The complaint states concern that, among other things, there was improper consultation and exclusion of relevant stakeholders during the design and formulation of the project. It expresses concern that stakeholders' rights, such as the requirement of Free, Prior, Informed Consent and certain relevant national laws, were not properly adhered to when formulating the project. The complainant further states that people potentially affected by the project protest and are apathetic to the project, and that the project documentation improperly refers to relevant lands as protected areas when in fact they are not.