AUSA Second Road Safety and Urban Mobility Program
1.Scope of Review
Autopistas Urbanas S.A. (AUSA, or the “Borrower”) is a joint stock company whose main shareholder is the Government of the Autonomous City of Buenos Aires (“ACBA”). AUSA’s mission is to maintain and manage the highways, as well as build works for the government of the ACBA. The investments are intended to continue supporting the Sustainable Transportation Plan of the City of Buenos Aires, which is designed to increase road safety, improve urban transportation (both regular and rail), and promote the general sustainability of the Metropolitan road network. The investment program is based on the successful execution of the first IDB financing of US$130 million granted to the AUSA in 2014. This financing enabled the company to execute its 2013-2015 investment program. The IIC will finance a portion of the AUSA program for the 2016-2019 period. This investment includes the construction of a new bridge to connect the capital city of Buenos Aires with the city of Lanús in the province of Buenos Aires (the Lacarra Bridge), the diversion of a section of the Illia highway where it enters Avenida 9 de Julio (New Illia Highway Viaduct), and other civil works that will be identified by the AUSA over the next two years, including the Nazca and Balbín railway underpasses.
The technical due diligence visit was conducted on July 13-15, 2016. The visit was performed by Ernani Pilla and Ricardo Torres, officials from the IIC Environmental, Social, and Governance Division and by Karin Torres, with the consulting firm ERM. The visit also served to assess environmental, social, and health and safety conditions related to highway operation, verify management records generated on these aspects (e.g. internal documents on procedures, certifications, and construction permits/operating authorizations), and interview those in charge of social, environmental, and safety and health issues. Meetings were held with the AUSA team: Hugo Pagliotti, quality and environment manager; Norberto Picciani , in charge of environmental management and health and safety at the civil construction work fronts; Alejandro Pérez, head of community relations and corporate social responsibility; Matilde Uzal, contracts manager; and Carlos Silva, secretary of urban development of the municipality of Lanús. The evaluation included a visit to the future site of the Lanus-Buenos Aires (Lacarra) bridge, the site of the existing viaduct in Barrio 31/31bis (Illia), the Beiró underpass, which is in progress, the construction work to finish the San Martín underpass, and the conservation status and operation of the Lacroze Avenue and Constituyentes Avenue underpasses.
Environmental and Social Categorization
This is a category B project according to the IIC’s Environmental and Social Sustainability Policy because its potential impacts may be avoided or mitigated by following generally recognized performance standards, guidelines, or design criteria. The Project’s negative impacts during its construction phase include: the generation of noise and vibration; air emissions from dust and particulates; generation of solid waste; social impact due to the removal and relocation of families; temporary blockage of businesses/commercial establishments in Barrio 31/31bis; and risks to the health and safety of workers, passersby, and neighboring communities. The main impacts during the Project’s operational phase have to do with the generation of noise by the new section of the Illia viaduct and the Lacarra Bridge, as well as increased vehicle traffic at the access points and junctions of the Lacarra bridge (mainly on the Lanús size, where a roundabout is planned on Coronel Osorio street, along with a spur connecting directly to Avenida de la Ribera).
In most cases, these impacts and risks are contained, reversible, and localized in specific areas of the works. They can be avoided and/or controlled through the application of the AUSA’s comprehensive management system (CMS), including through the implementation of the involuntary resettlement plan prepared by the Social and Urban Integration Department of the ACBA (SECISYU), in line with the IDB Group’s Involuntary Resettlement Policy.
2. Environmental and Social Context
The Technical Environmental Impact Studies (TEIS) for the Lacarra Bridge and the Illia Viaduct, currently under review by the Environmental Protection Agency of Buenos Aires (APRA) describe the location and situation of the current urban environment, as well as the trends in the areas of influence and a description of the project proposals. These studies indicate that the Project and its physical investments are located in a completely urbanized area, for which reason the land and water of the natural environment should be considered to be located in a ‘brownfield’, fully anthropic context within the ACBA (Lanús municipality). That is, their biological characteristics are such that practically no traces remain of the original biota. Currently, the biological elements present are found mainly in the urban woodlot and green spaces and parks.
