant erosion in recent years.  

The Project has developed a Pest Management Program which addresses the use of pesticides in a general manner. The Program will be updated so that it fully aligns with the requirements under the Pesticide Use and Management header in PS3 (ESAP item), which includes the following requirements: implementation of an integrated pest management approach; selection of low-toxicity, targeted chemical pesticides; and prohibition of the use of products classified by the World Health Organization as Highly Hazardous. 

The Project will require capital dredging during the construction phase, as well as regular maintenance dredging of channels and turning areas during operations. It is estimated that approximately 2,000,000 cubic meters (m3) of bottom sediments will be dredged with a Trailing Suction Hopper Dredge during construction. The dredge material will be disposed in an offshore dumping site approximately 4 – 6 km from the dredging site. Maintenance dredging is likely to be every seven years, corresponding to a dredging volume of 440,340 m3 based on a rate of sedimentation of 7 centimeters per year. The material coming from the maintenance dredging will be deposited in the same disposal area as the construction dredge material. Sediment dispersion modeling was undertaken as part of the ESIA, which indicated that the sediment dispersion plume in the dredging and disposal area did not exceed a 300 m diameter. Underwater noise and vibration from dredging is further discussed under PS6. 

Under the contract, the EPC contractor is required to establish a “warning” level to be used for water quality monitoring during dredging as the level at which to commence mitigation actions to reduce the level of suspended sediment solids in the water column (ESAP item). If the level of suspended sediment solids exceeds the specified limit, dredging operations in the area shall cease and not recommence until the level is below the “warning” threshold. 

PS4:  Community Health, Safety and Security 

Community Health and Safety:   

Key Project risks related to community health and safety include the following: (i) potential transportation-related accidents (on roads, rivers and at sea); (ii) potential respiratory effects from dust and from engine emissions; (iii) spread of vector-borne diseases; (iv) transmission of communicable diseases (e.g., HIV/AIDS); (v) deterioration of living conditions or living standards due to population influx (worker and non-worker); (vi) nuisances from Project-related noise and vibrations; (vii) misconduct among private security forces; and (viii) accidents involving unexploded ordinances (UXO) in the Project area. To address these and any other community health and safety risks, the Project has developed draft Community Health and Safety and Worker Influx Management Plans (November 2019), which will be updated to address any comments from the IESC and MIGA (ESAP item). These plans will also include procedures for regular follow-up with local communities regarding the plan’s implementation.  

To address diseases specifically, the Project has developed a Vector Management Plan (June 2019) containing preventative actions for protecting the health of workers and surrounding communities. The plan encompasses the following themes: camp management; camp closure policies; and sanitation of worker facilities. It also covers worker interactions with nearby communities and sexual health training. 

Regarding Project-related emergencies that could affect local communities, the Project will include in its Emergency Preparedness and Response Plan procedures for addressing emergencies that could affect surrounding communities (ESAP item). The Plan will be developed in consultation with the affected communities. 

A desktop UXO risk assessment was undertaken in November 2019 to determine the potential for UXO or Explosives Remnants of War (ERW) contamination at the site. The assessment identified two levels of UXO-related risk: the offshore section was classified as ‘Low’ risk and the onshore section classified as ‘Moderate’ risk. Based on the findings of the risk assessment, the Project will develop a UXO Management Plan (ESAP item). 

Security Personnel: 

The Project has prepared a Security and Protection of Human Rights Plan aimed at guiding the general provision of security within the Project’s boundaries with a focus on respecting the human rights of the local population. The Plan includes a mechanism for complaints and follow-up through the CGM. Given the location of the Project in a post-conflict zone, the Project will take the additional step of developing a Security Forces Management Plan aligned with the following standards: (i) The IFC Good Practice Handbook—Use of Security Forces: Assessing and Managing Risks and Impacts; and (ii) The Voluntary Principles on Security and Human Rights (ESAP item). The Plan will include a procedure and schedule for consulting on the Plan with local communities, artisanal fisherfolk, and Port service providers.  

PS5:  Land Acquisition and Involuntary Resettlement 


The Project has developed a Land Acquisition and Involuntary Resettlement Policy consistent with PS5. The Policy is designed to guide any future land acquisition that the Project may need—although based on current design, such a need is not expected to arise.  


