Attachment_J.3_EDUCATION__PIEE_Asia_11-133.pdf

DCN#: Asia 11-133 Approved on 8/12/2011

ENVIRONMENTAL COMPLIANCE FACESHEET &

INITIAL ENVIRONMENTAL EXAMINATION (IEE)

Objective: Objective 3/ Investing in People

Program Areas: 3.2 Education

Program Elements: 3.2.1 Basic Education, 3.2.2 Higher Education

Country/Region: Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, and Uzbekistan

Funding Period: FY2011 – FY2020

Resource Levels/Amount(s): $105,000,000

Statement Prepared by: Lesley Duncan, Regional Education Advisor, Health and Education Office, USAID/CAR

IEE Amendment? Yes No

Environmental Media and/or Human Health Potentially Impacted (check all that apply):

None Air Water Land Biodiversity Human health Other

Environmental Action(s) Recommended (check all that apply):

Categorical Exclusion(s) Initial Environmental Examination:

Negative Determination: no significant adverse effects expected regarding the proposed activities, which are well defined over life of activity. IEE prepared:

With conditions: no special mitigation measures needed; normal good practices will be used. For the possible limited procurement of equipment, including electric and electronic equipment (computers, printers, etc.) as described in Table 2, Section II, the proposed action is that the Implementer should provide evidence that the implementer is required to ensure that equipment, commodities (also see ADS 312) and materials are procured from certified retailers; environmental safety and quality certificates conforming with national and/or international standards are available; equipment and materials are used in an environmentally sound and safe manner, properly disposed of when applicable at the end of their useful life in a manner consistent with best management practices according to USG, European Union or equivalent standards acceptable to USAID.

RFP #72011519R00002 Annex J.3

With conditions (special mitigation measures specified to prevent unintended impact for activities listed in Table 2, Section III of the

IEE).

Summary of Findings:

This IEE reflects the current and new group of Education activities taking place in all five Central Asian countries covered under Objective 3: Investing in People (program elements 3.2.1 Basic Education, and 3.2.2 Higher Education) to be implemented in 2011- 2020. Up until now all on-going programs have been covered by the umbrella SO 4.2 IEE for Crosscutting activities, including the CAR Participant Training Program, Education Program, the Community Action Investment Program, and the Peaceful Communities Initiative (DCN : # 2002-CAR-003 signed by BEO on 9/3/2002). This new IEE fully supersedes the IEE for all education activities and reflects increased budget, more diverse types of activities, and extended Length of Projects.

Table 1 characterizes main types of activities that are proposed under current and any future education projects.

Table 1. Main Types of Education Activities

Objective 3: Investing in People Program Area: 3.2 Education

Program Element

On-going projects under the Program Element.

Types of Activities

3.2.1 Quality Learning Project (QLP)

Creative Associates, 2007-2012 .

Kg, Tk, Tj

The project assists the governments to implement their National Education Strategies, support the implementation of its Education for All Fast Track Initiative Grant (Tajikistan) and participate in the development of a new policies and curriculum.

3.2.1 School Dropout Prevention

Initiative (Creative Associates), 2009-2013, Tj

Activities include development of a baseline of dropout rates, an in-depth assessment to identify youth most vulnerable to dropping out of school and determining the most common reasons for youth dropouts.

3.2.1 Early Reading Enhancement

Project (Implementer TBD), Tj, Kg, Tk

May include creation of better reading materials, teacher training at the pre and in-service levels, parent and community participation activities, frequent assessment, and national policy and structural reform activities.

3.2.2 American University Central Asia

(AUCA), 2009-2012, Kg

AUCA will become a more sustainable institution by improving the learning environment through the creation of new programs for our students and the broader community, faculty development, further diversification and better support of the student body and the creation of more robust assessment mechanisms. AUCA will also upgrade technology systems to make work flow more efficient and responsive to the needs of students, faculty and staff.

3.2.2 Promotion of Information and

Communication Technology in Turkmenistan (PICTT) (Counterpart/IREX), 2009-2012

PICTT aims to increase the quality of higher education in Turkmenistan by improving access to communication tools that promote student and faculty learning while fostering social partnerships and dialogue.

3.2.2 National Scholarship testing

(CEATM), 2003-2012, Kg

Activities include development of independent testing entity to draft, implement and monitor provision of National Scholarship Examinations for university education.

3.2.2 Cross-Border Vocational

Education (CVEB) (University of Central Asia), 2009 –2015, Tj

Our support includes scholarships for Tajik and Afghan scholars, curriculum development, staff capacity building, and vocation and professional training.

Note: Kg - Kyrgyzstan, Tj -Tajikistan, Tk -Turkmenistan

It is anticipated that procurement of electronic equipment including computers, electronic devices (white boards, projectors, etc.) and small scale construction or minor renovation activities that might include painting, and repair of furniture, equipment and buildings (ceilings and walls) will occur in many projects. It could also include subcontracts for professional implementation of larger improvements such as roofing, potable water, heating, installation of latrines, etc.