For the Lacarra Bridge work, the area of direct influence of the project to be developed would be the southern part of the “Villa Soldati” neighborhood (ACBA) and the southwest portion of the “Villa Jardín” neighborhood, in the Lanús West portion of the province. The town of Lanus Oeste will function as the edge of the project’s operating area during the work stage, and later be part of the new urban setting once the bridge is in use. The project’s impact area features largely open land, where three abandoned buildings are located. They will be turned over for the execution of the works for the bridge. The operating area is located in the space between Avenida Olazábal and a stream (the “Riachuelo”). It will affect the area between Avenida Coronel Osorio and Avenida de la Ribera Sur, connecting both by means of a highway interchange. The municipality of Lanús has one of the highest levels of urbanization in the country. Its urban fabric includes mixed land-use, with shantytowns and illegal settlements and low density residential sectors, as well as both obsolete and modern industries and abandoned buildings.
On the ACBA side, the project development area and its area of influence include the Presidente Julio A. Roca sports center, which features a number of sports fields, buildings, and open land. Resident density in the project area is very low, and it includes a number of projects undertaken for the 2018 Youth Olympic Games. In this urban area, adjoining Avenida Coronel Roca, Avenida 27 de Febrero, Pergamino, and Autopista 7 (Presidente H. J. Cámpora), construction is already taking place on a cargo transfer center for trucks and containers to improve management of heavy transit linked to the city’s port. As mentioned, the two areas of influence for the bridge works have few structures, and none of them involve housing. Thus, removal and relocation of people will not be necessary.
At the same time, the body of water to be crossed by the Lacarra Bridge, known as the Riachuelo, is the most polluted in Argentina and has a long history of negative environmental impacts. These impacts are exacerbated by regular flooding on both banks of the Riachuelo as a result of both natural and man-made causes. The natural causes include precipitation that is intense and concentrated into short periods of time that exceeds absorptive capacity, while on the other hand, the tributaries and the Riachuelo itself encounter flow restrictions emptying into the River Plate due to sporadic strong winds that come off the river, known locally as the sudestada. Human causes include the straightening and channeling/pipelining of the Riachuelo, which increased the speed of its waters and worsened overflows, as well as the increasing occupation of the low areas of the basin, and thus the inevitable loss of permeable soil. For this reason, one of the goals of the bridge’s design is to minimize changes to the runoff of rainwater and water linked to flooding of the Riachuelo.
New Section of Illia Highway-Viaduct. The project area (considering the surface area affected by the construction) is located in the Cristo Obrero sector of Barrio 31bis. It will affect a number of housing structures located at the edge of the railroad tracks. The situation in Barrios 31 and 31bis is different from that of the city’s other settlements and slums. First, they were not included in any settlement or development plan. Second, the land on which they are located has been in dispute since it was settled, and its residents have put up organized resistance to projects to move or eradicate them throughout its history.
The new section of the Illia Highway is being developed in the context of the urbanization master plan that the ACBA government is carrying out for an area of the city in a situation of social vulnerability. The way the section of the Presidente Doctor Arturo Umberto Illia Highway currently connects to Av. 9 de Julio is a physical, social, urban, and sanitary barrier that not only divides the residents of Barrio 31 from the residents of Barrio 31bis, but at the same time presents an obstacle to integrating the two neighborhoods into the ACBA’s urban framework. From an environmental and social point of view, the project will be developed in an urban environment that is completely anthropized; the current highway presents a situation of constant danger for the people who live near and under it due to the high velocities and the closeness of the vehicles traveling along it, as well as the lack of lighting, isolation, poor ventilation, air pollution, noise pollution, and other problems that affect the environment for the residents.
Underpasses. At the time of writing this ESRS, AUSA plans to build two underpasses: Nazca and Balbín. Both projects have their TEIS, prepared in 2013, and the necessary public hearings were held in 2014. Both projects have had their Statements of Environmental Aptitude (DAA)/Environmental Aptitude Certificate (CAA) issued. The works will take place in fully anthropized and built up urban areas. For the Nazca underpass, the area of influence considered in this study is bound by Campana, Tinogasta, Condarco, and Santo Tomé streets and fully located in Villa del Parque, ACBA. The crossing will be at Avenida Nazca, between Marcos Sastre and Pedro Lozano. Regarding the works and their areas of influence, they are located in the Radio Nuevo drainage network. The underpass (under study) is projected to evacuate and channel waters from rainstorms that happen on average once every 10 years in the case of ground-level streets and from rainstorms that happen once every 20 years for trench and tunnel areas. Under these design conditions, it should operate normally according to projections, enabling maintenance and control of the drainage system to be built and to the drains included in the project.