To date, the Project has required the involuntary resettlement of 32 families (145 people) living in 24 houses in the El Canal community. This community was located immediately adjacent to the dirt road, which will be upgraded to be the Project’s new access road, on lands frequently flooded by rains. The entire community, except for two families, was relocated to new housing by the previous Project Sponsor in 2013. The PE has assumed responsibility for completing the process and is currently in the process of arranging the relocation of the two remaining families.  

The Project has prepared a Resettlement Completion Report for the El Canal community which confirms the following results: housing and services, including access to schools, have been duly provided to the new settlement; the sanitary and other living conditions in the new settlement exceed those in the original community; and the resettlement did not result in any significant disruption of livelihoods. The Project has obtained signed confirmations from each of the relocated families stating satisfaction with the relocation process and its outcomes. To ensure that the process is finalized in a manner compliant with the Performance Standards, the Project has committed to closing two remaining gaps: (i) the Project will ensure that all the relocated families gain legal title to their new lands; and (ii) the Project will build a boat dock for the resettled fisherfolk, as agreed during the resettlement negotiations in 2013 (ESAP item).  

Regarding potential economic displacement, the Project could potentially impact the livelihoods of three groups of people: (i) owners of business along the existing road to Río Grande whose businesses may be affected by roadworks; (ii) artisanal fisherfolk; and (iii) workers in the current banana export logistics operations. In response, the Project will develop: (i) a Compensation Plan, including a procedure for determining and dispensing compensation if the construction or operation of the Project results in economic losses to roadside business owners or to fisherfolk; and (ii) a plan to mitigate and monitor livelihood impacts to workers in the current banana transport system (ESAP item). 

An inventory of the dwellings and structures located along the entirety of the road between Río Grande and Nueva Colonia indicated that there are 56 residential dwellings and 28 commercial structures along the road. The inventory did not include the physical condition of the identified dwelling and structures; however, they are in close proximity to the road and the vibration caused by heavy trucks during construction has the potential to impact their integrity. Additional baseline work will be undertaken to include the physical condition of the structures along the road (ESAP item).  

A draft ESIA, which is currently under review by the IESC, has been prepared for the proposed alternative access road and Nueva Colonia Bypass to be built for Port Operations. The findings indicate that much of the land to be acquired for the road is banana plantations. The Project will update the ESIA once comments are provided (ESAP item).  

The Project has carried out a series of actions aimed at understanding its potential impact to fisherfolk. First, the Project conducted workshops in 2017 and 2018 with the participation of artisanal fisherfolk belonging to the three local fisherfolk associations: APEANCO, la Asociación de Pescadores de Turismo (ASOPESCATUR) and Asociación de Pescadores de Puerto Girón. In these workshops, fisherfolk identified a series of anticipated Project-related impacts. These included adverse effects on fishing grounds, limitations and changes to traditionally used fishing routes, and changes to cultural practices. Second, the Project has undertaken an artisanal fisheries baseline study to measure parameters such as the fisherfolk numbers, fishing techniques, and the contribution of fishing activities to the livelihoods of the fisherfolk. The baseline study is still ongoing, with work still pending to ensure that the statistics are inclusive of fisherfolk who are unassociated with any of the three local fisherfolk associations. The Project has prepared a Participatory Artisanal Fishing Monitoring Plan to ensure that any changes in the artisanal fishery relative to the baseline conditions are detected and addressed.  

Since the Project’s marine footprint does not significantly overlap with artisanal fishing grounds, any adverse impacts to fisherfolk livelihoods are expected to be temporary. Nevertheless, prior to the initiation of any construction activities, the Project will carry out an objective, science-based evaluation of all the Project’s potential risks and impacts to predict and quantify any such potential impacts ex ante (ESAP item).  

The Project has already signed MOUs with the three local fisherfolk associations in November 2018, committing to a series of mitigation and compensation measures, including the following: providing training and other technical support to improve artisanal fishing productivity, or developing activities that could generate alternative income for local fisherfolk. Such activities could include fish farming or the provision of ecotourism or maritime transportation services. The MOUs are grounded in alliances between the Project and strategic partners, including marine research academic institutions, governmental institutions that regulate fishing activities, the chamber of commerce, and tourism agencies. 

The Project will evaluate the potential impacts from changes to the local banana transport systems (ESAP item), which could include loss of jobs and livelihoods for unionized and non-unionized workers. The evaluation will identify and characterize the existing workforce, and determine the potential for impacts on these workers, including consideration of sub-groups (e.g. temporary; unskilled, without contracts, etc.). Once impacts have been identified, measures to address these impacts will be developed and implemented in discussion with affected people. 