Table 2 presents results of environmental screening and recommends threshold determinations for main types of activities under all program elements.

Table 2. Environmental Screening of the Objectives 3 Activities

No. Activities Effect on

Natural or Physical Environment

Threshold Decisions and Reg. 216 actions required

I All Program activities that won’t have an effect on the natural or physical environment.

This includes: education, technical assistance, training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.); consultations, participant training, document transfers and information dissemination, analysis, studies, conferences workshops, study tours, curriculum development, working with training programs, developing information networks, etc, No effect

Categorical Exclusion, no actions required

II All activities regarding which no significant adverse effects are expected. No special mitigation measures are needed; activities are implemented with conditions. This includes procurement of electric and electronic equipment, commodities and materials

Insignificant effect

Negative Determination with conditions. The implementer is required to ensure that equipment, commodities (also see ADS 312,) and materials are procured from certified retailers; environmental safety and quality certificates conforming with national and/or international standards are available; equipment and materials are used in an environmentally sound and safe manner, properly disposed of when applicable at the end of their useful life in a manner consistent with best management practices according to USG, European Union or equivalent standards acceptable to USAID.

III Small-scale activities and procurement of services that normally don’t have a significant effect on the environment. Activities are developed with conditions (special mitigation measures specified to prevent unintended impact for activities for example:

As part of school-community partnerships, small scale construction or minor renovation activities might include painting, and repair of furniture, equipment and buildings (ceilings and walls). It could also include subcontracts for professional implementation of larger improvements such as roofing, potable water, heating, installation of latrines.

Large scale improvements are not anticipated within the scope of these projects.

Potential for a significant adverse effect of one or more activities

Negative Determination with conditions; Positive Determination EDD in form of Environmental Review and Assessment Checklist (Annex

1) is required to identify environmental effects, develop Environmental Manual and Mitigation and Monitoring Plans when applicable, confirm /neglect and mitigate a potentially significant adverse effect. If confirmed, a Scoping Statement (SS) and Environmental Assessment (EA) shall be conducted by the implementer prior to start of activities. SOW/Terms of Reference (TOR) for Scoping Statement and EA Report must be reviewed by MEO and approved by Asia BEO.

For references please see Section “ Implementer procedures”

Note: EDD - Environmental Due Diligence Review

a) Recommended Action: Categorical Exclusion (90% of funding) Pursuant to 22 CFR 216.2(c)(2)(i), the originator of the activities has determined that all of Activities consist of types of interventions entirely within the categories listed in paragraph (c)(2), “Categorical Exclusions,” of Section 216.2, “Applicability of Procedures,” of Title 22 CFR Part 216, “AID Environmental Procedures”, and therefore are categorically excluded from any further environmental review requirements. The originator of the proposed action has further determined that the proposed activities are fully within the following classes of actions:

a. Education, technical assistance, or training programs except to the extent such program includes activities directly affecting the environment (such as construction of facilities, etc.) [22 CFR 216.2(c)(2)(i)];

b. Analyses, studies, academic or research workshops and meetings. [22 CFR 216.2(c)(2)(iii)];

c. Document and information transfers. [22 CFR 216.2(c)(2)(v)]; and

d. Studies, projects or programs intended to develop the capability of recipient countries to engage in development planning, except to the extent designed to result in activities directly affecting the environment (such as construction of facilities, etc.) [22 CFR 216.2(c)(2)(xiv)].

b) Recommended Action: Negative Determination with conditions (5% of funding) for.

the possible limited procurement of equipment, including electric and electronic equipment (computers, printers, telephones etc.). No special mitigation measures needed;

normal good practices will be used. The proposed action required is that the Implementer should provide evidence that equipment is procured from certified retailers;

environmental safety and quality certificates conforming with national and/or international standards are available; recipient of the equipment is following all applicable national and international laws to ensure that it’s used in an environmentally sound and safe manner, and properly disposed of (when applicable) at the end of their useful life in a manner consistent with best management practices according to USG, European Union or equivalent standards.

c) Recommended Action: Negative Determination with conditions (5% of funding) for small-scale infrastructure improvements and/or rehabilitation that could have a potential for moderate adverse impact on the natural or physical environment. For each type/class of activities the implementer will develop an Environmental Manual (EM) and Framework Environmental Mitigation and Monitoring Plan (FEMMP) when applicable.

These EM and FEMMP will then be approved by the MEO, in consultation with the Regional Environmental Advisor for Asia (REA/Asia). The EM and FEMMP will be adapted to a specific site before the activity implementation, and incorporated into the project design. The Standard Conditions List in Annex 3 and Table 2 of this IEE may be used as a guide in developing of the EM and FEMMP.