Regarding the Balbín underpass, the project is located in the basin of Medrano Creek, which has been enclosed and straightened. The area of influence of the underpass considered in the TEIS is bound by Avenida Ruiz Huidobro, Calle Rómulo Naón, Avenida Crisólogo Larralde, and Calle Machain. The crossing will be at Avenida Balbín between Av. Pedro Goyeneche and Calle Estomba. Like the Nazca underpass, the Balbín underpass has the same project design for evacuating and channeling waters from rains that take place every 10/20 years. No special areas or protected natural reserves or similar sites have been found in the area of influence of either underpass. Regarding the Zoning Code, both underpass projects are to be built in districts without any special protection regimes.
3. Environmental Risks and Impacts and Proposed Mitigation and Compensation Measures
3.1 Assessment and management of environmental and social risks and impacts
AUSA has a robust comprehensive management system (CMS) the scope of which includes the “administration, operation, and maintenance of the highways concessioned to AUSA by Law 3060 of the ACBA, as well as managing the contracting, technical direction, and execution management of the projects entrusted to it by the ACBA government within the ACBA.” In 2016, the CMS was recertified under ISO-9001 (for the management, operation, and maintenance of highways and their facilities), 14001 (for the administration, operation, and maintenance of concessioned works), and OHSAS 18001 (monitoring of project construction). The AUSA’s commitments under the existing loan, as indicated in the document “AUSA Road Safety and Urban Mobility Program – Loan Proposal,” include having a road safety management system in place and certified under the ISO 39001:2012 standard (see below).
Policy: AUSA has a comprehensive management policy (version 003) that has been approved and signed by its directors and includes senior management commitments on issues of quality, road safety, the environment, security, and occupational health. The policy includes commitments to strengthen links to the external public by improving communication mechanisms for addressing complaints.
Identification of risks and impacts: AUSA identifies hazards and evaluates risks to health and safety through the risk matrix. It also addresses the socioenvironmental impacts of its activities in the framework of the CMS. At the works, the contractors manage risks through use of the Unified Safety and Hygiene Program (PUSH).
Management programs: AUSA management procedures are documented in the CMS. These procedures are used to avoid and/or mitigate potential impacts and risks associated with the construction work and the operation of the facilities. The CMS master list of documents indicates there is a procedure for incident investigation (INS-HYS-001 Version 3). There is also an annual environmental management and health and safety program through which performance targets and indicators are established. In addition, for each work and prior to its execution, approval will be sought of the TEIS, which will include an evaluation of risks and impacts and an environmental and social management plan. The plan is required as a reference for preparation of the environmental and social management plan for execution, which will be prepared by the main contractor of each work, under AUSA’S supervision.
Organizational capacity and competency: The organizational chart of AUSA (June 2015 version) indicates that the quality, occupational safety and health, and environment management team (CSSOMA) reports to the Operational Planning and Oversight Office, which reports to the general director. The construction operations office has its own SSOMA management team. At the works, AUSA assigns a person responsible for technical issues and one responsible for SSOMA; it also hires a supervisory company to oversee the service orders book, which is used to record SSOMA findings that are then forwarded to the contractor. The person in charge of SSOMA who is assigned to the work reports to the works manager, while CSSOMA management has its own staff who conduct visits to the works to verify compliance with CMS requirements. During due diligence, the IIC has observed that the CMS documents do not clearly establish the CSSOMA chain of command for stopping a work due to its condition or for safety reasons.
Emergency Preparedness and Response: AUSA has procedures for identifying and managing possible emergency situations and the contingencies to be applied during operation and maintenance of the facilities. AUSA has also prepared a works contingency plan for managing potential emergency situations that could arise during construction in order to maintain the safety of the works, the health and safety of workers and third parties, and the environmental quality of each project’s area of influence. During due diligence, it was observed that the prevention and emergency plans prepared by AUSA’s contractors differ from each other as far as their structure and content. For example, they do not include gas leaks during demolition work as one of the potential emergency situations; also, not all the plans adequately describe the composition of the fire brigades or the evacuation plans. It is therefore recommended that at a minimum, AUSA reviews the structure and content of each of its contractors’ prevention and emergency plans to ensure they are consistent with the works contingency plan prepared by the AUSA, to eventually update the content of the contingency plan and ensure it includes all potential emergency situations.