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource  


The Gulf of Urabá is an ecosystem of great environmental value, constituting one of the most important estuaries of the Colombian Caribbean. It is heavily influenced by the Atrato River Delta on the western shore, which forms a complex, ecologically important ecosystem composed of mangroves, wetlands, rocky coastline and sandy beaches.  

Potential impacts on terrestrial and marine biodiversity were considered in the Project ESIA. In addition, a Critical Habitat Assessment (CHA) (draft September 2019), additional field surveys and a Residual Biodiversity Impact Assessment (draft December 2019) were completed in 2019. According to the ESIA and Residual Biodiversity Impact Assessment, the main sources of impacts to biodiversity during Project construction include: site clearing and preparation; construction of infrastructure; pile driving (995 piles for the offshore trestle and the viaduct); dredging a volume of approximately 2,000,000 cubic meters of bottom sediments; and disposal of dredge spoils at an offshore disposal site approximately four to six kilometers from the dredging site. The ESIA defines the main sources of impacts during Project operation as follows: truck traffic on the viaduct; operation of cargo ships and tugs (during navigation, approach and anchoring); loading and unloading of cargo; operation of onshore cargo vehicle traffic; and maintenance dredging.  

As indicated under PS1, a Project Area of Influence has been defined in line with the requirements of PS1. For the purposes of the CHA, an Ecological Area of Analysis (EAA) with a 15 km radius centered on the proposed location of the offshore platform was established based largely on the biogeography of the Gulf. The EAA includes both the terrestrial and marine environment given the presence of IUCN Red Listed Critically Endangered (CR) and Endangered (EN) species in the Gulf of Urabá. The CHA identified two sensitive habitats within the EAA: Choco-Darién Tropical Moist Broadleaf Forest and coastal mangroves. The EAA includes remnant habitat that historically has belonged to the forests of the Choco-Darién, which are notable for high species diversity and endemism; however, in the Project area, this habitat has been heavily modified by banana plantation activities. The EAA contains coastal mangroves, which are considered a priority conservation site in Colombia.   

Protection and Conservation of Biodiversity:  

The onshore platform (38 ha) is located on degraded pasture area considered Modified Habitat. Regarding the viaduct corridor, the alternatives analysis for its alignment was reviewed by Autoridad Nacional de Licencias Ambientales (ANLA) and Regional Autonomous Corporation of Urabá Antioquia (CORPOURABÁ), and the selected alternative was approved as part of the Environmental License. The Project chose the alignment that maximizes the portion located in degraded habitats and minimizes the portion that passes through coastal mangroves and adjacent Natural Habitat. The corridor will affect 0.98 ha of land, of which approximately 0.25 ha is considered Natural Habitat (mangroves and riparian forest). The chosen alignment crosses what was formerly the extreme eastern edge of a protected area known as Parque Natural Regional de los Humedales de los Ríos León y Suriquí; however, this area was removed from the Reserva Forestal Protectora de los Humedales entre el Río Leon y Suriquí based on extensive compensation (restoration of degraded areas) in the reserve via agreement (CORPOURABA Res. No. 100-02-02-01-0004-2011) in March 2011. No other protected areas are intersected by the Project or its Associated Facilities.  

To determine the alignment of the access road, the Project worked in consultation with the national and regional regulatory agencies, ANLA and the CORPOURABÁ. As required by Colombian licensing procedures, the Project ultimately chose the option that minimized impacts to Natural Habitat. Based on the current alignment, the access road will affect approximately 96 ha of Modified Habitat and 9 ha of Natural Habitat. 

The immediate estuarine portion where the offshore platform is planned could also be considered Modified Habitat. This area receives 500-700 ocean going freighters per year and has been subject since the 1970s to year-round maintenance dredging in the river Leon to facilitate barging of containers to the existing offshore transshipment area. The configuration of the offshore platform was modified to reduce impacts to biodiversity. The modifications included: (i) construction phases were reduced from two to one, reducing the duration over which the local environment will be exposed to construction-related impacts; (ii) the footprint of the offshore terminal was reduced from 12.8 hectares to 5.2 hectares; (iii) the number of steel piles to be driven for the offshore platform was reduced from 3,100 to 995, significantly reducing underwater noise generation; (iv) the offshore area to be dredged was reduced by approximately 35 percent; and (v) the volume of marine sediments to be dredged was reduced by approximately 25 percent.  

