The Requesters state that they are likely to suffer harm as a result of the World Bank’s failures and omissions in the Project. They claim that “although the Project covers an area of the Albanian coastline from Butrint region in the South (Ionian Sea) to the Porto Romano in the North (Adriatic Sea), it nevertheless excludes from its scope and implementation the area covering the northern part of the Bay of Vlora up to the mouth of River Vjosa”, an area which is south of Porto Romano and is the area where the Requesters reside. According to the Requesters, the Project’s integrated coastal management and clean up strategy has artificially divided the Vlora Bay into two regions. They believe that this is “discriminatory, simply unnatural and fundamentally harmful” to their interests. The Requesters argue that the Project creates a “dangerous vacuum” by excluding the northern part of the Vlora Bay from its scope and, as a result, it will significantly harm tourism development in the Bay and its vicinity. According to the Requesters, the Project’s discriminatory approach “opens the way for other potentially detrimental development projects with long standing negative consequences” for the Bay of Vlora and the Albanian Adriatic-Ionian coastline. They also claim that the Project “ignores the on-going decontamination efforts” taking place in the Vlora region, thus leaving the area “to the mercy of oil-storage developers.” The Requesters further believe that works such as water supply and waste management that the Project provides for the municipalities of Saranda and Himara would also be needed in the municipalities of Orikum and Vlora and the communities of Quender and Radhim. The Requesters claim that the “very purpose, goals and importance of the Project are being undermined” by focusing on the southern part of the Albanian coast and excluding the north part of the Vlora Bay, which is, according to the Requesters, “widely accepted” to be the “real gateway to Albania’s tourism and valorization of cultural heritage.” They claim that such exclusion from the Project is harmful for their economic interests. The Requesters state that they have raised their concerns with Bank staff but have received no satisfactory response. They ask that the Project be extended to include the entire area of Vlora Bay up to the mouth of the River Vjosa. They also request that the Panel conduct a full investigation of this matter. The above claims may, inter alia, constitute non-compliance by the Bank with various provisions of the following operational Policies and Procedures: OP/BP 4.01 Environmental Assessment OMS 2.20 Project Appraisal OPN 11.03 Management of Cultural Property in Bank-financed Projects