Monitoring and Reporting: As part of its CMS, AUSA has an annual monitoring plan with monitoring procedures and an audit program. These plans and procedures establish the performance of inspections and oversight to generate information that is used to prepare compliance reports every six months and measure compliance with AUSA’s performance indicators and those of its contractors. The CSSOMA management team is responsible for leading the development and implementation of CSSOMA policies and procedures, supervising compliance with the CMS, coordinating external audits, and following up on addressing findings. AUSA performs supervision of works and services contractors. The construction operations office, through Works Management, continually monitors compliance with the CMS, while the CSSOMA management conducts unannounced supervision of the works and operating activities.
Stakeholder Engagement: AUSA manages community issues through the community relations office, which reports to operational communications and modernization management team. Consultations with residents are managed continuously at the construction works and through public hearings held for each project (the hearings are called by the regulatory body). At the work fronts, traffic detour plans are prepared with the contractor for each work and with the participation of the affected residents. They receive final approval from the ACBA’s Traffic Office. For the pre-work stage, a baseline report will be prepared by the structural engineer and a notary public to verify and document the structural integrity and conservation status of each taxpaying home that will be affected by the work; each evaluation is documented using a standardized form. These reports are used to plan the works and to manage responses to grievances.
External communications and grievance mechanisms: AUSA has procedures in place to manage external and internal communication and has set up a call center to centralize the complaints of the highways’ users. AUSA has established an IVR system () through which it can manage high call volumes, monitor the calls, and generate quality and performance statistics on the call service. Most of the complaints and claims have to do with the service provided by the tollbooth staff. Response to complaints at the works is traced manually. Each work has a community agent to maintain permanent communication with affected residents and channel complaints and claims. The Office of Anthropology of the Ministry of Urban Development (MDU) prepares the communication plans and conducts mass communication with those affected by the works. AUSA coordinates with the MDU in responding to complaints at the works and managing community relations. Common complaints involve cuts to power and drinking water services and cuts to the community’s communication services by the service provider companies. The community relations office is not assigned a budget to take action to respond to complaints submitted by residents; 80% of the reports it issues are forwarded for consideration of the works management team.
3.2 Labor and Working Conditions
As of May 2016, AUSA had 1028 workers, approximately 60% men and 30% women. It also has contracting companies for the works, with average rotation periods of eight months.
Working conditions and labor relations management
AUSA manages labor relations in compliance with current law.
Occupational Health and Safety: AUSA has a robust system for managing health and safety. Environmental, social, and occupational health and safety management at AUSA’s facilities is conducted through a comprehensive system that is certified under ISO 9.001 (for managing, operating, and maintaining highways and their related facilities) and ISO 14.001 (for managing, operating, and maintaining concessioned works). For monitoring construction works and as part of its comprehensive management system, the AUSA has an OHSAS 18.001-certified system. Through its health, safety, and environment supervisors, AUSA manages risks and impacts by applying operating oversight appropriate for minimizing undesirable consequences as a result of the activities conducted in AUSA facilities and at its works. Regarding road safety, the annual road safety review (June 2016) found that seven of the eight operational safety procedures required of AUSA under the IDB loan remain pending. In the framework of that loan agreement, AUSA committed to obtain the ISO 39001:2012 (road safety management) certification by the end of December 2016. As of the date of this report, AUSA had designed and implemented road safety management procedures to prepare for the ISO 39001:2012 certification auditor’s first visit on October 3 and 4, 2016.
Supply Chain: AUSA has defined the responsibilities of contractors and subcontractors in its Works Health and Safety Manual. Compliance is monitored by AUSA’s supervisors. Through Contract Management, AUSA is implementing a contractor rating system to perform technical evaluations, as well as assessments of economic and financial background and legal aspects of each contractor. All the contractors are evaluated annually. At the conclusion of each work, a tabular rating (audit) is performed to evaluate the contractor’s SSMA performance and its relationship to subcontractors, as well as management of interference with public entities. The results of the contractor ratings are taken into account for possible application of corrective measures, as well as for evaluating bids received for construction works.
3.3 Resource efficiency and pollution prevention
AUSA identifies the environmental aspects and impacts arising from its operation and implements corrective measures aimed at minimizing their impact on the environment. In the context of operating the highways and through implementation of specific procedures, AUSA separates its common waste into recyclable and nonrecyclable. It also has standards for disposal of gravel and sand, scrap, dredging waste, green space maintenance waste, and route indicators (cones). During construction, and following the specifications included in the Works Environmental Management Manual, AUSA has established that contracting companies must rationalize their water use, use energy-saving practices, and separate their waste, including into a category for recycling. In the annual monitoring plan, AUSA looks at consumption, environmental quality results, solid waste and effluent management, contractor management, permits and authorizations, complaint management, and other environmental management issues.