As part of the ESIA process, the Project conducted field surveys to census the species within the Project’s area of influence for terrestrial, marine and riverine ecosystems. The ESIA report presents the IUCN Red List status of each species detected, as well as the status of each of these species on national lists of threatened species (Resolution 192/2014 and Colombian Red List). The surveys recorded the presence of 131 species. Subsequently, a CHA (draft November 2019) was undertaken, which initially identified 42 species of conservation significance that had the potential to trigger a Critical Habitat designation for some of the habitats within the Project area. Additional field surveys were then undertaken to collect more information on potential Critical Habitat qualifying species, which confirmed that the EAA is considered Critical Habitat for 8 species. Additionally, a further 10 Critical Habitat qualifying species were identified as possibly being in the EAA. The following is a summary of the most significant findings:  

Amphibians: One threatened species was confirmed within the EAA: Pipa myersi (Myer’s Surinam Toad), which is Endangered on the IUCN Red List. Residual impact on this species was identified to be negligible. 

Aquatic Reptiles. Trachemys medemi (Atrato Slider / Hicotea), was not confirmed at the species level, but may be present in the area, and while not listed on the IUCN Red List, Trachemys medemi is a restricted range species that has a distribution and habitat that overlaps with the EAA. Other species not confirmed but likely found in the EAA include: Crocodylus acutus (American Crocodile) (IUNC Vulnerable; considered Endangered in Colombia); Eretmochelys imbricata (Hawksbill Turtle) (IUCN Critically Endangered); and Chelonia mydas (Green Turtle) (IUCN Endangered); however, not turtle nesting sites were identified within the EAA. The study found that residual impacts of the Project on these species are negligible, with the exception impulsive sound from pile-driving, which could have a minor, temporary impact. 

Crustaceans: Potamocarcinus pinzoni is a range-restricted crab species (IUCN Data Deficient) found in the EAA. Residual impacts on this species are likely to be negligible.  

Birds. Lepidopyga lilliae (Sapphire bellied hummingbird) (IUCN Critically Endangered) and Nycstactes moanamae (Sooty capped puffbird) (IUCN Near Threatened) were both confirmed to be in the Project area; however residual impacts on these two species related to displacement due to land clearance are likely to be minor. 

Terrestrial mammals. Saguinus oedipus (Cotton-headed Tamarin) and Ateles fusciceps rufiventris (Colombian Spider Monkey) are listed as Critically Endangered according to the IUCN Red List and the Colombian Red List and were both confirmed to be present within the EAA.  

River and marine species. Caribbean Manatee (Trichecus manatus ssp manatus—Endangered on both the IUCN and Colombian Red List was identified in the EAA. Additionally, 3 fish species of conservation significance were identified in the EAA (Megalops atlanticus (Atlantic Tarpon); Epinephelus itajara (Goliath Grouper); Sphyrna lewini (Scalloped Hammerhead Shark)); however, not at thresholds required for Critical Habitat designation.  

Several other threatened species known to inhabit the Gulf were not detected as part of the EIA, CHA or Residual Biodiversity Impact Assessment process, including the following: Neotropical Otter (Lontra longicaudis—Vulnerable on the Colombian Red List) and Guiana dolphin (Sotalia guianensis – Near Threatened on the IUCN Red List and Vulnerable on the Colombian Red List). 

The Project has developed a preliminary Invasive Alien Species Management Plan which will be revised to ensure that it aligns with the International Convention for the Control and Management of Ship’s Ballast Water and Sediments. The Project’s Biodiversity Monitoring Plan will also include procedures for early detection of invasive alien species.  

The Project intends to adhere to international conventions applicable in Colombia regarding ballast water management by providing support to the Colombian Maritime Authority (DIMAR). DIMAR already has a presence in the Port of Turbo, approximately 15 km to the north of the Project’s proposed offshore facility, where it implements the ballast water management program for the 700 ships that call there each year. 

The Project has developed a Biodiversity Loss Compensation Plan to address impacts to the protected area mentioned above and to other natural habitats expected to be impacted by the Project. Implementation of the plan will begin once Project construction is initiated. The entire compensation process (site selection, planting, and monitoring of success) will be carried out under the supervision of ANLA and CORPOURABÁ. It is estimated that the implementation of the compensation plan will take approximately 5 years following a detailed schedule. The area to be restored will total 255.4 hectares, in compliance with national regulations requiring compensation factors of between 5:1 and 10:1 depending on the habitat type.  