Implementer Procedures:

All program activities will seek to raise environmental awareness, promote regional and national environmentally and socially sustainable development, biodiversity conservation, adaptation to climate change, foster the culture of environmental compliance and governance, in accordance with The UNECE Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters with reference to it:

http://www.unece.org/env/pp/welcome.html

The Implementer will include environment compliance considerations into all aspects of the program implementation and will promote and train local counterparts on environmental requirements and standards across all of the program’s activities. Such proposed activities will be included into annual work plans, and results will be reported in annual reports.

Each activity should be conducted in a manner consistent with good design and implementation practices described in USAID Environmental Guidelines for Small-Scale Activities in Africa, 2nd edition as provided at:

http://www.encapafrica.org/egssaa.htm; IFC Environmental, Health and Safety Guidelines as provided at:

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines, and the World Bank 1999 Pollution Prevention and Abatement Handbook(PPAH) as provided at: http://www-wds.worldbank.org/external/default/main?pagePK=64193027&piPK=64187937&th eSitePK=523679&menuPK=64187510&searchMenuPK=64187283&siteName=W DS&entityID=000094946_99040905052283 and http://www-wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/1999/06/03/000 094946_99040905052283/Rendered/PDF/multi0page; and Standard Conditions for Small-Scale Construction, Small-Scale Road Rehabilitation, Small- Scale Water and Wastewater Activities, and Small-Scale Irrigation Projects attached to this

IEE.

The Implementer will use the Environmental Review and Assessment Checklist (EAL) (Annex 1) and Leopold Matrix (Annex 2) as a main reporting document for each activity having an adverse environmental impact.

Prior to the launch of each activity including small grants, the Implementer will conduct an Environmental Due Diligence (EDD) review as an inherent part of the EAL for each type/class of activities that may have a potential for moderate and high adverse environmental impact (e.g. small-scale construction; small road rehabilitation , rehabilitation of potable and irrigation facilities; etc) to document existing environmental concerns and foreseeable environmental effects resulting from such types of activities. If the EDD results in a finding of potential significant environmental impact, a Scoping Statement (SS) and Environmental Assessment (EA) will be done by the implementer prior to start of activities. Terms of Reference (TOR) for Scoping Statement and EA Report must be reviewed by MEO and approved by Asia BEO.

Based on EDD results and mitigation measures from Environmental Guidelines for Small-scale Activities, IFC EHS Guidelines, World Bank PPAH, etc. as referenced above, implementer will develop Environmental Manual (EM) and Framework Environmental Mitigation and Monitoring Plan (FEMMP) for each type/class of expected activities when applicable. EM will establish criteria for eligibility, selection and screening against potential environmental risk (low, moderate, and high). EM and FEMMP might be done per implementing partner (IP) or the whole program and then adapted as needed for different IPs. These documentation will then be approved by the MEO, in consultation with the Regional Environmental Advisor for Asia (REA/Asia), incorporated in project design and FEMMP will be adapted to a specific site prior to the activity implementation (EMMP).

The implementer will have a qualified, MEO-approved environmental impact professional(s) (EIP) who will assess and recommend environmental actions to be taken by the program and will coordinate implementation of mitigation measures, monitoring, and reporting. EIP will conduct environmental reviews and will identify: 1) activity category in consultation with the MEO); 2) potential environmental impacts (based on EAL, EDD, Leopold Matrix, and his/her technical knowledge of the local, U.S., and international environmental standards, guidelines, requirements, and practices; and 3) mitigation and monitoring measures needed.

Should EIP lack any special technical knowledge to identify any special environmental impact, the Implementer will consult with a specialist in the relevant area.

Host country Environmental, Occupational Health and Safety (OHS) and other relevant laws and regulations, standards, norms and best practices for environmental protection and management will be followed in implementing the activities. Implementer will ensure compliance by its staff, subcontractors, and subgrantees with USAID regulations, policies, procedures and acceptable best practice as well as compliance with applicable international environmental obligations.

For activities categorized as “potential risks”' or “definite risks” of adverse environmental impact, the Implementer will be required to obtain a letter from the local or regional office for environmental protection stating that the office: a) has been contacted by the Implementer concerning the project activities; b) will maintain contact with the project; and c) will be aware of the potential environmental impacts of the project to help ensure that no detrimental impact will result from this project.

For such activities prior to their implementation the Implementer will conduct public consultations and will seek concurrence from the national duly authorized environmental agency on FEMMPs and EMMPs.

Monitoring will be conducted during the project (beginning with baseline conditions) to determine the environmental impact (positive and/or negative) of project activities. The Implementer shall use only qualified staff for overseeing the mitigation and monitoring work. Monitoring shall occur on an as-needed basis. The Implementer will ensure that the environmental procedures are implemented, potential impacts mitigated, and indirect and cumulative effects are considered for each activity. If negative environmental impacts are discovered through regular monitoring and evaluation of project activities, immediate actions will be taken to rectify the situation.

Resource Allocation, Training and Reporting requirements:

The contract with the Implementer will include a requirement to follow all recommendations of this IEE. The Implementer will be responsible for training his staff, grantees, subcontractors, and counterparts on the contract’s environmental requirements and for ensuring their compliance with these requirements.