3.4 Community health and safety
The risks and impacts to the community generated by the operation of the highways are identified and managed by AUSA systematically; one of the main impacts is the noise generated by traffic on the highways. During due diligence, AUSA reported it had installed acoustic panels to dampen noise at all the critical points identified by the company on the 25 de Mayo and Perito Moreno highways. At the time of the visit, 40 critical noise emission points had preliminarily been identified.
The risks and impacts to the community neighboring the construction works are managed according to the particularities of each work and its surroundings. The community relations head, in coordination with the MDU, is specifically designated by the AUSA to identify the needs of each resident and communicate them to the work manager. Likewise, for the duration of the work, the community relations team is able to continually distribute information on the project, communicate important events (such as service cuts and traffic detours), and collect grievances and suggestions from residents and/or any third party that may feel affected by the project. Emergency management is done in coordination with the CSSOMA management, which is responsible for activating emergency protocols. AUSA performs emergency containment until the authorities assume leadership and control of the emergency.
3.5 Land acquisition and involuntary resettlement
As described above, and as part of its permanent communication mechanism, AUSA coordinates with the MDU in responding to complaints at the works and managing community relations. For the new Project, AUSA must ensure that the contractor programs for community relations with residents living near the works meet its requirements, especially for cases in which residents have already expressed some opposition to the concept and/or execution of the project (e.g., in the case of the Balbín underpass) or where involuntary resettlement will be necessary (e.g. Barrio 31bis).
For this latter case, ACBA’s SECISYU has developed an involuntary resettlement policy framework for the affected area in the Cristo Obrero sector of Barrio 31bis and committed itself to carrying it out. This will require SECISYU to implement the following lines of action: i) identify the families that are directly affected (relocation) and most vulnerable by sociodemographic surveys conducted on-site so as to provide comprehensive solutions to improve living conditions; ii) once they are identified, conduct a targeted diagnostic for the affected families to measure their vulnerability; iii) conduct meaningful consultations with residents, affected communities, and local authorities in the framework of a community participation strategy that addresses the concerns of residents and provides them with tools for developing their life projects; iv) in cases in which a group must be resettled, guarantee access to durable housing, with its corresponding compensation mechanisms, and provide all the assistance necessary during resettlement and post-resettlement; and v) follow-up individually on the affected families in the framework of the Secretariat’s family assistance program to mitigate adverse impacts.
It should be noted that the new design of the Illia Highway-Viaduct is part of a larger urban renovation program for the Buenos Aires metropolitan area that seeks to integrate the Villa 31/31bis informal settlements into their urban surroundings. The general objective of the program, which will be partially financed by the World Bank, is to promote comprehensive solutions to contribute to improving the quality of life of vulnerable inhabitants of the metropolitan area. Through SECISYU, the ACBA government has drawn up a resettlement policy framework for managing housing risks. It includes precautionary resettlement of households whose homes are located under the existing Illia highway, as well as the resettlement of households that will potentially be affected by works for basic infrastructure, public services, opening streets, or other civil works, such as those affecting the construction of the new viaduct in the Cristo Obrero del Barrio 31bis area.
The resettlement policy framework has three main objectives: mitigation and compensation of the impacts caused by resettlement; (2) improving, or at least maintaining, the current living conditions of the resettled population; and (3) taking advantage of resettlement as an opportunity to contribute to the development of the resettled by helping them share in the benefits of the project causing the resettlement. These three objectives correspond to the core fundamentals of IIC’s resettlement policy (which also includes IFC performance standards). It is important to highlight that the resettlement policy framework serves as a guide for the executive resettlement plan for the Illia Highway-Viaduct, which must be prepared prior to starting the works. In fact, the resettlement policy framework describes the structure and the information needed to prepare an executive resettlement plan that complies with the IIC policy. Although the document does not contain specific information on the project, it will be used as a basis for executing the process itself and be incorporated into the processes and actions of the teams that communicate and stay in constant contact with the families and others impacted by the project, as well as the government bodies involved in the process. IIC specialists will monitor and supervise not only the preparation of the executive plan but also the actions taken to ensure the policies are followed, along with their outcomes. Hence, the resettlement framework policy prepared by SECISYU is a document that meets IIC requirements. It will be monitored throughout the process.