The Project will incorporate the Biodiversity Loss Compensation Plan into a PS6-compliant Biodiversity Action Plan to address, according to the mitigation hierarchy, the potential impacts identified via the Residual Biodiversity Impact Assessment (ESAP item). The Project will also update its Dredging Monitoring and Management Plan, as described in the ESAP, to ensure full alignment with relevant international standards and the protection of the surrounding ecosystems. 

The Project is developing a Monitoring Plan for Biodiversity Conservation and Sustainable Management of Natural Resources which will be fully aligned with PS6 (ESAP item).  

Management of Ecosystem Services: 

The EIA process assessed Project impacts on ecosystem services, as well as the dependencies of both the communities and the Project on these services. The assessment included semi-structured interviews with stakeholders in local communities. The most important ecosystem services identified related to those provided by the Gulf’s fisheries to the region’s fisherfolk. The Artisanal Fisheries Baseline and Impact Assessment and the Participatory Fisherfolk Monitoring Program, both described previously in this review, have been conceived to mitigate any potential impacts to these services.  

PS7: Indigenous Peoples:  


Two Afro-descendant ethnic minority groups, both officially recognized by the Colombian Government, are potentially affected by the Project: the Consejo Comunitario de Puerto Girón (Puerto Girón); and, the Consejo Comunitario Mayor de Comunidades Negras de Nueva Colonia (COMANUCO). Neither of these two groups has yet been assigned a collective territory under Colombian Law. Nevertheless, to different degrees, both have a collective attachment to their respective territories, make traditional use of natural resources, and have social, or political institutions different from those of mainstream society.  

The Project area is characterized by a lack of formalized property rights and unassigned collective lands. The area has a history of forced displacements and dispossession of land rights. Port-induced economic development in the area has the potential to exacerbate these conditions. The result could be increased risks to the traditional cultural practices of afro-descendent communities, to their access to natural resources, and to their collective land rights. Worker influx and Project-related traffic also present Puerto Girón and COMANUCO with potential risks related to community health and safety and to their traditions and living standards. Temporary Project-related disruptions of artisanal fishing routes may potentially impact the livelihoods of fisherfolk from these communities.  

Benefits of the Project to these communities include local employment opportunities, Project investments in local development, and the Project’s benefit-sharing program during port operations (the Project has committed to dedicate a percentage of its revenues to local development projects). Puerto Girón also is expected to benefit from a significant reduction in barges passing by the community along the León River. 

Circumstances requiring Free, Prior, and Informed Consent:  

The Project has duly obtained certifications from the Ministry of the Interior, Directorate of Previous Consultation, whereby the Directorate determined that, given the characteristics of the project, no direct affectation to the rights of the community of Puerto Girón was identified, and therefore, it is not mandatory to conduct the prior consultation (Consulta Previa in Spanish) protocol with said community. Furthermore, in February 2019 the Project received an official correspondence from the Ministry of Interior expressing the Ministry’s conclusion that, “in the area of the Project there is no evidence of the presence of ethnic communities (Indigenous Communities, Rom and Minorities, Black Communities, Afro-descendents, Palenqueras, or Raizales) and therefore, for the execution of the said Project, it is not appropriate to advance a process of prior consent.”  

Nevertheless, the Project has, on its own accord, obtained and maintained the Free, Prior and Informed Consent of both Puerto Girón and COMANUCO. The IESC confirmed that the Project has shared pertinent information in a free and prior manner and reached agreement with the communities pursuant to a mutually accepted process. The IESC also confirmed strong support for the Project from both COMANUCO and Puerto Girón. During the field visit in March 2019, the IDB Invest Project Team met with representatives from the two communities and received confirmation of Free, Prior and Informed Consent (FPIC) from community leaders. The leaders confirmed that the Project has carried out good faith negotiations with regard to Project employment and social investment programs to support community development initiatives. They declared that they know the details of the Project and understand the Project’s impacts. MIGA will meet with community representatives during the site visit planned in January 2020 to verify and confirm ongoing consent for the Project.  Written evidence of FPIC will also be reviewed, including community meeting records as well as the MoUs signed with the Comité Técnico Territorial de Nueva Colonia (of which COMANUCO is member) and Puerto Girón.  