Implementer shall have sufficient permanent staff with expertise in an environmental field and compliance and resources to implement and report on the expected scope of environmental compliance work.

The Mission will provide for environmental training for the Implementer(s) EIP(s) by the REA/Asia and/or the USAID/CAR Mission Environmental Officer prior to the start of the activity implementation.

The Implementer will have the following documentation and reporting requirements associated with the environmental compliance:

Annual Work Plans will have a section on the planned activities related to environmental compliance.

EM and FEMMP, EALs, EDD reports and EMMPs as described above will be developed by the Implementer and approved by USAID prior to the launch of each activity having an adverse impact on physical and natural environment including small grants.

Progress Reports will have a section on the status of activities related to environmental compliance and results, including project summaries along with environmental impacts, success or failure of mitigation measures being implemented, results of environmental monitoring, and any major modifications/revisions to the project. If the activities implemented do not have any negative impact on the environment, this should be documented as well.

For activities having adverse environmental impact, progress reports should include Environmental Review Reports in form of EALs for each activity and affected site (including site specific EMMPs at the outset of the activity and upon activity completion).

Implementer’s annual report will include an annex containing a table indicating the title, date of award, and category of each grant activity, and status of mitigation measures and monitoring results, when applicable.

Final Report will have a section that will summarize program’s activities related to environmental compliance and will describe results, including information on any positive or negative environmental effects of program activities.

Grant specific Mitigation and Monitoring Reports will be submitted to USAID at the completion of each relevant activity at every affected project site, and not on an annual basis. Reporting will include photographic documentation and site visit reports which fully document that all proposed mitigation procedures were followed throughout implementation of the subject work including quantification of mitigation. All such reports and documentation will be submitted to theAgreement/

Contracting Officer’s Technical Representative (AOTR/COTR) and Mission Environmental Officer (MEO).

Limitations of the IEE This IEE does not cover activities involving:

Assistance for the procurement (including payment in kind, donations, guarantees of credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, clean- up of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides, rodenticides, etc. covered under FIFRA - ‘Federal Insecticide, Fungicide, and Rodenticide Act’. Note that the activities affected cannot go forward until a Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP) is approved by the Bureau Environmental Officer.

Activities involving support to wood processing, agro-processing, industrial enterprises, and regulatory permitting.

Procurement or use of genetically modified organisms (GMOs).

DCA or GDA programs.

Procurement or use of Asbestos Containing Materials (ACM) (i.e. piping, roofing, etc), Polychlorinated Biphenyls (PCB) or other toxic/hazardous materials prohibited by US EPA as provided at: http://www.epa.gov/asbestos and/or under international environmental agreements and conventions, e.g. Stockholm Convention on Persistent Organic Pollutants as provided at: http://chm.pops.int.

Any of these actions would require an amendment to the IEE duly approved by the ANE

BEO.

Revisions Pursuant to 22 CFR 216.3(a)(9), if new information becomes available which indicates that activities to be funded by the Project might be "major" and the Program’s effect "significant", this determination will be reviewed and revised by the originator of the project and submitted to the Asia Bureau Environmental Officer for approval and, if appropriate, an environmental assessment will be prepared.

USAID APPROVAL OF ENVIRONMENTAL ACTION(S) RECOMMENDED:

Clearance:

Acting Mission Director: ____________________ Date: ________

Glenn Anders

USAID Kazakhstan Program Liaison Manager : cleared by e-mail Date: ________ Benjamin Chapman

USAID Kyrgyzstan Country Office Director: Date: ________ Carey Gordon USAID Tajikistan Supervisory Program Officer: Date: ________ Jeffrey Lehrer

USAID Turkmenistan Country Office Director: ________________ Date:________ Andrew Segars

USAID Uzbekistan Country Office Director: Date: ________

John Pennell

Acting HE Director: __________________ Date: ________ Bryn Sakagawa

Regional Environmental Advisor for Asia & OAPA: concurred by e-mail Date: 7/8/2011

Andrei Barannik

Mission Environmental Officer: _____________________ Date: ________ Nina Kavetskaya

Concurrence:

ANE Bureau Environmental Officer ____________________ Date: ________

Robert Macleod

Approved: Disapproved:

INITIAL ENVIRONMENTAL EXAMINATION

Objective: Objective 3/ Investing in People

Country/Region: Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, and Uzbekistan

Title of the Program Area: Education

1. BACKGROUND AND ACTIVITY DESCRIPTION

The following activity descriptions cover current activities to be implemented during FY2011 - FY2020, under the USAID/CAR Objective 3/Investing in People, Program Area: Education.