3.6 Cultural heritage
The environmental mitigation programs included in the TEIS for the project works are required to make it a goal to preserve, protect, and safeguard archaeological and paleontological heritage in accordance with National Law 25,743, of June 2003. The obligation to properly manage any chance finds or discoveries of a site or of any other object or paleontological remains during excavations is part of contractors’ environmental management plans.
Based on an examination of AUSA management documentation prepared for the environmental management of the works, there is no evidence that the contractor is required take preventative actions in the event of chance cultural finds during excavation. It is recommended that AUSA include requirements enabling the implementation of such preventative actions.
4. Access to Information on the Project
AUSA has prepared a document (“Environmental Analysis – Road Safety Program of Buenos Aires”) describing the main environmental and social aspects of each Project component—e.g., physical investments and works, regulatory framework, and the strategy for managing the impact of the investments. This document is available to the public through the AUSA’s website: http://www.ausa.com.ar/obras-realizadas/. The resettlement framework document for the Illia viaduct work has also been published on the same internet site.
In addition, considering: i) that Avenida Balbín railway underpass faces some local opposition by residents (even though it has successfully been granted its Environmental Aptitude Certification); and ii) that as part of the process of public consultations involving SECISYU decision makers currently in progress for Villa 31, the families that will be affected in the Cristo Obrero section of Villa 31 may have concerns or questions; the recommendation is for AUSA’s community relations and corporate social responsibility team to implement a communication strategy to inform the locals and affected individuals about the Project as part of a permanent communication mechanism by preparing and implementing a stakeholder engagement plan. Also, for the Balbín underpass, the recommendation is to call a new neighborhood meeting to clarify certain technical and environmental aspects of the work, as well as highlight its benefits and receive and process any grievance or suggestions for improvements that the locals may submit. The IIC finds it highly advisable to extend the consultation process and that the processing of the complaints from locals should be continuous, taking place throughout the execution of both works.
5. Draft Environmental and Social Action Plan
Please press on the link below entitled ESRS_AUSA-II_Final_section5_table.pdf
 The SECISYU, which is under the cabinet head, is the body in charge of executing and coordinating the integration plan for Barrios (also villas, or shantytowns) 31/31bis. The department’s main objective is to launch a comprehensive multi-sectorial strategy that combines infrastructure investments and social components, thereby seeking to improve the quality of life in the Barrio by helping build community and finally completing the neighborhood’s social and urban integration into the rest of the City of Buenos Aires.
 Lacarra Bridge Draft Project and Environmental Impact Study (Consulbaires, 2016).
Household and Population Census (Villas 31 and 31bis): https://www.estadisticaciudad.gob.ar/eyc/?p=39240.
 The border of the area that the project will affect has been defined as 12 meters from the outer edge of the highway. It marks the limit for the buildings. This means that homes will need to be relocated that currently occupy approximately 2,200 m2 of land within the affected area of 4,500 m2. To do so, the actions established in a resettlement program will need to be executed by the SECISYU.
In December 2009, the Housing Committee of the Buenos Aires Legislature issued Dispatch 888/09 approving a bill to urbanize Villas 31 and 31bis in the Retiro area. The bill, which came under development in 2002, was based on research conducted jointly by the School of Architecture of the Universidad de Buenos Aires with the residents of Villas 31 y 31bis to design an urbanization plan that would respect public space and their history of living there.
 Transportation is the greatest generator of noise, and in some places in the city reaches constant levels of 75 to 80dBA. Noise levels that are this intense present a critical situation because they approach levels that can damage the human ear, easily exceeding the 45 dB recommended by international organizations and the limits imposed by ACBA Law 1540.
Social and urban integration of Villa 31 and 31bis of the ACBA. Note on the New Illia Draft Project (SECISYU, 2016)
 i) Environmental impact study of Avenida Nazca underpass. Former General San Martín railways; ii) environmental impact study of Avenida Ricardo Balbín underpass. Former Mitre railways, Mitre branch.
 Resolution 35/98 of the Workplace Risk Superintendence establishes that contractors are required to coordinate a PUSH across the whole work, and it must be communicated to the workplace risk insurer. The PUSH is part of the work’s technical construction file.
 An IVR system consists of an automated answer system that uses prerecorded voice messages to direct users to a series of options they can choose from and enable them to securely interact with the company’s information system.
 Loan Agreement; Schedule 10; AUSA Road Safety Action Plan – Reference 6.