The Project’s FPIC process encompassed the following elements: 

  1. A prior-to-the-Project information and engagement process formally started in 2018 with the two communities.  

  1. A mutually accepted process adapted to the communities’ language needs and decision-making procedures, which consisted of a free information exchange and consultations on Project-related matters. The outcomes of these exchanges and consultations were reflected in formal agreements, to be jointly followed up on by the Project and the respective Consejos Comunitarios, with a special focus on actions and programs agreed to in the signed MoUs. 

  1. Signed MoUs (2018) and agreements aimed at supporting training programs and defining a road map to support and protect traditional cultural practices, ongoing ethno-education initiatives and collective rights.  

  1. Written statements of support for the Project and mutual willingness to engage, contained in MoUs and verbally conveyed to IDB Invest’s E&S consultant and members of the Project Team in field visits carried out in 2018-2019.  

  1. Oral confirmation from representatives of both communities that they were not coerced or intimated into supporting the Project.  

The Project has committed to informing the communities regarding the mitigation measures the Project develops as it completes its ESMS. Once the communities are duly informed, and before initiating any construction activities, the Project will ensure that it still has the communities’ consent. 

Mitigation and Development Benefits: 

The Project has engaged COMANUCO and Puerto Girón in impact assessment exercises and has reached agreements recorded in MoUs (one with Puerto Girón and the other with the Comité Técnico Territorial y Comunitario de Nueva Colonia). The MoUs signed with the communities, as well as those signed with fisherfolk associations, include the extension of specific Project benefits such as training, temporary employment and capacity building. The MoUs also include agreements to improve the efficiency of artisanal fishing and to contribute to other income-generating activities. Taken together, these agreements constitute a strategy to mitigate Project-related adverse economic impacts on the communities. Project documentation and interviews conducted with community leaders confirm that the MoUs contain community development strategies that respond to genuine aspirations of the communities.  

The Project will prepare an Indigenous People’s Development Plan and a Monitoring Plan for COMANUCO and Puerto Girón, with a focus on the protection of traditional cultures and collective territories (ESAP item).  

PS8:  Cultural Heritage  

Protection of Cultural Heritage in Project Design and Execution: 

Cultural heritage issues were adequately addressed during the ESIA process and the subsequent update. With the assistance of authorized, qualified and officially registered archaeologists, and in close consultation with the Instituto Colombiano de Antropología e Historia (ICANH), the Project undertook Archaeological Prospective Studies, including terrestrial and subaquatic archaeological surveys.  

The terrestrial survey (2015) reports no evidence of pre-Hispanic occupation or critical cultural sites in the onshore area. The subaquatic survey areas included the designated port dredging area and the planned dredging spoils deposit. The survey was conducted using standard and reliable remote sensing technologies (side scan sonar, magnetometer and echo sounder). Whenever possible, visual inspections were also undertaken. The surveys did not reveal any cultural heritage resources.  

Consistent with Colombian legislation on Cultural Heritage, the Project prepared a Cultural Heritage Management Plan (CHMP) aligned with PS8 requirements. The Project’s Archaeological Management Proposal (FICHA 7) of its Environmental License includes a Preventive Archaeological Program based on procedures in the event of archaeological finds during the construction phase. The ESIA states that construction activities are to be suspended if cultural remains are found and requires involvement of the corresponding local and national authorities. In addition, ICANH recommends supplemental archaeological monitoring of dredging works.  

The Project’s CHMP includes the participation of a cultural heritage specialist with stop-work authority, to monitor construction activities, make an initial determination, coordinate with ICANH, and undertake initial rescue efforts for all sites and construction activities requiring soil removal. If cultural heritage resources are found, the contractor must stop activities, inform the Project and jointly engage in an Action Plan before resuming dredging and or construction activities. 

The documentation listed below is available electronically as PDF attachments to this ESRS at   

The above documentation is also available at the following locations: 

Rubén Burgos, Environmental and Social Director (

Carrera 7 N.° 71-52 Torre B, Piso 6 

Bogotá D.C.  Colombia 

Andrés Felipe Bustos, Project Manager (

Calle 104 #101-15, Piso 8, Edificio Cámara de Comercio 

Apartadó, Colombia 


MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities. 


In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA. 


Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm. 


Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below: 


Compliance Advisor/Ombudsman 
International Finance Corporation 
2121 Pennsylvania Avenue NW 
Room F11K-232 
Washington, DC 20433 USA 
Tel: 1 202 458 1973 
Fax: 1 202 522 7400