The CRMU registered the complaint concerning the Outer Ring Road Project in Nairobi, Kenya, on 07 October, 2015. This is in fact the second complaint about this project. Previously, in 2014, the CRMU had reported on the handling of a petition relating to this project through problem-solving. When the Requestors initially contacted the CRMU, the Director conducted a preliminary review of the complaint and observed that the complainants had not raised the issues with Bank Management, a step that was required under the old IRM Operating Rules and Procedures. Therefore, the CRMU facilitated dialogue between the complainants, the Project Implementation Unit in Kenya and the relevant Bank department to enable an amicable resolution of the issue on the ground. In June 2014, the Requestors and the Project Implementation Unit informed the Director of the CRMU of the resolution of the issues to the satisfaction of the Requestors, with the Requestors included in the list of affected persons to be considered for compensation. The CRMU concluded then that the issues had been successfully resolved. However, on 14 September, 2015, the CRMU received a second complaint about the same project, with the complainants arguing that the Project Implementation Unit had not fulfilled its commitments under the agreement reached as a result of the 2014 dialogue facilitation initiative by the CRMU. In this Request, the open air traders were reported to have been omitted as people affected by projects (PAPs) in both the Outer Ring Road Environment and Social Impact Assessment (ESIA) and the Appraisal Reports when it was well established that they had been carrying out their businesses in the project area for between 7 and 20 years. The complainants claimed that despite being among people adversely affected by the project, they had not been recognized in the report by the Project Implementation Unit, the Kenya Urban Roads Authority (KURA) that had deliberately ignored them and established a non-transparent list of PAPs. With their names excluded from the list of PAPs they would thus not be eligible for compensation, in violation of Bank policies. (IRM Annual Report 2015, '3.3. The Outer Ring Road Project, Kenya', pg 9: https://irm.afdb.org/sites/default/files/documents/ENG%20-%20IRM%20ANNUAL%20REPORT%20-%202015.pdf)