3.2.1 BASIC EDUCATION

1. Quality Learning Project (QLP) (Creative Associates)

LOP: 10/01/2007-09/30/2012

LOP Budget: $18,000,000 Country: Kyrgyzstan, Turkmenistan and Tajikistan The Quality Learning Program (QLP) is a regional project implemented in Tajikistan, Kyrgyzstan and Turkmenistan aimed to improve access and quality to basic education project through broad application of modern teaching and student assessment methodologies; active participation of teachers in curriculum reforms and education policy development and usage of transparent and efficient school financing and management systems. The project assists the governments to implement their National Education Strategies, support the implementation of its Education for All Fast Track Initiative Grant (Tajikistan) and participate in the development of a new policies and curriculum. Expected short-term results include newly developed in-service and pre service teacher training materials that includes formative assessment methodology, improved school financial management and pedagogical leadership, training of school accountants and Parent Teacher Associations, improved partnerships between schools and district education departments. Long-term results include improved teaching quality, administrative and financial management and system capacity built to maintain the new education financing mechanism that will contribute to the improvement of student learning outcomes.

2. School Dropout Prevention Initiative (Creative Associates)

LOP: 9/1/2009 – 8/3/2013

LOP Budget: $4,000,000 Country: Tajikistan

A three-year pilot project encompassing Tajikistan, India, Cambodia and East Timor, this project aims to increase the AME bureau’s knowledge of dropout prevention programming in the region and to determine best practices and model programs. Activities will include development of a baseline of dropout rates, an in-depth assessment to identify youth most vulnerable to dropping out of school and determining the most common reasons for youth dropouts.

3. Early Reading Enhancement Project (Implementer TBD)

LOP: 10/01/2012-09/30/2018

LOP Budget: $45,000,000 Country: Kyrgyzstan and Tajikistan, possibly Turkmenistan This project, to begin to in 2012, will be built around early grade reading activities in the primary grades and will be designed to improve reading skills in native languages. May include creation of better reading materials, teacher training at the pre and in-service levels, parent and community participation activities, frequent assessment, and national policy and structural reform activities.

3.2.2 HIGHER EDUCATION

1. American University Central Asia (AUCA)

LOP: 09/30/2009-10/01/2012

LOP Budget: $1,000,000 Country: Kyrgyzstan Higher Education funs support AUCA, an international, multi-disciplinary learning community in the American liberal arts tradition. Its 1,300 students are drawn primarily from the five former Soviet Central Asian republics, but include a growing number from the larger region and the world. With USAID support, AUCA will become a more sustainable institution by improving the learning environment through the creation of new programs for our students and the broader community, faculty development, further diversification and better support of the student body and the creation of more robust assessment mechanisms. AUCA will also upgrade technology systems to make work flow more efficient and responsive to the needs of students, faculty and staff.

2. Promotion of Information and Communication Technology in Turkmenistan (PICTT) (Counterpart/IREX)

LOP: 09/30/2009-10/01/2012

LOP Budget: $1,000,000 Country: Turkmenistan PICTT aims to increase the quality of higher education in Turkmenistan by improving access to communication tools that promote student and faculty learning while fostering social partnerships and dialogue. The project, operated by Countepart/IREX works with research institutes, teacher-training colleges, universities, and the relevant officials, departments, ministries, and professional associations responsible for higher education in Turkmenistan.

3. National Scholarship testing (CEATM)

LOP: 1/2003 – 6/30/2012

LOP Budget: $600,000 Country: Kyrgyzstan This project has supported the development of independent testing entity to draft, implement and monitor provision of National Scholarship Examinations for university education.

4. Technical Support for Student Loans (Eurasia Foundation for Central Asia)

LOP: 05/2009-05/2015

LOP Budget: $800,000 Country: Kyrgyzstan This project assists in developing a system that will provide students with low interest student loans to increase access to quality education.

5. Cross-Border Vocational Education (CVEB) (University of Central Asia)

LOP: 10/1/2009 – 9/30/2015

LOP Budget: $1,000,000 Country: Tajikistan USAID provides support to the University of Central Asia Khorog campus School of Professional and Continuing Education in their ongoing efforts to develop professional links across their border with Afghan Badakhshan (GBAO).

Through capacity building initiatives on both sides of the border, UCA is strengthening human resources, developing vocational training programs and fostering economic development. Our support includes scholarships for Tajik and Afghan scholars, curriculum development, staff capacity building, and vocation and professional training.

2. COUNTRY AND ENVIRONMENTAL INFORMATION (BASELINE

INFORMATION)

The five Central Asian Republics together have a combined population of 55 million, a land mass greater than Western Europe and a significant share of the world’s oil and gas reserves. Surrounded by Russia, China, Iran and Afghanistan, they are adjacent to and affected by some of the contemporary world’s most pressing ideological, political and economic struggles. These landlocked nations have a history of flux and conquest, with historically limited access to world markets and ideas. The region’s circumstances and prospects still, long after the breakup of the USSR, appear fluid and uncertain. Other than in the hydrocarbon fuels industry in Kazakhstan, the countries of Central Asia suffer from limited investment and isolation from major world markets. Despite potentially vast energy assets and other resources, the Central Asian countries are generally very poor and there is considerable poverty and income inequality.

