The signatories of the Second Request believe that it is probable that they will suffer damages as a consequence of the deficiencies or omissions of the World Bank in the proposed Project providing for the transformation of Road No. 19 into a Highway connecting the city of Santa Fe (Province of Santa Fe) with the city of San Francisco (Province of Cordoba) in the Republic of Argentina. The alleged damages include excessive expropriation of lands; reduced productivity; discrimination; and economic insecurity and psychological damages. According to the Requesters, the Project needs to be analyzed by taking into consideration the social and economic conditions of the area between the cities of Santo Tome and Frontera along National Road No. 19. The Requesters claim that the Project is building on a 40-year old project that provided for the construction of a provincial motorway parallel to the Road No. 19, in order to improve the area’s inter-communication. However, they argue that realities have changed and thus needs have changed too and these factors have not been considered in the design and preparation of the proposed Project. The Requesters state that at the time of the original project the area’s production was mainly from dairy farms. However, most of these farms have now disappeared, only few “company-type dairies” remain, while most of the owners are now smallholders. Service stations, diners and stores have emerged at each crossroad, and the only places still fully inhabited are those close to the main roads such as National Road no. 19. They also say that the run off flows have changed and this has created critical situations in various parts of the road. According to the Request, because of this changed environment, the transformation of Road No. 19 and the expropriations needed for this are “not logical”. Under the Project, 1000ha would be expropriated, but 2000 to 3000ha would be affected in reality because all this land would become “useless or restricted in terms of production” as it would be isolated with no access to the highway. In the Requesters’ view, some fields would be divided and this will not support production activities. The Requesters acknowledge that construction of the highway is necessary, and believe that “developing a comprehensive and consistent project that minimizes the damages to the affected people” would “foster a new production pole.” They argue that the project would be “reasonable” if it takes less land than planned, indemnifies land owners for the updated values of the assets expropriated, and takes into consideration that people may lose their means of livelihood. The Requesters believe that in relation to the proposed Project there is “lack of consensus, questionable project [design], deprivation of lands, loss of value of lands, environmental impact, [and] destruction of family-based economic models.” The Requesters state that they have raised their concerns with the World Bank staff and sent them a fax on September 21, 2006. In their Request to the Panel, the Requesters asked the Inspection Panel to recommend to the Board of Executive Directors of the World Bank that an investigation be conducted on the alleged matters. The above claims may constitute non-compliance by the Bank with various provisions of the following operational Policies and Procedures: OP/BP 4.01 Environmental Assessment OP/BP 4.12 Involuntary Resettlement OP/BP 13.05 Project Supervision