The situation for the Education sector in Central Asia has changed dramatically in the last 15 years. The almost universal literacy, high attendance rates, and excellent quality of education that was taken for granted as part of the legacy of Soviet Union has been dismantled. Each country is now facing unique opportunities and challenges to create a new education system that meets their specific needs and reflects each countries individual identity. At the time of the collapse of the Soviet Union the issues facing each country had more similarities than differences; Each country was faced with developing a new curriculum, language policies needed to be addressed, teacher training institutes needed to be developed, and the system of financing education had to be reformulated to reflect the environment.

The current situation in Central Asia is characterized by a divergence in priorities for each of the five Central Asian nations. Kazakhstan leads the region in education reform in part due to the relative openness of the government, and the sizeable resources they have to support the sector. Uzbekistan and Turkmenistan have resisted efforts for outside support and instead rely on their own resources to fund and modernize education. While attendance and literacy rates may continue to be high, the overall quality and relevance of education is at question as the governments isolate their schools and universities to outside collaboration. Kyrgyzstan and Tajikistan are the most in need, with declining educational outputs, decaying infrastructure, poor quality of teaching, outdated curriculum and limited financing as some of the primary challenges. In these two countries there are concerns that the failing education system will continue to drag down other development and strategic challenges for the region.

3. EVALUATION OF PROGRAM ISSUES WITH RESPECT TO

ENVIRONMENTAL IMPACT POTENTIAL

As described in Section 1, Table II, all of the specific activities consisting of technical assistance, training, analysis, policy advice and information sharing, are not anticipated to pose any environmental risks and qualify for a Categorical Exclusion.

Some projects will purchase office equipment, electric and electronic equipment, and commodities (Section II of Table 1) for which no significant adverse effect is anticipated, and therefore Mitigation and Monitoring Plan is not required provided that normal good practices, engineering methods and standard instructions are followed in their procurement, storage, transportation, installation and use. However, these activities are qualified as Negatively Determinated with conditions, because: 1)the implementer is required to ensure that equipment, commodities, and materials are procured from certified retailers; 2) environmental safety and quality certificates conforming with national and/or international standards are available; 3)equipment and materials are used in an environmentally sound and safe manner, properly disposed of when applicable at the end of their useful life in a manner consistent with best management practices according to USG, European Union or equivalent standards. Electronic devices, including audio-visual components (televisions, VCRs, stereo equipment), mobile phones and other hand-held devices, and computer components, contain valuable elements and substances, are suitable for reclamation, including lead, copper, and gold, if treated properly;

however if not treated properly they are a major source of toxins and carcinogens. They also contain a plethora of toxic substances, such as dioxins, PCBs, cadmium, chromium, radioactive isotopes, and mercury. Additionally, the processing required to reclaim the precious substances (including incineration and acid treatments) release, generate and synthesize further toxic by-products.

Activities such as minor renovations or small-scale infrastructure qualify for a Negative Determination with conditions and require screening, monitoring, evaluation, and reporting.

4. RECOMMENDED MITIGATION MEASURES (INCLUDING

MONITORING AND EVALUATION

For the limited procurements of electric and electronic equipment the implementer will include a requirement in the equipment transfer letter that a recipient will use the equipment in an environmentally sound and safe manner and will properly dispose it of at the end of its useful life in a manner consistent with best management practices according to European Union, USA, or equivalent standards. In order to provide information on best management practices to the recipient, the implementer will: 1)approach the vendor, who might be an authorized dealer for an equipment producing company regarding their corporate policies on how to collect & where to dispose/recycle certain products and these should be consistent with the aforementioned standards and directives; 2) if a vendor does not have capacity to collect and dispose the equipment, then the implementer will approach relevant national authorities, (i.e. the Ministry of Environment) to seek their guidance on how this can be accomplished in accordance with the law. The implementer is also required to ascertain where the certified waste recycling/processing companies with capacity to deal with certain types of equipment may be found in the country as well.

For any project that includes renovation or rehabilitation of buildings, activities will need to address environmental safety issues including ensuring the proposed structure(s) meets country requirements and standards, practices such as is the building structurally safe (how was it made?, is it earthquake stable? Is the roof safe and in good repair), does it provide access to heat in the winter, are there any fire hazards, does it provide for proper security, sanitation and waste removal, and the like. Some small scale infrastructure and/or rehabilitation are likely and have the potential for adverse impact on the natural or physical environment. For each of these types of activities the implementer will conduct an Environmental Due Diligence (EDD) review to document existing environmental concerns and foreseeable environmental effects resulting from the activity and develop an Environmental Manual and Framework Mitigation and Monitoring Plan (FEMMP). This FEMMP will then be approved by the MEO, in consultation with the Asia Regional Environmental Advisor (REA), adapted to a specific site before the activity implementation, and incorporated into the project design. The Standard Conditions List in Annex 3 and Table 2 of this IEE may be used as a guide in developing of FEMMP.

Table 1: Illustrative Environmental Effects and Mitigation Measures for Potential Activities Activities Effect on Natural or Illustrative Mitigation Measures

Physical Environment and related links Procurement of computers, office and other equipment

Insignificant adverse effect.

Obsolete computers are a valuable source for secondary raw materials, if treated properly. However if not treated properly they are a major source of toxic and carcinogenic substances, such as dioxins, Polychloninated Byphenils (PCBs), cadmium, chromium, radioactive isotopes, and mercury.

The project will ensure that equipment is used in an environmentally sound and safe manner and properly disposed of at the end of its useful life in a manner consistent with best management practices according to U.S, European Union or equivalent standards acceptable to USAID.

Small-scale Construction Activities (Rehabilitation/re novation of community centers, schools, or the like)

Potential for significant adverse effect of one or more activities.

Improperly conducted small construction activities may result in a wide variety of negative environmental and cultural effects. Site selection, particularly for new construction, is sensitive and may result in loss of places with historical and cultural importance, damage to sources of water, damage to forests, and damage to agricultural lands. Improper site selection may also place buildings – even merely rehabilitated structures – in flood zones or locations at particular risk for landslides.

During construction, noise, dust, and other disruption to normal activities are possible.

Construction waste may also pollute water ways

Sites that are susceptible to negative impacts should be avoided, and alternative sites should be identified.

If that is not possible, there are other possibilities for mitigating the social and environmental damage from small construction activities.

- Develop and implement appropriate human health and worker safety measures during construction.

- Backfill and/or restore borrow areas and quarries before abandonment unless alternative uses for those sites are planned

- Control runoff into borrow pits

- Recover and replant topsoil and plants as practicable.

- Avoid pollution of waterways with stockpiled construction materials.

- Use lead-free paint, primers, varnishes and stains.

- Minimize the use of solvent-based paints, or replace with water-based materials.

See more recommendations in Attachment 3.

and fields or deplete local fauna. Construction materials may be hazardous or sourced through environmental destructive extraction methods.

5. SUMMARY OF FINDINGS.

b) Recommended Action: Negative Determination with conditions (5% of funding) for the possible limited procurement of equipment, including electric and electronic equipment (computers, printers, telephones etc.). No special mitigation measures needed;

normal good practices will be used. The proposed action required is that the Implementer should provide evidence that equipment is procured from certified retailers;

environmental safety and quality certificates conforming with national and/or international standards are available; recipient of the equipment is following all applicable national and international laws to ensure that it’s used in an environmentally sound and safe manner, and properly disposed of (when applicable) at the end of their useful life in a manner consistent with best management practices according to USG, European Union or equivalent standards.

c) Recommended Action: Negative Determination with conditions (5% of funding) for small-scale infrastructure improvements and/or rehabilitation that could have a potential for moderate adverse impact on the natural or physical environment. For each type/class of activities the implementer will develop an Environmental Manual (EM) and Framework Environmental Mitigation and Monitoring Plan (FEMMP) when applicable.

These EM and FEMMP will then be approved by the MEO, in consultation with the Regional Environmental Advisor for Asia (REA/Asia). The EM and FEMMP will be adapted to a specific site before the activity implementation, and incorporated into the project design. The Standard Conditions List in Annex 3 and Table 2 of this IEE may be used as a guide in developing of the EM and FEMMP.

Implementer Procedures:

All program activities will seek to raise environmental awareness, promote regional and national environmentally and socially sustainable development, biodiversity conservation, adaptation to climate change, foster the culture of environmental compliance and governance, in accordance with The UNECE Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters with reference to it:

http://www.unece.org/env/pp/welcome.html

The Implementer will include environment compliance considerations into all aspects of the program implementation and will promote and train local counterparts on environmental requirements and standards across all of the program’s activities. Such proposed activities will be included into annual work plans, and results will be reported in annual reports.

Each activity should be conducted in a manner consistent with good design and implementation practices described in USAID Environmental Guidelines for Small-Scale Activities in Africa, 2nd edition as provided at:

http://www.encapafrica.org/egssaa.htm; IFC Environmental, Health and Safety Guidelines as provided at:

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines, and the World Bank 1999 Pollution Prevention and Abatement Handbook(PPAH) as provided at: http://www-wds.worldbank.org/external/default/main?pagePK=64193027&piPK=64187937&th eSitePK=523679&menuPK=64187510&searchMenuPK=64187283&siteName=W DS&entityID=000094946_99040905052283 and http://www-wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/1999/06/03/000 094946_99040905052283/Rendered/PDF/multi0page; and Standard Conditions for Small-Scale Construction, Small-Scale Road Rehabilitation, Small- Scale Water and Wastewater Activities, and Small-Scale Irrigation Projects attached to this

IEE.

The Implementer will use the Environmental Review and Assessment Checklist (EAL) (Annex 1) and Leopold Matrix (Annex 2) as a main reporting document for each activity having an adverse environmental impact.

Prior to the launch of each activity including small grants, the Implementer will conduct an Environmental Due Diligence (EDD) review as an inherent part of the EAL for each type/class of activities that may have a potential for moderate and high adverse environmental impact (e.g. small-scale construction; small road rehabilitation, rehabilitation of potable and irrigation facilities; etc) to document existing environmental concerns and foreseeable environmental effects resulting from such types of activities. If the EDD results in a finding of potential significant environmental impact, a Scoping Statement (SS) and Environmental Assessment (EA) will be done by the implementer prior to start of activities. Terms of Reference (TOR) for Scoping Statement and EA Report must be reviewed by MEO and approved by Asia BEO.

Based on EDD results and mitigation measures from Environmental Guidelines for Small-scale Activities, IFC EHS Guidelines, World Bank PPAH, etc. as referenced above, implementer will develop Environmental Manual (EM) and Framework Environmental Mitigation and Monitoring Plan (FEMMP) for each type/class of expected activities when applicable. EM will establish criteria for eligibility, selection and screening against potential environmental risk (low, moderate, and high). EM and FEMMP might be done per implementing partner (IP) or the whole program and then adapted as needed for different IPs. This documentation will then be approved by the MEO, in consultation with the Regional Environmental Advisor for Asia (REA/Asia), incorporated in project design and FEMMP will be adapted to a specific site prior to the activity implementation (EMMP).

The implementer will have a qualified, MEO-approved environmental impact professional(s) (EIP) who will assess and recommend environmental actions to be taken by the program and will coordinate implementation of mitigation measures, monitoring, and reporting. EIP will conduct environmental reviews and will identify: 1) activity category in consultation with the MEO); 2) potential environmental impacts (based on EAL, EDD, Leopold Matrix, and his/her technical knowledge of the local, U.S., and international environmental standards, guidelines, requirements, and practices; and 3) mitigation and monitoring measures needed.

Should EIP lack any special technical knowledge to identify any special environmental impact, the Implementer will consult with a specialist in the relevant area.

Host country Environmental, Occupational Health and Safety (OHS) and other relevant laws and regulations, standards, norms and best practices for environmental protection and management will be followed in implementing the activities. Implementer will ensure compliance by its staff, subcontractors, and subgrantees with USAID regulations, policies, procedures and acceptable best practice as well as compliance with applicable international environmental obligations.

For activities categorized as “potential risks”' or “definite risks” of adverse environmental impact, the Implementer will be required to obtain a letter from the local or regional office for environmental protection stating that the office: a) has been contacted by the Implementer concerning the project activities; b) will maintain contact with the project; and c) will be aware of the potential environmental impacts of the project to help ensure that no detrimental impact will result from this project.

For such activities prior to their implementation the Implementer will conduct public consultations and will seek concurrence from the national duly authorized environmental agency on FEMMPs and EMMPs.

Monitoring will be conducted during the project (beginning with baseline conditions) to determine the environmental impact (positive and/or negative) of project activities. The Implementer shall use only qualified staff for overseeing the mitigation and monitoring work. Monitoring shall occur on an as-needed basis. The Implementer will ensure that the environmental procedures are implemented, potential impacts mitigated, and indirect and cumulative effects are considered for each activity. If negative environmental impacts are discovered through regular monitoring and evaluation of project activities, immediate actions will be taken to rectify the situation.

Resource Allocation, Training and Reporting requirements:

The contract with the Implementer will include a requirement to follow all recommendations of this IEE. The Implementer will be responsible for training his staff, grantees, subcontractors, and counterparts on the contract’s environmental requirements and for ensuring their compliance with these requirements.

Implementer shall have sufficient permanent staff with expertise in an environmental field and compliance and resources to implement and report on the expected scope of environmental compliance work.

The Mission will provide for environmental training for the Implementer(s) EIP(s) by the REA/Asia and/or the USAID/CAR Mission Environmental Officer prior to the start of the activity implementation.

The Implementer will have the following documentation and reporting requirements associated with the environmental compliance:

Annual Work Plans will have a section on the planned activities related to environmental compliance.

EM and FEMMP, EALs, EDD reports and EMMPs as described above will be developed by the Implementer and approved by USAID prior to the launch of each activity having an adverse impact on physical and natural environment including small grants.

Progress Reports will have a section on the status of activities related to environmental compliance and results, including project summaries along with environmental impacts, success or failure of mitigation measures being implemented, results of environmental monitoring, and any major modifications/revisions to the project. If the activities implemented do not have any negative impact on the environment, this should be documented as well.

For activities having adverse environmental impact, progress reports should include Environmental Review Reports in form of EALs for each activity and affected site (including site specific EMMPs at the outset of the activity and upon activity completion).

Implementer’s annual report will include an annex containing a table indicating the title, date of award, and category of each grant…